HomeMy WebLinkAboutDRC-2025-001462 CLIVE SITE
LETTER OF TRANSMITTAL DATE: 5/2/2025 ATTN: LLRW
CC; Treesa Parker Karen Kirkwood RE: Transmittal 2025-025
Description of Documents Transmitted Qty
See attached updates for Safety and Health. CL-SH-PN-001 Rev 1 Silica Compliance Plan Clive Facility. 1
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CL-SH-PN-001
Silica Compliance Plan – Clive Facility
Revision 1
Authored By:
Joshua Cordova, Safety and Health Technician II Date
Reviewed By:
Leon Baker, Safety and Health Manager Date
Approved By
Thomas A. Brown, Radiation Safety Officer Date
Approved By
David Booth, General Manager, Clive Facility
Date
Non-Proprietary New
Proprietary Title Change
Restricted Information Revision
Safeguards Information Rewrite
Sensitive Security Information Cancellation
Josh S. Cordova Digitally signed by Josh S. Cordova
Date: 2025.05.02 11:06:42 -06'00'
Leon Baker Digitally signed by Leon Baker
Date: 2025.05.02 12:24:54 -06'00'
Thomas Brown Digitally signed by Thomas Brown
Date: 2025.05.02 13:40:08 -06'00'
Digitally signed by David F Booth
DN: C=US, O=EnergySolutions, CN=David F Booth, E=dbooth@energysolutions.com
Reason: I am approving this document.Location: NA
Date: 2025-05-02 15:58:19
Foxit PhantomPDF Version: 9.7.5David F Booth
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Table of Contents
1 PURPOSE AND SCOPE .............................................................................................. 3
2 REFERENCES .............................................................................................................. 3
3 DEFINITIONS .............................................................................................................. 3
4 PRECAUTIONS AND LIMITATIONS ..................................................................... 4
5 Silica Activities .............................................................................................................. 4
6 Exposure monitoring .................................................................................................... 5
7 Engineering Controls .................................................................................................... 7
8 Administrative Controls ............................................................................................... 8
9 Personal Protective Equipment ................................................................................... 8
10 Regulated Areas ............................................................................................................ 8
11 Housekeeping................................................................................................................. 9
12 Medical Surveillance ..................................................................................................... 9
13 Training ......................................................................................................................... 9
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1 PURPOSE AND SCOPE
The purpose of this Plan is to identify and evaluate job activities at the Clive facilities
where employees may be exposed to respirable crystalline silica. It provides site-specific
guidance and recommendations to control and minimize occupational exposure to
respirable crystalline silica, in line with the requirements identified in 29 CFR 1910.1053,
Silica. This Plan must be implemented for all exposures to respirable crystalline silica at
or above the Action Level (AL) of 25 µg/m³, calculated as an 8-hour TWA, under any
foreseeable condition.
2 REFERENCES
2.1 CL-SH-PR-100 Clive Health and Safety Program
2.2 ES-SH-PR-308 Respiratory Protection
2.3 ES-SH-PR-401- Medical Surveillance
2.4 ES-SH-PR-200 Industrial Hygiene
2.5 Occupational Safety and Health Administration 29 CFR 1910.1053 Silica
3 DEFINITIONS
3.1 Action Level- An OSHA occupational exposure limit (without regard to the use of
respirators) for airborne contaminants. For respirable crystalline silica it is 25
micrograms per cubic meter of air (25 µg/m³) for an 8-hour Time-Weighted
Average (TWA). Employees whose exposure is above the Action Level for more
than 30 days per year are required to be in a medical surveillance program.
3.2 HEPA- A High Efficiency Particulate Air Filter capable of filtering 0.3-micron
particles with 99.97 percent efficiency.
3.3 Local Exhaust Ventilation (LEV) – Exhaust ventilation designed to capture and
remove air from one or more specific areas and move that air to another location.
A typical application can include the use of LEV’s to capture and remove silica
dust from a grinding operation and relocate that contaminated air to another
location away from the workers conducting the work.
3.4 Medical Surveillance- Consists of medical examinations performed by a
Physician or other Licensed Health Care Professional.
