DRC-2025-001055

CLIVE SITE
LETTER OF TRANSMITTAL DATE: 3/24/2025 ATTN: LLRW
CC; Treesa Parker Karen Kirkwood RE: Transmittal 2025-020
Description of Documents Transmitted Qty
See attached updates to Rail Facility. CL-RF-PR-001 Rev 2, Railcar Maintenance in Section 29 1
------------------------------------------------------------------------------------------------------------ Please replace your current procedure revisions with the documents within this Transmittal. You are not required to sign any documents to verify receipt of this distribution. However, you should make every effort to ensure that your copy of the License is current. FROM: EnergySolutions
Document Control Clive Facility
CL-RF-PR-001

Railcar Storage &Maintenance in Section 29
Revision 2

Authored By:

David Pitt, Clive Rail Facility Manager

Date
Reviewed By:

Justin Lee, Shipping & Receiving Manager Date
Approved By:
Thomas A. Brown, Radiation Safety Officer (RSO) Date
Approved By:

David F Booth, General Manager of Clive

Date

Non-Proprietary New
Proprietary Title Change
Restricted Information Revision
Safeguards Information Rewrite
Sensitive Security Information Cancellation

David C. Pitt Digitally signed by David C. Pitt
Date: 2025.03.24 11:11:55 -06'00'
Justin Lee Digitally signed by Justin Lee
Date: 2025.03.24 12:00:40 -06'00'
Digitally signed by Thomas Brown
DN: OU=Health Physics, O="EnergySolutions, LLC", CN=Thomas Brown,
E=[e-mail]
Reason: I am approving this documentLocation: Clive
Date: 2025-03-24 13:18:01Foxit PhantomPDF Version: 9.7.5
Thomas Brown
Digitally signed by David F Booth
DN: C=US, O=EnergySolutions, CN=David F Booth, E=[e-mail]
Reason: I am approving this document.
Location: NA
Date: 2025-03-24 13:43:54Foxit PhantomPDF Version: 9.7.5David F Booth
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Table of Contents

1 PURPOSE AND SCOPE ........................................................................................................ 3
1.1 Purpose........................................................................................................................... 3
1.2 Scope............................................................................................................................... 3
2 REFERENCES ....................................................................................................................... 3
3 GENERAL .............................................................................................................................. 4
3.1 Definitions ...................................................................................................................... 4
3.2 Responsibilities .............................................................................................................. 5
3.3 Precautions and Limitations ........................................................................................ 6
3.4 Document Control and Records .................................................................................. 9
4 REQUIREMENTS AND GUIDANCE .................................................................................. 9
5 ATTACHMENTS AND FORMS......................................................................................... 11

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1 PURPOSE AND SCOPE
1.1 Purpose
To provide requirements for empty railcar storage, transloading, maintenance, and
repairs in Section 29.
1.2 Scope
This procedure applies to all operations associated with the storage, transloading,
maintenance and repairs of railcars in Section 29. Personnel affected include
EnergySolutions/MHF Services personnel and contractors/subcontractors
performing any activities within Section 29 at the Clive, Utah facility.
2 REFERENCES
2.1 10 CFR § 20.1001 – 20.2401 Appendix C
2.2 CL-RS-PG-002, EnergySolutions’ Clive Facility Radiation Protection Program
2.3 CL-SE-PR-001, Clive Facility Security Operations Protocol
2.4 CL-CH-PR-251, Container Management and Storage
2.5 CL-SR-PR-041, Incoming Radioactive Waste Shipment Acceptance
2.6 CL-RS-PR-115, Radiological Surveys
2.7 CL-RS-PR-140, Radiation Work Permit
2.8 CL-RS-PR-150, Posting Requirements for Radiological Hazards
2.9 CL-TN-PR-100, Clive Facility Training
2.10 ES-SH-PR-105, Fall Protection
2.11 ES-SH-PR-201, Hot Work
2.12 CL-SH-PR-100, Clive Health and Safety Program
2.13 CL-SR-PR-062, Rail Safety and Operations
2.14 Radioactive Material License UT2300249
2.15 49 CFR 215, Railroad Freight Car Safety Standards
2.16 R614-6-4, Utah Code for Industrial Railroads
2.17 CL-QA-PR-005, Quality Assurance Records
2.18 Environmental Monitoring Plan

