DRC-2024-004291

January 31, 2024
Vern C. Rogers
Director, Regulatory Affairs
EnergySolutions, LLC
299 South Main Street, Ste 1700
Salt Lake City, UT 84111
RE:Request for Information for the East Side Rotary Facility As-Built Report:Radioactive Material License UT 2300249
Dear Mr. Rogers:
On April 24, 2023, EnergySolutions submittedthe “East Side Rotary Facility As Built Report” (CD-2023-091, DRC-2023-003771) for the Construction Report and As Built Engineering Drawing
set for the East Side Rotary Facility (ESRF). Additionally, on October 11, 2023 (CD-2023-196) EnergySolutions submitted an addendum to the As-Built Report which provided: a completed
construction report and As-Build Drawings, ESRF Surety Analysis Report, Ground Water Quality Discharge Permit modification requests, technical basis document for the Environmental Monitoring
Plan Analysis, and a water balance analysis for the ESRF. This letter is a compilation of all outstanding requests and where needed a request for information for consideration to approve
the ESRF.
CD-2023-091 (DRC-2023-00371)
The narrative and record of the engineering as built is incomplete and needs to be updated to include:
The three dry wellsinstalled without Division review/knowledge or plans being submitted for approval. The result of dry well infill and removal/mediation from the plan set. Please update
the narrative to reflect the important distinction between an approved plan to close the sumps while the construction of the sumps themselves were not approved for construction.
Please address the steel structure collapse during construction and the steps taken to determine that the corrective actions assure that the building meets construction and safety standards.

Placing the new facility into service will require expansion of the Licensed Restricted Area boundary fence line beyond the East Side Rotary footprint.
Please provide clarificationfor therequest to modify the Restricted Area Boundary and include a standalone, updated drawing of this proposed expansion in the Licensed Restricted Area
for review including: section lines, property lines, and all relevant data for review.
CD-2022-029 (DRC-2022-001741)
Request 6 states, “Provide justification that there is sufficient water capacity in the existing East Side Drainage System and pond to accommodate the East Side Rotary Facility and all
existing management needs. ES Response: The existing 1995 and 1997 ponds do not have sufficient capacity to efficiently manage water from both the current facilities and the ESRF. EnergySolutions
will be submitting a design for a new 8.7 million gallon "East Evaporation Pond" that will replace the 1995 Pond, which will provide an additional 7.4 million gallons beyond the current
capacity (-1.3 million gallons) of the 1995 Pond. The new pond is schedule[d] for construction in 2023 (pending Director approval to construct).
According to EnergySolutions letter dated May 15, 2023, (CD-2023-106, DRC-2023-004371) the request to construct an East Evaporation Pond was rescinded. How will EnergySolutions ensure
that capacity will be met?
The proximity of the waste handling that will occur near the Elevated Water Tank on the North Side of the Restricted Area is a concern for the Division as standing water within the Restricted
Area has been observed year-round originating from the Elevated Water Tank. Please provide a plan that will rectify this infiltration point pathway or provide updated drawings that move
the Elevated Water Tank to a different location.
CD-2023-196 (DRC-2023-074200)
In statement 3, EnergySolutions states that,
“EnergySolutions agrees to monitor the effectiveness of the clay-lined gabion baskets via groundwater sample well(s). EnergySolutions will coordinate well installation with the Director
regarding other unrelated investigations. EnergySolutions acknowledges that the Director’s permit modification is prerequisite to placing the new East Side Rotary Facility into service…”
Wells associated with investigations such as the Petroleum Hydrocarbon investigation may require a well network that extends beyond the scope of the ESRF. For the ESRF to go into service,
a well-monitoring network specifically designed for this facility must be proposed by EnergySolutions. For guidance on the requirements, please reference the Ground Water Quality Discharge
permit,Appendix B: Water Monitoring Quality Assurance Plan and R317-6-6.3 where additional information may be required. This needs to include:
groundwater monitoring to determine groundwater flow direction and gradient, background quality at the site, and the quality of groundwater at the compliance monitoring point;
installation, use and maintenance of monitoring devices;
description of the compliance monitoring area defined by the compliance monitoring points including the dimensions and hydrologic and geologic data used to determine the dimensions;
monitoring of the vadose zone
measures to prevent groundwater contamination after the cessation of operation, including post-operational monitoring;
description and justification of parameters to be monitored
4.0 Alarm Testing at Manhole MH-1A Leak Detection System:
Please provide the pressure testing methodology used to ensure pipe integrity and resulting data collected as Division staff was not present for this process.
Attachment H Sealing of Rail/RailSeal at Facility Entrances
The sealing of the vertical joints at the ESRF entrances may solve some of the potential for contact water to leave the facility and move into the subsurface. Additionally,the following
variables need to be addressed to provide assurances to the Division:
What steps will be taken to prevent contact water run-off from exiting the facility at the gap caused from the rail line itself? This cannot be sealed with Aquascape Pond and Waterfall
Foam Sealant as it would preclude the rail line from functioning as intended. Given the intended design life of this facility, the Division is concerned about the long-term potential
for contamination to the groundwater through this pathway.
What process will be put into place to ensure that the Aquascape Pond and Waterfall Foam Sealant will continue to function as intended once the facility is in operation as it will not
be readily accessible for a visual inspection?
Redline Strikeout BAT Recommendations provided by EnergySolutions.
The recommendations for non-substantive changes such as grammatical errors, etc. are appreciated, however, the review of the requested changes to the GWQDP have only been reviewed as
they relate directly to the ESRF. No additional changes will be considered and must be submitted under a separate request for consideration from the Director.
Once the RFIs above have been satisfied, a Redline Strikeout Version of the GWQDP with relevant appendices will be provided to EnergySolutions.
As a reminder, no request for PCB wastes to be handled at the ESRF has been received. Therefore, no consideration will be given to any requests to handle PCB waste at the ESRF at this

