DRC-2025-001609

CLIVE SITE
LETTER OF TRANSMITTAL DATE: 5/19/2025 ATTN: LLRW
CC; Treesa Parker Karen Kirkwood RE: Transmittal 2025-028
Description of Documents Transmitted Qty
See attached updates for Safety and Health. CL-SH-PR-150 Rev 9, Laboratory Chemical Hygiene Plan 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-SH-PR-150

Laboratory Chemical Hygiene Plan
Revision 9

Authored By:
Leon Baker, Safety & Health Manager Date
Reviewed By:
Brian Lichtenfels, Corporate Health & Safety Date

Reviewed By:
Curtis Kirk, Quality Assurance Manager Date
Approved By:
Thomas A. Brown, Radiation Safety Officer Date
Approved By:
David Booth, General Manager Date

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

Leon Baker Digitally signed by Leon Baker
Date: 2025.05.16 08:16:16 -06'00'
Brian D. Lichtenfels Digitally signed by Brian D. Lichtenfels
Date: 2025.05.19 09:25:02 -06'00'
Digitally signed by Curtis Kirk
DN: C=US, OU=EnergySolutions, O=Quality Assurance, CN=Curtis Kirk, E=[e-mail]
Reason: I am the author of this documentLocation: your signing location here
Date: 2025-05-19 10:53:12Foxit PhantomPDF Version: 9.7.5
Curtis Kirk
Thomas Brown Digitally signed by Thomas Brown
Date: 2025.05.19 11:53:53 -06'00'
Digitally signed by David F Booth
DN: C=US, O=EnergySolutions, CN=David F Booth, E=[e-mail]: I am approving this document.
Location: NA
Date: 2025-05-19 13:29:57Foxit 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 .............................................................................................................................. 3
3.1 Definitions ...................................................................................................................... 3
3.2 Responsibilities .............................................................................................................. 5
3.3 Precautions and Limitations ........................................................................................ 6
3.4 Records........................................................................................................................... 8
4 REQUIREMENTS AND GUIDANCE .................................................................................. 8
5 ATTACHMENTS ................................................................................................................. 14