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3 GENERAL
3.1 Definitions
3.1.1 Radioactive Material Area (RMA) – An area or room in which licensed
material is stored in an amount exceeding 10 times the quantity of such
material specified in 10 CFR § 20.1001 – 20.2401 Appendix C. An RMA
within Section 29 includes all rail lines on which licensed material is being
stored.
3.1.2 49 CFR 173.403 Contaminated Compliant Survey – Survey and release
criteria for conveyances used for the transport of Class 7 (radioactive
material) exclusive use shipments which are not considered the package
(i.e., intermodal railcars) and are being shipped back with a DOT package
(i.e., DOT Empty, 49 CFR 173.443(c) Compliant).
3.1.3 49 CFR 173.443(c) Compliant – Survey and release criteria for empty
conveyances exclusively used for the transport of Class 7 (radioactive
material).
3.1.4 Controlled Areas – All EnergySolutions property at the Clive Facility that
is outside a restricted area but inside the site boundary and to which
EnergySolutions can limit access for any reason by use of badges, fences,
gates and/or signs.
3.1.5 Conveyance – Any vehicle or large freight container with a capacity of
greater than 106 cubic feet for transport of radioactive material by public
highway or rail.
3.1.6 DOT Empty Release (EP) – Survey and release criteria for conveyances or
containers that have previously contained Class 7 (radioactive material)
that have been emptied of contents as far as practical, and that are
exempted from certain specific transportation related regulatory
requirements as detailed in 49 CFR 173.428.
3.1.7 Radiation Work Permit (RWP) – The primary method (designated in CL-
RS-PR-140) for ensuring all work activities involving radioactive and/or
hazardous materials are conducted safely and in full compliance with state
and federal regulations. The RWP establishes personal protective
equipment (PPE) and monitoring requirements, informs workers of
radiological conditions, specifies engineering controls, and gives specific
instructions for conducting work activities.
3.1.8 Restricted Area Boundary – The area within the EnergySolutions, Clive
Site Controlled Area that requires control of access and occupancy for
radiation protection purposes as defined in the Radiation Safety program.
The Restricted Area boundary is posted “Caution, Radioactive Material”
and is bordered by a six (6) foot high fence as defined by Reference 2.1
and 2.2, except in buildings where a lockable door or other device is
present to prevent unauthorized or inadvertent entry.
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3.1.9 Section 29 – The Tooele County designated area within Township 1
South, Range 11 West, SLBM, north of Section 32 where EnergySolutions
has established a Controlled Area and RMAs with authority to stage
railcars, store empty railcars, move and switch railcars, transload closed
packages from railcars, and perform maintenance on railcars.
3.1.10 Section 32 – The Tooele County designated area within Township 1 South
and Range 11 West, SLBM, in which EnergySolutions has authority to
manage radioactive waste.
3.1.11 Unrestricted Release – Vehicles, containers, facilities, materials,
equipment, or other items released from the Licensee’s control for
unrestricted use which do not exceed limits found in Table 27-A of
Radioactive Material License UT 2300249.
3.1.12 Constant Surveillance and Monitoring – The continuous surveillance by
security or other qualified personnel of opened access gates through the
fenced EnergySolutions Controlled Area of Section 29. This surveillance
ensures unauthorized personnel cannot achieve undetected access to the
RMA(s) within this area.
3.1.13 Personnel – Includes EnergySolutions employees, contractors,
subcontractors, and vendors stationed at the Clive Facility.
3.1.14 Railcar Transfer Area – The tracks on the east side of Section 29 where
incoming railcars containing licensed material are delivered by a railroad
operator (e.g. Union Pacific Railroad) for initial shipment inspections,
acceptance, labeling, and switching may take place prior to storage and/or
processing. These railcars may only remain in this transfer area for up to
10 days. Outgoing railcars may also be stationed in the Railcar Transfer
Area while awaiting offsite transfer.
3.2 Responsibilities
3.2.1 The General Manager of Clive has overall responsibility for the
EnergySolutions Clive Facility.
3.2.2 The Radiation Safety Officer (RSO) has overall responsibility for
radiation safety, contamination control and compliance with state and
federal regulations in accordance with the Clive Radiation Protection
Program (CL-RS-PG-002).
3.2.3 Clive Rail Facility Manager is responsible for:
