DRC-2022-001282 - 0901a06881008aa0

DRC-2022-001282 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL

Douglas J. Hansen
Director

March16, 2022

Vern C. Rogers
Director of Regulatory Affairs
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111

RE: Conditional Approval: Revised Amendment and Modification Request, Capacity and
Disposal Footprint 11e.(2) License, February 26, 2021 (CD-2021-030), Amendment and
Modification Request to Reduce Capacity and Disposal Footprint, October 19, 2020
(CD-2020-157), EnergySolutions (ES) Response to wells remaining and abandonment
regarding the 11e.(2) embankment only, April 9, 2021 (CD-2020-052),
Public Notice, July 21, 2021 (DRC-2021-006545)
EnergySolutions Radioactive Material License UT2300478

Dear Mr. Rogers:

In letters dated February 26, 2021 (CD 2021-030), October 19, 2020 (CD-2020-157), and April 9, 2021
(CD-2020-052), EnergySolutions requested approval for Revised Amendment 3 and Modification
Request Capacity and Disposal Footprint, and the surety update to 11e.(2) Radioactive Material License
UT2300478. In conjunction EnergySolutions requested that the Groundwater Quality Discharge Permit
GWQDP, No. UGW450005 be modified to abandon several monitoring wells.

The Division of Waste Management and Radiation Control (DWMRC) held a public hearing regarding
this matter on September 8, 2021. Comments received during the public comment period are
documented in the Public Participation Document (DRC-2022-002682) created by the Division. The
Division considers the administrative record relating to this amendment request to now be complete and
adequate to support the Director’s final agency action.

(Over)

After reviewing the complete administrative record, the Director hereby approves EnergySolutions’
Radioactive Material License UT2300478 Amendment 3, modification of GWQDP, No. UGW450005
and the associated engineering drawings submitted on February 26, 2021 (CD-2021-030), subject to the
following conditions:

1. Groundwater monitoring well GW-36 shall remain in service as a down gradient monitoring well
for the 2000 evaporation pond.

2. Wells GW-37 and GW-38 may be abandoned because the wells will no longer be compliance
monitoring points in an upcoming modification of GWQDP, No. UGW450005.
Well abandonment will be performed in accordance with requirements in Utah Administrative
Code (UAC) R655-4-12 including:

a. Any groundwater monitoring well that is to be permanently abandoned shall be done
in accordance with the provisions of UAC R655-4-14.

b. Permanently abandoned wells shall be completely filled in such a manner as to prevent
vertical movement of water within the borehole as well as preventing the annular
space surrounding the well casing from becoming a conduit for possible contamination
of the groundwater.

c. The well closure shall be completed under the direct supervision of a currently licensed
water well driller who shall be responsible for verification of procedures and materials
used.

d. EnergySolutions will meet the requirements of Part II.M. of GWQDP,
No. UGW450005.

3. This approval is limited to EnergySolutions’ Radioactive Material License UT2300478 and
GWQDP, No. UGW450005.

The basis for the Director’s conditional approval is set forth in the Administrative Record, including the
Statement of Basis (DRC-2022-002684) and the Public Participation Summary (DRC-2022-002682).
Based on the Administrative Record, the Director has determined that the foregoing conditions are
appropriate.

NOTICE OF RIGHT TO APPEAL

NOTICE is hereby given that any person may file a Petition for Review regarding the above-referenced
docket, pursuant to Utah Code Section 19-1-301.5 and Utah Admin. Code R305-7, within 30 days of the
date that this agency action is signed.

If you have any questions, please call David Esser at [phone] or Otis Willoughby at
[phone].

