DRC-2025-002643

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com
August 17, 2025 CD-2025-165 Mr. Doug Hansen Director
Utah Division of Waste Management and Radiation Control
195 North 1950 West Salt Lake City, Utah 84114-4880 Subject: Radioactive Material License UT 2300249; Relocation of the Owner Controlled
Fences
Dear Mr. Hansen, EnergySolutions respectfully submits this response to your electronic inquiry dated August 13,
2025, regarding the plans for the establishment of a new owner-controlled fence-line at the Clive
Facility.1 This response outlines the relevant operational and regulatory frameworks, addresses
the specific questions posed, and reaffirms our commitment to safety and compliance.
Regulatory and Operational Framework:
Radioactive Material License UT2300249 requires the Clive Facility to operate under the Clive
Facility Radiation Protection Program (CL-RS-PG-002, Revision 21), which establishes
protocols for the receipt, possession, processing, use, transfer, and disposal of licensed
radioactive material. Central to Clive’s operations is the commitment to the "As Low As
Reasonably Achievable" (ALARA) philosophy, as detailed in the Clive Facility ALARA
Program (CL-RS-PG-001, Revision 18). These programs prioritize minimizing radiation doses
to both the public and facility personnel through engineering and administrative controls, as
outlined in Sections 2.2.4.1, 3.1.2.1, and 5.4.1.1 of CL-RS-PG-002. Section 3.2.4 further
specifies requirements for personal protective equipment (PPE), while Section 3.2.4.1
emphasizes that protective clothing is not a substitute for engineering and administrative
controls.
To achieve ALARA objectives, the Clive Facility implements three fundamental principles:
minimizing exposure time, maximizing distance from radiation sources, and utilizing effective
shielding. Minimizing exposure time reduces the duration of contact with radioactive materials,
thereby lowering the cumulative radiation dose. Maximizing distance leverages the inverse
square law, where radiation intensity decreases with increased distance from the source.
Effective shielding employs dense materials, such as lead or concrete, to absorb or block

1 Woolf, B. Email communication from the Division of Waste Management and Radiation Control to Vern Rogers of EnergySolutions, dated August 13, 2025.

Mr. Doug Hansen CD-2025-165 August 17, 2025 Page 2 of 4

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radiation. These strategies collectively ensure the safe handling and management of radioactive
materials.
Section 1.3.3 of CL-RS-PG-002 authorizes Clive Facility management to designate owner-
controlled areas outside the Restricted Area but within the site boundary, where access may be
restricted for any reason. Additionally, Condition 22 of Radioactive Material License
UT2300249 mandates weekly gamma radiation surveys along the perimeter of the Restricted
Area. Since the third week of July 2025, elevated external dose rates have been observed near
Environmental Monitoring Station A-35 and the bypass track adjacent to the West Rotary
Facility. Although these dose rates remain well below the limits specified in Utah Administrative
Code R313-15-302(2)(b)(ii), projections indicate potential increases due to the staging of
decontamination and decommissioning project railcars with elevated radioactivity through the
end of 2025. In response, the Clive Facility Radiation Safety Officer has implemented additional
owner-controlled fencing, as depicted in Figure 1, to increase the distance between the public
and the bypass track, aligning with ALARA principles.

Figure 1 - Additional Owner-Controlled Fencing Constructed Adjacent to the West Rotary Facility

Mr. Doug Hansen CD-2025-165 August 17, 2025 Page 3 of 4

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Responses to Specific Inquiries:
In the August 13, 2025 electronic message, the Division requested brief narratives addressing the
following:
1. What will this newly created area be categorized as? Is this an extension of the
Restricted Area into section 29 or is this considered a buffer zone? The EMP states
that designated air monitoring stations are to be located along the restricted area
perimeter.

The additional fencing, as illustrated in Figure 1, constitutes an access control measure
within EnergySolutions’ owner-controlled property. This fencing does not alter the existing
Restricted Area boundary or necessitate the relocation of Environmental Monitoring
Station A-35. Station A-35 remains positioned at the Restricted Area perimeter, consistent
with the Environmental Monitoring Program (EMP) requirements.

2. Is the TLD badge currently stationed at A-35 going to remain in place until the end of
the current EMR reporting period or will it be moved with the fence-line? If the TLD
badge is not relocated, will a new TLD be installed along the Northern portion of the
newly created fence line?

In accordance with the Clive Facility Radiation Protection Program (CL-RS-PG-002), a
Thermoluminescent Dosimeter (TLD) badge has been installed along the northern portion
of the newly constructed owner-controlled fence, representing the closest permissible
proximity for members of the public to that section of the Restricted Area. External
exposure rates measured by both TLDs will be combined in the next Environmental
Monitoring Report (based on the fraction of the reporting period each TLD represented
dose rates at locations accessible to a hypothetical member of the public).

Mr. Doug Hansen CD-2025-165 August 17, 2025 Page 4 of 4

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3. Will there be an establishment of a new “bird cage” as an air monitoring station if the
restricted area is expanded?

The additional owner-controlled fencing does not impact the position of Environmental
Monitoring Station A-35 or the size of the Restricted Area. Therefore, no new air
monitoring station, such as a “bird cage,” is required or planned.

4. Will/How does the expansion of this fence-line adjust surety costs for that area.

The installation and potential removal of structures and fencing outside the licensed
Restricted Area are addressed within the bond pledged to Tooele County, as stipulated in
EnergySolutions’ Conditional Use Permit No. 2700-87. The additional fencing does not
necessitate adjustments to existing surety arrangements.
Conclusion:
EnergySolutions remains committed to ensuring the safety of the public and our personnel while
maintaining compliance with all applicable regulations. Should you have further questions or require
additional information, please contact me at 801-649-2000.

Sincerely,

Vern C. Rogers
Director, Regulatory Affairs
Vern C.
Rogers
Digitally signed by Vern C. Rogers DN: cn=Vern C. Rogers, o=EnergySolutions, ou=Waste Management Division, email=[e-mail], c=US Date: 2025.08.17 20:42:11 -06'00'