DRC-2021-005514 - 0901a06880e6d340

FEDERAL CELL FACILITY APPLICATION FOR A
RADIOACTIVE MATERIAL LICENSE
CLIVE, UTAH

APRIL 9, 2021

STATE OF UTAH RADIOACTIVE MATERIAL
LICENSE APPLICATION FOR A
FEDERAL CELL FACILITY

April 9, 2021

By
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111

For
Utah Division of Waste Management and Radiation Control
Post Office Box 144880
195 North 1950 West
Salt Lake City, UT 84114-4880

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TABLE OF CONTENTS

Section Title Page
SECTION 1. GENERAL INFORMATION 1-1
1.1 INTRODUCTION 1-2
1.2 GENERAL FACILITY DESCRIPTION 1-3
1.3 SCHEDULES 1-19
1.4 INSTITUTIONAL INFORMATION 1-21
1.5 MATERIAL INCORPORATED BY REFERENCE 1-21
1.6 CONFORMANCE TO REGULATORY GUIDES 1-21
1.7 SUMMARY OF PRINCIPLE REVIEW MATTERS 1-22
SECTION 2. SITE CHARACTERISTICS 2-1
2.1 GEOGRAPHY, DEMOGRAPHY AND FUTURE DEVELOPMENTS 2-1
2.1.1 Site Location and Description 2-1
2.1.2 Population Distribution 2-2
2.2 METEOROLOGY AND CLIMATOLOGY 2-5
2.3 GEOLOGY AND SEISMOLOGY 2-7
2.3.1 Geologic Site Characteristics 2-8
2.3.2 Seismology 2-9
2.4 HYDROLOGY 2-12
2.4.1 Surface Water Hydrology 2-12
2.4.2 Groundwater Characterization 2-14
2.5 GEOTECHNICAL CHARACTERISTICS 2-17
2.6 GEOCHEMICAL CHARACTERISTICS 2-19
2.7 NATURAL RESOURCES 2-21
2.7.1 Geological Resources 2-22
2.7.2 Water Resources 2-22
2.8 BIOTIC FEATURES 2-22
2.9 SITE CHARACTERISTIC PREOPERATIONAL MONITORING 2-26
SECTION 3. DESIGN AND CONSTRUCTION 3-1
3.1 PRINCIPAL DESIGN FEATURES 3-3
3.2 CONSIDERATIONS FOR NORMAL AND ABNORMAL/ACCIDENT CONDITIONS 3-5
3.3 CONSTRUCTION CONSIDERATIONS 3-15
3.3.1 Construction Methods and Features 3-15
3.3.2 Construction Equipment 3-16
3.4 DESIGN OF AUXILIARY SYSTEMS AND FACILITIES 3-17
3.4.1 Utility Systems 3-17
3.4.2 Auxiliary Facilities 3-17
3.4.3 Fire Protection System 3-19
3.4.4 Erosion and Flood Control Systems 3-19
SECTION 4. FACILITY OPERATIONS 4-1
4.1 FEDERAL GENERATOR CERTIFICATION 4-1
4.2 FEDERAL WASTE PROFILE RECORD 4-2
4.3 RECEIPT AND INSPECTION OF FEDERAL WASTE 4-2
4.4 WASTE HANDLING AND INTERIM STORAGE 4-4
4.5 FEDERAL WASTE DISPOSAL OPERATIONS 4-5
4.6 OPERATIONAL ENVIRONMENTAL MONITORING AND SURVEILLANCE 4-6
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SECTION 5. FEDERAL CELL FACILITY CLOSURE PLAN AND CONTROL 5-1
5.1 SITE STABILIZATION 5-1
5.1.1 Surface Drainage and Erosion Protection 5-2
5.1.2 Geotechnical Stability 5-3
5.2 DECONTAMINATION AND DECOMMISSIONING 5-5
5.3 POST-OPERATIONAL ENVIRONMENTAL MONITORING AND SURVEILLANCE 5-5
SECTION 6. SAFETY ASSESSMENT 6-1
6.1 RELEASE OF RADIOACTIVITY 6-1
6.1.1 Determination of Types, Kinds, and Quantities of Waste 6-2
6.1.2 Infiltration 6-2
6.1.3 Radionuclide Release - Normal Conditions 6-3
6.1.4 Radionuclide Release – Accidents or Unusual 6-4
6.1.5 Radionuclide Transfer to Human Access Location 6-6
6.1.6 Assessment of Impacts and Regulatory Compliance 6-12
6.2 INTRUDER PROTECTION 6-16
6.3 LONG-TERM STABILITY 6-17
6.3.1 Surface Drainage and Erosion Protection 6-17
6.3.2 Stability of Slopes 6-17
6.3.3 Settlement and Subsidence 6-18
SECTION 7. OCCUPATIONAL RADIATION PROTECTION 7-1
7.1 OCCUPATIONAL RADIATION EXPOSURES 7-1
7.2 RADIATION SOURCES 7-1
7.3 RADIATION PROTECTION DESIGN FEATURES 7-5
7.4 RADIATION PROTECTION PROGRAM 7-6
SECTION 8. CONDUCT OF OPERATIONS 8-1
8.1 ORGANIZATIONAL STRUCTURE 8-1
8.2 QUALIFICATIONS OF APPLICANT 8-1
8.3 TRAINING PROGRAM 8-1
8.4 EMERGENCY PLANNING 8-2
8.5 REVIEW AND AUDIT 8-3
8.6 FACILITY ADMINISTRATIVE AND STANDARD OPERATING PROCEDURES 8-4
8.7 PHYSICAL SECURITY 8-4
SECTION 9. QUALITY ASSURANCE 9-1
9.1 QUALITY ASSURANCE DURING THE DESIGN AND CONSTRUCTION 9-2
9.2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE 9-2
SECTION 10. FINANCIAL ASSURANCE 10-1
SECTION 11. HOUSE BILL 220 11-1
SECTION 12. REFERENCES 12-1

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LIST OF APPENDICES

Appendix Title
A Suggested Radioactive Material License for the Federal Cell Facility
B 2020 Annual Meteorologic Report (MSI, 2021)
C Hydrogeologic Report – Bingham Environmental (1992)
D Phase 1 Basal-Depth Study Report and 2021 Interrogatory Responses
E Revised Hydrogeologic Report – Waste Disposal Facility Clive, Utah
F 2020 Annual Groundwater Monitoring Report
G SWCA Vegetation Study (2011)
H Federal Cell Facility Engineering Drawings
I Proposed Federal Cell Facility Construction Quality Assurance/Quality Control Manual
(FCF CQA/QC Manual)
J Cover/Liner Construction Estimates
K Drainage Ditch Calculations
L Methodologies for Evaluating Long-Term Stabilization Designs (NUREG/CR-4620)
M Geosyntec Federal Cell Engineering Evaluation (Geosyntec, 2021)
N Neptune Erosion Analysis (Neptune, 2021a)
O Federal Cell Facility Waste Characterization Plan
P Neptune Cover infiltration Analysis (Neptune, 2021b)
Q Depleted Uranium Performance Assessment
R Financial Surety Calculations
S Example Standby Trust Agreements
T Long-Term Stewardship Agreement for the Federal Cell Facility
U Draft Memorandum of Agreement

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LIST OF FIGURES

Figure Title Page

1-1 EnergySolutions Site Location 1-12
1-2 EnergySolutions Property Ownership 1-13
1-3 Tooele County Hazardous Industrial District Zoning 1-14
1-4 EnergySolutions’ Clive Facility General Site Plan 1-16
2-1 EnergySolutions Wind Rose January 1993 – 2020 (MSI, 2021) 2-6
2-2 EnergySolutions Fault and Seismicity Map (AMEC, 2012) 2-11
11-11 Tooele County Subdivision Parcel Map 11-4

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LIST OF TABLES

Table Title Page

1-1 Utah Radiation Control Rules Compliance Matrix 1-4
1-2 NUREG-1199 Compliance Matrix 1-8
2-1 12-Kilometer Population Wheel 2-3
2-2 Tooele County Growth Projection: 2010-2030 2-4
2-3 Selected data from 26 earthquakes within 100 km of the Clive site. Data from catalogs 2-13
maintained by the University of Utah and the University of Nevada-Reno.
2-4 Geotechnical Properties of Clive Site Surface Soils 2-20
2-5 Preoperational Radioactivity Concentrations in Soil 2-27
3-1 Design Criteria of the Principle Design Features 3-4
3-2 Pertinent Characteristics of the Principle Design Features 3-6
3-3 Projected Performance of the Principle Design Features 3-9
6-1 Peak TEDE: Statistical Summary 6-8
6-2 Peak Groundwater Activity Concentrations within 500 years, Compared to GWPLs 6-10
6-3 Cumulative Population TEDE: Statistical Summary 6-11
6-4 Statistical Summary of Lake Water Concentrations at Peak Lake Occurrence 6-13
6-5 Statistical summary of Sediment Concentrations at Peak Lake Occurrence 6-14
6-6 Quantitative Assessment Results for Model Analyses 6-15
7-1 EnergySolutions Employee Annual Dose Summary 7-7

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SECTION 1. GENERAL INFORMATION

In accordance with applicable requirements, the Director of the Utah Division of Waste Management and
Radiation Control (Division) has issued several permits and licenses to EnergySolutions, LLC to receive,
store, and dispose, by land burial, the following categories of radioactive materials and waste:
• Naturally occurring and accelerator produced radioactive material (NORM) waste,
• Low-activity radioactive waste (LARW),
• Class A low-level radioactive waste (LLRW) (including concentrated depleted uranium prior to
2010),
• Special nuclear material (SNM),
• 11e.(2) waste, and
• Radioactive waste that is also determined to be hazardous (mixed waste).

EnergySolutions now holds the following licenses and permits that have been issued by the Director:
• State of Utah Radioactive Material License UT2300249, Amendment 25, under timely renewal;
• State of Utah Radioactive Material License, 11(e).2 Byproduct Material License UT2300478,
Amendment 2;
• State of Utah Part B Permit, U.S. Environmental Protection Agency (EPA) Identification Number
UTD982598898, under timely renewal; and
• State of Utah Ground Water Quality Discharge Permit (GWQDP) Number UGW450005, under
timely renewal.

To comply with applicable regulatory requirements and thereby justify granting the permits and licenses,
EnergySolutions’ applications documented, and the Director found acceptable site characteristics, facility
operations, occupational radiation protection, waste management operations, and a quality assurance program.
Via routine inspections, the Director ensures that these characteristics continue to function and promote
satisfaction of required performance objectives. Many site, facility, and administrative characteristics
applicable to this Application reflect conditions have already been subject to extensive review during other
licensing activities and approved by the Director.

The proposed Federal Cell Facility will be used for the disposal of federally generated or otherwise owned
radioactive waste and materials. The Director is responsible for regulating activities in the State of Utah that
involve radioactive materials, some types of radioactive waste, and radiation. As part of this responsibility,
the Director enforces requirements promulgated by the State of Utah in Utah Code 19-3, “Radiation Control
Act.” Requirements applying to land disposal of radioactive waste are contained in UAC Rule R313-25,
"License Requirements for Land Disposal of Radioactive Waste – General Provisions." Additional applicable
rules are contained in UAC Rule R313-15 "Standards for Protection Against Radiation," which defines
requirements for protecting individuals from the effects of radiation and UAC Rule R313-22, "Specific
Licenses," which identify licensing requirements, many of which are met by compliance with or superseded
by the provisions of UAC Rule R313-25. Additional chapters of the UAC are also applicable.

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The Radiation Control Act also includes specific requirements herein addressed that are prerequisite to
receiving license authority to dispose of concentrated depleted uranium. In order to be licensed to dispose of
concentrated depleted uranium, Utah Code §19-3-103.7(3) requires that the Director (a) approve a depleted
uranium performance assessment; (b) agree to a Federal Cell Facility designation and (c) enter into an
agreement wherein the U.S. Department of Energy (DOE) accepts perpetual management of the Federal Cell
Facility, title to the land on which the Federal Cell Facility is located, title to the waste in the Federal Cell
Facility, and financial stewardship for the Federal Cell Facility and waste in the Federal Cell Facility.

1.1 INTRODUCTION

The framework for the technical analysis of the disposal of radioactive waste was developed in the 1980s with
the U.S. Nuclear Regulatory Commission’s (NRC) issuance of Title 10 of the Code of Federal Regulations
(10 CFR) Part 61, “Licensing Requirements for Land Disposal of Radioactive Waste.” Part 61 establishes a
waste classification scheme based on the role that radionuclide concentrations and waste forms play in the
long-term performance of disposal facilities. When initially suggested for 10 CFR 61.55, concentrated
depleted uranium was considered Class A LLRW. Although included in the draft analysis, depleted uranium
was removed from the final Part 61 rule, because the nominal amounts of depleted uranium in need of disposal
were not found to create elevated risk to human health and the environment. Additionally, there were no
commercial facilities producing large quantities of depleted uranium at that time and depleted uranium in store
at Federal facilities was not regulated by the NRC; instead, it was controlled and managed by DOE as a
potential future resource. Because Utah is an Agreement State with the NRC, the Utah regulations for the
issuance of licenses for the land disposal of low-level radioactive wastes closely follow the NRC’s Part 61
regulations.

On February 28, 1988, EnergySolutions, LLC, a Utah limited liability company, (known then as Envirocare
of Utah, Inc.) was first issued a license by the Utah Bureau of Radiation Control to dispose of naturally
occurring radioactive material (NORM). On March 21, 1991, the Utah Bureau of Radiation Control granted
EnergySolutions a license to dispose of LARW. The license authorized receipt and disposal of a select group
of 44 radionuclides (including depleted uranium) with specific concentration limits less than the Class A limits
promulgated in UAC R313-15-1009. On October 5, 2000, EnergySolutions was issued Radioactive Material
License UT2300249 by the Utah Division of Radiation Control to manage and dispose of LLRW (including
depleted uranium) up to the Class A limits promulgated in UAC R313-15-1009. The Radioactive Material
License UT 2300249 was later renewed by the Director on January 25, 2005 and is currently in effect, under
timely renewal status.

On January 31, 2005, Envirocare of Utah, Inc. was sold and became Envirocare of Utah, LLC. On February
2, 2006, Envirocare of Utah, LLC became EnergySolutions, LLC, which is a subsidiary of EnergySolutions,
Inc. On January 7, 2013, EnergySolutions, LLC announced it had entered into agreement to be acquired by
Energy Capital Partners II, LLC. EnergySolutions, LLC is a privately held Utah limited liability company
with Corporate Headquarters at 299 South Main Street, Suite 1700, Salt Lake City, UT 84111. All references,
attachments, and appendices to this Application that were performed for, or in support of, Envirocare of Utah,
Inc. or Envirocare of Utah, LLC, are pertinent to this EnergySolutions Application.

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In October 2008, 5,408 drums of depleted uranium were sent to the EnergySolutions facility at Clive from
DOE’s Savannah River Site (SRS) for authorized disposal under Radioactive Material License UT2300249
(out of a total inventory of 33,000 drums needing final disposition). EnergySolutions was also informed that
DOE further intended to dispose of the large quantity of depleted uranium expected to be generated in facilities
in Ohio and Kentucky [~700,000 megagrams (Mg) or 700,000 metric tons; Neptune 2015]. Because depleted
uranium concentration limits were excluded when the final Part 61 rules were promulgated, the State of Utah
initiated formal rulemaking on March 2, 2010 to amend UAC R313-25 and Radioactive Material License
UT2300249, significantly limiting further disposal of concentrated depleted uranium until a site-specific
depleted uranium performance assessment (“DU PA”) could be completed.

In 2011, EnergySolutions submitted a DU PA to meet Condition 35 of License UT2300249 and requested
approval of the DU PA from the Director. EnergySolutions and the Director have worked in good faith on the
DU PA in the ensuing years. In 2018, the Director decided that EnergySolutions should apply for a unique
radioactive material license for a dedicated Federal Cell as the facility ultimately destined for receipt of DOE’s
concentrated depleted uranium. Therefore, EnergySolutions herein applies for a new Radioactive Material
License authorizing disposal of DOE-generated concentrated depleted uranium in a dedicated Federal Cell.
This Application is governed by Utah Administrative Code R313-25-9(5)(a), the applicable sections of Utah
Administrative Code R313-22, et seq., and Utah Code section 19-3-103.7 (among other applicable law)—but
not Condition 35 of License UT2300249.

To the extent practicable, the information presented in this Application was prepared in accordance with UAC
R313-25-13 and conforms to the format and outline suggested by NRC (NRC, 1991). Table 1-1 provides a
compliance matrix relating requirements found in the Utah regulations for the issuance of licenses for the land
disposal of radioactive wastes (UAC R313-25) to the location of this information in the Application.
Similarly, Table 1-2 provides a matrix relating this Application’s information to guidelines set forth by NRC
(1991), “Standard Format and Content of a License Application For a Low-Level Radioactive Waste
Disposal Facility.” A suggested Radioactive Material License for the Federal Cell Facility is provided in
Appendix A.

1.2 GENERAL FACILITY DESCRIPTION

The Clive site is on the eastern edge of the Great Salt Lake Desert, three miles west of the Cedar Mountains,
2.5 miles south of Interstate 80, and 1 mile south of a switch point called Clive on the tracks of the Union
Pacific system. Figure 1-1 shows the location of the site in relation to Salt Lake City and surrounding towns.
The disposal site is a parcel of land, consisting of one square mile in Tooele County, Utah. The land was
owned by the State of Utah, and, except for approximately 100 acres used in the Vitro Remedial Action
project, has been purchased by EnergySolutions. DOE owns the 100 acres used in the Vitro Remedial Action
project. The property owned by EnergySolutions, is Utah SLB&M, Section 32 of Township 1 South and
Range 11 West, Section 29 of Township 1 South, Range 11 West, and Section 5 of Township 2 South, Range
11 West, Tooele County, Utah.

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Table 1-1

Utah Radiation Control Rules Compliance Matrix

Rule Definition Application References
R313-25-1 Purpose and Scope
R313-25-2 Definitions
R313-25-3 Pre-licensing Plan Approval Criteria
for Siting of Commercial Radioactive
Waste Disposal Facilities.

(1) Persons proposing to construct or operate
commercial radioactive waste disposal
facilities shall obtain plan approval from
the Director before applying for a
license.
1.1
(2) The siting criteria and plan approval
requirements in R313-25-3 apply to pre-
licensing plan approval applications.
1.1
(3) This license requirement delineates
where treatment facilities, including
commercial radioactive incinerators
cannot be located. It specifies the
hydrogeologic, seismic, archeological,
and federal criteria that would prevent
the licensing of a disposal facility.
2.1-2.9
(5) Facilities may not be located within a
distance to existing drinking water wells
and watersheds for public water supplies
of one year ground water travel time plus
1,000 feet for incinerators and of five
years groundwater travel time plus 1,000
feet for land disposal facilities.
2.4
(6) The plan approval application shall
include hydraulic conductivity and other
information necessary to estimate
adequately the groundwater travel
distance.
2.6
(7) The plan approval application shall
include the results of studies adequate to
identify the presence of ground water
aquifers in the area of the proposed site
and to assess the quality of the ground
water of all aquifers identified in the area
of the proposed site.
2.5, 2.6, 2.7, 2.9
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Rule Definition Application References
(9) This license requirement specifies plan
approval requirements pertinent to
emergency response and safety during
operations at the disposal facility.
4.5
R313-25-4 License Required 1.1
(1) Persons shall not receive, possess, or
dispose of waste at a land disposal
facility unless authorized by a license
issued by the Director pursuant to R313-
25 and R313-22.
1.1
(2) Persons shall file an application with the
Director pursuant to R313-22-32 and
obtain a license as provided in R313-25
before commencement of construction of
a land disposal facility. Failure to
comply with this requirement may be
grounds for denial of a license and other
penalties established by law and rules.
1.1
R313-25-5 Content of Application
(1) In addition to the requirements set forth
in R313-22-33, an application to receive
from others, possess, and dispose of
waste shall consist of general
information, specific technical
information, institutional information,
and financial information, as set forth by
R313-25-6 through R313-25-10.
Section 1, Section 2, Section
3, Section 5, Section 10
R313-25-7 General Information
(1) Identity of the applicant. 1.1
(2) Applicant qualifications. 1.1
(3) Description of site location, waste and
technical abilities.
1.1, 1.2, 2.1, 2.3 - 2.10, 6.1,
6.2
(4) Proposed schedules for construction,
receipt, and waste emplacement.
1.3, 4.2, 4.3
R313-25-8 Specific Technical Information
(1) A description of the natural and
demographic disposal site characteristics
shall be based on and determined by
disposal site selection and
characterization activities. The
description shall include geologic,
geochemical, geotechnical, hydrologic,
ecologic, archeological, meteorological,
climatologic, and biotic features of the
disposal site and vicinity.
1.2, 2.1 - 2.9
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Rule Definition Application References
(2) Design feature descriptions, including:
water infiltration; cover integrity;
structural stability; contact water
management; disposal site drainage,
closure, and stabilization; elimination to
the extent practicable of long-term
disposal site maintenance; inadvertent
intrusion; occupational exposures;
disposal site monitoring; and adequacy of
buffer zone size.
1.2, Section 2, 3.1, 3.2, 3.3,
3.4, Section 5, Section 7
(3) Description of principal design criteria. Section 3
(4) Description of natural events or
phenomena on which the design is based
and their relationship to the principal
design criteria.
1.2, 2.1-2.9
(5) Description of codes and standards which
the applicant has applied to the design,
and will apply to the construction of the
land disposal facility.
1.1, 1.5, 1.6, Section 3, 6.2,
6.3, 4.8
(6) Description of construction and operation
of land disposal facility, including:
disposal unit construction methods, waste
emplacement and segregation methods,
types of intruder barriers, onsite traffic
and drainage systems, survey control
program, methods and areas of waste
storage, surface and groundwater waste
access control, and methods to be
employed in handling chelating agents or
other non-radiological substances which
might affect meeting the performance
objectives.
1.2, Section 2, Section 3,
Section 5, Section 7, 4.1-4.9
(7) Description of site closure plan,
including those design features which
will facilitate disposal site closure and
eliminate the need for active maintenance
after closure.
Section 5
(8) Identification of natural resources that
could lead to inadvertent intrusion.
2.9
(9) Description of radioactive waste (kind,
amount, classification, and
specifications).
6.2
(10) Description of QA program. Section 9
(11) Description of radiation safety program. 4.4, Section 7
(12) Description of environmental monitoring
program.
2.11, 4.9
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Rule Definition Application References
(13) Description of administrative procedures. 4.8, 9.5
(14) Description of the facility electronic
recordkeeping system as required in
R313-25-33.
4.2
R313-25-9 Technical Analyses
(1) Air, soil, groundwater, surface water,
animal burrowing will be considered in
general population protection. Analysis
will differentiate between roles
performed by the natural site
characteristics and roles performed by
design features.
1.2, 2.1, 6.4, 4.7
(2) Inadvertent intruder protection. 1.2, 6.4, 4.7
(3) Expected exposure to workers during
operation.
4.4, 6.3, 7.2
(4) Long term stability. Analysis based on
natural processes including erosion, mass
wasting, slope failure, settlement,
infiltration, and surface drainage.
Section 3, 6.4
(5) Performance Assessment that
demonstrates that the performance
standards will be met for the total
quantities of concentrated depleted
uranium for 10,000 years.
Appendix Q
R313-25-10 Institutional Information 1.4, 5.4, 10.3
(1) A certification from the agency which
owns the disposal site that the agency is
prepared to accept transfer of the license
when the provisions of R313-25-16 are
met and will assume responsibility for
institutional control after site closure and
for post-closure observation and
maintenance.
1.4
(2) Evidence, if the proposed disposal site is
on land not owned by the federal or state
government that arrangements were
made for assumption of ownership in fee
by the federal or state agency.
1.4
R313-25-11 Financial Information 1.4, 5.4, 10.1-10.3
R313-25-12 Requirements for Issuance of a
License by the Director

(1) Won’t cause unreasonable risk to public
safety or health.
2.1, 2.4, 2.7
(2) Applicant is qualified. 1.1
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Rule Definition Application References
(3) Disposal site is adequate: to protect the
public health and safety.
5.1, 6.3, 4.4, 4.6-4.9
(4) Disposal site is adequate: to protect from
inadvertent intrusion.
1.2, 4.7
(5) Disposal site is adequate: to protect
public post-closure.
1.2, 2.1, 2.4 - 2.8, 4.7
(6) Disposal site is adequate: long-term
stability.
2.1-2.10, 3.1, 4.3, 5.1, 6.4
(7) Applicant provides reasonable assurance
that the requirements of R313-25 will be
met.

(8) Demonstrate adequacy of institutional
controls.
4.6, 5.4, 9, 10.3
R313-25-13 Conditions of License
(5) Requirement to confine waste and waste
handling equipment to approved areas
only.
4.1-4.3
R313-25-14 Application for Renewal or Closure
(1) An application for renewal or an
application for closure shall be filled at
least 90 days prior to license expiration.
1.1
(2) Application requirements. 1.1
(3) If a licensee has filed an application in
proper form for renewal of a license, the
license shall not expire unless and until
the Director has taken final action to
deny application for renewal.
1.1
(4) In evaluating an application for license
renewal, the Director will apply the
criteria set forth in R313-25-11.
1.1
R313-25-15 Contents of Application for Site
Closure and Stabilization

R313-25-16 Post-Closure Observation and
Maintenance
4.9, 6.4
R313-25-17 Transfer of License: Following closure
and the period of post-closure
observation

R313-25-18 Termination of License
R313-25-19 General Requirement: Land Disposal
Facilities shall be sited, designed,
operated, closed, and controlled after
closure so that reasonable assurance
exists that exposure to individuals do
not exceed the limits stated in R313-
25-19 and 25-22.
Section 2, Section 3, Section
7
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Rule Definition Application References
R313-25-20 Protection of the General Population
from Releases of Radioactivity.
6.3, 6.4, 7.3
R313-25-21 Protection of Individuals from
Inadvertent Intrusion
1.2, 4.7, 6.4, 7.3
R313-25-22 Protection of Individuals During
Operations
6.3, 4.4, 7.3, 7.4
R313-25-23 Stability of the Disposal Site After
Closure
2.1, 2.3
R313-25-24 Disposal Site Suitability Requirements
for Land Disposal-Near-Surface
Disposal

(1) Primary emphasis: Isolation of wastes
and disposal site features that ensure that
the long-term performance objectives are
met.
2.1-2.10, 3.1-3.3
(2) The disposal site shall be capable of
being characterized, modeled, analyzed,
and monitored.
1.2, Section 2, 5.1, 5.3
(3) Future population growth considerations. 1.2, 2.1
(4) Natural resource considerations. 1.2, 2.9
(5) Flooding considerations. 2.5, 6.3
(6) Minimization of upstream drainage areas. 2.5
(7) The disposal site shall provide sufficient
depth to the water table that groundwater
intrusion, perennial or otherwise, into the
waste will not occur.
2.6, 2.7
(8) The hydrogeologic unit used for disposal
shall not discharge groundwater to the
surface within the disposal site.
2.5-2.8
(9) Seismic considerations. 2.4, 5.1
(10) Geologic process considerations. 2.4, 5.1
(11) Environmental considerations. 1.2, 2.10, 2.11, 4.9
R313-25-25 Disposal Site Design for Near-Surface
Land Disposal

(1) Primary emphasis: Long-term isolation. 2.1, 2.3-2.8, 5.1
(2) Design compatible with closure plan. 5.1
(3) Disposal site design requirements. 6.4, 4.3
(4) Cover requirements. 1.2, 3.1, 3.2, 3.3, 5.1, 5.1
(5) Ditch requirements.
(6) Water and waste contact issues. 2.5, 2.6, 5.1
R313-25-26 Near Surface Land Disposal Facility
Operation and Disposal Site Closure

(1) Segregation of Class A wastes. 1.2
(3) Waste acceptance requirements. Section 6, Section 7
(4) Waste emplacement requirements. 4.3
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Rule Definition Application References
(5) Void space minimization requirements. 4.3
(6) Radiation dose minimization
requirements.
4.4
(7) Boundary marking requirements. 1.2, 2.1, 6.3
(8) Buffer zone requirements. 4.3
(9) Closer and stabilization requirements. Section 5
(10) Disposal operation requirements. 4.3
(11) Waste specifications.
(12) Director authority. 1.1
R313-25-27 Environmental Monitoring
(1) Requirement for pre-operational
monitoring.
2.11, Section 2
(2) Maintenance of an environmental
monitoring program.
4.9
(3) Post operational monitoring. 5.3
(4) Emergency cleanup plans. 4.5
R313-25-29 Institutional Requirements Section 4, Section 6, 5.4,
10.1-10.3
R313-25-30 Applicant Qualifications and
Assurances
1.1, 9, 10.3
R313-25-31 Funding for Disposal Site Closure and
Stabilization
10.1-10.3
R313-25-32 Financial Assurances for Institutional
Controls
1.1, 5.4, 10.1-10.3
R313-25-33 Maintenance of Records, Reports, and
Transfers
1.1, 1.2, 5.4, 9.4-9.6
R313-25-34 Tests on Land Disposal Facilities 5.1

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Table 1-2

NUREG-1199 Compliance Matrix

Rule Definition Application
References
1.0 General Information
1.1 Introduction 1.1
1.2 General Facility Description 1.2
1.3 Schedules 1.3
1.4 Institutional Information 1.4, 5.4
1.5 Material Incorporated by Reference 1.5
1.6 Conformance to Regulatory Guides 1.6
1.7 Summary of Principle Review Matters 1.7

2.0 Site Characteristics
2.1 Geography, Demography, and Future
Developments 2.1
2.1.1 Site Location and Description 2.1.1
2.1.2 Population Distribution 2.1.2
2.2 Meteorology and Climatology 2.2
2.3 Geology and Seismology 2.3
2.3.1 Geologic Site Characterization 2.3.1
2.3.2 Seismic Investigation 2.3.2
2.4 Hydrology 2.4
2.4.1 Surface Water Hydrology 2.4.1
2.4.2 Groundwater Characterization 2.4.2
2.5 Geotechnical Characteristics 2.5
2.6 Geochemical Characteristics 2.6
2.7 Natural Resources 2.7
2.7.1 Geologic Resources 2.7.1
2.7.2 Water Resources 2.7.2
2.8 Biotic Features 2.8
2.9 Site Characterization Monitoring 2.9

3.0 Design and Construction
3.1 Principle Design Features 3.1
3.2 Design Considerations for Normal and
Abnormal/Accident Conditions 3.2
3.3 Construction Considerations 3.3
3.3.1 Construction Methods and Features 3.4.1
3.3.2 Construction Equipment 3.4.2
3.4 Design of Auxiliary Systems and
Features 3.4
3.4.1 Utility Systems 3.4.1
3.4.2 Auxiliary Facilities 3.4.2
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Rule Definition Application
References
3.4.3 Fire Protection System 3.4.3
3.4.4 Erosion and Flood Control System 3.4.4

4.0 Facility Operations
4.1 Receipt and Inspection of Waste 4.1
4.2 Waste Handling and Interim Storage 4.2
4.3 Waste Disposal Operations 4.3
4.4 Operational Environmental Monitoring
and Surveillance 4.9

5.0 Site Closure Plan and Institutional
Controls
5.1 Site Stabilization 5.1
5.1.1 Surface Drainage and Erosion Protection 5.1.1
5.1.2 Geotechnical Stability 5.1.2
5.2 Decontamination and Decommissioning 5.2
5.3 Post Operational Environmental
Monitoring and Surveillance 5.3

6.0 Safety Assessment
6.1 Release of Radioactivity 6
6.1.1 Determination of Types, Kinds, and
Quantities of Waste 6
6.1.2 Infiltration 6
6.1.3 Radionuclide Release - Normal
Conditions 6
6.1.4 Radionuclide Release - Accidents or
Unusual Operating Conditions 6
6.1.5 Radionuclide Transfer to Human Access
Location 6
6.1.6 Assessment of Impacts and Regulatory
Compliance 6
6.2 Intruder Protection 6
6.3 Long-Term Stability 6
6.3.1 Surface Drainage and Erosion Protection 6
6.3.2 Stability of Slopes 6
6.3.3 Settlement and Subsidence 6

7.0 Occupational Radiation Protection
7.1 Occupational Radiation Exposures 7.1
7.2 Radiation Sources 7.2
7.3 Radiation Protection Design Features 7.3
7.4 Radiation Protection Program 7.4

8.0 Conduct of Operations
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Rule Definition Application
References
8.1 Organizational Structure 8.1
8.2 Qualifications of Applicant 8.2
8.3 Training Program 8.3
8.4 Emergency Planning 8.4
8.5 Review and Audit 8.5
8.6 Facility Administrative and Operating
Procedures
8.6
8.7 Physical Security 8.7

9.0 Quality Assurance
9.1 Quality Assurance During the Design and
Construction Phase
9.1
9.2 Quality Assurance During the Operations
Phase
9.2

10.0 Financial Assurance
10.1 Financial Qualifications of Applicant 10.1
10.2 Funding Assurances 10.2
10.3 Corporate Guarantees 10.3
10.4 Assets Held by a Third Party Such as in a
State Fund
10.4
10.5 Trusts and Standby Trusts 10.5
10.6 Other Financial Assurances 10.6
10.7 Adjustment to Surety Amounts 10.7
11.0 References Section 11

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Most of the land within a 10-mile radius of the site is predominantly within the public domain, as administered
by the U.S. Bureau of Land Management (BLM). As is illustrated in Figures 1-2 and 1-3, the non-federally
owned lands around the Clive facility have been designated as a Hazardous Industrial District MG-H by
Tooele County. This designation limits, through zoning, the future uses of land in the area of the disposal
facility to heavy industrial processes (General Industrial District M-G type uses) and to industries dealing with
hazardous wastes, by the issuance of conditional use permits. Because the Hazardous Industrial District MG-
H designation does not authorize any other types of land-use, it also reduces the potential for population
encroachment near EnergySolutions’ Clive facility. In fact, previous to the Vitro project, there were no
industrial, residential, or municipal activities near the site. Since that time, three hazardous waste facilities
have located in the Clive area:
• Clean Harbors’ Grassy Mountain facility, a commercial, hazardous waste, treatment, storage and
disposal facility located greater than ten miles north-northwest of EnergySolutions’ Clive facility;
• Clean Harbors’ Aragonite facility a 140 million Btu slagging rotary kiln with a vertical afterburner
chamber located approximately 8 miles east-northeast of EnergySolutions’ Clive facility; and,
• Clean Harbors Clive facility, a defunct incinerator site currently permitted for transfer and storage of
hazardous waste located one mile west of EnergySolutions’ Clive facility.

No new industrial facilities have been established in this area of Tooele County’s West Desert since June 30,
1988. Individuals who work at these facilities do not live on site, nor do they represent permanent residential
population centers.

The remoteness of the site from the urbanized areas of Tooele County makes the surrounding area an
improbable location for any other significant industrial use which might be impacted by the disposal project.
BLM has seasonal sheep and cattle grazing allotments near Clive. Additionally, the low precipitation and high
evaporation rates are not conducive to any sustainable crop yields.

The groundwater at Clive is classified as Class IV, saline ground water according to UAC R317-6-3 Ground
Water Classes, with total dissolved solids (TDS) concentrations ranging from 30,000 mg/L to 100,000 mg/L.
Because of the naturally poor quality and high salinity, the underlying groundwater in the vicinity of the Clive
site is not suitable for most human uses or potable for humans (Lundberg, 2014). Because of this, residential
population cannot be centered in this area as the groundwater dramatically exceeds the Utah Division of
Drinking Water primary and secondary drinking water standards.

EnergySolutions operates an LLRW disposal facility west of the Cedar Mountains in Clive, Utah. Clive is
located along Interstate-80, approximately 3 miles south of the highway, in Tooele County. The facility is
approximately 50 miles east of Wendover, Utah, and approximately 60 miles west of Salt Lake City, Utah.
The facility sits at an elevation of approximately 4,275 feet above mean sea level (amsl) and is accessed by
both road and rail transportation.

Separate than that herein considered, EnergySolutions has licensed four disposal facilities. In addition, DOE
constructed and owns the Vitro Federal Disposal Facility located adjacent to EnergySolutions’ facilities. A
current site layout is provided on Figure 1-4, including the location of the Federal Cell Facility in relation to
other site facilities. A brief description of these five facilities follows.

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Figure 1-1. EnergySolutions Site Location
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Figure 1-2. EnergySolutions Property Ownership
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Figure 1-3. Tooele County Hazardous Industrial District Zoning.

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Vitro Federal Disposal Facility: The Vitro Federal Disposal Facility was constructed between 1984 and 1988
and is owned by DOE. It contains waste generated by the cleanup of the Vitro Chemical Company site in
South Salt Lake City, Utah. This plant had processed uranium and vanadium ore from 1951 through 1968.
Total capacity of the Vitro Federal Disposal Facility is approximately 2.5 million cubic yards.

LARW Disposal Facility: The LARW Facility was EnergySolutions’ first disposal facility at the Clive
Disposal Complex. Disposal operations began in 1988 as a Naturally Occurring Radioactive Materials
(NORM) Disposal Facility, with Low-Activity Radioactive Waste later included for disposal. The LARW
Disposal Facility is completed and covered, with final waste placed on May 26, 2004 and final cover
completed June 12, 2006. Environmental monitoring activities continue, as described in this Application.
Total capacity of the LARW Disposal Facility is approximately 2.2 million cubic yards.

Mixed Waste Disposal Facility: Disposal operations in the Mixed Waste Disposal Facility began in early
1992, as authorized by a state-issued Part B Permit (EPA ID Number UTD982598898), originally issued to
EnergySolutions by the Utah Division of Solid and Hazardous Waste on November 30, 1990. Mixed wastes
contain both hazardous and radioactive constituents. EnergySolutions also disposes of select non-hazardous
radioactive wastes in the Mixed Waste Disposal Facility. Total design capacity of the Mixed Waste Disposal
Facility is approximately 1.3 million cubic yards.

11e.(2) Federal Byproduct Facility: Disposal operations in the 11e.(2) Federal Byproduct Facility began in
fall 1994 and are restricted to the disposal of 11e.(2) byproduct material (uranium and thorium wastes), as
authorized by Byproduct Material License (UT 2300478) issued to EnergySolutions by the Director on
November 30, 2003. Prior to 2021, the total design capacity of the 11e.(2) Federal Byproduct Facility was
approximately 5.0 million cubic yards. In conjunction with this Application, EnergySolutions filed a request
on February 26, 2021 (via CD-2021-030) to reduce the licensed footprint of the 11e.(2) facility from
5,048,965 yd3 to 1,629,255 yd3 to accommodate the Federal Cell Facility footprint herein proposed. That
amendment request is currently under review by the Director.

Class A West Facility: Disposal operations in the Class A Facility (a predecessor to the Class A West Facility)
began in summer 2000. A second LLRW Disposal Facility was initially licensed in 2005 (the Class A North
Disposal Facility). The Class A and Class A North disposal facilities were combined into the Class A West
Disposal Facility in late 2012. EnergySolutions also licensed the Clive Containerized Waste (CWF) disposal
concept to manage radioactive waste shipments with higher contact radioactivity (but with relatively low
volumes) in contrast to the LLRW typically disposed at Clive (higher volumes of low activity waste). The
CWF is wholly contained within the Class A West Disposal Facility. In addition to the CWF, a footprint has
been designated as a clean restricted area reserved for disposal of large components. Total design capacity of
the Class A West Disposal Facility is approximately 8.7 million cubic yards.

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Figure 1-4. General Clive Disposal Complex Layout
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Section 29 Railyard Facility: In 2018, EnergySolutions received permission to receive, store and transload
railcars containing radioactive materials or having residual surface radioactivity above unrestricted release
levels within a new railyard facility constructed in Section 29 of their owner-controlled property (immediately
adjacent and north of the property licensed for management and disposal of LLRW (Section 32).
EnergySolutions’ Railcar Facility includes 10 Ladder Tracks (approximately 3 miles), creating a capacity to
store an LLRW-dedicated rail fleet of approximately 300 railcars, maintenance / repair support facilities and
infrastructure to transload intermodals, sealands and other bulk containers.

On January 4, 2008, EnergySolutions requested a design change to the 11e.(2) Cell that would allow LLRW
to be disposed of in the western portion of the 11e.(2) Cell, which was and still is unused. That configuration
was known as the Class A South (CAS) Cell proposal. That LLRW disposal area was to be 1,472 feet by
1,860 feet in size. Following consideration of operational efficiencies, interest in a separate CAS cell was later
amended to request combination of the legacy Class A and Class A North embankments into the currently
licensed single Class A West embankment. EnergySolutions herein proposes that a Federal Cell Facility be
licensed in the area originally considered for the CAS cell and be physically separated from the 11e.(2) Cell.

The Clive Complex is served by Rocky Mountain Power for electric power. Electric service includes three-
phase 440-volt service. Additionally, EnergySolutions has installed a telephone cable. EnergySolutions does
not have a public supply of water, and transports potable water to site storage tanks from Grantsville, Utah.
Non-potable groundwater (provided by a well owned by EnergySolutions north of Interstate 80) and collected
storm water are used for decontamination and dust suppression. Sanitary sewage is handled via septic tank
drainage fields.

Many of the Clive facilities, buildings, and infrastructure are common to the operating areas of the facility
and will support EnergySolutions’ Federal Cell Facility disposal operations. Key facilities and buildings (with
building numbers from Figure 1-4 parenthetically noted) that will be utilized to support Federal Cell Facility
disposal operations include:
• Track #4 Rail Wash Facility (12): A railcar decontamination facility within the Clive Facility
Restricted Area.
• Intermodal Unloading Facility (16): This facility is used for unloading bulk intermodal
containers.
• 1997 Evaporation Pond (19), 1995 Evaporation Pond (23), 2000 Evaporation Pond (42) and
Northwest Corner Evaporation Pond (51): Storm water collected from non-hazardous waste
management and disposal facilities is contained and evaporated in these ponds.
• LARW Container Storage Pad (24): This facility is used for the short-term storage of waste filled
containers (boxes, drums, etc.).
• East LLRW Truck Unloading Facility (41): Trucks carrying containers of waste can be unloaded
without bringing the truck into the restricted area. Large equipment reaches over the Restricted
Area boundary to transfer the containers of waste from the trucks into the Restricted Area.
• Batch Plant (62): The batch plant produces concrete for construction and waste disposal
operations.
• Waste Haul Roads (65): Waste haul roads are used to haul waste from receiving areas to final
placement within the Federal Cell Facility. Also used for general operations within the facility.
• Perimeter Road (66): The perimeter road provides general site access.
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• Rotary Dump Facility (Thaw, Rotary & Wash) (67): This facility is used to thaw and offload
bulk rail shipments received in gondola type railcars. It is also used for the decontamination of
railcars after waste is offloaded.
• Meteorological Station (68): Weather station equipment is used to gather wind, temperature,
evaporation, and precipitation data.
• QC & GW Laboratories Building (70): Offices and laboratories for quality control (QC) and
groundwater/environmental monitoring.
• Outside Maintenance Building (57): Maintenance facilities for equipment not used in the
Restricted Area. Offices for quality control (QC) and groundwater and environmental monitoring.
• Shredder Facility (75): The shredder facility is utilized to size reduce waste debris.
• Intermodal Container Wash Facility (78): Supports decontamination of waste shipping
containers.
• Administration Building (1): The Administration Building houses office space for Security,
Shipping and Receiving, Health Physics, Engineering and Quality Assurance.
• LLRW Operations Building (82): This building houses administrative offices, laboratories, and
locker rooms; as well as the principal access control point to the Restricted Area.

The storage and concentrated depleted uranium handling areas will include, but are not limited to, the LARW
storage pad (24), the Rotary Dump Facility (67), the Truck Unloading Facility (41), and the Federal Cell
Facility.

Decontamination of workers, if needed, takes place at the Operations Building (5). Railcars are
decontaminated at the Railcar Decontamination Facilities (12). Containers, other than railcars, transported
via rail are decontaminated at the Intermodal Container Wash Facility (78). Vehicle maintenance inside the
Restricted Area is performed at the Inside Maintenance Shed (8), or in the north bay of the Mixed Waste
Operations Building (32). Decontamination and wastewater management facilities also include the Intermodal
Container Wash Building (78), East Side Drainage and Gray Water System, and Northwest Corner
Evaporation Pond (51). Design and operation of these facilities will be unaffected by this Application. No
new support facilities are proposed in this Application to specifically serve the Federal Cell Facility.

Site security procedures for the Clive facility are provided in the Site Radiological Security Plan referenced
in Condition 54 of License UT2300249. The Site Radiological Security Plan requires that personnel enter the
Restricted Area through designated access control points in the LLRW Operations Building. Traffic is
allowed to enter the site through one of the approved access gates.

The entire controlled area of the Clive Facility is fenced to ensure that intruders do not gain access to the site
inadvertently. The fences are posted with appropriate warning signs, and all entrances into the work areas are
locked or guarded by personnel when unlocked. All fences are of the chain link type. Temporary fencing is
constructed with “T” posts located at least every 12 feet. Permanent fencing is built with permanent posts
cemented in concrete and topped with 3 strands of barbed wire. In order to assist security personnel in
identifying material or equipment that has been removed from the Restricted Area without authorization, the
Site Radiological Security Plan requires vegetation near the fence lines to be removed.

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The Site Radiological Security Plan requires that signs be present to guide visitors to the Administration
Building. Because some visitors to the Clive facility remain within the Administration Building or are
required to always be accompanied by an authorized escort, visitors desiring unescorted access beyond the
Administration Building are briefed on radiation posting, security measures and general risks found at the
Clive Facility.

Standard heavy construction equipment will be used for the operation of the Federal Cell Facility. The actual
equipment will vary, but it will normally consist of rock trucks, bulldozers, track mounted backhoes, front-
end loaders, water trucks, and other equipment as required. The Federal Cell Facility will utilize the same, or
similar, equipment currently used at the Clive Complex. Daily service and maintenance of the equipment is
performed in the Restricted Area. If required, major service may be performed outside of the Restricted Area.
Equipment serviced outside of the Restricted Area is decontaminated and surveyed to applicable release
standards prior to release from the Restricted Area.

Excavated materials will be used in the construction of the Federal Cell Facility. Clays and other soil materials
are excavated from Sections 5 and 29, for use in disposal facility liner and cover construction, as required.
Other borrow materials are excavated from publicly-available sources nearby. Excavated materials are often
stockpiled on EnergySolutions property to the north and south of the disposal facilities.

1.3 SCHEDULES

A schedule for construction, placement of depleted uranium and eventual closure of the Federal Cell Facility
is subject to receipt of a Radioactive Material License, execution of the prerequisite long-term stewardship
agreements, successful construction, and rate of generation and shipment by DOE of concentrated depleted
uranium. Much of the necessary excavation for the Federal Cell Facility has already been completed through
clay and sand material excavation activities supporting construction of other EnergySolutions Clive disposal
facilities. Additionally, EnergySolutions’ existing equipment has been demonstrated as appropriate for
embankment construction and personnel experienced in construction to the applicable specifications. No
additional personnel or equipment will be necessary to construct and operate the Federal Cell Facility. Upon
awarding of a License for the Federal Cell Facility, foundation preparation and liner construction is anticipated
to commence during the next available construction season. The Director will be notified prior to liner
construction activities in order to facilitate inspection. Additionally, EnergySolutions will continue to provide
the Director with detailed weekly construction schedules during clay liner construction projects.
EnergySolutions’ Annual As-Built Reports will provide detailed information regarding each year’s progress
in Federal Cell Facility construction activities.

