The URL can be used to link to this page

Home My WebLink AboutDRC-2025-002001UtahDEQ Division of Waste Management and Radiation Control Health Physics Inspection Report INSPECTION REPORT FOR: Energy Solutions DATE OF INSPECTION: May 1, 2025 to May 20, 2025 FACILITY ADDRESS: EnergySolutions Clive Facility 1-80 Exit 49 Grantsville, Utah 84029 FACILITY CONTACT: Thomas Brown, RSO 801-649-2168 Dale Thome, ARSO 801-649-2219 APPLICABLE REQUIREMENTS: References • Radioactive Materials License UT2300249; • Radioactive Materials License UT2300478; • R313-15-204, Determination oflntemal Exposure • R313-15-205, Determination of Prior Occupational Dose ES Health Physics Manual; EnergySolutions Radiation Safety Manual CL-RS-PR-210, Personnel External Radiation Monitoring CL-RS-PR-221, Bioassay Monitoring and Internal Dose Determination CL-IN-PR-450, Instrument Operation TYPE OF INSPECTION: Module 7, Dosimetry PARTICIPANTS: Kevin Camey -WMRC Inva Braha -WMRC Bryan Woolf -WMRC Curtis Kirk -ES Dale Thom -ES Thomas Brown -ES REPORT PREPARED BY: Kevin Camey FACILITY DESCRIPTION: LLRW and MW disposal site. OPENING MEETING May 1, 2025@ 0945 with Thomas Brown and Curtis Kirk ofEnergySolutions. Inspector(s) discussed the aspects of the inspection and requested access to dosimetry records. ES staff agreed to accommodate the inspection. MANAGEMENT ACTIVITES: During the inspection, routine site activities were being conducted at the Clive facility. Activities included waste placement at LLRW and CWF, container receipt and unloading, container decontamination, Mixed Waste Treatment, thermal desorption, laboratory, unloading activities at both East and West railcar Rotary Facilities and various other site compliance and maintenance activities. NARRATIVE: The Inspector(s) reviewed various personnel files filed in the Health Physics Office at the Clive Administration Building. With the help of the Assistant Radiation Safety Officer (ARSO), personnel records were chosen: five (5) workers employed less than one (1) year at Clive, five (5) workers employed greater than five (5) years at Clive and fifteen (15) workers chosen randomly. Records were reviewed for the inclusion of Previous Radiation History Form, CL-RS- PR-210-F2, Hazardous Screening Certification Form, CL-RS-PR-210-F7, and Bioassay Submittal per Bioassay Monitoring Form, CL-RS-PR-221-Fl. Records were also reviewed for completion of special in-vitro bioassay monitoring required by ES procedures. The ARSO was interviewed as to any lost dosimetry incidents and any assigned dose based on bioassay results. One incident of lost dosimetry occurred during this calendar year and an assigned dose based on bioassay results. Reviewed records were complete and compliant with ES Procedures and Utah Rules. Records were also reviewed for who had exceeded the 100 mR procedural dose limit for the first half of 2024. All Semiannual TEDE Exceedance Investigation Forms, CL-RS-PR-210-F5 have been completed for these employees. The Inspector also observed the ARSO perform a lung count (in-vivo bioassay) at the site's Canberra Model 2280 Accuscan II Lung Counter. Records were reviewed pertaining to the operator's (ARSO) qualifications, calibration, daily and weekly background counts and quarterly surveillance. Field observations were made by the Inspector for proper personnel dosimetry use and proper storage of dosimetry badges. ISSUES: No discrepancies were noted during this inspection. All records were readily available and found to be complete and accurate. The lung counter and bioassay programs were administered in accordance with site procedures and state rules. CLOSEOUT MEETING: May 20, 2025 @ 1100 with Dale Thorn, Thomas Brown and Curtis Kirk ofEnergySolutions and Kevin Carney, Inva Braha and Bryan Woolf of WMRC. The inspector(s) discussed the results of the inspection with ES staff. The inspector(s) informed ES staff that there were no discrepancies found during the inspection and thanked them for their cooperation. ES staff had no comments. NAME: SIGNATURE: DATE: Inspector( s): Kevin Carney Inva Braha Bryan Woolf Section Manager: Larry Kellum UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL HEALTH PHYSICS INSPECTION MODULE 7 (rev. 11) RADIATION PROTECTION PROGRAM-DOSIMETRY EnergySolutions Clive Site License Numbers UT2300249 and UT2300478 Inspection Dates: Start May 1, 2025 End May 20, 2025 Inspector(s): Kevin Carney, Inva Braha, Bryan Woolf Related Documents Utah Rules R313-15-204, Determination oflnternal Exposure R313-15-205, Determination of Prior Occupational Dose EnergySolutions Radiation Safety Manual CL-RS-PR-210, Personnel External Radiation Monitoring CL-RS-PR-221, Bioassay Monitoring and Internal Dose Determination CL-IN-PR-450, Instrument Operation Dosimetry Records 1) Have any employees or contractors been assigned dose based upon either bioassay urinalysis or lung count in the past year? [g!Yes □No la) If yes, have the doses assigned been determined in accordance with Utah Rule R313-15-204 and CL-RS-PR-221? [gl Yes □No 0 N/A Comments: Records reviewed at Administration Building Health Physics Office. n .... ,....,.... 