DRC-2024-005623

[Date]
EnergySolutions, LLC
Attn: Jonathan Anderson, Environmental Compliance Manager
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
RE:Request for Information (RFI): Request for Approval to Construct an Evaporation Pond- Exhibit F: Confirmatory Sampling PlanRadioactive Materials License UT 2300249
Dear Mr. Anderson:
In reviewing EnergySolutions’ Request for Approval to Construct an Evaporation Pond (“Request") (DRC-2024-005275; CD-2024-080) submittal, the Division of Waste Management and Radiation
Control (“the Division”) has identified an area in Exhibit F: Confirmatory Sampling Plan that requires further detail. This RFI addresses only Exhibit F and additional questions regarding
the Requestwill be forthcoming.
The Division requests that EnergySolutions provide additional information:
Throughout Exhibit F, there is no discussion or mention of the specific number and locations of each proposed sample. Please provide to the Division a table with the initial number of
samples to be taken, the figure/map that shows thegrid spacingfor the initial sample area, and a figure/map with the locations of where the initial samples will be taken with justification.
As the purpose of CL-RS-PR-115 is to provide instruction for survey work inside a restricted area and that it does not provide instruction to workers for removing contaminated soils
outside of a restricted area, please clarify for the Division which procedure EnergySolutions would follow in the unlikely event that contamination is identified in the proposed pond
area.
CL-RS-PR-115 addresses radiological surveys, however, potential constituents of concern exist on the site in the subsurface. Specifically, a hydrocarbon investigation is underway at
the Clive Site in near proximity to the proposed Evaporation Pond location. Please update Exhibit F to include how, what, and where EnergySolutions plans to sample hydrocarbons.
Step 3. “Clear and grub the native vegetation satisfactorily to expose the native soils within that perimeter for sampling” does not provide confidence that the material being removedis
devoid of contamination. MARSSIM in land areas 4.8.4.2 states that, “Initial radiological screening surveys should be performed to ensure that cleared material or equipment is not contaminated.”
And that, “… precautionary procedures need to be developed to prevent spreading surface contamination during ground cover removal or the use of heavy equipment.”. The goal should not
be to remove all soils to a native soil level, but to capture values of potential contamination at the surface to include aeolian and saltation deposition. How does EnergySolutions intend
to accomplish this?
Please provide clarification as to where the soil excavated for the proposed pond will be placed for disposed.
UAC R313-15-301(1)(b) states the following with states with respect to Individual Members of the Public:
“The dose in any unrestricted area from external sources, exclusive of the dose contributions from patients administered radioactive material and released in accordance with Rule R313-32
(incorporating 10 CFR 35.75 by reference), does not exceed 0.02 mSv (0.002 rem) in any one hour”
As there will be individual members of the public working in the proposed pond area for prolonged amounts of time, which is also adjacent to areas of waste handling, please providefurther
information regarding how Clive intends comply with this rule and what methods are employed to ensure that this rule is complied with.
Please provide a schedule of when sampling will take place as the Division intends to split samples with EnergySolutions.
Please ensure that responses related to Radiation Safety are addressed by the Radiation Safety Officer, per Condition 31 of RML # UT 2300249
If you have any questions, please call Larry Kellumat (385)-622-1876.
Sincerely,
Otis H. Willoughby, Low-Level Waste Section Manager
Division of Waste Management and Radiation Control
OHW/[???/[???]
Enclosure(s):
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