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HomeMy WebLinkAboutDRC-2025-001070 CLIVE SITE LETTER OF TRANSMITTAL DATE: 3/20/2025 ATTN: LLRW CC; Treesa Parker Karen Kirkwood RE: Transmittal 2025-018 Description of Documents Transmitted Qty See attached for Update to State-issued Part B Permit; Attachment II-6 Contingency Plan 3/18/2025 1 Attachment II-6-1, Contingency Plan Quick Reference Guide for the Clive Facility 3/18/2025 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 ATTACHMENT II-6-1 Contingency Plan Quick Reference Guide for the Clive Facility (Prepared in accordance with R315-262-262) Attachment II-6-1 shall be evaluated during the review and modification process of Attachment II-6 Contingency Plan and updated, if necessary. March 18, 2025 Table of Contents 1. Types and Names of Hazardous Waste ............................................................... Page 2 2. Estimated Maximum Amount of Hazardous Waste ............................................ Page 3 3. Exposures Requiring Unique or Special Treatment ............................................ Page 2 4. Map of Facility showing Hazardous Waste Areas ............................................... Page 5 Exhibit 1, Hazardous Waste Map 5. Map of Surrounding Properties ............................................................................ Page 6 Exhibit 2, Street Map 6. Water Supply Information ................................................................................... Page 7 Exhibit 3, Water Supply Map 7. On-Site Notification System Information ............................................................ Page 4 8. Emergency Contact Information .................................................................... See Below Emergency Contact Information Site Security (Available 24/7) 801-649-2175 Emergency Coordinators Name Position Office Phone Cell Phone Tom Brown Radiation Safety Officer 801-649-2168 801-739-4592 Brennon Dick Operations Manager 801-649-2158 435-830-7865 Justin Lee Shipping & Receiving / Security Manager 801-649-2190 435-841-7075 Brett Davis Operations 801-649-2123 435-830-4102 Roger Ekins Operations 801-649-2052 435-830-8003 Garrett Dutson Site Facility Engineer 801-649-2156 801-721-1425 Todd Stewart Maintenance & Construction Manager 801-649-2250 435-228-8838 EnergySolutions LLC Issued – November 2, 2022 Revised – March 18, 2025 EnergySolutions Clive Facility Contingency Plan Quick Reference Guide Page 2 1. Types and Names of Hazardous Waste 3. Exposures Requiring Unique or Special Treatment Table 1 describes the types of hazardous waste that may be present at the Clive Facility and includes the hazard associated with each waste type and describes medical treatment necessary for exposures to each hazardous waste type. Exposure to radioactive waste is the only site exposure that requires unique/special treatment. The table also includes the general location of hazardous waste (as described below the table, in Table 2, and on Exhibit 1, Hazardous Waste Map). Table 1. Types of Hazardous Waste, Associated Hazards, and Medical Treatment Hazardous Waste Type Notes Associated Hazards Medical Treatment Site Locations Radioactive Waste Limited to Class A concentrations as defined in Utah Administrative Code (UAC) R313- 15-1009 Internal Chronic Ionization Wash Off Flush Thoroughly Perform a Radiological Scan of the Exposed Area Entire Site* RCRA Solid Hazardous Waste Soils, Sludges, and Debris (incl lead solids) Chronic Wash Off Flush Thoroughly MW Facility, Lab PCB Waste Soils, Sludges, Debris, and Liquids Chronic Fetus Wash Off Flush Thoroughly MW Facility, Lab Flammable Liquids Flash Point < 60 oC (140 oF) Ignitable Wash Off Flush Thoroughly MWOB, MWSB, MWTB, Lab Corrosive Liquids pH ≤ 2 or ≥ 12.5 Corrosive Wash Off Flush Thoroughly MWOB, MWSB, MWTB, Lab Organic Waste High concentration organic solvents Carcinogen Neurotoxin Wash Off Flush Thoroughly MWOB, MWSB, MWTB, Lab Oxidizers Fire Hazard Provides Oxygen Ignitable Sustains Reactions Wash Off Flush Thoroughly MW Facility, Lab * The Entire Site includes all the Restricted Area in Section 32 and the Railyard Area in Section 29. Both areas are fenced and have restricted access. The Entire Site includes Radioactive Waste disposal embankments as well as facilities where waste may be stored. Waste storage locations are described in Table 2 and depicted on Exhibit 1, Hazardous Waste Map. Exhibit 1 also includes emergency access gate locations. Due to the