• Managing the activities within Section 29 pertaining to empty railcar
storage, maintenance and repair;
• Ensuring employees and contractors working in Section 29 are in
compliance with all EnergySolutions Clive Facility procedures and
policies;
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• Ensuring personnel entering a RMA for performing activities
pertaining to empty railcar maintenance and inspections are properly
trained, certified, and qualified for the tasks they are performing;
• Annual reporting required by Radioactive Material License
UT2300249 pertaining to railcars that enter/exit a SSection 29 RMA.
3.2.4 Radiation Safety Technicians (RSTs) are responsible for the radiological
survey of all equipment, containers, and packages prior to the release from
the RA and that all activities are carried out in accordance with all
applicable procedures. They are also responsible for performing
conveyance surveys on rail conveyances, or for visually observing railcars
without a conveyance survey while outside the restricted area.
3.2.5 The Safety and Health Staff are responsible to support the development
and implementation of personnel health and safety training programs and
for assisting employees by providing technical support for work.
3.2.6 Security Staff are responsible for maintaining constant surveillance and
monitoring of all access points in the Controlled Areas whenever receipt,
storage, transloading of licensed material, or maintenance/repairs of
released railcars is being performed. Security staff shall train all visitors to
the Clive Facility regarding authorized visitor access roads.
3.2.7 Facility Personnel (including Maintenance Technicians and Contractors)
are required to:
• Follow all posted, written and oral, radiological control instructions,
permits, and procedures;
• Read, understand, and sign into an appropriate RWP prior to entering a
RMA and to comply with all requirements of the RWP;
• Wear appropriate Personal Protective Equipment (PPE) as designated
in the RWP and/or site policy;
• Obtain proper training to enter and perform work in a RMA when
work is conducted on railcars containing licensed radiological
material;
• Complete Maintenance Reports (CL-RF-PR-001-F1) and Railcar
Inspection Checklists (CL-RF-PR-001-F2) as required.
3.3 Precautions and Limitations
3.3.1 All personnel working in a RMA shall be signed in to a specific RWP for
their task(s) prior to entering the RMA(s). There may be different RWP
tasks for maintenance activities categorized by their associated
radiological risks. This determination is made by the RSO.
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3.3.2 Security personnel are to verify all visitors, including passengers, have
checked in to the security office upon arrival and shall review the site
regulations with visitors ensuring they understand the site traffic plan
which includes the Admin parking lot and authorized visitor access roads
in accordance with CL-SE-PR-001, Clive Facility Security Operations
Protocol and Department Work Instruction.
3.3.3 Transloading shall only be conducted with undamaged closed packages in
an area designated by the RSO in accordance with CL-CH-PR-251,
Container Management and Storage.
3.3.4 Incoming shipment surveying and acceptance shall be in accordance with
CL-SR-PR-041, Incoming Radioactive Waste Shipment Acceptance.
3.3.5 All personnel entering a RMA shall implement ALARA principles. Safe
and efficient work practices shall be adhered to during the performance of
work in a RMA.
3.3.6 Routine radiological surveys of the RMA(s) and transfer area in Section
29 shall be performed in accordance with section 4.1.3.1 of CL-RS-PR-
115, Radiological Surveys.
3.3.7 PPE shall be inspectedfor physical integrity, correct size, and efficiency
for job performance prior to use. Appropriate PPE shall be used for the
specific task being performed (i.e., puncture resistant gloves, welding
mask).
3.3.8 CL-SH-PR-100, Clive Health and Safety Program shall be followed for all
activities conducted at the EnergySolutions Clive Facility which includes:
3.3.8.1 Job Hazard Analysis shall be conducted and documented in
accordance with ES-SH-PR-101, Job Hazard Analysis as
applicable for tasks not already evaluated.
3.3.8.2 All work conducted above four feet shall be performed on a man
lift, platform or other means approved by the Safety and Health
Staff in accordance with ES-SH-PR-105, Fall Protection.
3.3.8.3 All work involving an open flame, burning, welding, grinding, or
any other operation capable of initiating a fire or explosion
requires a Hot Work Permit in accordance with ES-SH-PR-201,
Hot Work.
Note: Appropriate radiological monitoring shall be conducted
during hot work as predesignated by the RSO.