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1 PURPOSE AND SCOPE
1.1 Purpose
To define the hygiene requirements for the on-site laboratories at the
EnergySolutions Clive facility
1.2 Scope
This procedure applies to all facility personnel (including contract employees)
who work in the on-site laboratories at the EnergySolutions Clive facility.
2 REFERENCES
2.1 29 CFR 1910.1450 Occupational Exposure to Chemicals in Laboratories
2.2 29 CFR 1910.1200 Hazard Communication
2.3 29 CFR 1910.120 Hazardous Waste Operations
2.4 40 CFR 261
2.5 ES-AD-PR 005 First Notifications
2.6 CL-SH-PR 500 Contingency Implementation Plan
2.7 ES-SH-PR 308 Respiratory Protection Program
2.8 ES-SH-PR 401 Medical Surveillance
2.9 CL-TN-PR 100, Clive Facility Training
2.10 ES-SH-PR-402, Case Management of Occupational Injuries
3 GENERAL
3.1 Definitions
3.1.1 Carcinogen A chemical is considered to be a carcinogen if: (a) It has been
evaluated by the International Agency for Research on Cancer (IARC),
and found to be a carcinogen or potential carcinogen; or (b) It is listed as a
carcinogen or potential carcinogen in the Annual Report on Carcinogens
published by the National Toxicology Program (NTP) (latest edition); or,
(c) It is regulated by OSHA as a carcinogen.
3.1.2 Clean Area—Designated areas in the laboratory where open waste or
chemical containers are not handled.
3.1.3 Corrosive— Any chemical that causes visible destruction of or
irreversible alterations in living tissue by chemical action at the site of
contact, or which causes a severe corrosion rate in steel or aluminum. A
waste that exhibits a “characteristic of corrosivity” as defined by RCRA
and may be regulated by EPA as a hazardous waste.
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3.1.4 Chemical Hygiene Officer-Laboratory employee responsible for the
administration and direction of the safe handling and use of chemicals
procedures within the laboratory.
3.1.5 Reactive Chemical— A chemical that is:
• Ranked by NFPA as a reactivity hazard, or
• Is determined by the USDOT to be an oxidizer, organic peroxide,
or an explosive (class A, B or C), or
• Fits the USEPA definition of reactive in 40 CFR 261, or
• Fits the OSHA definition of unstable or polymerizable, or
• Is found to be reactive with ordinary substances.
3.1.6 NFPA Hazard Labeling— The hazard labeling method required as part of
the Globally Harmonized System.
3.1.7 Flammable— The term used to refer to a substance’s ability to ignite.
Flammable Aerosols will ignite at normal atmospheric temperature with
an air concentration of 13% by volume. Flammable Solids will ignite
readily and continue to burn vigorously and persistently. Flammable
Liquids have a flashpoint below 1000 F.
3.1.8 Flashpoint— Is the minimum temperature at which a liquid gives off
vapor in sufficient concentration to form an ignitable mixture with air.
3.1.9 Fume hood— Is a full enclosure with a movable sash or otherwise
partially enclosed on one side; constructed and maintained to draw air
from the laboratory and to prevent or minimize the escape of air
contaminants into the laboratory; and allows chemical manipulations to be
conducted in the enclosure without insertion of any portion of the
employee's body other than hands and arms.
3.1.10 Skin, Eye Contact Hazard— A chemical whose route of entry for its toxic
effects is through the skin or eyes. Chemicals that are contact hazards
will be determined by examining medical and industrial hygiene literature,
and by reviewing the associated Safety Data Sheets.
3.1.11 Threshold Limit Value (TLV) — The level determined by the American
Conference of Governmental Industrial Hygienists (ACGIH) to express
the maximum airborne concentration of a material to which most workers
can be exposed during a normal daily and weekly work schedule without
adverse health effects.
3.1.12 Permissible Exposure Limit (PEL) — The OSHA-mandated airborne
concentration of a material expressed as a time-weighted average (TWA)
limit, a short-term exposure limit (STEL), or as a ceiling exposure limit.
A ceiling limit shall not be exceeded even if the TWA is not violated.
3.1.13 RWP/Hazard Assessment— An EnergySolutions document which
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indicates prior evaluation of potential safety hazards for the handling of a
specific waste stream through a specific process in a specific location and
which stipulates the engineering controls, protective equipment, and
employee monitoring required for the activity.
3.1.14 Designated Area— An area where carcinogens or other toxic substances
are handled. In the Labs, the Fume Hoods are Designated Areas.
3.1.15 Simple Asphyxiant—A substance which displaces oxygen in the
atmosphere and may cause loss of consciousness or death due to
suffocation.
3.2 Responsibilities
3.2.1 Safety & Health Manager or designee is responsible for:
• Reviewing this procedure annually and revise it as necessary.
• Ensuring this procedure complies with applicable regulatory
requirements.
• Providing technical assistance in complying with the Laboratory
Chemical Hygiene Plan (LCHP).
• Assisting with the development of appropriate safety precautions
for new projects and procedures.
• Assisting the Chemical Hygiene Officer in the investigation of all
complaints of employee overexposure to toxic or hazardous
substances in the workplace.
3.2.2 Lead, Laboratory is responsible for:
• Ensuring that employees comply with the LCHP.
• Ensuring that appropriate personal protective equipment is
available as needed.
• Providing regular chemical hygiene and housekeeping inspections
including routine inspections of all emergency equipment.
• Understanding the current legal requirements concerning regulated
substances.
• Determining the required levels of protective apparel and
equipment.
• Ensuring that facilities and training for use of any material being
ordered are adequate.
• Monitoring procurement, collection, and disposal of chemicals.
• Remaining current on developing legal rules and regulations
concerning chemicals used at EnergySolutions.
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• Training employees to detect the malfunction of engineering
controls.
• Investigating all complaints of employee overexposures.
• Acting as the Chemical Hygiene Officer.

3.2.3 Laboratory Personnel are responsible for:
• Planning and conducting daily tasks under the direction of the
Lead, Laboratory in accordance with the LCHP.
• Performing equipment inspections under the direction of the Lead,
Laboratory.
• Reporting any discrepancies to the Lead, Laboratory.

