HomeMy WebLinkAboutDRC-2025-002242 CLIVE SITE
LETTER OF TRANSMITTAL DATE: 7/7/2025 ATTN: LLRW
CC; Treesa Parker Karen Kirkwood RE: Transmittal 2025-041
Description of Documents Transmitted Qty
See attached updates for Safety and Health. CL-SH-PR-500 Rev 8, Contingency Implementation 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
Electronic documents, once printed, are uncontrolled and may become outdated.
Refer to the Intranet or the Document Control authority for the correct revision.
CL-SH-PR-500
Contingency Implementation Plan
Revision 8
Authored By:
Curtis Kirk, Quality Assurance Director Date
Reviewed By:
Vern Rogers, Regulatory Affairs Director Date
Approved By
Thomas A. Brown, Radiation Safety Officer
(RSO) Date
Approved By
David Booth, GM of Clive
Date
Non-Proprietary New
Proprietary Title Change
Restricted Information Revision
Safeguards Information Rewrite
Sensitive Security Information Cancellation
Digitally signed by Curtis Kirk
DN: C=US, OU=EnergySolutions, O=Quality Assurance, CN=Curtis Kirk, E=ckirk@energysolutions.com
Reason: I am the author of this document
Location: your signing location hereDate: 2025-07-01 09:49:48
Foxit PhantomPDF Version: 9.7.5
Curtis Kirk
Vern C. Rogers Digitally signed by Vern C. Rogers
DN: cn=Vern C. Rogers, o=EnergySolutions, ou=Waste Management
Division, email=vcrogers@energysolutions.com, c=US
Date: 2025.07.03 07:14:27 -06'00'
Thomas Brown Digitally signed by Thomas Brown
Date: 2025.07.07 06:59:16 -06'00'
Digitally signed by David F Booth
DN: C=US, O=EnergySolutions, CN=David F Booth, E=dbooth@energysolutions.comReason: I am approving this document.
Location: NA
Date: 2025-07-07 08:05:32
Foxit PhantomPDF Version: 9.7.5David F Booth
CL-SH-PR-500
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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 .............................................................................................................................. 4
3.1 Definitions ...................................................................................................................... 4
3.2 Responsibilities .............................................................................................................. 8
3.3 Precautions and Limitations ...................................................................................... 11
3.4 Records......................................................................................................................... 13
4 REQUIREMENTS AND GUIDANCE ................................................................................ 14
5 ATTACHMENTS ................................................................................................................. 25
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1 PURPOSE AND SCOPE
1.1 Purpose
This Plan details instructions for implementation of the currently approved
Contingency Plan, Attachment II-6 of the State-issued Part B Permit. The Plan
describes actions to protect personnel and/or the environment in the event of an
explosion, fire, unplanned release to the environment, or a medical emergency.
This Plan also provides supplemental information required by UAC R313-22-
32(8)(c).
1.2 Scope
This Plan applies to all EnergySolutions contractors, visitors, and employees who
enter the EnergySolutions premises at Clive. The Clive premises include Section
32 and adjacent sections owned by EnergySolutions. EnergySolutions facilities
affected by this Plan are described in Exhibit II-6 of the Contingency Plan. The
facility is located in a desert area that Tooele County has zoned for Hazardous
Waste Industries (MG-H).
2 REFERENCES
2.1 CL-TN-PR-100, Clive Facility Training
2.2 CL-SH-PR-100, Clive Health and Safety Plan
2.3 ES-SH-PR-308, Respiratory Protection
2.4 CL-LB-PR-003, Sample Control
2.5 ES-AD-PR-005, First Notifications
2.6 ES-AD-PR-008, Condition Reports
2.7 ES-SH-PR-201, Control of Hot Work
2.8 ES-SH-PR-301, Bloodborne Pathogens
2.9 MOU with University of Utah Health Sciences Center
2.10 State-issued Part B Permit
2.11 11e.(2) Radioactive Material License UT2300478
2.12 Federal Register, Vol. 61, No. 109 / Wednesday, June 5, 1996
2.13 40 CFR 261.20-24 and 30-33
2.14 40 CFR 761.120-135
2.15 Radioactive Material License UT2300249
2.16 Utah Administrative Code (UAC) R313-22-32(8)(c)
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3 GENERAL
3.1 Definitions
3.1.1 Permittee – EnergySolutions Clive Facility.
3.1.2 Incident – Any occurrence that results in the implementation of this Plan.
3.1.3 Initial Identifier – The first person who recognizes a condition exists
which requires implementation of this Plan.
3.1.4 Controlled Area – The property contained within EnergySolutions Clive
Facility in Section 32.
3.1.5 Restricted Area – The area to which EnergySolutions limits access for the
purpose of protecting individuals against undue risks from exposure to
radiation and radioactive materials.
3.1.6 Exercise Drill – A preplanned practice scenario conducted for the purpose
of training managers, supervisors, and employees in the proper response to
emergency situations.
3.1.7 Post Evacuation Gathering Point – The designated locations to which
affected evacuees gather for purposes of establishing personnel
accountability and providing instructions.
3.1.8 Post-Evacuation Roll Call – The use of Visitor Logs, Restricted Area
Access Logs, or other personnel lists to identify missing persons.
3.1.9 Contingency Plan – The Plan implemented during an unplanned event
involving an explosion, fire, or spontaneous discharge to the environment
(spill) at the EnergySolutions Clive Facility.
3.1.10 Medical Emergency – A serious personnel injury or illness requiring
immediate response from site EMS personnel and/or immediate transport
to a medical facility.
3.1.11 First Aid Response – A personnel injury or illness needing assistance from
site EMS personnel but not requiring immediate response or transport to a
medical facility.
Note: When in doubt, personnel should assume an injury or illness is
a medical emergency.
3.1.12 Minor First Aid Injury – A minor injury or illness which does not require
response from site EMS personnel.
3.1.13 Site Emergency Medical Services (EMS) Personnel – Site EMT’s and First
Responders.