In construction of Federal Cell Facility’s liner, between 4 and 8 equipment operators will excavate within the
Federal Cell Facility’s footprint to a depth of approximately seven to ten feet below native grade with existing
equipment. Overburden removed in reaching foundation elevation will be stockpiled for future use in liner
construction, capping the embankment, or as fill material. Between 4 and 8 equipment operators will then
compact the Federal Cell Facility’s foundation from in-situ soils to meet design, grade, and compaction
specifications. Excavation and foundation preparation of the Federal Cell Facility is projected to be completed
within 2 months of commencing construction. The Federal Cell Facility’s clay liner will then be constructed
by compacting clay using methods demonstrated with a Clay Liner Test Pad. Between 4 and 8 equipment
operators will place and compact clay liner materials in lifts. Clay liner construction within the Federal Cell
Facility footprint is projected to require approximately 3 months.
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Once the approved footprint has been excavated to foundation and clay liner built, existing EnergySolutions
operators using existing equipment will commence disposal of concentrated depleted uranium. Immediate
placement of the 5,408 drums of SRS depleted uranium already in storage at the Clive Disposal Complex is
expected in the Federal Cell Facility in 2022 (following construction of sufficient clay liner). Waste placement
will be conducted in accordance with the specifications. Following acceptance and unloading, concentrated
depleted uranium containers will be placed in order to minimize the volume of void spaces between
containers. Containers will be placed to minimize entrapped air in the disposal lift. Quality Control Inspectors
will visually inspect the placed waste for compliance with the specifications. After an acceptable quality
control inspection, the lift will be backfilled by pouring CLSM over the waste. Standard concrete mixing and
delivery equipment will be used to pour CLSM in the disposal region. The flowability of the CLSM will be
controlled to ensure adequate filling of the voids. Quality Control Inspectors will test the CLSM against the
specifications. The schedule and required manpower for placement of concentrated depleted uranium will be
a function of receipt rate. EnergySolutions projects receipt of approximately 50% of DOE’s remaining
projected volume of depleted uranium over a 20-year period (i.e., 50% of 700,000 metric tons). The Federal
Cell Facility’s waste volume and nuclide-specific disposed activities will be reported annually to the Director.
It is not anticipated that additional personnel or equipment will be necessary to operate the Federal Cell
Facility.

Closure of the Federal Cell Facility will take place after the concentrated depleted uranium has been placed
within the approved, below-grade disposal areas. Once the available disposal capacity for concentration
depleted uranium (below grade and beneath the Embankment’s top slope) has been consumed and backfilled
with CLSM, fill meeting the required specifications will be placed in the Federal Cell Facility to the Director-
approved design height and covered to meet final design specifications before being closed. Fill placement
will be completed with existing operators and equipment and expected to require a minimum of 2 years.

Prior to final cover construction, closure activities will include settlement monitoring. Settlement monitoring
includes a requirement that temporary cover be placed and monitored for at least one year prior to final cover
construction, with evaluation of differential settlement. If differential settlement exceeds or is projected to
exceed the established criteria, surcharging of affected areas is required. Settlement will be completed using
existing operators and equipment and expected to be completed within 18 months.

Following completion of settlement monitoring, the final cover will be constructed, and the Federal Cell
Facility closed, using existing equipment and labor. It is projected that cover construction of the Federal Cell
Facility will require 4 years. Upon final closure of the Federal Cell Facility, the prerequisite activities required
for transition of the closed Federal Cell Facility to DOE will commence. It is expected that the transition
activities will require 5 years to complete. Following completion, the decommissioned Federal Cell Facility
will be subject to DOE for long-term surveillance.

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1.4 INSTITUTIONAL INFORMATION

EnergySolutions has 30 over years of experience with the design, construction, management, engineering, and
operation of radioactive waste disposal at the Clive site. Since receiving its first radioactive material license
in 1988, EnergySolutions has completed construction on a low-activity radioactive waste (LARW) Facility
and is currently constructing a RCRA mixed radioactive and hazardous waste (Mixed Waste) Disposal
Facility, the Class A and Class A North Disposal facilities (which have now been combined into the Class A
West Disposal Facility), and a uranium- and thorium-mill radioactive tailings 11e.(2) Byproduct Disposal
Facility.

Division regulations UAC R313-25-3(8) and UAC R313-25-9(2) require that “that if the proposed disposal
site is on land not owned by state or federal government, that arrangements have been made for assumption
of ownership in fee by a state or federal agency.” EnergySolutions and DOE entered into an Agreement that
establishes covenants and restrictions related to DOE long-term stewardship of the Federal Cell Facility. This
Agreement requires transfer of ownership of the closed Federal Cell Facility (including land and disposed
waste) from EnergySolutions to DOE for permanent maintenance and monitoring. In support of this transfer,
EnergySolutions will pledge surety for use at the Federal Cell Facility, to allow the complete decontamination,
decommissioning, closure and other reasonably expected activities following closure.

Funds for the closure, decommissioning and long-term surveillance of the facility will be made available
through surety bonds, established by EnergySolutions and a Standby Trust Agreement established with Zions
First National Bank. EnergySolutions will also establish funds with Zions First National Bank for the post-
closure care of the closed and stable Federal Cell Facility. Following closure, post-closure care monies will
be released to address costs required for stewardship of the closed Federal Cell Facility. As is already required
for its other disposal facilities, EnergySolutions will annually review and revise the amount of funds required
to close and for post-closure care of the Federal Cell Facility. Results of this annual review and any
adjustments in funding conducted will be reported to the Director and DOE by March 1 of each year.

1.5 MATERIAL INCORPORATED BY REFERENCE

Section 11 of this Application lists the references herein cited. Other references supporting the information
that the Director has previously found acceptable (noted in “blue”) can be found in EnergySolutions’ other
radioactive material license applications, requests, permits and permit modification requests.

1.6 CONFORMANCE TO REGULATORY GUIDES

To the extent practicable, the information presented in this Application was prepared in accordance with UAC
R313-25-13. Additionally, EnergySolutions strives to meet and exceed all requirements applicable to its
operations, including
• NUREG-0902, “Site Suitability, Selection and Characterization;”
• NUREG-1199, “Standard Format and Content of a License Application for a Low-Level Radioactive
Waste Disposal Facility;”
• NUREG-1200, “Standard Review Plan for the Review of a License Application for a Low-Level
Radioactive Waste Disposal Facility;”
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• NUREG-1293, “Quality Assurance Guidance for a Low-Level Radioactive Waste Proposal Facility;”
• NUREG-1300, “Environmental Standard Review Plan for the Review of a License Application for a
Low-Level Radioactive Waste Disposal Facility;”
• NUREG-1388, “Environmental Monitoring of Low-Level Radioactive Waste Disposal Facility;”
• NUREG-1623, “Design of Long-Term Erosion Protection Covers for Reclamation of Uranium Mill
Sites;”
• NUREG/CR-2700, “Parameters for Characterizing Sites for Disposal of Low-Level Radioactive
Waste;”
• Regulatory Guide 1.8, “Personnel Selecting and Training;”
• Regulatory Guide 1.28, “Quality Assurance Program Requirements (Design and Construction);”
• Regulatory Guide 1.33, “Quality Assurance Program Requirements (Operational);”
• Regulatory Guide 1.74, “Quality Assurance Terms and Definitions;”
• Regulatory Guide 4.14, Revision 0, “Radiological Effluent and Environmental Monitoring at
Uranium Mills”.
• Regulatory Guide 4.15, "Quality Assurance for Radiological Monitoring Programs (Normal
Operations) - Effluent Streams and the Environment;”
• Regulatory Guide 4.18, “Standard Format and Content of Environmental Reports for Near-Surface
Disposal of Radioactive Waste;”
• Regulatory Guide 8.10, “Operating Philosophy for Maintaining Occupational Radiation Exposure As
Low As Is Reasonably Achievable;”
• Regulatory Guide 8.15, “Acceptable Programs for Respiratory Protection;”
• NRC’s “Final Standard Review Plan for Review and Remedial Action of Inactive Mill Tailings Sites
under Title I of the Uranium Mill Tailings Radiation Control Act, Revision 0;” and
• NRC’s 1982 “Technical Position on Near-Surface Disposal Facility Design and Operation.”

1.7 SUMMARY OF PRINCIPLE REVIEW MATTERS

This Application addresses the principal matters required for Director’s review. EnergySolutions requests the
Director issue a new Radioactive Material License to authorize management and disposal of concentrated
depleted uranium in a Federal Cell Facility.

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SECTION 2. SITE CHARACTERISTICS

EnergySolutions’ overarching objective for its Federal Cell Facility siting and design decision focuses on the
permanent isolation of concentrated depleted uranium. These decisions target minimizing disturbance and
dispersion by natural forces, without the need of ongoing maintenance. For practical reasons, specific siting
decisions and design standards involve finite times [a compliance period of 10,000 years for depleted uranium
has been promulgated in UAC R313-25-9(5)]. The Director has previously reviewed and approved that Clive
general site characteristics are appropriate for siting disposal facilities (UDRC, 2012). The information
justifying License UT2300249 and other relevant documents, (engineering reports, supplemental data
submissions and interrogatory responses) indicate that the requirements of UAC R313-25-3 are met for
facilities licensed at Clive, Utah. The legal location of the operating Clive radioactive waste disposal facility
as Section 32, Township 1 South, Range 11 West, Salt Lake Basin and Meridian (SLB&M), Tooele County,
Utah.

The proposed disposal site and activities for the Federal Cell Facility are conceptually similar to those of the
licensed Class A West embankment, with the exception of including a smaller Federal Cell Facility footprint
size and height. The Federal Cell Facility is designed as a primarily below-grade disposal embankment (with
fill placement between grade and design height of the Federal Cell Facility final cover. The following site
features are considered in judging the adequacy of the Federal Cell Facility:
a. Remoteness from populated areas;
b. Hydrology and natural conditions that contribute to immobilization and isolation of contaminants
from groundwater resources; and
c. Minimal impact of erosion, disturbance, and dispersion by natural forces over the long-term.

2.1 GEOGRAPHY, DEMOGRAPHY AND FUTURE DEVELOPMENTS

The geography, demography and the limited potential for any future residential developments are appropriate
for siting disposal facilities at the Clive site. The Federal Cell Facility will be situated in a remote area of
Tooele County in the western portion of Utah. The nearest resident is a person acting as caretaker at a rest
stop along I-80, roughly 7 miles to the Northeast, with the nearest community being approximately 35 miles
from the site. Strict access control and security provide additional assurance of protection to the public. The
Federal Cell Facility is designed to minimize dispersion of fill material and subsurface waste by resisting
water erosion, wind erosion, geotechnical instability and other natural events. All features are designed to
promote Federal Cell Facility stability.

2.1.1 Site Location and Description

The site’s location is appropriate for siting disposal facilities. The Clive site is on the eastern edge of the Great
Salt Lake Desert, three miles west of the Cedar Mountains, 2.5 miles south of Interstate 80, and 1 mile south
of a switch point called Clive on the tracks of the Union Pacific system. The Clive Disposal Complex is
located on a parcel of land, consisting of one square mile in Tooele County, Utah. The land is owned by
EnergySolutions, with the exception of approximately 100 acres owned by DOE for the Vitro Remedial
Action project. The licensed property owned by EnergySolutions, is Utah SLB&M, Section 32, Township 1
South, Range 11 West, Tooele County, Utah, except for the following legal description of the Vitro site:

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Beginning at a point located 1120.32 feet N 89 degrees 56' W., along the section line, and 329.49 feet
South from the Northeast corner of Section 32, Township 1 South, Range 11 West, Salt Lake Base
and Meridian and running thence: N 89 degrees 56' 32" W 1503.72 feet, thence S 0 degrees 03' 28"
W 2880.50 feet, thence S 89 degrees 56' 32" E 1503.72 feet, N 0 degrees 03' 28" E 2880.50 feet to the
point of the beginning.

Operations are conducted in Sections 5, 29, and 32 (Township 1 South, Range 11 West, SLB&M), of Tooele
County, Utah. These locations are known as Clive, Utah. Most of the land within a 10-mile radius of the site
is public domain administered by BLM. Land use in the immediate vicinity of the Site will not be affected
by granting of the License, since the Federal Cell Facility and associated licensed actions are located entirely
within the licensed area of Section 32.

While EnergySolutions also owns property adjacent to the licensed area, properties outside of Section 32 are
not licensed for active LLRW management. The south portion of the site contains EnergySolutions’ Class A
West Federal Cell Facility, LARW Facility, Mixed Waste Landfill Cell, and the 11e.(2) Facility.
EnergySolutions’ Federal Cell Facility will be located to the west of the 11e.(2) Facility and south of the Class
A West Facility.

The low precipitation and high evaporation rates at the site are not conducive to sustainable crop yields.
Further, because the groundwater is saline with high TDS, it is not conducive to support of a permanent,
residential population center in the site area.

2.1.2 Population Distribution

The site’s isolation from population centers is appropriate for siting disposal facilities. While 67,397 people
resided within 50 miles of the Clive site at the time of the 2020 Census, most of the immediate area is
uninhabited (Census, 2020). The closest resident lives roughly seven miles to the northeast of the site, and
acts as a caretaker for the rest stop just off I-80. As is illustrated in Table 2-1, the largest group of people lives
48 - 80.5 miles to the east and southeast of the site in the Tooele-Grantsville area.

Table 2-2 summarizes a study projecting that Tooele County will continue to increase its population at the
annual average rate of 3.74 percent until the year 2040 (most recent three-year average). It is projected that
Tooele and Grantsville Cities will continue to be the areas of greatest growth, with growth rates of 3.74 percent
through the year 2040 (Census, 2020).

The remoteness of the site from the urbanized area of Tooele County makes the surrounding area an
improbable location for any other significant industrial use. This was one of the chief reasons for its selection
as a disposal site for the Vitro project. The Tooele County Commission has designated the Clive site and
surrounding areas as hazardous industries zones. This designation prohibits all residential housing in the
vicinity of the Clive site. Also, NRC identified the absence of any culinary water sources at the Clive Facility
as a major deterrent to any potential population growth within a 12-kilometer radius (NRC, 1993c).

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Table 2-1

12-Kilometer Population Wheel

0 - 2 2 - 4 4 - 6 6 - 8 8 - 10 10 - 12
N - 0.0
NNE - 22.5
NE - 45.0
ENE - 67.5 1
E - 90.0
ESE - 112.5
SE - 135.0
SSE - 157.5
S - 180.0
SSW - 202.5
SW - 225.0
WSW - 247.5
W - 270.0
WNW - 292.5
NW - 315.0
NNW - 337.5
Total 0 0 0 0 0 1
Direction Distance (km)

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Table 2-2

Tooele County Growth Projection: 2020-2040

Year
County
Population*+
2040 140,464
2039 135,400
2038 130,519
2037 125,813
2036 121,278
2035 116,905
2034 112,691
2033 108,628
2032 104,712
2031 100,937
2030 97,298
2029 93,790
2028 90,409
2027 87,149
2026 84,007
2025 80,979
2024 78,059
2023 75,245
2022 72,533
2021 69,918
2020 67,397
* from the 2020 U.S. Census
+ Forward growth rate computed as average of that from three years available (2016 – 2018)

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2.2 METEOROLOGY AND CLIMATOLOGY

The site’s meteorology and climatology are appropriate for siting disposal facilities. EnergySolutions has
operated a weather station at Clive since April 1992. The station monitors wind speed and direction, 2-m and
9-m temperatures, precipitation, pan evaporation and solar radiation. Annual meteorological reports are
submitted to the Director for Clive data collected from July 1992 to December 2020, (MSI, 2021 attached as
Appendix B). Since the Federal Cell Facility is located entirely within Section 32, this information adequately
characterizes the site.

The site region is in the Intermountain Plateau climatic zone that extends between the Cascade-Sierra Nevada
Ranges and the Rocky Mountains and is classified as a middle-latitude dry climate or steppe. The climate is
characterized by hot dry summers, cool springs and falls, moderately cold winters, and a general year-round
lack of precipitation.

While neighboring mountain ranges generally restrict the movement of weather systems into the area, there
are occasional well-developed storms in the prevailing regional westerlies. The mountains act also as a barrier
to frequent invasions of cold continental air. Precipitation is generally light during the summer and early fall
and reaches a maximum in spring when storms from the Pacific Ocean are strong enough to move over the
mountains. During the late fall and winter months, high pressure systems tend to settle in the area for as long
as several weeks at a time.

In the 26-year period of time (July 1992 through December 2020) the most frequent (and predominant) winds
were from the south-southwest direction, with the second most frequent direction being the east-northeast,
followed by the south. Wind Rose data summarized in Figure 2-1 has been obtained from the on-site weather
station and checked for accuracy by a certified meteorologist (MSI, 2021). Temperatures at Clive range from
an hourly minimum of -31.5 oC to an hourly maximum of 41.3 oC.

The Clive site receives an average of 8.37 inches of precipitation per year. Measurements taken at the Clive
site showed that the lowest monthly precipitation recorded was 0 inches, during several distinct months. The
highest recorded monthly precipitation was 4.28 inches, in May 2011.

Pan evaporation measurements are taken from April through October when ambient temperatures remain
above freezing. Maximum hourly evaporation values usually occur in July. The 24-year average annual
evaporation at the Clive site is 53.4 inches (excluding 2 years of reported instrument malfunction).

Historically, a severe weather phenomenon in the west desert-region of Utah has taken one of four forms:
tornadoes, severe thunderstorms, damaging hail, or dust devils. Tornadoes are rare in the State of Utah
primarily due to the lack of atmospheric moisture and the presence of mountainous terrain. Utah tornadoes
tend to be much weaker and smaller than their central U.S. counterparts. Utah tornadoes stay on the ground
for an average of only a few minutes and their path widths are usually one-eighth of a mile or less. Five
tornadoes were observed in Tooele County for the period 1847–2017 (Lietz, 2017). Based on this historic
record, the probability of a tornado strike at any one point in Tooele County is extremely low. Although
tornadoes are very rare and not statistically likely to strike the Clive site, they are amongst weather phenomena
that can occur in the State of Utah.

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Figure 2-1. EnergySolutions Wind Rose January 1993 – December 2020 (MSI, 2021).
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While thunderstorms are fairly common over Utah, especially in the late summer months, these storms are
typically not severe. The Dugway, Utah station records an average of 20 thunderstorm-days per year. Historic
records suggest than approximately 10% of these thunderstorms develop into the severe category, equating to
two annual high-speed wind events (50 knots or greater) at the Clive site.

Large damaging hail is another rare phenomenon in the State of Utah, primarily due to the lack of atmospheric
moisture needed to develop strong thunderstorms and related hail. During the last 60 years there have been
four severe thunderstorm events in Tooele County with reported hail damage (Brough, et.al; 2010). Two of
these reports indicated hail with a diameter of one inch or greater. These reports also suggest a return interval
of 10–15 years for such storms with potential damaging hail for the EnergySolutions site.

Dust devils are quite common throughout the west desert of Utah. They are caused by local thermally induced
updrafts and do little more than stir up dust and other light objects. Wind speeds associated with dust devils
are normally less than 50 miles per hour and are short-lived. The highest recorded wind speed for a west
desert dust devil is 60 miles per hour.

2.3 GEOLOGY AND SEISMOLOGY

The site’s geology and seismology are appropriate for siting disposal facilities. The Federal Cell Facility will
be located on the eastern fringe of the Great Salt Lake Desert. Geophysical surveys performed in the
surrounding region included (1) a regional gravity survey conducted over a study area that included the eastern
half of the Great Salt Lake Desert - performed by the University of Utah Geophysics Department between
1957 and 1961 (Cook et. al, 1964); and (2) an earth resistivity survey (Bisdorf and Zohdy, 1980) conducted
in the Fish Springs area, about 50 miles south of the site to delineate faults and their influence on springs in
the area. Many basin and range faults, grabens and horsts are indicated in Cook’s report on the Great Salt
Lake Desert study area. The gravity data was used to determine regional geologic conditions (Cook et. al,
1964). In addition to these regional surveys, the Utah Department of Natural Resources has prepared two
hydrologic reports for the Great Salt Lake West Desert area (Stephens, 1974; UDNR, 1981). These reports
provide a description of physiographic conditions, regional characteristics, groundwater aquifers, flow
characteristics and water quality. The U.S. Geological Survey has also prepared geologic and surface water
resources maps for the same areas (Moore, 1979; Bucknam, 1977). These historic surveys and studies have
been combined with characterization of the site geology and hydrogeology, in the Revised Hydrogeologic
Report prepared by EnergySolutions (EnergySolutions, 2019).

The EnergySolutions Clive facility is located in the extreme eastern margin of the Great Salt Lake Desert,
which is part of the Basin and Range Province of North America. The Basin and Range topography is typified
by block-faulted (normal fault) mountain ranges that generally trend north to south. This predominant
geologic structural feature with alluvial filled basins is discontinuous and was created by extensional normal
faulting. The basins consist primarily of sediments originating from Quaternary lacustrine Lake Bonneville
deposits and Quaternary and Tertiary colluvial and alluvial materials eroded from adjacent mountains. The
unconsolidated to semi-consolidated valley fill is generally about 800 to 1,000 feet thick throughout the central
portions of the valleys in the Great Salt Lake Desert.

The block-faulted mountains mainly consist of Paleozoic limestones, dolomites, shales, quartzites, and
sandstones. Tertiary extrusive igneous rocks of basaltic lava flows and pyroclastics are also found in isolated
areas of the Great Salt Lake Desert. The valley sediments are composed of alluvial fans, evaporites and
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unconsolidated and semi-consolidated valley fill (Stephens, 1974). These sediments consist of intercalated
colluvium, alluvium, lacustrine, and fluvial deposits with some basalt flows, pyroclastics and deposits of
eolian material. Generally, the colluvial and coarse alluvial deposits are near the mountain ranges where they
contain a wide range of grain sizes, varying from boulders to clay. Extending to the center of the valleys, the
deposits grade into well sorted beds of sand and gravel interlayered with alluvial and lacustrine silt and clay.
Thick beds of alluvial fans generally fringe the mountains ranges. The alluvial fans grade laterally into fine-
grained alluvium and thin toward the center of the valleys where it is present as a veneer overlying and
adjacent to fine-grained Lake Bonneville lakebed deposits.

The ranges are affected by mass-wasting and fluvial erosion where ephemeral streams that enter the desert
basins deposit their load as they evaporate or infiltrate. The desert mountain perimeters of the basins are
therefore impacted by the deposition and erosional processes of alluvial fans. The central portions of the
basins, which typically demonstrate relatively flat topographic relief, are unaffected by surface fluvial
activities, and therefore mechanical and chemical weathering processes advance at very slow rates. These
geomorphic processes are typical of the proposed Federal Cell Facility’s semiarid to arid desert setting.

Natural resources in Tooele County include limestone, metallic minerals, potassium salts, tungsten, salt, clays,
and sand and gravel. Gravel quarries have been located in the alluvial fans that flank the Cedar Mountains
(DOE, 1984). Mineral extraction by evaporation of brine occurs near Knolls, about 10 miles northwest of the
site. Limestone is quarried in the Cedar Mountains about five miles east of the site. Presently no oil and gas
production takes place in the area. The classification of the area as prospectively valuable for oil and gas is
based solely on general criteria. Even so, there has been little interest in the western desert for oil and gas
exploration. Previous exploration near the west side of the Great Salt Lake revealed a low-grade product with
little or no yield. There is no coal production in the area or geologic formations with coal resources. No
active or pending mining claims or mineral leases are located on the site.

2.3.1 Geologic Site Characteristics

The site’s geologic characteristics are appropriate for siting disposal facilities. The proposed Federal Cell
Facility is located in the eastern margin of the Great Salt Lake Desert, part of the Basin and Range Province.
This province is characterized by north-south trending mountain ranges with discontinuous alluvium-filled
valleys found between the ranges. The mountains are composed of mainly Paleozoic-age sedimentary rocks,
but can also be composed of volcanic rocks. Metamorphic rocks do not outcrop in the vicinity of the facility,
with the closest occurring in the Granite Peak area, approximately 40 miles south of Clive. The
intermountain troughs are filled primarily with unconsolidated alluvial, lacustrine, fluvial, and evaporite
deposits; but pyroclastics, aeolian sediments, and basalt flows also occur (Bingham Environmental, 1992 –
[see Appendix C] and Stephens, 1974). Sediments near the mountains are predominately colluvial and
alluvial, and are generally coarser grained than the lacustrine deposits found in the center of the valleys.
The proposed Federal Cell Facility is situated on Quaternary-age lacustrine lakebed deposits associated with
the former Lake Bonneville. These surficial lacustrine deposits are generally comprised of low-permeability
silty clay. Surficial sand and gravel outcrops are mapped in the sections adjacent to the facility.

Beneath the proposed Federal Cell Facility, the sediments consist predominantly of interbedded silt, sand,
and clay with occasional gravel lenses. The depth of the valley fill beneath the facility is unknown; a 2019
exploratory investigation confirmed their presence at the Clive Facility down to 620 feet below ground
surface (bgs); with estimates ranging from 250 to 3,000 feet bgs (the Phase 1 Basal-Depth Aquifer Study
Report and responses to related interrogatories received from the Section Manager (Willoughby, 2021) are
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included as Appendix D). The deepest borehole within Section 32 (well I-1-700) was drilled to a depth of
620 feet bgs without encountering bedrock. An exploratory borehole for a potential water-supply well on
Section 29 north of the EnergySolutions facility did not encounter bedrock at a depth of 700 feet bgs. Up
to 3,000 feet of basin fill sediment are present in the Ripple Valley (the basin immediately north of
Interstate-80, east of the Grayback Hills).

The Grayback Hills are located approximately four miles north of the proposed Federal Cell Facility and are
outcrops of extrusive igneous and sedimentary rocks. Igneous extrusive rocks (trachyandesite lava flows)
form a resistant cap on the Grayback Hills, and volcaniclastic rocks are mapped in the area. The lava flows
and volcaniclastics have been dated as latest Eocene to earliest Oligocene (38-35 million years before
present). Exposed sedimentary rocks in the Grayback Hills are Permian and Triassic Grandeur, Murdock
Mountain, Gerster, Dinwoody, and Thaynes Formations consisting of predominantly carbonate units. Lake
Bonneville cycle lakes have inundated and modified the outcropping rocks of the Grayback Hills.
Lacustrine deposits are present, including sands and gravels associated with bars, splits, and beaches.
Petrographic examination of gravel from the Grayback Hills determined the gravel is composed almost
entirely of acidic to intermediate volcanic rock. Rock types were identified as trachyandesite,
dacite/andesite with a coriaceous texture, pyroclastic, rhyolite, and a small volume of limestone. Many of
the gravel particles are partially or completely coated in caliche (see EnergySolutions, 2019 in Appendix
E).

2.3.2 Seismology

The seismic activity at the site is appropriate for siting disposal facilities. The Clive site does not have any
known active faults in its vicinity. NRC (1993c) indicates that the nearest fault is located 29 km (18 miles) to
the north, having occurred between 1 million to 25 million years ago. Although the site is not located near
any active faults, isostatic rebound is suspected to be the cause of any recent seismic activity in the Lake
Bonneville area.

NRC (1993c) cites two seismic investigations that were conducted for the Vitro tailings disposal facility and
a proposed site for a supercollider that was to encompass a 15-mile elliptical ring around the Clive site. Based
on these studies, NRC (1993c) indicated that nearby structures and seismogenic areas that could pose a hazard
include the fault zones within a 45-mile radius of the site. These include the eastern flank of the Cedar
Mountains, western flank of the Lakeside Mountains, Northwest Puddle Valley, eastern flank of the
Newfoundland mountains, and the western flank of the Stansbury Mountains. However, NRC (1993c)
concluded that no active fault zones lie beneath the Clive site, and there is no macroseismic evidence of a
capable fault in the vicinity of the site.

The lack of Quaternary and/or capable faults in the vicinity of the Clive site is not sufficient evidence to
dismiss seismic activity as a potential issue of concern. While the absence of surface faults in the site is
consistent with a low probability of surface-fault rupture, ground shaking associated with background
earthquakes require assessments (i.e. moderate-size earthquakes (M5.5 – 6.5) that do not cause surface
rupture, (Wong, 2013).

Seismic hazard assessments have been evaluated previously for the Clive site including assessments of active
or potentially active faults in the region and background earthquakes. The peak ground accelerations for both
seismic sources is 0.24 g. The peak ground accelerations for the Clive site are within the range of estimated
ground accelerations for two DOE regulated and approved low-level waste disposal sites (Area G, Los
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Alamos, New Mexico (LANL, 2008). Performance assessments for these sites conclude that the impacts of
ground shaking on waste disposal systems are minor and are overshadowed by the longer-term effects of
subsidence.

The negligible effects of the peak ground accelerations on the long-term stability of Clive’s embankments has
previously been demonstrated and found acceptable by the Division. No new information on seismic hazards
has been identified that would change or require revisions of the previous work.

The seismic hazard for the faults near the proposed Federal Cell Facility (as illustrated in Figure 2-2) was
evaluated using methodology consistent with the requirements of UAC R313-25-8(5) (AMEC, 2012). The
seismic hazard assessment included analysis of the peak ground acceleration (PGA) associated with the
Maximum Credible Earthquake (MCE) for known active or potentially active faults in the proposed Federal
Cell Facility region. The PGA was obtained from a probabilistic seismic hazard analysis (PSHA) to assess
the seismic hazard for earthquakes that may occur on unknown faults in the area surrounding the proposed
Federal Cell Facility (i.e., background seismicity). For fault sources, the PGA was based on the maximum
rupture length and rupture area for each fault. The return period for ground motions resulting from a
background earthquake was estimated at 5,000 years (i.e., equal to a one percent probability of exceedance in
50 years).

The approach of selecting an MCE PGA from the larger of the values associated with the deterministic MCE
for faults or the PSHA result for background earthquakes at a 5,000 year return period is consistent with
recommendations of the Utah Seismic Safety Commission (2003) and requirements promulgated by the Utah
Division of Water Rights (Dam Safety Section) for assessment of dams (AMEC, 2012).

The maximum PGA value that was calculated for the maximum events on neighboring fault sources was
projected as 0.28 g, (which is the largest PGA from the deterministic assessment of fault-specific sources and
the probabilistic assessment of the background earthquake). The maximum magnitude of the MCE varies
from 7.0 to 7.3 for the sources that result in the maximum PGA. The largest value of 7.3 is considered
conservatively appropriate for use in the seismic stability analyses for the proposed Federal Cell Facility.

The liquefaction/cyclic softening potential of the subsurface soil profiles below the proposed Federal Cell
Facility have also been evaluated (AMEC, 2012). The potential for liquefaction of sand-like soil has been
determined to be low and the potential for seismic settlement to be on the order of one to two inches. The
potential for cyclic softening was also found to be low.

Historical Earthquake catalogs for the site region were obtained from the seismological observatories at the
University of Utah and the University of Nevada. The Utah catalog begins in 1850, whereas the Nevada
catalog begins in 1852. The two catalogs combined contain 1277 epicenters within 100 km of the proposed
Federal Cell Facility. The earliest earthquake occurred in 1915 and the latest in September 2005. The smallest
was M 0.0 and the largest M 5.2. The closest was 9.9 km from the site and the farthest was 99.9 km. Selected
Data for 26 Earthquakes are presented in Table 2-3 which is sorted by increasing distance from the site. These
26 earthquakes are located within 100km of the site, but a magnitude and distance filter was applied to the
catalogs to produce the data shown in Table 2-3 because most of the epicenters represent small earthquakes
more than 50 km form the site.
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Figure 2-2. EnergySolutions Fault and Seismicity Map (AMEC, 2012)
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Most of the faults in the site region that cut deposits of Quarternary age were identified a number of years
ago. Most of them had not been studied in detail by the time the USGS was conducting their 1996 seismic
hazard mapping project, and the USGS omitted them as line sources because key parameters (maximum
magnitude and recurrence or slip rate) were not available. Subsequently, a systematic inventory of
Quaternary faults was completed in the Western United States, and more complete information was
available for the 2002 USGS update. In addition, faults in the Skull Valley were discovered and
characterized. Ten Quaternary faults are included in the USGS database within about 70km of the proposed
Federal Cell Facility. The closest Quarternary fault to the site is the Cedar Mountains fault at a distance of
23km to the east.

2.4 HYDROLOGY

Other than characterization of the site’s basal-depth groundwater (which is still under review), the site’s
unconfined aquifer-region groundwater characterization are appropriate for siting disposal facilities. The
proposed Federal Cell Facility is located in the semi-arid desert of western Utah. The area containing the site
lies within the Great Basin drainage, a closed basin having no outlet. The proposed Federal Cell Facility
drains into the normally dry Ripple Valley depression on the eastern fringe of the Great Salt Lake Desert. The
nearest usable body of water east of the Clive site is 28.1 miles away. At this location, a perennial stream
flows from Big Spring (1,000 feet south of I-80) to the Timpie Springs Waterfowl Management Area, about
2,000 feet north of I-80. Stream flows from higher elevations evaporate and infiltrate into the ground before
reaching lower, flatter land. The watershed up-gradient of the site covers approximately 46 square miles.
There are no perennial surface-water systems associated with the proposed Federal Cell Facility. Activities at
the proposed Federal Cell Facility will have no effect on surface-water quantities or quality at the Clive
Disposal Complex. Water necessary for construction is provided by existing wells in the vicinity, or
impounded water.

2.4.1 Surface Water Hydrology

The site’s surface water hydrology is appropriate for siting disposal facilities. The proposed Federal Cell
Facility is located in the eastern margin of the Great Salt Lake Desert, part of the Basin and Range Province.
This province is characterized by north-south trending mountain ranges with discontinuous alluvium-filled
valleys found between the ranges. The mountains are composed of mainly Paleozoic-age sedimentary rocks,
but can also be composed of volcanic rocks. Metamorphic rocks do not outcrop in the vicinity of the facility,
with the closest occurring in the Granite Peak area, approximately 40 miles south of Clive. The
intermountain troughs are filled primarily with unconsolidated alluvial, lacustrine, fluvial, and evaporite
deposits; but pyroclastics, aeolian sediments, and basalt flows also occur (Bingham Environmental, 1996
and Stephens, 1974). Sediments near the mountains are predominately colluvial and alluvial, and are
generally coarser grained than the lacustrine deposits found in the center of the valleys.

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Table 2-3

Selected data from 26 earthquakes within 100 km of the Clive site. Data from Catalogs
Maintained by the University of Utah and the University of Nevada-Reno.

Month/Day/Year North Latitude West Longitude Earthquake
Magnitude
Site Distance
(km)
April 03, 1998
October 23, 1976
March 29, 1979
November 15, 1979
June 10, 1975
40.7568
40.6723
40.4807
40.8668
40.5408
-113.1897
-112.8315
-113.2092
-112.9173
-112.8650
2.0
1.30
2.20
2.00
1.20
9.87
23.81
24.69
25.58
26.71
July 11, 1981
April 26, 2004
December 06, 1996
January 04, 1975
August 05, 1988
40.4573
40.4685
40.4627
40.6602
40.9568
-113.1952
-113.2412
-113.2773
-112.7690
-113.0798
1.70
1.07
2.32
1.20
1.90
26.82
26.95
28.89
29.20
29.71
August 11, 1915
October 23, 1987
September 25, 1987
October 26, 1987
September 25, 1987
40.5000
41.1963
41.1957
41.2008
41.2068
-112.6500
-113.1693
-113.2137
-113.1777
-113.1357
4.30
4.20
4.30
4.70
4.10
44.46
56.39
56.77
56.95
57.38
September 26, 1987
September 25, 1987
September 28, 1987
February 16, 1967
September 05, 1962
41.2090
41.2135
41.2267
41.2733
40.7153
-113.1500
-113.1318
-113.1808
-113.3338
-112.0888
4.00
4.80
4.00
4.00
5.20
57.68
58.12
59.84
67.37
86.52
February 22, 1943
April 10, 1992
March 16, 1992
November 04, 1992
September 08, 1983
40.7000
40.7000
40.4702
41.5098
40.7480
-112.0800
-112.0800
-112.0448
-113.3878
-111.9927
5.00
4.30
4.20
4.80
4.30
87.23
87.23
93.60
93.91
94.78
October 05, 1915

40.1000 -114.0000 4.30 99.91

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The lack of surface water bodies, the sparse precipitation and the high evaporation rate make it unlikely that
any condition creating a permanent body of standing water will occur. Standing water at the Clive Site is
managed during the operational life of the facility according to Condition I.E.7 of GWQDP
UGW450005,“Run-on and Run-off Control Requirements” and “Waste Water, Runoff, and Storm Water
Management Requirements.” Standing water in depressions outside waste management areas is not actively
managed. UAC R313-25-23(5) states: “The disposal site shall be generally well drained and free of areas of
flooding or frequent ponding.” Federal Cell Facility areas will be similarly managed to remove standing
water, when necessary. EnergySolutions uses a mobile pumping truck to access and remove water from
disposal site areas which are not designed to free-drain into an evaporation pond or equipped with permanent
pumps. Other areas of the property are channeled to the southwest. The site has also been designed to drain
any water that may accumulate during flooding.

There is no data indicating that historical floods have impacted the Clive site. Analyses prepared in support
of Radioactive Material License UT2300249 modeled the Probable Maximum Precipitation (PMP) and
Probable Maximum Flood (PMF) for the Clive Disposal Complex. The largest “instantaneous” value of
runoff from the watershed was 29,800 cubic feet per second (cfs) and was associated with the six-hour PMP.
Modeling shows a PMP of 10.10 inches for the six-hour storm and 6.1 in. for a 1-hour storm. The Probable
Maximum Flood expected at the site from a six-hour Probable Maximum Precipitation event is 13,100 cfs, as
compared to an estimated 100-year flood of 1,300 cfs. Additionally, EnergySolutions Federal Cell Facility
disposal operations will not take place in a 100-year flood plain (UGS, 1999).

The Probable Maximum Flood would most likely flow into the south and east borders of the site with the
fringes of the flow encroaching on EnergySolutions' Clive Disposal Complex. The maximum depth of flow
at the site was calculated to be between 2 and 4 feet and last for 6 hours. Thus, the Probable Maximum Flood
would not infiltrate into groundwater beneath the proposed Federal Cell Facility. These events demonstrate
that for post-closure, a short-term flood of any depth is likely to have no impact on the Federal Cell Facility’s
performance. Additionally, short-term flooding of any depth on the order of days or even weeks can
intuitively be seen to have minimal impact on long-term performance.

Runoff from such a hypothetical event as the Probable Maximum Flood will be diverted from encroaching
into the Federal Cell Facility by using a berm surrounding the disposal area. Flow would be diverted around
the site to the south and away from the Federal Cell Facility. With prior licensing actions, the Director
concluded that

“Based on the information summarized above, the Licensee has discussed how the facility’s surface
features have been designed to direct surface water away from the disposal units at velocities and
gradients which would not be expected to result in erosion that would require ongoing active
maintenance in the future.” (UDRC, 2012).

These same design features will continue to direct surface water away from the proposed Federal Cell in a
manner that does not result in erosion.”

2.4.2 Groundwater Characterization

Other than characterization of the site’s basal-depth groundwater (which is still under review), the site’s
unconfined aquifer-region groundwater characterization are appropriate for siting disposal facilities.
Numerous geologic and hydrogeologic studies have been performed within and adjacent to Section 32. DOE
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performed the first detailed hydrogeologic investigations within Section 32 in the 1980s. Since
EnergySolutions’ operations began in 1988, additional studies were performed at the site in order to
characterize the hydrogeology. In January 2019, EnergySolutions prepared a Revised Hydrogeologic Report
that summarizes the hydrogeology of the site based upon historical data (EnergySolutions, 2019 – see
Appendix E).

Alluvial and lacustrine sediments that fill the valley floor are estimated to extend to depths of greater than 620
feet with unconsolidated sediments ranging from 300 to over 600 feet (as demonstrated in boring
investigations completed by EnergySolutions in 2019). North-south trending mountains and outcrops define
the hydrogeologic boundaries for the aquifer system. Lone Mountain located two miles east of the site, rises
approximately 950 feet above the valley floor. The Grayback Hills located to the north with outcropping
features to the west rise 500 feet and 230 feet respectively above the valley floor.

The site aquifer system consists of a shallow unconfined aquifer that extends through the upper 40 feet of
lacustrine deposits. A confined aquifer begins around 40 to 45 feet below the ground surface and continues
through the valley fill. Due to the low precipitation and relatively high evapotranspiration, little or no
precipitation reaches the upper unconfined aquifer as direct vertical infiltration. Groundwater recharge is
primarily due to infiltration at bedrock and alluvial fan deposits which then travels laterally and vertically
through the unconfined and confined aquifers. Groundwater flow in this area is generally directed
northeasterly to northwesterly.

Fresh water from the recharge zones along the mountain slopes develops progressively poorer chemical
quality in response to dissolution of evaporite-minerals during its travel through the regional-scale flow
systems and through concentration by evaporation at the points of discharge. The groundwater quality in the
unconfined aquifer at the Clive Facility is considered saline with concentrations of several chemical species
(sulfate, chloride, total dissolved solids, iron, and manganese) significantly exceeding EPA’s secondary
drinking water standards.

The groundwater flow regime beneath the Federal Cell Facility has been evaluated extensively and defined
based on (1) information collected from water level measurements, (2) the aquifer hydraulic properties which
were calculated from slug out tests and laboratory testing, (3) isotope dating of groundwater, and (4) hydraulic
testing performed for wells in the shallow and deep aquifers. Water levels obtained from monitoring wells
between 1991 and present day were used to develop contour maps and flow nets to define the direction of
groundwater flow and hydraulic gradients within the aquifers. These data are combined with measured
hydraulic conductivities to develop estimates of groundwater velocities.

Horizontal ground water gradients in the shallow aquifer below the proposed Federal Cell Facility range from
1.9 x 10-5 to 5.4 x 10-3 ft/ft. The site-wide average gradient is 8.9 x 10-4 ft/ft. Using these gradients, average
horizontal velocities ranging from 0.004 ft/day to 0.009 ft/day are calculated (EnergySolutions, 2019). A
hydraulic conductivity of 2.98 x 10-4 cm/sec has been observed for Unit 2; with minimum and maximum
values of 2.3 x 10-6 cm/sec and 4.3 x 10-3 cm/sec, respectively. The Unit 3 sandy materials exhibit a saturated
hydraulic conductivity of 3.2 x 10-4 cm/sec. The vertical hydraulic conductivity of Unit 1 was measured in
the laboratory using soil core samples obtained from 43 to 60 feet below ground surface in Unit 1 ranged from
2.2 x 10-8 to 1.6 x 10-6 cm/sec, with an arithmetic mean of 2.9 x 10-7 cm/sec.

Data characterizing the shallow, unconfined groundwater surface are provided to the Director in the Annual
Groundwater Quality Reports. The groundwater level data indicates that the water level fluctuations at any
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given well are generally less than one foot (with the exception of areas with localized mounding). The
groundwater surface is relatively flat in Section 32, with elevations varying about two feet per mile.

The aquifer system investigated in the area of the EnergySolutions Clive Facility consists of unconsolidated
basin-fill and alluvial-fan aquifers which extend to depths on the order of 620 feet below Section 32. The
lacustrine deposits, which comprise the majority of the aquifer system below the Clive Facility, are somewhat
variable in depth and thickness, which makes the exact delineation of aquifers and aquitards difficult.
Characterization of the aquifer system as a whole is based on subsurface stratigraphy and potentiometric data.

A shallow, unconfined aquifer has been identified in the upper 40 feet of lacustrine deposits, with groundwater
surfaces ranging from 19 to 31 feet below the ground surface (with a historic minimum depth of approximately
24 feet). The unsaturated zone consists of an upper 8- to 15-foot-thick silty clay and clayey silt (Unit 4) that
overlies a 10 to 20 foot thick silty sand layer (Unit 3). Groundwater occurs within the lower part of Unit 3
below the approximate western half of Section 32 and the primary movement of groundwater is assumed to
be in the silty sand lenses and layer of the shallow, unconfined aquifer here. Below this silty sand layer, a
silty clay deposit (Unit 2) is present at variable depths and thickness. It appears that this silty clay layer is
continuous based on exploratory boreholes and monitoring well installations. The top of Unit 2 generally
slopes down from east to west across Section 32. In the eastern half of Section 32, groundwater in the shallow
unconfined aquifer occurs in Unit 2, and Unit 3 is above the water table. Unit 1, which consists of a relatively
thick silty sand layer, is present below the silty clay (Unit 2) at depths ranging from 40 to 45 feet below the
ground surface. Wells and piezometers, which penetrate into Unit 1, typically exhibit higher freshwater
equivalent heads than wells screened shallower in Units 2 and/or 3.

Because the shallow aquifer contains saline water with TDS concentrations ranging from approximately
30,000 mg/L in monitoring wells GW-26 and GW-63 to 100,000 mg/L in monitoring well GW-19A, it is
classified as Class IV groundwater based on the criteria of TDS greater than 10,000 mg/l of the Utah Ground
Water Quality Protection Regulations. Additionally, the saline water typically exhibits a specific gravity
averaging 1.033.

The majority of the recharge to the shallow aquifer appears to occur as vertical leakage from the deeper
confined aquifer. In addition, a small amount of vertical infiltration from the surface and some lateral
movement of water from the recharge zone to the east occurs. Movement in the shallow aquifer is primarily
laterally to the north, northeast and/or northwest.

The confined aquifer consists primarily of lacustrine deposits in Unit 1, which occurs below a depth of 40 to
45 feet. This deeper aquifer primarily consists of silty sand deposits with occasional silty clay layers and is
overlain by one or more silty clay layers. Wells completed with screened intervals located at least 70 to 100
feet below the ground surface have static fresh water equivalent levels ranging from 3 to 18 inches above
wells screened in the shallow, unconfined aquifer. Similarly, a well completed with screened interval located
between 320 and 350 feet below the ground surface have static fresh water equivalent levels ranging up to 20
inches above wells screened in the shallow, unconfined aquifer. In the vicinity of the GW-19A/B well nest,
increased water levels in the shallow aquifer have caused a downward switch in gradients at the southwest
corner of the site. It has been observed that as the mound decreases, and the site conditions return to normal,
the vertical gradient in GW-19A/B has decreased. It is anticipated that the gradient in this area will eventually
return to regional conditions.

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This deeper, confined aquifer also contains saline water with TDS concentrations well above 20,000 mg/l,
also classifying it as Class IV groundwater. However, it is generally better quality than the shallow
groundwater. The deeper saline groundwater typically exhibits a specific gravity on the order of 1.019.
Recharge to the deeper confined aquifer probably occurs south and east of the facility in the coarser alluvial
deposits adjacent to Lone Mountain.

Water level measurements from deeper monitor wells screened in Unit 1 between 70 and 350 feet below the
ground surface have also been obtained and analyzed. When comparing water levels within deep and shallow
monitor well clusters, the deep wells exhibit higher piezometric levels than the shallow wells, indicating an
upward vertical gradient of approximately one foot based on fresh water equivalent heads. While this is offset
somewhat by the downward density gradient of 0.2 feet, overall groundwater flow is from the confined to the
unconfined aquifer. Based on the historic minimum depth to groundwater, groundwater levels would need to
rise some 20 feet below the Federal Cell Facility to begin to threaten contact with disposed waste. The historic
minimum depth to shallow groundwater for this area is roughly 24 feet below original contour. The Federal
Cell Facility will be constructed by excavating approximately eight feet below the ground surface, then
constructing a two-foot-thick liner of compacted low-permeability clay. Therefore, the groundwater would
need to rise 18 feet and pass through the liner to threaten disposed waste.

2.5 GEOTECHNICAL CHARACTERISTICS

The site’s geotechnical characteristics are appropriate for siting disposal facilities (Geotechnical Analysis
included in Appendix E). Analyses have been conducted to measure the geotechnical characteristics and
features of the proposed Federal Cell Facility in accordance with the requirements of UAC R313-25-7(1) and
UAC R313-25-23. Information evaluated demonstrates that the geotechnical and geophysical field
investigations and laboratory and field testing are adequate; interpretations of the data to develop typical soil
and rock laying, typical cross-sections, and design parameters for use in design are reasonable and
conservative; and geotechnical characterization of the Clive site meets the applicable guidance and acceptance
criteria

A significant amount of field and laboratory information has been developed for the site and surrounding area,
as a result of studies and investigations conducted in and adjacent to Section 32. Available geotechnical data
adequately characterizes the subsurface soil conditions below the site. DOE collected initial geotechnical and
hydrogeologic information to locate and dispose of the Vitro uranium waste in the north central part of Section
32. Dames & Moore, Jacobs Engineering Group and CSU collected information for DOE between 1982 and
1984 (DOE, 1985b). Additionally, Delta Geotechnical collected geotechnical and hydrogeologic information
for EnergySolutions between 1988 and 1990 as part of the permitting process for the Mixed Waste landfill
cell. EnergySolutions has further updated and revised the data collected in the Revised Hydrogeologic Report
(Appendix E) and a Basal-Depth Aquifer Study Plan (Appendix D).

