DRC-2025-000296

DRC-2025-000296 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. 711
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL

Douglas J. Hansen
Director

January 28, 2025

Vern C. Rogers, Director, Regulatory Affairs
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111

RE: RECIPROCITY APPROVAL FOR TEMPORARY JOB SITE – WORK EPISODE AWE-6359
NRC 39-35044-01, Amendment 03, RL-25-0019, Service Work

Dear Mr. Rogers:

EnergySolutions, LLC’s request dated January 28, 2025 to work in the State of Utah beginning
January 29, 2025 and ending January 30, 2025 is hereby approved. The approved work location is:

EnergySolutions, LLC
Rail car location 15 miles South of Deseret, UT

All work must be conducted in accordance with Utah’s Radiation Control Rules and the licensee’s current
radioactive materials license. Immediately report deviation from work locations or scheduled work dates
to Alyssa Stringham by email or by phone (see below). Immediately report emergency situations or
accidents to the Division of Waste Management and Radiation Control (Division) at 801-536-0200 during
normal business hours or 801-536-4123 after business hours.

If you have any questions, please contact the Division by email at [e-mail] or call
Alyssa Stringham at 801-536-4002.

Sincerely,

Phil Goble, Radioactive Materials Manager
Division of Waste Management and Radiation Control

PRG/as
Related Details Documents Application Approval
Application Work Episode Name
AWE-6359
Application
RL-25-0019 (/lightning/r/Application__c/a06eq000005l7snAAA/view)
Status
Submitted
Work Location
Deseret, Utah
Work Start Date
1/29/2025, 8:00 AM
Work End Date
1/30/2025, 6:00 PM
Isotope
10 CFR 35.392
Activity Level
1
Work Crew Name
o Dave Cummings – Contractor Project Manager o Dave Cummings –
Contractor Project Manager
Work Crew Phone
[phone] (tel:[phone])
Work Crew Email
[e-mail] (mailto:[e-mail])
Company contact owner
On-Site Client Representative
Thomas Brown
Approval Date
Submission Date/Time
1/28/2025, 2:22 PM
Total Number of Work Days
1.42
Account
Attestation Checkbox
Attestation Date Time
1/28/2025, 2:22 PM
Legacy Data
Inspector Id Updated by
Inspection date Updated on
Inspection result Id REG Id
Delete WE External Id
Deleted date
Created By
Vern Rogers (/lightning/r/User/0053d000002tey5AAA/view), 1/28/2025,
2:16 PM
Last Modified By
Alyssa Stringham (/lightning/r/User/0053d0000013AlrAAE/view),
1/28/2025, 2:48 PM
Application Work EpisodeAWE-6359 New Contact Edit New Opportunity
Application Work EpisodeAWE-6359
Application ContactACN-67025 Follow Edit New Contact New Opportunity
Related Details
Application Contact Name
ACN-67025
Owner
Vern Rogers (/lightning/r/Name/0053d000002tey5AAA/view)
Questions Name
Client Name
Application Contact Type
Member of Management
Contact
Vern Rogers (/lightning/r/Contact/0033d00000BPHl2AAH/view)
Application Report
Application
Application Work Episode
AWE-6359
(/lightning/r/Application_Work_Episode__c/a0leq00000BEgsHAAT/view)
External ID
Med Auth Users Legacy Data
Active 35-690
35-190 35.690 GSR
35-290 35.690 HDR
35-200 35-57
Cardiac Only 35.1000
35-390 Emerging Technologies Comments
35.390(b)(1)(ii)(G)(1)Board Certified
35.390(b)(1)(ii)(G)(2)Certifying Board
35.390(b)(1)(ii)(G)(3)Certificate Subspeciality
35-392 Board Expiration Date
35-394 Board Certification Verification
35-396 Verification Expiration Date
35-490
TR_941
35-491
Med Phys License Legacy Data
Physicist ID Gamma knife
HDR Other
IVB Comments
Sr-90 Ophthalmic Device
Created By
Vern Rogers (/lightning/r/User/0053d000002tey5AAA/view), 1/28/2025,
2:17 PM
Last Modified By
Vern Rogers (/lightning/r/User/0053d000002tey5AAA/view), 1/28/2025,
2:17 PM
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Upcoming & Overdue

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com

January 28, 2025 CD-2025-016

Mr. Doug Hansen, Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880

Subject: Mobile Radioactive Material License #39-35011-01 (RL-25-0019): Work
Episode Notification

Dear Mr. Hansen:
EnergySolutions’ herein notifies the Director of the Division of Waste Management and
Radiation Control of a Work Episode scheduled to commence January 29, 2025 for
activities performed under control of U.S. Nuclear Regulatory Commission (NRC)
Mobile Radioactive Material License #39-35044-01 (RL-25-0019). The Work Episode
will focus on evaluating and potentially repairing railcars MHFX-5941 and MHFX.
These railcars are currently located at mile marker 52 on Utah State Highway 257
(approximately 15 miles south of Deseret, Utah).

