DRC-2024-007631

299 South Main Street, Suite 1700 Salt Lake City, Utah 84111
[phone] Fax: [phone] www.energysolutions.com
November 22, 2024 CD-2024-239
Kristen Schwab, M.S.
Alternate Executive Director, Northwest Interstate Compact (NWIC)
Office of Radiation Protection
Washington State Department of Health
[e-mail]
Subject: Disposal of Radiological Wastes from the Dugway Proving Ground (DPG)
Solid Waste Management Unit (SWMU)-11 Area 2 Remedial Action
Dear Ms. Schwab:
EnergySolutions has received a request from the United States Army Corps of Engineers
(USACE) Sacramento District to determine whether the Clive Facility can accept the
radiological waste from a remedial action at the SWMU-11 at DPG in Dugway, Utah
(UT) for disposal. This letter is being written to request that this waste be exempted from
the requirements of the North West Interstate Compact (NWIC) and be disposed at the
EnergySolutions disposal facility in Clive, UT. There are several reasons for this request,
and they are summarized in the following paragraphs.
USACE will be excavating two trenches at DPG on behalf of the Army Environmental
Command. Historical records indicate that buried wastes in the trenches consists
primarily of “contaminated rags and papers.”1 Various sampling efforts in the trenches
identified soils with elevated levels of Radium-226 (Ra-226), Lead-214 (Pb-214),
Bismuth-214 (Bi-214), Strontium-90 (Sr-90) Niobium-94 (Nb-94), and Cesium-137 (Cs-
137).2 The work will be performed in accordance with the DPG Site Operations Plan and
Radiation Protection Plan (provided under separate cover). These plans have been
reviewed by the US Nuclear Regulatory Commission (NRC) and its contractor (Oak
Ridge Associated University). The NRC’s role at DPG is defined within the
Memorandum of Understanding between the NRC and the U.S. Department of Defense,
dated April 28, 2016.
1 NRC, 2001. “Terminated License Review,” Dwight D. Chamberlain, Director of Division of Nuclear
Materials Safety, U.S. Nuclear Regulatory Commission. March 26, 2001.
2 North Wind Services, Final Record of Decision: Area 2 of SWMU-11 – Dugway Proving Ground,
Dugway, Utah” Report prepared for the U.S. Army Environmental Command. March 2022.
Mr. Doug Hansen
CD-2024-239
November 22, 2024
Page 2 of 3
299 South Main Street, Suite 1700 Salt Lake City, Utah 84111
[phone] Fax: [phone] www.energysolutions.com
Bulk Waste. The expected volume of this waste is at least 572 bank cubic yards (BCY;
approximately 858 tons) of soil and debris. USACE plans to load the bulk waste into
lined intermodal containers (IMCs) capable of holding approximately 11.3 BCY (17 tons)
of waste. This approach would require leasing approximately 51 total IMCs and
conducting 51 total shipments. The IMCs would be reused during and after the project. If
the waste were to be loaded into B-25 containers for disposal at the NWIC Washington
site with maximum payloads of 3.3 BCY (5 tons), then USACE would require
approximately 172 containers that would be transported and buried within the NWIC
disposal cell.
Travel Distance. The over-the-road haul distance from DPG to Clive, Utah is
approximately 73 miles. Considering 51 shipments will be required for this campaign, a
total of 3,723 conveyance miles would be traveled. By comparison, the road distance
from DPG to the US Ecology site in Richland Washington is 721 miles, resulting in a
significantly larger total of 36,771 vehicle miles traveled over highway, (an increase of
33,048 miles for this campaign). According to the U.S. Department of Transportation,
3
these extra miles would result in an increase of 0.004 fatalities, 0.02 injured persons, and
0.06 vehicle crashes (which are 887% higher than the incidents projected from the
cumulative truck miles projected for this campaign if from DPG to Clive, UT).
Increase in Dose Potential. The potential collective public radiation dose would also be
significantly higher for a campaign of shipments to the NWIC site compared to the Clive,
Utah site due to the considerably transportation route, which results in extended radiation
exposure time. Shipping to the NWIC site would increase the collective public dose by
887% compared to shipping to Clive, Utah, even without accounting for the higher
vehicle density on the busier interstates between DPG and Washington versus the lower
density between DPG and Clive. Additionally, remediation workers could face a higher
radiation dose with a NWIC campaign compared to one to Clive, Utah, due to the
increased packaging requirements. USACE estimates that remediation and waste
packaging using IMCs will take about 3 weeks. Loading waste into B-25 containers to
meet the Condition 25 of U.S. Ecology Washington’s Radioactive Material License WN-
I019-2 would add approximately 2 more weeks to the fieldwork, raising the workers’
dose potential by 67% over what would be expected from a Clive Utah campaign.
Arsenic Levels.There is a possibility that some of the waste from the trenches may be
co-mingled with hazardous materials. During a characterization survey of the trenches, a
sample of solidified sand inside a drum was found to have an arsenic concentration of
155 milligrams per kilogram, which is more than 20 times the hazardous waste limit of
5.0 milligrams per liter as defined by 40 CFR Part 268. USACE plans to sample
additional waste from the trenches to assess the presence of hazardous constituents. If the
3 National Highway Traffic Safety Administration. “Traffic Safety Facts; 2022 Data. Summary of Motor
Vehicle Traffic Crashes” (DOT HS 813 643) NHTSAs National Center for Statistics and Analysis. U.S.
Department of Transportation. September 2024,
Mr. Doug Hansen
CD-2024-239
November 22, 2024
Page 3 of 3
299 South Main Street, Suite 1700 Salt Lake City, Utah 84111
[phone] Fax: [phone] www.energysolutions.com
waste is determined to be hazardous (mixed) waste, USACE will collaborate with
EnergySolutions to update the waste profile and treat the material at Clive before
disposal.
Given the reasons outlined above, we respectfully request approval for the disposal of
USACE remediation waste from DPG at the EnergySolutions disposal facility in Clive,
Utah. If you have any questions or need additional information, please feel free to contact
me by phone at 801.649.2253 or via email at [e-mail].
Sincerely,
Vern C. Rogers
Director of Regulatory Affairs
cc: Thomas A. Brown, RSO, EnergySolutions, LLC
Greg Bright, Project Manager, EnergySolutions Federal Services
Douglas J. Hansen, Director of the Division of Waste Management and Radiation
Control