Sincerely,

Douglas J. Hansen, Director
Division of Waste Management and Radiation Control

Enclosure: Radioactive Material License #2300478 (DRC-2022-003082)

DJH/DKE/wa

c: Jeff Coombs, EHS, Health Officer, Tooele County Health Department
Bryan Slade, Environmental Health Director, Tooele County Health Department
EnergySolutions General Correspondence (Email)
LLRW General Correspondence (Email)
Douglas Tonkay, USDOE (Email)
Lexi Tuddenham, HEAL Utah (Email)
Ty L. Howard, Deputy Director, Utah Department of Environmental Quality
Kimberly D. Shelley, Executive Director, Utah Department of Environmental Quality
DWMRC-03 UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL RADIOACTIVE MATERIAL LICENSE Pursuant to the Utah Code Annotated (UCA), Title 19, Chapter 3 and R313 of the Utah Administrative Code and in reliance on statements and representations heretofore made by the Licensee designated below, a license is hereby issued authorizing such Licensee to transfer, receive, possess and use the radioactive material designated below; and to use such radioactive material for the purpose(s) and at the
place(s) designated below. This Licensee is subject to all applicable rules, and orders now or hereafter in effect and to any conditions specified below.
LICENSEE ) 3. License Number: UT 2300478
) Amendment #3
1.Name EnergySolutions, LLC ) ***********************************************
) 4. Expiration Date 2.Address 299 S. Main St., Suite 1700 )November 13, 2027 Salt Lake City, UT 84111 ) ***********************************************
) 5. License Category 2-c
6.Radioactive material 7.Chemical and/or 8.Maximum quantity
( element and mass physical fonn Licensee may possess at
number)any one time
11 e.(2) Byproduct Packaged or Bulk 1,629,255 Cubic YardsMaterialRadioactive Waste ***********••··········································••************************************* SECTION 9.0. ADMINISTRATIVE CONDITIONS 9.1 All notices to the Division of Waste Management and Radiation Control required under this
license shall be addressed to the Director of the Division of Waste Management and Radiation
Control (Director), Department of Environmental Quality, 195 North 1950 West, P.O. Box 144880, Salt Lake City, UT 84114-4880.
9.2 Authorized place for use shall be the Licensee's facility located in Section 32 of Township I S, Range 11 W, Tooele County, Utah, near Clive.
9.3 Authorized use is for the receipt, storage and disposal of l le.(2) byproduct material in accordance with statements, descriptions, and representations contained in the Licensee· s
application, including appendices.
9.4 ln order to ensure that no disturbance of cultural resources occurs, the Licensee shall cease any work resulting in the discovery of previously unknown cultural or historical artifacts and report
the discovery, in writing, to the Director and the State Historic Preservation Office (SHPO). The
artifacts shall be inventoried and evaluated in accordance with UCA 9-8-404, and no disturbance shall occur until the Licensee has received written authorization from the Director and SHPO to proceed. 9.5 The Licensee shall:
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL
RADIOACTIVE MATERIAL LICENSE
SUPPLEMENTARY SHEET License# UT 2300478
Amendment #3
a)Establish, implement and comply with standard operating procedures (SOPs) for alloperational activities involving the handling, storing or disposal of radioactive materials.
SOPs for operational activities shall enumerate pertinent radiation safety practices to be
followed. In addition, SOPs shall be established and implemented for non-operationalactivities to include environmental monitoring, bioassay analysis and instrument calibration.An up-to-date copy of each written SOP, as controlled under the quality assurance (QA)procedures, shall be kept in each area where it is used.
b)Design, implement and comply with an effective air sampling program in the workplacebased on Revision I to Nuclear Regulatory Commission (NRC) Regulatory Guide 8.25(June 1992), "Air Sampling in the Workplace" or an equivalent program.
9.6 The Licensee shall have all written SOPs reviewed and approved by the Radiation Safety Officer
(RSO), or designee, qualified by way of specialized radiation protection training equivalent to that required for the RSO as defined in License Condition 9.8, before being implemented and