1 ,.....po 2) -Has the licensee maintained a completed form DRC-05, or other clear and legible record, for each individual reviewed? (R313-15-205(4)) (Review dosimetry records of25 individuals including at least 5 individuals employed at Clive for more than 5 years and at least 5 individuals employed at Clive for less than one year) [8J Yes Comments: Reviewed personnel files. 5 > 5 years, 5 < 1 year and 15 randomly selected. ONo 3) Have TLD's, or equivalent, been issued to any individuals reviewed, who have not met the following requirements? (CL-RS-PR-210, § 4.1.10) (Review dosimetry records of 25 individuals including at least 5 contractors, 5 individuals employed at Clive for more than 5 years and at least 5 individuals employed at Clive for less than one year) • Completion of a Previous Radiation History Form CL-RS-PR-21 0-F2 • Completion of a Hazardous Screening Certification CL-RS-PR-210-F7 • Bioassay Submittal per Bioassay Monitoring CL-RS-PR-221-Fl [8J Yes Comments: Reviewed personnel files. 5 > 5 years. 5 < 1 year and 15 randomly selected. ONo 4) Have there been any reported personnel exposures in excess of 100 mrem TEDE for the first or second halves of the past year? (CL-RS-PR-210 § 4.1.13) [8J Yes ONo 4a) If yes, have they been investigated and reported on the Semiannual TEDE Exceedance Investigation Form, CL-RS-PR-210-F5? [8J Yes ONo □NIA Comments: Dale Thome was able to show to the Division Inspectors document copies of the semiannual TEDE Exceedance form in the past year. dating on 1/13/25 (CWF employee) 5) Have there been any lost TLDs, or equivalent, by any worker whose exposure would have been expected to result in a dose greater than 1 mrem in the past year? (CL-RS-PR-210 § 4.4) 1:8:] Yes 0No If yes, number of lost TLDs, or equivalent: 1 Number of lost TLD, or equivalent reports reviewed: --~l __ 5a) Has the Dosimetry Technician initiated a Record Dose Evaluation Form(s) CL-RS-PR-210-F3 for the worker(s)? (§ 4.4.3.1) 1:8:] Yes D No □NIA 5b) Has the Dosimetry Technician completed the Record Dose Evaluation Form(s) CL-RS-PR-210-F3? (§ 4.4.4.3) 1:8:] Yes D No □NIA 5c) Has a copy of the Record Dose Evaluation Form(s) CL-RS-PR-210-F3 been kept in the Record Dose Evaluation Form book and the original placed in the employees' dosimetry file?(§ 4.4.4.3) 1:8:] Yes D No □NIA Comments: Upon reviewing the documentation, the Division Inspectors verified one case of lost TLD on 10128124. Dale Thome assigned the individual a new Dosimeter, although the lost one was found hours later. Bioassay Monitoring 6) CL-RS-PR-221 § 4.1.1.514.1.1.6 state: "Three in-vitro special samples shall be collected on a monthly basis representatively for individuals working in areas with an elevated potential of intake. Samples shall be collected from workers at each of the following areas: • Mixed Waste Facility, • LLRW Facility/I 1 e. (2) Facility. These monthly specials shall be analyzed for isotopic thorium (TH-230 and TH-232), gross beta-K- 40, Ra-226 and total Uranium, at a minimum. Samples from the Mixed Waste Facility are also analyzed for Am-241. Other isotopic analyses may be specified by the RSO as needed." Has the licensee performed these required special samples within the last year? 6a) Have the individuals sampled included: • Workers from Mixed Waste? • Workers from the LLRWll le.(2) Facilities? 1:8:] Yes 1:8:] Yes 1:8:] Yes □No □No □No Comments: ---------------------------------- 6b) Have these samples been analyzed for the minimum required radionuclides? !ZI Yes □No Comments: All samples were analyzed for thorium (TH-230 and TH-232), ~ross beta-K-40. Ra-226 and total Uranium. 7) CL-RS-PR-221 § 4.1.1.7 states: "At the end of each quarter, five individuals that performed work during that quarter in areas with an elevated potential of intake will be randomly selected to submit routine samples. These samples may be either in-vivo or in-vitro as determined by the RSO. " Has the licensee performed these required routine samples within the last year? !ZI Yes □No Comments: ----------------------------------- 8) CL-RS-PR-221 § 4.1.1.8 states: "Special samples shall be collected.from individuals that are potentially exposed to 8 DAC-hrs (20 mrem) as measured using work area air sampling. When a special sample is collected as a result of air sample analysis, it may not be considered to be one of the routine samples as outlined in 4.1.1. 