3.1.14 Medical Direction – The oversight of patient care aspects for an EMS
system by an applicable Medical Director to include:
Off-Line medical direction consisting of Standing Orders issued by the
Medical Director allowing EMT’s to give specific medications or
perform specific procedures without speaking to the Medical
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Director or another physician.
On-Line medical direction consists of orders from the on-duty Physician
given directly to the EMT in the field by radio or by Telephone.
3.1.15 Secondary Containment – Any engineered facility/structure approved by
the appropriate regulatory agency that prevents the release of liquid to the
environment. Secondary Containment must be capable of containing
100% of the capacity of the largest tank, or 10% of the total capacity of all
tanks, whichever is greater.
3.1.16 Explosion – A sudden release of pressure, gas, and heat involving any
chemical compound, mixture, or device.
3.1.17 Fire – Visible or non-visible flames associated with the ignition and
burning of any solid, liquid, or gas. Overheated engines, transmissions,
rear ends, brakes, and carburetor backfires, or other combustibles that do
not involve waste material, chemicals, or hazardous material shall not be
considered as reportable fires. Controlled flames associated with hot work
are not regarded as fires (See ES-SH-PR-201, Control of Hot Work).
Note: The Contingency Plan shall be implemented for all fires as
defined above. However, the CL-SH-PR-500-F1 form,
Attachment 5.1 is not required if it is determined a fire is not
reportable. At a minimum, non-reportable fires shall be
documented by submitting a written First Notification in
accordance with ES-AD-PR-005.
3.1.18 Unplanned Release (Spill) – A spontaneous discharge into the
environment of radioactive or hazardous material (including elements,
compounds, and mixtures) by which the material may reach water, the
ground, groundwater, and/or the atmosphere. Table 1 below indicates the
quantities of spilled material that require implementation of the
Contingency Plan and under what circumstances they are subject to
regulatory reporting requirements.
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TABLE 1
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Item Quantity Contingency Plan
Implementation Reportable
Radioactive Waste > 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, 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 > 25 gallons Yes
Yes, if spill occurs
outside of Secondary
Containment
PCB Waste
< 1 lb of PCBs
by weight Yes No
> 1 lb 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 Utah Division of Environmental Response and
Remediation.
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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 > 25 gallons Yes Yes
PCB Waste
< 1 lb of PCBs
by weight Yes No
> 1 lb 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)
3.1.19 Hazardous Material – Any substance or mixture of substances having
properties capable of producing adverse effects on the health and safety of
humans or the environment and includes all listed and/or characteristic
hazardous wastes.
3.1.20 Listed Hazardous Waste – Any waste material listed as hazardous under
the provisions of 40 CFR 261.30-33 or by equivalent state environmental
regulations. These wastes are categorized using letter designators to
indicate the source of the waste. “F” code is Non-specific sources. “K”
code is Specific sources. “U” code is off-specification toxic products.
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“P” codes are acutely hazardous off-specification products.
3.1.21 Characteristic Hazardous Waste – A code “D” waste material that
exhibits one or more of the hazardous characteristics of ignitability
(flammable), corrosivity, toxicity, or reactivity as defined in 40 CFR
261.20-24.
3.1.22 Leachate – Any liquid, including suspended components in the liquid that
has percolated through or drained from hazardous waste.
3.1.23 Potentially Contaminated Liquid – A liquid that has come in contact with
a radioactive or hazardous material but has not been analyzed chemically
or radiologically.
3.1.24 PCB – Any chemical substance limited to the biphenyl molecule that has
been chlorinated to varying degrees or any combination of media which
contain such substances.
3.1.25 PCB Waste – Waste contaminated with PCBs at concentrations exceeding
50 ppm. Spill response regulations for PCB Waste are codified in 40 CFR
761.120-135. Spill response includes double washing/rinsing solid
surfaces and excavation/backfill of soil. For liquid spills of any quantity
with contamination greater than 500 ppm, or greater than 270 gallons with
contamination less than 500 ppm; the area must be isolated, the extent of
the visible contamination documented, and the cleaned area sampled to
ensure contamination has been removed.
3.1.26 Structural Fire Fighting – The physical activity of fire suppression inside
of buildings or enclosed structures which are involved in a fire situation
beyond the incipient stage.
3.1.27 Incipient Stage Fire – A fire which is in the initial or beginning stage and
which can be controlled or extinguished by portable fire extinguishers,
Class II standpipe, or small hose systems without the need for protective
clothing or breathing apparatus.
3.1.28 Immediately Dangerous to Life or Health (IDLH) – An atmosphere that
poses an immediate threat to life, would cause irreversible adverse health
effects, or would impair an individual's ability to escape from a dangerous
atmosphere.
3.1.29 Buddy System – Two people who operate together as a single unit so they
are able to monitor and help each other during an emergency response.
3.1.30 Radiation Safety Access Control Database – An integrated radiation
safety records management and access control system designed to assist in
the collection, maintenance, and reporting of radiation protection
information.
3.1.31 Alert – means events may occur, are in progress, or have occurred that
could lead to a release of radioactive material but that the release is not
expected to require a response by off-site response organizations to protect
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persons off-site.
3.1.32 Site Area Emergency – means events may occur, are in progress, or have
occurred that could lead to a significant release of radioactive material and
that could require a response by off-site response organizations to protect
persons off-site.
3.2 Responsibilities
3.2.1 Initial Identifier – Shall immediately implement The Contingency Plan
and notify Security upon discovery of a fire, explosion, unplanned release
to the environment, or a medical emergency. This individual shall remain
in charge unless relieved by someone with more expertise such as an EMT
or First Responder or by the Emergency Coordinator.
3.2.2 Emergency Coordinator (EC) shall (as needed):
Ensure the safety of all personnel involved in emergency actions.
Respond and manage emergency situations in accordance with this Plan
and take all necessary steps to obtain and mobilize the necessary
resources if additional manpower or equipment is required.
Contact the (RSO) or designated Radiation Safety Personnel regarding
protection from airborne and other radiological safety concerns or
whenever there is a fire involving radioactive waste materials.
