DRC-2025-002433

Inspection Module:
lnspection Location:
lnspection Items:
Inspection Dates:
Inspectors:
Personnel Contacted:
INspncuoNRrponr
19 - Laboratory
EnergySolutions - Clive Facility, Utah
Radiation Work Permit, Data Packets, Survey Procedures
Opening meeting: June 23, 2025
Closeout: July 10,2025
Bryan Wooll Utah Division of Waste Management and Radiation Control
(DWMRC)
Inva Braha, Utah Division of Waste Management and Radiation Control
(DWMRC)
Kevin Carney, Utah Division of Waste Management and Radiation Control
(DWMRC)
Tom Brown; Radiation Safety Officer (RSO)
Dale Thorne; Assistant Radiation Safety Officer (ARSO)
Curtis Kirk; Quality Assurance Manager
Janod Anderson: Laboratory
Governing Documents:o Radioactive Materials License (RML) UT2300249
. Utah Rules R3l3-15
. EnergySolutions Radiation Safety Manual
o EnerrySolutionsProcedureso CL-CW-PR-200, Package Liquid/Void Verificationo CL-CH-PR-252,Incoming Shipment Inspection and Samplingo CL-SH-PR-I50: Laboratory Chemical Hygiene Plan
o CL-LB-PR-003: Sample Control
Openinq Meetins
EnergySolutions:
Tom Brown; Radiation Safety Offrcer (RSO)
Dale Thorne; Assistant Radiation Safety Officer (ARSO)
Curtis Kirk; Quality Assurance Manager
Utah DWMRC:
Bryan Woolf (Health Physics Inspector)
Inva Braha (Health Physics Inspector)
Kevin Carney (Health Physics Inspector)
During the opening meeting on June 23,2025, the inspectors discussed the inspection items and
documentation to be reviewed during the inspection. The inspectors informed Clive staffthat they would
be accessing the laboratory, interviewing staff, and reviewing associated laboratory procedures.
Insnection Summarv
The Division of Waste Management and Radiation Control (Division) inspection consisted of
interviewing EnergySolutions (ES) staff, examining documentation that pertains to sampling, and
examining possible radiological contamination. Division inspectors' (Inspectors) interviews with ES staff
provided clarity on ES' operations associated with sampling in the lab and the facility's compliance with
all applicable Rules and Regulation and ES UT Radioactive Material License UT2300249 (License).
Item 1. Stafling/ PPE
Observations: The Division lnspectors interviewed various laboratory staff with regards to their training
qualification. The Inspectors were able to veriff:. The laboratory is staffed by a team of 6 employees. Division Inspectors were able to veri$r that
lab staff are all current on their training and qualifications within ES' QualCard system.. All laboratory staff have successfully completed Radiation Safety Worker Training and their
annual refresher course.o All staff were briefed and working under the appropriate Radiation Work Permit and were
knowledgeable with regards to the requirements of this Permit.o At the time of the inspection, the laboratory personnel were not actively handling or processing
samples. Consequently, they were not wearing full PPE, specifically goggles, lab coats, and
gloves. However, all laboratory staffwere appropriately equipped with steel-toed boots,
dosimeters, and safety glasses.
Deficiencies: None
Item 2. Sampling
Observations: The Division Inspectors observed laboratory staff during their assigned work tasks. The
Inspectors were able to verifu:o The EWIS database plays a crucial role in generating sampling orders based on a timeline,
generator shipments, and the volume of shipments sent over time. Once a sampling order is
established, a corresponding collection report is created and then executed by the appropriate
personnel.o Random chain-of-custodies were reviewed and appeared to be properly maintained from
sampling to disposal.o All samples received in the laboratory from the contaminated restricted area were appropriately
surveyed by laboratory staff. The area where samples are received is physically segregated from
the general laboratory space via radiation rope, signs, and proper postings.o All samples appeared to be properly stored according to the dose rate of sample.o Inspectors utilized a Bicron microrem meter to survey various locations within the lab. No areas
of the lab were of concern during the time of inspection.o All sampled wastes are disposed in accordance with their procedures and ALARA principles.