whenever a change in a procedure is proposed. All existing facility SOPs related to operational and non-operational activities shall be reviewed and documented by the RSO on an annual basis
in the 11 e.(2) Annual Report, to be submitted to the Director by April 30.
9.7 Any change to the Lieensee·s corporate organizational structure, as presented in the license
application, affecting the assignment or reporting responsibility of the radiation staff shall conform to the RC's Regulatory Guide 8.31, ··Infonnation Relevant to Ensuring That
Occupational Radiation Exposures at Uranium Mills Will Be As Low As ls Rea onably
Achievable·' as amended.
9.8 The Liecnsee·s staff shall meet the qualifications as described in the currently approved Organization layout of Condition 32.A of Radioactive Material License UT 2300249. In addition to the responsibilities and qualifications specified in the Licensee ·s application, the RSO
or designee shall be qualified as specified in Sections 1.2 and 2.4 of the RC Regulatory Guide
8.31, .. Information Relevant to Ensuring that Occupational Radiation Exposures at Uranium Mills will be As Low As Reasonably Achievable,'' as amended. In addition, the RSO shall also
receive 40 hours ofrelated health and safety refresher training every two years.
9.9 For the purpose of this License Condition, reference to ··uranium mill .. or ··milling"· in the RC
Regulatory Guide 8.31, as amended, shall mean the Licensee's facility and authorized activities.
9.10 The Licensee shall conduct:
a)Annual training for its facility inspectors that covers all areas included in the dailyinspections of the 11 e.(2) byproduct material and the disposal area.
b)Annual operational training that covers all aspects of operational safety and emergencyprocedures for all employees. The SOPs shall be used to conduct operations training toassure consistency and thoroughness.
DWMRC-03
DIVISION OF WASTE MA AGEMENT AND RADIATION CONTROL RADIOACTIVE MATERIAL LICENSE
SUPPLEMENTARY SHEET License# UT 2300478 Amendment #3
9.1 t The Licensee shall, at all times, maintain a Surety that satisfies the requirements of R3 I 3-24-4 (IO CFR 40, Appendix A, Criterion 9 and IO incorporated by reference), as defined by License Condition 9.13 (a) or 9.13 (b) (or more frequent, at the Licensee ·s sole discretion) and shall include closure and post-closure costs in all areas subject to the portions of the facility herein licensed.
9.12 Annually, by March I, the Licensee shall submit proposed closure and post-closure costs in a Surt:ty Report, upon which financial assurance amounts are based, including costs of potential
remediation at the licensed facility, as if accomplished by a third party contractor, for completion of a Director-approved reclamation/decommissioning plan of the Licensee·s licensed grounds, equipment and facilities including above-ground decommissioning and decontamination, soil and water sample analyses and groundwater restoration associated with the site, as warranted.
9.13 At its election, the Licensee·s annual proposed closure and post-closure costs shall be based on
either:
a)a proposed annual cost estimate using unit rates from the current edition of RS MeansFacilities Construction Cost Data and other site-specific processes, indirect costs based onthe sum of applicable direct costs in accordance with the indirect cost multipliers inTable 9.13A or others mutually agreed to by the Licensee and the Director; or
Table 9.13A
Workin Conditions 5.5%
Mobilization I Demobilization 4.0%
11.0%
and Redesi 2.25%
Overhead and Profit 19.0%
Mana cment Fee and Le 4.0%
4.0%
b)an initial financial assurance determination and for each financial assurance detenninationevery five years thereafter, a proposed competitive site-specific estimate for closure and post­closure care of the licensed facility shall be used; and for each year between this financialassurance determination, a proposed financial assurance estimate that accounts for currentsite conditions and that includes an annual inflation adjustment to the financial assurancedetermination using the Gross Domestic Product Implicit Price Deflator of the Bureau ofEconomic Analysis, United States Department of Commerce, calculated by dividing thelatest annual deflator by the deflator for the previous year shall be used.

