DRC-2024-005429

[Date]
EnergySolutions, LLC
Attn: Thomas A. Brown, Radiation Safety Officer, Clive Facility
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
RE:Deep Dose Equivalent (DDE) Exceedance at Air Monitoring Station A-28 for the year of 2023Radioactive Materials License UT 2300249
Dear Mr. Brown:
The Division of Waste Management and Radiation Control (“Division”) has received a notification letter (the “Notification”)dated March 26, 2024 (DRC-2024-005110; CD-2024-060), which
outlines the details and circumstances relating to the exceedance of dose to the public recorded at Air Monitoring Station (A-28).
The Division appreciates the timeliness of this notification. As it is the Division’s duty to collect and maintain a complete administrative record relating to all licensing and compliance
actions, the Division requests that EnergySolutions provide clarification for the following items:
The Notification reports that the annual dose to individual members of the public recorded at A-28 to be the Deep Dose Equivalent (DDE) of 160 mrem/year. UAC R313-15-301 (1)(a) stipulates
that the Total Effective Dose Equivalent (TEDE) to any individual member of public must not exceed 100 mrem/year. Please provide to the Division your calculations for the TEDE to an
induvial member of the public.
Please provide to the Division clarification as to why an unanticipatedly large volume of waste volume disposed of in 2022 is the cause of a dose exceedance to the public nearly two
years after disposal seeing that there was no exceedance in public dose in 2022.
Please provide to the Division clarification/information as to how EnergySolutions’ system of tracking waste and specific activity at the various open cells/lifts failed to prevent/mitigate
this exceedance considering the proximity of the High Radiation Area’s to the county road.
In the Notification, EnergySolutions’ reported that mitigating actions were taken as far back as 2022 in connection to the exceedance in 2023/2024. However, the actions listed were almost
entirely carried out after the Division raised concerns regarding dose to the public based on the results of the 2023 First Semi-Annual Environmental Monitoring Report (CD-2023-195).
To remove ambiguity, provide a timeline with specific dates for each remedial action taken and if said action was part of operational procedures or specific to this incident.
Please provide clarification to the Division as to how the results of weekly fence line dose surveys failed to prompt closer scrutiny of dose to the public in the vicinity of A-28.
As part of your response, the Division requests the results of your Root Cause Analysis Report that evaluates the root and contributing causeto this exceedance to public dose.Additionally,
the Division requests that the Radiation Safety Officer respond to this letter within 30 days of receipt.
If you have any questions, please call Larry Kellumat (385)-622-1876.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/[???/[???]
Enclosure(s):
c:Local health Department (go to U:\HW General Folders\Local Health Depts and Dist. Engineers and insert correct health department file)
List all other persons who are to receive copies, including division staff.
List email addresses next to the names of persons who are to receive a copy via email. List mailing addresses next to the names of persons who are to receive a hard copy.