Deficiencies: None
Closeout Meeting
EnergySolutionsz
Tom Brown; Radiation Safety Officer (RSO)
Dale Thorne; Assistant Radiation Safety Officer (ARSO)
Curtis Kirk; Quality Assurance Manager
Utah DWMRC:
Bryan Woolf (Health Physics Inspector)
Kevin Carney (Health Physics Inspector)
Inva Braha (Health Physics Inspector)
Findines:
The Division Inspectors observed and interviewed laboratory staff during operation. The lab appears to be
operating in a manner that is consistent with ALARA principles and the Facility's Radiation Protection
Program.
Recommendations
None.
Recommendation for Next Year's InsDection
The Inspectors should time the inspection for when samples are actively being sampled to visually verif,
their process.
Prepared By: Bn{q LJ*F oz/ r las'(Date)
Y#li',"rltt/n__r?ilr)-Reviewed By:
(PrintName)
Lawrence Kellum
(Print Name)(Signature)
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
License Numbers UT2300249 and VT230047 8
INSPECTION MODULE 19 Revision 3
Laboratory
InspectionDates: Start: 6/23/2025 End 0711012025
Inspector(s): Bryan Woolf. Kevin Carney. Inva Braha
Related Documents
o Utah Rules R313-15. f,nergySolutions Radiation Safety Manualo RML UT2300249o RML UT2300478
ES' Personnel Contacted
Jarrod Anderson
Stafling
1. How is the Laboratory staffed?
Comments: EnergySo/allions' ZaboralorJ Staff has a team of 6 employees. 5 out of 6 employees were
present and working in their laboratory areas/desks.
2. What training is required of the staff with respect to sample handling and radiation safety?
Comments: Division Inspectors Interviewed Jarrod Anderson" which verified that all laboratory employees
are trained in sample collection and handling. Some of the ES' training for laboratory staff include
procedures such as:
o CL-SH-PR-I50: Laboratory Chemical Hygiene Plan
o CL-CH-PR-252: Incoming Shipment and Samplingo CL-LB-PR-003: Sample Control
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3. Radiation Work Permit: What are the radiation and contamination levels? What are the PPE
requirements?
Comments: Inspectors interviewed Jarrod Anderson on his RWP: 25-002- Task 2. Other staff laboratory
members such as Giovanni had RWP:25-005-Task 2. At the time of the inspection. the laboratory personnel
were not activelv handling or processing samples. Consequently. they were not wearing fullPPE.
specifically goggles. lab coats. and gloves. However. all laboratory staff were appropriately equipped with
steel-toed boots and dosimeters. It was observed that both the Division Inspectors and Jarrod Anderson wore
protective glasses throughout the inspection of this module.
Chain of Custody (COC)
4. Is the sample chain of custody maintained from collection to analysis to disposal?
How are samples stored in the laboratory in this regard?
Comments: Division Inspectors interviewed Jarrod Anderson to gain a comprehensive understanding of the
sample management process. from the initial sample collection plan to sample processinq.
The EWIS database plays a crucial role in this process by generating sampling orders based on a timeline.
generator shipments. and the volume of shipments sent over time. Once a sampling order is established. a
corresponding collection report is created and then executed by the appropriate personnel.
After samples are collected. they are delivered to a designated area within the laboratory. read)'for Chain of
Custody (COC). Figzre / illustrates this COC area within the laboratory. Upon completion of the COC.
samples are categorized into two main groups:
l. On-Site Samples: These samples undergo analysis internally within the facility.
2. DC Samples: These samples are sent to a third-party laboratory for analysis.
Data Packets
5. How are data packets managed? (Trace the data from acquisition to document control)
Comments: From the initial sampling order through to sample analysis. data is primarily managed within
the EWIS database and subsequently processed by Oracle BI Publisher. Additionally. all supporting
documentation is securely stored in the Energy Solutions database called OnBase. Division Inspectors also
observed physical copies of tracking documents pertaining to both the sampling processes and their
subsequent analyses.
90 -D ay | 45-Day Reportin g
6. Is the BI Publisher 90-Day or 45-Day 11e.(2) Compliance report in use? (to ensure sample receipt and
processing is performed within 30 days of arrival of the shipment, to ensure that sample analysis
analytical reporting may be obtained within 90-days for LLRW and MW waste samples and within 45-
days for Ile.(2) waste samples.)