radioactive nature of the site, Restricted Area gates will be monitored by EnergySolutions personnel. Individuals who have entered on foot or exited vehicles while in this area will be scanned for radioactive contamination. EnergySolutions LLC Issued – November 2, 2022 Revised – March 18, 2025 EnergySolutions Clive Facility Contingency Plan Quick Reference Guide Page 3 2. Estimated Maximum Amount of Hazardous Waste Table 2 lists waste storage locations at the Clive facility, beginning in the Northwest corner of Section 32 and proceeding clockwise around the facility as depicted in Exhibit 1, Hazardous Waste Map. Table 2 also provides the estimated maximum amount of waste that may be stored in each of these locations. Maximum volumes do not include waste that has been disposed in embankments. Note that these maximum volumes are theoretical maximums, actual volumes of hazardous waste on-site at any time will be a small fraction of these. Table 2. Locations and Maximum Storage Volumes Location Designation Description General Location within Section 32 Maximum Storage Volume ǂ Rotary Dumper Pit Railcar Rollover Facility, includes pit where Radioactive Waste may be stored Northwest ~ 300 cy (~8,000 cf) Shredder Pad Radioactive Waste Storage Pad east and west of the Large Shredder North Central ~53,000 cy (~1.4 M cf) Chemistry Lab Laboratory inside the Restricted Area within the Operations Building North Central ~ 25 cf Intermodal Unloading Facility (IUF) Outdoor Concrete Bays that may contain Radioactive Waste East Central ~150 cy (~4,000 cf) MW Facility Manages and Stores Waste that is Radioactive and Hazardous Southeast Corner of Section 32 6,000 cy* (162,000 cf) Mixed Waste Operations Building (MWOB) Liquid Hazardous Waste Storage. Some solid wastes. All Waste is Containerized. East Central in MW Facility ~80,000-gal liquid ~11,000 cf solid (~400 cy) Mixed Waste Storage Pads Solid Hazardous Waste Storage with some Liquid Hazardous Waste Storage on secondary pallets All Waste is Containerized. South of MWOB and Between MWTB and MWSB ~8,600-gal liquid 6,000 cy solid (162,000 cf) Mixed Waste Treatment Building (MWTB) Open Tank Storage Areas and Active Treatment (Mixing, Shredding, etc.). Highly Contaminated Area. Southeast in MW Facility ~20,000-gal liquid ~3,000 cf solid (~110 cy) Mixed Waste Storage Building (MWSB) Houses the VTD Organic Treatment Process. High concentration organic Waste. South Central in MW Facility ~3,300-gal liquid ~1,000 cf solid (~37 cy) ǂ Storage Volume unit abbreviations: cy = cubic yards; cf = cubic feet; gal = US gallons (M = million) * Volume includes the Impoundment Pond in the northeast portion of the MW Facility, but not the Mixed Waste Landfill Cell. EnergySolutions LLC Issued – November 2, 2022 Revised – March 18, 2025 EnergySolutions Clive Facility Contingency Plan Quick Reference Guide Page 4 4. Map of Facility Showing Hazardous Waste Areas Exhibit 1, Hazardous Waste Map, points to each of the waste accumulation areas described in Table 2. The map also shows gates that may be used to access the Restricted Area and a general access route highlighted green. Main access is through the Operations Building in the north-central section of Exhibit 1. 5. Map of Surrounding Property Exhibit 2, Street Map, provides direction from Interstate-80 (Exit 49) south to the Clive facility. The areas immediately surrounding the section that radioactive waste is managed are either owned by EnergySolutions or the Bureau of Land Management (BLM). The nearest business is a hazardous waste management facility owned by Clean Harbors located approximately one mile to the west (using the same access road from I-80). There are no residential areas or schools within 50 miles of the facility. The closest residential address is the caretaker at the East Grassy Mountain Rest Area at mile marker 54 on I80 (approximately eight miles from the facility). 6. Water Supply Information By policy, EnergySolutions does not fight fires at the facility. Fire extinguishers are located in all buildings throughout the facility (locations highlighted in Exhibits to the Contingency Plan); however, these are only for fighting incipient fires and to aid in evacuation. There is no firefighting water supply to buildings outside of the Mixed Waste Facility. The firefighting water supply for the Mixed Waste Operations Building (MWOB) and the Mixed Waste Treatment Building (MWTB) is located outside of the restricted area south of the MWTB. The water supply consists of a buried tank (60,000 gallon), a fire pump in a small enclosure, and an emergency generator. Exhibit 3, Water Supply Map, shows the southeast corner of the facility and calls out the fire pump house and the location of fire hydrants for the MWOB and the MWTB. Both hydrants can supply water at a rate of 500 gallons per minute for two hours. 