3.3 Precautions and Limitations
3.3.1 Safety
3.3.1.1 The following list contains specific guidance on
appropriate hygiene practices for Lab Personnel:
• Wash skin promptly if contact is made with any
chemical, regardless of corrosiveness.
• All employees, and visitors, shall wear appropriate
eye protection during testing or in required areas.
• Avoid purposely inhaling chemicals.
• Use suction bulbs or other appropriate methods for
transferring liquids. Mouth pipetting is expressly
prohibited.
• Handle and store laboratory glassware with care to
avoid damage or injury. Do not use damaged
glassware.
• Use only those chemicals for which the quality of
the available ventilation system is appropriate.
• Wear appropriate gloves when the potential for
contact with toxic/hazardous materials exists.
• Inspect gloves before each use and replace them
periodically.
• Confine long hair and loose clothing. Wear shoes at
all times. Sandals and perforated shoes shall not be
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worn in the lab during lab operations.
• Avoid use of contact lenses in the laboratory.
Contact Lenses are not allowed where
splash/fume/vapor hazards are present.
• Drinking is allowed in the office area from
approved containers only.
3.3.2 Training
3.3.2.1 Before any new employee may use the lab, the Lead,
Laboratory, or designee shall provide an orientation that
shall include:
• The hazardous chemical located in the lab.
• Appropriate safeguards for using the laboratory and
other chemicals
• Location and proper use of Safety Data Sheets.
• Appropriate procedures in an emergency, including
the location and proper use of emergency
equipment.
• How and where to properly store chemicals when
not in use.
• Proper personal hygiene practices.
• The proper use, maintenance and limitations of
personal protective equipment.
• The proper methods of transporting chemicals
within the facility.
• Proper methods for disposal of laboratory chemicals
and wastes and the location of satellite
accumulation containers.
• Location and contents of the Chemical Hygiene
Plan.
• Physical and health hazards of the chemicals
present in the lab.
• Signs and symptoms of overexposure to the
chemicals present in the lab.
• Methods for documentation of chemical releases.
• Spill Prevention, control and response.
3.3.2.2 When new chemicals are introduced into the workplace, all
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affected employees shall be trained in accordance with
Section 3.3.2.
3.3.2.3 Additional training will be provided to potentially exposed
laboratory personnel on particularly hazardous chemicals
on an annual basis. Chemicals to be trained on will be
determined by the Clive Site Chemist. In addition,
Site EMT’s will receive monthly training on how to
respond to hazardous chemicals and treat potentially
exposed personnel as determined necessary by the Lead
EMT, Laboratory lead or Safety Manager. Such training
will be provided by the Lead site EMT or Chemistry Lab
personnel pertaining to a list of hazardous chemicals, CL-
SH-PR-150-F3.
3.3.2.4 The Lead, Laboratory shall provide refresher training on
the requirements of this procedure at least annually to
regular laboratory employees.
3.3.2.5 The Lead, Laboratory shall document training according to
CL-TN-PR 100, Clive Training Procedure.
3.4 Records
3.4.1 Inspections performed in accordance with this procedure shall be
documented and documentation retained in accordance with sections 4.9
and 4.10 of this procedure.
3.4.2 All training records for employees, contractors, and visitors shall be kept
in accordance with CL-QA-PR-005 and CL-AD-PR-004.
3.4.3 Training Documentation should include the following:
3.4.3.1 Employee identification
3.4.3.2 Training date and length of session
3.4.3.3 Name of individual conducting the training
3.4.3.4 Outline of training and/or copies of training materials used
3.4.4 CL-TN-PR-100 F2, Attendance Roster and CL-TN-PR-100 F3, Training
Outline, can be utilized together to meet the training documentation
requirements of this section.
4 REQUIREMENTS AND GUIDANCE
4.1 Personal Protective Equipment
4.1.1 EnergySolutions shall provide adequate personal protective equipment
(PPE) to laboratory employees.
4.1.2 Laboratory employees shall wear an appropriate splash resistant apron,
long sleeves, appropriate gloves, and goggles when working with liquid
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chemicals or corrosive chemicals. A hood with sash may be a substitute
for goggles and a face shield, but safety glasses are then required.
4.1.3 A face shield is required in addition to the requirements in 4.1.2 when
working with corrosive chemicals.
4.1.4 Laboratory personnel shall wear appropriate gloves in accordance with the
SDS for the substance(s) being handled.
4.1.5 Laboratory personnel shall wear long-sleeved lab coats when working
with open containers of waste or chemicals.
4.1.6 Sampling personnel shall wear standard PPE including Tyvek, hard hat,
safety shoes, safety glasses and gloves for work inside the Restricted Area.
4.1.7 Employees shall wear appropriate respiratory protection when handling
waste samples or when working with chemicals that have the potential for
airborne exposure at or above the PEL when engineering controls are not
in place and/or inoperable.