3.5 Permissible Exposure Limit (PEL)- An OSHA occupational exposure limit
(without regard to the use of respirators) for airborne contaminants. For
respirable crystalline silica it is 50 micrograms per cubic meter of air (50 µg/m³)
for an 8-hour Time-Weighted Average (TWA).
3.6 Physician or other licensed health care professional (PLHCP) - an individual
whose legally permitted scope of practice (i.e., license, registration, or
certification) allows him or her to independently provide or be delegated the
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responsibility to provide some or all the health care services required by
paragraph (i) of this section.
3.7 Protected Health Information (PHI) - All “individually identifiable health
information” held or transmitted by a covered entity or its business associate, in
any form or media, whether electronic, paper, or oral. This normally includes
name, address, date of birth, and social security number.
3.8 Regulated Area – A restricted area where airborne exposures to silica will be or
are expected to be equal to or greater than the Permissible Exposure Limit for
silica.
3.9 Time Weighted Average (TWA) – An average of measurements expressed over a
period of time. For occupational exposures, this time period is typically 8 hours
but can include periods ranging from 10 hours to 12 hours. The time period is
typically stated prior to the “TWA” designation as in “8-hour TWA”.
4 PRECAUTIONS AND LIMITATIONS
4.1 This Plan addresses work that is performed on a regular basis, even if the
frequency may be limited to once or twice a year. The Plan will be required to be
updated if new work is performed that has not been addressed in Section 5.0.
4.2 This Plan is required to be reviewed on an annual basis.
4.3 Silica work and this Work Instruction apply to all silica work conducted at Clive.
It is noted, however that silica work performed inside the Radiological Controlled
Area (RCA) within the facility will benefit from radiological controls that
minimize the spread of radiological contamination. These controls which can
include personal protective equipment, ventilation, job rotation, decontamination,
etc..
4.4 Medical surveillance records and personal exposure monitoring data are
considered PHI and must be stored and controlled as confidential information.
Only individuals with a “need to know” may have access to the data.
4.5 Medical records and personal exposure monitoring data generated during this
work activity shall be maintained for at least 40 years or the length of
employment plus 20 years, whichever is longer.
5 SILICA ACTIVITIES
5.1 Workplace Evaluation - Each work area where silica operations are performed
will be evaluated using the Qualitative Exposure Assessment form (ES-SH-PR-
200-F1) to determine if silica exposure activities have to potential to expose
personnel to silica at or above the Action Level of 25 µg/m3averaged over an 8-
hour period. If it is determined that the potential for exposures to silica are greater
than the Action Level, then exposure monitoring will be completed per Section 6
of this procedure.
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5.2 Potential Respirable Silica Exposure Generating Activities
5.2.1 Concrete Truck Drum Chipping Activities: On an occasional basis,
concrete trucks used at the Clive Facility must have their drums cleaned
out. This requires the use of electric and pneumatic chipping tools to chip
out concrete adhered to the drum interior surfaces. Risks include dust,
silica, noise, LOTO (Lockout/Tagout) (equipment) and heat stress. Work
conducted inside drums also falls under the purview of facility Confined
Space requirements. Work durations typically run a several hours to a full
shift. This operation typically occurs approximately every 6 to 8 months.
Currently the concrete mixes used on site can vary and can include various
percentages of Cement, Pozzolan, water and air. The relative silica
concentration of the mix can vary 1% or higher. Historic sampling for this
operation has indicated low exposure risks to workers.
5.2.2 Batch Plant Operations and/or Maintenance: Batch Plant Operations
and/or Maintenance involves the operation of the site concrete batch plant
to produce concrete used on site for waste cell construction and other uses
as needed. Operation of the batch plant is variable depending upon the
needs for concrete on site. Currently the concrete mixes can vary and can
include various percentages of Cement, Pozzolan, water and air. The
relative silica concentration of the mix can vary 1% or higher. Individual
components used in the mix can have silica concentrations of 10% (i.e.
Pozzolan) or higher. Exposures to workers can occur during material
delivery operations, transference (conveyance) operations to the concrete
trucks and during maintenance/repair activities on individual concrete
trucks or batch plant equipment. Historic sampling for these operations
has indicated low exposure risks to workers.
5.3 Non-Standard Silica Activities at Clive
5.3.1 All non-standard silica activities that are not detailed in Section 5.2 will be
evaluated on a case-by-case basis using the Qualitative Exposure
Assessment form (ES-SH-PR-200-F1).
