DRC-2025-002683

[Date]
Vern C. Rogers, Director of Regulatory Affairs
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
[e-mail]
RE:Request for Information - Amendment Request to Adjust Occupancy Factors Radioactive Material License Number UT 2300249
Dear Mr. Rogers:
The Division of Waste Management and Radiation Control (Division) received your request to amend Radioactive Material License Number UT 2300249 by reducing the occupancy factor from
25% to 6.25% (DRC-2025-002237).
Utah Administrative Code (UAC)313-15-302(2)(a) requires a licensee to show compliance with the annual dose limit set forth through UAC R313-15-301 by, “Demonstrating by measurement or
calculation that the total effective dose equivalent to the individual likely to receivethe highest dose from the licensed or registered operation does not exceed the annual dose limit.”
Within the amendment request letter received by the Division, it details that the 25% occupancy factor was granted by the Division due to the distance from the Restricted Area boundary
to the
neighboring Clean Harbor’s facility. Due to EnergySolutions’ purchase of the western portion ofland adjacent to its property, the distance from the Restricted Area Boundary has changed
from 40 ft to more than 5,000 ft. The request to lower the occupancy factor assumesthat because of this landprocurement “the members of the general public that [now] receive the highest
dose along thewestern boundary of EnergySolutions’ Restricted Area are those traveling along theTooele County Road adjacent to the Restricted Area western boundary.”
In a letter from Envirocare of Utah Inc.to Dwight Chamberlain, the Director of the Division of Nuclear Materials Safety at the Nuclear Regulatory Commission in 1999, rationaleis provided
in support of being granted a 25% occupancy factor. Within this letter, Envirocare of Utah Inc. determined that “Due to the remoteness of the Clive Facility, it is most likely that the
Maximally Exposed Individual would be a member of the public that works at the site.” An unmonitored Engineering Secretary’s average year of working at the Clive Facility was utilized
in calculating the 25% occupancy factor by Envirocare of Utah Inc.
Request for Information:
Please provide the Division with details on why a member of the public that works at the Clive Facility would no longer be considered the most likely Maximally Exposed Individual when
calculating an occupancy factor.
Please elaborate on the rationaleof utilizing NCRP Report No. 49, which is concentrated on the structural shielding design and evaluation for medical use of x rays and gamma rays of
energies up to10 MeV, in generating the requested 6.25% occupancy factor.
Please respond to this request within 30 days of receipt of this letter.
If you have any questions, please contactBryan Woolf by email at [e-mail] by phone at 385-454-8060.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/BMW/xx
c:Taylor Palmer, Tooele County Health DepartmentEnergySolutions General Correspondence Email
LLRW General Correspondence Email
Jalynn Knudsen, Assistant Director,
Division of Waste Management and Radiation Control, UDEQ