7. Onsite Notification System Information The site has an extensive alarm system to ensure safety of personnel. Evacuation alarms are located on the exterior of the Operations Building, the Administration Building, the Mixed Waste Operations Building, the Mixed Waste Treatment Building, and the Mixed Waste Storage Building. Furthermore, the MWTB, MWOB, and MWSB have local alarms that signal when carbon monoxide (CO) levels are high or if a lower explosive limit (LEL) is reached or if the buildings have oxygen deficient atmospheres. All personnel carry radios and the principle means of communicating emergency situations is an all-hands alert on the emergency channel to which all radios automatically turn to when in use. There are no alarms that ring off site. Procedures and training are in place such that the site security department or the safety department calls applicable off-site local authorities. EnergySolutions LLC Issued – November 2, 2022 Revised – March 18, 2025 EnergySolutions Clive Facility Contingency Plan Quick Reference Guide Page 5 EnergySolutions LLC Issued – November 2, 2022 Revised – March 18, 2025 EnergySolutions Clive Facility Contingency Plan Quick Reference Guide Page 6 EnergySolutions LLC Issued – November 2, 2022 Revised – March 18, 2025 EnergySolutions Clive Facility Contingency Plan Quick Reference Guide Page 7 Attachment II-6 - Contingency Plan - Page 1 ATTACHMENT II-6 CONTINGENCY PLAN March 18, 2025 Emergency Coordinator Revision: May 23, 2023 IN CASE OF EMERGENCY, USE THE INFORMATION ON THESE PAGES: Emergency Telephone Numbers: Page 2 Facility Building Locations: Page 3 Fuel Tank Locations: Page 4 Emergency Response Information: Pages 5-14 Location of Emergency Equipment: Pages 15-42 BASIC EMERGENCY PROCEDURES A. ______ Contain the emergency, if possible. B. ______ Notify and alert others, contact the Primary Emergency Coordinator or alternate in the order listed. Use the list of emergency numbers. C. ______ Evacuate personnel if necessary. Identify the materials involved. Assess the hazards. D. ______ Obtain equipment and resources to respond to emergency. Use the equipment listed on the maps. E. ______ Control the emergency. Prevent its recurrence. Direct the clean-up efforts. F. ______ Report emergency to the appropriate agencies. Use the checklists in the plan. EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 2 FOR ALL NUMBERS, PLEASE DIAL “8” TO OBTAIN AN OUTSIDE LINE EnergySolutions OFFICES: BUSINESS EMERGENCY SALT LAKE CITY OFFICE (801) 649-2000 (801) 649-2000 EnergySolutions SITE OFFICE (801) 649-2175 (801) 649-2175 (SITE ADDRESS: 50 miles east of Wendover, Utah, 72 miles west of Salt Lake City, Utah, and about 5 miles from I-80. DIRECTIONS: From I-80, take Clive Exit 49. From the exit, go south and onto the paved county road and follow the signs to EnergySolutions. EnergySolutions’ Administration Building is about 2 miles east and 1 mile south of the Clive railroad crossing. The Clive railroad crossing is about 3 miles southwest of I-80 Exit 49.) UTAH HIGHWAY PATROL (435) 843-4436 (435) 843-4436 TOOELE COUNTY Health Department (435) 277-2300 (435) 277-2440 24-HOUR DISPATCH FOR: AMBULANCE FIRE (435) 882-5600 SHERIFF UT HIGHWAY PATROL WENDOVER, UTAH (CONTACT TOOELE COUNTY SHERIFF) (435) 882-5600 HOSPITALS MOUNTAIN WEST MEDICAL CENTER (435) 843-3600 (435) 843-3600 (Tooele, Utah) UNIVERSITY OF UTAH HEALTH SCIENCES CENTER (801) 581-2121 (801) 581-2291 (MEDICAL CENTER, Salt Lake City, Utah) AIR TRANSPORT/AIR MED (Call the Air Med Helicopter for life-threatening emergencies only) SALT LAKE CITY AIR MED HELICOPTER (801) 581-2500 (801) 581-2500 UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY: DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL (801) 536 0200 (801) 536 4123 DIVISION OF WATER QUALITY (801) 536-4300 (801) 536-4123 DIVISION OF EMERGENCY RESPONSE AND REMEDIATION (801) 536-4100 (801) 536-4123 U.S. BLM SALT LAKE CITY FIELD OFFICE (801) 977-4300 (801) 977-4300 U.S. EPA REGION VIII (DENVER) (800) 227-8917 (800) 227-8917 U.S. NRC OPERATIONAL CENTER (301) 816-5100 (301) 816-5100 NATIONAL RESPONSE CENTER (800) 424-8802 EnergySolutions EMERGENCY COORDINATORS AND TELEPHONE NUMBERS On-site Security Guards: 801-649-2175. Emergency Coordinator addresses are kept in the Site Security Office. 