Lacustrine deposits typically comprise the soils encountered at the site. These soils consist of silty clays and
clayey silts, and oolitic silty sands and sands. Calcium carbonates in the form of aragonite and calcite
contribute as much as 60 percent of the total mineralogy of the clayey materials. The remaining mineralogy
consists of smectite, quartz, dolomite, K-feldspar, plagioclase, kaolin, illite and a trace of gypsum. Calcareous
n nature the oolitic silty sands and sands, ranging in size from approximately 0.08 mm to 4.0 mm, will fizz
when put in contact with dilute HCl.

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Four hydrostratigraphic units have been delineated for the Clive site soils (extending from the surface, through
the unsaturated zone, and into the shallow aquifer). This upper most layer consists of an upper silty
clay/clayey silt (labeled Unit 4). Below the Unit 4 materials is an upper silty sand layer (Unit 3). Beneath the
Unit 3 materials is a middle silty clay layer (Unit 2). Finally, below the Unit 2 material is a lower sand/silty
sand layer (Unit 1).

The clayey soils, typically encountered from the surface down to a depth of 10 feet and between depths of 30
to 45 feet, typically are medium stiff, to stiff and moderately compressible. The majority of these clayey soils
exhibit low to moderate plasticity and moisture contents ranging from 20 to 40 percent by weight.

The silty sand and sand layers, typically encountered between a depth of 10 and 30 feet and below a depth of
45 feet, are medium dense and low to moderately compressible. Moisture contents of the silty sands above
the water table typically range from 5 to 15 percent by weight. Field investigations did not observe any adverse
conditions due to site characteristics that would affect the long-term performance of any of the Clive facilities
(AMEC, 2011). This assessment is also applicable to the Federal Cell Facility.

Basal-depth geotechnical analysis found carbonate mud; insoluble residue clayey material; sand-size grains
of quartz, muscovite; manganese dioxide; and weathered volcanic rock from 356 to 359 feed bgs. (Oviatt,
2020). Similarly, carbonate mud; insoluble residue clayey material; brown clay in vein-like bodies that range
in width from much-less-than 1 mm, to several mm; larger clay bodies, 1-2 cm in diameter; crystalline material
secondary or un-weathered phenocrysts; manganese dioxide; weathered volcanic rock; clays; and Mn-
dioxides at depths from 360 feet to 382 feet bgs. Breccia consisting of conglomerate, rounded to sub-angular
pebbles; calcareous cement; carbonate coated pebbles; clasts of coarse sand grains, well rounded; tiny quartz
crystals line some vugs; composition of clasts: sandstone, chert, limestone, soft carbonate mud, soft,
weathered volcanic rock; sand-sized dark mineral, feldspar, quartz, chert; most clasts sub-rounded to well
rounded; some clasts angular; well sorted, overall (no fines); and gravel cemented by calcium carbonate and
silica from 607 to 617 feet bgs (Oviatt, 2020).

EnergySolutions, (2019) describes the geologic information, shallow hydrogeologic cross-sections, shallow
groundwater elevation contour maps, and structure and isopach maps and evaluates current conditions at the
facility. EnergySolutions, (2019) also contains a complete and thorough evaluation of all groundwater and
vadose zone water quality available. It features graphs of temporal concentration trends for all compliance
monitoring parameters in each compliance monitoring well. It contains the number of water quality data
available for all compliance monitoring parameters in each compliance monitoring well. There has been
significant water quality data collected for the groundwater below Section 32. Since groundwater conditions
were characterized for all of Section 32, this information is applicable to the Federal Cell Facility.

EnergySolutions Clive Disposal Complex is an operational site that has access to adequate amounts of borrow
material for proposed operations in adjacent Sections (Sections 29 and 5) owned by EnergySolutions. The
rock and borrow material is abundant in the Grayback Mountains and EnergySolutions has a contract for
removal of sand and gravel from this site. EnergySolutions will continue to work with BLM and other
commercial vendors to ensure sufficient amounts of material are available to complete operations. The rock
must meet the construction quality assurance/quality control specifications prior to use.

EnergySolutions uses native clay materials from adjacent land owned by EnergySolutions for liner and radon
barrier construction. In other liner and cover construction activities, EnergySolutions has demonstrated that
the clays can be placed with a hydraulic conductivity as low as 1 x 10-6 cm/sec without any additives being
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used. Similarly, a hydraulic conductivity as low as 5 x 10-8 cm/sec can be achieved with the use of a
deflocculant.

The calculations prepared in support of Radioactive Material License UT2300249 conservatively estimated
nearly 3.2 million cubic yards of available clays from borrow areas located within EnergySolutions’ property.
Similarly, at least 1.6 million cubic yards of mineral materials is available in the Grayback Hills source (BLM,
2012a).

As is summarized in Table 2-4, the four stratigraphic units beneath the site are comprised of alternating clayey
and sandy layers. All the units are Lake Bonneville lacustrine deposits and are part of the Lake Bonneville
Formation. Unit 4 is the upper silty clay layer and is unsaturated across the site. The Unit 3 silty sand layer
and Unit 2 silty clay layer comprise the upper aquifer. A confined aquifer extends from the top of the silty
sand, Unit 1, down several hundred feet to bedrock.

Hydrogeologic cross-sections that illustrate the distribution of these units beneath Section 32 are shown in
(EnergySolutions, 2019). The cross-sections are based on stratigraphic information from well, borehole,
piezometer, and lysimeter soil classification logs. Cross sections are included in EnergySolutions (2019).

2.6 GEOCHEMICAL CHARACTERISTICS

The site’s geochemical characteristics are appropriate for siting disposal facilities. A significant amount of
water quality data and geochemical information has been assembled for the subsurface soil and groundwater
below Section 32 (EnergySolutions, 2019). Since groundwater quality is well characterized for all of Section
32, this information is applicable to the facility (see Appendix F for EnergySolutions’ 2020 Annual
Groundwater Monitoring Report).

Federal Cell Facility design minimizes the potential for transport of contaminants away from the waste. The
cover reduces the potential for infiltration, which is already believed to be minimal in the area due to the low
incident precipitation and high potential evapotranspiration. Additionally, seepage is not expected to reach
the groundwater as a result of moisture redistribution within the disposal materials. The impact of this seepage
on the groundwater is expected to be minimal for several reasons:
1. Waste must not exhibit free liquids at the time of disposal;
2. The volume of seepage is small, generally occurring over a long period of time;
3. There are no receptors for groundwater contamination, due to the existing poor quality of the
groundwater;
4. The hydraulic head gradient in the groundwater is small, limiting the velocity of groundwater
movement away from the site to a maximum of 1.1 feet per year; and
5. Analyses project that it would take approximately 400 to 600 years for leachate to move through the
unsaturated zone and then another 800 years to travel to the nearest off-site groundwater well
(EnergySolutions, 2019).

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Table 2-4

Geotechnical Properties of Clive Site Surface Soils

Approx.
Range of Particle Sizes (%)

Atterberg
Limits

Unit
Name

USCS

Thickness
(feet)

Sand

Silt

Clay

LL

PL
Bulk Density
(g/cc)
Unit 4 CL 8 - 15' 2 - 11 42 -56 38 - 56 35 22 1.37-1.66
Unit 3 SM 10 - 16' 46 - 89 8 - 39 8 - 16 NA NA 1.55-1.67
Unit 2 CL 12 - 20' 0 - 32 27 - 52 40 - 48 36 20 1.32
Unit 1 SM 100 + 40-60 20-30 10-20 NA NA NA
NA: Not Analyzed
Source: (DOE, 1984)

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Available groundwater quality data indicates that the shallow, unconfined aquifer exhibits variable quality
within Section 32. Seasonal variations in water quality appear to be relatively small. However, spatial
variations appear to be significant. One indicator parameter, TDS, had concentrations ranging from
approximately 30,000 mg/L to 100,000 mg/l. Deeper screened wells below 70 feet exhibit lower TDS values
than the shallow screened wells. There are significant water quality variations in the shallow, unconfined
aquifer possibly due to the variations in subsurface soils that leach salts to the groundwater and the small
gradients and corresponding velocities in the shallow groundwater system, which limit the mixing of the
groundwater. Variations may also be related to groundwater mounding, which may dilute concentrations or
may increase some concentrations.

The water quality data collected for Section 32 includes results of laboratory analyses for organic, inorganic
and radionuclide constituents and is reported in annual monitoring reports to the Director. The inorganic
parameters analyzed indicate that many naturally present concentrations are above the Criterion 5C limits for
groundwater. Sulfate, chloride, and TDS concentrations in all wells also exceeded the EPA secondary
drinking water standards. Analytical results for the radionuclide parameters also indicate that gross alpha,
gross beta, sum of radiums, and total uranium have exceeded Utah’s Division of Drinking Water standards in
two or more of the wells. Because of this, it is concluded there would be a minimal potential for degradation
of water quality in the vicinity of the Clive site. The groundwater at the site is characterized as “a brine.”
The water is suitable for limited industrial uses, without prior extensive treatment. The nearest current use of
groundwater is located over three miles from the site and up-gradient.

EnergySolutions has performed geochemical compatibility testing of the brown and white Unit 4 clay
materials being utilized for the clay bottom liner of the Federal Cell Facility (Bingham, 1994). In addition to
the geochemical compatibility testing, EnergySolutions has also performed numerous permeability tests of
both the clay liner and radon barrier materials to evaluate the hydraulic conductivity and stability of the clay.
Physical and chemical analyses, designed to approximate 80 years of leachate contact with the Federal Cell
Facility liner material, show minimal loss of liner integrity for approximately 80 years, (demonstrating more
than adequate performance for the time period during which the Federal Cell Facility is open for operations).
This testing indicated that leachate will not reduce the hydraulic conductivity performance of the clay liner
below design specifications. At the conclusion of the testing, the samples stabilized at hydraulic conductivity
ranging from 5.0 x 10-8 to 1.0 x 10-7 cm/sec, comparable to their initial pre-test conductivities (Bingham,
1994). Once final cover is placed, infiltration will be minimized, and leachate will not build up on top of the
Federal Cell Facility liner.

Laboratory permeability tests of Clive’s clay indicated that no significant volume of soil was leached out
(even though approximately half is characterized as water soluble). Cation exchange capacity for the Unit 4
clay was determined to be 13.4 MEQ/100 g. In previous evaluations of distribution coefficient (kd) values
(calculated from available koc values), the organic percentage for Unit 3 was assumed to be 2 percent. This
percentage is the recommended value for “clean” soils without significant organic content.

2.7 NATURAL RESOURCES

The site’s natural resources are appropriate for siting disposal facilities. Continued exploitation of such
resources will not negatively impact the Federal Cell Facility’s ability to meet the performance objectives of
UAC R313-25-19 through -22.

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2.7.1 Geological Resources

The site’s geological resources are appropriate for siting disposal facilities. Natural resources in Tooele
County include limestone, metallic minerals, potassium, salts, tungsten, salt, clays, sand and gravel. Gravel
quarries are located in the alluvial fans that flank the Cedar Mountains (DOE, 1984). Limestone is quarried
in the Cedar Mountains about five miles east of the site. Presently, no oil or gas production takes place in
the area. Although the area has been classified as possibly valuable for oil and gas, the classification is
based on very general criteria. Additionally, little interest has been historically shown in the western desert
for oil and gas exploration. Previous exploration near the west side of the Great Salt Lake revealed a low-
grade product with little or no yield. There is neither coal production in the area nor geologic formations
with coal resources. No active or pending mining claims or mineral leases are located on the site.

2.7.2 Water Resources

The site’s water resources are appropriate for siting disposal facilities. In general, the use of groundwater and
surface water in the Great Salt Lake Desert is concentrated along mountain fronts where the majority of fresh
groundwater and spring discharge occurs. This water is obtained from wells located up-gradient of the
shallow aquifer below the site. Without extensive treatment, uses of the groundwater in the Clive area are
confined to limited industrial uses.

Other than the monitoring wells installed for the Vitro project, and wells used for construction and makeup
water during the Vitro project, there are no existing groundwater wells near the proposed Federal Cell Facility.
The closest known wells are approximately two to three miles west, northwest and east of the site. However,
the well west of the site has been destroyed. While one of the two wells east of the site is in current use to
water livestock, the second well has been destroyed.

2.8 BIOTIC FEATURES

As is recorded SWCA 2011 Study provided in Appendix G, the site’s biotic features are appropriate for siting
disposal facilities. In August 1993, NRC concluded an Environmental Impact Study (EIS) and generated a
report detailing the potential impacts associated with the siting of EnergySolutions’ 11e.(2) disposal facility
in Utah’s West Desert. Subsequent to NRC’s EIS, EnergySolutions compiled an Environmental Assessment
in support of its application to renew Radioactive Material License UT2300478. In the process of creating
the EIS and EA, extensive research was performed into the vegetative and terrestrial populations in and around
Section 32. Even though it was originally conducted in support of the 11e.(2) Federal Cell Facility, the
analysis is applicable to this Application. Data from the EIS was later revisited by SWCA (SWCA, 2011).
This section summarizes ecological findings of SWCA and NRC.

The vegetation of the proposed Federal Cell Facility is a homogeneous, semi-desert low shrubland, primarily
composed of shadscale (Atriplex confertifolia). The shrubland is part of the Northern Desert Shrub Biome of
the Cold Desert Formation and is described as a Saltbush (Shadscale)-Greasewood Shrub complex. Plant
communities identified on the site are Shadscale-Gray Molly (Kochia americana var. vestita), a transitional
community type of Shadscale-Gray Molly-Black Greasewood (Sarcobatus vermiculatus), and Black
Greasewood-Gardner Saltbush (Atriplex nuttallii). Dominant shrubs on the proposed Federal Cell Facility
include shadscale, Nuttall’s saltbush, and winterfat (SWCA, 2011). All three communities are low in species
diversity. The proposed Federal Cell Facility occurs in the Desert Alkali range site, which is rated by BLM
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as being poor for grazing or forage production. However, the vegetation forms an important ground cover
and deterrent to soil erosion and provides habitat for wildlife species. Annual production of the three
community types ranged from 152 to 517 pounds per acre, air dry. Annual production for the range site is
given as 50 to 200 and 500 to 1,500 pounds per acre during unfavorable and favorable years, respectively.
Livestock carrying capacity with such production would range from 3 to 80 acres per animal-unit month.
Representative of the desert shrub/saltbush community are low widely spaced shrubs, totaling approximately
10 percent ground cover (Cronquist et. al, 1972).

Dominant shrubs on the proposed Federal Cell Facility include shadscale, Nuttall’s saltbush, and winterfat
(SWCA, 2011). Vegetation patterns of the proposed Federal Cell Facility are correlated with soil salinity and
corresponding shifts in presence or abundance of species. All three communities are low in species diversity.
Seep-weed or inkweed (Suaeda torreyana) and scattered perfoliate pepperweek (Lepidium perfoliatum) are
the only prominent understory species of the Shadscale-Gray Molly community. This community occurs over
most of the proposed Federal Cell Facility, although black greasewood becomes prominent enough in the
eastern quarter to form a Shadscale-Black Greasewood-Gray Molly community. Except for black greasewood
and occasional stands of halogeton (Halogeton glomeratus), the composition is similar to the more prominent
Shadscale-Gray Molly community. Maximum root depth of the late successional shadscale species is reported
to be 39 inches, while fourwing saltbush roots generally extend to a maximum depth of 20 inches (SWCA,
2011).

Black greasewood may have tap roots that extend beyond 11 feet beneath the surface. The Black Greasewood-
Gardner Saltbush community type is floristically the most diverse, but only occurs in the extreme northeast
corner and eastern edge of the proposed Federal Cell Facility. In addition to Gardner saltbush, the flora is
composed of all species found in the other communities except halogeton.

In the SWCA Study (2011), forty-one plant species were identified. However, because many desert forbs are
spring ephemerals and field sampling was conducted at the end of a growing season, the plant species diversity
and cover, particularly for herbaceous forbs, was underrepresented. Of the few forb species that were
detected, all were dead or senesced, with the exception of Halogeton (Halogeton glomeratus), a late-season
invasive annual weed. Biological soil crusts are a dominant feature of vegetation communities throughout
the Great Salt Lake basin. Soil crusts were present in all vegetation associations sampled, but were more
prevalent in the low desert vegetation associations (e.g., black greasewood, haltogeton-disturbed, and
shadscale-gray molly) present on and adjacent to the proposed Federal Cell Facility.

SWCA also examined the root density and maximum rooting depth of dominant plant species on the proposed
Federal Cell Facility. Excavations were performed to obtain cross-sections of the rooting mass of dominant
plant species. The roots were carefully exposed by gradual removal of vertical layers of soil with the backhoe
and hand tools. Root density measurements were collected by measuring the width of the rooting mass and
by counting visible roots across a set of sample widths or for the entire width of the root mass. Observed root
densities were higher near the surface of the soil, where roots were mostly fibrous with few woody structures.
A few large, woody roots were encountered in deeper soils. Rooting depths were shallower than expected,
with the maximum rooting depth of dominant woody plant species ranging from 40 to 70 cm. Woody plant
species maximum rooting depths were proportional to aboveground plant mass with an above-ground height
root depth ratio of 1:1 and an above-ground width root depth ratio of approximately 1.4:1. The halogeton had
higher ratios of plant height and width to maximum rooting depth (1.4:1 and 1.7:1, respectively). The low
proportion of roots to above-ground biomass is expected for annual plants, which invest the bulk of their
energy in reproduction and little energy in root systems.
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The proposed Federal Cell Facility is located within the year-long range of the pronghorn antelope. The West
Desert Herd Unit 2A occurs south of I-80 and includes the Clive site (BLM, 1988). Pronghorns are rare in
the project area south of Interstate-80. The area is considered poor pronghorn habitat. Interstate-80 acts as a
pseudo-barrier to most pronghorn movement south from the Puddle Valley Herd Unit.

Mourning doves are summer residents, arriving in February or March and migrating out of the area in August
or September. Doves are most abundant in edge or ecotone areas, particularly interspersions of agricultural,
sagebrush, and pinyon-juniper types. Mourning doves are the only game bird occurring on the proposed
Federal Cell Facility.

A variety of other non-game mammals, birds, and reptiles are supported by habitats found in the area and
associated utility, railroad, and access road rights-of-way. Species that may occur include the Townsend’s
ground squirrel, Ord’s kangaroo rat, desert woodrat, western harvest mouse, side-blotched lizard, gopher
snake, Brewer’s sparrow, black-throated sparrow, and horned lark (BLM, 1987).

Supplemental terrestrial life analysis, conducted by SWCA (2011), also observed species of small mammal:
deer mouse (Peromyscus maniculatus), northern grasshopper mouse (Onchomys leucogaster), and Great
Basin kangaroo rat (Dipodomys microps). Deer mice accounted for 22 of the 24 captured mammals (92%).
One northern grasshopper mouse and one Great Basin kangaroo rat were captured. At a second sampling
location, SWCA observed deer mice comprised 84% of the captures, Great Basin kangaroo rats 14%, and
Ord’s kangaroo rat 2%. Ord’s kangaroo rats were captured only at this site.

SWCA also observed several ant mounds near the proposed Federal Cell Facility. A total of 1,624 ants in the
genus Pogonomyrmex was collected in SWCA Sample Locations and determined to be the western harvester
ant. Four other ants collected were determined to be in the genus Lasius, with species not positively
determined but most likely niger. The western harvester ant is a widely distributed ant occurring throughout
most of Utah and many other western states. It frequently occurs in areas that are relatively flat and have been
recently disturbed by human activities.

Aquatic ecosystems do not occur on or near the proposed Federal Cell Facility.

No important plant or animal species, as identified in NRC (1980a), are known to occur on the proposed
Federal Cell Facility and no known important habitats have been identified in the area. Furthermore, no
threatened or endangered plant species are known to occur in the vicinity of the proposed Federal Cell Facility.
However, the Utah Division of Wildlife Resources reports that the area is used for foraging by bald eagles
and American peregrine falcon, which are federally listed endangered species, during the winter (SWCA,
2011). The bald eagle is a winter resident from late November to mid-March in the project vicinity. The
majority of wintering eagles are found in Rush Valley with others occurring in Skull and Cedar Valleys. No
bald eagle roosts are located within the proposed project area. However, the black-tailed jackrabbit is the
primary food source utilized by bald eagles in Tooele County (BLM 1988), and eagles potentially hunt within
this area.

One historical aerie of the American peregrine falcon was located near Timpie Springs Wildlife Management
Area in the northern end of the Stansbury Mountains. The nest site became inactive following the construction
of Interstate-80 in the late 1960s (BLM, 2012a). In an attempt to re-establish a breeding pair of peregrines,
the Utah Division of Wildlife Resources, in cooperation with the U.S. Fish and Wildlife Service (USFWS),
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erected a hack tower at the Timpie Springs Wildlife Management Area, approximately 26 miles from the
Clive site. The hack tower became active in 1983 and 1984. EnergySolutions monitored the site between
2005 and 2012, seeing no peregrine activity. Due to the distance between the proposed Federal Cell Facility
and the aerie, it is unlikely any peregrines utilize the project area.

The Great Basin fishhook cactus (Sclerocactus pubispinus) is currently under review for threatened status.
This species is associated with gravelly beach terraces of Pleistocene Lake Bonneville in western Tooele
County and is not expected to occur in the proposed Federal Cell Facility.

The Cedar Mountain has previously hosted approximately 362 horses or a range of 290 to 434 horses,
protected under the Wild and Free Roaming Horse and Burro Act of 1971 (BLM, 2012b). This number
fluctuates due to horse movement between the Cedar Mountains, the Onaqui Mountains, and Dugway Proving
Grounds. Fences that might preclude horse movement between the three areas are generally insufficient to
deter movement. The current established appropriate management level for the Cedar Mountains is set at 190
horses on the low end and 390 at the upper level (BLM, 2012b). Dependable summer water sources are a
major problem. In drought years, natural water sources may dry up, generating the need for water to be trucked
in. Hauling water is a financial impact to BLM and the transportation infrastructure. In times of reducing
budgets, there is no certainty that BLM will be able to continue to haul water to wild horses in sufficient
quantity to insure the quality of their existence and avoid mortality. During drought, increased stress is also
placed on the water sources and adjacent vegetation as horses congregate around troughs whether or not water
is in the spring. Wild horses are seldom encountered on the proposed Federal Cell Facility (BLM, 2012b),
and are monitored so that the herd population does not exceed more than the environment could sustain
(Grams, 2009). No wild horses have been observed in the proposed Federal Cell Facility since 2012. The
state sensitive kit fox may occur throughout the West Desert Hazardous Industry Area (UDWR, 2010).

Because nationwide populations have been declining for the past 25 years, the Greater sage-grouse have been
designated a Federal Candidate species and heightened monitoring efforts are being conducted (UDNR,
2009). On March 5, 2010, the US Fish and Wildlife Service announced that greater sage-grouse now have a
“warranted, but precluded” status, meaning the Service considers the Sage-grouse warrant listing on the
Endangered Species Act, but that other species are a higher priority (BLM, 2012b). Because Sage-grouse
require large tracts of sagebrush plant communities for their life cycle, a range-wide Assessment of Greater
Sage-grouse included potential distribution in the West Desert, but noted that, “barren habitats west of the
Great Salt Lake and forested and alpine areas in mountainous areas were not historically occupied by sage-
grouse,” (UDNR, 2009).

The Assessment further noted that the most favorable Sage-grouse habitat is located near Vernon (eastern
Tooele County) and in the Ibapah (western Tooele County), (UDNR, 2009). In 2006, a total of 190 males
were counted on six mating sites in Vernon. In Ibapah, a total of 93 males were counted on five mating sites.
The Assessment notes that a variable but stable pattern in sage-grouse numbers has been observed near Vernon
since the late 1960s. However, because there has been difficulty in accessing private and Tribal lands, the
Assessment has not been able confirm a similar trend for Sage-grouse mating sites near Ibapah. No Sage-
grouse mating sites have been observed near the Clive facility. Additionally, the viable hazards identified
Assessment’s threat analysis (e.g., altered water distribution for irrigation, home and cabin development, tall
structure construction, and aggressive road construction) have negligible to no likelihood of occurrence at the
proposed Federal Cell Facility.

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2.9 SITE CHARACTERISTIC PREOPERATIONAL MONITORING

EnergySolutions’ preoperational characterization of the site is appropriate for siting disposal facilities. As is
summarized in Table 2-5, EnergySolutions and DOE have collected extensive radiological preoperational
environmental samples before starting major construction of its various licensed and permitted disposal
facilities and continues operational sampling according to the requirements of Radioactive Material Licenses
UT2300249 and UT2300478. Environmental results are reported semi-annually to the Director. In addition
to the proposed Federal Cell Facility, EnergySolutions also operates an adjacent Class A West Facility and
11e.(2) byproduct disposal facility under Agreement-State licenses issued by the Director. Because of the
facilities’ close proximity, locations used for monitoring both facilities will also inform environmental
monitoring for the Federal Cell Facility. Subsequently, the results of environmental monitoring performed at
those locations that are common to both facilities are reported to the Director.

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Table 2-5

Preoperational Radioactivity Concentrations in Soil

RADIONUCLIDE
CONCENTRATION RANGE
(pCi/g)
Curium-244 0.0 +/- 0.1 - 0.1 +/- 0.1
Plutonium-238 0.0 +/- 0.1 - 0.0 +/- 0.1
Plutonium-239/240 0.0 +/- 0.1 - 0.1 +/- 0.2
Plutonium-241 0.0 +/- 0.1 - 0.0 +/- 1.6
Plutonium-242 0.0 +/- 0.1 - 0.3 +/- 0.4
Uranium-238 0.7 +/- 0.1 - 1.1 +/- 0.1
Thorium-232 0.9 +/- 0.1 - 1.1 +/- 0.2
Thorium-230 1.1 +/- 0.2 - 1.6 +/- 0.2
Radium-226 0.9 +/-0.1 - 1.2 +/- 0.1
Lead-210 1.1 +/- 0.1 - 1.8 +/- 0.2
Polonium-210 1.5 +/- 0.6 - 2.6 +/- 0.6
Cesium-137 0.4 +/- 0.1 - 1.1 +/- 0.2
Iodine-129 0.4 +/- 3.6 - 0.0 +/- 6.6
Technetium-99 0.0 +/- 0.7 - 0.7 +/- 1.0
Strontium-90 0.3 +/- 0.3 - 0.3 +/- 0.4
Nickel-63 0.0 +/- 3.1 - 5.0 +/- 1.4
Iron-55 0.0 +/- 2.1 - 0.0 +/- 2.9
Potassium-40 12.3 +/- 0.4 - 13.4 +/- 0.5
Carbon-14 0.0 +/- 6.6 - 3.1 +/- 8.9
Source: (DOE, 1984)

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SECTION 3. DESIGN AND CONSTRUCTION

As is depicted on the Engineering Drawings included as Appendix H, EnergySolutions’ Federal Cell Facility
design is a near-surface landfill. EnergySolutions’ proposes that the Federal Cell Facility be constructed using
materials native to the site or found in close proximity to the site (see material calculations reported in
Appendix J). Engineered features of the Federal Cell Facility, documented in the Federal Cell Facility
Construction Quality Assurance / Quality Control Manual (FCF CQA/QC Manual), and are designed based
upon State of Utah regulations, NRC guidance, EPA guidance, and EnergySolutions’ past experience at this
location (see Appendix I). Principal design features of the Federal Cell Facility include: clay liner, waste
placement, backfill placement, final cover, drainage systems, and a buffer zone. Adequate auxiliary systems
and facilities already supporting EnergySolutions’ other disposal facilities include utility systems, operational
support facilities, fire protection systems, and water management systems.

The general design requirements for the licensing the Federal Cell Facility are set forth in the UAC R313-25,
administered by the Director. UAC Rule R313-25-25 outlines six design requirements for near-surface land
disposal of radioactive waste as follows:
1. Site design features shall be directed toward long-term isolation and avoidance of the need for
continuing active maintenance after closure;
2. The disposal site design and operation shall be compatible with the disposal site closure and
stabilization plan and lead to disposal site closure that provides reasonable assurance that the
performance objectives will be met;
3. The disposal site shall be designed to complement and improve, where appropriate, the ability of the
disposal site’s natural characteristics to assure that the performance objectives will be met;
4. Covers shall be designed to minimize, to the extent practicable, water infiltration, to direct percolating
or surface water away from the disposed waste, and to resist degradation by surface geologic
processes and biotic activity;
5. Surface features shall direct surface water drainage away from disposal units at velocities and
gradients which will not result in erosion that will require ongoing active maintenance in the future;
and
6. The disposal site shall be designed to minimize to the extent practicable the contact of standing water
with waste during disposal, and the contact of percolating or standing water with wastes after disposal.

UAC R313-25-23 requires that the Federal Cell Facility be sited, designed, used, operated, and closed to
achieve long-term stability of the disposal site without the perpetual need for ongoing active maintenance.
Radiation protection standards are set forth in UAC R313-25-19, R313-15-301 and R313-15-302.

The Utah Division of Water Quality (DWQ) has adopted performance based Best Available Technology
(BAT) standards for EnergySolutions’ Federal Cell Facility, requiring that groundwater protection standards
will not be exceeded at compliance wells within 200 years for non-radioactive hazardous constituents and
within 500 years for radioactive constituents (where 10,000-year compliance period is required by UAC
R313-25-9(5)(a)).

Where required design criteria set forth specific criteria, the facility has been designed to meet that
requirement, such as the DWQ water quality protection levels. However, the general criteria that the facility
design must “achieve long-term stability... to eliminate, to the extent practicable, the need for ongoing active
maintenance of the disposal site after closure,” requires a determination of the meaning of “long-term.” UAC
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R313-25-9(5) requires a performance assessment successfully demonstrate that the performance standards
specified in 10 CFR Part 61 and corresponding provisions of Utah rules will be met for the total quantities of
concentrated depleted uranium for a compliance period of 10,000 years. EnergySolutions has adopted this
standard to determine the design criteria for long-term stability.

Site characteristics that influence the extent to which radioactive material may be released to the general
environment and potentially cause radiation exposure to members of the general public include: precipitation
rate, depth to groundwater, dissolved solids content of groundwater, and probable maximum magnitude of
flood events. Proposed Federal Cell Facility design, operating, and closure features complement and improve
the ability of the site to limit the release of radioactive material from the site and potentially cause radiation
exposure to members of the general public include the following: multi-layer engineered cover system; waste
emplacement procedures and configurations that produce a stable disposal embankment; clay liner under
disposed waste with permeability greater than that of the cover system; inventories of radionuclides disposed
in the Federal Cell Facility will meet limitation requirements determined through the performance assessment
analyses and final cover will not be constructed until settlement is shown to be within acceptable limits. The
site characteristics that influence the extent to which individuals may be exposed to radiation during facility
operations include a sparse population density in vicinity of the disposal embankment.

Design, operating, and closure features complement and improve the ability of the site to limit the extent to
which individuals may be exposed to radiation during facility operations include: waste with highest
radioactive concentrations and hazards are contained in shipping containers that are disposed of without
opening them; and waste handling and placement operations are conducted so as to limit the release of
radioactive materials during operations.

The site characteristics that influence the extent to which long-term stability of the disposal site is achieved
and to which the need for ongoing active maintenance of the disposal site following closure is eliminated
include: average annual precipitation rate is less than 9 inches per year; and concentration of dissolved solids
in groundwater is greater than 20,000 mg/L.

Design, operating, and closure features provided that complement and improve the ability of the site to limit
the extent to which long-term stability of the disposal site is achieved and to which the need for ongoing active
maintenance of the disposal site following closure is eliminated include: the final cover will not be constructed
until the Federal Cell Facility settlement has been demonstrated to be within acceptable limits The cover
system is designed to limit the potential for water erosion and wind erosion. Internal erosion between layers
of the cover system side slope will be minimized or prevented by adhering to specified design (e.g., filter)
criteria during construction The proposed cover system slopes have been demonstrated to be stable under
static and dynamic conditions; and the permeability of the cover system is designed and would be constructed
to be lower than that of the liner system.

Based on the information herein summarized, the proposed Federal Cell Facility is designed to complement
and improve, where appropriate, the ability of the disposal site's natural characteristics to assure that the
performance objectives will be met.

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3.1 PRINCIPAL DESIGN FEATURES

As is summarized in Table 3-1, the Federal Cell Facility is designed with cover, backfill placement, waste
placement configurations, liner, drainage systems and a buffer zone as critical principal features that provide
long-term isolation of disposed depleted uranium, minimize the need for continued active maintenance after
Facility closure, and improve the Facility’s natural characteristic in order to protect public health and safety.
These principal design features minimize the infiltration of water into the Federal Cell Facility; ensures the
integrity of the Facility’s cover; provides for structural stability of backfill, concentrated depleted uranium
and cover; minimize contact of concentrated depleted uranium with standing water, provide adequate drainage
during operations and after Facility closure, facilitate site closure and stabilization, minimize the need for
long-term maintenance, provide barrier against inadvertent intrusion, maintain occupational exposure as low
as is reasonably achievable, provide adequate disposal site monitoring, and provide an adequate buffer zone
for monitoring and potential mitigative action.

Cover System
The Federal Cell Facility’s cover design is engineered to reduce infiltration, prevent erosion, and protect from
radionuclide exposure by limiting water flow to monitoring wells (for at least 500 years in compliance with
the Groundwater Quality Discharge Permit conditions and 10,000 years in compliance with UAC R313-25-
9.5.a), increasing evapotranspiration from the top slope and promoting runoff via steeply sloped sides. The
general design aspect of the Federal Cell Facility is that of a hipped cover, with relatively steeper sloping sides
nearer the edges. The upper part of the Federal Cell Facility, known as the top slope, has a moderate slope,
while the side slope is markedly steeper. The top slopes of the cell will be finished at a 2.4% grade, with side
slopes at 20%. The depleted uranium waste disposal region of the Federal Cell Facility is also constructed
such that a portion of it lies below-grade. The overall length of the Federal Cell Facility is 1,920 ft, and the
overall width is 1,226.5 ft. Since depleted uranium waste is only placed beneath the top slope of the Facility’s
cover, the depth of the waste below the top slope is a maximum of 37.8 ft. As shown within the drawings in
Appendix H, the design includes both a low-angled top slope and steeper side slope section of the cover. The
layers to be used in the Federal Cell Facility top slope (constructed to 2.4%) cover consist of the following,
from top to bottom:
• Surface layer: This layer is composed of native vegetated Unit 4 material with 15 percent gravel
mixture. This layer is 12 inches thick. The functions of this layer are to control runoff, minimize
erosion, and maximize water loss from evapotranspiration. This layer of silty clay provides storage
for water accumulating from precipitation events, enhances losses due to evaporation, and provides a
rooting zone for plants that will further decrease the water available for downward movement. A
residual moisture content meeting or exceeding 3.5% is required for surface layer soils (as required
by Condition 1.D.4.a(3) of the GWQDP), with gradations meeting the specifications reported on
Drawing 10014-C04.
• Evaporative Zone layer: This layer is composed of Unit 4 material. The thickness of this layer is 12
inches. The purpose of this layer is to provide additional storage for precipitation and additional depth
for plant rooting zone to maximize evapotranspiration. A residual moisture content meeting or
exceeding 3.5% is required for evaporation zone layer soils (as required by Condition 1.D.4.a(3)
of the GWQDP), with gradations meeting the specifications reported on Drawing 10014-C04.

Radioactive Material License Application / Federal Cell Facility

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Table 3-1: Design Criteria of the Principle Design Features

Principal
Design
Feature
Required
Function
Complementary
Aspects
Design Criteria Design Criteria Justification Conditions

Liner

Minimize contact
of wastes with
standing water

Minimize contact of
wastes with standing
water during
operations

Permeability
 1 x 10-4 cm/sec
Prevent contact of water with waste.
Operational experience shows that 10-4
cm/sec permeability promotes runoff and
allows accumulation of water to occur. Water
is then removed by pumping.
normal 25 yr. 24 hr. storm
abnormal 100 yr. 24 hr. storm
accident Heavy equipment damage to liner
Minimize contact of
wastes with standing
water after closure

Liner permeability  cover permeability

Inflow into embankment < outflow out of
embankment.
normal Liner and cover retain design permeability over time
abnormal Degraded cover
accident Not required per NUREG-1199

Ensure cover
integrity

Mitigate differential
settlement

Maximum allowable distortion in
cover = 0.02

Geosyntec “Geotechnical Engineering
Evaluation for Federal Cell at the Clive
Facility (Appendix M)
normal Settlement completed during operations
abnormal One area to cover height with adjacent area less than 25 feet
high
accident Not required per NUREG-1199

Waste
Placement

Ensure cover
integrity

Mitigate differential
settlement

Maximum allowable distortion in
cover = 0.02

Geosyntec “Geotechnical Engineering
Evaluation for Federal Cell at the Clive
Facility (Appendix M)

AMEC, 2012a,b “EnergySolutions Clive
Facility – Clay Distortion Study.”
normal All primary and portion of secondary settlement in soil layers
complete during construction and 100-year institutional control
period
abnormal Creep of compressible waste and additional secondary
settlement of soils after 100-year institutional control period.
accident Not required per NUREG-1199
Ensure structural stability
Maintain slope stability
Static safety factor  1.5
Seismic safety factor
 1.2
State of Utah Statutes and Administrative Rules for Dam Safety, Rule R625-11-6

Geosyntec “Geotechnical Engineering
Evaluation for Federal Cell at the Clive
Facility (Appendix M)
normal Static conditions
abnormal Earthquake
accident Not required per NUREG-1199

Backfill

Ensure cover
integrity

Mitigate differential
settlement

Maximum allowable distortion in
cover = 0.02

Geosyntec “Geotechnical Engineering
Evaluation for Federal Cell at the Clive
Facility (Appendix M)

AMEC, 2012a,b “EnergySolutions Clive
Facility – Clay Distortion Study.”
normal All primary and portion of secondary settlement in soil layers
complete during construction and 100-year institutional control
period
abnormal Creep of compressible waste and additional secondary
settlement of soils after 100-year institutional control period.
accident Not required per NUREG-1199

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Principal
Design
Feature
Required
Function
Complementary
Aspects
Design Criteria Design Criteria Justification Conditions

Ensure structural
stability

Maintain slope stability

Static safety factor  1.5
Seismic safety factor  1.2

State of Utah Statutes and Administrative
Rules for Dam Safety, Rule R625-11-6

Geosyntec “Geotechnical Engineering
Evaluation for Federal Cell at the Clive
Facility (Appendix M)

normal Static conditions
abnormal Earthquake
accident Not required per NUREG-1199

`

Cover

Minimize
infiltration

Minimize infiltration
Average Infiltration  0.036
inches/year
(0.09 cm/year) top
slope0.066 inches/year
(0.168 cm/year) side slope

Neptune 2021 (Appendix P)
Neptune 2015 (Appendices Q)
normal Average annual precipitation (7.92 ")
abnormal All abnormal conditions related to the Complementary Aspects
of "Encourage Runoff", "Desiccation", "Frost Penetration", and
"Biointrusion".
accident Not required per NUREG-1199

Encourage runoff
Maintain positive drainage;
Maximum design velocity within
drainage layer > calculated
drainage velocities;
Do not allow water accumulation

Drainage (flow) needs to be maintained under
all conditions
normal 100 yr. 24 hr. storm
abnormal PMP (1-hour = 6.1 inches)
accident Downstream blockage
Prevent desiccation No desiccation cracking in Radon
Barrier Clay
Ensure infiltration design criteria is attained normal Historic weather patterns
abnormal Drought
accident NA

Limit frost penetration
Thickness of rock/filter/sacrificial
soil zones  maximum depth of
frost (3 feet)
Ensure infiltration design criteria is attained normal Historic weather patterns
abnormal Monthly average minimum temperatures below those
predicted by the 500 year return frequency
accident Not required per NUREG-1199
Limit biointrusion Biointrusion shall be discouraged and shall not cause increased infiltration
Ensure infiltration design criteria is attained normal Desert plant growth (shallow rooted)
abnormal Desert plant growth (deep rooted)
accident Not required per NUREG-1199

Reduce Exposures

Surface dose rates

100 mrem TEDE

R313-15-301
normal Low to moderate gamma emitters
abnormal High gamma emitter at top of waste
accident NA

Ensure Cover Integrity
Mitigate Differential Settlement
Maximum Allowable Distortion = 0.02
Geosyntec “Geotechnical Engineering Evaluation for Federal Cell at the Clive Facility (Appendix M) AMEC, 2012a,b “EnergySolutions Clive Facility – Clay Distortion Study.”
normal All primary and portion of secondary settlement in soil layers complete, no container deterioration up to 100 years
abnormal Container deterioration after 100 years, allowing creep of
compressible waste and additional secondary settlement of
soils. Earthquake.
accident Not Required per NUREG-1199

Prevent NUREG/CR-4620 normal 100 yr. 24 hr. storm
abnormal PMP (1-hour = 6.1 inches)
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Principal
Design
Feature
Required
Function
Complementary
Aspects
Design Criteria Design Criteria Justification Conditions

Cover

Ensure
Cover
Integrity
Internal
Erosion
Water velocity < 5.41 ft/sec on
Radon Barrier Clay
(see Appendix L) accident Not Required per NUREG-1199

Prevent Piping:
D15(filter)/D85(soil)  5 AND
D50(filter)/D50(soil)  25

Prevent Upward Migration of
Fines
D15(Lower Layer)/D85(Upper
Layer)  4
Reduce plugging of lower filter layer.
Cedergren, H.R., (1977), "Seepage,
Drainage, and Flow Nets" second edition,
John Wiley & Sons, New York, pp. 178-182.

DOE, 1989. Technical Approach Document,
Revision II, UMTRA-DOE/Al 050425.0002,
pp. 82-83
normal
Performance calculations are developed for saturated
conditions within dams. Conditions at Clive are much less
severe.

DOE ratios have been developed for abnormal saturated
conditions within an UMTRA embankment.
abnormal
accident
Material Stability / Endure Weathering, External Erosion
10,000 year life NUREG-1623 NUREG/CR-4620 (Appendix L)
normal Historic Weather Patterns
abnormal PMP (1-hour = 6.1 inches)
accident Not Required per NUREG-1199

Ensure
Structural
Stability
Settlement
Long Term Cover Drainage (No Slope Reversal)
Minimize Ponding
normal Evenly Distributed Weight Loading
abnormal Creep of compressible waste and additional secondary
settlement of soils after 100-year institutional control period.
accident Not Required per NUREG-1199
Maximum Total Settlement
 15% of Embankment Height

Highway embankments and major waste
storage embankments have settled up to 15%
of their height and performed adequately

normal Evenly Distributed Weight Loading
abnormal Creep of compressible waste and additional secondary
settlement of soils after 100-year institutional control period.
accident Not Required per NUREG-1199
Maintain
Slope
Stability

Static Safety Factor  1.5
Seismic Safety Factor  1.2

State of Utah Statutes and Administrative
Rules for Dam Safety, Rule R625-11-6
normal Static Conditions
abnormal Earthquake
accident Not Required per NUREG-1199

Drainage Systems

Provide Site Drainage

Facilitate flow away
from the embankment
Depth of water < depth of ditch.
Promote free flowing conditions.
Freeboard  0.5 foot under
normal conditions.

Minimize potential infiltration into the waste.
normal 25 yr. 24 hr. storm
abnormal 100 yr. 24 hr. storm
accident Downstream Blockage

Minimize Infiltration
under flood conditions
Flood water shall dissipate faster
than water travels through the
cover system.
Ponded flood water would promote infiltration.
So long as flood water drains or evaporates
faster than the travel time through the cover,
increased infiltration will be minimized.
normal 100 year flood (3,802 cfs)
abnormal PMF (48,500 cfs)
accident Downstream Blockage
Ensure Ditch
Integrity
Prevent
Internal
Erosion

Size of rock able to handle
stresses related to flow

NUREG/CR-4620 - (Appendix L)
NUREG-1623
normal 25 yr. 24 hr. storm
abnormal 100 yr. 24 hr. storm
accident Not Required per NUREG-1199

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Principal
Design
Feature
Required
Function
Complementary
Aspects
Design Criteria Design Criteria Justification Conditions

Buffer
Zone

Provide Site
Monitoring

Not applicable

Sized adequate for monitoring
and corrective measures

Compliance monitoring
normal No releases
abnormal Contaminant releases
accident Not Required per NUREG-1199

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• Frost Protection Layer: This material ranges in size from 16 inches to clay size particles. This layer
is 18 inches thick. The purpose of this layer is to protect layers below from freeze/thaw cycles,
wetting/drying cycles, and to inhibit plant, animal, or human intrusion. (as required by Condition
1.D.4.a(3) and the rock scoring specifications in the FCF CQA/QC Manual). Environmental
sampling and performance modeling demonstrates that the frost depth will not exceed the
cumulative depths of the surface, evaporation zone, and frost protection layers (Montgomery
Watson, 2000; Western Regional Climate Center, 2000; RBG 2020).
• Upper Radon Barrier: This layer consists of 12 inches of compacted clay with a low hydraulic
conductivity. This layer has the lowest conductivity of any layer in the cover system. This is a barrier
layer that reduces the downward movement of water to the waste and the upward movement of gas
out of the disposal cell. The as-built saturated hydraulic conductivity (Ksat) of this layer is 5x10-8 cm/s.
Modeling further demonstrates that the steady-state moisture content of the clay radon barrier will
remain constant throughout the life of the Facility.
• Lower Radon Barrier This layer consists of 12 inches of compacted clay with a low hydraulic
conductivity. This is a barrier layer placed directly above the waste that reduces the downward
movement of water. The as-built Ksat of this layer is 1x10-6 cm/s. Modeling further demonstrates that
the steady-state moisture content of the clay radon barrier will remain constant throughout the life of
the Facility.

The layers used in the Federal Cell Facility side slope cover (constructed to 20%) consist of the following,
from top to bottom:

• Rip Rap cobbles. Approximately 18-inches of Type-A rip rap will be placed on the side slopes
above the Type-A filter zone. The Type-A rip rap ranges in size from 2 to 16 inches (equivalent to
coarse gravel to boulders) with a nominal diameter of 12 inches. Engineering specifications indicate
that 100% of the Type-A rip rap would pass a 16-inch screen and not more than 15% would pass a
4½-inch screen (as required by Condition 1.D.4.a(1) and the rock scoring specifications in the FCF
CQA/QC Manual).
• Filter Zone. The thickness of the Type B filter in the side slope will be 12 inches. The Type B filter
material in the side slope will consist of granular material with a particle size ranging from 0.3125
to 3.0 inches in diameter (coarse sand to fine cobble) and a minimum hydraulic conductivity of 42
cm/sec. In order to promote drainage and avoid ponding, the filter zone is constructed with a
specification that its permeability exceed 3.5 cm/sec, with strict gradation specifications (as
reported on Drawing 10014-C04) and rock scoring testing exceeding 50 (as required by
specifications of the FCF CQA/QC Manual and Condition I.D.4.a(5) of the GWQDP).
• Frost Protection Layer (Sacrificial Soil). This material ranges in size from 16 inches to clay size
particles. This layer is 18 inches thick. The purpose of this layer is to protect layers below from
freeze/thaw cycles, wetting/drying cycles, and to inhibit plant, animal, or human intrusion. A
residual moisture content meeting or exceeding 3.5% is required for sacrificial soils (as required
by Condition 1.D.4.a(3) of the GWQDP), with gradations meeting the specifications reported on
Drawing 10014-C04. FCF CQA/QC Manual specifications frost protection layer require runoff
water velocities not to exceed 2.3 x 10-2 ft/sec during typical rainfall events and 8.0 x 10-4 ft/sec
during Probable Maximum Precipitation events (Whetstone, 2005; Neptune 2020). Environmental
sampling and performance modeling demonstrates that the frost depth will not exceed the
cumulative depths of the rip rap, filter zone, and frost protection layers (Montgomery Watson,
2000; Western Regional Climate Center, 2000; RBG 2020).
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• Upper Radon Barrier. This layer consists of 12 inches of compacted clay with a low hydraulic
conductivity. This layer has the lowest conductivity of any layer in the cover system. This is a
barrier layer that reduces the downward movement of water to the waste and the upward movement
of gas out of the disposal cell. The as-built Ksat of this layer is 5x10-8 cm/s. Modeling further
demonstrates that the steady-state moisture content of the clay radon barrier will remain constant
throughout the life of the Facility.
• Lower Radon Barrier This layer consists of 12 inches of compacted clay with a low hydraulic
conductivity. This is a barrier layer placed directly above the waste that reduces the downward
movement of water. The as-built Ksat of this layer is 1.x10-6 cm/s. In order to ensure cover long-
term performance, clays are selected for radon barrier construction that have 85% fines (< 0.075
mm), a plasticity index between 10 and 25, and a liquid limit between 30 and 50. The clays must
also demonstrate an ability to be compacted to 95% of a standard proctor when moisture contents
are maintained between optimum and optimum plus 5% (as required by specifications of the FCF
CQA/QC Manual and Condition I.D.4.a(5) of the GWQDP). Modeling further demonstrates that the
steady-state moisture content of the clay radon barrier will remain constant throughout the life of the
Facility.