5.3.2 Air sampling for silica will be performed on the exposed employees/SEGs
to quantify personal exposures during non-standard silica operations. All
exposure monitoring will be conducted in accordance with ES-SH-PR-
200, Industrial Hygiene, and based upon risk identified during the
qualitative exposure assessment process.
5.3.3 Any activities that deviate from the standard silica activities will be
considered non-standard silica processing activities.
6 EXPOSURE MONITORING
6.1 Personal Air Monitoring (General)
6.1.1 Personal air monitoring is performed to evaluate occupational exposure to
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silica and other contaminants and the results are compared to the
OSHA(Occupational Safety and Health Administration) established
regulatory limit.
6.1.2 Air monitoring results are used to assess the effectiveness of engineering
and administrative controls. The results shall also be used to ensure
respiratory protection is adequate to protect the workers based on the
exposure levels.
6.1.3 All air sampling shall be performed by a person who is trained on the
proper calibration and use of sampling equipment and has an adequately
understanding of the work and safety and health requirements. All
sampling data collected will be documented, reviewed, and properly
stored as employee exposure records.
6.1.4 All air sampling media used to evaluate workers exposure on the job shall
be analyzed by an AIHA accredited lab.
6.1.5 Air sampling will be performed to assess the job tasks. The sampling will
be representative of the different job classifications performed during the
work activity (Example Process Technicians, Radiation Safety Technician
(RST), and Furnace Operator).
6.1.6 Full shift sampling will be performed when performing silica work
whenever possible.
6.1.7 Air sampling media must be radiologically free released prior to shipping
to an analytical lab. Radiological controlled samples must be shipped to an
AIHA (American Industrial Hygiene Association) accredited lab that has a
radiation permit capable of accepting the controlled sample. Coordinate
with the analytical lab prior to shipping any radiological controlled media
for analysis.
6.1.8 Employees shall be notified of their sample results within 15 working days
of the receipt of the analytical lab results.
6.2 Personal Air Monitoring (Greater than Action Level)
6.2.1 If initial monitoring or previous monitoring data indicates that exposures
are greater than the Action Level for the associated work shift length but
lower than the PEL then monitoring will be completed every 6 months if
the silica operation is being performed until at least two consecutive
measurements, taken greater than 7 days apart are below the Action Level.
6.3 Personal Air Monitoring (Greater than PEL)
6.3.1 If initial monitoring or previous monitoring data indicates that exposures
are greater than the PEL for the associated work shift length then
monitoring will be completed every quarterly if the silica operations are
being performed until at least two consecutive measurements, taken
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greater than 7 days apart are below the PEL.
6.3.2 If quarterly monitoring indicates exposures are less than the PEL, but
greater than the Action Level the monitoring will be completed every 6
months if the silica operations are being performed until at least two
consecutive measurements, taken greater than 7 days apart are below the
Action Level.
6.4 Air Monitoring Frequency requirements:
6.4.1 Tasks resulting in air monitoring results less than the Action Level are to
be monitored on an annual basis to ensure no changes in conditions have
occurred.
6.4.2 Tasks with air monitoring results exceeding the Action Level but less than
the PEL shall be monitored on a semi- annual basis (6-month interval) or
as work is performed.
6.4.3 Tasks with air monitoring results exceeding the PEL shall be sampled at
least quarterly or as tasks are performed if work is performed infrequently.
6.5 Exposure Levels: Exposure control levels are normally based on an eight-hour
shift length. If personnel work an extended shift (10 or 12 hours), air sampling
should be conducted over the period that represented the “worst exposure” 8-hr
period.
Shift
Length
Sample
Time
Action
Level
Permissible
Exposure Limit
8 hours 7 hours 25
µg/m3
50 µg/m3
10 hours 8 hours
(worst
case)
25
µg/m3
50 µg/m3
12 hours 8 hours
(worst
case)
25
µg/m3
50 µg/m3
7 ENGINEERING CONTROLS
7.1 For job tasks where occupational exposures exceed the PEL, engineering controls
shall be the utilized to reduce exposure levels to as low as feasible.
