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Home My WebLink AboutDRC-2025-001605 CLIVE SITE LETTER OF TRANSMITTAL DATE: 5/12/2025 ATTN: LLRW CC; Treesa Parker Karen Kirkwood RE: Transmittal 2025-027 Description of Documents Transmitted Qty See attached updates for Radiation Safety. CL-RS-PR-114 Rev 8, Receipt and Evaluation of Radiologically Contaminated Material and Equipment for Use/Reuse at EnergySolutions 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EnergySolutions Document Control Clive Facility Electronic documents, once printed, are uncontrolled and may become outdated. Refer to the Intranet or the Document Control authority for the correct revision. CL-RS-PR-114 Receipt and Evaluation of Radiologically Contaminated Material and Equipment for Use/Reuse at EnergySolutions Revision 8 Authored By: Mark White, Radiation Safety Specialist Date Reviewed By: Dale Thorne, Lead, Health Physics/ARSO Date Approved By Stephen Long, Lead, Health Physics/ARSO Date Approved By Thomas A. Brown, Radiation Safety Officer (RSO) Date Non-Proprietary New Proprietary Title Change Restricted Information Revision Safeguards Information Rewrite Sensitive Security Information Cancellation Mark White Digitally signed by Mark White Date: 2025.05.12 11:27:12 -06'00' Dale Thorne Digitally signed by Dale Thorne Date: 2025.05.12 12:03:43 -06'00' Stephen J. Long Digitally signed by Stephen J. Long Date: 2025.05.12 13:40:07 -06'00' Thomas Brown Digitally signed by Thomas Brown Date: 2025.05.12 14:23:21 -06'00' CL-RS-PR-114 Receipt and Evaluation of Radiologically Contaminated Material and Equipment for Use/Reuse at EnergySolutions Revision 8 Non-Proprietary Page 2 of 11 Table of Contents 1 PURPOSE AND SCOPE ........................................................................................................ 3 1.1 Purpose........................................................................................................................... 3 1.2 Scope............................................................................................................................... 3 2 REFERENCES ....................................................................................................................... 3 3 GENERAL .............................................................................................................................. 3 3.1 Definitions ...................................................................................................................... 3 3.2 Responsibilities .............................................................................................................. 3 3.3 Precautions and Limitations ........................................................................................ 4 3.4 Records........................................................................................................................... 4 4 REQUIREMENTS AND GUIDANCE .................................................................................. 4 5 ATTACHMENTS AND FORMS........................................................................................... 8 CL-RS-PR-114 Receipt and Evaluation of Radiologically Contaminated Material and Equipment for Use/Reuse at EnergySolutions Revision 8 Non-Proprietary Page 3 of 11 1 PURPOSE AND SCOPE 1.1 Purpose To provide instruction for performing and documenting an evaluation of potential risk from radiologically contaminated equipment destined for use/reuse inside the radiologically restricted areas at the EnergySolutions Clive Facility; and to provide the method for tracking radioactive equipment received. To also provide documentation and radiological survey requirements for the release of Locomotive TR-3 after maintenance and repair in the Contaminated Restricted Area. 1.2 Scope This procedure applies to all Radiation Safety personnel at EnergySolutions, Clive Facility. 2 REFERENCES 2.1 CL-QA-PR-005, Quality Assurance Records 2.2 EnergySolutions Radioactive Material License UT# 2300249, As Amended 3 GENERAL 3.1 Definitions 3.1.1 Contaminated Area/Contamination Area — An area accessible to individuals in which the removable loose surface beta-gamma contamination levels exist in excess of 1000 dpm/100cm2 or loose surface alpha contamination exist in excess of 100 dpm/100cm2. 3.1.2 Inaccessible Surface(s) - A surface on an item or piece of equipment that cannot be directly measured (physical measurement) for the presence of removable or fixed radioactive contamination. 3.1.3 Restricted Area (RA) — The area within the controlled area that requires control of access and occupancy for radiation protection purposes. The restricted area boundary is posted “Caution, Radioactive Material” and is bordered by a six (6) foot high fence except in buildings where a lockable door or other device to prevent unauthorized or inadvertent entry is present. 3.1.4 Reuse - Is the use of potentially contaminated or contaminated equipment by EnergySolutions at its licensed facility that has been received and/or purchased from other nuclear facilities (nuclear power plants, DOE sites, etc.). 