Backfill Placement
Since depleted uranium can only be placed beneath grade and then entombed by Controlled Low-Strength
Material (CLSM), unit 3 soils will be placed above grade to the design height of approximately 38 feet above
grade. Above grade backfill placement in the Federal Cell Facility will be controlled in accordance with the
FCF CQA/QC Manual, Work Element – Backfill Placement. No other novel engineering designs or
construction methods will be required for backfill placement within the Federal Cell Facility.

Waste Placement Configurations
When placing depleted uranium waste in the proposed Federal Cell Facility, EnergySolutions will utilize
construction specifications detailed in the FCF CQA/QC Manual. The specifications methods within this
manual have been previously approved in other CQA/QC Manuals, and successfully implemented in the
construction of other waste embankments at Clive. No other novel engineering designs or construction
methods will be required for management of waste or construction of the Federal Cell Facility, nor will the
waste disposed in the Federal Cell Facility differ from waste currently being disposed in other disposal
facilities in EnergySolutions’ Clive Disposal Complex in regard to radioactivity, physical form, or potential
hazard.

The principal objectives of the Federal Cell Facility design are to: (1) provide long-term isolation of disposed
depleted uranium waste, (2) minimize the need for continued active maintenance after site closure, and (3)
augment the site’s natural characteristics in order to protect public health and safety. EnergySolutions has
designed the Federal Cell Facility to effectively control any radioactive release for at least 10,000 years.
Accordingly, the principal design features include those elements of the completed Federal Cell Facility that
impact long-term performance of the facility.

Concentrated depleted uranium disposal in the Federal Cell Facility will be limited to the bottom of the
Facility, below native grade and only under the cover’s top slope. Dimensions for the depleted uranium
disposal zone are approximately 7.4 feet thick by 877 feet wide (east–west) by 1570 feet long (north–south)
(see design drawings in Appendix H). This equates to a design capacity for depleted uranium disposal of about
10.2 million cubic feet, all below native grade. To ensure stability, EnergySolutions commits to placing
controlled low-strength material (CLSM) backfill between the depleted uranium cylinders and drums. The
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addition of the CLSM matrix fills voids and prevents subsidence. FCF CQA/QC Manual specifications further
limit the differential settlement of placed wastes to 0.01 under abnormal conditions. Similarly, waste
placement configuration is designed to ensure a static safety factor meets or exceeds 2.1 (with a minimum
static factor of safety of 1.5) and a seismic safety factor (abnormal conditions) meets or exceeds 1.2. Other
construction specifications for application of CLSM are provided in the FCF CQA/QC Manual. No revision
to this specification will be needed for construction of the proposed Federal Cell Facility.

Liner
The general design aspect of the Federal Cell Facility is that of a hipped cover, with relatively steeper sloping
sides nearer the edges. The embankment is constructed such that a portion of it lies below-grade into the native
Unit 4 silty clay soil (8 feet). Waste will be placed above a constructed liner consisting of a two-foot-thick
layer of compacted Unit 4 clayey soils, covered by 1 foot of liner protective media (using Unit 4 clayey soils).
Groundwater does not need to be directed away from the proposed Federal Cell Facility, since the lowest top
of liner elevation is more than 13 feet above the highest recorded elevation for the upper, unconfined aquifer.
The lowest top of liner elevation will be at approximately 4,262 feet above sea level (see Drawing 14004-C02
in Appendix H); the highest recorded elevation for the upper, unconfined aquifer, based on available data
from recent years for wells near the proposed Federal Cell Facility is 4,251.3 feet above sea level. FCF
CQA/QC Manual specifications limit in-service liner performance to a maximum distortion of 0.001 under
normal conditions and 0.007 under abnormal conditions.

The clay liner proposed for the Federal Cell Facility is identical to that approved for EnergySolutions’ other
disposal embankments. The proposed Federal Cell Facility liner system consists of a prepared foundation
overlain by a two-foot-thick layer of compacted clay having a saturated hydraulic conductivity of 1x10-6
cm/sec or less. The permeability of the Federal Cell Facility liner will be less than or equal to 1 x 10-4 cm/sec
and greater than that of its cover system. Existing terrain has been excavated to a depth of approximately
seven to ten feet below native grade. Excavation depth is determined based on the top of liner elevation shown
on design drawings. The minimum excavation depth is two feet deeper than the top of liner elevation shown
on design drawings. Overburden removed in reaching foundation elevation is stockpiled for future use in liner
construction, capping the embankment, or as fill material. The embankment foundation is prepared from in-
situ soils to meet design, grade, and compaction specifications. Specifications and inspection activities for
foundation preparation are detailed in the FCF CQA/QC Manual. Clay liner construction methods are
approved with the satisfactory construction of a clay liner test pad, as detailed in the FCF CQA/QC Manual.
The equipment and procedures used for the test pad are reviewed and approved by a professional engineer
qualified to certify such soil considerations. The test pad method is then reviewed and approved for
construction by the Director.

Drainage Systems
The post-closure drainage system surrounding the proposed Federal Cell Facility has been designed to direct
flow from ambient precipitation away from the side slope of the disposal unit. The current drainage system
routes the flows from the proposed Federal Cell Facility beginning from a high point at the northwest corner,
around both sides, to the south-east corner. From that point, the combined flow runs south to the westward
flowing ditch that runs along the south boundary of Section 32. That south ditch currently carries stormwater
from all embankments in Section 32. The revised drainage system depicted on the drawings isolates
stormwater flows from the proposed Federal Cell Facility and route them to the southwest corner of proposed
Federal Cell Facility, then southward along the west edge of Section 32, where the flow will discharge at the
southwest corner of Section 32.

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Drainage system design for the proposed Federal Cell Facility is a minimum of 4 feet deep. Rock armoring
of the drainage ditches consists of Type A filter material and rip rap (with a D50 of 4.5 inches as required in
the FCF CQA/QC Manual). A site-wide drainage evaluation was performed, and total ditch flow calculations
have been included as Appendix K. The ditch flow calculations were devised to determine whether ditch
designs associated with the proposed Federal Cell Facility were rigorous enough to withstand both the normal
(25-year, 24 hour) and abnormal (100 year, 24 hour) storm conditions. Flow calculations were also performed
for the drainage ditch system along the southern edge of Section 32 as water for all of the embankments will
flow through these ditches before reaching the drainage system outlet.

Flow velocities for the proposed Federal Cell Facility drainage ditches were calculated based on the drawings
provided in Appendix H. Upon obtaining flow velocities, storm events were calculated using isopluvial maps
and calculations provided by the National Oceanic and Atmospheric Administration (NOAA, Atlas 14,
Volume 1, Version 5). Drainage areas, previously calculated for other designed embankments at the Clive
facility, have been included with that from the proposed Federal Cell Facility. These drainage areas, and ditch
volume equations were used to ascertain whether upstream storage would cause ditch overflow given the
normal (25-year, 24 hour) and abnormal (100 year, 24 hour) storm conditions.

Drainage calculations were performed first for the proposed Federal Cell Facility ditches and the Section 32
southern ditches (as a representation of total site drainage). These calculations illustrate that current ditch
designs meet drainage systems design criterion for the proposed Federal Cell Facility, and are adequate to
handle site-wide flows associated with both the normal and abnormal storm events during operations.

Buffer Zone
Following completion of the construction and closure of all embankments at the Clive Facilities,
EnergySolutions’ licensed area (Section 32) will be permanently fenced and posted, leaving a buffer zone
between the toe of waste from each embankment and the Section 32 perimeter fence. This allows room inside
of the fence for an inspection roadway and groundwater monitoring wells. With the exception of the Vitro-
EnergySolutions property line, a buffer zone of at least 300 feet will be maintained between the closest edge
of any Facility (i.e., toe of waste) and the outside site boundary or property line. This 300-foot buffer zone is
a requirement of the facility’s Conditional Use Permit issued by Tooele County and ensures ground water
protection limits are not exceeded at offsite monitoring wells within 10,000 years of Facility closure (Neptune
2020).

Permanent site boundary markers are affixed to provide documentation of the exact location of the disposal
facilities. The markers are United States Geological Survey (USGS) quadrant “brass cap” markers, whose
design disposal facility locations have been verified by licensed surveyors. All locations have been tied into
the USGS survey control stations. Upon closure, permanent markers will be placed at the head and toe of
each disposal facility.

EnergySolutions controls all access to property at the Clive facility, through fences, gates, and security
monitoring. Drawing set 14004 (provided in Appendix H) shows the relationship between the Federal Cell
Facility and the property boundaries. All areas utilized for depleted uranium material receiving, unloading,
hauling, handling, and placement in the Federal Cell Facility will be considered a Restricted-Access (or
Controlled) Area, (as defined in UAC R313-15-2). As such, any person entering the Controlled Area must
check in and out through Access Control, or through a truck/vehicle entrance gate. Radiation exposure to
persons working within the controlled area is monitored using Thermo Luminescent Dosimeters (TLD), or
equivalent monitoring devices. The fence is conspicuously posted with “Caution -- Radioactive Materials”
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signs bearing the standard radiation symbol. Other signs are posted as appropriate. The Restricted Area
boundary may change as waste placement proceeds in the Federal Cell Facility. There are not, however, any
changes proposed to the requirements for control of the Restricted Areas as part of this Application.

3.2 CONSIDERATIONS FOR NORMAL AND ABNORMAL/ACCIDENT CONDITIONS

In this Application, each of the aspects of the Federal Cell Facility principal design features has been analyzed
for normal conditions, abnormal conditions, and potential accident conditions (see Tables 3-2 and 3-3). The
review demonstrates that each aspect of the facility remains stable through these conditions.

In NUREG-1199 (section 6.3.2), NRC contemplates evaluation of design against a factor of safety only in the
area of slope stability analysis. In the context of retention systems at uranium recovery facilities, Regulatory
Guide 3.11 (Revision 3, November 2008) further elaborates on the factors of safety considered in slope
stability analysis. Importantly, Regulatory Guide 3.11 defines allowable minimum factors of safety for
earthquake and liquefaction analyses as being 1.0. As with previous licensing actions that consider disposal
facility performance against various design criteria, a minimum factor of safety of 1.0 is applied to the Federal
Cell Facility.

Although factors of safety are not required by NRC to be developed for each aspect of the design, a factor of
safety is calculated for each design criteria where supporting analyses provides a value for comparison. This
approach is consistent with EnergySolutions’ other major licensing actions. Thus, only the slope stability
analysis has a regulatory basis for the minimum factor of safety evaluation; other factors of safety provide
information about relative robustness of the design. In each case, cited references should be consulted in order
to understand and evaluate the basis for the reported safety factor.

Cover System
The Federal Cell Facility’s design functions of the cover are to minimize infiltration, reduce exposures, ensure
cover integrity and ensure embankment structural stability. The Federal Cell Facility’s cover system is
designed to:
1) Minimize infiltration by encouraging evapotranspiration from the top slope (by slowing vertical
infiltration to maximize its time of concentration), promoting run-off away from the side slope
(by ensuring the slope and design will maintain positive drainage; that the maximum calculated
design velocity within the side-slopes drainage layer is greater than the predicted maximum
drainage velocity for extreme storm events; and that no accumulation of water occurs on the
surface of the Federal Cell Facility side slope); and protecting the radon barrier from desiccation
(by protecting the layer from frost damage and ensuring that the thickness of cover layers placed
above the radon barrier exceeds the maximum projected depth of frost penetration).
2) Reduce exposures through limiting occupational exposures at the cover surface (by ensuring the
dose rate at cover surface is less than 100 mrem total effective dose equivalent (TEDE) per year).

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Table 3-2: Pertinent Characteristics of the Principle Design Features

Principal Design
Feature
Principal Design Element Pertinent Characteristics References

Liner

Clay Liner under Embankment
2 feet thick
Permeability  1 x 10-6 cm/sec

Compacted to 95% of a standard proctor
Moisture between optimum and optimum +5%
85% fines (<0.075 mm)
10 < plasticity index < 25
30 < liquid limit < 50
Thickness, permeability: GWQDP Condition I.D.4.(c)

Compaction and Moisture in FCF CQA/QC Manual Work Element - Clay Liner Placement; Compaction specification; Fines, plasticity index, and liquid limit in FCF CQA/QC Manual Work Element - Clay Liner Borrow Material, Material specification.

Waste Placement

Waste Placement
Waste below grade and under top slope
Entombed in CLSM

FCF CQA/QC Manual, Attachment II-A, Work Element – Waste
Placement

Backfill

Backfill Placement
Backfill lift average lift thickness  24 inches
Compacted with at least 4 machine passes of a CAT 826 compactor, and
must meet CAES acceptance criteria.
First one foot of material above liner debris-free native soil
Last one foot before radon barrier debris-free

FCF CQA/QC Manual, Attachment II-A, Work Element – Backfill Placement With Compactor
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Principal Design
Feature
Principal Design Element Pertinent Characteristics References

Cover

Clay Radon Barrier

1 foot of 1x10-6 cm/sec clay 1 foot of 5x10-8 cm/sec clay 85% fines (<0.075 mm) 10 < plasticity index < 25 30 < liquid limit < 50
Compacted to 95% of a standard proctor
Moisture between optimum and optimum + 5%

Top Slope: 2-4%
Side Slope: 20%

Thickness, permeability, slope: GWQDP Condition I.D.4.a(5)
Compaction and Moisture in FCF CQA/QC Manual Attachment II-A, Work Element - Radon Barrier Placement, Compaction specification
Fines, plasticity index, and liquid limit in FCF CQA/QC Manual, Attachment II-A, Work Element - Clay Liner Borrow Material, Material specification.

Lower Filter Zone
Type B Filter
6 inches thick on the top slope and 18 inches thick on the side slopes

Permeability  3.5 cm/sec Type B filter and Sacrificial Soil gradations must meet specified ratios Rock Scoring Test > 50
Thickness, permeability: GWQDP Condition I.D.4.a(4)

Gradation criteria on drawing 10014-C04

Rock Scoring Criteria in FCF CQA/QC Manual, Work Element - Filter
Zone, Quality of Rock specification

Sacrificial Soil
12 inches thick

Residual moisture content  3.5% Type B filter and Sacrificial Soil gradations must meet specified ratios

GWQDP Condition I.D.4.a(3)

Gradation criteria on drawing 10014-C04

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Principal Design
Feature
Principal Design Element Pertinent Characteristics References

Cover

Upper Filter Zone Type A Filter

6 inches thick
D100  6 inches
D70  3 inches
D50  1.57 inch (40 mm)
D15  0.85 inch (22 mm)
D10  No. 10 Sieve (2.0 mm)
D5  No. 200 Sieve (~ 0.075 mm)

Rock Scoring Test > 50

Thickness, gradation: GWQDP Condition I.D.4.a(2) Rock Scoring Criteria in FCF CQA/QC Manual, Work Element - Filter Zone, Quality of Rock specification

Erosion Barrier
24 inches thick

Top Cover (Type B riprap):
D100  4.5 inches
D50  1.25 inches
D10  0.75 inch
D5  No. 200 Sieve (~ 0.075 mm)

Side Cover (Type A riprap):
D100  16 inch
D90  12 inch
D50  4.5 inch
D10  2 inch
D5  No. 200 Sieve (~ 0.075 mm)

Rock Scoring Test > 50

Thickness, gradation: GWQDP Condition I.D.4.a(1)

Rock Scoring Criteria in FCF CQA/QC Manual, Work Element - Filter
Zone, Quality of Rock specification

Drainage Systems

Drainage Ditches

4 feet deep
“Irregular quadrilateral” with a 2% bottom slope and 5:1 (H:V) sides slopes
Borrow Material = CL or ML soils
Natural Ground or Imported Borrow Material Compacted
to 95% of a Standard proctor
6 inches of Type A filter material
18 inches of Type A riprap material

Drawing 10014-C03

Borrow Material in FCF CQA/QC Manual,
Attachment II-A, Work Element - Drainage Ditch
Imported Borrow, Material specification

Buffer Zone
Buffer Zone
94 feet from toe of waste to fence <90 feet from toe of waste to compliance well 300 feet from toe of waste to property line 97.7 feet from toe of waste to Vitro property line
Section 5.3 of this report

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Table 3-3: Projected Performance of the Principle Design Features

Principal Design
Feature
Required Function Complementary
Aspects

Design Criteria

Projected Performance

Performance Reference

Safety Factor

Liner

Minimize contact of
waste with standing
water
Minimize contact of
wastes with standing
water during
operations

Permeability
 1 x 10-4 cm/sec

Design permeability = 1 x 10-6 cm/sec

FCF CQA/QC Manual

100
(all conditions)
Minimize contact of wastes with standing
water after closure
Liner Permeability  Cover Permeability
Liner design permeability = 1 x 10-6 cm/sec
Cover design permeability = 5 x 10-8 cm/sec
FCF CQA/QC Manual

20
(all conditions)
Ensure Cover Integrity Mitigate Differential Settlement
Maximum Allowable Distortion in Cover = 0.02
Normal maximum distortion = 0.001 Abnormal maximum distortion = 0.007
Geosyntec “Geotechnical Engineering Evaluation for Federal Cell at the Clive Facility (Appendix M)

AMEC, 2012a,b “EnergySolutions Clive
Facility – Clay Distortion Study.”

Normal = 20 Abnormal = 2.86

Waste Placement
Ensure Cover Integrity Mitigate
Differential
Settlement
Maximum Allowable Distortion
in Cover = 0.02
Maximum differential settlement (distortion) calculated
at 0.01 for bulk waste facility under abnormal
conditions

Geosyntec “Geotechnical Engineering
Evaluation for Federal Cell at the Clive
Facility (Appendix M)

AMEC, 2012a,b “EnergySolutions Clive
Facility – Clay Distortion Study.”

Abnormal: 2.0
Ensure Structural Stability
Maintain Slope
Stability

Static Safety Factor  1.5
Seismic Safety Factor
 1.2

Static Safety Factor  2.1

Seismic Safety Factor = 1.2
Geosyntec “Geotechnical Engineering Evaluation for Federal Cell at the Clive
Facility (Appendix M)

AMEC, 2012a,b “EnergySolutions Clive
Facility – Clay Distortion Study.”

Static  2.5 (exceeds
design criteria of 1.5)
Seismic = 1.2 (meets
design criteria of 1.2)

Backfill
Ensure Cover Integrity Mitigate
Differential
Settlement
Maximum Allowable Distortion
in Cover = 0.02
Maximum differential settlement (distortion) calculated
at 0.01 for bulk waste facility under abnormal
conditions

Geosyntec “Geotechnical Engineering
Evaluation for Federal Cell at the Clive
Facility (Appendix M) AMEC, 2012a,b “EnergySolutions Clive Facility – Clay Distortion Study.”

Abnormal: 2.0
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Principal Design
Feature
Required Function Complementary
Aspects

Design Criteria

Projected Performance

Performance Reference

Safety Factor
Ensure Structural Stability
Maintain Slope Stability

Static Safety Factor  1.5
Seismic Safety Factor
 1.2

Static Safety Factor  2.1

Seismic Safety Factor = 1.2
Geosyntec “Geotechnical Engineering Evaluation for Federal Cell at the Clive Facility (Appendix M)
AMEC, 2012a,b “EnergySolutions Clive
Facility – Clay Distortion Study.”

Static  2.5 (exceeds
design criteria of 1.5)
Seismic = 1.2 (meets
design criteria of 1.2)

Cover

Minimize Infiltration

Minimize Infiltration Average infiltration  0.036 inches/year
(0.090 cm/year) top
slope
0.066 inches/year
(0.168 cm/year) side slope

Infiltration meets performance criteria of transport to
monitoring wells for at least 500 years.

Neptune 2015 (Appendix Q)
Neptune 2021 (Appendix P)

Not applicable
Encourage Runoff
Maintain positive drainage; Maximum design velocity within drainage layer > drainage velocities; Do not allow water
accumulation
Cover design slope = 2.4%. Maximum theoretical velocities: Maximum drainage velocities during PMP:
Neptune 2015 (Appendix Q) Neptune 2021 (Appendix P)
Top Slope: 4.01 Side Slope:
28.75

Prevent
Desiccation

No desiccation cracking in
Radon Barrier Clay
Modeling establishes that the steady-state moisture
content of the clay radon barrier will remain constant
through all conditions throughout the life of the
embankment.

Neptune 2015 (Appendix Q)
Neptune 2021 (Appendix P)

1.91
(all conditions)
Limit
Frost
Penetration
Thickness of
rock/filter/sacrificial soil zones
(3.5 ft)  maximum depth of
frost

Top Slope frost depth = 3.4 feet
Side Slope frost depth = 3.2 feet

Neptune 2015 (Appendix Q)
Neptune 2021 (Appendix P)
Top > 1.03
Sides > 1.09
(abnormal condition)

Minimize Infiltration

Limit
Biointrusion

Biointrusion shall be
discouraged and shall not
cause increased infiltration

Due to increased evapotranspiration, vegetation
decreases infiltration through the cover under both the
normal and the abnormal conditions.

Neptune 2015 (Appendix Q)

Neptune 2021 (Appendix P)

Normal = 2.60

Abnormal = 1.86
Reduce Exposure Surface Dose Rates 100 mrem TEDE 3 mrem/year through cover using abnormal event of
high-gamma source at the top of waste.

Neptune 2015 (Appendix Q)
Neptune 2021 (Appendix P)
100/3 = 33.33
(abnormal condition)

Mitigate
Differential Settlement
Maximum Allowable
Distortion = 0.02
Maximum differential settlement (distortion) calculated
at 0.01 for bulk waste facility under abnormal conditions

Neptune 2015 (Appendix Q) Neptune 2021 (Appendix P)

Abnormal: 2.0
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Principal Design
Feature
Required Function Complementary
Aspects

Design Criteria

Projected Performance

Performance Reference

Safety Factor

Cover

Ensure
Cover
Integrity

Prevent
Internal
Erosion

Water velocity < 5.41 ft/sec
on Radon Barrier Clay
Interstitial Velocities at Radon Barrier/Filter Zone
Interface:

Neptune 2015 (Appendix Q)
Neptune 2021 (Appendix P)
Top ~ 98
Side ~ 45
(all conditions)
Prevent Piping:
D15(filter)/D85(soil)  5 AND
D50(filter)/D50(soil)  25

Prevent Upward Migration of Fines D15(Lower Layer) /
D85(Upper Layer)  4
Incorporated as construction specification on
drawing 10014-C04

Top Slope: Type A Filter D15/Type B riprap D85 =
0.19
Side Slope: Type A Filter D15/Type A riprap D85 =
0.52

Neptune 2015 (Appendix Q)
Neptune 2021 (Appendix P)
Not applicable

Top = 26.3
Side = 9.6
(all conditions)

Material Stability /
External Erosion

1000 year life
Design riprap D50:
Top Slope = 1.25 inches
Side Slopes = 4.5 inches

Neptune 2015 (Appendix Q)
Neptune 2021 (Appendix P)
Top = 1.13
Side = 1.21
(abnormal condition)
Weighted average quality scoring for specific gravity,
absorption, sodium soundness, and L.A. abrasion.
Reject rock with quality scoring < 50

Geosyntec “Geotechnical Engineering
Evaluation for Federal Cell at the Clive
Facility (Appendix M)

Not applicable

Ensure Structural
Stability

Settlement
Long Term Cover Drainage
(No Slope Reversal)
Even if the total potential settlement were focused at
the crest of the embankment, the drop in elevation
from the crest to the shoulder eliminates the potential
for slope reversal.

Geosyntec “Geotechnical Engineering
Evaluation for Federal Cell at the Clive
Facility (Appendix M)

37.7/3.95 = 9.54
Maximum Total Settlement  15% of Embankment Height
(12.6 feet for 84 foot embankment crest)
Primary foundation settlement 1.25 feet
Secondary foundation settlement 2.0 feet
Waste settlement after cover construction 0.7 feet
Total 3.95 feet
Embankment height at crest 84 feet

Geosyntec “Geotechnical Engineering
Evaluation for Federal Cell at the Clive
Facility (Appendix M)

12.3/3.95 = 3.20

Maintain
Slope
Stability

Static Safety Factor  1.5
Seismic Safety Factor  1.2

Static Safety Factor  2.5

Seismic Safety Factor = 1.2

Geosyntec “Geotechnical Engineering
Evaluation for Federal Cell at the Clive
Facility (Appendix M)

Static  2.5 (exceeds
design criteria of 1.5)
Seismic = 1.2 (meets
design criteria of 1.2)

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Principal Design
Feature
Required Function Complementary
Aspects

Design Criteria

Projected Performance

Performance Reference

Safety Factor

Drainage System

Provide Site Drainage

Facilitate flow of
precipitation away
from the embankment

Depth of water < depth of
ditch.
Freeboard  0.5 foot under
normal conditions.
Design ditch height = 4 feet.
Max height of water during normal event = 2.07
feet at downstream limit of ditch system.
Max height of water during abnormal event =
2.47 feet at downstream limit of ditch system. Downstream blockage improves post-closure performance

Appendix K

Downstream:
Normal SF = 1.69
Abnormal SF = 1.62
Minimize Infiltration under flood conditions Flood water shall dissipate faster than water travels through the cover system.
Maximum depth of PMF is approximately one foot across the site. This depth would last about 15 hours. Water travel time through the cover system
is over 89 years.
Appendix K
Abnormal SF > 50,000

Ensure Ditch
Integrity
Prevent Internal
Erosion Size of rock able to handle
stresses related to flow
The type A riprap in the ditches is adequately sized
with a D50 of 4.5 inches.

Appendix K

Normal = 7.65
Abnormal = 6.40

Buffer Zone

Provide Site
Monitoring

NA

Sized adequate for monitoring
and corrective measures
No contaminants will reach the monitoring wells
located approximately 90 feet from the edge of
waste, within the buffer zone boundary
of 94 feet) within 500 years.

Neptune 2015 (Appendix Q)

Not applicable

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1) Ensure cover integrity is preserved (by mitigating differential settlement through ensuring a final
maximum allowable angular distortion criteria for the cover will not be exceeded), preventing
internal erosion (limiting run-off water velocity to less than 3 ft/sec on surface of radon barrier
and to minimize piping by requiring particle size specification for Type B Filter Zone material to
D15 (filter)/D85 (soil) below 5; D50 (filter)/D50 (soil) less than or equal to 25; and
D15(filter)/D85(soil) greater than or equal to 4) and exhibiting material stability to resist external
erosion (rock erosion barrier of the side slope must exhibit internal stability and endure
weathering/external erosion).
2) Ensure Federal Cell Facility stability through promoting settlement without damage (total
settlement must be less than 15 percent of Federal Cell Facility height in order to not compromise
drainage capability of the cover) and maintaining slope stability (Federal Cell Facility will be
constructed to meet a minimum global factor of safety against sliding instability of 1.5 under
static conditions and 1.2 under dynamic).

Waste Placement Configurations
Waste placement within the Federal Cell Facility will be placed and entombed within Controlled Low-
Strength Material (CLSM). The Federal Cell Facility’s design functions of the waste placement configuration
are to minimize contact of waste with standing water during operations, minimize contact of waste with
standing waste following closure and to promoting cover integrity by mitigating differential settlement. The
Federal Cell Facility’s waste placement specifications are designed to:
1) Minimize contact of waste with standing water during operations by demonstrating adequate
drainage (if a 25-year, 24-hour storm event occurs; if a 100-year, 24-hour storm event occurs or
if heavy equipment damages the liner).
2) Minimize contact of wastes with standing water following closure without active maintenance
(liner and cover are constructed to retain their respective design permeability’s over time; and
standing water is minimized in the cell waste done if cover conditions become degraded).
3) Ensure cover integrity is protected by mitigating differential settlement (ensuring all settlement
has completed during operations and by demonstrating negligible settlement if a cell area is
constructed to the proposed height of the cover while an adjacent area is constructed to a height
of less than design height).

Liner
The Federal Cell Facility liner will be designed and constructed in accordance with the specifications in the
design drawings and the FCF CQA/QC Manual. The Federal Cell Facility’s design functions of the liner are
justified through development and application of permeability specifications and limiting radon barrier clay
layer distortion. The Federal Cell Facility’s waste liner specifications are designed to:
1) Limit liner permeability to less than or equal to 1 x 10-4 cm/sec (operational experience at the
facility shows that a liner permeability of 1 x 10-4 cm/sec or less is sufficient to discourage
standing water accumulation to occur within the waste zone. Water ponds or pools on top of the
working surface are immediately removed by active means such as pumping).
2) Ensure the liner permeability is greater than the radon barrier cover clay layer permeability to
prevent water from accumulating on the liner (cover design requires a liner permeability of 1 x
10-6 cm/sec or less and greater than the lowest cover component (radon barrier) permeability of
1 x 10-8 cm/sec).
3) Ensure distortion in radon barrier clay layer does not exceed specification (maximum distortion
of the cover due to settlement under abnormal conditions must be projected to be less than or
equal to the specified Maximum Allowable Distortion Criterion).
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Drainage Systems
The Federal Cell Facility drainage system will be designed and constructed in accordance with the
specifications in the design drawings and the FCF CQA/QC Manual. The post drainage system surrounding
the proposed Federal Cell Facility has been designed to direct facility precipitation flow away from the Federal
Cell Facility, minimize infiltration under flood conditions and ensure ditch integrity is preserved. The Federal
Cell Facility’s drainage specifications are designed to:
1) Facilitate flow of precipitation away from the Federal Cell Facility. The normal condition
includes an analysis of the drainage ditch design with respect to impacts of the 25-year, 24-hour
storm event for the site. The 25-year, 24-hour storm event was identified as representing the
probable worst-case precipitation event that might be encountered during active site operations.
The abnormal condition considers an analysis of the drainage ditch design with respect to impacts
of the 100-year, 24-hour storm event for the site.
2) Minimize infiltration under flood conditions. The results evaluate the depth of water expected
from the abnormal condition PMF for the watershed encompassing the Clive site. That analysis
calculates a depth of the PMF across the site at approximately 1 foot above grade.
EnergySolutions notes that the depth of the 100-year flood is considerably less. Based on the
geometry of water accumulation in the ditch with respect to the Federal Cell Facility the abnormal
flood event would not cause water to accumulate above the toe of the waste in the embankment
and the drainage system is adequately designed to minimize infiltration of water through the
waste under both normal and abnormal conditions.
3) Ensure ditch integrity based on demonstration that the drainage ditch exhibits an ability to resist
disruption under anticipated normal and abnormal surface water flow conditions. The design
criterion that the size of the rock used to line the ditches be able to handle projected peak flows
without movement, was selected based on guidelines contained in NUREG/CR-4620 (see
Appendix L) and NUREG-1623 (NRC 2002).

Buffer Zone
The Federal Cell Facility buffer zone will be designed and constructed in accordance with the specifications
in the design drawings and the FCF CQA/QC Manual. The buffer zone criteria and a buffer zone width is no
less than 94 feet, as included consideration of site monitoring during the 100-year period of institutional
control and sufficient for mitigation in the event of unanticipated migration of radionuclides. The Federal Cell
Facility’s buffer specifications are designed to:
1) Facilitate site-monitoring activities to confirm that no unacceptable releases occur from the
Federal Cell Facility.
2) Facilitate mitigation measures following a hypothetical contaminant release. EnergySolutions
performance assessment shows that no contaminants will reach the compliance groundwater
monitoring wells within 10,000 years. The groundwater monitoring wells are already located
approximately 90 feet from the edge of the waste embankments, within the boundary of the buffer
zone. If contaminants are detected at the monitoring wells within the 10,000-year groundwater
quality discharge permit period, remediation measures could easily be accommodated due to the
extremely slow linear velocity of the groundwater underlying the site area.

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3.3 CONSTRUCTION CONSIDERATIONS

EnergySolutions has designed the facility to meet or exceed the performance standards established by
regulatory authority. Engineering evaluations performed on the design confirm that it meets or exceeds the
design criteria. Engineering evaluations have been performed for the normal, abnormal, and accident (as
appropriate) conditions.

3.3.1 Construction Methods and Features

Construction methods for the proposed Federal Cell Facility will be unchanged from current approved
embankment construction practices at the Clive Facility. These methods are provided in the current FCF
CQA/QC Manual.

Site Preparation
Site preparation requirements for the proposed Federal Cell Facility are those provided in the FCF CQA/QC
Manual. The existing surface of the proposed Federal Cell Facility includes areas excavated to near-
foundation elevation and areas that have been disturbed but remain at or near the original native elevation.

Control and Diversion of Water
Surface water is controlled by a system of run-on and run-off berms. A comprehensive discussion of berm
systems for the proposed Federal Cell Facility is provided in the FCF CQA/QC Manual. The highest
groundwater elevation is more than 13 feet below the top of liner elevation; therefore, groundwater control
will not be necessary.

Construction of Disposal Units
The proposed Federal Cell Facility will be constructed to the existing liner, waste placement, and cover
requirements of the FCF CQA/QC Manual. See also engineering drawing series 14004 in Appendix H.

Concrete and Steel Construction
One aspect of disposal at the proposed Federal Cell Facility is the incorporation of concrete as a component
of disposal facility construction: CLSM used to fill voids in depleted uranium waste placement. CLSM use
will be controlled in accordance with existing requirements applicable to disposal in the proposed Federal
Cell Facility. CLSM requirements are located in Specification 84 through 93 of the FCF CQA/QC Manual.
CLSM is a low-strength void filling material; no reinforcing steel is used.

Backfilling
Waste placement in the proposed Federal Cell Facility will be controlled in accordance with Specifications
56 through 100 of the FCF CQA/QC Manual. No changes to existing approved waste placement methods
are requested.

Closure of Disposal Unit
The cover over the proposed Federal Cell Facility will be constructed in accordance with applicable
specifications of the FCF CQA/QC Manual. See also drawing series 14004 provided in Appendix H.
Timing for different areas of cover construction is ultimately controlled by the open cell time limit provided
at Part I.E.6 of GWQDP UGW450005.

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Accordingly, cover construction will proceed in stages. Considerations that will affect the timing and areas
to be covered in a particular construction project include:
1. Open cell time limit: If an area of waste placement is reaching its deadline, it will be a compliance
requirement to complete cover construction.
2. Maintaining continuous progression of cover: Cover should progress in a contiguous manner. In
other words, “islands” of cover surrounded by active waste placement; or conversely “islands” of
waste placement surrounded by cover should be avoided.
3. Scale of construction projects: A number of factors affect the area of cover that can be physically
completed within a construction season. These include the weather, size and experience of the
construction crew, and when in the construction season the project begins.
4. Time required to complete waste placement to the design elevations, slopes, and grades: Cover
construction cannot begin before placement of the waste column is complete for a lift area, with
adjacent lift areas also at or near the design top of waste.

Accordingly, it is not feasible at this time to provide a more detailed schedule for cover construction over
the proposed Federal Cell Facility; nor is there a regulatory basis to require one. The staged approach to
liner and cover construction has been standard practice at the Clive Disposal Complex since its inception,
and dozens of liner and cover construction projects have been successfully completed. The FCF CQA/QC
Manual provides controls for ensuring sections of liner and radon barrier constructed at different times will
perform seamlessly.

Applicable Codes, Standards and Specifications
Applicable codes and standards are discussed concurrent with establishment of design criteria for each of
the principal design features, as referenced above. In addition, ASTM standards applicable to construction
of the proposed Federal Cell Facility are listed in the FCF CQA/QC Manual and referenced in individual
specifications as appropriate.

Construction Materials and Quality Assurance
Construction materials for the proposed Federal Cell Facility will consist of native soils and rock.
Specifications for each component are provided as discussed above. Quality assurance and quality control
measures required for construction are provided in the FCF CQA/QC Manual.

Site Plans, Engineering Drawings and Construction Specifications
Engineering drawing series 14004 details the proposed Federal Cell Facility and are provided as Appendix H
to this Application. In accordance with Condition I.H.6 of GWQDP UGW450005, EnergySolutions is
required to provide an annual as-built report and drawing set documenting embankment construction.

3.3.2 Construction Equipment

Construction equipment will consist of standard heavy construction and earth-moving equipment.
Equipment used construction of the Federal Cell Facility will be identical to that used for the Class A West
Facility that was previously reviewed and approved by the Director. Equipment used to construct the
proposed Federal Cell Facility will be equal to that used in construction of the Class A West embankment.

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3.4 DESIGN OF AUXILIARY SYSTEMS AND FACILITIES

Auxiliary facilities include buildings and roadways that are designed to support the operational needs of the
multiple Clive Facilities by directly contributing to worker safety, support the construction requirements,
and not adversely affect completed closure measures. The Federal Cell Facility auxiliary systems and
facilities are identical to those for the Class A West Facility that were previously reviewed and approved by
the Director.

3.4.1 Utility Systems

The Federal Cell Facility utility systems will be identical to those for the Class A West Facility that were
previously reviewed and approved by the Director. Due to remoteness, municipal utilities at
EnergySolutions’ Clive facility are limited. Fuel and potable water (culinary water) must be brought in from
off-site locations and stored on-site for usage. Toilet facilities are available at office buildings, outside of
the Restricted Area. No toilet facilities are available inside the Restricted Area. Decontamination showers
are provided in the Mixed Waste Operations Building, and the LLRW Operations Building. Safety showers
are available as detailed in the Contingency Plan, Attachment II-6 of the state-issued Part B Permit.

For personnel working with radioactive materials in the Restricted Area, communication with other workers
is available through two-way radio or cellular phone communication. Radio and cellular range is adequate
to reach all areas of the site at any time. During emergencies on site, personnel contact security via radio or
cell phone; then security issues a general alert to affected personnel.

The site is served with electricity by Rocky Mountain Power. This service includes three phase 440 volt
supply. This service is transformed down to 120-volt single phase service for supply to the administrative
building and for general site conventional electric service.

3.4.2 Auxiliary Facilities

All auxiliary facilities on the site will be removed at decommissioning; accordingly, there will be no adverse
impact on Federal Cell Facility performance due to failure of any of these facilities.

Decontamination Facilities
EnergySolutions has developed an extensive set of decontamination facilities in support of waste disposal
operations. These facilities address decontamination activities necessary for equipment and tools used in
shipping, receiving, managing, and disposal of LLRW. Decontamination procedures have also been
developed to address release of the various shipping containers from the Restricted Area.

At the time of closure, a detailed Decommissioning Plan for the proposed Federal Cell Facility will be
prepared for Director approval, consistent with applicable regulations and requirements. Additional support
facilities are not expected to be required beyond that specified in this Application. It is also assumed that
these support facilities will be decontaminated and decommissioned upon closure. The decontamination
and decommissioning activities include:
a. Decontaminating off-site soils and rail road spur, if necessary, by removing all surface materials
contaminated with LLRW materials such that the contamination in the residual soil or rail road
ballast is ALARA and below the respective cleanup limits. Soil will be disposed of at the Federal
Cell Facility using disposal methods approved in the FCF CQA/QC Manual.
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b. Decontaminating on-site soils within EnergySolutions’ property but excluding the disposal Federal
Cell Facility, by removing all surface soils contaminated with LLRW such that the contamination in
the residual soils is ALARA and below the respective cleanup limits. Soils will be disposed of at
the Federal Cell Facility using disposal methods approved in the FCF CQA/QC Manual.
c. Decontaminating on-site structures such as the rollover facility, geotechnical laboratory, and rail
spur to meet the unconditional release criteria or, remove and place structures the Federal Cell
Facility.
d. Decontaminating the on-site support structures and contents including the change and laboratory
facilities within the administration building to meet the unrestricted release criteria, or remove and
dispose of contents and structures in the Federal Cell Facility.

Clive waste handling facilities are used for both LLRW and 11e.(2) waste management activities. Since
Federal Cell Facility radionuclides represent a subset of the potential contaminants in LLRW, it is
appropriate to place decommissioning waste from these facilities into the Class A West Disposal Facility.

Waste Handling Facilities
The Federal Cell Facility waste handling facilities will be those used for the Class A West Facility that were
previously reviewed and approved by the Director. EnergySolutions’ waste handling procedures and
associated facilities ensure that 11e.(2) or mixed wastes are not co-mingled with LLRW. These facilities
and procedures outline the necessary precautions required to ensure that vehicle, facility and equipment
cleaning occurs prior to hauling or handling LLRW material. They also address signage requirements for
vehicles, facilities and equipment handling LLRW. Procedures have also been created to require unique
site-specific shipment tracking numbers (Bates Numbers) be assigned used for tracking purposes, and
finally accepted for disposal.

Containers approved for storage in accordance with Condition I.E.10 of EnergySolutions’ GWQDP are
visually inspected to ensure that the containers have structural integrity. Drums and barrels of material are
placed on pallets and stacked a maximum of two (2) high. Storage areas are inspected daily in accordance
with the GWQDP. Containers which are found to be deteriorating are re-containerized or over-packed, i.e.,
placed inside another, larger container of assured structural integrity.

Waste Water Facilities
During operation, EnergySolutions’ Clive Disposal Complex is managed to prevent precipitation from
flowing into the proposed Federal Cell Facility. This is accomplished by construction of a run-on berm
around the perimeter of the disposal Federal Cell Facility. Therefore, there are no design features to
promote deposition during operations since there is no runoff which flows into the impoundment area.
EnergySolutions’ proposed Federal Cell Facility is designed to maintain sheet flow for all precipitation that
falls on it. By maintaining sheet flow, the turbulence and velocity of the water are minimized; thus
improving the deposition of sediment and minimizing the erosion of the cover.

The post-closure drainage system surrounding the proposed Federal Cell Facility has been designed to direct
water from precipitation or sheet flow away from the disposal unit. Drainage systems designed for the
Federal Cell Facility are included in Appendix H. Potentially contaminated standing water at proposed
Federal Cell Facility will be managed during the operational life of the facility according to Condition I.E.7
of the GWQDP. Federal Cell Facility areas are managed to remove any intermediate standing water when
necessary.

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EnergySolutions will use mobile pumping trucks and other equipment as needed to access and remove water
from the proposed Federal Cell Facility, which are not designed to free-drain into an evaporation pond or
equipped with permanent pumps. Runoff from other areas of the Clive Disposal Complex are channeled to
the southwest. Short-term bodies of standing water on the surface in other areas of the property will not
affect the performance of the proposed Federal Cell Facility. This water dissipates primarily through
evaporation due to the climatic features of the site rather than percolation; and thus will have no impact on
groundwater horizontal gradients.

3.4.3 Fire Protection System

No additional fire protection will be added to support the Federal Cell Facility (as authority to dispose of
federal waste is only being sought for depleted uranium) than has already been developed to support the
Class A West Facility. Due to the remoteness of the Clive Disposal Complex, the availability of municipal
fire protection is limited. The nearest services of this type are in the Tooele-Grantsville area, approximately
35-50 miles away. Fires in offices or other building areas are controlled using portable fire extinguishers
and/or water as available. If necessary, for control, water may be obtained from nearby wells and/or the
non-contact runoff containment pond located to the southwest of the site. Water trucks used for dust
suppression on site roads would also be available in an emergency to provide water for fire control. There is
at least one water truck on site during operations.

3.4.4 Erosion and Flood Control Systems

During operations, the Federal Cell Facility is protected against offsite flood waters by run-on berms.
Construction requirements for run-on berms are provided in the FCF CQA/QC Manual. Run-on berms
surround the perimeter of the Federal Cell Facility at all times. Once a section of the Facility cover is
completed to the design toe of waste, runoff berms for that section will be replaced by drainage ditches.

Run-on berms surround the perimeter of the Facility at all times. They are constructed of native soils to a
minimum height of three feet above the original ground surface of the site (as determined by original
engineering drawings showing site contours) and have a minimum width of 10 feet at the top. The berms
are compacted to 90 percent of a standard proctor to ensure their integrity and often serve as
inspection/travel roads. Run-on berms are inspected regularly during operation of the facility for degradation
or low spots caused by erosion or frequent traffic. In addition, run-on berms are surveyed and improved
annually to verify compliance with height requirements.

Runoff berms are constructed immediately following approval of clay liner construction for a zone to be
opened for depleted uranium placement. Runoff berms are constructed of native soils directly on the clay
liner to a height of three feet above the liner. Runoff berms have a minimum width of three feet at the top
and are compacted to 90 percent of a standard proctor. As with the run-on berms, runoff berms are inspected
regularly for low spots or degradation. All runoff berms are also surveyed and improved annually.

Once the runoff berms are constructed, depleted uranium material may be placed over the clay liner.
However, a minimum separation of 10 feet is maintained between the toe of the runoff berm and the toe of
waste. This 10-foot separation allows for collection of runoff water from the active Facility and minimizes
potential contact of depleted uranium with standing water.

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SECTION 4. FACILITY OPERATIONS

EnergySolutions’ waste receipt and inspection procedures and waste acceptance criteria are developed in
accordance with the Federal Cell Facility Waste Characterization Plan (included in Appendix O). Using this
Plan, EnergySolutions ensures that arriving federal waste shipments follow applicable requirements and waste
acceptance criteria of the proposed Federal Cell Facility Radioactive Material License. This Plan provides
assurance that federal waste receipt and inspection processes are conducted in accordance with UAC R313-
25-35 and in a manner that assists in meeting the performance objectives of UAC R313-25-20 through UAC
R313-25-23. Additionally, EnergySolutions verifies that the classification and characteristics of waste
entering the site are in accordance with UAC R313-15-1009. A primary focus in these procedures is
EnergySolutions’ ability and objective to protect occupational individuals during Federal Cell Facility
operations (in accordance with UAC R313-25-22). In addition to ensuring conformance with applicable
regulations, EnergySolutions demonstrates ability and commitment to identify and respond to Federal Cell
Facility waste packages requiring remediation. As such, federal waste not in compliance with regulations and
License conditions are prohibited from being managed at the Federal Cell Facility.

4.1 FEDERAL GENERATOR CERTIFICATION

Prior to authorization to ship federal waste, EnergySolutions will document its review and acceptance of a
federal generator’s waste management program. EnergySolutions’ review will include a federal generator’s
procedures for radioactive waste characterization, packaging, and transportation. EnergySolutions will assure
and document that these procedures demonstrate that federal waste sent for management at the Federal Cell
Facility meets the License’s radiological requirements, License’s prohibitions, federal waste acceptance
criteria (including the absence of regulated hazardous waste), and receipt and federal waste disposal
requirements. EnergySolutions’ review will also include a federal generator’s programs and procedures for
radiological characterization, hazardous waste exclusion from Federal Cell Facility packages, free liquid
management, inspections, and void space minimization.

In addition, EnergySolutions’ will review and accept a federal generator’s Quality Assurance/Quality Control
(QA/QC) Program to affirm that it demonstrates a federal generator’s ability to correctly characterize,
package and ship federal radioactive waste that does not exceed the Federal Cell Facility requirements.
Furthermore, the federal generator’s QA/QC Program must also demonstrate that the federal generator
understands the prohibitions of the License. QA/QC Program review will include inspection reports or
summaries for the previous three years from agencies with oversight over the federal generator’s program,
responses and corrective actions to identified deficiencies applicable to waste characterization, packaging,
and/or transportation and the concurrence from the oversight agency that deficiencies have been adequately
addressed.

A federal generator will become certified after the reviews are satisfactorily completed. Any changes in
federal facility programs that affect waste management will require additional review and recertification.