5 of this procedure. " Have any special samples been collected in reference to section 4.1.1.8? OYes □No Comments: ----------------------------------- Lung Counter Operation (CL-IN-PR-450 § 4.3) The steps in this section are performed by observation of personnel performing lung count(s) and review of records. 9) CL-IN-PR-450 § 3.3.11.2 states: "All radiation sources used during implementation of this procedure SHALL be stored in a secure location inside a lock box that is labeled with source activities, isotopes, reference dates, the words "Caution Radioactive Material," and the universal trefoil symbol." Were the sources for the Lung Counter found to be stored in a secure location, inside a lockbox and properly labeled? [8J Yes ONo Comments: Sources were found to be double locked in a desk in the HP office at the Administration Building. Lock box containing sources was properly labeled. 10) Was the operation of the lung counter performed by an individual that has completed Q1028, Lung Count Qualification? (CL-IN-PR-450 § 3.3.11.4) [8J Yes ONo Comments: Lung Count of employee was observed on May 1, 2025 by WMRC Inspectors and performed by the Assistant RSO. Q1028 gual card on file. 11) Has the efficiency calibration of the Lung Counter been performed within 2 years of the observed operation, by the Radiological Engineer and an approved vendor? (CL-IN-PR-450 § 3.3.11.8) [8J Yes ONo lla) CL-IN-PR-450 § 3.3.11.8 states: "Note: After the biennial (every other year) calibration has been completed, a minimum of 30 readings will be taken to establish the reference activity to be used for the calibration checks. " Have the above requirements been met? [8J Yes ONo Comments: Lung Counter was calibrated on January 30, 2025 by Mirion Services. Cal due is January 30, 2027. The subsequent thirty, one-minute counts were performed on January 30, 2025 as documented on the ES Lung Counter computer system. 12) Have the quarterly surveillances been performed? CL-IN-PR-450 § 3.3.11.5 states: "The Health Physics Instrument Technician, or any personnel assisting the Health Physics Instrument Technician, SHALL follow the guidance of ES-QA-PR-002, Quality Assurance Surveillance, while performing quarterly surveillance as required by this procedure. " [g!Yes □No Comments: Records observed in WBC Logbook located in the Lung Counter Room at the Administration Buildin . 13) Has a minimum one-minute background count been conducted prior to performing the observed lung count bioassay measurement(s)? (CL-IN-PR-450 § 4.3.1) [gl Yes □No Comments: One minute background performed prior to observed lung count. Record on ES Lung Counter com uter. 14) Has the licensee performed the Weekly Environmental Background Checks (one hour count) over the past year? (CL-IN-PR-450 § 4.3.2) [gl Yes □No Comments Record on ES Lung Counter computer. Review the records of several random lung counts over the last several months and verify that the Background and Energy/Efficiency Calibration Checks were performed for the days the lung counts were performed. 15) Were the Daily Calibration Checks performed for the days the reviewed lung counts were performed? C8J Yes □No Comments: Checked five recently performed lung counts. Records indicate that the Daily Calibration Checks were performed as required. External Monitoring 16) Were any TLDs, or equivalent, found to be stored outside of the locations assigned by the Dosimetry Technician (DT)? (CL-RS-PR-210 § 4.1.1) OYes C8J No Comments:---------------------------------- 17) Were Control TLDs, or equivalent, found to be stored at the locations assigned by the Dosimetry Technician (DT)? (CL-RS-PR-210 § 4.1.4) C8J Yes □No Comments: The Control TLDs were found at the employee dosimeter storage location in the LLRW Operations Building. 18) Were all observed permanently badged radiation worker personnel found to be wearing their TLD, or equivalent, while inside the Restricted Area? (CL-RS-PR-210 § 4.1.5) C8J Yes □No Comments: Personnel were observed at the LLRW Building Access Control Point as they were returning to the Section 32 Restricted Area for their afternoon shift. Approximately 30 to 40 personnel were observed. All displayed proper dosimetry upon entry. Additional Comments: Opening Meeting was on May 1, 2025 @ 0945 with ES Staff Curtis Kirk and Thomas Brown, WMRC Inspectors Kevin Carney, Inva Braha and Bryan Woolf. Closeout meeting was on May 20, 2025 @ 1100. Inspectors communicated to ES Staff Dale Thom, Curtis Kirk and Thomas Brown that no discrepancies were noted during the inspection.