3.3.9 Prior to placing railcars containing licensed radiological material in
storage, surveys shall be completed by a RST in accordance with CL-RS-
PR-115, Radiological Surveys to ensure radiological conditions meet DOT
and license conditions for storage in Section 29.
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3.3.10 A qualified engineer shall be consulted for maintenance that involves
railcar structural components. This correspondence shall be attached to
CL-RF-PR-001-F1, Railcar Maintenance Report when applicable.
3.3.11 All personnel working around railcars shall be familiar with and follow all
requirements regarding rail safety in CL-SR-PR-062, Rail Safety and
Operations.
3.3.12 Personnel conducting railcar maintenance requiring certification from the
Association of American Railroads (AAR) and/or training in accordance
with Federal Railroad Administration (FRA) must have the appropriate
certification/training prior to performing the work. A copy of all
applicable certifications/training shall be kept in accordance with CL-TN-
PR-100, Clive Facility Training.
3.3.13 Maintenance of empty railcars shall occur on the RSO designated tracks
within the posted RMA(s) of Section 29 Controlled Area.
3.3.14 Maintenance on empty railcars shall only be performed after surveys are
completed by an RST in accordance with CL-RS-PR-115, Radiological
Surveys.
3.3.15 When maintenance is required on a location of an empty railcar with
contamination above acceptable limits, the railcar shall be transferred to
the restricted area of Section 32 for decontamination and/or maintenance.
Gondola lids on railcars containing licensed material may only be
removed within Section 32.
3.3.16 Radiological decontamination activities (e.g. cleaning, washing, etc.)shall
not be performed within Section 29.
3.3.17 Unless decontaminated for unrestricted release, empty railcars shall not be
stored in the RMA(s) for longer than two continuous years.
3.3.18 Each RMA shall be posted as a Radioactive Material Area (RMA) in
accordance with CL-RS-PR-150, Posting Requirements for Radiological
Hazards. The posting shall also note that an RWP is required for entry.
Note: Rail Line RMAs in Section 29 are measured from the centerline
of the track to a distance of no less than 10 feet in each direction.
3.3.19 Roads that lead to the designated RMA(s) that can be easily accessed by
visitors shall be posted with a sign deterring entrance. (For example, DO
NOT ENTER, AUTHORIZED PERSONNEL ONLY).
3.3.20 All personnel and items that enter a RMA shall comply with exit
surveying requirements specified in the RWP.
3.3.21 All personnel working within the RMA(s) shall be trained in accordance
with CL-TN-PR-100, Clive Facility Training.
3.3.22 All rail related activities shall comply with the requirements of R614-6-4,
Utah Code for Industrial Railroads.
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3.3.23 Periodic rail inspections shall be performed in accordance with CL-SR-
PR-062, Rail Safety and Operations.
3.3.24 Environmental monitoring of Section 29 including the fenced boundary of
the controlled area, non-fenced interior boundaries of the RMAs,
transloading areas, and maintenance/repair areas, shall be conducted in
accordance with the current Environmental Monitoring Plan.
3.3.25 Railcars stored within a RMA shall not exceed an external dose of 2 mrem
per hour at 30 centimeters.
3.3.26 Railcar shipments of licensed material shall be placed into a RMA within
10 days of arrival.
3.4 Document Control and Records
3.4.1 Completed Railcar Maintenance Reports, (CL-RF-PR-001-F1), and
Railcar Inspection Checklists, (CL-RF-PR-001-F2), shall be transmitted to
Document Control within 60 days of review.
3.4.2 Clive Rail Facility Quarterly Inspections, (CL-RF-PR-001-F3) shall be
attached to a completed Clive Facility Surveillance Form and sent to
Quality Assurance for assignment of a facility surveillance number and
transmitted to Document Control within 60 days of review
3.4.3 These reports shall be kept for three years after the date maintenance was
performed in accordance with CL-QA-PR-005, Quality Assurance