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4.2 FEDERAL WASTE PROFILE RECORD

In order to ship federal waste for management at EnergySolutions’ Federal Cell Facility, a certified federal
generator must provide EnergySolutions with the necessary information for creation of a Federal Waste
Profile, including a description of the federal generator (Agency and Facility Name, mailing address, business
telephone number, a 24-hour emergency telephone number), a description of the federal waste stream, a
determination that the waste does not meet the definition of a hazardous waste as found in R315-261 of Utah
Administrative Code, whether the federal waste contains liquids, a general indication of the federal waste’s
density, any distinguishing color or odor of the federal waste, a statement that characterization samples are
representative of the federal waste, the presence of sorbents and any other additional information necessary
for determining appropriate management of the waste stream (chemical, physical, and general characteristics
and properties, information relating to the federal waste’s generation and history, an indication of the possible
presence of non-hazardous waste constituents such as asbestos, chelating agents, etc. and limits of any non-
hazardous waste constituents, as applicable).

4.3 RECEIPT AND INSPECTION OF FEDERAL WASTE

Receipt and inspection of Federal Facility Waste will be managed similar to that shipments arriving at the
Containerized Waste Facility. Prior to shipment, certified federal generators must inspect the federal waste
to ensure that they meet the incoming shipment inspection requirements of EnergySolutions’ Federal Cell
Facility Waste Characterization Plan. Federal generator sampling of waste must demonstrate that Deferred
Chemical Screening Parameters and Radiological Analytical Parameters meet the appropriate sampling and
analysis requirements of the Federal Cell Facility Waste Characterization Plan. A federal generator will
certify that the appropriate QA/QC objectives have been during their waste sampling. The description made
by the federal generator will include a statement declaring that the federal generator has determined that the
material is within the parameters of the License, that it is depleted uranium, and that the material is not a
hazardous waste as defined by UAC R315-1. The federal generator’s description must include all of the
nuclides, and their general range of activities, that are present in the waste, with supporting laboratory
documentation. These descriptions and information must also include documents and certifications provided
by the federal generator or the federal generator's agents. Each federal shipment must have a certification
statement that it has been properly characterized in order to manifest the shipment as required by UAC R313-
15-1006.

When a federal shipment arrives at EnergySolutions’ Federal Cell Facility, it is not considered to be accepted
to the proposed Federal Cell Facility until the acceptance procedures have been completed and the material
has been accepted for disposal. A transportation vehicle may be physically located on EnergySolutions’ Clive
site and may still not be considered “accepted” for disposal at the proposed Federal Cell Facility.
EnergySolutions does not direct that containers of non-accepted materials be unloaded or that railcars of non-
accepted material be dumped or unloaded. Incoming federal waste shipments are accepted for disposal in
accordance with established procedures.

A completed Uniform Low-Level Radioactive Waste Manifest (Manifest), or equivalent documentation must
be received by EnergySolutions before a federal shipment is accepted for disposal. The manifest will
accompany the shipment and a copy may be received by EnergySolutions prior to the time that the shipment
arrives. The manifest serves several functions, including:
a. Complies with the requirements of a manifest as outlined in UAC R313-15-1006.
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b. Describes container types, volumes, number.
c. Provides weights, activities, and isotopes of the waste.
d. Documents federal generator's certification of packaging, classification, markings, labels, condition
of containers, and compliance with the applicable regulations and conditions of the License.
e. Documents federal generator’s certification that the waste is LLRW.
f. Documents federal generator’s warranty that the information provided in the manifest is true and
correct.
g. Provides a checklist for EnergySolutions for inspection of the incoming material and for possible
violations.
h. Documents EnergySolutions’ acceptance or rejection of the federal shipment for disposal.
i. Alerts receiving staff to probable concentrations and gamma exposure rates to be expected.

Upon receipt, the manifest will be reviewed for completeness. The EnergySolutions reviewer also will ensure
that the form is signed as required by regulation. The freight container will be externally surveyed for gamma
radiation readings with a micro-R meter or equivalent, to assure compliance with DOT regulations. Other
portable instruments are appropriate and may be used to measure the external surface contamination.
Container surveys will be performed in accordance with established procedures. Each incoming freight
container will be smear tested for removable contamination for comparison to the standards of 49 CFR
173.443, in accordance with established procedures.

The Director will be notified of material non-compliances observed during inspection of incoming federal
waste, including the name of the federal generator, name of the nonconforming federal waste stream, date
nonconforming waste was received and a plan and compliance schedule for managing the non-conforming
federal material. In accordance with UAC R313-15-906, EnergySolutions will immediately notify the final
delivery carrier and the Director when:
1. Removable radioactive surface contamination exceeds the limits of R313-15-906; or
2. External radiation levels exceed the limits of UAC R313-25-26.

Upon arrival at the proposed Federal Cell Facility, each incoming shipment will be visually inspected for the
following items in compliance with the shipment inspection requirements of UAC R313-25-34(5) and
established procedures:
1. Ensure accuracy of information provided on the radioactive waste manifest (the container/car ID
numbers, number of cars or containers) and ensure that the material is packaged, marked, labeled,
and placarded according to DOT regulations in 49 CFR.
2. Verify whether there is any evidence of physical damage to the container that might jeopardize its
integrity. This will be accomplished by visually examining the containers for any appearance of
packaging breach or any such potential problem.

Should EnergySolutions discover any discrepancies in the documentation, certification, or shipment, the
discrepancy(s) must be resolved with the generator or shipper prior to acceptance of the material.
EnergySolutions will not unload/dispose of a shipment until such discrepancies have been settled, either
through a generator visit to the disposal site or through written documentation that reflects the necessary
changes in the manifest.

If there are any problems with the integrity of an incoming shipment, the problems will be reported to the
shipper within 24 hours of discovery. EnergySolutions will also provide notification to the Director within
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24 hours of discovery. If a shipment arrives on site that is unacceptable under the conditions of the license,
EnergySolutions will notify the generator and the Director within seven days.

As a result of these steps, EnergySolutions will either accept or reject a shipment for disposal. If a shipment
meets all acceptance criteria except for possible noncompliance with license conditions, it will be placed into
an approved storage area until additional testing can determine its status. In accordance with established
procedures, waste will not be accepted from a Generator when one or more of the following conditions apply:
• The shipping and disposal documents do not agree with the waste profile record;
• The waste exceeds License limits;
• Generator sends a shipment to the Clive facility prior to receiving a notice to transport from
EnergySolutions.

If the federal shipment is rejected for disposal at the proposed Federal Cell Facility, EnergySolutions will
document the rejection in accordance with established procedures and notify the Director. If the shipment is
accepted, the material will be placed in an approved management area or in the Federal Cell Facility.

Shipments that are not found acceptable or approvable will be returned to the Generator or to another licensed
radioactive waste management facility in accordance with established procedures. A shipment which has
been found to be in violation of DOT shipping regulations, but which is otherwise acceptable, will not be
accepted for disposal until:
1. The Director has been notified of the shipment discrepancy; and
2. The generator or generator’s agent has made necessary corrections to bring the shipment into
compliance with DOT regulations, if possible.

Pending such corrective action, the shipment will remain on EnergySolutions property in order to eliminate
the potential risk associated with transporting the waste, but will not be disposed. If such a shipment is in
violation of DOT regulations due to leakage of radioactive materials, it will be placed over an approved
surface in the Restricted Area or placed in another container until the situation is resolved in order to prevent
contamination of the environment.

4.4 WASTE HANDLING AND INTERIM STORAGE

Upon acceptance to the proposed Federal Cell Facility, each federal shipment will be transferred to an
appropriate federal waste container unloading area. To prevent inadvertent cross-contamination of federal
waste types, all waste containers received will be labeled as to federal waste type, federal generator, receipt
date, and the Federal Cell Facility as ultimate disposal location. Containers of depleted uranium wastes will
be taken to the Federal Cell Facility, placed in storage or emptied into the Intermodal Unloading Facility.
Depleted uranium waste management facilities will be visually inspected on a daily basis in accordance with
the BAT Performance Monitoring Plan, Appendix J of GWQDP UGW450005, to ensure proper storage and
management of the waste. Storm water is managed in accordance with Condition I.E.12 of the GWQDP.

All federal wastes received at the proposed Federal Cell Facility will be entered into and tracked with an
electronic waste tracking system (the System). The System tracks waste type, volume, activity, and placement
location within the disposal Federal Cell Facility. The System also contains waste profile information and
provides automated compliance checks of the waste shipment against license limits, sampling frequency, etc.

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4.5 FEDERAL WASTE DISPOSAL OPERATIONS

Depleted uranium will be disposed below grade at EnergySolutions’ Federal Cell Facility in accordance with
site procedures and the FCF CQA/QC Manual. Federal waste placement will be controlled in accordance
with the FCF CQA/QC Manual. Drums and metal containers that are to be disposed in the Federal Cell
Facility will be punched and entombed in Controlled Low-Strength Material (CLSM) in accordance with the
FCF CQA/QC Manual. Whenever the Federal Cell Facility is covered with snow of sufficient depth to impair
the quality of placement of the federal waste, snow will be removed beyond the limits of active construction.
During winter months it may be necessary to stockpile contaminated material. Workers will be protected
during waste emplacement procedures in accordance with the policies of EnergySolutions’ Radiation Safety
Plan and ALARA Plan.

Minimizing void spaces is critical to long-term stability of the Federal Cell Facility. The FCF CQA/QC
Manual provides controls for filling void spaces, including:
a. Depleted uranium waste containers will be distributed throughout a below-grade vault to prevent void
containing materials that minimizes the voids that may occur between two federal waste containers
by distributing the containers throughout each vault.
b. CLSM will be used as fill around depleted uranium containers that maintains minimum flowability
requirements; and QC inspections will be performed to verify the infilling of voids.

Federal waste covering operations will be controlled in accordance with the FCF CQA/QC Manual. The
designed cover has been modeled and found to be sufficiently impermeable to water, structurally sound, and
erosion resistant. The liner will be protected from damage during operations by a minimum one-foot-thick
layer of clean native material (referred to as liner protective cover). The entire Federal Cell embankment
above the disposed depleted uranium to the radon barrier will consist of clean native material (fill). The
construction of both the liner protective cover and clean fill is specified in the FCF CQA/QC Manual.

The design of the proposed Federal Cell Facility enables isolation of the Facility after it has been filled and
covered. Once the Federal Cell Facility is closed it will not be disturbed by other continuing operations at the
site. The final Federal Cell Facility cover integrates long-term water and erosion control methods into the
overall design, thus eliminating the need for active maintenance of the closed Federal Cell Facility.

Once closed, the Federal Cell Facility will be designed to have recognizable features, such as permanent
granite markers placed on the closed Federal Cell Facility. Upon Federal Cell Facility closure, the following
information will be recorded upon disposal unit monuments:
• The total activity of radioactive materials in curies;
• The total amount of source material in kilograms;
• The total amount of special nuclear material in grams;
• The disposal unit Federal Cell Facility name.
• The date the Federal Cell Facility was opened and closed by completing the covering; and,
• The total volume of federal waste in the disposal unit Federal Cell Facility.

Upon completion of the Federal Cell Facility, it will be permanently fenced and posted, leaving a buffer zone
between the toe of waste and the fence. In addition, a 300-foot buffer zone exists between the closest edge of
the Federal Cell Facility and the outer property boundary. Finally, the buffer zone beneath the emplaced waste
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will consist of the two feet-thick clay liner, followed by a minimum depth of 10 feet to the unconfined aquifer
water level.

4.6 OPERATIONAL ENVIRONMENTAL MONITORING AND SURVEILLANCE

EnergySolutions’ Environmental Monitoring Plan is appropriate for operation of its disposal facilities. The
Federal Cell Facility will use the existing approved Environmental Monitoring Plan during operation.
EnergySolutions will use the Environmental Monitoring Plan to:
1. Provide an early warning of a release before it reaches the site boundary;
2. Evaluate the need for mitigative measures;
3. Evaluate health and environmental effects;
4. Estimate dose as required by UAC R313-15-301(1)(a), UAC R313-15-101(4), and UAC R313-25-
19; and
5. Assist in emergency response planning if accidental releases are to occur.

Results of environmental monitoring activities at EnergySolutions’ Federal Cell Facility will be reported to
the Director semiannually. Radioactive airborne particulate samples are collected with low volume air
samplers at perimeter locations of EnergySolutions’ Federal Cell Facility and at background locations. Radon
concentrations in outdoor air are similarly collected. Direct gamma exposure rates using TLDs are measured
at EnergySolutions’ Federal Cell Facility perimeter. Surface soil samples are also collected along
EnergySolutions’ Federal Cell Facility perimeter.

EnergySolutions will perform environmental monitoring in accordance with the Environmental Monitoring
Plan in and around its Federal Cell Facility. These measurements provide data that is used to assess the
potential net radiological impact of the licensed activities on the surrounding area, and form the basis for
demonstrating compliance with the applicable regulations and license conditions. Data are compiled into a
report and submitted semi-annually to the Director. The Environmental Monitoring Plan is designed to detect
and quantify the net radiological effects in areas accessible to members of the general public that occur as a
result of the licensed activities. The data is also used to proactively adjust work practices and site operations
as necessary to sustain continued compliance.

Because of the site’s physical configuration, its remote location, and the nature of the licensed operations, a
postulated individual member of the public near the site boundary must directly inhale airborne radionuclides
to receive a measurable dose via any internal dose pathway. The results from the environmental soil samples
therefore serve mainly as supplemental indicators of the degree to which otherwise undetected effluents may
be accumulating on surfaces outside the restricted areas, while the airborne radioactivity and gamma
monitoring provide the data used as the basis for dose estimates.

Semi-annual environmental monitoring reports have been compiled following this Plan and submitted to the
Division Director, since 1999, to document and evaluate potential long-term trends in environmental
monitoring parameters and assess potential environmental effects and the need for mitigative measures. Based
on this information, the Director has concurred with EnergySolutions’ conclusion that its operational
monitoring plan provides early warning of releases of waste from the disposal site before they leave the site
boundary. Since EnergySolutions has ongoing waste disposal operations at the site, the operational
Environmental Monitoring Program for those activities has been demonstrated as sufficient for future
operational environmental monitoring program for the Federal Cell Facility.
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EnergySolutions’ Federal Cell Facility will operate in accordance with Air Approval Order DAQE-
AN107170021-19, administered by the Utah Division of Air Quality. Prior to the issuance of this Order the
Division of Air Quality performed a review of air quality concerns, including dispersion modeling for
particulate matter. The Utah Division of Air Quality will perform routine audits of EnergySolutions’ Federal
Cell Facility to determine compliance with the Order. The order requires EnergySolutions to maintain
optimum air opacity standards. When these conditions are not met, dust suppression is applied as needed
regardless of the time of year. EnergySolutions demonstrates that with licensing of the Federal Cell Facility,
the monitoring network is situated within (beneath) the existing monitored footprint and buffer zone.
Construction of the Federal Cell Facility will not require removal or construction of current monitoring
locations.

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SECTION 5. FEDERAL CELL FACILITY CLOSURE PLAN AND CONTROL

The Federal Cell Facility will be progressively closed once depleted uranium has been placed below grade
and infilled with controlled low-strength material (CLSM). Interim fill will then be placed and compacted, in
accordance with the specifications proposed for the FCF CQA/QC Manual (see Appendix I). An interim
cover system is first applied and allowed to settle, consolidate, and stabilize for at least one year. Once the
interim cover is demonstrated to be stable within acceptable limits, settlement monitors will be placed, and
the final cover system constructed. Before the Federal Cell Facility is closed, any on-site support facilities
will be decommissioned and demolished. Decommissioning and demolition may involve any of the following
activities: decontamination as necessary prior to release, demolition, disposal on site, release for unrestricted
use and restoration to required final condition. Once all federal decommissioning waste requiring on-site
disposal has been placed in the Federal Cell Facility, the interim cover will be placed and monitored as
required for differential settlement.

The design and construction of the Federal Cell Facility will facilitate disposal site closure and are intended
to eliminate the need for active maintenance after closure. Principal design features and their characteristics
are chosen to support the final condition that the facility and its components achieve stability and limit
subsequent environmental releases. The information contained in this Application and relevant documents
demonstrate that the requirements of UAC R313-25-8(7) will have been met. The site closure plan is
acceptable for use in the Federal Cell Facility.

The Federal Cell Facility is designed to eliminate to the extent practicable the need for active maintenance after
closure. Once the Federal Cell Facility is closed, no further maintenance to the Federal Cell Facility is
anticipated. Closure of the Federal Cell Facility is expected to begin well before overall facility
decommissioning. Prior to closure, EnergySolutions will submit a detailed site Decontamination and
Decommissioning Plan. The Plan will address site closure in the context of current site conditions.

5.1 SITE STABILIZATION

EnergySolutions’ site stabilization plans are appropriate for siting disposal facilities. EnergySolutions’
Federal Cell Facility cover system is designed to minimize infiltration of water into the waste, to direct
precipitation away from disposed waste and to resist degradation caused by surface geologic processes. The
principal design systems are classified into two categories: 1) deep infiltration minimization, surface drainage
and erosion protection, and 2) geotechnical stability.

EnergySolutions has modeled the fate and transport of water through this the proposed Federal Cell Facility
cover system using GoldSim. The GoldSim model simulates processes known to have a significant role in
water flow in landfill covers in arid regions and utilize easily measured environmental characteristics as
input to its calculations, including:
• water flow in variably saturated porous media;
• material hydraulic property functions;
• atmospheric surface boundary conditions including precipitation and evapotranspiration;
• root water uptake; and
• free-drainage boundary conditions.
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5.1.1 Surface Drainage and Erosion Protection

The EnergySolutions facility incorporates three separate design systems in directing the surface drainage away
from the site. These systems are designed to meet the requirements of UAC R313-25-8(7), UAC R313-25-
8, UAC R313-25-24, and UAC R313-25-25, in that they are designed and constructed to prevent erosion and
flooding of the disposal unit without active maintenance.
1. The first system consists of the two elements designed to control precipitation that falls on site. This
system includes the perimeter or run-on berms and the drainage ditches. The berms and ditches are
designed to promote stability and protection during normal, abnormal, and extreme storm and flood
events (defined as Probable Maximum Precipitation and Flood events by UAC R313-25). The
perimeter or run-on berms are constructed to sufficient height to contain water created from the worst
storm event that could occur during the design life of the Federal Cell Facility. They will also prevent
offsite floodwaters created during a worst-case flood event from running onto the Federal Cell
Facility.
2. Likewise, the drainage ditches are constructed to a sufficient depth to promote drainage of storm
waters offsite, preventing the waters from backing up and infiltrating into the Federal Cell Facility.
These ditches intercept runoff from the Federal Cell Facility and direct the flow into the natural
drainage patterns to the southwest of the site. Infiltration and erosion barriers cover the drainage
ditches in order to protect them from erosion forces. The run-on berms and drainage ditches are a
key system for the following principal design features: a) they protect against water infiltration by
directing surface water offsite, b) they promote disposal unit/cover integrity by preventing erosion
due to contact with surface water, c) they minimize contact of the radon barrier or emplaced waste
with standing water, and d) they allow the site to be free draining.
3. Upon completion of waste placement, a clay radon and infiltration barrier will be constructed. The
first layer of this cover is the radon barrier, consisting of no more than 1x10-6 permeability clay. The
radon barrier is covered by the infiltration barrier, consisting of 5x10-8 cm/sec permeability clay. The
infiltration barrier is a key system for the following principal design features: a) it encourages
precipitation evapotranspiration rather than infiltrate into the Federal Cell Facility, b) it maintains
cover integrity by protecting it against severe storm events, and c) it protects against inadvertent
intrusion into the radon barrier and emplaced waste.

Immediately over the filter layers is 18 inches of frost protection zone, which protects the infiltration barriers
from the influences of frost. The frost protection zone also serves as a biointrusion barrier, protecting the
Federal Cell Facility from damage. It consists of bankrun borrow material, with boulders larger than 16 inches
removed, to resist the erosive forces caused by severe storm events. It is a key system for the following
principal design features: a) it provides leak resistance for the Federal Cell Facility by protecting the radon
barrier from cracking due to extreme cold/hot weather conditions, b) it maintains disposal unit and radon
barrier integrity by protecting it against erosion, c) it promotes structural stability, and d) it protects against
inadvertent intrusion.

Above the frost protection zones of the Federal Cell Facility’s top slope are the evaporation (12 inches) and
surface layers (12 inches). These layers consist of loam clays that are designed to trap and absorb infiltrating
precipitation. This entrained moisture can then be removed from the cover system by evapotranspiration.
Gravel is added to the surface layer to provide additional erosion protection (15% by volume).

Above the frost protection zones of the Federal Cell Facility’s side slope is a rock filter zone (12 inches) and
rock armor layer (18 inches). These layers serve as erosion barriers (equivalent to the side slopes of the 11e.(2)
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Byproduct Facility). The erosion barriers will consist of large, fairly well graded rock, of sufficient diameter
to resist the erosive forces caused by severe storm events. The erosion barrier covering the sides and drainage
ditches of the embankment will resistance against flows caused during flood conditions. The erosion barrier
provides principal design features: a) it provides leak resistance for the embankment by protecting the radon
barrier from cracking due to biointrusion and/or extreme cold/hot weather conditions, b) it maintains disposal
unit and radon barrier integrity by protecting it against erosion, c) it promotes structural stability, and d) it
protects against inadvertent intrusion.

5.1.2 Geotechnical Stability

The geotechnical stability of the Federal Cell Facility is contingent upon proper execution of the design bases
and construction procedures for the Federal Cell Facility’s design systems. These systems are also designed
to meet the performance objectives and technical requirements of UAC R313-25. Analyses have been
performed for each of these systems to justify their design and performance. Each of these systems is
completed prior to closure of the Federal Cell Facility and eliminates the need for active maintenance of the
facility after closure.

The clay liner provides a firm construction base for the entire Federal Cell Facility that minimizes contact of
wastes with standing water. It is constructed over a compacted foundation of in situ soils. To ensure long-
term stability of the Federal Cell Facility, the clay liner is compacted to near maximum compaction. It is
constructed with clay materials that will maintain their strength at relatively high moisture contents to ensure
that: it can remain firm under the loads of the emplaced waste; long-term settlement is minimized; and
liquefaction does not occur. In addition, the liner is constructed with a permeability greater than the top foot
of radon barrier, to protect against ponding or “bath-tubbing” that could cause saturation of the bottom of the
Federal Cell Facility.

The structural stability of the Federal Cell Facility is also ensured by proper placement and compaction of
waste materials. As outlined in the FCF CQA/QC Manual, depleted uranium waste placed will be placed
below ground level with CLSM to minimize voids in the Federal Cell Facility. All placed materials will be
tested for density, moisture and thickness to ensure compliance with design bases and construction procedures.
Above depleted uranium waste, soil and soil-like fill materials will be placed in lifts and compacted near
maximum compaction and optimum moisture to protect against long-term settlement. To further protect
against differential settlement, uniformity of the Federal Cell Facility will be developed by terracing or tying
in intersecting sections of the Federal Cell Facility. The Federal Cell Facility will be surveyed annually, and
As-Built drawings produced and submitted to the Director. Settlement will be monitored both before and after
final cover construction in accordance with applicable specifications of the FCF CQA/QC Manual.

Once waste and fill materials have been placed and graded to the design slopes and elevations indicated in the
design drawings, a radon barrier will be constructed. The radon barrier will be constructed with low
permeability clays and will be sloped to promote precipitation runoff. This is also a key element to prevent
against liquefaction as it minimizes water infiltration and saturation of the emplaced fill and depleted uranium
waste. The radon barrier, like the clay liner, will be compacted to almost maximum compaction and near
optimum moisture to protect against long-term settlement. The final cover protects the radon barrier against
cracking due to freezing/thawing, and erosion. The design of the Federal Cell Facility’s side slope of five
horizontal to one vertical was studied in detail to assure that the slopes would not fail due to the expected
maximum seismic event.

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The DOE Technical Approach Document (DOE, 1989), provides data and calculations used in evaluating the
slope stability and liquefaction potential for the Vitro Federal Cell Facility. It was concluded that

“due to the short- and long-term unsaturated Federal Cell Facility conditions, the dense nature of
the granular site soils and a depth to groundwater in excess of 25 feet below existing grade,
liquefaction in the facility or foundation soils will not occur at the site due to [Maximum Considered
Event] acceleration.”

In determination of features and construction specifications that promote long-term stability of the Federal
Cell Facility, EnergySolutions evaluated the effects of erosion, mass wasting, slope failure, foundation
settlement and settlement of wastes and backfill, infiltration through the cover and adjacent soils, and surface
drainage at the disposal site. Collectively, the design of the proposed Federal Cell will be stabile over the long-
term. The design methodologies used for designing the Federal Cell are acceptable for ensuring embankment
stability include thickness and gradation of the riprap layer lining the side slopes and the perimeter drainage
ditch adjacent to the Federal Cell; the thickness of, and particle gradation (filter) requirements for, the Type
B Filter Zone layer used in the Federal Cell cover side-slopes; and the maximum allowable distortion
limitation for the Federal Cell cover.

The Federal Cell Facility cover is designed to be capable of resisting damage by erosion resulting from surface
water flows expected to occur during normal and abnormal precipitation conditions at the site. The D50
specification of the rock riprap material to be used on the side-slope cover demonstrate long-term erosional
stability of the embankment. In response to the Director’s additional erosion questions (Willoughby, 2021),
additional erosion analysis and responses are included as Appendix N. The Federal Cell’s external erosion
protection measures are adequate and that long-term stability of the cell against erosion will be achieved with
reasonable assurance.

EnergySolutions has also developed filter criteria (gradation and permeability criteria) recommended in
NUREG/CR-4620 (see Appendix L), that demonstrate that the proposed Federal Cell side-slope cover will
provide long-term stability with respect to minimizing potential long-term internal erosion within the side-
slope cover layers over the Federal Cell’s s design life under normal and abnormal precipitation conditions at
the site. The side-slope riprap D15/D85 specification meets the criteria as described in NUREG/CR-4620 for
minimization of migration of the filter layer into the riprap. Furthermore, specifications on the sacrificial soil
gradations ensure that migration of material between the sacrificial soil layer and the Type A Filter layer of
the side slope will be minimized. Finally, the Type A Filter Zone specifications will minimize internal erosion
of the underlying sacrificial soil layer of the Federal Cell side slope, regarding the projected interstitial
velocities associated with the rock.

EnergySolutions has also selected characteristics of the riprap materials used to line the Federal Cell perimeter
ditches to resist movement (internal erosion) of the riprap materials under flows projected to occur during
normal and abnormal precipitation events at the site. The drainage design calculations have performed in
accordance with guidelines provided in NUREG/CR-4620. A specification for the minimum average D50 of
the riprap lining the ditches is specified in the FCF CQA/QC Manual to prevent failure under abnormal ditch
flow. The analyses of the effects of erosion on long-term stability of the proposed Federal Cell and perimeter
drainage ditches are adequate and that long-term stability of the Federal Cell will be achieved with reasonable
assurance.

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The area of the proposed Federal Cell, at and immediately surrounding the Clive Facility, is relatively flat
with no landforms or soil conditions present that would be prone to landslides, rock toppling or rock falls,
debris flows, or other forms of mass wasting. Analyses of slope stability of the Federal Cell and of other
disposal embankments at the Clive Facility demonstrate that all slopes will be stable in the long term. Based
on this information, the long-term stability of the proposed Federal Cell will not be impacted by mass wasting.

EnergySolutions has proposed FCF CQA/QC Manual specifications to monitor and measure settlement prior
to cover placement appropriately reduces the risk of uncertainties in estimating settlements. By comparison
with the neighboring Class A West cell, the settlement of the Federal Cell will be far less due to the absence
of disposed dry-active waste and the cell’s smaller design height with identical 5H:1V side-slope inclinations.
The fact that the waste type proposed to be disposed in the Federal Cell and waste placement and compaction
procedures are unchanged compared to the Class A West embankment, indicate that settlements would be
expected to be less in the Federal Cell relative to the Class A West embankment.

5.2 DECONTAMINATION AND DECOMMISSIONING

Decontamination and decommissioning of the Federal Cell Facility will be provided at the time of closure.
EnergySolutions has developed an extensive set of decontamination facilities in support of the Federal Cell
Facility and other waste disposal operations, addressing activities necessary for equipment and tools used in
shipping, receiving, managing, and disposal of depleted uranium. Decontamination procedures have also
been developed to address release of the various shipping containers from the Restricted Area.

In the Decontamination and Decommissioning Plan, it is assumed that additional support facilities will not be
required beyond that specified in this Application. It is also assumed that these support facilities will be
decontaminated and decommissioned upon closure. The decontamination and decommissioning activities
directly related to the Federal Cell Facility include:
a. Decontaminating on-site soils within the Federal Cell Facility property boundary but excluding the
Federal Cell disposal embankment, by removing all surface soils contaminated with depleted uranium
such that the contamination in the residual soils is ALARA and below the respective cleanup limits.
Soils contaminated with depleted uranium will be disposed of at the Federal Cell Facility using
disposal methods approved in the FCF CQA/QC Manual.
b. Decontaminating any on-site support structures and contents dedicated to supporting Federal Cell
Facility construction and operation.

In addition to management of depleted uranium destined for placement in the Federal Cell Facility,
EnergySolutions’ waste handling facilities are also used for both Class A and 11e.(2) waste management
activities. Decommissioning waste from all facilities will be placed into the Class A West embankment.
Additionally, GWQDP UGW450005 requires that sludge and other wastes from eventual decommissioning
of the Evaporation Ponds will also be disposed as LLRW in the Class A West embankment.

5.3 POST-OPERATIONAL ENVIRONMENTAL MONITORING AND SURVEILLANCE

Upon successful licensing of the Federal Cell Facility, EnergySolutions’ has secured financial assurance to
perpetually conduct necessary post-operational monitoring. After decontamination and decommissioning of
the Federal Cell Facility is complete and perpetual stewardship transferred to DOE, post-operational
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monitoring will include annual inspections and minor maintenance of the Federal Cell Facility and areas that
may have been impacted by Federal Cell Facility operations, to ensure that the Federal Cell Facility and other
required elements perform as intended and that there are no adverse impacts to the environment or the public
due to degradation of the Federal Cell Facility. Monitoring and surveillance includes inspection and minor
maintenance of the Federal Cell Facility, fencing, roads, and annual groundwater sampling.

The existing program for monitoring airborne particulate radioactivity (Environmental Monitoring Plan) will
continue with air samplers surrounding the operational area and at least one control station remote from the
area for at least one sampling event after final cleanup and closure. Composite samples from each station will
be analyzed by gamma spectrometry and radiochemical techniques. Air sample collection will continue
during the period required for sample analysis. Measured concentrations will be compared with the dose
standards in accordance with the Environment Monitoring Plan.

Passive environmental radon monitors will be used for one year after closure at all air sampling sites employed
during post-closure airborne particulate monitoring. Samplers will be exchanged at the frequency prescribed
by the Environmental Monitoring Plan. If these samples all demonstrate compliance with the concentration
limit of R313-15-420, Table II for Rn-222 no further radon sampling will be required. For the purpose of this
evaluation the concentration will be the measured concentration, minus the sum of the average baseline
concentration, plus three standard deviations.

TLDs will be used for gamma exposure monitoring at the same locations for one-year post-closure and will
be exchanged at the frequency prescribed by the Environmental Monitoring Plan. If the net annual exposure
rate does not exceed the baseline exposure rate, plus three standard deviations as adjusted for changes in
worldwide fallout levels by 25 mR/year, no further monitoring of gamma exposure rates will be required.

EnergySolutions will make a final collection of soil samples at site closure. No further collections will be
necessary post-closure. If any site boundary samples contain concentrations of radionuclides greater than the
mean plus two standard deviations determined for the background samples an investigation will be made to
determine the possible cause and sampling will continue in that area and at the background sites until the
levels return to background.

The Federal Cell Facility design minimizes the potential for transport of contaminants away from the disposed
waste. The cover reduces the potential for deep infiltration, which is already likely to be minimal in the area
due to the low incident precipitation and high potential evapotranspiration. Seepage is not expected to reach
the groundwater as a result of moisture redistribution within the waste. The impact of this seepage on the
groundwater is expected to be minimal for several reasons:
1. Depleted uranium waste must have equal to or less than 1% free standing liquids upon arrival. Most
shipments have no free-standing liquids.
2. Depleted uranium waste must have no free liquids at disposal.
3. Evaporation at the site exceeds precipitation. Accordingly, even waste with some moisture content
upon receipt is likely to dry out during placement.
4. The existing poor quality of the groundwater makes it difficult to significantly degrade it.
5. The hydraulic head gradient in the groundwater is minimal, limiting the velocity of groundwater
movement away from the site to a maximum of about a foot per year.

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Due to the high and variable concentrations of naturally occurring radionuclides inherent with depleted
uranium, results for analysis of these radionuclides will be subjected to trend analysis to identify any increase
in ground-water concentrations. Manmade radionuclides are not expected to be found in groundwater as a
result of releases from the Federal Cell Facility, any positive findings will be considered as evidence of
possible contamination from other site operations. Any findings of radioactivity above predicted baseline
values will be reason for increased frequency of sampling at the affected well to determine the reason for the
finding and any possible course of action.

Settlement analyses will be performed for the Federal Cell Facility and cover materials to ensure that total and
differential settlements is within an acceptable range for the cover system. The foundation soils will include
both sand and clay that will settle under the weight of the depleted uranium and cover. The sand layers will
be relatively free draining and will settle rapidly.

EnergySolutions’ Long Term Settlement Monitoring Plan (included in the FCF CQA/QC Manual) was
developed in accordance with the recommendations contained in "Guidance for UMTRA Project Surveillance
and Maintenance" (UMTRA-DOE/AL-350124.000). The Plan specifies that geotechnical monitoring
inspections will be performed by EnergySolutions on the completed Federal Cell Facility to evaluate
settlement of the Federal Cell Facility as well as slope stability. Surveys will be performed annually and will
be made to second order standards.

In accordance with the recommendations contained in “Guidance for UMTRA Project Surveillance and
Maintenance” (UMTRA-DOE/AL-350124.000), annual visual inspections of the completed Federal Cell
Facility will be conducted. Among the items to be observed and/or inspected will be:
1. Adjacent off-site features.
2. Access roads, fences, gates, and signs.
a. Needed maintenance.
b. Breach of integrity.
3. Monuments and wells.
a. Disturbances.
b. Replacement or protection.
4. Crest.
a. Observation of erosion, soil color, vegetation, trails.
b. Subsidence, settling, cracks, etc.
c. Deterioration of cover.
5. Slopes.
a. Settlement, sliding.
b. Animal and/or plant intrusion.
c. Vandalism.
6. Periphery.
7. Diversion Channels.
a. Functional.
b. Erosion, sediment.
c. Vegetation, blockage.
8. Photography

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In addition to the scheduled surveillance, unscheduled inspections may be performed following unusual
events (e.g., tornadoes, extremely high winds, extended or high periods of precipitation, floods, earthquakes,
or human events such as vandalism or inadvertent).

The closed Federal Cell Facility will be marked in the same way as a closed uranium mill tailings cell.
Permanent granite markers, similar to those placed at the Vitro embankment, will be placed at the closed
embankment. Markers will consist of unpolished granite of specified minimum dimensions, inscribed with
lettering of specified characteristics. The markers will be set in a bed of reinforced concrete and slightly raised
from the ground/cover surface. Markers will be placed at the entrance to the site and near the center of the
crest of the completed Federal Cell Facility. They will identify the site; the general location of the disposed
materials; dates of construction and closure; volume, mass, or tonnage of disposed material; kilograms of
source material; grams of special nuclear material; and total activity of radioactive material disposed of in the
Federal Cell Facility. Based on this information, the marking for the proposed Federal Cell Facility satisfies
applicable regulatory requirements.

The horizontal buffer zone will be no less than 97.7 feet between the toe of the disposed waste and perimeter
fence. During construction and waste emplacement operations, a 300-foot buffer zone exists between the
closest edge of any embankment and the site boundary. A vertical buffer zone is provided between the bottom
of the embankment and the underlying unconfined aquifer water table. This buffer zone consists of the 2-foot-
thick clay liner and at least 10 ft of undisturbed soils. Although the water surface elevation may rise slightly
over time, it is not anticipated that this elevation will exceed the 10 feet of buffer zone in addition to the 2-
foot clay liner. Based on this information, the plans to maintain a buffer zone satisfy applicable regulatory
requirements. The dimensions and characteristics of the buffer zone are such that monitoring and mitigative
measures can be undertaken, as needed.
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SECTION 6. SAFETY ASSESSMENT

Neptune and Company, Inc., (Neptune) under contract to EnergySolutions developed the Clive depleted
uranium performance assessment model to support decision making related to the proposed disposal of
depleted uranium wastes at a Federal Cell Facility at Clive, Utah, operated by EnergySolutions. Version 1.4
of the Model provides a platform on which to conduct analyses relevant to performance assessment, as
required by the State of Utah in Utah Administrative Code (UAC) R313-25, License Requirements for Land
Disposal of Radioactive Waste. Specifically, a performance assessment is required in UAC R313 25 9,
Technical Analyses. The model may also serve to inform decisions made by the Site operator to gain
maximum utility of the resource that is the Clive Facility.

6.1 RELEASE OF RADIOACTIVITY

The model is written using the GoldSim probabilistic systems analysis software, which is well-suited for the
purpose. In order to provide decision makers with a broad perspective of the behavior and capabilities of the
Facility, the model considers uncertainty in input parameter values. This probabilistic assessment
methodology is encouraged by NRC and DOE in constructing performance assessments and the models that
support them. The model can be run in deterministic mode, where a single set of median model inputs is used,
but running in probabilistic Monte Carlo mode provides greater insight into the model behavior, and especially
into model sensitivity to the distribution of input parameter values. In Monte Carlo mode, a large number of
realizations are executed with values drawn at random from the input parameter distributions using Latin
Hypercube Sampling to ensure equal probability across the range of the input distributions. The distributions
of results, therefore, reflect the uncertainty in these values. To the extent that the model reflects the uncertain
state of knowledge at a site, the model provides insight about how the site works, and what should be expected
if different actions are taken, or different wastes are disposed. In this way, the model aids in decision making,
even in the face of uncertainty.

By examining detailed descriptions of Clive’s physical environment, the engineered disposal facility, the
sources and chemical forms of disposed wastes, potentially affected media, potential release pathways and
exposure routes, and potential receptors were evaluated in the performance assessment. Features and
processes considered that may potentially drive release of radioactivity from the Federal Cell include:
• frost weathering and other meteorological events (e.g., precipitation, atmospheric dispersion,
resuspension);
• resuspension of particulates from surface soils allows redistribution by atmospheric dispersion;
• groundwater transport, inundation, and water table changes;
• chemical sorption and partitioning between phases, aqueous solubility, precipitation, chemical
stability, complexation, changes in water chemistry (redox potential, pH, Eh), fluid interactions,
speciation, interactions with clays and other host materials, and leaching of radionuclides from the
waste form;
• ecological changes and pedogenesis (soil formation);
• Denudation (cap erosion) from pluvial, fluvial or aeolian processes from extreme precipitation,
changes in surface water channels, and weathering;
• Sedimentation/deposition onto the repository;
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• failure of general engineered features, repository design, repository seals, material properties, and
subsidence of the repository;
• degradation and corrosion of waste packages (fractures, fissures, and corrosion - pitting, rusting);
• leaching;
• radon emanation,
• plant uptake;
• translocation by burrowing animals;
• resuspension;
• atmospheric dispersion;
• biotically-induced transport;
• animal ingestion, both as ingestion of fodder and feed by livestock,

6.1.1 Determination of Types, Kinds, and Quantities of Waste

Depleted uranium is the remains of the uranium enrichment process, of which the fissionable uranium isotope
235U is the product. The leftover uranium, depleted in 235U, is predominantly 238U, but may include small
amounts of other U isotopes. In general, depleted uranium will contain very small amounts of decay products
in the uranium, thorium, actinium, and neptunium series of decay chains. Some specific depleted uranium
waste, resulting from introduction of uranium recycled from used nuclear reactor fuel (reactor returns) into
the separations process, contains varying amounts of contaminants, in the form of fission and activation
products. Since some of the depleted uranium evaluated in this performance assessment includes reactor
returns. The national inventory of depleted uranium is on the order of 700 Gg (700,000 Mg, or metric tons) in
mass as uranium hexafluoride (DUF6), and the bulk of it exists in its original storage cylinders, awaiting
conversion to oxide form for disposal. This conversion is being performed at the Portsmouth, Ohio, and
Paducah, Kentucky gaseous diffusion plant sites, using new purpose-built “deconversion” plants to produce
triuranium octoxide( U3O8). A much smaller mass of depleted uranium waste was generated by the Savannah
River Site (SRS) in the form of uranium trioxide (UO3), a powder stored in several thousand 200 L (55 gal)
drums. While the composition of the SRS depleted uranium is reasonably well known, the content of the
gaseous diffusion plant depleted uranium is not well documented. For the purposes of this assessment, it was
assumed that some fraction of the gaseous diffusion plant depleted uranium waste is contaminated to the same
extent as the SRS the depleted uranium waste. Depleted uranium waste from both sources is considered in the
Clive gaseous diffusion plant depleted uranium performance assessment model.

6.1.2 Infiltration

The Clive Facility is a remote and environmentally inhospitable area for human habitation. Human activity at
Clive has historically been very limited, due largely to the lack of potable water, or even water suitable for
irrigation. The site is located on flat ground, with the bottom of the waste disposal cells shallowly excavated
into local lacustrine silts, sands, and clays. A single waste disposal cell, or embankment, is considered in this
model: the Federal Cell Facility housing depleted uranium. The Federal Cell Facility is modeled with an
engineered cover, as per design documents. As designed, the top of the Federal Cell Facility is above grade,
and the cover has layers of a rock-armored cover system similar to that constructed over the closed LARW
and Vitro cells and under construction on the Class A West embankment. In addition to the infiltration
documented with the Model 1.4 Performance Assessment presented in Appendix Q, Neptune has assembled
additional analysis and information in Appendix P in specific response to the Director’s December 2020 Cover
and Infiltration questions (Willougby, 2020).
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The design criteria selected for encouraging surface water run-off drainage from the Federal Cell Facility are
intended to ensure that (lateral) run-off of precipitation that falls on the surface of the completed Federal Cell
will be maintained under expected and possible extreme, future environmental conditions. Encouraging run-
off helps ensure that the design objective of minimizing the volume of precipitation available to infiltrate into
the embankment can be achieved.

The side slopes of the Federal Cell Facility will be graded at a 5H:1V inclination to help promote lateral run-
off from the Federal Cell Facility side slopes while balancing long-term erosion protection requirements for
the Federal Cell Facility in a manner consistent with published NRC recommendations and guidelines.
Additionally, filter permeability criteria have been established for the Type B Filter Zone layer and Sacrificial
Soil Layer in the side slope portions of the Federal Cell Facility cover to help ensure that the Type B Filter
Zone layer will maintain sufficient permeability (hydraulic conductivity) to retain its ability to function as a
lateral drainage layer in the cover.

Water balance modeling of the cover indicates that some water penetrates the cover system, and this
infiltration has the potential to leach radionuclides from the waste and transport them down through the cell
liner and unsaturated zone to the aquifer. In the saturated zone (aquifer), contaminants are transported laterally
to a hypothetical monitoring well located about 90 feet from the edge of the interior of the Federal Cell
Facility. Since the side slopes of the Federal Cell Facility are modeled to not contain depleted uranium waste,
the effective distance to the well from the depleted uranium waste itself is about 240 ft. This environmental
transport pathway is relevant for long-lived and readily leached radionuclides such as 99Tc. Contributions to
groundwater radionuclide concentrations from the proposed depleted uranium waste are calculated for
comparison to groundwater protection limits (GWPLs) during the next 500 years.

The performance assessment simulations resulted in a distribution of average annual infiltration into the waste
zone, and average volumetric water contents for each cover layer. Infiltration flux into the waste zone ranged
from 0.0067 to 0.18 mm/yr, with an average of 0.024 mm/yr, and a log mean of 0.018 mm/yr. Based on its
analysis, EnergySolutions’ design criteria and justification supporting those design criteria and design basis
conditions acceptably demonstrate infiltration rates through the Federal Cell Facility will be minimized and
run-off will be encouraged.

6.1.3 Radionuclide Release - Normal Conditions

In addition to water advective transport, radionuclides are transported via diffusion in both water and air
phases within the cover system, which can provide upward transport pathways. Gaseous radionuclides, such
as 222Rn, partition between air and water. Soluble constituents partition between water and solid porous media.
Coupled with all these process are the activities of biota, with plants transporting contaminants to their above-
ground surface tissues via their roots, and burrowing animals (ants and small mammals) moving bulk
materials upward and downward through burrow excavation and collapse. Biota do not play a major role in
contaminant transport contributing to human doses or uranium hazard according to model results. The model
does not consider the effects of enhanced radon diffusion from a compromised radon barrier, but the model
does include an expanded assessment of the performance of the radon barriers with respect to infiltration.

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Once radionuclides reach the ground surface at the top of the engineered cover via the aforementioned
processes, they are subject to suspension into the atmosphere and dispersion to the surrounding landscape.
Atmospheric transport of gases (222Rn) and contaminants sorbed to suspended particles are modeled. The
results of this model are abstracted into the Clive depleted uranium performance assessment model, and
contributions of airborne radionuclides to dose and uranium toxicity hazard are evaluated.

The impact of sheet and gully erosion in the model is evaluated by the application of results of landscape
evolution models of hill slope erosion loss and channel development conducted for a borrow pit at the site.
The model domain for the borrow pit includes the borrow pit floor, a 10-foot-high pit face at a 1:1 slope and
several hundred meters of ground surface upslope from the pit face at a slope of 0.003 (0.3 percent). The soil
characteristics are consistent with the Unit 4 silty clay, though the landscape evolution model did not consider
the presence of vegetation or rock cover. The surface layer of the top slope of the cover proposed for the
Federal Cell Facility has a slope of about 2 percent. While the cover on the top slope part of the embankment
has a greater slope than that of the undisturbed area upslope from the borrow pit face, the top slope
characteristics act to minimize erosion and channel formation.

A subset of the borrow pit model domain was selected to represent the cover. Gully depths estimated by the
erosion model were extrapolated to 10,000 years and a statistical model was developed that generated values
of the percentage of the cover where gullies ended within a given depth interval. This model provided an
estimate of the volume of embankment cover material removed by gullies. The depositional area of the gully
fan is assumed to be the same as the area of waste exposed in the gullies, using projections onto the horizontal
plane. If these embankment materials include depleted uranium waste components, then this leads to some
contribution to doses and uranium hazards. No associated effects, such as biotic processes, effects on radon
dispersion, or local changes in infiltration are considered within the gullies.

6.1.4 Radionuclide Release – Accidents or Unusual

Potential releases from an unlikely accident from EnergySolutions’ waste management activities are
negligible for their disposal facilities. EnergySolutions’ operations, by their nature, limit the magnitude of
potential accidental releases. Flammable or explosive fuels are not stored in close proximity to the wastes
and the principal flammable material is in the fuel tanks of the individual work vehicles. As authorization to
dispose of dry active waste (DAW) is not being sought for the Federal Cell Facility, a highly unlikely fire in
a loaded haul truck carrying closed containers of depleted uranium and dry active waste (DAW) could result
in some release of airborne particulate depleted uranium in the scenario discussed below. A fire in the Federal
Cell Facility disposal cell after waste is placed and entombed with CLSM is unlikely. The possible release
scenarios previously evaluated, all of low probability, but ranged in order of decreasing magnitude (based on
probability of happening times impact), are:
1. On-site truck turnover or collision;
2. Train derailment;
3. On-site truck fire;
4. Flooding;
5. Tornado; and
6. Severe wind.

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The following discussion estimates consequences of the above scenarios.

On-site truck turnover or collision:
Any accident involving a truck turnover would be comparable to the same truck releasing bulk depleted
uranium from breached containers in the Federal Cell. For an on-site truck accident immediate assistance is
available to wet down, cover, or clean up any spilled wastes; as well as to provide any necessary respiratory
protection. Assuming a moisture content of five percent, wind speed of 40 mph and spillage of the entire load,
the total release of depleted uranium waste material is calculated at 265 g. Most of the material from the truck
would be deposited on the ground in the immediate vicinity of the truck.

