DRC-2025-002523

Deq submit <[e-mail]>
Fwd: CD-2025-158: Actions from the Extent of Condition Evaluation for Discrepant
Shipment 9125-13-0007 and Notification of Waste Greater than Class A Disposed at
Clive
1 message
LLRW DWMRC <[e-mail]>Thu, Aug 7, 2025 at 9:36 AM
To: Deq submit <[e-mail]>
drc
---------- Forwarded message ---------
From: Vern C. Rogers <[e-mail]>
Date: Wed, Aug 6, 2025 at 4:26 PM
Subject: CD-2025-158: Actions from the Extent of Condition Evaluation for Discrepant Shipment 9125-13-0007 and
Notification of Waste Greater than Class A Disposed at Clive
To: [e-mail] <[e-mail]>
Cc: Duane R. Quayle <[e-mail]>, Dave Booth <[e-mail]>, Tab Brown
<[e-mail]>, Karen Kirkwood <[e-mail]>, Kristina M. Garcia
<[e-mail]>, Dave Squires <[e-mail]>, jknudsen <[e-mail]>,
Scott Baskett <[e-mail]>, Tim Orton <[e-mail]>
Dear Mr. Hansen,

In compliance with Condition 68 of Radioactive Materials License UT2300249, EnergySolutions notified the
Director of the Utah Division of Waste Management and Radiation Control of a waste classification
discrepancy, as defined in Utah Administrative Code R31-15-1009, identified in Shipment 9125-13-0007
(Bates Number M16438; Generator Site Access Permits 1307008022).[1] Upon discovery, EnergySolutions
immediately halted further management of the shipment and notified the Generator. The Generator was
instructed to investigate the discrepancy and asses the extent of non-compliance within their waste
characterization processes. The discrepant waste package was returned to the Generator on May 22, 205.
EnergySolutions documented this issue in Condition Report CR-2025-0457 to track its resolution.

On August 5, 2025, representatives from the Generator met with EnergySolutions’ and the Director’s staff to
present the findings of their investigation. The Generator reported that they paused waste shipments,
conducted a root cause analysis, and performed an extent-of-condition assessment to identify process
weaknesses. To prevent recurrence, the Generator implemented the following corrective actions:
1. Enhanced their classification spreadsheet to minimize input errors.
2. Revised their waste characterization procedure and trained staff on proper techniques, calculation
accuracy, verification methods, and the importance of independent reviews of data provided to waste
brokers.
3. Completed an extent-of-condition assessment to ensure comprehensive process improvements.

In addition to the Generator’s actions, EnergySolutions has determined that relying solely on Generator Site
Access Permits (GSAPs) for shipments characterized by a generator without independent verification by
EnergySolutions does not align with best practices. Consequently, EnergySolutions has discontinued the
use of its GSAPs for shipments not directly characterized or independently verified by EnergySolutions. To
formalize this change, EnergySolutions updated Broker Procedure ES-BR-PR-002 to include detailed steps
for evaluating a generator’s characterization process.
8/7/25, 3:13 PM State of Utah Mail - Fwd: CD-2025-158: Actions from the Extent of Condition Evaluation for Discrepant Shipment 9125-13-0007 and …
https://mail.google.com/mail/b/AEoRXRQWBPfqVTL5tpo4EF20NJkma_DXA4ujxplbMH94uCrLYd1V/u/0/?ik=adf9d5e615&view=pt&search=all&permth…1/3

The Generator’s extent-of-condition assessment also revealed that Shipment 9125-01-0020, transferred to
EnergySolutions’ Clive Facility on April 17, 2024, and received on April 19, 2024, was affected by a similar
data entry error. The shipment manifest (attached) characterized container RW103931 with 2.0352E+03
pCi/g Am-241. Recalculations received from the generator this week describe this container with Am-241
concentrations greater than Class A (calculated at 6.08E+04 pCi/g). Based on the original manifested
concentration, this shipment was accepted at Clive and macroencapsulated on August 27, 2024. Although
non-compliant as received, the waste in Macro Vault MW9A240827MV is less than 3.5% of Class A
concentrations, when accounting for the volume of macromedia used.

Any attempt to remove Shipment 9125-01-0020 from the Macro Vault would be inconsistent with the Clive
Facility’s ALARA Program (CL-RS-PG-001) and will result in unnecessary exposure to radiation workers.
Therefore, EnergySolutions recommends that Shipment 9125-01-0020 remain encapsulated.

Should there be any questions with this notification, please contact me at 801-649-2000.

Sincerely,

Vern C. Rogers | ENERGYSOLUTIONS
299 South Main Street, Suite 1700
Salt Lake City, UT 84111

PHONE: [phone]
DIRECT: 801.649.2253
MOBILE: [phone]
FACSIMILE: 801.880.2879
EMAIL: [e-mail]

CONFIDENTIALITY NOTICE: This electronic message transmission contains informaon from the firm of ENERGYSOLUTIONS, which is confidenal and privileged,
in accordance with Utah Code 63G-2-309. The informaon is intended to be for the use of the individual or enty named above. If you are not the intended
recipient, be aware that any disclosure, copying, distribuon or use of the contents of this informaon is prohibited. If you have received this electronic
transmission in error, please nofy me by telephone [phone]) or by electronic mail ([e-mail]) immediately. Nothing herein or in
the message above is intended to create a contractual relaonship.

[1] Gurr, S.D. “Radioactive Material License UT 2300249; Condition 68, 24-Hour Notification of Discrepancies with
Shipment 9125-13-0007.” (CD-2025-084) Letter to Doug Hansen of the Division of Waste Management and Radiation
Control from EnergySolutions. April 30, 2025.
8/7/25, 3:13 PM State of Utah Mail - Fwd: CD-2025-158: Actions from the Extent of Condition Evaluation for Discrepant Shipment 9125-13-0007 and …
https://mail.google.com/mail/b/AEoRXRQWBPfqVTL5tpo4EF20NJkma_DXA4ujxplbMH94uCrLYd1V/u/0/?ik=adf9d5e615&view=pt&search=all&permth…2/3
8/7/25, 3:13 PM State of Utah Mail - Fwd: CD-2025-158: Actions from the Extent of Condition Evaluation for Discrepant Shipment 9125-13-0007 and …
https://mail.google.com/mail/b/AEoRXRQWBPfqVTL5tpo4EF20NJkma_DXA4ujxplbMH94uCrLYd1V/u/0/?ik=adf9d5e615&view=pt&search=all&permth…3/3