Contact the Health and Safety Manager or designee regarding protection
from chemical or industrial safety concerns.
Ensure the appropriate Spill Response Team has been activated.
Make verbal notifications, to include the applicable Site Manager as soon
as reasonably feasible and ensure a written First Notification is
submitted in accordance with ES-AD-PR-005, First Notifications.
• Determine if the necessary response activities will extend past the
capability of the present on duty personnel involved with the event and
use qualified contractors and contracted equipment as deemed
necessary.
• Assign site personnel to assist in response and remediation to
efficiently manage the incident. This action may include Spill
Response Team members, Emergency Medical Technicians, Radiation
Safety personnel, Safety personnel, Chemistry Lab personnel or others
deemed appropriate for the circumstance.
• 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:
(1) Use of Security Cameras to verify that the RED strobe light located
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on top of the Fire Water Pump House has activated or,
(2) Assign an employee to drive to the Fire Water Pump House and
visually verify that the pump is operational.
Notify the appropriate offsite Emergency Response Agency and
coordinate the remaining efforts with them in the event the
containment, remediation, and/or cleanup is beyond the capability of
EnergySolutions resources.
Initiate a Condition Report if deemed necessary.
Completing sections two and four of CL-SH-PR-501-F1, Contingency
Notification Report and transmitting the completed Contingency
Notification Report to Document Control within 30 days of
completion. If a Condition Report has been initiated as a result of the
Contingency, a copy of the completed Contingency Notification
Report shall be included with the Condition Report file.
3.2.3 Reserved for future use
3.2.4 Radiation Safety Officer (RSO) – Shall review this Plan annually or when
deficiencies are identified or required by changing regulations and making
revisions as necessary. The RSO is responsible for ensuring the safety
aspects for actions undertaken during a contingency are carried out in
accordance with this and other applicable Safety & Health (S&H)
procedures. This shall include, but not limited to, such areas as material
handling, heavy equipment use, electrical safety, EMT/1st Aid/CPR
Responder, and general safety support to the responding EC, Laboratory,
Radiation Safety Personnel, Security, and Access Control Personnel. The
RSO is also responsible for evaluating implementations of this Plan in
light of applicable radiological regulatory requirements.
3.2.5 Health and Safety Manager – Shall ensure the safety aspects for actions
undertaken during medical emergencies are carried out in accordance with
this and other applicable Safety & Health Procedures and is responsible
for ensuring employees and contractors are trained on the provisions of
The Contingency Plan and this procedure.
3.2.6 Chemistry Laboratory Personnel – Shall respond to any implementation of
The Contingency Plan as directed by the EC. Specifically, these personnel
may be asked to provide information regarding chemical hazards of the
hazardous waste streams, pH testing and Paint Filter testing of liquid spills
or releases, and other sampling services in support of remediation efforts.
3.2.7 Radiation Safety Personnel – Shall respond as directed by the EC in
support of any implementation of The Contingency Plan, specifically,
these personnel may be asked to provide information regarding the
radiological hazards associated with hazardous waste streams, personnel
monitoring, and sampling services in support of remediation efforts and
are also responsible to monitor open wounds received by personnel within
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contaminated areas.
3.2.8 Emergency Medical Technicians (EMT) – Shall evaluate and treat injured
personnel and are to advise site management and the EC (if applicable) on
matters regarding employee injuries with respect to the feasibility,
necessity, and practicality of various modes of transport. They are
specifically responsible to recommend the use of AirMed patient
evacuation services.
3.2.9 Lead EMT – Shall direct medical aspects of the emergency scene. The
first EnergySolutions EMT to the scene shall serve as the lead EMT unless
relieved by an EnergySolutions EMT with the same or greater level of
experience or training.
3.2.10 First Responders – Shall assist EMT personnel in caring for injured
personnel. If an EMT is unavailable, First Responders shall evaluate and
treat injured personnel and advise site management and the EC (if
applicable) on matters regarding employee injuries with respect to the
feasibility, necessity, and practicality of various modes of transport.
3.2.11 Security – Shall assist the Initial Identifier in following the Contingency
Plan, contact the EC with communication, documentation, and personnel
accountability, and/or the site EMS personnel by providing information
such as wind speed and direction and establishing lines of communication
with outside medical facilities and services, including Air-Med or other
transportation services. Security is also responsible to notify Clive
Department Managers that the Plan has been implemented and for
completing Section 1 of CL-SH-PR-500-F1, Contingency Notification
Report (Attachment 5.1) and forwarding to the EC immediately after
implementation of the Plan.
3.2.12 Site Employees – Shall be authorized to provide medical assistance to
other employees in accordance with their level of training and comfort and
shall seek additional assistance as needed. Employees certified in CPR
shall respond to Medical Emergencies in accordance with their training
when it is safe to do so.
3.2.13 Spill Response Team(s) – Shall provide timely response to spills of
radioactive and/or hazardous waste as directed by the EC.
3.2.14 Spill Response Team Leader – Shall lead Spill Response Team activities
occurring at specific facilities as directed by the applicable Manager. The
Spill Response Team Leader is subordinate to the EC.
3.2.15 Department Managers – Shall ensure personnel are designated and trained
for Spill Response Teams as required by this procedure and are to
designate Spill Response Team Leaders as deemed appropriate.
3.2.16 GM of Clive – Ensures procedural compliance for activities defined
herein.
3.2.17 Compliance and Licensing Department – Evaluate implementations of this
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Plan in light of applicable regulatory requirements to determine regulatory
reportability. If deemed reportable the Compliance and Licensing
Department provides initial and follow-up notifications to all regulatory
agencies, as required. Additionally, Compliance and Licensing personnel
are responsible for completing Section 3 of CL-SH-PR-500-F1
(Attachment 5.1).
3.3 Precautions and Limitations
3.3.1 Safety
3.3.1.1 All personnel on the Clive Site shall respond to an
implementation of the Contingency Plan ONLY after having
evaluated the situation in terms of their personal safety and by
direction of the EC.
3.3.1.2 A medical emergency shall take precedence over other site
operational needs.