4.1.8 Contaminated PPE shall not be permitted in the laboratory office.
4.1.9 All employees shall comply with PPE requirements in the applicable
Radiation Work Permit.
4.2 Engineering Controls
4.2.1 All engineering controls shall be properly maintained, inspected on a
regular basis, and operated within design limits.
4.2.2 All laboratory personnel shall be familiar with the proper use of
engineering or administrative controls employed to limit employee
exposure to physical or chemical hazards where applicable.
4.2.3 At least one of the fume hood fans shall be turned on to ensure adequate
air change (at least 1 room changes of air per hour) throughout the
laboratory when open containers of chemicals and/or waste are handled
within the LLRW Chemistry Lab.
4.2.4 Chemicals with Threshold Limit Values (TLV) or Permissible Exposure
Limits (PEL) equal to or less than 5 PPM or 1 mg/m3 shall be handled
inside the fume hood or with respiratory protection.
4.2.5 Chemicals with an airborne concentration at or above the PEL or TLV or
unknown concentration shall be handled inside the fume hood or with
appropriate respiratory protection. Any carcinogen or suspected
carcinogen shall be managed only inside a Fume Hood.
4.2.6 Chemicals with a vapor pressure above 25 mm of Hg at 20 C shall be
handled in the fume hood or with respiratory protection.
4.2.7 Chemicals with a Lethal Dose (LD50) below 1mg/kg (1 ppm) shall be
handled in the fume hood or with respiratory protection. Chemicals with a
flashpoint of 100oF or lower shall be used in a vented fume hood, away
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from any source of ignition.
4.2.8 In accordance with ANSI/AIHA Z9.5, The fume hood sash shall not be
raised above 18 inches while actively working in the hood and shall
provide 80-140 fpm (feet per minute) of air velocity on average, with no
measurement more than plus or minus 20% of the average at the hood
face, CL-SH-PR-150-F2.
4.2.9 The fume hood shall not be used as a storage area.
4.2.10 The ventilation ducts and fans shall be kept clean and clear of
obstructions. Large apparatus shall be elevated on blocks for optimal air
flow.
4.2.11 The fume hood ventilation fan shall remain “on” any time that it contains
a chemical that is exposed to the atmosphere.
4.2.12 Chemicals and other work materials shall be placed at least six (6) inches
inside the sash when feasible.
4.2.13 Do not operate the Fume hoods near open doors, open windows, or fans.
4.2.14 In case of fume hood failure, all activities in the fume hood shall cease and
all open containers shall be closed.
4.2.15 The fume hood shall be visually inspected prior to use to ensure that it is
operating properly. Monthly documentation of the ventilation flow rate
shall be recorded using CL-SH-PR-150-F2 and be indicated on the sash
height marker label. Velocity of the hood shall be measured using a
calibrated instrument.
4.3 Housekeeping
4.3.1 Aisles and hallways shall be kept clear of all chemicals and other
obstructions.
4.3.2 Work areas and benches shall be kept clear of clutter and obstructions.
4.3.3 All working surfaces and floors shall be cleaned regularly.
4.3.4 Access to emergency equipment, showers, eyewashes, and exits shall not
be obstructed at any time.
4.3.5 Wastes shall be kept in properly labeled containers except when being
actively tested.
4.3.6 All chemicals shall be placed in the proper storage areas when no longer
in use, or at a minimum, by the end of each workday.
4.3.7 All chemical containers shall be labeled with the identity of the chemical,
its hazards (NFPA label), date received, and initials of the individual
documenting receipt.
4.3.8 All spills shall be promptly cleaned up. Any spilled chemical shall be
properly disposed of.
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4.3.9 Corrosive liquid chemicals in quantities greater than one liter shall have
secondary containment during storage. Secondary containment may be
integral to the chemical container.
4.3.10 The Safety & Health Manager or designee shall be consulted regarding
storage of simple asphyxiants so that appropriate hazard evaluations may
be performed, and protective measures implemented, as necessary.
4.4 Signs and Labels
4.4.1 Emergency telephone numbers shall be posted near the telephone.
4.4.2 Signs shall be posted for the emergency showers and eyewashes.
4.4.3 Signs shall be posted above all fire extinguishers.
4.4.4 Warning labels shall be posted on cabinets containing hazardous
chemicals (acids, bases, oxidizers, or carcinogens).
4.5 Abnormal Conditions
4.5.1 Under the following conditions, employees shall review the appropriate
laboratory procedure or consult with the Lead, Laboratory before
proceeding with the task.
• A new procedure, process, or test is being performed.
• A change or substitution is being made to any of the ingredient
chemicals in a procedure.
• A failure of any of the equipment used in the process. (specially
safeguards such as fume hoods or clamp apparatus)
• A test result occurs that is different than predicted.
4.5.2 If any member(s) of the laboratory staff becomes ill, suspects exposure,
smells chemicals, or suspects a failure of engineering controls, all work
in the laboratory shall cease. All personnel shall exit the laboratory.
The Lead, Laboratory shall immediately conduct an investigation and
document all necessary corrective actions. The Safety and Health