3.2 Responsibilities CL-RS-PR-114 Receipt and Evaluation of Radiologically Contaminated Material and Equipment for Use/Reuse at EnergySolutions Revision 8 Non-Proprietary Page 4 of 11 3.2.1 Radiation Safety Officer (RSO) or designee has overall responsibility for this procedure and is responsible for approving the release of the material / equipment for use/reuse. The RSO is responsible for conducting an ALARA review prior to each planned maintenance or repair activity of Locomotive TR-3 and for completing form CL-RS-PR-114-F2, Radiological Evaluation of Proposed Maintenance/Repair of Locomotive TR-3. 3.2.2 Lead, Health Physics/ARSO or designee is responsible for review of all documents generated in compliance with this procedure. 3.2.3 Radiation Safety Technician (RST) is responsible for the implementation of this procedure. 3.2.4 The Preparer is an appropriately skilled individual responsible for performing and documenting the evaluation. 3.2.5 The Independent Reviewer is an appropriately skilled individual responsible for performing an independent review of the documented evaluation. 3.3 Precautions and Limitations 3.3.1 Equipment shall be appropriately immobilized prior to surveying. 3.3.2 EnergySolutions’ radioactive material license does not authorize receipt of contaminated material/equipment for use/reuse at the Clive facility. Specific Utah DWMRC approval is required to accept any contaminated material/equipment for use/reuse at the Clive facility. 3.3.3 Any equipment designated as contaminated equipment for reuse shall require authorization from the Utah DWMRC before it can be released in accordance with License Condition 27 of EnergySolutions Radioactive Material License UT2300249. 3.3.4 All maintenance or repair of Locomotive TR-3 shall take place within the Contaminated Restricted Area and in the presence of a RST. 3.4 Records 3.4.1 Documents generated pursuant to this procedure shall be maintained in accordance with CL-QA-PR-005, Quality Assurance Records. 4 REQUIREMENTS AND GUIDANCE Note: This evaluation can be initiated prior to receiving the material/equipment being evaluated. Decontamination, if required, may be performed by the owner of the material/equipment. Additionally, when the owner doesn’t have the capability to perform the decontamination necessary to meet the objectives of this procedure, EnergySolutions may receive the material/equipment with the intent to decontaminate the material/equipment to meet these CL-RS-PR-114 Receipt and Evaluation of Radiologically Contaminated Material and Equipment for Use/Reuse at EnergySolutions Revision 8 Non-Proprietary Page 5 of 11 objectives. Any material/equipment shipped to the Clive facility under this designation must meet the conditions specified in Radioactive Material License UT2300249 for disposal. Specifically, EnergySolutions may not receive any equipment that exceeds the Class A limit for radioactive waste and/or SNM Exemption levels. 4.1 Collection of Information and the Determination of Process History for Material/Equipment to be reused Note: As much radiological information as possible should be obtained from the previous owner of the material/equipment. The radiological information should be included as a data point in the overall decision to obtain the material/equipment. 4.1.1 When possible, OBTAIN available use/process history information from the previous owner for material/equipment that will be reused at the Clive facility. Note: Potential risk is inherently related to the specific isotopes that may have come in contact with the material/equipment at the previous owner’s facility(ies). Information regarding isotopes can prevent overly conservative risk estimates based upon assumed most restrictive isotopes. 4.1.2 When possible, DETERMINE radiological isotopes that may have contacted the material/equipment. 4.1.3 When possible, OBTAIN available and relevant radiological survey maps/data from the previous owner for material/equipment that will be reused at the Clive facility. Note: Calculations and/or estimates of radiological conditions may be made if survey data is incomplete or not available. 4.1.3.1 DETERMINE external dose rates on contact with item surfaces, and at least 30 cm from the item surfaces. 4.1.3.2 DETERMINE total and removable radioactive contamination levels on accessible and inaccessible surfaces of the material/equipment. 4.1.4 OBTAIN verification surveys of the material/equipment at the site to validate and/or establish radiological characterization of the items. 4.2 Waste Classification and Special Nuclear Material (SNM) Exemption Note: Equipment for reuse will become waste for disposal in the future. Therefore, it is necessary to consider the potential CL-RS-PR-114 Receipt and Evaluation of Radiologically Contaminated Material and Equipment for Use/Reuse at EnergySolutions Revision 8 Non-Proprietary Page 6 of 11 waste classification and any special SNM concerns prior to receipt. 