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Comments: Interviewed Jarrod Anderson and he was able to demonstrate through Bi Publisher database:
all the samples processed in that last 3 months were within the designated timeframe. The system flags
samples approaching their deadline by changing color. ensuring timely processing.
Sample Handling
Sample Receipt / Exposure and Contamination Control
7. How are samples received from the contaminated restricted area?
Comments: Access to the laboratory from the contaminated restricted area is facilitated through a
designated acceptance area. a controlled zone as depicted in Figure 1. This area is physically segregated
from the general laboratory space via radiation rope. signs and postings. The area had an access door to the
Contaminated Restricted Area where samples are dropped off at the lab. ES personnel provided an overview
of their sample collection and transfer protocols. emphasizing the EPA 261.4 rules and regulations. This was
aphysically printed document hung on the wall.
8. How is the dose rate on the sample established?
Comments: The sample's initial dose rate is determined from the generator's shipping information. such as
manifests. Upon collection" ES' staff independently veriff this by conducting their own survey using a dose
rate instrument and swipe tests once dropped off at the lab.
9. Are adequate precautions taken to prevent contamination of the Laboratory when samples are received
from the contaminated restricted area?
Comments: The Chain of Custody process is an important step" allowins staff to precisely communicate the
source and type of each sample. After this initial documentation. samples are then sorted into distinct bins
within the laboratory. categorizing them as DC samples or Onsite samples (Figure 2). To maintain safetv.
Health Physicists perform weekly contamination screens of the laboratory floors. utilizing smears and dose
rate meters.
Sample Storage
10. How are samples stored? (Exposure rate considerations)
Comments: To manage samples exceedine a dose rate of 2 mrem/hr. laboratory staff utilize a dedicated.
shielded containment box (lead pig). This isolated unit. built from lead (Pb) and tape. is clearly marked with
a "Radiation Caution" sign to alert personnel to the higher dose rates within. Samples below 2mremlhr are
stored in a plastic bin prior to sampling. a refrigerator. or coolers.
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Sample Preparation
I 1 What radiation safety precautions are taken when samples are prepared for analysis and/or shipment?
Comments: Laboratory personnel underso comprehensive training. documented via qualification cards. to
ensure the safe handling. preparation. storage. and shipment of samples. Some of these trainine paths
involve procedures such as:
. ES-QA-PR-0O3: HazardCommunication. CL-LB-PR-003: Sample Control
Sample Analysis
12. When samples are analyzed in the laboratory are contamination and personnel exposures controlled?
Comments: Personnel exposure is continuously monitored using both dosimeters and lapel badqes.
Additionally. ES Health Physics staff conduct weekly contamination surveys of the laboratory area.
Sample Disposal
13. How are samples disposed?
Comments: Samples are categorized and disposed of based on their required treatment tvpe and waste
handling procedures. As shown in Fieure l. the designated area utilizes color-coded coolers olaced on a
shelf for this purpose. For instance. samples requiring VTD treatment are placed in the Mixed Waste cooler.
Each cooler and shelf are also clearly labeled the final destination of the sample for disposal.
Work Area Monitoring
Work Area Exposure Rates
14. How are the exposure rates monitored in the working areas?
Comments: While exposure rates are not continuously monitored within the laboratory .areas, personnel
wear dosimeters and lapel badees for individual exposure trackins. Additionally. Health Physics staff
conduct weeklv surveys of the area.
Contamination Monitoring in the Work Areas
15. How is radioactive contamination monitored (who, how often)?
Comments: Similar to the previous point. radioactive contamination in the laboratory area is monitored
through weekly surveys and indicated by radiation signs and postings.
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Air Monitoring
16. What air monitoring is being performed in the laboratory (BZA,High Vol, Low Vol)? Frequency?
Comments: Jarrod Anderson verified that air monitoring is performed as needed. depending on the type of
analysis being conducted.
Additional Comments:N/A
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Figure L Designated area withing the laboratory where sample
categorization and Change of Custody (COC) is conducted.
Figure 2. Designated area withing the laboratory where samples
are categorization into DC qnd Onsite samples.
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