7.2 Portable Local Exhaust Ventilation (LEV) systems can be used to reduce
exposures. In areas where radiological contamination is a concern or exposure to
other personnel in the work area, HEPA filtration must be used to capture silica
dusts. In areas that are open to the outside atmosphere, exhaust ducting set up to
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exhaust away from the work area may be used for dust/silica management. ESH
must be consulted on set up and use of exhaust ventilation.
7.3 HEPA vacuums shall be utilized to perform cleanup activities and reduce surface
contamination as much as possible. Dry sweeping or use of compressed air is not
permitted for cleanup operations.
8 Administrative Controls
8.1 When silica exposures change, operating procedures shall be updated to include
exposure control measures.
8.2 Access shall be restricted to qualified workers who have the training and medical
requirements to enter an area with airborne silica exposure potential greater than
the Action Limit.
8.3 An assessment of the work controls, exposure data, and processes shall be
performed on an annual basis to ensure this plan is current.
8.4 Any new work activities or potential exposures shall be evaluated prior to
performing the work tasks.
8.5 No general sweeping is allowed without the use of a floor sweep type material
(usually oil based) to minimize dust.
8.6 No compressed air shall be used for cleaning in the silica exposure area during
related work operations.
9 PERSONAL PROTECTIVE EQUIPMENT
9.1 All employees will be medially qualified and trained to wear approved respiratory
protection.
9.2 Powered Air purifying respirators (PAPR) with high efficiency particulate
cartridges (P100) are the most utilized respirator when performing silica work.
The PAPR has been assigned a protection factor of 1,000 . The PAPR may be
used for a maximum use concentration of 50,000µg/m3 based on a 8-hour TWA.
9.3 A Full-Face tight-fitting air purifying respirators (APR) with P100 cartridges has
an assigned protection factor of 50. The APR may be utilized to a maximum
concentration of airborne silica of 2,500 µg/m3.based on a 8-hour TWA.
10 REGULATED AREAS
10.1 Establishment - Regulated areas shall be establish a regulated area wherever a
worker’s exposure to airborne concentrations of respirable crystalline silica is, or
can reasonably be expected to be, more than the PEL
10.2 Demarcation – Regulated areas shall be demarcated from the rest of the
workplace in a manner that minimizes the number of workers exposed to
respirable crystalline silica within the regulated area.
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10.3 Signs shall be posted at all entrances to regulated areas that bear the legend
specified below:
DANGER
RESPIRABLE CRYSTALLINE SILICA
MAY CAUSE CANCER
CAUSES DAMAGE TO LUNGS
WEAR RESPIRATORY PROTECTION IN
THIS AREA
AUTHORIZED PERSONNEL ONLY
10.4 Access to regulated areas shall be limited to only those workers and personnel
authorized by this work instruction and CFR1910.1053 to be present in the
regulated areas.
11 HOUSEKEEPING
11.1 All surfaces within a regulated area shall be cleaned utilizing a HEPA vacuum on
a regular basis to minimize silica surface contamination.
11.2 All tools and equipment shall be cleaned on a regular base after use to limit the
spread of silica contamination.
12 MEDICAL SURVEILLANCE
12.1 Employees shall be enrolled in a medical surveillance prior to an initial
assignment in areas where airborne silica levels are at or exceed the Action Level
for more than 30 days per year.
12.2 EnergySolutions shall ensure that all medical examinations are conducted by a
PLHCP. Examination requirements followed shall be consistent with those
found in CFR1910.1053(i) Medical Surveillance.
12.3 All medical surveillance will be scheduled and managed through a third-party
medical management system which provides test results to the Safety & Health
Department and health for review.
13 TRAINING
13.1 All employees who have exposure potential to airborne silica at any level shall
have silica awareness training which complies with the requirements outlined in
29 CFR 1910.1053.
13.2 Employees exposed to airborne silica above the Action Level will be trained
accordance with the requirements outlined in 29 CFR 1910.1053 (j)(3).
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13.3 All training will be documented for tracking purposes and will be performed on
an annual basis.
13.4 All workers will be trained on the use of Respiratory Protection on an annual
basis. A respirator mask fit is also required on an annual basis when utilizing tight
fitting respirators.
13.5 Information regarding respirable crystalline silica shall be included within the
training related to potential silica exposures at the site as well as part of
initial/regular hazard communication training conducted for all personnel at the
facility.
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