4.2.1 DETERMINE that the equipment/material for reuse does not exceed Class A. 4.2.2 EVALUATE the potential SNM impact from the material with respect to the EnergySolutions Exemption criteria. 4.2.2.1 IF SNM is present, RSO shall OBTAIN shipper’s CL- WM-PR-001-F3, Special Nuclear Material Exemption Certification and ATTACH completed form to radiological risk evaluation. 4.3 Occupational Radiological Risk Evaluation Note: Total Effective Dose Equivalent (TEDE) is a measure of radiological risk and represents the sum of the Committed Effective Dose Equivalent (CEDE) and the Deep Dose Equivalent (DDE) 4.3.1 SELECT/DEVELOP a method and model to evaluate and estimate the DDE and CEDE that could result from material/equipment use. 4.3.2 DETERMINE/ESTIMATE Worker Occupancy (WO-hours per year) in the vicinity of the material/equipment. 4.3.3 ESTIMATE the Deep Dose Equivalent (DDE) that could result to an occupational worker due to material/equipment use. 4.3.4 ESTIMATE the Committed Effective Dose Equivalent (CEDE) that could result to an occupational worker by inhalation and/or ingestion of radioactive material due to material/equipment use. 4.3.5 ESTIMATE TEDE that could result to an occupational worker due to material/equipment use. 4.3.6 CONSIDER ALARA decontamination actions if any of the following conditions exist: • The material/equipment has removable contamination levels that are greater than two times the average contamination levels in the area where the material will be used. • The material/equipment contributes to area external dose rates that are greater than two times the average dose rate where the material will be used. • The contact external dose rate is equal to or greater than five (5) times the 30 cm dose rate. CL-RS-PR-114 Receipt and Evaluation of Radiologically Contaminated Material and Equipment for Use/Reuse at EnergySolutions Revision 8 Non-Proprietary Page 7 of 11 4.4 Documentation of Evaluation Results 4.5.1 DOCUMENT the evaluation results, and as a minimum, include the following: • Description of the material/equipment • Brief process history description • Isotopes of Interest • Radiation dose rates • Contamination levels • Waste Classification determination • SNM Exemption Certification • Assumptions • Model and method for TEDE estimate • TEDE estimate • Required ALARA decontamination actions 4.4.1 ATTACH copies of associated radiation and contamination surveys, or other documentation supporting evaluation results. 4.4.2 SIGN/DATE evaluation documentation. Preparer 4.4.3 OBTAIN an independent review of the evaluation results by an appropriately skilled individual as determined by the Radiation Safety Officer equivalent management position. Independent Reviewer 4.4.4 SIGN/DATE evaluation documentation when agreement has been reached with preparer. 4.4.5 SIGN/APPROVE the evaluation prior to releasing the material/equipment for use/reuse at EnergySolutions. 4.5 Tracking Reuse Material/Equipment 4.5.1 Upon Receipt of the material/equipment, the RSO shall enter the following information onto the Reuse Equipment Log. • Equipment ID # • Description of equipment/material • Date Received • Current Disposition CL-RS-PR-114 Receipt and Evaluation of Radiologically Contaminated Material and Equipment for Use/Reuse at EnergySolutions Revision 8 Non-Proprietary Page 8 of 11 4.5.2 Notify Maintenance of the arrival of the material/equipment for entry into the surety log. Note: Equipment received under this procedure requiring maintenance shall have the work performed with in the Contaminated Restricted area. 4.5.3 In addition to the tracking requirements outlined in 4.5.1, EnergySolutions will track equipment in accordance with Condition 50-B of the EnergySolutions Radioactive Material License UT2300249. 4.5.4 Upon receipt of any material/equipment under this designation, a 541 disposal document will be generated in order to track any waste fees that are associated with disposal of the material/equipment. 5 ATTACHMENTS AND FORMS 5.1 “CL-RS-PR-114-F1, Contaminated Material and Equipment for Use / Reuse at the EnergySolutions Clive Facility, Example 5.2 CL-RS-PR-114-F2, Radiological Evaluation of Proposed Maintenance/Repair of Locomotive TR-3, Example CL-RS-PR-114 Receipt and Evaluation of Radiologically Contaminated Material and Equipment for Use/Reuse at EnergySolutions Revision 8 Non-Proprietary Page 9 of 11 Attachment 5.1 – CL-RS-PR-114-F1, Contaminated Material and Equipment for Use/Reuse at the EnergySolutions Clive Facility (Example) CL-RS-PR-114 Receipt and Evaluation of Radiologically Contaminated Material and Equipment for Use/Reuse at EnergySolutions Revision 8 Non-Proprietary Page 10 of 11 Attachment 5.2 – CL-RS-PR-114-F2, Radiological Evaluation of Proposed Maintenance/Repair of Locomotive TR-3 (Example) CL-RS-PR-114 Receipt and Evaluation of Radiologically Contaminated Material and Equipment for Use/Reuse at EnergySolutions Revision 8 Non-Proprietary Page 11 of 11