Records.
4 REQUIREMENTS AND GUIDANCE
4.1 Pre-Job Requirements
4.1.1 An informal pre-job briefing shall be conducted before maintenance
activities begin each day.
4.1.2 Personnel needing to enter a RMA shall log into a RWP for the task
applicable to the activity (e.g. inspections, maintenance,) being conducted.
4.1.3 Personnel shall be or shall have been briefed on the applicable Job Hazard
Analysis for the tasks being conducted.
4.2 Railcar Movement
4.2.1 All railcar movements shall be conducted in accordance with CL-SR-PR-
062, Rail Safety and Operations.
4.2.2 Empty railcar(s) containing licensed radiological material requiring
maintenance shall be moved to the designated maintenance area within the
RMA.
4.3 Maintenance of Empty Railcars
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4.3.1 Radiological surveys shall be conducted by qualified RSTs in accordance
with CL-RS-PR-115, Radiological Surveys, of all locations on the railcar
where maintenance is to be performed as applicable.
Note: If it is discovered during maintenance an unsurveyed location
on the railcar requires maintenance, RSTs shall be called to
perform the required surveys BEFORE performing
maintenance on that location.
4.3.1.1 Contamination exceeding 100 dpm/100 cm2 alpha or 1000 dpm
/100 cm2 beta/gamma shall be moved to Section 32 for either
decontamination or performance of the required maintenance.
Note: Contamination meeting 49 CFR 443 limits may not
necessarily be low enough for the maintenance required.
This is determined by the RSO.
4.3.1.2 The RST shall document the radiological survey on CL-RS-PR-
115-F1, Radiological Survey Form. The form shall include the
location on the railcar where maintenance is requested to be
performed.
4.3.2 Blue flagging shall be conducted in accordance with CL-SR-PR-062, Rail
Safety and Operations.
4.3.2.1 Blue flag targets shall be used to indicate personnel working on, in,
or underneath railcars or to block sections of track where rail
movements are undesired.
4.3.2.2 This procedure shall be used anytime personnel are on tracks,
performing maintenance on rail equipment, when unloading or
loading railcars, and when performing any activities on or between
railcars such as radiological surveying, inspections, etc.
4.3.3 Track isolation shall be achieved when active maintenance is being
performed. The track shall be isolated by locking out the switch
preventing rail traffic from accessing the track.
4.3.4 Maintenance shall only be performed on external portions of the railcar
unless the railcar meets Unrestricted Release criteria or is otherwise not
regulated under the RML.
4.3.5 After completion of required maintenance, inspect the railcar to ensure it
meets the inspection requirements for 49 CFR 215 appendix D.
4.4 Documentation
4.4.1 After maintenance has been performed, complete form CL-RF-PR-001-
F1, Railcar Maintenance Report, to document maintenance performed on
the railcar including railcar location, area on the railcar where
maintenance was conducted and outcome. Attach the corresponding
survey(s) to the maintenance report (when applicable).
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4.4.2 Document the post maintenance railcar inspection on form CL-RF-PR-
001-F2, Railcar Inspection Checklist.
4.4.3 Quarterly, inspect the CRF and document this inspection on form CL-RF-
PR-001-F3, Clive Rail Facility Quarterly Inspection.
5 ATTACHMENTS AND FORMS
5.1 CL-RF-PR-001-F1, Railcar Maintenance Report – Example
5.2 CL-RF-PR-001-F2. Railcar Inspection Checklist – Example
5.3 CL-RF-PR-001-F3, Clive Rail Facility Quarterly Inspection – Example

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Attachment 5.1 - CL-RF-PR-001-F1, Railcar Maintenance Report – Example

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Attachment 5.2 - CL-RF-PR-001-F2, Railcar Inspection Checklist– Example

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Attachment 5.3 - CL-RF-PR-001-F3, Clive Rail Facility Quarterly Inspection – Example

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DOCUMENT SUMMARY FORM