Manager or designee shall be notified immediately. Work shall resume
upon implementation of the necessary corrective actions.
4.6 Safety Containers
4.6.1 Flammable liquids shall be kept in containers specifically designed for
them.
4.6.2 Flammable liquid containers shall be kept closed except when adding or
removing liquid.
4.6.3 The flame arrestor screen shall be kept in place at all times and replaced if
punctured or damage.
4.6.4 Chemicals in safety cans shall be stored in storage areas, not in laboratory
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work areas or hallways.
4.7 Flammable Storage Cabinets
4.7.1 Chemicals with a flashpoint of 100oF or lower shall be stored in a
flammable solvent storage area or flammable storage cabinet. They shall
be used in a vented fume hood, away from any ignition source.
4.7.2 Store only compatible materials inside the cabinet.
4.7.3 Chemicals of similar vapor density shall be stored together (e.g., heavier
than air vapors are vented through the bottom vent and lighter than air
vapors through the top vent).
4.7.4 Any paper or cardboard shall not be stored inside the cabinet.
4.7.5 All storage containers shall be inspected at least monthly.
4.8 Chemical Reactivity
4.8.1 All proper safety precautions shall be used for reactive chemicals
including segregation in storage, and prohibition on mixing with other
chemicals without appropriate personal protection and precautions.
4.9 Laboratory Inspection
4.9.1 The Lead, Laboratory or designee shall inspect and assess chemical
storage areas monthly, document the inspection and forward the
documentation to the Site Safety and Health Manager or designee.
4.9.2 The inspection shall include an evaluation of chemical compatibility. The
Lead, Laboratory shall segregate chemicals that may react based on
reactivity group numbers, SDS information or other source of chemical
reaction information.
4.9.3 The Lead, Laboratory shall examine chemical containers to ensure their
integrity and verify that they are within applicable expiration dates.
4.9.4 The Lead, Laboratory shall verify that all chemical storage areas are
labeled in accordance with 4.4.4 and are posted with lists of reagents that
can and cannot be stored in the same area.
4.10 Eyewashes and Safety Showers
4.10.1 Laboratory personnel shall inspect the plumbed eyewash stations daily and
document the inspection on form CL-SH-PR-150-F1, Eyewash and
Emergency Shower Inspection.
4.10.2 The shower (where available) shall be checked daily to assure that access
is not restricted and that the start chain is within reach. Flow must also be
checked daily for the presence of adequate flow and cleanliness of the
water.
4.10.3 At least monthly, the laboratory personnel shall document on the Eyewash
and Emergency Shower Inspection form that the flow through the safety
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shower is at least 5 gallons in 15 seconds (20 GPM).
4.10.4 Form CL-SH-PR-150-F1 shall be forwarded to the Lead, Laboratory by
laboratory personnel and shall be reviewed by the Lead, Laboratory then
transmitted to document control monthly.
Note: A drench hose is available for use in the groundwater
lab. This hose is not subject to the above inspections.
4.11 Exposure Evaluations and Medical Consultations
4.11.1 Laboratory employees shall receive a physical examination in accordance
with ES-SH-PR-401, Medical Surveillance prior to performing work in the
laboratory.
4.11.2 The employee shall receive appropriate medical treatment for exposure
incidents as determined by Case Management Procedures (ES-SH-PR-
402).
4.11.3 Records of Exposure Evaluations, Medical Consultations, and reports shall
be maintained in accordance with 29 CFR 1910.120.
4.12 Spill Prevention, Control and Response
4.12.1 Laboratory personnel shall follow the established laboratory procedures to
prevent the occurrence of spills.
4.12.2 Walkways shall be kept free of items or materials that cause slips, trips or
falls.
4.12.3 Counters, hoods and sinks shall be kept free of items or materials that
could cause spills.
4.12.4 The Chemical Hygiene Officer shall be immediately notified of spills of
toxic substances or accidents involving any hazardous chemical.
4.12.5 If the event involves any of the implementing criteria from the
Contingency Implementation Plan (CL-SH-PR-500), he or she shall
implement the Contingency Implementation Plan.
4.12.6 If the event does not require implementation of the Contingency
Implementation Plan, the Chemical Hygiene Officer shall:
• Evaluate the event in terms of content, size and location and
determine the appropriate measures for clean-up and disposal.
• Restrict access to the affected area(s), evacuate the affected
area(s), and arrange for immediate medical treatment of affected
individuals, if necessary.
• Document the event and determine corrective actions to prevent
recurrence.
• Notify the Safety and Health Manager or designee.
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• Notify appropriate site management personnel.
• Notify appropriate regulatory agencies and Director of Compliance
and Permitting, if necessary.
5 ATTACHMENTS
5.1 CL-SH-PR-150-F1, Eyewash and Emergency Shower Inspection
5.2 CL-SH-PR-150-F2, Chemical Lab Fume Hood Velocity Record
5.3 CL-SH-PR-150-F3, List of Hazardous Chemicals for Training