time.
Please provide the expected facility life of the ESRF.
Technical Basis Document ESRF Environmental Monitoring Plan Analysis
The submitted ESRF Environmental Monitoring Plan Analysis is too limited in scope and lacking in technical analysis to be considered a viable document that supports the proposal of no
additional environmental monitoring be added because of the addition of the ESRF.
The Division does not agree with the statement purported by EnergySolutions that, “… no new, or unanalyzed condition is created by operating the East Side Rotary Facility,” in part because
the construction of a new waste-handling facility designed explicitly to handle bulk-radioactive waste creates an unanalyzed condition.
As part of the analysis, EnergySolutions states that, “… the northern perimeter fence-line is within EnergySolutions Owner-Controlled Property (secured by a 6-foot fence and 24-hour
security) and not easily accessible to the public. This claim does not have merit when considering dose at the fence line. According to §10CFR20.1301(2)(b) and R313-15-301(2), “If the
licensee or registrant permits members of the public to have access to controlled areas, the limits for members of the public continue to apply to those individuals.” To maintain compliance
with NRC and State regulations, the Northern Fence line of the Restricted Area should be the reference point as it is the closest boundary.
The licensee cited NUREG/CR-3332 as guidance that was utilized during the airborne particulate sample locations. However, this guidance is not listed in the currently approved Environmental
Monitoring Plan associated with RML UT 2300249. If this is an oversite, please provide the specific citationswithin the currently approved EMP that utilizes NUREG/CR-3332.
Please include the atmosphere transport modelling used in previously approved EMPs to include the in-service load of the ESRF and provide input and output values.
The Division will continue its evaluation of the submitted documents and may have additional requests for information. If you have any questions, please call Brandon Davis at385-622-1873.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/BBD/[???]
c:Jeff Coombs, Health Officer, Tooele County Health Department
Bryan Slade, Environmental Health Director, Tooele County Health Department
EnergySolutions General Correspondence Email
LLRW General Correspondence Email