DWMRC-03
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL RADIOACTIVE MATERIAL LICENSE SUPPLEMENTARY SHEET License# UT 23004 78 Amendment #3
9.14 The annual Surety Report shall be prepared under the direct supervision of and be certified by a
professional with at least five years of construction cost estimation experience, who bears the seal of either a Professional Engineer or Professional Geologist currently licensed by the State of Utah. The Licensee shall prQvide the Surety Report in both paper and electronic fonnats.
Within 60 days of the Director's approval of the Surety Report, the Licensee shall submit written evidence that the surety instruments have been adequately funded. The currently-approved Surety Report and instrument(s) shall be maintained as a Surety Appendix to the License.
9.15 The combined annual surety is $82,460,030.51 with the 11 e.(2) subtotal of$ I 0,805,563.27 as approved in the Director's letter dated June 23, 2020.
9 .16 The Licensee shall require a radiation work permit (R WP) for work where the potential for
significant exposure to radioactive materials exists and for which no SOP exists. Each RWP shall contain the information specified in Regulatory Guide 8.31, as amended.
9.17 The RSO, or designee, qualified by way of special radiation protection training equivalent to that
required for the RSO as defined in License Condition 9.8, shall indicate by signature, the review and approval of each R WP, prior to the initiation of the work.
9.18 The Licensee shall provide SOPs for controlling internal contamination of workers from dust inhalation, which shalJ include the use of dust suppressants (e.g., magnesium chloride or water)
on all operational roads, as necessary.
9.19 The Licensee shall have qualified individuals, designated by the RSO and Manager, Health and Safety, perform quantitative respirator fit tests on all employees required to wear respirators prior to the initial use of a respirator and annually thereafter. During the annual fit test, the qualified individual performing the test shall ensure that the employee is correctly performing negative
pressure fit checks and shall instruct the employee that the fit test is to be performed each time a respirator is donned and prior to entering an area where respirators are required. The Licensee shall follow the guidance provided in the NRC Regulatory Guide 8.15 "Acceptable Programs for Respiratory Protection" as amended.
9.20 The Licensee shall complete "as built drawings" of the facility on an annual basis. The as built
drawings shall be certified by a professional engineer.
9.21 The Licensee shall provide for an independent internal audit of facility operations to ensure
compliance with applicable regulations and license conditions. The independent internal audit
shall be conducted annually by a qualified health physicist knowledgeable of operations
concerning radiation protection programs at milling/waste disposal facilities. The contractor report shall be submitted to the Director as part of the 11 e.(2) Annual Report.
9.22 The operational environmental monitoring program shall be conducted in accordance with the current Environmental Monitoring Plan approved by the Director.
DWMRC-03
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL RADIOACTIVE MATERIAL LICENSE
SUPPLEMENTARY SHEET License# UT 2300478 Amendment #3
SECTION 10.0. OPERATIONAL CONTROLS, LIMITS AND RESTRICTIONS
10.1 The Licensee shall restrict eating and drinking to the administrative offices and enclosed lunch areas that are separated from the disposal areas. With the exception of drinking from closeable containers, there shall be no eating, drinking, smoking, defecating or urinating in the restricted areas at any time.
I 0.2 The Licensee shall analyze and adequately characterize all incoming waste to identify any new hazardous constituents not listed in the Waste Characterization Plan referenced in Condition 58 of Radioactive Material License UT 2300249. The Licensee shall develop, implement and comply with methodologies and procedures for systematic characterization and analysis of the incoming waste so that any new hazardous constituents are identified. The Licensee shall
