DRC-2025-000393

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.

Vern C.
Rogers
Digitally signed by Vern C. Rogers DN: cn=Vern C. Rogers, o=EnergySolutions,
ou=Waste Management Division, email=[e-mail], c=US Date: 2025.01.28 14:15:49 -07'00'

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