3.3.1.3 Personal protective equipment shall be worn by site EMS
personnel in accordance with ES-SH-PR-301, Bloodborne
Pathogens.
3.3.1.4 Site EMS Personnel may respond to off-site Medical
Emergencies (i.e., requests to assist with an I-80 motor vehicle
accident from Tooele County Dispatch) unless otherwise directed
by the GM of Clive or a senior company representative in order
to maintain adequate emergency response capabilities to support
operations.
3.3.1.5 Equipment such as SCBA’s, fire extinguishers, spill kits, gas
sensors, eye washes, safety showers etcetera that are utilized to
mitigate the consequences of incidents shall be maintained
according to manufacturer’s guidelines, industry standards, or
regulations as they apply.
3.3.2 Training
3.3.2.1 In accordance with CL-TN-PR-100, Clive Facility Training,
personnel responding to this Plan shall receive training on the
requirements of this procedure. Refresher training shall also be
conducted on an annual or more frequent (as-needed) basis.
3.3.2.2 At least annually, a medical drill and a contingency plan
exercise/drill along with a fire drill shall be performed in the
Mixed Waste Facility and biennial site wide exercises to test
response to simulated emergencies. For biennial exercises, an
invitation to off-site response organizations is recommended but
is not required. Document and include the following information:
• List of key participation personnel
• Timeline of events
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• Evaluation of response
• Corrective actions (if applicable)
3.3.2.3 Quarterly communications checks with off-site response
organizations shall include the check and update of all necessary
telephone numbers.
3.3.2.4 Spill Response Teams shall be trained in elements of this
procedure, the personal protective equipment to be worn, and
procedures for handling the types of spills applicable to their
designated areas of responsibility and shall be conducted prior to
initial assignment and as deemed necessary by the RSO
thereafter.
3.3.3 Compliance
3.3.3.1 The responding EC shall notify Compliance and Licensing
personnel as soon as possible after implementation of the
Contingency Plan so the required regulatory notifications can be
made.
3.3.3.2 EnergySolutions is a member of the Tooele County Local
Emergency Planning Committee.
3.3.3.3 Currently the Clive Facility has a memo of understanding in
place for employee treatment at the University of Utah hospital.
3.3.3.4 Site EMT’s shall be certified by the Utah Bureau of EMS. First
Responders shall be certified in accordance with requirements of
a recognized training agency (such as the National Safety
Council).
3.3.3.5 EMS personnel shall provide the Health and Safety Manager
with copies of their certifications and give notification whenever
certifications have lapsed. EMT’s who are not currently certified
shall not provide care beyond the First Responder Level.
3.3.3.6 Unless it is being used as a resource in a Contingency, a copy of
the most current revision of the emergency phone numbers and
Contingency Plan shall be kept near every site telephone.
3.3.3.7 This Plan shall be reviewed and amended, if necessary, under
any of the following circumstances:
• Deficiencies are identified.
• 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.
• The emergency contacts, agencies, or EC names, addresses,
or telephone numbers change.
• The list of emergency equipment changes.
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• When new facilities are constructed or existing facilities are
remodeled or demolished.
3.3.3.8 The Tooele County Sheriff Department trained HazMat
Response Team shall respond to the Clive Site to support an
implementation of this Plan when requested by the EC or other
authorized EnergySolutions representative. The HazMat
Response Team may request assistance from the following
Emergency Response units as needed:
• Tooele City Fire Department and HazMat response team;
• Grantsville City Fire Department and HazMat response
team;
• Dugway Proving Ground (U.S. Army) Fire Department and
HazMat response Team;
• Wendover City Fire Department and HazMat response
team;
• Utah State Emergency Services.
Note: Tooele County Dispatch (435-882-5600) shall be called
for outside emergency response needs rather than
dialing 911.
Note: This notification shall not take precedence over the
necessary appropriate response to protect human life or
the environment.
3.3.3.9 Radiation and radioactive emissions from the facility are
monitored in accordance with the Environmental Monitoring
Plan, referenced in Condition 26 of Radioactive Material License
UT2300249.
3.3.3.10 Clive Facility shall complete annual requirements of the
Emergency Planning and Community Right-To-Know Act
(EPCRA).
3.3.4 Spill Response
3.3.4.1 Spill Response Teams shall be established from the Safety,
Operations, Radiation Safety, and Shipping and Receiving
Departments, and the Chemistry Lab (when feasible) to ensure
effective, compliant, and timely response to unplanned releases
to the environment (spills).
Note: The EC may request immediate assistance from
additional site personnel as needed.
3.3.4.2 Spill kits shall be maintained by applicable Managers to ensure
equipment routinely needed in emergency response situations is
readily available.
3.4 Records
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3.4.1 EMS Run Reports (see Attachment 5.4) shall be maintained in a fire-proof
cabinet by Safety and Health personnel and shall have limited access to
protect confidentiality of patient information. EMS Run Reports and
Release of Medical Responsibility forms from the previous calendar year
shall be forwarded to document control annually.
3.4.2 The completed Contingency Notification Report, CL-SH-PR-500-F1, shall
be transmitted to Document Control within 30 days of completion. If, at
the discretion of the Emergency Coordinator, a Condition Report is
initiated as a result of the contingency, a copy of the Contingency
Notification Report shall be included in the Condition Report file.
3.4.3 A copy of page one of CL-SH-PR-500-F1 shall be retained in the Security
office for at least one year.
3.4.4 Documentation for the medical drills, contingency exercise/drills, and fire
drills shall be retained by the Safety & Health Department for at least one
year.
4 REQUIREMENTS AND GUIDANCE
4.1 Implementation of the Plan, General Instructions
4.1.1 The Contingency Plan shall be implemented immediately in the event of
an explosion, fire, or unplanned release to the environment, or when a
medical emergency arises.
4.1.2 Upon discovery of a condition which requires implementation of this Plan
the Initial Identifier shall announce the following information to Security
via radio, telephone, or in person:
“The Contingency Plan is Being Implemented”
Indicate Location;
Indicate Reason (spill, fire, explosion, or medical emergency);
Indicate Name of Person implementing the Plan;
Indicate if any persons are Injured or Trapped, but do not give
individual’s names out during radio communications.