On January 17, 2025, Union Pacific notified EnergySolutions that two railcars had
tripped a load-level sensor while en route to EnergySolutions’ Clive Facility for
management of low-level radioactive waste. The railcars were transferred to a sidetrack
and decoupled for further inspection. EnergySolutions and Broken Arrow
(EnergySolutions’ contractor) are mobilizing equipment, instrumentation, and technical
expertise to assess whether the railcars can be restored to railworthy to complete delivery
to the Clive Facility, or if alternative measures must be taken to complete the delivery.

Work Episode will commence at 800am on Wednesday, January 29, 2025, and will
include:
• 0730: Arrive at work site
• 0745: Pre-job Brief and site examination
• 0800: Confirm safe working conditions
o Review applicable Job Hazards Analyses
o Ensure communication operable
o Appy blue flag barriers to side track
o Distribute / ensure PPE in use
o Define and demarcate an exclusion zone
o Define the operations to be conducted in the work area
o Review steps planned for work
o Review radiological safety expectations
Mr. Doug Hansen
CD-2025-016
January 28, 2025
Page 2 of 4

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com

Work Episode (continued):
• 0900: Commence Operations
o Conduct preliminary baseline radiological surveys
 Radiagtion levels of materials within each gondola are < 0.2 mr/hr
 Contamination levels within each gondola are < 1000 dpm/100cm2
beta/gamma and < 20 dpm 100cm2 alpha
o Prepare work area by applying plastic to the ground out of the way and
using the telehandler and lift rig remove the first lid and set it on the
o Drape liner over side with radiological approval. May tuck along edge
inside container
o Place lid on dunnage
o Stage ladders
o Take photos of interior and exterior of railcars
o Take photos periodically during work to document operational changes
o Open one side of liner to facilitate sand delivery to the void spaces inside
the gondola liner to level gondola.
o Stop work if sand does not level cars. Re-lid and reevaluate.
o Exceptions
 If off-centered large debris/ concrete is identified and easily
accessible, evaluate its movement AFTER approval from
radiological protection. Caution to create airborne
 If there are no void space available or little void space, reconvene
and reevaluate.
o As long as there is void space, add sand one scoop at a time until periodic
measurements determine that the car is close to level.
o Determine that the car is close to level by measuring top of rail to bottom
of rail cars.
o If this activity is effective, push the plastic into the rail car and put a lid on
that rail car.
o Seal lid with TLD
o Repeat the same evolution for the second rail car.
o Evaluate accuracy of Uniform Waste Manifest. Change, as needed.
 Gross weight on active manifest will be changed to reflect the new
weight if dunnage is added.
 New manifest will be affixed to railcar and forwarded to Clive and
SONGS
o Confirmation of radiological conditions on final shipping package
Mr. Doug Hansen
CD-2025-016
January 28, 2025
Page 3 of 4

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com

Materials to bring:
o 2 cases of water
o Kesler Handheld unit
o High visible vest, hard hats, required PPE
o Dry decontamination tools, if needed.
o Blue flags (2 total)
o Rope for tag lines.
o Duct tape
o Plastic
o Bungee cords to hold Super Load Wrapper out the way when liner is
opened.
o Tape measure
o 4’ or 6’ level.
o Radiological 7 placards
o Rigging and shackles for lid lift rig
o TLDs
o 490 Komatsu excavator,
o telehandler,
o skid steer
o sixty tons of sand will be available at the site for rebalancing.
o The burrito bags within each gondola are not tied or buckled shut as they
are used to help removal of the material from the gondola.
o Two 10 mil. plastic flaps are used at the top of the waste.

Phone List of Key Individuals
o Michael Chase - Project Manager [phone]
o Dave Squires – Project Director [phone]
o Mark Alverez – rail expert [phone]
o Dave Pitt – rail expert [phone]
o Thomas Brown (TAB) - Radiation Safety Officer [phone]
o Mark White - Assistant Radiation Safety Officer [phone]
o Dale Thorne - Assistant Radiation Safety Officer [phone]
o Dave Cummings – Contractor Project Manager [phone]
o Justin Lee (offsite) – Clive shipping/receiving [phone]
o Jake Gardner (offsite) – tech. services [phone]
o Vern Rogers (offsite) – reg. affairs (801) 557- 9840
o James Christafano (offsite) - rail logistics [phone]

Mr. Doug Hansen
CD-2025-016
January 28, 2025
Page 4 of 4

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com

Given the potential for changes in the scope of work, EnergySolutions may need to revise
or clarify this Work Episode Notification, including adjustments to work locations,
radioactive materials involved, or the specific work activities undertaken.
EnergySolutions will promptly notify the Director of any such changes.

EnergySolutions agrees to comply with all relevant sections of the Utah Radiation
Control Rules as part of this reciprocity request. Should you have any questions or
require further information, please do not hesitate to contact me at 801-649-2000.

Sincerely,

Vern C. Rogers
Director, Regulatory Affairs

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com