1. Justin Lee (Primary) 801-649-2190 435-841-7075 2. Brett Davis 801-649-2123 435-830-4102 3. Tom Brown 801-649-2168 801-739-4592 4. Roger Ekins 801-649-2052 435-830-8003 5. Brennon Dick 801-649-2158 435-830-7865 6. Todd Stewart 801-649-2250 435-228-8838 7. Garrett Dutson 801-649-2156 801-721-1425 EMERGENCY TELEPHONE NUMBERS/LIST OF EMERGENCY COORDINATORS EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 3 EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 4 EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 5 CONTINGENCY PLAN 1. Implementing this Contingency Plan. a. This plan shall be implemented immediately in the event of the following contingencies: i. fires ii. explosions iii. releases (Note: a release is defined in Module I, Standard Conditions, Condition I.L.) 2. Contingency Plan Procedure. a. Any employee, contractor, security guard or other worker upon discovery of a fire, explosion, or release at the Facility shall implement this Contingency Plan. b. Following discovery of a fire, explosion or release, the discoverer shall notify an individual on the list of Emergency Coordinators. 3. Access to Corporate Resources a. All employees shall have access to Permittee resources for emergency response. 4. Arrangements with Local Response Organizations a. No formal arrangements have been made with outside emergency response organizations. However, such response agencies may be contacted in the event of an emergency. (Note: See the list of emergency telephone numbers on page 2 of this plan.) 5. List of Emergency Equipment a. Following is a list of onsite emergency equipment and descriptions and a brief outline of their capabilities, or use: EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 6 Equipment/Description Capability/Use Self-Contained Breathing Apparatus- SCBA has a high-pressure tank, a pressure regulator, and an inhalation connection, connected together and mounted in a carrying frame Rescue in hazardous atmosphere Eye Wash Stations Continuous flow/fountain of water Flush debris/foreign material from eyes Emergency Showers Employee showers for personal decontamination Flush clothing/the body of contaminants Fire Extinguishers -ABC style -D style ABC -Personal Escape, hot work, small fires. D- Suited for metal fires involving magnesium, sodium, potassium, uranium, and powder aluminum. First Aid Stations/Kits Contains bandages, over the counter medications, etc. Initial treatment of minor injuries Emergency Lighting Light supplied when the main power is out Activated when main AC power supply is lost Neutralizing Chemicals Soda Ash and/or Clay material Spill clean-up, containment, and initial treatment Over-pack Containers Secure storage of leaking containers Chemical Spill Protective Apparel PPE (i.e. face shields, gloves, goggles, safety glasses, hard hat) Assess/Clean-up laboratory chemical spills Evacuation Alarms Visual and/or Audio signals Warning indicators Fire Suppression System Automatic liquid/or foam systems integrated into the Mixed Waste Operations and Treatment Buildings Mitigates the spread of facility fires that have increased beyond the incipient stage Gas Monitors LEL, O2, CO, and H2S or NO2 Alarms to warn personnel if hazardous conditions exist Air Sample Draw Pumps Portable air sample vacuum pump Monitoring various chemicals at the point of exposure Fall-Arrest Tripod w/ Lifeline Tripods, slings, harnesses, ropes, and miscellaneous attachments Safety precaution for working at heights, and rescue from confined spaces Ambulance w/ EMT Supplies Vehicle retrofitted with lifesaving emergency equipment Life support and transport Automatic External Defibrillators (AEDs) Heart/Cardiac arrest treatment b. Fixed equipment shall be kept at locations identified in Exhibits II-6a-1 through EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 7 II-6w. Mobile equipment (Ambulance, First Aid Kits, Monitors, Draw Pumps, and Rescue Tripod w/Lifeline) may be in use throughout the Clive Site as required. 6. Fuel and Propane Stored Onsite a. Exhibit II-6a provides facility locations of fixed fuel (gasoline and diesel) and propane tanks. The exhibit includes the quantity of tanks per location and the individual tanks capacity. These materials are a flammability hazard concern. 