Get an initial call in for special need items such as EMT response, AED,
etcetera.
Note: Personnel names may be stated over the radio using the EMT
channel if such information is essential for a timely response
(e.g., to obtain necessary prescribed medications).
4.1.3 Security personnel shall immediately contact an EMT if it is a Medical
Emergency and/or an EC for any implementation of the Contingency Plan.
4.1.4 The Responding EMT and/or EC Shall:
• Immediately acknowledge the communication and respond to the
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area of the event if appropriate and
• Maintain communication with EMT(s) and facility personnel.
Note: The EMT radio channel or telephone systems are the preferred
communications between site EMS personnel to protect patient
privacy.
4.2 Communication General Instructions
4.2.1 Notification of the implementation of the Contingency Plan shall be
transmitted on the EMT or Emergency Channel via radio or by telephone.
4.2.2 A radio group shall be established for all facility EMTs. A radio
compatible with transmission between facility EMTs shall also be
maintained in the security office and on the facility ambulance.
4.2.3 A list of employees who are trained and qualified to perform the following
responsibilities shall be kept and maintained in the Security office:
Emergency Coordinator
EMT’s
Spill Response members
Ambulance Drivers
First Responders
Confined Space Rescue Team
4.2.4 A list of Emergency Coordinators may be found on page 2 of the currently
approved Contingency Plan located near all site phones.
4.3 Potentially Contaminated Liquids
4.3.1 Leaking shipments of 11e.(2) material shall be managed and reported in
accordance with the requirements found in Condition 10.6 of the 11e.(2)
Radioactive Material License UT2300478.
4.3.2 If the Initial Identifier observes liquids draining from a waste container or
conveyance, he/she shall contact Security and request a Spill Response
Team Leader or EC report to the location or implement the Contingency
Plan.
4.3.3 If the Spill Response Team Leader or EC is unable to determine the source
of the liquid, they shall direct action be taken to control the leaking liquid
and move the container into the restricted area (if outside) for further
evaluation to determine the source. The period of time for evaluation shall
not exceed 24 hours.
4.3.4 If the Spill Response Team Leader or EC determines the liquid is
potentially contaminated by means of analytical (pH, radiation detection,
etc.) or visual (obvious container integrity breach, etc.) observation, the
Contingency Plan shall be implemented.
Note: A liquid in contact with an unpackaged LSA I or SCO I, or a
non-DOT hazardous material is not a potentially contaminated
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liquid.
4.3.5 At a minimum, measure the pH of the potentially contaminated liquid and
record result(s) on the Contingency Notification Report, CL-SH-PR-500-
F1.
4.3.6 Liquid grab sample(s) for radiological analysis may be taken if at least 500
ml of volume is collected using sample equipment provided by the lab.
Note: Analytical results shall be considered suspect for liquid
samples that have come in contact with other contaminated
sources.
4.3.7 Grab samples for radiological and or chemical analysis in the lab require
at least one pre-clean up and one post-clean up sample of the spill area:
Note: For spills outside of the R.A., the area shall be cleaned up to
Unrestricted Release Criteria. Post clean-up samples within the
R.A. shall be evaluated by the RSO or Designee.
4.3.8 Surface swipe for radiological or chemical analysis may be performed to
identify contamination.
4.3.9 All samples submitted to the lab require a Chain of Custody in accordance
with CL-LB-PR-003, Sample Control.
4.3.10 If a Condition Report is initiated, copies of all reviewed analytical data are
to be included in the Condition Report File.
4.4 IDLH Atmospheres
4.4.1 If a potential IDLH atmosphere is present the EC shall ensure employees
use the following guidelines:
4.4.1.1 Employees in emergency situations in an assumed or measured
IDLH atmospheres shall utilize SCBA’s.
4.4.1.2 Employees working in an assumed or measured IDLH
atmosphere shall have visual, voice, or signal line contact with
employees outside the IDLH area who are ready to respond in
the case of an emergency. Those employees who will respond
shall be trained in proper response protocols.
Note: If response involves entering the IDLH atmosphere,
responding employees outside the IDLH atmosphere
shall also be equipped with SCBAs.
4.4.1.3 Employees utilizing SCBA’s shall be trained in accordance with
ES-SH-PR-308, Respiratory Protection.
4.4.1.4 Employees utilizing SCBA’s shall use a buddy system during
activities inside of an IDLH atmosphere.
4.4.1.5 In the case of a respirator failure or if the alarm sounds
employees shall immediately exit the IDLH area.
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4.4.1.6 Appropriate retrieval equipment shall be stationed outside the
IDLH atmosphere for removing the employee(s) who enter(s)
these hazardous atmospheres (where retrieval equipment would
contribute to the rescue of the employee(s) and would not
increase the overall risk resulting from entry).
4.5 Medical Responses
4.5.1 The immediate supervisor of an injured employee shall notify the Health
and Safety Manager of the incident and provide a written report as soon as
reasonably possible in accordance with CL-SH-PR-100, Clive Health and
Safety Plan.
4.5.2 The EC shall (when necessary):
4.5.2.1 Activate the applicable Spill Response Team.
4.5.2.2 Assign the Chemistry Lab and Radiation Safety Personnel to
perform the pre and post-remediation sampling functions when
responding to a spill or release.
Note: These personnel shall not attempt to clean up spills or
take further action beyond emergency measures
unless directed to do so by the EC.
4.5.2.3 Ensure pH sampling and paint filter liquid testing are performed
and documented if sufficient liquid is available in the event of
liquid spills and/or releases.
4.5.2.4 Ensure employees safety during response to an emergency
situation. During any fire event, an evaluation shall be conducted
to ascertain potential hazards to employees. At no time shall
employees be allowed to enter a building to conduct structural
firefighting activities.
4.5.2.5 Immediately identify the character, exact source, amount, and
areal extent of any released material and may do this by
observation or review of facility records or manifest, and if
necessary, by chemical analysis.