assume that the baseline background concentrations for any new constituents are at their detection levels, unless the Licensee demonstrates to the Director's satisfaction that the constituents will not reach the water table in one year and proceeds to establish background based on direct monitoring of these constituents in the Point of Compliance (POC) wells for one
full year.
I 0.3 The following key radon attenuation model parameter values shall be used during placement to
verify that the values used in the Licensee1s model (see Licensee's correspondence to the NRC dated August 30, 2000 and to the DRC dated October 31, 2007) have been achieved: (1) dry
density and (2) moisture content (percent by dry weight) of the placed compacted radon barrier
material and the upper ten feet of 11 e.(2) byproduct material. Average values for each parameter
by lift, for the upper ten feet of the l le.(2) embankment only, per year shall be calculated and submitted to the Director in the 11 e.(2) Annual Report.
10.4 The distribution of the Ra-226 and Th-230 concentrations in the l le.(2) byproduct material in the upper 3 .3 meters (10 feet) of the contaminated material shall be used to verify that the concentration in any lift does not exceed the values used in the radon attenuation model. The
Licensee shall measure the Ra-226 and Th-230 concentrations using standard analytical
procedures for every 2500 cubic yards of material placed for compaction and at least once per lift for lifts smaller than 2500 cubic yards. This sampling may be performed from the waste container/conveyance at receipt or on the lift during waste placement. ln the case where sampling will be performed from the waste container/conveyance, proper tracking shall be
perfonned to accurately identify disposal location (or lift number). ln the case where sampling
will be performed at the disposal lift, each sample shall be a composite sample consisting of ten
aliquots from random locations on the lift. The data shall include the elevation (or lift number) of the sample location. The results shall be presented as average values for each lift and submitted to the Director in the 11 e.(2) Annual Report.
10.5 The Licensee shall assume full responsibility for remediation of any groundwater contamination caused by hazardous constituents originating from the 11 e.(2) disposal facility that have been detected at the Point of Compliance (POC) wells in concentrations exceeding the limits specified
in Tables 1-C and 1-0 of the Groundwater Discharge Quality Permit UGW450005. It shall be
DWMRC-03 DIVISION OF WASTE MANAGEMENT AND RADIATIO CONTROL RADIOACTIVE MATERIAL LICENSE SUPPLEMENTARY SHEET License# UT 2300478
Amendment #3
assumed that the 11 e.(2) disposal facility is the source of all of the hazardous constituents
detected in the POC wells, unless it can be demonstrated to the Director's satisfaction that the
11 e.(2) facility is not the source of those constituents.
I 0.6 The Licensee shall undertake corrective action to clean up groundwater contamination if and when required, but no later than 18 months from the date when exceedance of a standard has first been discovered and without taking credit for any delays caused by disagreements as to the
source of contamination. The Licensee shall consider and evaluate existing and new
groundwater clean-up technologies before selecting and implementing an appropriate clean-up program.
10. 7 The Licensee shall continue groundwater and land surface monitoring at all POC locations throughout the post closure period until the disposal facility is transferred to long-term government custody.
I 0.8 The Licensee shall implement the quality assurance plan as provided in the license application.
10.9 The Licensee shall, prior to managing waste for disposal, determine the presence of free liquids