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Attachment 5.1
CL-SH-PR-150-F1, Eyewash and Emergency Shower Inspection

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Attachment 5.2
CL-SH-PR-150-F2, Chemical Lab Fume Hood Velocity Record Example

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Attachment 5.3
CL-SH-PR-150-F3, List of Hazardous Chemicals for Training

*Subject to Change as needed*
Bases: Ammonium hydroxide, Sodium hydroxide
Oxidizers: Potassium permanganate, Hydrogen peroxide (30%), Sodium Nitrite
Reducing Agent: Iron powder
Strong Acids: Nitric acid, Hydrochloric acid, Sulfuric acid
Weak Acid: Acetic acid
HF: Hydrofluoric acid
Metals: elemental and solvated Heavy metal standards (Arsenic, Lead, Chromium, Mercury, Cobalt,
Manganese, Iron powder, etc…)
Organics: Nitromethane, benzene-like solvents such as xylenes, toluene
Halogenated Organics/PCBs: Methylene chloride, PCB’s
Treatment: Lime kiln-dust (calcium oxide – calcium carbonate), Calcium Polysulfide, Regenox, ferrous
sulfate, potassium permanganate.
Gases: Arsine, phosphine, ammonia, chlorine, hydrogen sulfide, hydrogen chloride
Liquid/compressed gases: Argon, Nitrogen (asphyxiation hazards) include information on the amount of
air that can be displaced by a tank of liquefied Nitrogen or Argon

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