An on-site truck turnover or collision can be compared to normal rail car rollover emissions prior to
construction of the rollover enclosure. The rail car rollover is equivalently close to the site boundary as the
haul roads. Therefore, doses for a hypothetical train derailment are conservative in estimating dose from a
truck turnover or collision. As input to the calculations, it was calculated that the total amount of resuspension
annually from rail car rollover operations is about 65.6 kg with winds blowing toward the nearest site
boundary monitoring station (Station A-14) 5.7 percent of the time. The scenario assumes an average uranium
concentration in rollover waste of 17,000 pCi/g; 820 pCi/g of Ra-226 in equilibrium with its daughter
products; 59 pCi/g of Th-230; and 27 pCi/g of Th-232 in equilibrium with its daughter products. The resultant
committed effective dose equivalent (from annual rail car rollover operations) to a hypothetical receptor at
Station A-14 was calculated to be 0.73 mrem. An enclosure has since been constructed over the rollover to
further minimize fugitive dust emissions.

For the truck accident case, a uranium concentration of 270,000 pCi/g with the other nuclides proportionately
the same as presented above was assumed, with winds blowing toward a receptor at the distance of the fence
line for the duration of the accident. Under those conditions, the committed effective dose equivalent at that
location, scaled from the modeled situation, would be 0.18 mrem. The individual organs receiving the
maximum dose, for the mix of nuclides assumed at the rollover, would be either the lung or bone surface
either of which would receive doses of no more than 10 times the committed effective dose, or less than two
mrem. For on-site workers there would be a very short exposure time since there would be no reason to stand
downwind and respiratory protection would be readily available.

From NUREG-0706 the probability of a truck accident is in the range of 1.0 to 1.6x10-6/km (NRC, 1980a).
There are two kinds of truck movements to be considered at the Clive site. These are arriving waste shipments
and haul trucks moving material from the rollover or storage to the disposal cell. Assuming that there are 3
incoming trucks per day and 50 loaded trucks per day from the rollover or storage to the trench and assuming
that the on-site distance traveled by any loaded truck is one kilometer, the probability of an accident in any
one year is:

1.3 x 10-6/km x 53 loads/day x 260 days/year x 1 km/load
= 1.8 x 10-2 or about 1.8%.

Most of the depleted uranium material from the breached containers on the truck would be deposited on the
ground in the immediate vicinity of the truck. Based on NUREG-0706, for a wind speed of 10 mph, about
0.1% of the material would become airborne immediately (for dry material). Obviously, if the material is
moist, the release fraction would be less. For a 20-ton (40,000 pound) truck, about 40 pounds or less might
become airborne. This compares with about 24 pounds of dust that becomes airborne daily per hectare of a
mill waste pile surface. If the spill is not cleaned up or dust controlled rapidly, the release fraction over a 24-
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hour period might increase to as much as 0.9 percent or 360 pounds. This is highly unlikely because of the
presence on-site of crews and equipment that are there for the express purpose of managing bulk wastes.
Because of moisture differences and differences in waste composition from the model mill assumptions, it
would expect to have lower release fractions in an actual accident situation.

For on-site workers, there would be a very short exposure time since there would be no reason to stand
downwind for 24 hours (or even one hour). For this scenario, it is assumed that an accident occurs involving
the spill of a breached load of depleted uranium containers with concentrations of 15,000 pCi/g, a period of
three hours for cleanup with no use of respiratory protection, an airborne concentration of 1 mg/m3, and a
respiratory rate of 1.2 m3/hr a total of 54 pCi of each nuclide would be inhaled. Comparing these to the
Allowable Limit of Intake (ALIs) from Appendix B of 10 CFR 20.1.001 - 4201, the sum of fractions is 0.022.
The external gamma dose, using the relationship of 3.1 mrem/h/pCi/g for Ra-226 and doubling for the
contribution from Ra-228, would be less than 140 mrem. Such a dose added to the projected maximum TEDE
of 1,032 mrem/yr would still be well within the permissible annual exposures for radiation workers. In actual
fact, no workers would be present under such conditions without respiratory protection and would not be
standing on the spilled waste for more than a few minutes.

Radiation doses to non-radiation workers would be limited by promptly evacuating such persons from the
vicinity of such an accident. Non-radiation workers who might respond as part of an emergency team would
be monitored and would spend a limited amount of time in proximity to the waste. It is believed that no
person who is not a radiation worker would remain in the vicinity for more than 30 minutes. Therefore,
comparing inhalation exposures and external doses to those for radiation workers, it is obvious that no non-
radiation worker would receive in excess of 100 mrem

6.1.5 Radionuclide Transfer to Human Access Location

Given the remote and inhospitable environment of Clive, it is not reasonable to assume that the traditional
residential receptors considered in other performance assessments are present. Traditionally, and based on
DOE (DOE M 435.1) and NRC guidance (10 CFR 61), members of the public are evaluated outside the fence
line or boundary of the disposal facility, and inadvertent intruders are assumed to access the disposal facility
and the disposed waste directly, in activities such as well drilling or house construction. For disposal facilities
in the arid west, these types of strictly defined default scenarios do not adequately describe likely human
activities. Their inclusion in a performance assessment for a site in the arid west, such as Clive, will usually
result in unrealistic underestimation of the performance of a disposal system, which does not lend itself to
effective decision making for the Nation’s needs to dispose of radioactive waste.

At Clive, there is no potable water resource to drill for, and historical evidence suggests there is little likelihood
that anyone would construct a residence on or near the site. There are present day activities in the vicinity,
however, that might result in receptor exposures if these activities are projected into the future when the
facility is closed and after institutional control is lost. Large ranches operate in the area, so ranch hands work
in the vicinity. Pronghorn antelope are found in the region, and hunters will follow them. Both of these
activities are facilitated by the use of off-highway vehicles (OHVs). OHV enthusiasts also ride recreationally
for sport in areas near the Federal Cell Facility.

In addition to these receptors, there are specific points of exposure within the vicinity of the Clive Facility
where individuals might be exposed. About 8 miles to the west, OHV enthusiasts use the Knolls Recreation
Area. Interstate 80 and a railroad are located to the north, with an associated rest area on the highway. Closer
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to the Clive Facility, the Utah Test and Training Range access road is used on occasion. The Model hence
evaluates dose and uranium hazard to these site-specific receptors.

These doses and the supporting contaminant transport modeling that provides the dose model with
radionuclide concentrations in exposure media are evaluated for 10,000 years, in accordance with UAC R313-
25-9(5)(a). After that time, the modeling focus turns to long-term, or “deep time” scenarios. Peak activity of
the waste occurs when the progeny of the principal parent, 238U (with a half-life that is approximately the age
of the earth— over 4 billion years), reach secular equilibrium. This occurs at roughly 2.1 million years (My)
from the time of isotopic separation, and the model evaluates the potential future of the site in this context. At
2.1 (My) the activity of the last modeled member of the chain, 210Pb, is equal to that of 238U, within less than
one half of one percent. While the calculation could be carried out further in time to achieve a greater degree
of accuracy, there is no benefit in doing so for decision-making purposes. This time frame borders on geologic,
and needs to consider the likely possibility of future deep lakes in the Bonneville Basin. The return of such
lakes is understood to be inevitable, and the Clive Facility, as constructed, will not survive in its current
configuration. Many lakes, of intermediate and deep size, are expected to occur in the 2.1 My time frame,
following the climate cycle periodicity of about 100,000 years, based on current scientific understanding of
paleoclimatology. In these timeframes, it is also important to consider processes such as eolian (i.e., wind-
borne) deposition, which can be seen in geologic formations in the Clive area. Deposition builds up the ground
surface over time, such that the ground surface when a lake returns is 2 – 3 m higher than the current ground
surface.

As each lake returns, estimates are made of the radionuclide concentrations in the lake and in the sediments
surrounding and subsuming the site. Because the exact behavior of lake intrusion and site destruction is
speculative, the model makes several conservative assumptions. Upward movement of radionuclides, via
diffusion and biota, is assumed to occur until the first lake returns. At that point in time, the radionuclides that
are above ground are assumed to comingle with sediments, dispersed over an uncertain area approximately
the size of an intermediate lake. In the presence of a lake, the radionuclides migrate into the water, in
accordance with their aqueous solubility. For U3O8, which is considered to be the only form of uranium oxide
remaining by the time the first lake arrives (since UO3 moves out of the waste first and what is left will become
more like U3O8 or UO2 in the presence of a wetter climate), the solubility of U is very low. As each lake
recedes, radionuclides are co-deposited with the sediment, only to be dissolved into the water again with the
next lake. This is a very conservative approach, especially for the lake concentrations, since in reality each
blanket of sediment could entrap constituents, and the concentrations in water and sediment over time should
decrease consequently. The analysis, therefore, focuses on the arrival of the first lake, which will be the most
destructive in terms of sudden release of radionuclides, and would provide the least amount of sediment to
encapsulate them. Subsequent lakes would see progressively less radionuclide activity as the site is slowly
buried under ever-deeper lacustrine deposits through the eons.

The utility of such a calculation, aside from responding to the UAC requirement, is to inform decisions
regarding the placement of wastes in the embankment. With downward pathways influencing groundwater
concentrations, and upward pathways influencing dose and uranium hazard, a balance must be achieved in
the placement of different kinds of waste. No depleted uranium waste has been modeled under the side slopes.
In version 1.4 of the Model, the erosion modeling was conducted under the assumption that gullies will occur
on the embankment. Additionally, the only depleted uranium waste configuration presently evaluated is for
disposal of these wastes in layers of the embankment below the current grade of surrounding soil. Dose results
for each type of potential receptor are presented in Table 6-1.

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Table 6-1

Peak TEDE: Statistical Summary

peak TEDE (mrem in a year) within 10,000 years
receptor mean median
(50th %ile) 95th %ile
ranch worker 6.2E-2 5.1E-2 1.5E-1
Hunter 4.5E-3 3.8E-3 9.9E-3
OHV enthusiast 8.4E-3 7.5E-3 1.8E-2
Results are based on 10,000 realizations of the Model.
TEDE: Total effective dose equivalent

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There is a question of which statistic from the many Model realizations is most appropriate for comparison to
performance criteria. The statistics in Table 6-1 represent summaries of the mean, median, and 95th percentiles
of the dose at 10,000 years for the 10,000 realizations. The peak mean dose is sometimes of interest for
comparison with performance objectives, and in this model, the peak mean dose occurs at or near 10 thousand
years (ky). In effect, 10 ky is the worst-case year in terms of dose. Under these circumstances, the 95th
percentile is analogous to the 95% upper confidence interval of the mean at 10 ky that is commonly used to
represent reasonable maximum exposure in CERCLA risk assessments.

For those radionuclides for which GWPLs exist, results are shown in Table 6-2. For all such radionuclides
compliance with the GWPLs is clearly demonstrated. The mean values for 99Tc and 129I are much greater than
the median, indicating that the distributions of these concentrations have a very strong degree of skewness.

Sensitivity analyses on the Model results indicate that receptor doses are dominated by radon inhalation,
whereas the downward migration pathway is dominated by groundwater concentrations of 99Tc. A trade-off
is indicated in terms of depleted uranium waste placement. The lower the depleted uranium waste is placed,
particularly the 99Tc-contaminated depleted uranium waste, the greater the groundwater concentrations of 99Tc, but the lower the doses due to increases in the diffusion path length to the ground surface. Conversely
the higher the depleted uranium waste is placed in the embankment, the lower the 99Tc groundwater
concentrations, and the greater the dose to receptors. Placement of depleted uranium waste below surface
grade in the Federal Cell Facility satisfies both dose and groundwater performance objectives. Sensitivity
analyses on the groundwater concentration of 99Tc indicate that these results are primarily sensitive to the α
parameter of van Genuchten equation and secondarily to the molecular diffusion coefficient.

In addition to the dose assessment for hypothetical individuals described above, the structure of the model
allows the cumulative population dose to be tracked. For the objective of keeping doses as low as reasonably
achievable (ALARA), estimated dose to the entire population of ranch workers, hunters, and OHV enthusiasts
over the 10,000-year simulation was evaluated. These cumulative population doses are shown in Table 6-3.

The population doses presented in Table 6-3 may be evaluated relative to doses received from natural
background radiation. NRC has suggested value of a statistical life (VSL)-based cost of $5,100 per person
rem. Using such a cost, the total ALARA cost over 10 ky (for example, $61,200 using the mean estimate of
total population dose, or $6 per year.) is very small compared to the cost of waste operations and disposal.
Average annual individual background dose related to natural background radiation in the United States is
approximately 310 mrem, which for the total cumulative receptor population of about 3,200,000 individuals
in 10,000 years is approximately 992,000 rem—a level that is many orders of magnitude greater than the
population doses shown in Table 6-3. ALARA is intended to support evaluation of options to reduce doses in
a cost-effective manner. Given the results of this ALARA analysis, it is not clear that further reduction in
dose is necessary.

The final set of analyses conducted with the Model are the deep-time analyses. As described above, the deep-
time model is very conservative in many ways with respect to dispersal of the depleted uranium waste
material. Deep lakes that obliterate the Federal Cell Facility are assumed to return periodically. Simplified
processes are used to keep the deep time model from becoming overly complicated for the amount of
uncertainty in both parameters and processes.

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Table 6-2

Peak Groundwater Activity Concentrations within 500 years, Compared to GWPLs

peak activity concentration within 500 years (pCi/L)
radionuclide GWPL1
(pCi/L) mean median
(50th %ile) 95th %ile
90Sr 42 0 0 0
99Tc 3790 26 4.3E-2 150
129I 21 1.7E-2 4.3E-11 1.1E-1
230Th 83 2.2E-28 0 0
232Th 92 1.4E-34 0 0
237Np 7 1.5E-19 0 3.7E-27
233U 26 5.6E-24 0 3.9E-28
234U 26 2.1E-23 0 2.2E-28
235U 27 1.6E-24 0 2.0E-29
236U 27 2.7E-24 0 3.3E-29
238U 26 1.5E-22 0 1.8E-27
1GWPLs are from UWQB Table 1A.
Results are based on 10,000 realizations of the Model.

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Table 6-3

Cumulative Population TEDE: Statistical Summary

population TEDE (person-rem) within 10,000 years
receptor type mean median
(50th %ile) 95th %ile
total population 12 11 26
ranch worker 2.8 2.5 5.7
Hunter 1.5 1.3 3.0
OHV enthusiast 8.3 7.4 17
Results are based on 10,000 realizations of the Model.
TEDE: Total effective dose equivalent

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Concentrations of 238U in lake water and sediment at the time of peak lake occurrence (90,000 years) are
presented in Tables 6-4 and 6-5. These results simply show the concentrations that might occur in response to
obliteration of the site by wave action during return of a lake to the elevation of Clive and subsequent dispersal
of the waste in a relatively confined system. The concentrations presented would continue to decrease with
each lake and climate cycle as more sediment is deposited with each lake event, and each lake event allows
radionuclides to be dispersed ever further afield.

The deep-time model disperses the above-ground radionuclides that have migrated upward from the depleted
uranium waste prior to the occurrence of the first returning lake. The current disposal scenario has the entire
depleted uranium waste disposed below grade. The model assumes that no material below grade is dispersed.
Based on these results, it is reasonable to expect that the deep-time concentrations could be close to or possibly
less than background concentrations for uranium in soil of about 1 pCi/g and approximately 2 pCi/L for
background uranium concentrations in the Great Salt Lake. In addition, the return of the first lake is
considered likely to be several tens of thousands of years, or even a few hundreds of thousands of years, into
the future, at which point eolian deposition will result in sedimentation deposits around the site of several
meters. This deposition will both stabilize the site and make it even less likely that any below-grade material
will be dispersed.

The quantitative results for all Model analyses are summarized in Table 6-6. Doses to all receptors are
always less than the 500 mrem (IHI) and 25 mrem (MOP) annual performance criteria. Groundwater
concentrations are always less than the GWPLs. Even in the case of 99Tc, the peak median, mean and 95%
groundwater concentrations are well below the GWPL of 3,790 pCi/L.

6.1.6 Assessment of Impacts and Regulatory Compliance

The State of Utah follows federal guidance by categorizing receptors in a performance Assessment in UAC
R313-25-9 and 10 CFR 61.41 according to the labels “member of the public” (MOP) and “inadvertent human
intruder” (IHI). NRC offers two definitions of inadvertent intruders in 10 CFR 61:
• § 61.2 Definitions. Inadvertent intruder means a person who might occupy the disposal site after
closure and engage in normal activities, such as agriculture, dwelling construction, or other pursuits
in which the person might be unknowingly exposed to radiation from the waste.
• § 61.42 Protection of individuals from inadvertent intrusion. Design, operation, and closure of the
land disposal facility must ensure protection of any individual inadvertently intruding into the
disposal site and occupying the site or contacting the waste at any time after active institutional
controls over the disposal site are removed.

NRC offers one reference to an MOP in the context of the general population:
• § 61.41 Protection of the general population from releases of radioactivity. Concentrations of
radioactive material which may be released to the general environment in ground water, surface
water, air, soil, plants, or animals must not result in an annual dose exceeding an equivalent of 25
millirems [0.25 mSv] to the whole body, 75 millirems [0.75 mSv] to the thyroid, and 25 millirems
[0.25 mSv] to any other organ of any member of the public. Reasonable effort should be made to
maintain releases of radioactivity in effluents to the general environment as low as is reasonably
achievable.

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Table 6-4

Statistical Summary of Lake Water Concentrations at Peak Lake Occurrence

Lake concentrations (pCi/L) at 90,000 years
radionuclide mean median
(50th %ile) 95th %ile
uranium-238 2.1E-5 0.018 0.11
radium-226 0.15 0.54 2.4
thorium-230 0.15 0.55 2.4
Results are based on 1,000 simulations of the Model

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Table 6-5

Statistical Summary of Sediment Concentrations at Peak Lake Occurrence

Sediment concentrations (pCi/g) at 90,000 years
radionuclide mean median
(50th %ile) 95th %ile
uranium-238 1.8E-3 2.0E-2 9.5E-2
radium-226 1.2E-3 5.0E-3 2.2E-2
thorium-230 1.2E-3 5.0E-3 2.3E-2
Results are based on 1,000 simulations of the Model

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Table 6-6

Quantitative Assessment Results for Model Analyses

performance objective meets performance
objective?
Dose to MOP below regulatory threshold of 25 mrem in a year Yes
Dose to IHI below regulatory threshold of 500 mrem in a year Yes
Groundwater maximum concentration of 99Tc in 500 years < 3790 pCi/L Yes
ALARA average total population cost equivalent over 10,000 years: $61,200

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DOE definitions in DOE M 435.1 (the Manual accompanying DOE Order 435.1) are much more specific.
However, the applicable federal agency that regulates disposal of low-level radioactive waste at the Clive
Facility is NRC. For the Clive Facility and the Model, based on the NRC definitions, the ranch hand, hunter
and OHV enthusiast are expected to engage in activities both on and off the site. These receptors fit the NRC
definition of inadvertent intrusion because they are assumed to occupy the site, albeit for limited periods of
time, and also because the use of OHVs on the cover may precipitate the creation of gullies. The receptors
that are located at specific offsite locations, instead, fit the NRC definition of MOP. The Model presents
predicted doses to the receptors identified above, under the conditions and assumptions that provide the basis
for the Model. These doses are presented as the results of the Model. A comparison of doses to both MOP
and IHI performance objectives is also presented.

The Model addresses radiation doses to human receptors who might come in contact with radionuclides
released from the disposal facility into the environment subsequent to facility closure. In accordance with
UAC R313-25-9, doses are calculated within a 10,000-year compliance period. The doses are compared to a
performance criterion of 25 mrem in a year for a MOP, and 500 mrem in a year for an inadvertent intruder.
The dose assessment component of the model, like the transport modeling components described above,
supports probabilistic Monte Carlo analysis. Spatiotemporal scaling is a critical component of the Model
development. For example, the Model differentiates the impact of short-term variability in exposure
parameters (values applicable over a few years or decades, such as individual physiological and behavioral
parameters) from the longer-term variability of transport parameters (values applied over the full 10,000-year
performance period, such as hydraulic and geochemical parameters). This distinction facilitates assessment
of uncertainties that relate to physical processes from uncertainties relating to inter-individual differences in
potential future receptors.

The information contained in this Application demonstrates that the requirements of UAC Subsection R313-
25-9(1) have been met. Each of the major media pathways of this requirement is examined. Both normal
operating conditions and accident scenarios are evaluated. The results overall demonstrate that the below-
grade disposal configuration can be used to dispose of the quantities of depleted uranium waste included in
the Model in a manner adequately protective of human health and the environment. Necessary protection is
provided to members of the general public.

6.2 INTRUDER PROTECTION

Utah regulations require special provision to protect inadvertent intruders from disposed LLRW only for Class
C LLRW. Since only Class A waste will be disposed of in the proposed Federal Cell, no special intruder
barrier, as defined by Utah regulations, is required. In a more general sense, however, intruder protection is
required by the performance objective stated in URCR R313-25-20. EnergySolutions’ satisfies intruder
protection requirements by remoteness of the facility from large population centers, lack of resources at the
site, provision of a cover system to separate the waste from the atmosphere, use of CLSM, erection and
maintenance of physical access barriers at the closed facility, maintenance of access controls at the closed
facility and placement of monuments denoting the locations of embankment boundaries.

The NRC evaluated the long-term hazards of LLRW disposal in its draft and final environmental impact
statements of the regulation of LLRW disposal (NUREG/CR-4370). Radiation hazards associated with Class
A waste are such that, should intrusion into disposed waste occur following the 100-year institutional control
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period, doses were projected to be within acceptable limits. Since EnergySolutions’ proposes only to dispose
of Class A LLRW, it implicitly complies with this regulatory requirement.

Compliance with the performance objectives for the inadvertent intruder dose of 500 mrem in a year and for
the MOP of 25 mrem in a year is clearly established for all three types of potential future receptors. This
indicates that for the disposal configuration where depleted uranium wastes are placed below grade, doses are
expected to remain well below applicable dose thresholds even if gullies are assumed to occur on the
embankment. None of the 95th percentile dose estimates for these receptors exceeds 1 mrem in a year, and all
of the peak mean dose estimates are at or below 0.1 mrem in a year.

6.3 LONG-TERM STABILITY

As part of the performance assessment, EnergySolutions evaluated the long-term stability of the proposed
Federal Cell, including analyses of the effects of natural processes that include erosion, mass wasting, slope
failure, foundation settlement and settlement of wastes and backfill, infiltration through the cover and adjacent
soils, and surface drainage at the disposal site. The analyses provide reasonable assurance that there will not
be a need for ongoing active maintenance of the Federal Cell and associated drainage features following its
final closure. Collectively, the analyses completed for the proposed Federal Cell demonstrate that long-term
stability of the Federal Cell will be achieved with reasonable assurance. The design methodologies used for
designing the Federal Cell are acceptable for ensuring embankment stability include thickness and gradation
of the riprap layer lining the side slopes and the perimeter drainage ditch adjacent to the Federal Cell; the
thickness of, and particle gradation (filter) requirements for, the Type B Filter Zone layer used in the Federal
Cell cover side-slopes; and the maximum allowable distortion limitation for the Federal Cell cover.

6.3.1 Surface Drainage and Erosion Protection

EnergySolutions has also demonstrated that the proposed Federal Cell cover has been designed to provide
long-term stability of the embankment and to ensure that the cover will be capable of resisting damage by
erosion resulting from surface water flows expected to occur during normal and abnormal precipitation
conditions at the site. For evaluating potential erosion in the cover, a 100-year, 24-hour storm event for the
normal precipitation condition and a 1-hr value of 6.1 inches of rain, as the abnormal precipitation condition
was evaluated. Erosion calculations were performed in accordance with guidelines provided in NUREG-1623.
These rock side-slope cover calculations demonstrate that the D50‟s of the rock riprap materials, proposed
for use on the side-slopes exceed the minimum D50 rock sizes required for ensuring long-term erosional
stability of the embankment. Additionally, the FCF CQA/QC Manual provided in Appendix I requires that
rock riprap materials used in the Federal Cell Facility side-slope cover have a weighted average aggregate
rock score of 50 or more, in accordance with NRC NUREG-1623 guidelines. In response to the Director’s
additional erosion questions (Willoughby, 2021), additional erosion analysis and responses are included as
Appendix N. The Federal Cell’s external erosion protection measures are adequate and that long-term stability
of the cell against erosion will be achieved with reasonable assurance.

6.3.2 Stability of Slopes

EnergySolutions has also developed filter criteria (gradation and permeability criteria) recommended in
NUREG/CR-4620 (see Appendix L), NUREG-1623 that demonstrate that the proposed Federal Cell side-
slope cover has been designed to provide long-term stability with respect to minimizing potential long-term
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internal erosion within the side-slope cover layers over the Federal Cell’s s design life under normal and
abnormal precipitation conditions at the site. The calculations demonstrate that the filter layer underlying the
side-slope riprap meets the D15/D85 criteria as described in NUREG/CR-4620 for minimization of migration
of the filter layer into the riprap. Furthermore, specifications on the sacrificial soil gradations ensure that
migration of material between the sacrificial soil layer and the Type A Filter layer of the side slope will be
minimized. Additionally, the effectiveness of the Type A Filter Zone to minimize internal erosion of the
underlying sacrificial soil layer of the Federal Cell side slope was assessed by calculating the interstitial
velocities associated with the rock. When comparing the calculated interstitial velocities to permissible
velocities from NUREG/CR-4620, worst-case calculated interstitial velocities at the surface of the side-slope
sacrificial soil layer would not be expected to cause erosion of that layer. In response to the Director’s
additional slope questions (Willoughby, 2021), additional embankment stability analysis and responses are
included as Appendix M.

EnergySolutions has also demonstrated that the selected characteristics of the proposed riprap materials that
would be placed in and used to line the Federal Cell perimeter ditches would be adequate to resist movement
(internal erosion) of the riprap materials under flows projected to occur during normal and abnormal
precipitation events at the site. For evaluating potential internal erosion in the ditches, the performance
assessment assumed a 100-year, 24-hour storm event (2.4 inches) for the normal condition, and a 1-hr value
of 6.1 inches of rain as the abnormal condition. The drainage design calculations have performed in
accordance with guidelines provided in NUREG-1623. In the calculations, the minimum average D50 of the
riprap lining the ditches required to prevent failure under abnormal ditch flow conditions was determined
using methods recommended in NUREG-1623. The analyses of the effects of erosion on long-term stability
of the proposed Federal Cell and perimeter drainage ditches are adequate and that long-term stability of the
Federal Cell will be achieved with reasonable assurance.

The area of the proposed Federal Cell, at and immediately surrounding the Clive Facility, is relatively flat
with no landforms or soil conditions present that would be prone to landslides, rock toppling or rock falls,
debris flows, or other forms of mass wasting. Analyses of slope stability of the Federal Cell and of other
disposal embankments at the Clive Facility demonstrate that all slopes will be stable in the long term. Based
on this information, the long-term stability of the proposed Federal Cell will not be impacted by mass wasting.

EnergySolutions has assessed performance of the Clive disposal facilities under normal (static) and abnormal
(seismic) conditions (see Appendices M and N). Slope stability analyses were performed for circular modes
of failure-associated movement. The calculated minimum static factor of safety, based on use of drained shear
strength values for the embankments and foundation materials was previously determined to be greater than
1.5. For assessing stability under seismic conditions, pseudo static stability analyses of embankment slope
stability were completed. The pseudo static analyses considered both drained and undrained foundation soil
strength parameters, and assumed a Peak Ground Acceleration (PGA) magnitude of 0.28g. The calculated
minimum factor of safety for seismic conditions was determined to be greater than or equal to 1.2. In all cases,
the stability of the embankments was found to be governed primarily by the height of the 5H:1V embankment
side slope.

6.3.3 Settlement and Subsidence

In the Embankment Stability Study included as Appendix M, EnergySolutions demonstrates that most
embankment settlement occurs during operations in the waste placement phase, prior to the final cover
placement. As a result, the FCF CQA/QC Manual specifications to monitor and measure settlement prior to
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cover placement appropriately reduces the risk of uncertainties in estimating settlements. By comparison with
the neighboring Class A West cell, the settlement of the Federal Cell will be far less due to the absence of
disposed dry-active waste and the cell’s smaller design height with identical 5H:1V side-slope inclinations.
The fact that the waste type proposed to be disposed in the Federal Cell and waste placement and compaction
procedures are unchanged compared to the Class A West embankment, indicate that settlements would be
expected to be less in the Federal Cell relative to the Class A West embankment.

Based on the results of the slope stability analyses included in Appendix M, the design of the proposed Federal
Cell Facility will remain stable for global static short-term, long-term, seismic and post-earthquake conditions.
Based on the results of the seismic deformation analysis, the design of the proposed Federal Cell slopes and
cover will not experience significant seismic induced deformations (<5 mm). Additionally, the current load
of the proposed Federal Cell will not result in more than 11-inches of elastic settlement of sand-like soils, 12-
inches of primary consolidation of clay-like soils and 6-inches of secondary compression settlement of clay-
like soils. Elastic settlement and primary consolidation settlement should be complete within one year after
the embankment depleted uranium and CLSM placement (which is within the required settlement monitoring
period in the FCF CQA/QC Manual) and will not interfere with the post-construction performance of the
cover. No more than 6-inches of secondary compression settlement of clay-like foundation soils may occur
over the compliance period of 10,000 years, but are not projected to impact the long-term performance of the
cover and embankment. The magnitude of settlement, estimated for the top slope portion of the Federal Cell
(where the maximum embankment height is experienced and expected to decrease linearly over the top slopes
to essentially no settlement at the toe of the embankment). Therefore, settlement of the foundational soils as
a result of construction of the Federal Cell should not adversely impact any adjacent cells.

Based on the results of liquefaction triggering analyses and seismically-induced cyclic softening (summarized
in Appendix M), these hazards will not undermine the stable condition of the proposed Federal Cell.
Seismically-induced settlements of the sand-like soils will be negligible (<1 inch). Cyclic softening of the
clay-like soils is highly unlikely to occur as a result of the design seismic event (0.24g PGA and 7.3 Mw).
While extremely unlikely, a 50% strength degradation of the clay-like soils would still yield a stable slope
condition post-earthquake.
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SECTION 7. OCCUPATIONAL RADIATION PROTECTION

EnergySolutions’ occupational radiation protection programs are appropriate for siting disposal facilities. In
compliance with UAC R313-15-101, EnergySolutions has developed a Radiation Protection Program, which
contains procedures and policies to ensure that occupational radiation exposures are controlled within the
limits of UAC R313-15-201, UAC R313-15-207, UAC R313-15-208, and UAC R313-15-301. The Program
also ensures that exposures are maintained as low as is reasonably achievable, in accordance with UAC R313-
15-101(2). EnergySolutions integrates the principles of ALARA into all activities related to exposures of
personnel.

7.1 OCCUPATIONAL RADIATION EXPOSURES

EnergySolutions has created an organizational structure and established personnel responsibilities and
activities to ensure that ALARA policy and procedures are not compromised because of pressures from
operational activities. In support of this position, ALARA principles are incorporated into facility operations,
training, development of radiation protection procedures, and design reviews.

EnergySolutions’ Radiation Protection Program is appropriate for operating disposal facilities.
EnergySolutions’ Radiation Protection Program ensures that all reasonable actions are taken to reduce
radiation exposures and effluent concentrations to levels that are considered ALARA. EnergySolutions’
ALARA management policy is detailed in the ALARA Program. EnergySolutions’ ALARA Program is
appropriate for siting disposal facilities. The ALARA Program is based upon past and continuing experience
with radiation operations. As new waste-handling procedures are developed, the ALARA Program is
modified to reflect the changes. Specific guidelines for operational reviews and modifications to the ALARA
Program are therein detailed.

The radiological risks from the depleted uranium materials received for disposal in the Federal Cell Facility
are comparable with the materials disposed of in the Class A West embankment. In fact, prior to the Utah
Radiation Control Board’s 2010 decision to significantly limit further disposal of concentrated depleted
uranium at the Class A West Facility, EnergySolutions’ Clive staff had extensive experience at safely
offloading, staging, placing and disposing of concentrated depleted uranium in a variety of package types and
waste forms. Therefore, radiation protection, access control to restricted areas, and personnel protective
equipment policies will not change from current policies. Although the Federal Cell Facility will increase the
overall licensed disposal capacity at the Clive Facility, EnergySolutions’ Radiation Protection Program will
continue to be bounded by the protections necessary to support License UT2300249.

7.2 RADIATION SOURCES

In order to produce suitable fuel for nuclear reactors and/or weapons, uranium has to be enriched in the
fissionable 235U isotope. Uranium enrichment in the US began during the Manhattan Project in World War II.
Enrichment for civilian and military uses continued after the war under the U.S. Atomic Energy Commission,
and its successor agencies, including DOE.

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The uranium fuel cycle begins by extracting and milling natural uranium ore to produce "yellow cake," a
varying mixture of uranium oxides. Low-grade natural ores contain about 0.05 to 0.3% by weight of uranium
oxide while high-grade natural ores can contain up to 70% by weight uranium oxide (NRC, 2010). Naturally
occurring uranium contains three isotopes, 238U, 235U, and 234U. Each isotope has the same chemical properties,
but they differ in radiological properties. Naturally occurring U has an isotopic composition of about
99.2739±.0007% 238U, 0.7204±.0007% 235U, and 0.0057±.0002% 234U (Rich et al., 1988).

The milled ore is refined to remove the decay products (226Ra, 230Th, etc.) that have built up in the material
naturally to the degree of secular equilibrium, leaving more or less pure uranium oxide. This uranium, still at
natural isotopic abundances, is enriched to obtain the 235U, with vast quantities of 238U as a by-product.
Although a variety of technologies exist for enrichment, the most prevalent enrichment process at the time
was by gaseous diffusion, which requires that the uranium be converted to a gaseous form: uranium
hexafluoride (UF6). This gas is introduced to a diffusion cascade, which separates the isotopes, generating
enriched uranium as a product, and depleted uranium hexafluoride (DUF6) as a waste stream. Depleted
uranium isotopic ratio values from gaseous diffusion plants are roughly 99.75% 238U, 0.25% 235U, and
0.0005% 234U (Rich, et al., 1988), but the 235U assay found in the cylinders today varies with fluctuating
enrichment goals, operational conditions, and where in the cascade process the depleted uranium was
removed. Because processing of uranium has been practiced for only about 60 years, there has not been
sufficient time for appreciable in-growth of decay products in this by-product. Depleted uranium is therefore
considerably less radioactive than natural uranium because it has less 234U and other decay products per unit
mass. The bulk of this material is still stored in the original cylinders in which it was first collected at the
gaseous diffusion plants.

Uncontaminated depleted uranium consists principally of three isotopes of uranium (238U, 235U, and 234U) and
a small amount of progeny from radioactive decay of these isotopes. Trace amounts of other uranium isotopes
(232U, 233U, and 236U) may also exist. The bulk of the depleted uranium at the gaseous diffusion plants is
uncontaminated uranium, but a significant amount of contaminated depleted uranium also exists, both at the
gaseous diffusion plants and in all the depleted uranium waste from the Savannah River Site.

The contamination problem arises from the past practice of introducing reactor returns into the isotopic
separations process. Irradiated nuclear fuel underwent a chemical separation process to remove the plutonium
for use in nuclear weapons. Uranium, then thought to be a rare substance, was also separated out, but contained
some residual contamination from activation and fission products. This uranium was again converted to UF6
for re-enrichment, and was introduced to the gaseous diffusion cascades, contaminating them and the storage
cylinders as well.

The types and quantities of depleted uranium materials are sources of external gamma, alpha, beta, and
neutron radiation. Personnel exposure to these materials will happen at various times e.g. while in the delivery
conveyances awaiting unloading; during storage; while being sampled and prepared for laboratory analysis;
while being actively worked in the proposed Federal Cell Facility; and while exposed following disposal.
While unlikely for depleted uranium, dose rate on packages could be in excess of 200 R/hr.

Depleted uranium wastes may also be potential sources of internal exposure during unloading at the rail car
rollover or bulk unloading area; while being sampled and prepared for laboratory analysis; while being worked
in the disposal cell or mixed waste treatment; and while exposed following placement in the Federal Cell
Facility. Internal doses are not expected to exceed 50 mrem per year.

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The most consistent source of radiation dose at the Clive Disposal Complex is external gamma radiation. In
recognition of that, EnergySolutions has set aggressive dose investigation levels for workers, based upon
annual ALARA goals per quarter deep dose equivalent. It is highly unlikely that workers at Clive exceed that
level each quarter. Control of external gamma exposures during waste handling operations is the primary
method of reducing dose. EnergySolutions will continue to rely primarily upon time, distance and shielding
to control employee exposure. EnergySolutions manages shipments under a radiation work permit (RWP) to
keep doses ALARA.

EnergySolutions has an aggressive policy of dose minimization. Waste streams require the preparation of a
Radiation Work Permit (RWP) that lists the specific radiation protection requirements. Common
requirements include clothing to be worn, the use of self-reading personal dosimeters, respiratory protection,
and special monitoring requirements. Special situations may include requiring a Radiation Safety technician
to be present, the use of remote handling equipment, dust suppression requirements, air monitoring or survey
requirements, stay times, or other controls needed to keep exposure ALARA. In addition, all workers are
trained in ALARA principles, especially in maintaining their distances from gamma sources and spending the
least amount of time necessary in gamma fields to get the job done.

EnergySolutions will continue to use standard health physics practices of limiting time in areas with higher
gamma dose rates, using respiratory protection at low airborne radioactivity concentrations, covering higher
activity wastes with lower activity wastes or clean soil to reduce gamma exposures and resuspension of
airborne particulates, and routinely monitoring work area radiation levels to protect workers from chronic
exposure from low level radiation sources.

All personnel entering the Restricted Area are required to wear radiation dosimeters at all times. Permanent
employees are issued a TLD badge or equivalent, as approved by the Clive Facility Radiation Safety Officer.
These badges are exchanged quarterly or read as soon as practical upon termination of employment. Badges
are selected that measure the skin dose equivalent (shallow dose) as well as the deep dose equivalent for
compliance with UAC R313-15-203 and UAC R313-15-502 and are worn in the proper place as instructed
by the Radiation Safety Officer. All badges, along with control badges, are maintained in designated areas at
the Clive site when the employee is not at work.

Should the Radiation Safety Officer determine that it is necessary to measure the shallow dose rather than use
a TLD, or equivalent devices, EnergySolutions implements a procedure to calculate the shallow dose by
applying a correction factor to the TLD, or equivalent reading(s). All exposures will be recorded when
received from the dosimetry vendor to demonstrate compliance with the standards. In the event that an
individual loses their TLD or equivalent, the Radiation Safety Officer or his designee will investigate the
potential exposure conditions and provide a record of the exposure.

Because of the low radionuclide activities in the waste, there is little potential for a significant penetrating or
non-penetrating external radiation dose from airborne radioactive material. The deep dose equivalent
component of this small dose will be included in the employee's personal dosimeter reading. EnergySolutions
allows visiting members of the public to access the Controlled and Restricted Areas of the site for tours, visits,
and inspections. All visitors requiring access to the Restricted Area are provided dosimetry and an
informational briefing appropriate for the expected hazards, and are accompanied by a responsible
EnergySolutions radiation worker. Procedurally, visitors are not allowed in posted radiation areas or areas
where respiratory protection is required. Individuals who are visiting the site on a limited basis will be issued
a pocket dosimeter or other self-reading dosimetry to monitor their external gamma radiation dose. The
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dosimeter is read upon exiting the Controlled Area and recorded on the Access Log. In the case of individuals
visiting as a group, one dosimeter may be used providing they stay together.

EnergySolutions pursues a policy of dust prevention to keep airborne particulate radioactivity ALARA.
However, as part of its ALARA Program, EnergySolutions requires all workers, in situations where they may
be unknowingly exposed to airborne particulate radioactivity, to wear respiratory protection providing a
protection factor of at least 10. With the combination of dust control and respiratory protection it is anticipated
that internal doses will never exceed 50 mrem per year.

Ambient air radon concentrations are continuously monitored at the environmental stations on and around the
site. Outdoor radon measurements have not shown any definite elevations above background levels.
Laboratory measurements, where samples are stored and prepared for analysis, show occasional
concentrations approximately 0.5 pCi/L above ambient concentrations (less than two percent of the DAC for
radon with daughters present).

The regulatory requirements for determining the occupational internal dose are in UAC R313-15-204.
EnergySolutions uses the dose calculations methods described in Regulatory Guide 8.34, but uses data based
on the updated Dose Conversion Factors of ICRP 68 in lieu of the ICRP 30 Dose Conversion Factors to
perform these dose calculations. The chemical form of significant dose contributors are determined as needed
from the waste manifests, air sample data, or other available sources of information. The applicable lung
clearance class is determined from the tables in ICRP 68. If the chemical form of significant dose contributors
cannot be determined, the most restrictive class is used in the dose assessment. The Environmental Monitoring
Plan lists the specific method, formula, and dose conversion factors that are used at the Facility to determine
internal dose to workers, based on the Effluent Concentration Limit (ECL) Radionuclide which, if inhaled or
ingested continuously over the course of a year, would produce a stochastic total effective dose equivalent of
50 mrem.

The indication provided by workplace air sampling guides the subsequent assessments of possible internal
doses from inhaled radioactive materials. Regulatory Guide 8.34 provides several acceptable methods for
determining internal doses from inhaled radionuclides. When calculating an employee’s internal dose from
inhaled radioactive material, Regulatory Guide 8.34 guides the dose calculations, with updated data based on
the Dose Conversion Factors of ICRP Publication 68. When initial estimates indicate a potential dose
equivalent in excess of 100 mrem (CDE or CEDE), additional evaluations are performed to further assess the
dose and guide follow-up actions.

The ingestion of radionuclides at the EnergySolutions site is suppressed primarily by prohibiting eating and
drinking inside Restricted Areas (with the exception that drinking from closeable beverage containers is
allowed). In addition, the use of respiratory protection in the most highly contaminated areas minimizes the
potential for facial contamination and subsequent ingestion of radioactive material.

Employees at the EnergySolutions Clive site are normally protected from intake through wounds and skin
absorption by wearing protective clothing. Requirements for wearing person protective equipment included
in each Radiation Work Permit. Should an accident result in an open wound, the Radiation Safety Officer
notifies the attending physician located at the Tooele County or University of Utah Hospitals, of the fact for
his guidance in effecting removal or reduction of the amount of radioactive material remaining in the wound.
The Radiation Safety Officer then performs an investigation and estimates the intake using data from wound
monitoring or other available information.
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7.3 RADIATION PROTECTION DESIGN FEATURES

EnergySolutions has incorporated the previously approved design and operational experience of its other
facilities into the design of this License’s Federal Cell Facility to minimize the potential for radiation
exposures. As such, the Federal Cell Facility design is directed toward reducing the occupational exposures.
The entire Federal Cell Facility will be enclosed by a fence, and considered a Restricted Area. All personnel
working in the Restricted Area are required to pass through an Access Control point. Access to exposure areas
at the facility is controlled. All vehicles and personnel working in the Restricted Area are monitored for
removable contamination prior to release.

EnergySolutions employs the radiation exposure controls of time, distance and shielding, as appropriate.
Waste receipts with dose rates in excess of 5 mrem/hr are controlled and posted as described in the Radiation
Safety Program. EnergySolutions’ Radiation Safety Program is appropriate for siting disposal facilities.
Radiation Work Permits are used to control worker exposure during waste handling and include time controls
or take advantage of natural shielding afforded by equipment as necessary and appropriate. Higher activity
wastes are covered, except when being actively worked, by lower activity wastes to reduce exposures to
workers in the area. For management of bulk wastes, the primary radiation control factors are time and
distance. Conversely, the use of portable shielding during the waste disposal process is used as needed to
minimize dose to the workers. Additionally, the nuclear density gauges are stored away from active work
areas and are shielded by lead bricks when in storage.

Since waste handling and disposal activities are generally conducted outdoors, no special ventilation
provisions are made for those activities. However, laboratory areas require normal ventilation and hoods.
Work area air samples are collected in the building to confirm the effectiveness of ventilation. External gamma
radiation monitors are used to document gamma radiation exposure levels. Surveys of gamma dose rates and
surface contamination are collected weekly. Any areas meeting the definition of a Radiation Area are posted.

Airborne radioactive particulates are monitored on a continuous basis. The continuous airborne particulate
samplers, operated on-site as part of the Environmental Monitoring Plan, provide an overall average airborne
radioactivity concentration. In addition to the fixed-location environmental stations, work-place samples are
also collected to better assess potential exposure to employees. The work area air samplers are used at
locations such as the rail car rollover, haul roads, the mixed waste treatment building, or near excavation,
disposal and other work activities to collect workday samples. Work area samples are collected several times
a week. In addition to the passive environmental radon monitors used at environmental monitoring stations,
indoor radon concentrations are measured in the LLRW and Mixed Waste Operations buildings.

Radiation Safety instrumentation used for EnergySolutions’ Radiation Protection Program include a variety
of portable and laboratory equipment selected to perform specific functions in monitoring of gross gamma
exposure rates, surface contamination, alpha and beta radioactivity of filters and smear samples and personnel
contamination. Instruments are calibrated, at a minimum every 12 months and are checked each working day
for consistency of response to a known source.

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7.4 RADIATION PROTECTION PROGRAM

EnergySolutions’ Radiation Protection Program is appropriate for operation of its disposal facilities.
EnergySolutions’ Radiation Protection Program has been developed to establish Clive Facility requirements
to receive, possess, process, use, transfer or dispose of licensed LLRW. EnergySolutions is committed to
managing its operations involving exposure to ionizing radiation and radioactive materials by incorporating
the philosophy that such doses should be ALARA. EnergySolutions’ Radiation Protection Program
establishes the measures that management uses to ensure that appropriate regulatory requirements and
policies, programs and procedures are met. The Radiation Safety Officer reviews EnergySolutions’ Radiation
Protection Program annually.

EnergySolutions’ Respiratory Protection Program is appropriate for operating disposal facilities. The
Respiratory Protection Program has been implemented, based on NRC guidance (NRC, 1976). The Program
elements include employee training, quantitative fit testing, cleaning and maintenance, written standard
operating procedure covering the program, medical surveillance, and recordkeeping. The Radiation Safety
Officer is responsible for administering the Respiratory Protection Program.

It is the policy of EnergySolutions, to maintain personnel/occupational radiation exposures ALARA. Because
of the nature of LLRW, experience has shown that radiation exposures are normally low and EnergySolutions
is committed to continuing to minimize exposures to the workers and the environment. As is illustrated in
Table 7-1, the employee doses since 1992 have been well below federal standards for radiation workers (as
compared to the average annual dose for 294 workers involved in the Vitro Remedial Action Project during
1986 which was 50 mrem, with maximum exposures of 250 mrem). This maximum value is only 5% of the
radiation dose standard of UAC R313-15-1101. EnergySolutions’ annual employee dose summary since 1992
is presented in Table 7-1. Procedures and methods to keep internal exposures ALARA include:
a. Dust suppression on all operational roads by application of water or other dust suppressant materials
or methods (e.g., Magnesium Chloride) as necessary;
b. Speed limit of 25 mph on all site roads;
c. Stopping operations in high wind conditions (all operations cease at winds of greater than or equal to
35 mph; radiation safety personnel have authority to stop operations at lower wind speeds if dusting
or other safety considerations warrant);
d. Daily, weekly, monthly and quarterly area radiation surveys with investigation of increasing levels to
determine the cause;
e. Requiring workers to wear respirators in areas of potential high dust concentrations, for example, the
rollover and selected heavy equipment operations;
f. Pre-planning tasks that have the potential for higher-than-normal exposures to limit exposures
through efficient use of time and handling procedures; and
g. Reviews of new proposed Waste Profile Records to assure that EnergySolutions’ procedures,
facilities, and equipment are appropriate and sufficient to limit exposures to workers and the
environment.