as described in Section lV of the Waste Characterization Plan referenced in Condition 58 of Radioactive Material License UT2300249. Solid waste received for disposal shall contain as little free standing and non-corrosive liquid as reasonably achievable, but shall contain no more free liquids than one percent of the volume of the waste.
I 0.10 The Licensee shall not accept any waste containing free liquid for disposal. Solid waste received and containing unexpected aqueous free liquids in excess of I% by volume shall have the liquid removed and placed in the evaporation ponds or the liquids shall be solidified prior to its management.
I 0.11 Unexpected non-aqueous free liquids less than I% of the volume of the waste within the container shall be solidified prior to disposal.
I 0.12 Should shipments arrive with greater than 1 % unexpected free liquids (total of aqueous and non­aqueous), the Licensee shall notify the Director within 24 hours that the shipments failed the requirements for acceptance and shall be managed in accordance with the Waste Characterization Plan as referenced in Condition 58 of Radioactive Materials License UT2300249.
10.13 The Licensee shall, upon arrival of waste, perform external exposure rate measurements of the waste conveyances. Any shipment with exposure rates greater than five mrem per hour at a distance of 30 cm from any surface and which cannot be disposed of within 24 hours, shall be
posted as a Radiation Area in compliance with R3 l 3-l 5-901, R313-15-902 and R3 I 3-15-903 [ I 0 CFR 20. l 902(a) incorporated by reference] until disposed.
I 0.14 The Licensee shall operate the facility in compliance with the following specifications:
DWMRC-03
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL
RADIOACTIVE MA TE RIAL LICENSE
SUPPLEMENTARY SHEET License# UT 2300478
Amendment #3
a)The maximum bulk mass of waste disposed of annually shall not exceed 4.536 x I 05 tonnes
(5 x 105 tons)or (3.82x 105 m 3) or (4.00 x 105 yd3).
b)The open cell area shall not exceed 78,038.55 m2, 93,333.33 yd2, 840,000 ft2 or 19.28 acres.
c)The total embankment capacity shall not exceed 1,245,655 m3 (1,629,255 yd3).
d)The maximum volume of waste that may be stored as in-cell bulk storage on site prior to
disposal shall not exceed 10,000 yd3 or (7,645.55 m3) at any one time.
e)Waste with an average concentration above 4,000 pCi/g for natural uranium or for any radionuclide in the radium-226 series; or above 60,000 pCi/g for thorium-230; or above6,000 pCi/g for any radionuclide in the thorium series in any truckload or railcar shall not be
accepted.
I 0.15 The Licensee shall maintain the detailed documents demonstrating compliance with the specifications in License Condition 10.16 on-site and shall summarize the data in Condition 10.17 and Condition 10.18. This information shall be submitted to the Director in the 11 e.(2)
Annual Report.
I 0.16 The minimum compacted radon barrier thickness placed in accordance with the specifications authorized in the LLRW and 11 e.(2) Construction Quality Assurance I Quality Control Manual, as revised (CQA/QC Manual) shall be 4.0 ft. on the top and 3.5 ft. on the side of the disposal cell. CLSM shall not be used in the upper ten feet of the l le.(2) embankment.
I 0.17 At the end of every calendar year, the Licensee shall ensure that the cumulative average activity concentration of waste placed within the upper three feet of disposed waste does not exceed 300 pCi/g ofRa-226 or 900 pCi/g of Th-230, and within the next seven feet does not exceed 500pCi/g Ra-226 or 1500 pCi/g ofTh-230. When both radionuclides are present, the unity rule
defined below shall apply to ensure that the Ra-226 limit is not exceeded within 1000 years.
Activity ofTh-230 (pCi/g)/X + Activity of Ra-226 (pCi)N <or= 1
Where:
X = 900 pCi/g in the upper three feet and 1500 pCi/g in the next seven feet of waste, and
Y = 300 pCi/g in the upper three feet and 500 pCi/gm in the next seven feet of waste
10.18 The cumulative average densities of the waste in the upper ten feet of the 11 e(2) embankment
and of the compacted radon barrier placed shall not be less than 1.5 g/cm3 for either.
SECTION 11. INSPECTION, MONITORING AND RECORDING REQUIREMENTS