4.5.2.6 Take all reasonable measures necessary to ensure explosions,
fires, and releases do not occur, recur, or spread to other
hazardous or radiologically contaminated waste or materials at
the facility.
4.5.2.7 Assess possible hazards to human health and/or the environment
that may result from an explosion, fire, or release.
4.5.2.8 Consider both the direct and indirect effects of the event, which
include, but are not limited to the following:
Toxic, irritating, or asphyxiating gases that are generated;
Potential for explosion(s);
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Potential for fire(s);
Effects of hazardous surface water run-off from water or
chemical agents used to control fire or heat-induced
explosions;
The release of radioactive elements to the atmosphere or
groundwater.
4.5.2.9 Review Section 1 of the Contingency Report (Attachment 5.1),
for accuracy and make any corrections necessary.
4.5.2.10 Complete Section 2 of the form as well as document the site
notification and details/results of the post implementation
critique meeting in Section 4.
4.5.2.11 Generate a condition report in accordance with ES-AD-PR-008 if
deemed necessary.
4.5.2.12 Determine if any of the events holds the potential to threaten
human health, safety, or the environment outside the boundaries
of the Controlled Area of the facility.
4.5.2.12.1 If determination is made, the following people shall
be notified:
Radiation Safety Officer
Manager, Compliance and Permitting
Quality Assurance Manager and
GM, Clive Facility
4.5.2.13 Make an assessment to determine if evacuation of local areas
may be advisable and immediately notify the appropriate local
authorities as necessary.
4.5.2.14 Remain available to assist local authorities with the evacuation
decision-making process.
4.5.2.15 For Medical Emergencies, the EC shall (when necessary):
• Direct the necessary auxiliary patient care efforts such as
obtaining U-Can (Utah Emergency Response Radio)
from Security, provision of transport vehicles,
arrangement of drivers, preparation of landing zone,
managing spectators, etc.
• Ensure appropriate crowd-control measures are taken to
keep non-essential employees from interfering with site
EMS response and to protect patient privacy.
• Notify all affected personnel regarding the termination of
the Medical Emergency with any necessary instructions
for follow-up actions and/or resumption of normal
activities.
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• Ensure blood and other potentially infectious materials
are segregated and disposed in accordance with ES-SH-
PR-301 Bloodborne Pathogens.
• Notify the Health and Safety Manager of the incident in
accordance with CL-SH-PR-100, Clive Health & Safety
Plan, and ES-AD-PR-005, First Notifications, and
conduct a post-incident debriefing with responding Site
EMS Personnel as deemed appropriate or as directed by
the Health and Safety Manager.
4.5.3 For Contingency implementations regarding a fire, explosion, or release,
Compliance and Licensing personnel shall:
4.5.3.1 Provide verbal notification to the Utah Division of Waste
Management and Radiation Control (DWMRC) within 24 hours.
4.5.3.2 Submit a written report to the Director of the DWMRC within
15-calendar days. The following information shall be provided
in the report:
• the name, mailing address, and telephone number of the person
reporting the incident;
• the address and telephone number of the Facility;
• the date, time, and type of incident (fire, explosion, or spill);
• the name and quantity of material(s) involved;
• the extent of injuries, if any;
• an assessment of actual or potential hazards to human health or
the environment, where this is applicable; and
• the estimated quantity and disposition of recovered material that
resulted from the incident.
4.5.3.3 Provide verbal notification to the Director of the DWMRC
within one hour of the site declaring an emergency that requires
the use of off-site resources (described in Section 3.3.3.7).
4.5.4 Affected and/or Responding Facility Personnel shall:
4.5.4.1 Evaluate the situation in terms of their personal safety and take
appropriate steps to protect themselves prior to taking any action
to remediate the incident.
4.5.4.2 When necessary, evacuate the area and remain away from the
incident until authorized to enter by the EC.
4.5.4.3 Take action to stop or mitigate the incident (i.e., turn off a
leaking valve, place absorbent pads over spilled liquids), if the
situation does not pose a serious personal health, safety, or
radiological exposure risk.
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4.5.4.4 Warn others about the incident.
4.5.4.5 Isolate the areas affected by the incident.
4.5.4.6 Prevent or minimize the spread of contamination by establishing
access boundaries.
4.5.4.7 First Responders shall assist EMT’s in the performance of their
duties when required.
4.5.5 The Spill Response Team shall:
4.5.5.1 Evaluate the scene of a spill in terms of personal safety prior to
responding to a spill.
4.5.5.2 Obtain the necessary spill response bag and other necessary
items from spill kits.
4.5.5.3 Take action to stop or mitigate a spill in accordance with
previous training and/or instructions from the Spill Response
Team Leader or EC.
4.5.5.4 Collect samples and perform photographic documentation as
necessary.
4.5.5.5 Assist clean-up of a spill in accordance with instruction from the
EC.
4.5.6 EMS Personnel shall:
4.5.6.1 Respond immediately to the specified location, evaluate the
injured personnel and make recommendations to the EC as to the
required medical treatment and the appropriate mode of patient
transport if necessary.
Note: In order to limit the effect on operations, EMT’s and
First Responders who are not required to be on scene
shall be released by the lead EMT.
4.5.6.2 The first EnergySolutions EMT to the scene shall serve as the
Lead EMT and direct medical aspects of the scene unless
relieved by an EnergySolutions EMT with the same or greater
level of experience or training.
4.5.6.3 Evaluate the situation in terms of their own personnel safety and
employ appropriate body substance isolation techniques.
4.5.6.4 Request assistance from other site EMS personnel as necessary.
4.5.6.5 Determine if transport or referral to a medical facility is
recommended.
Note: Decontamination shall be performed as necessary in
accordance with Section 4.5.7 of this procedure.
4.5.6.6 Implement the Plan for Medical Emergencies (if not already
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implemented).
4.5.6.7 Treat patients in accordance with protocols established by the
Utah Bureau of EMS and/or orders given by local assisting
Medical Direction.