7. Evacuation Plan a. When necessary in an emergency, the Facility shall be evacuated according to the following steps: i. Announcement of Evacuation. Instructions to evacuate shall be given in one of the following ways: A. by activating the alarm in the Mixed Waste Treatment Building, Mixed Waste Operations Building, or Mixed Waste Storage Building B. by oral evacuation instructions (radios and other available internal communication may be used) ii. Evacuation Routes A. Posted at each facility building are detailed evacuation routes that are specific to each building. B. All personnel shall safely proceed to the nearest established Access Control Point and exit as directed. C. Personnel shall evacuate to the MW or LLRW Unloading Docks or other alternate location announced by the Emergency Coordinator, when the Emergency Coordinator deems it is unsafe to evacuate to the established Access Control Point. D. Personnel may exit at any point that is safe to do so when the Access Control Point and the Unloading Docks are inaccessible. E. Off-site evacuation routes include, but are not limited to, the EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 8 perimeter access roads and county roads. F. Personnel exiting the restricted area without decontamination shall restrict their movements to as small an area as possible, declare to the Emergency Coordinator or authorized personnel that they are potentially contaminated and not spread the contamination to other personnel. iii. Post-Evacuation Gathering Points. The primary designated post- evacuation gathering points are at the Operations Building North Parking Lot (building # 7), the Administration Building North Parking Lot (Building #100), between the Maintenance Shop/Warehouse Building (Building #12) and the QC & GW Lab Building (Building #13) Parking Lots, and the Decon Access Control Building East Partking Lot (Building #27). These locations are noted on Exhibit II-6. A secondary point is at the northwest site entrance. The Emergency Coordinator may select an alternative gathering point depending on the nature of the emergency, weather conditions, or other considerations that affect the ability of personnel to gather at the primary or secondary gathering point. iv. Post-Evacuation Roll Call. A. The Emergency Coordinator or designee shall conduct a roll-call activity. Sign-in sheets may be used to facilitate this activity. B. Facility supervisors shall account for those employees under their charge. C. The Emergency Coordinator shall use this information to determine whether there are any personnel which have not yet evacuated. D. The Emergency Coordinator shall direct an effort to account for any missing personnel. v. Ending the Evacuation: After evacuation, personnel will not return to their work in evacuated areas until an "all clear" signal is given by the Emergency Coordinator. EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 9 8. Copies of This Contingency Plan a. The Permittee shall keep a copy of this Contingency Plan near each wired-in facility telephone. This requirement is not applicable for cellular, portable or mobile, or conference room telephones. b. Copies to Response Agencies. The Permittee shall provide a copy of this contingency plan and all revisions to the plan to each of the response agencies identified on the emergency list on page 2 of this plan and to the Division of Environmental Response and Remediation. Copies of this plan need not be provided to the reporting agencies on the list. 9. Duties of Emergency Coordinator a. Whenever there is an imminent or actual emergency situation, the Emergency Coordinator shall immediately ensure the following is done: i. Activate internal facility alarms, or communication systems, where applicable and appropriate, to notify facility personnel; and ii. Notify appropriate response agencies if their help is needed. b. Whenever there is a release, fire, or explosion, the Emergency Coordinator shall immediately identify the character, exact source, amount, and areal extent of any released materials. The Emergency Coordinator may do this by observation or review of facility records or manifests, and, if necessary, by chemical or radiological analysis. c. The Emergency Coordinator shall assess if the release contained PCB/Mixed Waste. If the released material involved PCB/Mixed Waste, decontamination shall occur in accordance with 40 CFR 761, Subpart G. d. Concurrently, the Emergency Coordinator shall assess possible hazards