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Table 7-1

EnergySolutions Employee Annual Dose Summary

Year Dose
(mrem)
<1
Dose
(mrem)
10-50
Dose
(mrem)
51-100
Dose
(mrem)
101-150
Dose
(mrem)
151-200
Dose
(mrem)
201-250
Dose
(mrem)
251-500

Dose
(mrem)
500+
1992 20 40 11 2 1 1 0 0
1993 92 5 1 0 0 0 0 0
1994 93 15 1 0 0 0 0 0
1995 84 62 4 0 0 0 1 0
1996 209 16 0 2 0 0 0 0
1997 325 61 1 0 0 0 0 0
1998 412 104 4 0 1 0 0 0
1999 363 138 19 5 2 1 1 0
2000 431 154 37 6 5 6 5 1
2001 538 85 21 8 5 0 1 0
2002 483 105 27 5 4 3 1 0
2003 520 74 13 3 2 7 0 0
2004 441 142 30 9 6 7 0 0
2005 649 103 26 14 3 9 0 0
2006 495 70 15 6 2 2 6 0
2007 287 59 5 6 2 3 5 0
2008 232 45 8 5 3 2 5 0
2009 239 39 12 3 2 0 6 0
2010 263 42 8 6 2 1 3 0
2011 215 54 14 7 4 4 6 0
2012 240 34 8 3 0 0 6 0
2013 160 25 17 3 1 0 5 0
2014 123 22 9 6 2 1 7 0
2015 136 33 11 3 5 1 6 3
2016 152 42 13 7 4 1 5 3
2017 232 25 17 3 3 2 2 2
2018 216 25 12 1 1 2 2 0
2019 233 32 11 3 2 0 3 0

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The Radiation Safety Officer has the day-to-day responsibility for maintaining occupational and
environmental radiation exposures ALARA, consulting such guidance documents as NRC Regulatory
Guides 8.31 (NRC, 2002) and 8.37 (NRC, 1993a). The Radiation Safety Officer documents ALARA
activities including:
a. Monthly reviews of work area, perimeter, and environmental air monitoring results noting trends and
adjusting work procedures when practical to further reduce potential exposures; and
b. Monthly reviews of work area gamma-ray exposure rates and advising the General Manager of Clive
Operations on operational changes that will reduce radiation exposure.

An audit of ALARA activities is conducted and documented by the Radiation Safety Officer at least annually.

All personnel working in the Restricted Areas are monitored for potential skin contamination each time they
exit the area. Workers are advised to consider any measurable skin contamination as excessive, and all
personnel must meet release criteria before they leave the Restricted Area. EnergySolutions has set ALARA
limits for personnel contamination monitoring at 100 dpm/100 cm2 gross alpha for skin and clothing, 300
dpm/100 cm2 gross alpha for the soles of shoes, and 1,000 dpm/100 cm2 gross beta for skin, clothing, and the
soles of shoes. A hand and foot monitor, or equivalent, sensitive to both alpha and beta contamination are
used for routine monitoring for personnel contamination.

Personnel are expected to accomplish any necessary decontamination by washing exposed areas of the skin
with soap and water. If this does not reduce the levels below the criteria, the Radiation Safety Officer is
notified, and other attempts made. Special radiation decontamination cleansers may be used to reduce skin
contamination levels as needed. Personnel with skin contamination above the limits are not allowed to leave
the site without approval of the Radiation Safety Officer. All personal contaminated clothing or personal
articles that cannot be decontaminated below the limits are retained at the site and managed as radioactive
waste. All personnel contamination events are documented.

Routine external gamma surveys using a gamma scintillation survey meter are conducted in waste
management and disposal. In addition, random external gamma surveys are performed during daily
operations as considered necessary by Radiation Safety personnel.

Routine smear surveys for surface contamination are conducted in office and laboratory areas. The smears
are analyzed for gross alpha and gross beta contamination. Smear samples are compared to previous samples
from the same area. The Radiation Safety Officer reviews any increase in surface contamination, deciding on
the need for decontamination. In keeping with EnergySolutions’ ALARA goals, any increase in
contamination is normally cleaned when found and the area re-sampled.

Routine worker evaluations demonstrate that it is extremely unlikely that any employee could receive a lung
burden of radioactivity that would require any action. If such an event happens, the individual involved
receives a whole-body count to evaluate the potential dose. Subsequent actions, such as reassignment to a
function not involving radiation exposure are then considered.

A worker might also be injured in an accident that would result in the impaction of radioactive material into
a wound. In such a case, EnergySolutions attempts to monitor injured employees before they are transported
to medical care. In any case, the treating physician is informed that the injury involves possible radioactive
contamination. Because the radionuclides involved are relatively insoluble, normal cleansing of the wound
generally removes most, if not all, of the radioactivity. A radiation survey is used to estimate any remaining
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radioactivity and potential doses calculated. The determination of need for additional treatment is based on
monitoring results.

Bioassay samples are used, as necessary, to help determine the body burden of any radioactivity that has
resulted from an unusual inhalation or wound. Any employees who are believed to have received a TEDE of
greater than 100 mrem from any source in one quarter are notified and assist in determining the source of the
exposure and in finding a way to reduce future exposures.

Summation of external and internal doses is required in UAC R313-15-202 when both internal and external
monitoring of an individual are required by UAC R313-15-502(1) and (2). The cumulative operating
experience at the Clive site indicates that the monitoring criteria of UAC R313-15-502(1) and (2) are not
likely to be exceeded. However, should EnergySolutions find that summation of occupational internal and
external doses is necessary, one of the five methods for calculating the Committed Effective Dose Equivalent
(CEDE), as described by NRC (NRC, 1993b), or an equivalent method, will be used. ALI, DAC, and ECL
values based on the ICRP 68 conversion factors will be calculated, as needed for internal dose estimation,
following the methodology described in Appendix B of 10 CFR 20.

If any employee is anticipated to receive an occupational dose in excess of 10 percent of the occupational
limits, EnergySolutions will determine the previous radiation exposure for use in limiting the annual dose
equivalent to the allowable limits and for planning special exposures. Determination of prior occupational
exposures will be done by:
1. Obtaining a written, signed statement from the employee or his most immediate employer, that
discloses the nature and the amount of any occupational dose that the individual may have received
during the current year; or
2. Obtaining or attempting to obtain from the employee's most recent employer, a written, signed
statement in the form of an NRC Form 4 or an equivalent form, showing the life-time occupational
exposure history. In case this cannot be done, the guidance in UAC R313-15-205 will be followed.

EnergySolutions does not anticipate authorizing planned special exposures since the radiation levels and
radioactive constituent concentrations in depleted uranium are low. In the event that circumstances warrant a
planned special exposure, EnergySolutions does so in full compliance with the guidance in UAC R313-15-
206.

The annual occupational dose limits for minors are 10 percent of the annual dose limits specified for adults.
However, in accordance with EnergySolutions’ Radiation Protection Program, minors are not granted access
to the Restricted Area. Similarly, the dose limit to an embryo/fetus is 0.5 rem during the entire pregnancy (in
accordance with UAC R313-15-208). EnergySolutions’ policy is to inform female workers of the regulations
regarding protection of the embryo/fetus and to ask them to inform EnergySolutions in writing, upon discovery
or suspicion of a pregnancy. The Radiation Safety Officer reviews the work assignments and offers the
woman the opportunity to take available positions in non-radiation areas for the duration of the pregnancy. If
no positions are available, the Radiation Safety Officer counsels the individual to assure an understanding by
the individual of the additional risks of continued employment. If the woman continues to work in the
Radiation Area, the Radiation Safety Officer monitors the work assignments and activities to assure that the
Total Effective Dose Equivalent (TEDE) to the embryo/fetus is ALARA and limited to 0.5 rem.

Operations are conducted such that the resulting dose equivalent to any individual members of the public is
less than the limits of UAC R313-15-301, UAC R313-25, and the ALARA constraint of UAC R313-15-101.
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Compliance with UAC R313-15-301 is demonstrated using the data acquired under the Environmental
Monitoring Plan. Airborne particulate monitoring is performed to confirm those predictions.

The analysis addresses the specific impacts of releases under normal operating conditions. Release
mechanisms were evaluated, exposures to workers and the public assessed, and the results compared to
applicable standards and regulations. It was concluded that with the proposed waste characteristics and
operating procedures, exposures to the workers and the public will be within acceptable limits and the design
limits the radon flux to less than 20 pCi/m2/s as provided in Appendix A of 10 CFR Part 40.

EnergySolutions’ Federal Cell Facility will be operated in accordance with EnergySolutions’ Air Approval
Order (DAQE-AN107170021-19), which requires EnergySolutions to apply dust suppression when minimum
waste moisture conditions as well as optimum air opacity standards do not exist. Air is continuously sampled
at work place locations surrounding the Federal Cell Facility, Restricted Area, and the Clive Facility.
Individual results with a net alpha or net beta concentration above the applicable Particulate Air Sample
Action Level are also analyzed by gamma spectroscopy. Gamma spectroscopy analysis results are reviewed
to determine if any additional actions need to be taken. Air is also continuously sampled for radon.

The following items are surveyed each week,
• Site warning signs must be visually checked weekly to determine that the signs are present, visible
and legible.
• The supply of personal protection equipment is inspected weekly to ensure that each employee has a
proper supply or access to gloves, boots, coveralls, hard-hat, goggles, and respiratory protection.

The daily BAT inspection includes:
• Check roads. The inspector must drive the access and facility roads to visually inspect them for
deterioration, erosion and evidence of spills;
• Loading and Unloading Areas. Visually inspect the loading and unloading areas. Note stains,
residues, and any evidence of a spill or leak;
• Container storage area. The container storage area must be inspected for evidence of a spill; and
• Inspect containers. The inspector visually inspects the exterior surface area for evidence of leaks,
corrosion, deterioration, holes, bulges, and poorly fitting lids.

Daily BAT inspections are to be performed each day that the facility is in operation. Problems are corrected
accordingly:
• Problems that pose an imminent threat to human health or the environment are corrected as soon as
possible but no later than 24 hours from the time of discovery;
• Problems that do not pose an imminent threat to human health or the environment are corrected within
72 hours of discovery; and
• If a longer time period is required to correct the problem, EnergySolutions notifies the Director prior
to the end of the 72-hour period. At the time of notification, EnergySolutions proposes a time
schedule for correcting the problem. The Director must approve the correction schedule.

The daily security inspection includes:
• Check fences. The inspector must inspect the site security devices (fences, gates, doors, and locks)
to check for items such as proper functioning, breaks, gaps, erosion, vandalism or damage to the fence
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abric, fence posts, gates, etc. The inspector must also check the gates and doors to ensure that the
gates and doors are locked or attended by a person assigned to control entry; and
• Check communication systems. The inspector performs an audio test on the external
communication system (telephone) by ensuring that dial tone exists and that the phone is operational.
This test may be conducted by placing and completing a telephone call. The inspector tests the
internal communication system (two-way radios, intercom, etc.) by operating the system and
achieving communication through the system.

The facility is considered to be in operation in the following instances:
• When off-site LLRW shipments have been received to the facility;
• When LLRW is being added to or removed from the Federal Cell Facility; or
• When LLRW containers are being added to or removed from the storage area.

All equipment, conveyances, railcars, and vehicles exiting the Restricted Area must be monitored,
decontaminated if necessary, and released before leaving the Restricted Area. Designated Commercial
transports for the exclusive use of waste transport may be released from a Restricted Area as long as the 49
CFR criteria are met. Entrances into parts of the Restricted Area that are not expected to be contaminated
under routine conditions may not require equipment (vehicles, cement trucks, haul trucks, etc.), personnel or
personal item decontamination. These areas include but are not limited to areas of new construction inside
the Restricted Area, unloading docks, and areas in which Federal Cell Facility closure is being performed
inside the Restricted Area.

Depending on individual circumstances, vehicles or equipment leaving the site are surveyed in accordance
with the unrestricted use of release criteria or to the standards of the DOT release. Unrestricted use release
entails decontamination and release to the standards of 49 CFR 173.443. All vehicles, packages, equipment,
or other items leaving the Restricted Area, except conveyances used for commercial transport of radioactive
waste material, are unrestricted use released.

Closed trucks and rail cars used exclusively for transport of radioactive materials are released as described in
Radioactive Material License UT2300249, measuring the removable contamination on the exterior surfaces
only. Transport vehicles that are being released from exclusive use service will be released as described
above, measuring removable contamination on both exterior and interior surfaces. Closed containers used
solely for the transportation of radioactive materials may be released, provided that the radiation level at any
point on the external surface of the container does not exceed 0.5 millirem per hour:
a. The non-fixed (removable) radioactive surface contamination on the external surface of the container
does not exceed the limits of Radioactive Material License UT2300249;
b. The container does not contain more than 15 grams of U-235, the container is in unimpaired condition
and is securely closed so that there will be no leakage of radioactive material under conditions
normally incident to transportation;
c. Internal contamination does not exceed 100 times the limits of the table above; and
d. Any labels previously applied are removed, obliterated, or covered and the “Empty” label prescribed
in 49 CFR 172.450 and the notices are affixed to the container.

Regardless of the type of release, all items must be visibly clean, meaning that all potentially contaminated
material that can be removed by a broom, shovel or other tool must be removed. Typical road dust and grime
that is on a vehicle as it arrives and is not part of the radioactive waste material being carried does not have to
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be removed. Trucks, rail cars or reusable containers hauling waste to EnergySolutions are released to the
DOT standards of 49 CFR 173.443, as set forth in Table 7-1, below.

Documentation of release surveys are kept in the operating record, including item identification number, item
type, instruments used, survey results, surveyor’s signature, and reviewer’s signature. A Radiation Safety
Technician performs the release survey and signs the completed form. As a quality control check, a second
Radiation Safety Technician signs the completed forms daily after reviewing them for completeness and
adherence to release policy. Release of waste conveyances may be performed remotely using field
measurements.

Contaminated equipment or vehicles may be decontaminated using brooms, shovels, high pressure water, or
other effective means. The waste water is allowed to drain into tanks and transferred to permitted evaporation
ponds. In accordance with GWQDP UGW450005, wastewater may also be used for dust suppression on the
Federal Cell Facility.

All personnel entering the Restricted Area are required to wear radiation dosimeters at all times. Permanent
employees are issued a TLD badge or equivalent, as approved by the Radiation Safety Officer. Badges are
exchanged quarterly or read as soon as practical upon termination of employment. They are selected to
measure the skin dose equivalent (shallow dose) as well as the deep dose equivalent for compliance with UAC
R313-15-203 and UAC R313-15-502 and are worn in the proper place as instructed by the Radiation Safety
Officer. All badges, along with control badges, are maintained in designated areas at the Clive site when the
employee is not at work.

All employees will notify their supervisor immediately upon discovery that a TLD or equivalent has been lost.
A new dosimeter will be issued prior to the employee’s reentry into the Restricted Area. When the Radiation
Safety Officer or designee determines that extremity monitoring is warranted, appropriate dosimeters will be
obtained from the dosimetry vendor.

All visitors requiring access to the Restricted Area are provided dosimetry and an informational briefing
appropriate for the expected hazards, and are accompanied by a responsible EnergySolutions radiation worker.
Procedurally, visitors are not allowed in posted radiation areas or areas where respiratory protection is
required. Individuals who are visiting the site on a limited basis will be issued a pocket dosimeter or other
self-reading dosimetry to monitor their external gamma radiation dose. The dosimeter is read upon exiting
the Controlled Area and recorded on the Access Log. In the case of individuals visiting as a group, one
dosimeter may be used providing they stay together.

Areas near or at the Access Control points are provided for the donning or doffing of personal protective
equipment and clothing. Lockers are provided for employees inside the Restricted Area for storage of clothing,
personal items, and personal protective equipment. These lockers are located near showers for
decontamination if necessary. Lockers outside the Contaminated Restricted area also available to employees
for storage of personal items or PPE.

Release limits for skin and clothing are based on the removable and fixed contamination limits specified in
Regulatory Guide 1.86. The great majority of alpha-emitting nuclides in the LLRW are uranium and natural
thorium with its decay products. For those nuclides, the appropriate alpha release limit for skin and clothing
is 1,000 dpm/ 100 cm2. Similarly, the removable limit for beta/gamma-emitting nuclides is 1,000 dpm/ 100
cm2. EnergySolutions also uses this level as the release limit for contamination of skin and clothing by
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beta/gamma-emitters. Regulatory Guide 8.30 recommends the use of fixed contamination limits for the soles
of shoes. Following this example, the release limit for the soles of shoes has been set at 5,000 dpm/ 100 cm2
for both alpha and beta/gamma activity.

EnergySolutions has set an ALARA goal for alpha-emitting radionuclides on the skin and clothing at 100
dpm/ 100 cm2. Because of the high natural backgrounds associated with beta/gamma monitors, the ALARA
goal is the same as the release limit for beta/gamma emitters - 1,000 dpm/ 100 cm2. The ALARA goal for
contamination of the soles of shoes is set at 500 dpm/ 100 cm2 alpha and 1,000 dpm/ 100 cm2 beta/gamma.

Contamination of personnel in the Restricted Area is controlled through the use of protective clothing, access
control, atmospheric monitoring, and bioassay analysis. Protective clothing is selected according to the
requirements of the Safety and Health Manual. Each employee is responsible to keep contaminated clothing
and other material inside the Controlled Area. Furthermore, access to the Restricted Area is controlled
according to Standard Operating Procedures. While in the Restricted Area, engineering controls and dust
suppression techniques are used to minimize levels of airborne particulates. Work area air samples are
routinely collected and analyzed.

All monitored individuals are required to participate in a whole-body count, with a random selection further
required to follow a bioassay program to assist in evaluating internal deposition of radionuclides. A baseline
sample is taken either through urinalysis or use of a whole-body counter at the beginning of the monitoring
period. A termination sample is taken whenever possible either through urinalysis or use of a whole-body
counter. All in-vivo baseline, and termination samples are analyzed by gamma spectroscopy for naturally
occurring radioactive material, including uranium and Ra-226. Urine samples are analyzed for total uranium
and Ra-226. EnergySolutions evaluates laboratory bioassay analysis results in accordance with NRC
Regulatory Guide 8.9 (NRC, 1993b).

For monitored individuals, a combination of air sampling, personnel contamination monitoring, and bioassay
sampling are used to initiate action levels and assess dose intakes and/or uptakes. The radiation safety staff
is responsible for taking appropriate actions when certain action levels are exceeded. In accordance with NRC
Regulatory Guide 8.9, the action levels for monitored individuals working directly with the waste are:
Evaluation Level: If internal bioassay measurements indicate that an intake is greater than an intake
of 0.02 ALI, additional available data, such as airborne measurements or additional bioassay
measurements, should be used to obtain the best estimate of actual intake.
Investigation Level: If a potential intake exceeds an investigation level of 0.1 ALI, multiple bioassay
measurements and an evaluation of available workplace monitoring data will be conducted.

Special bioassay sampling is done for individuals involved in an incident determined by the Radiation Safety
Officer as having the potential for a significant intake of radionuclides in accordance with the established
action levels. Appropriate samples are collected on a periodic basis until activities are below the minimum
detectable levels or a determination is made that continued monitoring is not necessary. If the waste contained
high Th-232 concentrations, lung or whole-body counting techniques may be employed to measure deposition
in the body.

Specific bioassay sampling is also used on a periodic basis for individual personnel working in areas with an
elevated potential of intake. The potential of an intake is evaluated by review of air sampling results, work
practices, and pre-operational modeling.

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Excretion models are used along with waste characterization data, bioassay data, and operational data to
estimate the radionuclide intake and the resultant dose to the organs. Methods recommended by NCRP are
used (NCRP, 1987). The guidance of UAC R313-15-201 is followed in cases where significant organ doses
or Total Effective Dose Equivalents are found.

The worker exposure pathway for radionuclides under normal operations is via the inhalation pathway.
Routine chronic exposure to radionuclides is limited by dust control measures and use of respiratory
protection. However, to check the adequacy of these measures, in vivo or in vitro methods may be employed
periodically, as determined by the Radiation Safety Officer or designee, to assure that intakes are a small
fraction of the regulatory limits.

The radiation safety staff under the direction of the Radiation Safety Officer are responsible for selecting
appropriate methods, properly assessing dose intakes and reporting the intakes. The Radiation Safety Officer
directs the Radiation Safety and Health Program. In addition, an Independent Industrial Hygienist conducts
quarterly industrial hygiene audits.
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SECTION 8. CONDUCT OF OPERATIONS

EnergySolutions’ administrative and operational procedures are appropriate for operation of its disposal
facilities. EnergySolutions’ corporate level management and technical organizations provide the technical
resources to support site characterization, facility design, construction, testing, and operation.
EnergySolutions corporate organization and technical staff also provide support for safe facility operation,
closure, and post-closure activities.

8.1 ORGANIZATIONAL STRUCTURE

Detailed requirements and qualifications for significant organizational positions are described in the
Organization Layout of Radioactive Material License UT2300249. EnergySolutions’ Organization Layout is
appropriate for management of disposal facilities. No organizational changes are proposed in support of the
proposed Federal Cell Facility.

8.2 QUALIFICATIONS OF APPLICANT

Detailed requirements and qualifications for significant organizational positions are described in the
Organization Layout of Radioactive Material License UT2300249 (referenced in Condition 32.A), such as
the Radiation Safety Officer, Assistant Radiation Safety Officer and Radiation Safety Technicians. The
information justifying License UT2300249, include the supporting and relevant documents, (engineering
reports, supplemental data submissions and interrogatory responses) indicated that the requirements of UAC
R313-25-6(2) have been met. EnergySolutions’ system of qualifications is appropriate for management of
disposal facilities. No changes in qualification requirements are proposed in support of the proposed Federal
Cell Facility.

8.3 TRAINING PROGRAM

EnergySolutions’ Training Program is appropriate for management and operation of disposal facilities. No
changes the Training Program are proposed in support of the proposed Federal Cell Facility. EnergySolutions’
Training Program is designed to educate the employees in the fundamentals of handling depleted uranium and
other radioactive materials, to provide information on ways of minimizing exposure, and to inform employees
of practices and programs aimed at preventing possible spread of contamination. During this training,
procedures and precautions are explained and the trainees are required to complete a written or computer-
based examination. In addition to the above training, all EnergySolutions site employees receive periodic
refresher training. This training is tailored to the specific employee needs and duties and covers such topics
as general occupational safety, radiological safety, and training on any specific items such as new procedures
or safety deficiencies. Elements of the training program include evaluation and testing, initial training,
continuing training, required qualifications, documentation and storage, and badging.

General facility training is overseen by the Safety and Health Manager. The Radiation Training Program is
operated under the direction of the Radiation Safety Officer. Radiation safety training is provided to all
persons before they are allowed to enter the Restricted Area. The amount of radiation safety training required
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for persons to enter the Restricted Area is related to the activities for which the person will enter the Restricted
Area. There are three categories of Restricted-Area functions:
1. Permanent Employee. A “Permanent Employee” is an employee of EnergySolutions hired for a
period longer than 20 days, or a long-term employee of a contractor to EnergySolutions;
2. Temporary Worker. A “Temporary Worker” is a service contractor (electrician, welder, consultant,
surveyor, driller, sampler, engineer, fence installer, forklift operator, laborer, mechanic, liner installer,
excavator, etc.) who works inside the Restricted Area under a contract or service order but who is not
an employee on the payroll of EnergySolutions or a long-term contractor performing work inside the
Restricted Area; and
3. Visitor. A “Visitor” is a person whose main interest inside the Restricted Area is to communicate
with personnel in the Restricted Area, to observe and/or inspect the operations, facilities, programs,
location and compliance at the site. Examples of visitors are compliance inspectors, visiting
dignitaries, representatives of organizations and corporations, tour groups, and associates of the
above. Most visitors will be required to be in the presence of a qualified escort while in the Restricted
Area. Certain visitors, such as compliance inspectors or auditors will not require escorts.

Training requirements have been established for each category. Refresher training is provided to review and
update training information. Radiation Safety training is directed by the Radiation Safety Officer. The
training includes the following items and topics:
• radioactive nature of the material being handled;
• fundamentals of handling radioactive materials;
• ionizing radiation and biological effects;
• radiation safety standards, principles and procedures;
• emergency procedures;
• methods of radiation protection; and
• a written or computer-based examination.

Records of training attendance and a copy of the examination provided are maintained by EnergySolutions.

8.4 EMERGENCY PLANNING

EnergySolutions’ Emergency Planning is appropriate for management of disposal facilities. No changes in
emergency planning is proposed in support of the proposed Federal Cell Facility. Clive Facility Procedure
CL-SH-PR-500, Contingency Implementation Plan, and EnergySolutions’ Contingency Plan (Attachment II-
6 of the state-issued Part B Permit) established emergency response requirements to protect personnel and the
environment in the event of an explosion, a fire, or an unplanned release to the environment. In addition to
EnergySolutions Clive staff, the Contingency Plan also applies to contractors and visitors at the Clive facility.
A copy of the current Contingency Plan is located next to every hard-wired telephone at the Clive Facility.

Notification of the implementation of the Contingency Plan is transmitted on the Emergency Channel or EMT
Channel of the Site Radio System and following the protocol established for emergency announcements on
the mobile phone system. Emergency communication lists are established as follows:
• Emergency Coordinators and Site Managers: Notifications are made via Assigned Mobile Phone
and/or e-mail to this distribution list.
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• Facility EMTs First Responders and Ambulance Drivers: Notifications are made to Assigned Mobile
Phones.
• Spill Response Team Members: Notifications are made to Assigned Mobile Phones.
• Facility Leads: Notifications are made to Assigned Mobile Phones (also include e-mail).
• All facility personnel: Notifications are made to group-assigned radios.

A radio group has been established for all facility EMTs. A radio compatible with transmission between
facility EMTs is also maintained in the security office and on the facility ambulance. Prior to the beginning
of each week the following responsibilities are assigned to qualified personnel:
• Emergency Coordinator
• EMT Leads
• Spill Response Team Leads

These designations are communicated in a weekly coordination meeting among the site management. An
ambulance driver is also specified.

Leaking waste shipments are managed and reported in accordance with the requirements found in the Licenses
and Permits. If the initial identifier observes liquids draining from a waste container or conveyance, the initial
identifier contacts Security and implements the Emergency Response Plan.

If the Spill Response Team Leader or Emergency Coordinator is unable to determine the source of the liquid,
they must direct action to be taken to control the leaking liquid and move the container into the restricted area
(if outside) so that further evaluation can be done to determine the source. The period of time for evaluation
will not exceed twenty-four hours.

If the Spill Response Team Leader or Emergency Coordinator determines that the liquid is potentially
contaminated by means of analytical (pH, radiation detection, etc.) or visual (obvious container integrity
breach, free liquids present inside the waste package, etc.) observation, the Division will be notified of the
incident within 24 hours.

At a minimum, measure the pH of the potentially contaminated liquid and record result(s) on 24 Hour/5 Day
Spill Notification Report. Liquid grab sample(s) for radiological analysis may be taken if at least 500 ml of
volume is collected.

Surface swipe for radiological or chemical analysis may be performed to identify contamination. All samples
submitted to the lab require a Chain of Custody. All reviewed analytical data and Chain of Custodies are
attached to the 24 Hour/5 Day Spill Notification Report.

8.5 REVIEW AND AUDIT

EnergySolutions’ program for facility review and audit is managed by the Quality Assurance Department.
EnergySolutions’ system or reviews and audits is appropriate for management of disposal facilities. No
changes in audit procedures are proposed in support of the proposed Federal Cell Facility. The Quality
Assurance audits and surveillances focus on facility operations staff’s review of operational activities, the
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independent review of facility operations, and the independent assessment of activities pertaining to safety
enhancement:
1. The functioning of the onsite organization with respect to the review of proposed changes to systems
or procedures and of unplanned events that have operational safety significance, including subject
matter to be reviewed, organizational provisions for conducting the reviews, and the documentation
and reporting of review activities;
2. The procedures and organization used to evaluate safety-related operational activities independent of
the operating organization, including how and when such a program is to be implemented, subject
matter to be reviewed, organizational provisions for conducting the review, and the documentation
and reporting of review activities; and;
3. The provisions to perform independent reviews and assessments of facility activities, including the
functions of the review group, organizational provisions for conducting the activities, and the
documentation and reporting of these activities.

8.6 FACILITY ADMINISTRATIVE AND STANDARD OPERATING PROCEDURES

EnergySolutions’ facility administrative and standard operating procedures are appropriate for management
of disposal facilities. No changes in administrative or operating procedures are proposed in support of the
proposed Federal Cell Facility.

8.7 PHYSICAL SECURITY

The Site’s physical security is managed in accordance with the Site Radiological Security Plan (referenced in
Condition 54 of Radioactive Material License UT2300249), which establish a barrier and a means to control
entry to accomplish the requirements of site security. EnergySolutions’ Site Radiological Security Plan is
appropriate for management of disposal facilities. No changes in the Site Radiological Security Plan are
proposed in support of the proposed Federal Cell Facility. Additional measures are also identified for specific
waste access areas within the Bulk Waste Facility. The Plan and procedures introduce a multi-layer security
model containing specific security controls for site access, Restricted Area boundary, and overall waste access.
This Plan applies to all personnel who access EnergySolutions’ facilities. The Plan and procedures further
define those subjects and locations germane to physical security, responsible individuals for the
implementation and requirements for site security. Security requirements are separated into three general
areas:
1. Site Access Boundary Controls: This area addresses population flow control into and out of the Site.
It includes security measures in place at the entrance gate to the facility and information electronically
gathered from individuals who badge into and out of the Site.
2. Restricted Area Access Controls: All personnel and equipment enter and exit the Restricted Area
through designated Access Control Points monitored by Health Physics personnel.
3. Waste Access Area Control: Security personnel perform daily random security searches on personnel
and vehicles accessing these areas. The railcar rollover and intermodal unloading facility are
monitored by security personnel, security cameras, or qualified access control personnel.

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SECTION 9. QUALITY ASSURANCE

EnergySolutions’ Quality Assurance Program is appropriate for operation of its disposal facilities.
EnergySolutions’ Quality Assurance Program addresses design, construction, and operations of the facility.
It includes a description of the management systems, assignments of responsibilities, and the organizational
structure necessary to accomplish the performance objectives of UAC R313-25. EnergySolutions sees the
Program as critical to prevent recurrence of problems. As such, root causes of problems are promptly
identified and corrected.

EnergySolutions’ policy is to perform all of the work activities comprising facility operations in such a manner
that required quality is attained or exceeded. In pursuit of this objective, EnergySolutions has developed a
Quality Assurance Program, which is consistent with guidance provided by the Nuclear Quality Assurance
Standard, ANSI/ASME NQA-1, Quality Assurance Program Requirements for Nuclear Facilities, and
satisfies the special needs of a LLRW disposal facility. This Program is described in the EnergySolutions’
Quality Assurance Program Document, containing a series of quality methods and procedures that define the
requirements. The EnergySolutions’ Quality Assurance Program is further documented by, and implemented
using more specific and detailed functional procedures. This Program will ensure that risks, safety, reliability,
and performance are maximized through the application of effective management systems commensurate with
the risk posed by the facility and its operations. In addition, this program will provide an environmental
management system to minimize environmental impacts with the prevention of pollution and continuous
improvement of environmental performance.

EnergySolutions’ organizational structure, functional responsibilities, levels of authority and lines of
communication for activities affecting quality are established and documented. The Director of Quality
Assurance is responsible for assuring that the Quality Assurance Program is established and verifying
activities affecting quality have been correctly performed. The Director of Quality Assurance has sufficient
authority, access to work areas and organizational freedom to:
• Identify quality problems;
• Initiate, recommend, or provide corrective actions to quality problems;
• Verify implementation of corrective actions; and
• Control further processing, installation or use of an item or activity until proper disposition of a
nonconformance, deficiency, or unsatisfactory condition has occurred.

The Director of Quality Assurance has direct access to responsible management at a level where appropriate
actions can be effected. The Director of Quality Assurance reports to the President of Waste Management.

Quality is achieved and maintained by those individuals who are assigned responsibility for performing the
work. Quality achievement is verified by other individuals not directly responsible for directing the work.
Where more than one organization is involved in the execution of verifying activities that affect quality, the
responsibility and authority of each organization shall be clearly established and documented.

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9.1 QUALITY ASSURANCE DURING THE DESIGN AND CONSTRUCTION

EnergySolutions’ Quality Assurance Program is appropriate for design and construction of its disposal
facilities. The Quality Assurance Program during construction is detailed in the FCF CQA/QC Manual.

EnergySolutions has established measures to define, control and verify design. Applicable design inputs is
appropriately specified on a timely basis and correctly translated into design documents. Design interfaces
shall be identified and controlled. Persons other than those who designed the item verify design adequacy.
Design changes, including field changes, are governed by control measures commensurate with those applied
to the original design. Design documents are adequate to support facility design, construction, and operation.
Appropriate quality standards are identified and documented, and their selection reviewed and approved.
Changes from specified quality standards, including the reasons for the changes, are identified, approved,
documented and controlled.

9.2 QUALITY ASSURANCE DURING OPERATION

EnergySolutions’ Quality Assurance Program is appropriate for operation of its disposal facilities. The Quality
Assurance Program is implemented through the following documents:
• The Statement of Corporate Quality Assurance Policy;
• Quality Assurance Program Document;
• Quality Assurance Procedures; and
• Implementing Procedures – Controlled documents that prescribe processes (a sequence of actions) to
be performed to achieve a desired outcome. Implementing procedures may apply to the entire
company, an organization, a program or a project.

The Program identifies the activities and items to which it applies. The Program includes considerations of
the technical aspects of the activities affecting quality. The Program provides control over activities affecting
quality to the extent consistent with their importance. The Program provides assurance that activities affecting
quality are documented and accomplished in accordance with written procedures, instructions and drawings.

The Program provides for the accomplishment of activities affecting quality under controlled conditions. Such
conditions include the use of appropriate equipment, suitable environmental conditions, and prerequisites for
a certain activity have been satisfied. The Program considers the need for special controls, processes, test
equipment, tools and skills to attain the required quality and verification of quality. The Program provides for
indoctrination and training of personnel performing quality related activities to assure that proficiency is
achieved and maintained.

The Director of Quality Assurance reports to the President, Waste Management and is responsible and
accountable for the effective implementation of the Quality Assurance Program. The CQAM has the
authority, responsibility, and accountability for establishing and maintaining the Quality Assurance Program.
Vice Presidents, Corporate Directors and Managers, and Facility/Department Leads (EnergySolutions
Management) have the authority, responsibility and accountability for establishing and maintaining programs
and procedures consistent with the system description provided in this document. EnergySolutions
Management may delegate tasks to contributing individuals or organizations, but they retain overall
responsibility for:
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• Providing resources to accomplish quality objectives in each work task;
• Continuously improving processes, products, and services;
• Ensuring that schedule and budget considerations are not used to compromise the attainment of the
requisite level of quality;
• Identifying, monitoring, evaluating, and reporting results of selected performance indicators;
• Providing employees with adequate education and training;
• Participating in recommending specific changes to policy, programmatic, or procedural documents;
• Identifying, preparing and approving procedures necessary to implement requirements applicable to
the scope of work;
• Working with support organizations to resolve concerns and issues; and
• Conducting management assessments.

All employees of EnergySolutions are responsible for achieving quality in their activities. Employees are
empowered by Management to continuously improve their performance, identify and report problems, and
participate in their resolution. For each employee who enters the Clive Facility Restricted Area and is likely
to have received in a year an occupational dose requiring monitoring, Clive management:
• Determines the occupational radiation dose received during the current year; and
• Attempts to obtain the records of lifetime cumulative occupational radiation dose.

Clive management may also:
• Accept as a record of the occupational dose that the individual received during the current year, a
written signed statement from the individual, or from the individual’s most recent employer for work
involving radiation exposure that discloses the nature and the amount of any occupational dose that
the individual may have received during the current year;
• Accept, as the record of lifetime cumulative radiation dose, an up-to-date NRC Form 4, or equivalent
signed by the individual and countersigned by an appropriate official of the most recent employer for
work involving radiation exposure, or the individual’s current employer (if the individual is not
employed by EnergySolutions); and
• Obtain reports of the individual’s dose equivalent(s) from the most recent employer for work
involving radiation exposure, or the individual’s current employer (if the individual is not employed
by EnergySolutions) by telephone, electronic media, or letter. EnergySolutions may request a written
verification of the dose data if the authenticity of the transmitted report cannot be established.

Clive management records the dose history, as required on NRC Form 4 or other clear and legible record, of
all the information required on the form. The form or record shows each period in which the individual
received occupational dose to radiation or radioactive material. For each period for which Clive management
obtains reports, Clive management uses the dose shown in the report in preparing NRC Form 4. For any
period in which Clive management does not obtain a report, Clive management places a notation on NRC
Form 4 indicating the periods of time for which data are not available. Records of all employees whom
monitoring was required and records of doses received during planned special exposures, accidents, and
emergency conditions include, when applicable:
• DDE, EDE, SDE to the skin, and SDE to the extremities;
• The estimated intake or body burden of radionuclides;
• The CEDE assigned to the intake or body burden of radionuclides;
• Specific information used to calculate the CEDE ;
• The TEDE when required; and
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• The total of the DDE and the ODE to the organ receiving the highest total dose.

Personal dose records are updated at least annually. Personal dose records are maintained on NRC Form 5 or
in clear and legible records containing all the information required by NRC Form 5. Electronic records are
maintained until license termination. Hardcopy records are maintained in accordance with the CL-QA-PR-
005, Quality Assurance Records. Required personal dose records are protected from public disclosure.
Records of dose to an embryo/fetus are maintained with the dose to the declared pregnant woman.
Declarations of pregnancy, including the estimated date of conception, are also kept on file. Radiation dose
records contain information sufficient to identify each person, or employee number.

EnergySolutions’ procurement system ensures that items and services comply with established requirements
and perform as specified. Applicable design bases and other requirements necessary to assure adequate quality
are included or referenced in documents for the procurement of items or services. Design and operational
requirements are incorporated into corresponding purchase requirements so that prospective suppliers are
evaluated before orders are placed; and that items received, and services provided are verified as complying
with purchase requirements.

Procedures provide instructions for identifying, controlling, distributing and approving documents, including
those provided by the supplier. They also specify criteria for purchasing commercial grade items and for
preventing the purchase of suspect or counterfeit material. Procurement documents require that all suppliers
have an established management system that implements appropriate controls for the service of items being
procured. The extent of the program required depend on the type and use of the item or service being procured.

Activities affecting quality are prescribed by documented instructions, procedures, or drawings of a type
appropriate to the circumstances and are accomplished in accordance with these instructions, procedures, or
drawings. Instructions, procedures, or drawings include appropriate quantitative or qualitative acceptance
criteria for determining that prescribed activities have been satisfactorily accomplished.

EnergySolutions controls the preparation, approval, issue, and changes of documents that specify quality
requirements or prescribe activities affecting quality. Such documents, including changes thereto, are
reviewed for adequacy, and approved for release by authorized personnel. Document Control is the act of
assuring that documents are reviewed for adequacy, approved for release by authorized personnel, and
distributed to and used at the location where the prescribed activities performed.

EnergySolutions’ control system provides for:
• Identification of documents to be controlled and their specific distribution;
• Assignment of responsibility for preparing, reviewing, approving, and issuing documents;
• Review of documents for adequacy, completeness, and correctness prior to approval and issuance.

Revisions to documents are reviewed and approved by the same individuals or organizations that performed
the original review and approval.

EnergySolutions assures that only correct and accepted items are used, treated, installed or disposed.
Identification shall be maintained on the items or in documents traceable to the item, or in a manner, which
assures that identification is established and maintained. Physical identification is the preferred method of
identification. Where physical identification on the item is either impractical or insufficient, physical
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segregation, procedural control, or other appropriate means are employed. When specified by permits,
licenses, or specifications that include specific identification or traceability requirements, the program is
designed to provide such identification and traceability control.

EnergySolutions plans and executes inspections required to verify conformance of an item or activity to
specified requirements. Inspection results are documented. Persons other than those who perform or directly
supervise the activity perform inspections for acceptance. Inspection requirements and acceptance criteria
include specified requirements contained in the applicable design documents or other pertinent technical
documents. Inspection activities are documented and controlled by instructions, procedures, drawings,
checklist, travelers, or other appropriate means.

Each person who verifies conformance of work activities for the purpose of acceptance is qualified to perform
the assigned inspection task. Inspections by persons during on-the-job training for qualification are performed
under direct supervision of a qualified person and verification of conformance is by the qualified person until
certification is achieved. Inspection of items in process or under construction is performed for work activities
where necessary to verify quality. If inspection of processed items is impossible or disadvantageous, indirect
control by monitoring of processing methods, equipment, and personnel is provided. Both inspection and
process monitoring is provided when control is inadequate without both.

Completed items are inspected for completeness, markings, calibration, adjustments, protection from damage
or other characteristics as required to verify quality and conformance of an item to specified requirements.
Final inspections include a record review of the results and resolution of nonconformance identified by prior
inspections. Inspection and test records as a minimum identify the following:
• Item inspected,
• Date of inspection,
• Inspector,
• Type of observation,
• Results or acceptability, and
• References to information or action taken in connection with nonconformance

EnergySolutions plans and executes tests required to verify conformance of an item or of a computer program
to specific requirements and to demonstrate satisfactory performance for service. Characteristics to be tested
and test methods to be employed are specified. Test results are documented and their conformance with
acceptance criteria shall be evaluated.

Test requirements and acceptance criteria are provided or approved by the organization responsible for design
of the item to be tested. Required tests, including, as appropriate, prototype qualification tests, production
tests, proof tests prior to installation; construction tests, pre-operational tests and operation tests, hardware
integration, verification test, or in-use tests are controlled. Test requirements and acceptance criteria are based
upon specified requirements contained in applicable design or other pertinent technical documents.

Test procedures include or reference test objectives and provisions for assuring that prerequisites for a given
test have been met. In lieu of specially prepared written test procedures, appropriate sections of related
documents, such as ASTM methods, supplier manuals, equipment maintenance instructions, or approved
drawings with acceptance criteria can be used. Such documents include adequate instructions to assure the
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required quality of work. Test results shall be documented and evaluated by a responsible authority to assure
that test requirements are satisfied.

Tools, gauges, instruments and other measuring and test equipment used for activities affecting quality are
controlled and at specific periods calibrated and adjusted to maintain accuracy within necessary limits. The
selection of measuring and test equipment are controlled to assure that such items are of proper type, range,
accuracy and tolerance to accomplish the function for determining conformance to specified requirements.

Measuring and test equipment are calibrated, adjusted, and maintained at prescribed intervals or, prior to use,
against certified equipment having known relationships to nationally recognized standards. If no nationally
known standard exists, the basis for the calibration shall be documented. Measuring and test equipment is
calibrated at intervals depending on the required accuracy, intended use, stability characteristics and other
conditions affecting the performance of the instrument.

When measuring and test equipment is found to be out of calibration, an evaluation is performed and
documented of the validity of previous inspection or test results and the acceptability of the items previously
inspected or tested. Out-of-calibration devices are tagged and segregated and not used until they have been
recalibrated. If any measuring or test equipment is consistently found to be out of calibration, it is repaired or
replaced. A calibration is performed when the accuracy of the equipment is suspect.

Calibration and control measures are not required for rulers, tape measures, levels and other such devices;
normal commercial equipment provides adequate accuracy. These items must be treated with care to prevent
damage or excessive wear and be replaced before accuracy becomes questionable. Measuring and test
equipment are properly stored and handled to maintain accuracy. Calibration records are be maintained and
equipment shall be suitably marked to indicate calibration status. EnergySolutions controls handling, storage,
packaging, shipping and preservation of items to prevent damage or loss and to minimize deterioration.

Handling, storage and shipping of items is conducted in accordance with established work and inspection
instructions, drawings, specifications, shipment instructions, or other pertinent documents or procedures
specified for use in conducting the activity. Specific procedures are used when required for critical, sensitive,
perishable or high-value articles.

Instructions for marking and labeling for packaging, shipment, handling, and storage of items are established
as necessary to adequately identify, maintain and preserve the item, including indication of the presence of
special environments or the need for special controls. The status of inspection and test activities is identified
either on the items or in the documents traceable to the items where it is necessary to assure that required
inspections and tests are performed and to assure that items which have not passed the required inspections
and tests are not inadvertently installed, used or operated. Status is maintained through indicators, such as
physical location and tags, markings, travelers, inspection records or other suitable means. The authority for
the application and removal of tags, markings and labels is specified. Status indicators are also provided for
indicating the operating status of systems and components of the facility, such as tagging valves and switches,
to prevent inadvertent operation.

EnergySolutions controls items that do not conform with specified requirements to prevent inadvertent use or
installation. Controls provide for identification, documentation, evaluation and segregation when practical
and disposition of nonconforming items, and for notification of affected organizations. Identification of
nonconforming items is by marking, tagging, or other methods, which do not adversely affect the end use of
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the item. The identification is legible and easily recognizable. If identification of each container is not
practical, the container, package, or segregated storage area, as appropriate, is identified.

Nonconforming characteristics are reviewed, and recommended dispositions of nonconforming items are
proposed and approved in accordance with documented procedures. Authorized personnel control further
processing, delivery, installation or use of a nonconforming item pending an evaluation and an approved
disposition. The responsibility and authority for the evaluation and disposition of nonconforming items is
defined. Personnel performing evaluations to determine a disposition are competent and they have an adequate
understanding of the requirements and have access to pertinent background information.

The disposition, such as use-as-is, reject, repair or rework of nonconforming items are identified and
documented. Technical justification for the acceptability of a nonconforming item, dispositioned repair or
use-as-is is documented. Nonconformance to design requirements dispositioned use-as-is or repair is subject
to design control measures commensurate with those applied to the original design. The as-built records, if
such records are required, will reflect the accepted deviation.

Repaired or reworked items are reexamined in accordance with the applicable procedures and with the original
acceptance criteria unless the nonconforming item disposition has established alternate acceptance criteria.
Conditions adverse to quality are identified promptly and corrected. In the case of a significant condition
adverse to quality, the cause of the condition is determined, and corrective action taken to preclude recurrence.
The identification, cause and corrective action for conditions adverse to quality are documented and reported
to appropriate levels of management. Follow-up action are taken to verify implementation of this corrective
action.

Corrective actions are prescribed in written form that provides adequate control; and are documented in a
manner that permits reviewing, evaluating and verifying the results of the activities. Where corrective or
preventive measures have already been taken to address conditions adverse to quality based on the program
elements covered in design, nonconformance surveillance or audit, no further action is required under that
element unless the conditions are judged to be significant. Conditions adverse to quality are defined as follows:
• Deficiencies in design, manufacturing, construction, testing, or process requiring substantial rework,
repair or replacement.
• Loss of essential data.
• Repeated failure to implement a portion of an approved procedure.
• Deviations from licensing or permit requirements.

Records that furnish documentary evidence of quality are specified, prepared and maintained. Records are
legible, identifiable and retrievable. Records are protected against damage, deterioration, or loss.
Requirements for record transmittal, distribution, retention, maintenance and disposition are established and
documented. An electronic record system is established, and this system is defined, implemented and enforced
in accordance with written procedures or instructions.

The applicable design specification, procurement documents, test procedures, operational procedures or
quality procedures specify the records to be generated, supplied or maintained by or for EnergySolutions’
documents that are designated to become records are legible, accurate, and completed appropriate to the work
accomplished. When required, records are corrected in accordance with procedures, which provide for
appropriate review or approval. The correction includes the date and the identification of the individual
making the correction.
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Each organization responsible for the receipt of records designates an individual responsible for receiving the
records. This individual or organization is responsible for implementing a receipt control system. Records are
stored in a manner to preclude deterioration or damage of the records. Provisions are made in the storage
arrangement to prevent damage from moisture, temperature, and pressure. Records are firmly attached in
binders, or placed in folders or envelopes for storage in steel file cabinets or shelving in containers.

EnergySolutions performs audits and has audits performed to verify compliance with all aspects of the quality
assurance program and to determine its effectiveness. These audits are performed in accordance with written
procedures by personnel who do not have direct responsibility for performing the activities being audited.
Audit results are documented and reported to and reviewed by responsible management. Follow-up action is
taken where indicated. In support of the Federal Cell Facility, EnergySolutions’ Quality Assurance Program
will largely remain unchanged from that in use for other waste disposal operations. The information
supporting License UT2300249 indicate that the requirements of UAC R313-25-7(10) will be met.
EnergySolutions’ Operating Procedures describe the steps used to ensure and document quality affecting
operational activities. Waste receipt, handling, and emplacement procedures are provided to the Director.
Controls used to ensure the independence, control, and reporting relationships of auditing personnel are
described in the manual. In addition, response to non-conformances and corrective action requests are
described in the manual.
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SECTION 10. FINANCIAL ASSURANCE

Surety protects the State of Utah and DOE from the need to fund the closure and post-closure care of the Clive
Disposal Complex. The Surety provides adequate monies for site decommissioning, reclamation and ongoing
monitoring in the event that EnergySolutions is unable to provide funds at the time of closure. The amounts
required to be pledged for closure and post-closure sureties are based on third-party closure to the standards
approved by the Director. The Director and DOE can annually review and confirm that EnergySolutions’
financial sureties are appropriate to protect the State of Utah’s citizens from financial burdens in the event of
premature facility closure. The surety funding projections are based on third-party estimates for the amount
of funding required to:
• Decontaminate, treat, and/or dispose of all contaminated equipment, structures, and soils;
• Place all waste material in the appropriate disposal embankment;
• Close the embankment(s) as outlined in EnergySolutions’ Permit and Licenses; and
• Complete required post-closure monitoring and inspections.