4.5.6.8 Document care given using an appropriate run report (See
Attachment 5.4, “Example EMS Run Report”) and forward a
copy to the Health and Safety Manager. A copy of this form
shall also be given to receiving EMS personnel during transfer of
the patient when necessary.
4.5.6.9 Ensure blood and other potentially infectious materials are
segregated and disposed in accordance with ES-SH-PR-301
Bloodborne Pathogens.
4.5.6.10 Clean and restock applicable emergency medical equipment and
transport vehicles upon completion of response to a Medical
Emergency. The Safety Technician(s) shall be notified of
used/missing supplies or items that need to be procured.
4.5.7 Decontamination of an injured person
4.5.7.1 Under the direction of a qualified Radiation Safety Technician
and an EMT, injured patients who require decontamination shall
be decontaminated to the maximum extent possible.
4.5.7.2 When feasible, decontamination shall be performed while the
emergency transport provider is en-route if transport is to be
provided by an offsite agency.
4.5.7.3 EnergySolutions has a memo of understanding with the
University of Utah allowing for transport and treatment of
contaminated patients. The protocols for, “Contaminated Patient
Transfer Instructions” Attachment 5.3 shall be followed if
immediate transport of a potentially contaminated patient is
necessary.
4.5.7.4 EnergySolutions Emergency Transport Vehicle may be used to
transport a contaminated patient to the closest available suitable
medical facility only if the RST’s or the EMT determines
decontamination is not feasible.
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4.5.7.5 Medical treatment of the patient shall always take precedence
over decontamination efforts.
4.5.8 First Aid Response
4.5.8.1 Upon discovery of a situation in which a personnel injury or
illness requires assistance from site EMS personnel but does not
require immediate response or transport to a medical facility,
personnel shall:
• Evaluate the situation in terms of their own personal
safety;
• Notify their immediate supervisor, and
• Contact a Site EMT or First Responder.
4.5.9 Minor First Aid Injuries
4.5.9.1 Personnel shall:
Notify their immediate supervisor of any injury.
Notify their immediate supervisor of any illness which may
affect their ability to work safely.
Bandage open wounds as necessary to prevent infection; and
Log equipment removed from stationary first aid kits on the
associated first aid supply log (if applicable).
4.5.10 Blood and other potentially infectious materials shall be segregated and
disposed in accordance with ES-SH-PR-301 Bloodborne Pathogens.
4.6 Hazardous Exposure Evaluation
4.6.1 Personnel shall immediately report any signs/symptoms of illness they
believe may be due to hazardous chemical or radiological exposure.
4.6.2 Employees who report an illness associated with hazardous exposure shall
be evaluated by site EMS personnel and the Health and Safety Manager
notified. The EMS evaluation shall be documented using an EMS Run
Report (Attachment 5.4) and shall include an assessment of vital signs and
a detailed description of reported symptoms.
4.6.3 Personnel reporting an illness associated with hazardous exposure shall be
offered further medical evaluation. If further evaluation is declined or
deemed unnecessary, this shall be documented using a Release of Medical
Responsibility form (Attachment 5.5).
4.7 Evacuation Plan
4.7.1 The EC shall:
Make the determination if an evacuation of an area, building, or the site is
necessary to protect personnel and shall designate an alternate
location when necessary.
Classify the accident as “alert” or “site area emergency”.
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Ensure activation of the audible and/or visual alarms at the Mixed Waste
Treatment Building, Mixed Waste Operations and/or the Mixed
Waste Storage Building.
Ensure evacuation instructions include the authority by which the
announcement is made (EC), wind direction & speed, and the
appropriate Post-Evacuation Gathering Point(s).
4.7.2 All Personnel shall:
Immediately move toward the appropriate Post-Evacuation Gathering
Point while avoiding any potential hazards associated with the
event (i.e., smoke, fire, or explosions).
Assist others needing help to the Post Evacuation Gathering Points.
4.7.3 Post-Evacuation Gathering Points
MW Area Primary: Operations/Administration Building
Parking Area
MW Area Secondary: Southwest Site Entrance
LLRW Area Primary: LLRW Operations/Administration
Building Parking Lot
LLRW Area Secondary: Decon Access Building Parking Lot
CWF Area: Northwest Site Entrance.
Note: Evacuation instructions specific to building fires shall be
posted on building evacuation maps. The default location for
evacuation of a building outside the restricted area is the
adjacent parking lot at least 100 feet away and upwind of a
fire.
4.7.4 Personnel from all Post-Evacuation Gathering Points shall proceed
expeditiously to the designated off-site Post-Evacuation Gathering Point in
the event of a Site Evacuation. This Off-Site point is located at the
Northwest site entrance where the access road intersects the Tooele
County Road.
4.7.5 Evacuation Routes
4.7.5.1 Off-site evacuation routes include, but are not limited to, the
perimeter access roads and county roads.
4.7.5.2 Within the Restricted Area, All Personnel shall:
4.7.5.2.1 Safely proceed to the nearest established Access
Control Point and exit as directed;
4.7.5.2.2 Proceed to the MW or LLRW Unloading Docks or
other alternate location announced by the EC to
evacuate when it is unsafe to proceed to the Access
Control Points; or
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4.7.5.2.3 Exit at ANY point that it is safe to do so when the
Access Control Points and the Unloading Docks are
inaccessible.
• Personnel exiting the restricted area without
decontamination shall restrict their movements to as
small an area as possible, declare to the EC or authorized
personnel that they are potentially contaminated, and not
spread the contamination to other personnel.
4.7.6 Post-Evacuation Roll Call
4.7.6.1 Immediate supervisors and/or Lead Personnel shall:
4.7.6.1.1 Conduct a roll-call activity at the Post-Evacuation
Gathering Point(s) or the Off-site Evacuation
Gathering Point and report to the EC.
4.7.6.1.2 Use the Visitors Log, access control logs, or the
Health Physics Access Control Database to facilitate
this activity.