to human health or the environment that may result from the release, fire, or explosion. As part of this assessment, the Emergency Coordinator shall consider both direct and indirect effects of the release, fire, or explosion (e.g., the effects of any toxic, irritating, or asphyxiating gases that are generated, or the effects of any hazardous surface water run-off from water or chemical agents used to control fire and heat-induced explosions). e. If the Emergency Coordinator determines that the Facility has had a release, fire, or explosion which could threaten human health, or the environment, outside EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 10 the Facility, the Emergency Coordinator shall report those findings as follows: i. If the Emergency Coordinator’s assessment indicates that evacuation of local areas may be advisable, the Emergency Coordinator shall immediately notify appropriate local authorities. The Emergency Coordinator shall be available to help appropriate officials decide whether local areas should be evacuated; and ii. The Emergency Coordinator shall immediately notify the National Response Center using their 24-hour toll free number (800) 424-8802. The report shall include: - Name and telephone number of reporter; - Name and address of the Facility; - Time and type of incident (e.g., release, fire); - Name and quantity of material(s) involved, to the extent known; - The extent of injuries, if any; and - The possible hazards to human health, or the environment, outside the Facility. iii. A leak or spill of one pound or less of hazardous waste, that is immediately contained and cleaned-up, need not be reported. iv. Releases that are contained within a secondary containment system need not be reported. v. The following tables shall be consulted to determine whether a spill is reportable or not: EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 11 In s i d e t h e R e s t r i c t e d A r e a Item Quantity Implementation of Contingency Plan Required Reportable Radioactive Waste Greater than 220 pounds Yes, if spill occurs outside of Secondary Containment Yes, if spill occurs outside of Secondary Containment Radiologically contaminated or potentially contaminated liquid (including leachate and excluding incidental drippage from routine decontamination operations and precipitation and condensation events). Any Amount Yes, if spill occurs outside of Secondary Containment. Yes, if spill occurs outside of Secondary Containment Hazardous Waste < 1 lb No No Hazardous Waste* > 1 lb Yes, if spill occurs outside of Secondary Containment Yes, if spill occurs outside of Secondary Containment Petroleum products Greater than 25 gallons Yes Yes, if spill occurs outside of Secondary Containment PCB Waste Less than one pound of PCBs by weight Yes No Greater than one pound of PCBs by weight Yes Yes *NOTE: For spills of hazardous waste > 2.2 lbs, the Manager, Compliance and Permitting or designee shall review the waste codes against UAC R315-9-1 to determine if notification is required to the Division of Environmental Response and Remediation. EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 12 f. During an emergency, the Emergency Coordinator shall take all reasonable measures necessary to ensure that fires, explosions, and releases do not occur, recur, or spread to other hazardous waste at the Facility. These measures shall include, where applicable, stopping processes and operations, collecting and containing released waste, and removing or isolating containers. i. In the event of a fire at the Mixed Waste Operations Building or Mixed Waste Treatment Building, the Emergency Coordinator shall verify that the Fire Suppression System Pump is operational. Verification shall be accomplished by either of the following methods: A. Use of Security Cameras to verify that the RED strobe light located on top of the Fire Water Pump House has activated or, B. Assign an employee to drive to the Fire Water Pump House and visually verify that the pump is operational. Ou t s i d e t h e R e s t r i c t e d A r e a Item Quantity Implementation of Contingency Plan Required Reportable F, K, P, U Listed Waste Non-U Listed Waste Characteristic Waste Leachate Radiologically contaminated or potentially contaminated liquid Radioactive Waste Any Amount Yes Yes Petroleum products Greater than 25 gallons Yes Yes PCB Waste Less than one pound of PCBs by weight Yes No Greater than one pound of PCBs by weight Yes Yes ** The reporting requirements for PCBs is based on the amount of PCBs within the spill, not the spill weight (e.g., if one pound of waste that contained 500,000 ppm of PCBs was spilled, the total amount of PCBs spilled for reporting requirements is only ½ pound) EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 13 g. If the Facility stops operations in response to a fire, explosion, or release, the Emergency Coordinator shall coordinate monitoring for leaks, pressure buildup, gas generation, or ruptures in valves, pipes, or other equipment, wherever this is appropriate. h. Immediately after an emergency, the Emergency Coordinator shall provide for treating, storing, or disposing of recovered waste, contaminated soil or surface water, or any other material that results from a release, fire, or explosion at the Facility. Unless it can be determined that the recovered material is not a hazardous waste, the recovered material shall be managed as a hazardous waste. If it is determined that the recovered material is PCB/Mixed Waste, it shall be managed in accordance with Attachment II-1-10, Management of Waste Containing Polychlorinated Biphenyls (PCBs) at the Mixed Waste Facility. i. The Emergency Coordinator shall ensure that, in the affected area(s) of the Facility: i. No waste that may be incompatible with the released material is treated or disposed of until cleanup procedures are completed; and ii. All emergency equipment listed in the contingency plan is cleaned and fit for its intended use before operations are resumed. j. The Permittee shall notify the Director that the Facility has completed the requirements in Condition 8.i., above, before operations are resumed in the affected area(s) of the Facility. k. The Permittee shall note in the operating record the time, date, and details of any incident that requires implementing this Contingency Plan. If reporting is required as described within this contingency plan, within 15 calendar days after the incident, the Permittee shall submit a written report on the incident to the Director. The report shall include: i. The Permittee’s name, mailing address, and telephone number; ii. Address and telephone number of the Facility; iii. Date, time, and type of incident (e.g., fire, explosion); iv. Name and quantity of material(s) involved; EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 14 v. The extent of injuries, if any; vi. An assessment of actual or potential hazards to human health or the environment, where this is applicable; and vii. Estimated quantity and disposition of recovered material that resulted from the incident. l. Within 30 calendar days of detecting a release to the environment from a tank system or secondary containment system, the Permittee shall report the following information to the Director of the Division of Waste Management and Radiation Control (Director): i. Likely route of migration of the release. ii. Characteristics of the surrounding soil (including soil composition, geology, hydrogeology, and climate). iii. Results of any monitoring or sampling conducted in connection with the release. If the Permittee finds it will be impossible to meet this time period, the Permittee shall provide the Director with a schedule of when the results will be available. This schedule shall be provided before the required 30-day submittal period expires; iv. Proximity of down-gradient drinking water, surface water, and populated areas. v. Description of response actions taken or planned. 10. Amendment of this Contingency Plan. This plan shall be reviewed and immediately amended, if necessary, under any of the following circumstances: a. This Permit is modified. b. This plan fails in an emergency. c. The Facility changes in a way that increases the potential for fires, explosions, or releases of hazardous or industrial waste constituents, or alters the response necessary in an emergency. d. The emergency names (emergency coordinators) or their telephone numbers change. EnergySolutions LLC Issued - April 4, 2003 Revised – March 18, 2025 Attachment II-6 - Contingency Plan - Page 15 e. The list of emergency equipment changes. 11. In accordance with R315-262-262 the Contingency Plan Quick Reference Guide for the Clive Facility will be attached to this document under Attachment II-6-1. a. This Attachment II-6-1 shall be evaluated during the review and modification process of Attachment II-6 Contingency Plan. END OF ATTACHMENT II-6 STAIRS DOWN STAIRS DOWN