10.1 FINANCIAL QUALIFICATIONS OF ENERGYSOLUTIONS

EnergySolutions herein provides information to demonstrate that its financial qualifications are adequate to
carry out the activities contemplated in this Application and the financial assurances required in UAC R313-
25-32.

10.1.1 Legal Description of EnergySolutions

EnergySolutions is an international nuclear services company headquartered in Salt Lake City, Utah, with
operations throughout the United States, Canada and Japan. EnergySolutions is an industry leader in the safe
recycling, processing and disposal of nuclear material, providing a full range of Decommissioning and
Decontamination (D&D) services to shut down nuclear power plants. EnergySolutions’ customers include
the United States Government, all United States Nuclear Power Plants, along with various medical and
research facilities. In May 2013, Energy Capital Partners (ECP) acquired EnergySolutions in a take-private
transaction. As a private ECP subsidiary, EnergySolutions continues its focus on U.S. nuclear power plants’
on-going waste disposal and end-of-life decommissioning needs.

Ken Robuck was appointed President and Chief Executive Officer of EnergySolutions in July 2018. Mr.
Robuck joined EnergySolutions in August 2013 as President of the Company’s Disposal and Nuclear
Decommissioning Division. Ken brings a wealth of experience and knowledge of the utilities industry and
in developing and managing new areas and markets. Prior to joining EnergySolutions, Mr. Robuck was
President of Williams Industrial Services Group, LLC, from 2006, where he was responsible for the
management of a multi-regional, industrial construction and maintenance company, serving a broad
customer base including petrochemical, steel, and power (both fossil and nuclear).

Jeff Richardson serves as Chief Operating Officer and is responsible for all aspects of company operations
for decommissioning, waste management, processing, logistics, and disposal as well as companywide
strategic initiatives and execution. Additionally, he leads the environmental, health & safety, regulatory
affairs, project management & controls, and quality assurance functions within EnergySolutions. Jeff has
over 30 years of power generation and nuclear operating experience. Specifically, his background includes
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developing, leading, & managing complex, multidiscipline projects, teams, & initiatives ranging from
construction megaprojects, corporate reorganizations, new business development, major engineering
initiatives, supply chain management/alliances, & organizational transformations.

Greg Wood was appointed Executive Vice President and Chief Financial Officer (CFO) of EnergySolutions
in June 2012. He previously served as Executive Vice President and CFO for Actian Corporation, a provider
of database and data analytics software. Prior to joining Actian, Mr. Wood held chief financial officer roles
at numerous public and private companies, including Silicon Graphics, Liberate Technologies, and
InterTrust Technologies.

John Sauger serves as President and Chief Nuclear Officer Reactor D&D and is responsible for all
commercial D&D projects. Mr. Sauger has more than 30 years of commercial nuclear experience covering
the entire nuclear life cycle. John was the original decommissioning manager for the Maine Yankee project
where he developed risk and project management systems, contract acquisition strategy, and led the first
year of decommissioning execution. Since 2013, John has led a fast‑paced transformation of the Zion
Station decommissioning project such that Zion is the benchmark against which future decommissioning
projects will be measured. As a utility executive, Mr. Sauger led the completion of the refurbishment of the
Bruce Nuclear Units 1 and 2 in Canada.

Russ Workman was appointed as General Counsel and Corporate Secretary in 2012. Prior to his
appointment, Mr. Workman had 22 years of experience advising and representing U.S. and international
companies in commercial transactions, litigation, and corporate governance. Mr. Workman is licensed to
practice in Utah and admitted to practice before the 10th Circuit Court of Appeals.

Brent Shimada, Senior Vice President Human Resources has been with EnergySolutions since July 2011.
Prior to joining EnergySolutions, Mr. Shimada was Vice President Administration and General Counsel for
Otix Global, Inc. (formerly Sonic Innovations, Inc.) (NYSE: OTIX), from October 2004. Between May
1999 to October 2004, he was Human Resources Director for American Express’ Global Travelers Cheque
Operations Group. Mr. Shimada served as Senior Corporate Counsel for grocery and drug retail
conglomerate, American Stores Company from 1996 to 1999. He was Legal Counsel for Alliant
Techsystems, Inc. (formerly Hercules Incorporated), a government contractor, from 1985 to 1996.

Joseph Heckman is President of EnergySolutions’ Waste Management Division, joining EnergySolutions in
September 1997. He has held various management positions throughout EnergySolutions, including
Operations Director of the Erwin ResinSolutions Facility and General Manager of Bear Creek Processing
Operations. Mr. Heckman began his career at EnergySolutions as a Radiation Safety Technician at the
Clive facility. Prior to joining EnergySolutions, Mr. Heckman held radiation safety positions in commercial
nuclear power plants, Department of Energy facilities, and environmental remediation sites.

10.1.2 Description of EnergySolutions’ Operations

EnergySolutions owns, operates and maintains a network of environmental infrastructure assets critical to
the U.S. nuclear industry that are among the largest commercial disposal facilities, processing facilities and
logistics and transportation businesses for low-level radioactive waste in the United States. Virtually all
nuclear plants in the U.S. and the U.S. Department of Energy use the company service offerings, and the
company is active in decommissioning multiple nuclear plants, including San Onofre Nuclear Generation
Station, Unit 2 of Three Mile Island and the Fort Calhoun Nuclear Generating Station.
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EnergySolutions owns and operates the Clive disposal facility, located in the West Desert of Utah
approximately 75 miles west of Salt Lake City. The Clive disposal facility plays a vital role in the nuclear
industry as a safe and compliant option for permanent disposal of radioactive waste, including soil and
debris from clean-up sites; low level waste created nuclear power plants; byproducts and equipment used in
the nuclear power generation; byproducts used in nuclear power plants; radioactive material from DOE
cleanup sites; and radioactively contaminated medical waste. EnergySolutions provides disposal services for
both the commercial and government nuclear industry including nuclear power plants, industrial and
research companies, hospitals, universities, DOE, Department of Defense, and many other companies and
state/federal agencies.

The Clive disposal facility is also permitted to accept Mixed Waste, which is a combination of both RCRA
hazardous and radioactive waste. Treatment technologies include macro encapsulation of radioactive lead
solids and hazardous debris, stabilization of heavy metals, neutralization and solidification of contaminated
liquids, thermal treatment of waste containing organic solvents, amalgamation of elemental mercury, and
treatment of other unique waste streams.

EnergySolutions also operates the Barnwell Disposal Facility, which is owned by the State of South
Carolina. The facility is the host disposal site for the Atlantic Compact which is comprised of South
Carolina, New Jersey, and Connecticut. The Facility began operations in 1971 and has provided continuous
disposal operations for over 45 years. The site is licensed to dispose of Class A, B and C low-level wastes,
including irradiated hardware and large components, steam generators, resins, and reactor pressure vessels.
Located with the Barnwell Disposal Facility, EnergySolutions also owns and operates the Barnwell
Processing Facility at which power plant resins are dewatered, waste is solidified and liquid waste
undergoes an evaporation processes.

EnergySolutions also owns the Bear Creek Processing Facility, located near Oak Ridge, Tennessee. The
facility’s primary function is the safe processing and packaging of radioactive material for permanent
disposal. Volume reduction and repacking of the material is the primary goal of the facility. The facility
houses radioactive materials processing capabilities including bulk waste assay, decontamination, recycle,
compaction, incineration, metal melting, and a variety of specialty waste stream management options. The
facility operates under regulatory authority of the state of Tennessee Department of Environment and
Conservation (TDEC) Division of Radiological Health (DRH) in agreement with the NRC.

EnergySolutions also owns the Erwin ResinSolutions Facility located in Erwin, Tennessee. This facility
utilizes an innovative solution for spent ion-exchange resins from U.S. commercial nuclear power plants.
The patented Steam Reforming Process safely dewaters, chemically reforms, homogenizes and reduces the
volume of spent ion-exchange resins into a solid-phase, stable waste form. Once the Steam Reforming
Process has been applied, the residual solid material is packaged and prepped for transportation to the
EnergySolutions Clive Disposal Facility located in Utah West Desert.

EnergySolutions' subsidiary, Hittman Transport Services, is the premier transporter of low-level radioactive
waste in the country, and one of the largest trucking companies for hauling nuclear fuel in the United States.
Its fleet logs millions of miles per year, transporting shipping casks, vans, and flatbeds throughout the
United States and Canada. Hittman began supporting the nuclear industry in 1977 and since this time has
accumulated over 148 million safely-driven miles. Hittman – as an average – logs over 8 million miles per
year and transports over 300 radioactive shipments per month.
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EnergySolutions also owns Hittman Transport Services, Inc., which supplies the company with logistics
capabilities. Hittman assists customers to efficiently transport materials for processing and disposal in a safe
and effective manner. Hittman’s transport specialists are responsible for delivering these materials over
millions of miles every year, by ensuring that all shipments are routinely inspected during transport to
identify any situation that could compromise the shipment while in transition. To support their logistic
needs, Hittman owns and offers a unique suite of tractor-trailers and containers that are dedicated to
radioactive waste transport.

EnergySolutions’ MHF Services subsidiary owns and operates five permanent transload facilities to enable
safe and secure method of transferring bulk or packaged materials between truck, rail, and marine
conveyance systems. MHF Services also provides flexible and durable packaging products for a wide range
of industrial and environmental applications. Working closely with customers to understand specific
packaging requirements, MHF recommends optimal solutions for individual project requirements.
EnergySolutions’ MHF team comprises the nation’s premiere group of waste transportation, logistics,
packaging, and disposal management experts, with extensive experience managing large volumes of waste
from point of origin to disposal for DOE, USACE, and EPA—as well as commercial clients.

Finally, EnergySolutions Nuclear Plant Services subsidiary provides full design and engineering capabilities
including industry standard 3-D rendering/modeling capabilities, development of specialty water treatment
medias, development of new technologies for the nuclear industry, development of specialized high activity
liquid water processing systems (currently in use at Fukushima, Japan), material balance and process flow
calculations, production of process flow diagrams, piping and instrumentation diagrams and complete
design/build capabilities for radwaste processing systems; coded pressure vessels; remote/automatic
handling equipment maximizing ALARA; complete shielding packages maximizing ALARA; licensed
shielded transport cask; instrumentation and control definition and design for all process and mechanical
systems; process and special radiological instrument design and specification; load analysis and power
distribution and Closed Circuit Television and communication systems.

10.1.3 EnergySolutions’ Detailed Financing Plan

In accordance with UAC R313-25-33(6), EnergySolutions annually submits a copy of its financial
statements within 30 days of its completion and certification (most recently on April 27, 2020 via CD20-
0073). In addition to annual sureties pledged, this information provides the Director with additional
justification for a determination of financial stability. EnergySolutions’ annual Consolidated Financial
Statements are transmitted to the Director under claim of business confidentiality (pursuant to Utah Code
Subsections 63G-2-305(2) through (4), and in accordance with Section 63G-2-306). EnergySolutions asserts
a claim of business confidentiality over the annual financial statements to protect EnergySolutions from
detrimental effects from the release of the information to members of the public, industry and competitors.

10.1.4 Parent Company Activities

In May 2013, ECP acquired EnergySolutions, Inc., in a take-private transaction. ECP focuses on acquiring
existing and new-build energy infrastructure projects primarily in North America. To successfully invest in
the energy sector, ECP provides marshal’s meaningful capital with significant domain knowledge and
extensive industry relationships. ECP’s team focuses extensive industry experience on industry scale, asset
ownership, and facilitated long-term relationships with industry executives and key strategic players. ECP
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actively manages its assets and businesses alongside management teams to execute growth strategies and
generate efficiencies. Core to ECP’s infrastructure is a focus of strategies across the entire portfolio to
allocate cash flows and value to protecting the downside of investments in lieu of maximizing upside return
potential. ECP’s applicable financial forms and bond ratings is included in the annual statements
referenced in Section 10.1.3.

10.2 FUNDING ASSURANCES

EnergySolutions herein demonstrates that the requirements of UAC R313-25-32 will be met. Additionally,
the closure and post-closure bonds will be secured from agencies that have legal authority to provide this
financial assurance in the State of Utah (where the proposed Federal Cell Facility will be located). Included
in this Application are third-party generated estimates of the cost of Federal Cell Facility closure and
stabilization. A detailed breakdown and explanation of the assumptions used by the third-party to produce
the cost calculations is also provided.

10.2.1 Premature Closure

EnergySolutions expects to close the Federal Cell Facility and perform the required maintenance and
monitoring. However, in order to protect the State of Utah and DOE from having to fund premature closure
of the Federal Cell Facility (in the event that EnergySolutions is unwilling or unable to do so), additional
monies will be added to the Clive Disposal Facility surety to specifically address the premature closure of the
Federal Cell Facility (in accordance with regulatory requirements).

As is included in Appendix R, the amount of financial surety is the amount estimated for the placement of
applicable contaminated material in storage into the Federal Cell Facility, for decommissioning and
decontamination of the Federal Cell Facility, for premature completion of Federal Cell Facility construction
to the required standards, to perform all required post closure monitoring and maintenance activities and to
transition its long term care stewardship to DOE. The volume of unplaced waste included in the Federal Cell
Facility surety calculations serves as a compliance point, limiting the volume of waste requiring placement to
less than the funds secured in surety. The Decontamination and Decommissioning Plan and the
Environmental Monitoring Plan of Radioactive Material Licenses UT2300249 and UT2300478 form the basis
for surety calculations.

EnergySolutions follows NRC, State of Utah, and EPA guidelines in developing its Clive Disposal Facility
surety.
• NRC instructs that surety calculations should include, “a detailed site-specific cost estimate for
decommissioning, based on the costs of an independent contractor to meet the criteria for unrestricted
use in 10 CFR 20.1402” (U.S. Nuclear Regulatory Commission. (2012), Consolidated
Decommissioning Guidance: Financial Assurance, Recordkeeping, and Timeliness – Final Report,
NUREG-1757, Volume 3, Revision 0, February 2012).
• UAC R313-25-31(1)(b) states “[T]he applicant’s cost estimates shall take into account total costs
that would be incurred if an independent contractor were hired to perform the closure and
stabilization work.”
• UAC R315-264-142(a)(2) states, “[T]he closure cost estimate shall be based on the costs to the owner
or operator of hiring a third party to close the facility.”

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Furthermore, Utah Code §19-3-104(12)(f)(ii) allows the following option for a Licensee or Permittee to
determine closure and post closure costs:
“(A) for an initial financial assurance determination and for each financial assurance
determination every five years thereafter, a competitive site-specific bid for closure and post-
closure care of the facility at least once every five years; and
(B) for each year between a financial assurance determination described in Subsection
(12)(f)(ii)(A), a proposed financial assurance estimate that accounts for current site
conditions and that includes an annual inflation adjustment to the financial assurance
determination using the Gross Domestic Product Implicit Price Deflator of the Bureau of
Economic Analysis, United States Department of Commerce, calculated by dividing the latest
annual deflator by the deflator for the previous year;”

Based on these regulatory requirements, EnergySolutions commissioned an independent evaluation by a
facility decommissioning- and closure-experienced third-party entity to estimate the process and activities
associated with all premature closure activities for the Clive Disposal Facility. This process was completed
in March 2021 and the combined surety calculations are currently under review by the Director. Subsequent
annual reviews after 2021 combined surety is approved will account for current site conditions and include
annual inflation adjustments. Clive Disposal Complex annual surety reviews conducted after this licensing
action will include evaluation of the premature closure of the Federal Cell Facility. The calculations and cost
estimates will be included in the Director’s annual review and adjustment to assure that the amount remains
appropriate to account for inflation, construction of new facilities, and other cost adjustments.

A summary of each necessary surety decommissioning activities for the Federal Cell Facility is presented
below. Each summary includes the general location of the item; a brief description of the item; how the item
will be decommissioned; and any major assumptions. References will be included for construction
specifications of the Federal Cell Facility Construction Quality Assurance / Quality Control Manual
(Appendix I). Details of premature embankment closure construction are presented in Appendix R.
31. Placement of Material
This item includes the maximum volume of depleted uranium that is allowed on-site in
container or bulk storage awaiting disposal. This surety item’s volume storage limit is
expected to be reflected as a condition to the Radioactive Material License authorizing
depleted uranium disposal in the Federal Cell Facility. During premature closure, sufficient
funds will be pledged so that all depleted uranium waste in storage or in conveyances at the
site are offloaded and placed in the Federal Cell Facility, in accordance with current
construction requirements. This surety item conservatively assumes the maximum volume
allowed is in storage or on site at the time of closure.
204. Liner/Liner Protective Cover
This item includes the use of clay and soil materials to construct additional cell liner and
cover necessary to complete premature closure of the Federal Cell Facility. This activity will
include the excavation of native clays and soils from surrounding areas and placement in the
embankment to specification and design.
205. Settlement Monitoring of Temporary Cover
In accordance with embankment construction requirements, fill and temporary cover will be
placed to specification over the depleted uranium waste and settlement monuments placed
on a 150-foot grid over the top slope of the embankment. The proposed temporary cover for
the Federal Cell Facility is a one-foot-thick layer of native soil and is monitored for settlement
prior to final cover construction. This item includes the cost of excavation and placement of
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the required volume of native soil (and overburden) along with the purchase and placement
of settlement monuments. The item also includes costs of monument surveys and
engineering reviews for the required one year of settlement monitoring.
207. Cover Construction
This item will include construction of the final cover over the Federal Cell Facility, roads and
drainage ditches around the Facility, and the installation of permanent monuments for the
Facility. The final cover consists of several elements including radon barriers, a filter zone,
and a rock erosion control barrier. Radon barrier borrow material will be excavated from
adjacent sections owned by EnergySolutions. Rock will be imported from the BLM quarry
located approximately five miles north of the Facility. The rock will be screened to meet
applicable gradation requirements for the individual cover layers. The final cover area will
be based on the premature closure plan and updated each year as part of the annual surety
review.
211. Final Cover Settlement Monitoring
In accordance with embankment construction requirements, final cover will be placed to
specification over the depleted uranium waste and settlement monuments placed on a 150-
foot grid over the top slope of the embankment. This item includes the cost of excavation
and placement of the required volume of native soil (and overburden) along with the purchase
and placement of settlement monuments. The item also includes costs of monument surveys
and engineering reviews for the required one year of settlement monitoring.
300. SG&A Overhead Costs
In accordance with EnergySolutions’ 2021 third-party surety estimate, a contractor charge of
5.5% of the sum of direct costs will be required for general and administrative expenses.
302. Contingency
In accordance with EnergySolutions’ 2021 third-party surety estimate, a contractor charge of
10% of the sum of direct costs will be required as contingency for unanticipated expenses.
303. Engineering and Redesign
In accordance with EnergySolutions’ 2021 third-party surety estimate, a contractor charge of
2.25% of the sum of direct costs will be required to account for engineering analysis and
redesign for premature closure of the Federal Cell Facility.
304. Profit and Overhead
In accordance with EnergySolutions’ 2021 third-party surety estimate, a contractor charge of
10% of the sum of direct costs will be required for contractor profit and overhead expenses.
305. Management Fee and Legal Expenses
In accordance with EnergySolutions’ 2021 third-party surety estimate, a contractor charge of
4% of the sum of direct costs will be required for project management and legal expenses.
306. DEQ Oversight of Project
In accordance with EnergySolutions’ 2021 third-party surety estimate, a contractor charge of
4% of the sum of direct costs will be required for regulatory oversight during premature
closure.
320. Facility Stewardship Transfer to DOE
Transfer of stewardship from DWMRC oversight to DOE-LM is projected to require 2
individuals for 5 years.
400. Perpetual Surveillance
This item includes the annual inspections and maintenance that will be performed at the
Federal Cell Facility and off-site features that may have been impacted by operations. In
addition to an embankment survey, this section includes costs to annually sample external
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radiation exposures from the embankment and atmospheric radon gas flux from the Federal
Cell Facility. The long-term surveillance monitoring includes is intended to ensure that the
Federal Cell Facility and other required elements perform as intended and that there are no
adverse impacts to the environment or the public due to degradation of these elements. This
item includes inspection of the embankments, fencing, roads, etc. and the performance of any
maintenance on these elements. Since funding for soils, airborne dust particulate and
groundwater leachate migration surrounding the Clive Disposal Complex licensed footprint
for low-level radioactive waste and 11e.(2) byproduct disposal, they are not duplicated in
Section 400.

The financial assurance mechanism proposed for premature closure of EnergySolutions’ Federal Cell Facility
will be a Surety Bond pledged for $7,693,454 with a Standby Trust Agreement executed with Zions Bank and
includes the necessary amount of coverage to provide for the following:
a. The Surety Bond will be sufficient to cover all the costs of closure of the Federal Cell Facility. The
Surety Bond includes identification and specification of the types and number of activities required
for each of Clive’s facilities.
b. The amount of the financial assurance will be equal to the cost estimates for premature closure of the
Federal Cell Facility after the first year of operation, and reflects the total costs incurred if an
independent contractor were hired.
c. The Surety Bond provides coverage throughout the term of the License.
d. The Director of the Division of Waste Management and Radiation Control will be authorized as
beneficiary.
e. As part of the annual review/revision, the Surety Bond will be adjusted so that it represents the current
condition of the Federal Cell Facility (accounting for depleted uranium placed in the embankment
and other related operational changes). As is allowed by UAC R313-25-31(2), activities in common
for premature closure of the Class A West Facility, Mixed Waste RCRA Facility, 11e.(2) Byproduct
Facility and Federal Cell Facility are generally funded in the Class A West Facility calculations.
f. As part of the annual review/revision, the Surety Bond will be adjusted for inflation, using the
inflation factor derived from the annual implicit price deflator for gross national product, as published
in the U.S. Department of Commerce’s Survey of Current Business and as reported by the Division
of Waste Management and Radiation Control.

The financial assurance mechanism proposed for post-closure of EnergySolutions’ Federal Cell Facility will
be a separate Surety Bond pledged for $1,344,977 with a Standby Trust Agreement executed with Zions Bank
and includes the necessary amount of coverage to provide for the following:
a. The Surety Bond will be sufficient to cover 100-years of post-closure, including stewardship transfer
of the Federal Cell Facility to DOE. The Surety Bond includes identification and specification of the
types and number of activities required for each of Clive’s facilities.
b. The amount of the financial assurance will be equal to the cost estimates for premature post-closure
of the Federal Cell Facility after the first year of operation, and reflects the total costs incurred if an
independent contractor were hired.
c. The Surety Bond provides coverage throughout the term of the License.
d. The DOE via an agreed-upon third party trustee will be authorized as beneficiary.
e. As part of the annual review/revision, the Surety Bond will be adjusted so that it represents the current
condition of the Federal Cell Facility (accounting for depleted uranium placed in the embankment
and other related operational changes).
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f. As part of the annual review/revision, the Surety Bond will be adjusted for inflation, using the
inflation factor derived from the annual implicit price deflator for gross national product, as published
in the U.S. Department of Commerce’s Survey of Current Business and as reported by the Division
of Waste Management and Radiation Control.

The design modification and construction for the premature closure of the Federal Cell Facility will be
accomplished by following the approved embankment and cover design principles. These principles will
guide the redesign of the Federal Cell Facility as suggested in the following conceptual redesign plan.
1. Conduct an aerial survey of the embankment and develop current topographical data to be used as the
base of the redesign.
2. Overlay on the aerial survey of the embankment the following areas:
a. Limits of disposed waste,
b. Extents of completed liner,
c. CLSM entombment of placed depleted uranium, and
d. Any additional areas of interest.
3. Determine the best areas for the placement for waste generated from the decommissioning of the
Federal Cell support facilities.
4. Redesign the Federal Cell Facility per the following criteria:
a. Work within the criteria used for the modeling performed for the licensed embankment designs,
b. Side slopes cannot exceed 5:1,
c. Storm water must freely drain off of and away from the embankment, and
d. Final contours (geometry) cannot concentrate storm water flow that may lead to erosion of the
cover materials.
5. Drainage ditches will be designed based on the approved closure ditch designs for the Federal Cell
Facility. In general, the ditches slope from the northeast to the southwest where they connect to the
southwest corner discharge.

Once the aerial survey is completed and converted into an electronic file, a team of one engineer and one
CAD designer (utilizing AutoCAD Land Desktop or similar software) will redesign, including reviews and
revisions, the premature closure embankment design within ten to twelve (10-12) working weeks.

Considering the annual Federal Cell Facility waste configuration at the time of the As-Built survey and design
criteria, a suitable premature closure design will be a reduced Federal Cell Facility within the design Federal
Cell Facility limits. In addition, Rock Cover Design Calculations will be performed, demonstrating that the
Federal Cell Facility riprap design is adequate for the possible varied slope lengths.

Projections of additional debris and soil needed within the prematurely closed embankment will be estimated.
EnergySolutions will ensure sufficient capacity is reserved with the premature closure Federal Cell Facility
for the surety decontamination volumes. This volume will be calculated from a summation of all other closure
cost volumes within the Federal Cell Facility surety calculations.

The proposed location for the clay borrow required for Federal Cell Facility closure is Sections 5 and 29.
There are three work elements identified in the surety calculations that require clay material. The calculated
surety volumes for Clay Liner/Protective Cover, Temporary Cover and Radon Barrier. The current premature
closure Federal Cell Facility embankment design may require the construction of additional clay liner.
EnergySolutions will ensure that sufficient clay materials within the borrow pit limits of Sections 5 and 29 are
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reserved for premature closure needs. Similarly, The BLM Community Pit 24 is projected to have a sufficient
remaining reserve of material required to cover the premature Federal Cell Facility embankment.

At completion of premature closure, the final conditions of the Federal Cell Facility, including airborne
particulate monitoring, will be defined and characterized as serve as the baseline for long term surveillance
and maintenance. This information will be assembled into a Federal Cell Facility file that will be reviewed
by the Director and DOE prior to stewardship transition.

As it is reasonable to expect that premature closure of each of Facility in the Clive Disposal Complex will
occur concurrently, a combined surety estimate for the entire Clive Disposal Complex was submitted for
Director approval in March 2021. The next independent third-party evaluation of the combined surety
estimate for the entire Clive Disposal Complex is required to be repeated by March 1, 2026. Premature closure
and perpetual care of the Federal Cell Facility is expected to be included in that combined estimate.

10.2.2 Premature Post-Closure

The Federal Cell Facility will be constructed in a manner that minimizes the need for long-term maintenance.
The containment structure will be made completely of natural materials. The only item at the facility that is
man-made will be the chain link fence that surrounds the site. With the exception of the chain link fence all
of the materials incorporated in the final Federal Cell Facility have been designed to remain intact for 10,000
years. Since the Federal Cell Facility will be resistant to water erosion, wind erosion, and slope failure for the
10,000-year design life of the facility, the need for ongoing active maintenance of the Federal Cell Facility
after closure is minimized. Even so, inspection and custodial maintenance, such as occasional repair of a
damaged perimeter fence is expected to be required at the site is included in the post-closure surety
calculations.

10.2.3 Site Ownership Transition to DOE

Following closure and decommissioning, EnergySolutions and the Director will participate with DOE to
support transition of the Federal Cell Facility and compile documentation required by the Site Transition
Framework for Long-Term Surveillance and Maintenance, (DOE, 2019). Funding to address transition
activities of the Federal Cell Facility from DWMRC to DOE-LM are included in the premature post-closure
calculations (see Appendix R). The Framework follows a systematic process of identifying a baseline for the
closed Federal Cell Facility to facilitate a smooth transition of Federal Cell Facility stewardship from
Licensee’s and Director’s closure (or premature closure) to DOE’s Office of Legacy Management (DOE-
LM). Site Transition information will be compiled and reviewed by representatives from DOE-LM,
Director’s staff and EnergySolutions.

10.2.3.1 Authorities and Accountabilities will be Assigned and Documented
The Roles and responsibilities of interested parties documented in the Memorandum of Agreement (located
in Appendix U) will be reviewed and revised, as necessary.
• Responsibilities during transition responsibilities and funding sources;
• Applicable federal and state requirements, policies and procedures for managing resources;
• Legal authority authorizing transfer of Federal Cell Facility stewardship to DOE-LM (including any
related reservation of rights); and
• Discussion of authorities related to DOE-LM’s institutional controls.
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10.2.3.2 Site Conditions will be Accurately and Comprehensively Documented
Federal Cell Facility’s historical uses, characterization and remediation (including Preliminary and Final
Closeout Reports) will be released to the General Public. This information will include a description of the
Federal Cell Facility’s condition at time of closure, including remedies and remaining hazards and associates
Geographical Information Systems (GIS) references, where applicable.
• Physical features of the Facility, including site topography, geology, hydrogeology, geomorphology,
seismicity, site and area boundaries and other features relevant to the long-term performance of the
Facility;
• Locations of active, inactive and decommissioned buildings, structures and surface and subsurface
infrastructure;
• Locations of residual hazards and associated engineered and institutional control systems;
• Locations of groundwater wells, wastewater outfalls and air quality monitoring stations (as depicted
on Facility maps);
• Locations of off-site buildings and structures, important ecological resources and associated potential
receptors in the vicinity of the Facility;
• Characteristics of the remaining contaminants (e.g., radionuclide activity and physical/chemical
forms);
• Descriptions of the initial risk at the Facility and the risk remaining at the Facility following
remediation;
• The existence of and basis for decisions on cleanup levels for the end state;
• A conceptual Facility model, depicting relationships between existing residual hazards,
environmental transport mechanisms, exposure pathways and human/ecological receptors;
• Completion, documentation and Director-approval of all remedial actions; and
• Identification of any Natural Resource Damage Assessment claims (including DOE-LM’s potential
environmental liability at the Facility).

10.2.3.3 Engineered Controls, Operation and Maintenance Requirements and Emergency / Contingency
Planning will be Documented
Engineering controls, any remaining operational or maintenance requirements necessary and the contingency
plans will be documented.
• Engineered controls will be identified and documented, including design and construction drawings,
specifications and completion report; site physical and geotechnical data; locations of engineered
controls on the Facility maps; any ongoing remediation and related waste management activities; and
performance history assessments supporting successful Facility operations;
• A life-cycle cost estimate, including basis and assumptions. The life-cycle cost estimate will be based
on best available data (including reasonable and prudent expectations for future contingencies);
• Master schedule of any ongoing activities;
• Risk-based end state, including exit criteria outlining when engineered controls will no longer be
necessary;
• Operation and maintenance activities (such as surveillance and monitoring) will be documented, and
funding needed and available sources identified; and
• Contingency planning authority and responsibilities will be identified (including uncertainties
associated with residual hazards, fate and transport mechanisms and exposure pathways; scenarios
related to uncertainties; role, responsibilities and procedures to respond to each scenarios; conceptual
Facility model and emergency/catastrophic planning for fires, floods, etc.);
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10.2.3.4 Institutional Controls, Real and Personal Property and Enforcement Authorities will be Identified
Land use and institutional controls will be identified and implemented. For those engineered barriers relied
upon as part of a remedy requiring institutional controls, longevity and performance of the barrier will be
projected.
• Engineered controls will be identified and documented, including design and construction drawings,
specifications and completion report; site physical and geotechnical data; locations of engineered
controls on the Facility maps; any ongoing remediation and related waste management activities; and
performance history assessments supporting successful Facility operations;
• Property records will be completed; and
• Personal property transfers will be completed in accordance with 41 CFR 101 and DOE Property
Management Regulations.

10.2.3.5 Regulatory Requirements and Authorities will be Identified
Regulatory requirements regarding residual contamination will be identified. Pertinent regulatory documents
will be maintained and made available to the public, including:
• Regulatory decision documents and Facility characterizations will be identified, completed and
maintained in accordance with regulatory requirements;
• Any remedies will be verified and confirmed as compliant with regulatory requirements;
• Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Five-Year
Review will be made prepared;
• EPA National Priority List status and/or RCRA permit status of state requirements and the basis for
these requirements will be clearly indicated;
• NRC license status will be established. This status information will identify the license holder and the
development of license transfer plans; and
• Locations of documents will be identified, and the documents made accessible.

10.2.3.6 Long-Term Surveillance and Maintenance Budget, Funding and Personnel Requirements will be
Identified
Stewardship transition of the Federal Cell Facility will follow the prescribed guidance, budget, funding and
personnel requirements, including:
• A Technical Basis for DOE-LM management of the Federal Cell Facility will be developed;
• Funding and associated cost-estimates will be compiled;
• Personnel requirements will be identified; and
• A business closeout process will be developed.

10.2.3.7 Information and Records Management Requirements will be Satisfied
EnergySolutions’ information and records management procedures are appropriate for its disposal facilities.
Post-closure disposition plans will reflect records and information for DOE-LM turnover and retention plans,
including
• Agreements in place that will identify the disposition of records transfer to the Facility custodian and
records that transfer to other organizations;
• Information and records needed for DOE-LM, property management, contractor personnel benefits
other than pensions, worker compensation and Energy Employees Occupational Illness
Compensation Program Act will be identified;
• Practices and procedures for the transition of information systems and records will be established;
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• The guidance and operations information for information systems transferring to the Facility
custodian, including metadata, will be identified and transferred along with the information systems;
• A Facility Information and Records Transition Plan will be developed and approved to establish a
framework to address Facility-specific records and information requirements, including storage
locations, special handling needs, geospatial data and access and retrieval requirements;
• The locations for storage and maintenance of Facility records and standards for data formats will be
provided for Facility transfer;
• Information from the transfer Facility’s records tracking systems will be migrated to the tracking
system, along with locator guides and indices;
• Necessary records and record locations will be identified, including points of contact;
• Systems and procedures used for the archival of Facility information will be developed;
• Retention schedules for continuity of benefits, worker compensation and Energy Employees
Occupational Illness Compensation Program Act claims will be developed;
• Systems and procedures to establish and facilitate public access to and retrieval of records and
information critical to DOE-LM stewardship of the Federal Cell Facility will be created;
• National Archives and Records Administration will be engaged through the DOE Office of Chief
Information Officer, to approve any transfer of records past their retention schedule;
• The DOE Librarian and Historian will be consulted regarding the transfer of non-record materials;
• User class and access requirements will be identified, and solutions implemented; and
• Information in DOE-approved information systems will be implemented.

10.2.3.8 Public Education, Outreach, Information and Notice Requirements will be Documented and Satisfied
Community involvement and associated Community Relations Plans will be developed from existing
participation standards and systems, including:
• List of Facility stakeholders with associated address information will be developed and a process
created for updating this list;
• Updates (at least annual) of the Administrative Record will be made available to interested parties;
• Community involvement tools will be developed; and
• Costs associated with public involvement will be projected and funds sufficient for public
involvement included in secured perpetual care funds.

10.2.3.9 Natural, Cultural and Historical Resource Management Requirements will be Satisfied
A system or process will be created to protect information about sensitive and natural resources from
unauthorized access or use, including:
• Biological resources, threatened and endangered species, archaeological and cultural resources,
Native American treaty rights and natural and cultural resource requirements will be identified.
• Locations and characteristics of natural and cultural resources will be identified. A management
system will be created and operated.

10.2.3.10 Business Closure Functions, Pension and Benefits, Contract Closeout or Transfer and Other
Administrative Requirements are Satisfied
Actions required by EnergySolutions and DOE-LM related to business closeout functions will be identified
and will reflect requirements, policies and procedures, schedules and cost estimates and budget.
• Responsibilities will be determined for the administration and funding of retiree benefits and pension
funds, work force transition services, National Defense Authorization Act – Section 3161 tuition,
worker compensation claims and EEOIPA claims;
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• Contractor pensions and benefits needs will be identified and planned;
• Status of pending litigation and liabilities will be identified;
• Contract closeout actions for closure of restoration contracts and financial agreements will be
identified; and
• Requirements from DOE’s applicable orders will be satisfied.

10.3 CORPORATE GUARANTEES

While EnergySolutions anticipates operating within the bounds of the license hereto requested through
closure and post-closure transition of the Federal Cell Facility to the DOE, neither EnergySolutions nor ECP
pledge any corporate assets nor make any corporate guarantees towards the performance of or payment for
specific closure or post-closure activities of the Federal Cell Facility (other than the collateral necessary for
EnergySolutions to secure the closure and post-closure bonds from the bond issuer).

10.4 ASSETS HELD BY A THIRD PARTY SUCH AS IN A STATE FUND

Other than funds pledged in the closure and post-closure surety bonds (to be held by the Director),
EnergySolutions does not pledge further assets towards premature closure or post-closure of the Federal Cell
Facility.

10.5 TRUSTS AND STANDBY TRUSTS

Funds in surety bonds for Funds in surety bonds for premature closure and post-closure and post-closure
activities are secured and revised annually to assure that the pledged amounts remain sufficient to account
for inflation, construction of new facilities and other cost adjustments. A Standby Trust Agreement with
Zion’s First National Bank (Trustee) for management of the funds from the premature closure surety bond
will cite the Director as beneficiary (see example in Appendix S). Any monies not used by the Director in
the premature closure of the Federal Cell Facility will be returned to EnergySolutions. A second Standby
Trust Agreement with Zion’s First National Bank as Trustee for management of the funds from the post-
closure surety bond will employ a third-party mutually agreed upon by the Director and DOE as beneficiary
(see example also included in Appendix S). The post-closure beneficiary will release funds for post-closure
of the Federal Cell Facility to the DOE-LM Section Manager until they are exhausted.

As a reputable financial entity authorized to act as such, Zion’s First National Bank has been selected as
trustee. The Standby Trust Agreements will be irrevocable, except with the written agreement of the trustee
and the beneficiary. The Standby Trust Agreements will be revised annually to reflect approval of annual
revisions to the premature closure and post-closure cost estimates. The Director will have possession of the
closure surety bond secured in trust by EnergySolutions (Grantor). Similarly, Zion’s First National Bank
will possess the post-closure surety bond secured in trust by EnergySolutions. The agreements’ trustees will
function under fiduciary duty to comply with the terms of the trusts and will be liable for breaches of this
duty.

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10.6 OTHER FINANCIAL ASSURANCES

Closure and post-closure surety bonds are secured for the unlicensed, LLRW, Mixed Waste and 11e(2)
facilities. Other than the closure and post-closure Federal Cell Facility surety bonds, no other financial
assurances will be pledged by EnergySolutions.

10.7 ADJUSTMENTS TO SURETY AMOUNTS

Closure and post-closure surety funding for the Federal Cell Facility will be reviewed annually to account for
inflation and changes in activities or design. This annual review ensures that the amount is adequate to fund
the decommissioning of the Clive Facility in the event that EnergySolutions is unable to close the
embankments. As with the funds secured for premature closure, EnergySolutions will annually revise and
adjust the required funding pledged for DOE’s post-closure care of the Federal Cell funds. The value of the
surety instruments secured to address the amount needed will be adjusted annually, as determined annually as
the result of the Director’s annual review. As is reflected in the stewardship transfer agreements in Appendix
T, EnergySolutions anticipates that the Director will closely coordinate the annual review and revision of the
Federal Cell Facility’s premature closure and perpetual care surety calculations with DOE-LM.

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SECTION 11. HOUSE BILL 220

In May 2019, House Bill 220 promulgated additional requirements in Utah Code §19-3-103.7 for disposal of
more than one metric ton of concentrated depleted uranium. These include: “(a) an approved performance
assessment; (b) designation of a federal cell by the director; and (c) pursuant to an agreement acceptable to
the director, that the United States Department of Energy accepts perpetual management of the federal cell,
title to the land on which the federal cell is located, title to the waste in the federal cell, and financial
stewardship for the federal cell and waste in the federal cell.” Utah Code § 19-3-103.7(3)(a)–(c).

11.1 APPROVED PERFORMANCE ASSESSMENT

As included in Appendix Q, a depleted uranium performance assessment has been conducted to evaluate the
range of likely impacts of disposal of DU in a new Federal Cell to be located in the southwest corner of the
licensed area. The DU PA is created as a systems-level model using the GoldSim probabilistic modeling
platform and is currently at version 1.4. The DU PA v1.4 model and supporting documentation have been
evaluated by the Director of the Utah Division of Waste Management and Radiation Control and their
contractor, SC&A Inc.

11.2 DESIGNATION OF A FEDERAL CELL BY THE DIRECTOR

The purpose of the Radioactive Material License application is for designation of a Federal Cell Facility by
the Director. In support of this designation, EnergySolutions has delineated the precise location of the Federal
Cell and filed a request with the Tooele County Planning and Zoning Committee to separately subdivide the
parcel on which the proposed Federal Cell Facility will be housed. See Figure 11-1 (showing the legal
description of the Federal Cell, which is marked “proposed subdivision”).

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Figure 11-1. Tooele County Subdivision Parcel Map
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11.3 PERPETUAL STEWARDSHIP AGREEMENT WITH THE DEPARTMENT OF ENERGY

Under Utah Code § 19-3-103.7(3)(C), the Director shall require as a condition of disposal of more than one
metric ton of concentrated depleted uranium that the DOE, pursuant to an agreement acceptable to the
Director, (1) accept perpetual management of the federal cell, (2) accept title to the federal cell and the waste
in the federal cell,1 and (3) accept financial stewardship for the federal cell and waste in the federal cell. For
the reasons discussed below, and those previously provided to the Division, this application meets these
requirements. See June 22, 2020 letter from Vern Rogers to Director Ty Howard, Subject: Land Ownership
Requirements and Long-Term Stewardship Issues Regarding the Forthcoming Federal Cell Radioactive
Material License Application (Appendix T).

On April 30, 2020, Department of Energy and EnergySolutions executed the Real Estate Transfer Agreement
for the Federal Cell by and between EnergySolutions, LLC and the U.S. Department of Energy (Federal Land
Transfer Agreement) (Appendix T). In the Federal Land Transfer Agreement, the DOE agrees to accept
ownership of the Federal Cell subject to the terms of the Agreement. Specifically, the DOE agrees that “all
right, title, and interest in the land and buildings of the [Federal Cell] shall be conveyed to the DOE or its
successor upon decommissioning of the [Federal Cell], regardless of whether the decommissioning is planned
or unplanned.” Federal Land Transfer Agreement (Appx. D) § 3. Following title transfer, the DOE accepts
responsibility for maintaining the closed Federal Cell to protect public health and the environment. Federal
Land Transfer Agreement (Appx. D) § 4.2. Under the terms of this Agreement, DOE has agreed to accept
title to the Federal Cell, the waste therein, and accept perpetual management of the Federal Cell to protect
human health and the environment. The DOE, as the long-term steward, will also be responsible for the
financial stewardship of the Federal Cell after title transfer. As discussed in the Section 10 Financial
Assurances, EnergySolutions is establishing a surety to provide for post-closure management of the cell by
DOE.

The DOE and the Division are also currently negotiating, and if appropriate terms can be reached, will execute
a Memorandum of Agreement Governing the Long-Term Stewardship of the Federal Cell at EnergySolutions
Clive Disposal Facility (MOA). EnergySolutions understands that DOE will submit a draft MOA for the
Division’s consideration in association with this application. Previous versions of the MOA recognized the
federal government’s legal responsibility for the disposal of low level radioactive waste owned by the federal
government and reiterated DOE’s intent to accept all rights and title to the Federal Cell following its closure
and decommissioning.

1 Utah law also requires that the Federal Cell be owned by the state or federal government at the time of disposal.
See Utah Admin. Code R313-25-29(1) (“Disposal of waste received from other persons may be permitted only on
land owned in fee simple by the Federal or a State government.”) EnergySolutions intends to maintain the Federal
Cell in private ownership during the time of disposal until the cell is decommissioned and transferred to DOE—a
period expected to be fifty years. EnergySolutions’ longstanding land-ownership exemption grants an exemption to
Utah Admin. Code R313-25-29(1)’s government ownership exemption requirement and applies to the Federal Cell.
See June 22, 2020 letter from Vern Rogers to Director Ty Howard, Subject: Land Ownership Requirements and Long-
Term Stewardship Issues Regarding the Forthcoming Federal Cell Radioactive Material License Application
(Appendix T) at pp. 3–6 (explaining why the exemption applies to the Federal Cell); See August 4, 2020 letter from
Director Howard to Vern Rogers, re: Preliminary Comments on Land Ownership Requirements and Long-Term
Stewardship Issues Regarding Anticipated Federal Cell Radioactive Material License Application (Appendix T) at pp.
5–6 (expressing preliminary support for EnergySolutions’ position re the land-ownership exemption).
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While EnergySolutions believes the Federal Land Transfer Agreement and the MOA are sufficient to meet
the requirements of Utah Code § 19-3-103.7(3)(c), the Division has expressed concerns regarding its ability
to enforce the Federal Land Transfer Agreement to ensure the transfer of title to DOE and ensure that the State
of Utah is not liable for the long-term stewardship of the Federal Cell. See August 4, 2020 letter from Director
Howard to Vern Rogers, re: Preliminary Comments on Land Ownership Requirements and Long-Term
Stewardship Issues Regarding Anticipated Federal Cell Radioactive Material License Application (Appendix
T).2 To address these concerns, EnergySolutions has proposed that it and the State enter into a separate State
Land Transfer Agreement that would provide the Division the ability to pursue a contractual remedy against
EnergySolutions if it fails to transfer title to the Federal Cell pursuant to the Federal Land Transfer Agreement.
See Draft State Land Transfer Agreement (Appendix T). Also, EnergySolutions proposes the following
condition be included in the license for the Federal Cell: “EnergySolutions shall abide by and comply with all
terms and conditions of the Federal Land Transfer Agreement between EnergySolutions and the U.S.
Department of Energy.” This would allow the Division to pursue a remedy through its administrative
enforcement powers if it chose to do so.

Further, in addition to the contractual and administrative remedies available against EnergySolutions to
force transfer of title, the State also has access to the financial assurances described in Section 10; and the
State has the ability to pursue the DOE for any release of hazardous substances under the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA). CERCLA grants a right of action
in federal district court by EPA, the states and private citizens for either threatened or actual releases of
hazardous substances into the environment. (See 42 USC §9601 et seq.). Radionuclides are a listed
hazardous substance under EPA and Utah DEQ rules. (40 CFR §302.4); see also Pennsylvania v. Lockheed
Martin Corp., 684 F. Supp. 2d 564 (M.D. Penn. 2010) (concluding CERCLA applies to Sr-90—a
radioactive and nuclear byproduct material). Any dispute in the future over title and ownership of the
Federal Cell would likely involve a concern about a threatened release of radioactive waste into the
environment. Further, DOE would likely be a potentially liable party under CERCLA because the agency
would meet the definition of a “generator” under CERCLA §107. (42 USC §107). Thus, if DOE refused to
accept title and EnergySolutions was experiencing financial hardship, Utah could bring a CERCLA action in
federal district court and demand that the court issue an order requiring DOE to accept title and properly
manage the LLRW—or at a minimum pay any response costs incurred by the State. DOE has been
previously sued by States under CERCLA. See, e.g., New York v. United States, 2013 WL 6175830, No.
06-cv-810-JTC (Complaint, dkt 1-1 (alleging first cause of action for CERCLA response costs and second
cause of action for CERCLA natural resources damages) and Consent Decree, dkt. 37 (providing for clean-
up costs to the State of New York)).

Overall, the Federal Land Transfer Agreement, the MOA, the State Land Transfer Agreement, the proposed
financial assurances, and the ability to pursue DOE through CERCLA provide the State with a strong basis to
find that the requirements of Utah Code § 19-3-103.7(3)(c) have been satisfied.

2 In the Division’s August 4, 2020 letter, it raises the issue of the application of § 10171(b) of the Nuclear Waste
Policy Act. 42 U.S.C. § 10171(b). EnergySolutions does not believe the Nuclear Waste Policy Act’s title and
custody subsection apply to agreement states like Utah based on a plain reading of the statute. Further, the DOE has
advised EnergySolutions that 42 USC §10171(b) does not apply in Utah.
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SECTION 12. REFERENCES

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