4.7.6.1.3 Produce a list(s) of personnel accounted for to the EC.
4.7.6.2 The EC Shall:
4.7.6.2.1 Use the personnel accountability lists to determine
whether there are any unaccounted personnel and/or
direct any effort to account for missing personnel.
4.7.6.2.2 Utilize any resources in effecting the rescue of
unaccounted personnel if it is within the capabilities
of On-Site rescue personnel or
4.7.6.2.3 Immediately notify the appropriate Off-Site
Emergency Response Agency if rescue is not within
the capabilities of On-Site rescue personnel.
4.8 Termination and Follow-up Actions
4.8.1 The EC Shall:
4.8.1.1 Notify all affected personnel regarding the termination of the
Contingency Plan with any necessary instructions for follow-up
action and/or resumption of normal activities.
4.8.1.2 Provide for treating, storing, or disposing of recovered waste,
contaminated soil, surface water, or any other material that
results from an explosion, fire, or release at the facility
immediately after an emergency.
4.8.1.3 Ensure any material recovered from an explosion, fire, or release
shall be managed as a hazardous or radiologically contaminated
waste unless it is verified to be otherwise.
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4.8.1.4 Ensure that in the affected areas of the facility:
• No waste that may be incompatible with the recovered
material is treated, stored, or disposed until the cleanup
procedure(s) are completed, and
• All emergency response and affected operational
equipment is cleaned and replaced appropriately before
operations resume.
5 ATTACHMENTS
5.1 Contingency Notification Report, CL-SH-PR-500-F2 (5 pages);
5.2 Contingency Plan Communications Flow Chart (2 pages)
5.3 Contaminated Patient Transfer Instructions (2 pages)
5.4 Example EMS run Report
5.5 Release of Medical Responsibilities
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Attachment 5.1 - CL-SH-PR-500-F1,
Contingency Notification Report
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Attachment 5.1 - CL-SH-PR-500-F1,
Contingency Notification Report cont.
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Attachment 5.1 - CL-SH-PR-500-F1,
Contingency Notification Report cont.
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Attachment 5.1 - CL-SH-PR-500-F1,
Contingency Notification Report cont.
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Attachment 5.1 - CL-SH-PR-500-F1,
Contingency Notification Report cont.
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Attachment 5.2 – Contingency Plan Flow Chart
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Attachment 5.2 – Contingency Plan Flow Chart Cont.
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Attachment 5.3
Contaminated Patient Transfer Instructions
Instructions for Transfer of a Potentially Contaminated Patient
from the EnergySolutions Clive Facility to
The University of Utah Medical Center
NOTE: Some of the following steps will be performed in parallel depending on the
severity of the injury. The performance of radiological assessment shall in no way
interfere with life-saving measures necessary for the patient(s). These instructions are
based upon a memo of understanding between the University of Utah Medical Center and
EnergySolutions.
1. The patient shall be checked by EMT personnel to determine the extent and severity of
injuries. EMTs shall transfer information regarding the patient to the AirMed nurse,
University of Utah Emergency Department Attending Physician, and Charge Nurse.
2. The Emergency Coordinator, lead EMT, or Security Personnel shall contact U of U
AirMed as required by the situation and as determined appropriate by the lead EMT. The
patient may also be transported directly to the U of U Medical Center’s Emergency
Decontamination Facility. The Emergency Coordinator, lead EMT, or Security personnel
shall call the U of U Emergency Department and notify the Charge Nurse immediately if
a patient is to be sent directly to the U of U Medical Center Emergency Department
Decontamination Facility.
3. The patient shall be checked by EnergySolutions Health Physics personnel for surface
contamination or possible internal contamination prior to transfer.
a. If no contamination is detected, notify the lead EMT or Emergency Coordinator
who can ensure transfer of the patient is discussed with the AirMed nurse and/or
U of U Emergency Department.
b. If contamination is detected on the patient, EC personnel shall attempt to
decontaminate the patient if the injury will allow. This should include removal of
contaminated clothing.
1) Patient contamination shall be documented. Specifically, a diagram shall
be drawn showing areas on the patient’s body that could not be
decontaminated. Any wound contamination must be clearly identified.
This drawing shall be forwarded to U of U EMS personnel.
2) Notify the lead EMT, Emergency Coordinator or Security Personnel so
they may discuss patient status, information regarding the accident, and
potential contamination with the AirMed nurse, U of U Emergency
Department attending physician and U of U Emergency Department
Charge Nurse.
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3) The final decision to transport the patient by AirMed will be made by
AirMed nurse. If patient transport via aircraft is deemed unnecessary the
patient may be transported to U of U Emergency Department via
ambulance.
4) A Health Physics Technician shall accompany the patient during transfer
to U of U Emergency Department unless directed otherwise by U of U
EMS personnel. In this case, EnergySolutions person competent in
radiological control methods (CRSO is the default designee for AirMed
transports) will meet the transporting vehicle at the U of U hospital
receiving area.
NOTE: A Health Physics Technician may not be permitted to accompany the
patient during AirMed transport due to limited room within the aircraft
and weight restrictions.
4. Prior to arrival of an AirMed Helicopter, EnergySolutions personnel shall move the
patient to helicopter landing zone or to the EnergySolutions ambulance in preparation for
transfer. Ensure the landing zone is well marked and that the AirMed pilot has been
given required coordinates.
5. In the event a potentially contaminated patient must be immediately transported, notify
the Clive Facility RSO. The RSO shall then notify the U of U RSO, of the radiological
status of the patient.
NOTE: If the RSO cannot be contacted, the attending Health Physics personnel shall
contact the U of U RSO regarding the radiological status of the patient.
6. Emergency Contact Information:
a. Thomas A. Brown (RSO) 801-739-4592
b. U of U RSO 801-581-6141
c. U of U Medical Center 801-581-2291
d. AirMed (if life-threatening) 801-581-2500 or 1-800-453-0120
e. U of U ED Attending Physician 801-581-2292
f. U of U ED Charge Nurse 801-581-2292
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Attachment 5.4 – EMS Run Report
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Attachment 5.5 Release of Medical Responsibility
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