DWMRC-03
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL RADIOACTIVE MATERIAL LICENSE
SUPPLEMENT ARY SHEET License# UT 2300478
Amendment #3
11.1 The Licensee shall fulfill and comply with all conditions and all compliance schedules stipulated in the Ground Water Discharge Permit, number UGW 450005, issued by the Director, as
amended.
11.2 The Licensee shall require that the RSO and the Engineering Director or designee perform and
document joint inspections of all work areas at least quarterly. The Licensee shall correct any deficiency noted during the inspection within seven working days. The results of the inspections and any necessary corrective actions shall be submitted to the Director in the 11 e.(2) Annual Report.
11.3 The Licensee is granted an exemption from R313-l 5-201 ( 4) and R313-l 5-302(2) and is authorized to use Annual Limit on Intake (ALI) and Derived Air Concentration (DAC) values based on dose coefficients adopted by the International Commission on Radiological Protection (ICRP) and published in ICRP publication No. 68 and adult dose factors published in ICRP publication No. 72, as required to demonstrate compliance with the requirements of Subpart C
and Subpart D of 10 CFR 20 (UAC R313-15).
11.4 The Licensee shall conduct an analysis to assess the need to characterize the basal aquifer.
SECTION 12. REPORTING REQUIREMENTS
12.1 The Licensee shall perform an annual ALARA audit of the radiation safety program which shall be led by the RSO or designee, qualified by way of specialized radiation protection training
equivalent to that required for the RSO as defined in License Condition 9.8, in accordance with
Section 2.3.3 ofNRC Regulatory Guide 8.31, as amended. A report ofthis audit shall be submitted to the Director in the 11 e.(2) Annual Report. The report shall include detailed summaries of the analytical results of the radiological surveys. In order to evaluate the A LARA objective, the Licensee shall, at a minimum, review the following records:
a)Bioassay results including any actions taken when the results exceed established action
levels as referenced in the NRC Regulatory Guide 8.9, "Acceptable Concepts, Models,Equations, and Assumptions For A Bioassay Program" as amended.
b)Records of external and internal exposure.
c)Safety meeting minutes, attendance records, and training program records.
d)Daily inspection log entries and summary reports of the annual review.
e)Radiological survey and monitoring data, as well as environmental radiological effluentand monitoring data.
f)Surveys required by radiation work permits.
g)Reports on overexposure submitted to the Director and previously submitted to the NRC.
h)Reviews of operating and monitoring procedures completed during the period.
DWMRC-03
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL
RADIOACTIVE MATERIAL LICENSE
SUPPLEMENTARY SHEET License# UT 2300478 Amendment #3
12.2 The ALARA audit shall also address any statistically significant trends in personnel exposures for identifiable categories of workers and types of activities, any trends in radiological effluent
data and the performance of exposure and effluent control equipment as well as its utilization,
maintenance and inspection history. Any recommendations to further reduce personnel exposures or environmental releases of uranium or radon and radon progeny shall be included in the report.
12.3 The Licensee shall conduct an annual land use survey for a five km radius around the site. The
purpose is to assess population growth or industry growth in the immediate vicinity of the Clive facility and provide an inventory of domestic and agricultural wells within the survey area. The Licensee shall document this survey in the 1 le.(2) Annual Report submitted to the Director.
12.4 The Licensee shall orally notify the Director within 24 hours and by submitting a letter within
seven days of any waste shipment where a violation of applicable regulations or license conditions occurs. For example:
a)Free liquids and leaking shipment discrepancy notifications made in accordance with
applicable provisions of the Waste Characterization Plan as referenced in Condition 58 ofRadioactive Materials License UT2300249.
12.5 Shipment discrepancies not addressed by the Waste Characterization Plan shall be noted on the
manifest and the manifest retained on site for Division review.
12.6 The Licensee shall, unless otherwise specified, include in 11 e.(2) the Annual Report submitted to the Director:
a)The annual reporting requirements as specified in the license conditions;
b)The results of calibration of equipment;
c)Reports on audits and inspections completed during the year;
d)The results of all meetings and training courses required by this license; and
e)Any other significant subsequent infonnation, reviews, investigations and corrective actions.Unless otherwise specified by rule, all such documentation shall be maintained at the site andcorporate headquarters for a period of at least five years.
12. 7 The Licensee shall, at least three months prior to license termination, submit to the Director a
report which demonstrates the site has met all applicable provisions for license termination and transfer of the facility to the government for long-term custody in accordance with R313-24-4 (IO CFR Part 40, Appendix A, Criterion 11 incorporated by reference). Specifically, the
Licensee shall document that:

a)
b)
c)
DWMRC-03
DIVISION OF WASTE MANAGEMENT AIID RADIATION CONTROL
RADIOACTIVE MATERIAL LICENSE
SUPPLEMENTARY SHEET
License # UT 2300478
Amendment #3
The concentrations ofall of the listed hazardous constituents at the POC are within their
designated concentration limits (standmds);
If a corrective action prcgram was implemented, that the hazardous constituents
contaminating the groundwater were returned to their designated limits; and
The facility has been properly decontaminated and decommissioned in accordance with the
decontamination and by the applicant in the license
application and shall not occur until the
Licensee has
12.8 The Licensee
a) Any
into
of waste