DRC-2022-021364 - 0901a068810f2dfb

DRC-2022-021364 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

October 3, 2022

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

RE: Federal Cell Facility Application Requests for Information #2

Dear Mr. Rogers:

The Division of Waste Management and Radiation Control (Division) hereby provides Requests for
Information (RFI) regarding the Federal Cell Facility Application dated August 4, 2022. Each
individual paragraph in the attached document is numbered and represents an issue discovered in a
review of the application. When responding to an RFI, please use the assigned number representing the
question. The Division will track all responses and provide regular updated information to the public
and reviewers.

The current review does not represent a comprehensive evaluation of the Application’s merit and
additional RFIs will follow where appropriate.

If you have any questions regarding this letter, please call Otis Willoughby at [phone].

Sincerely,

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

(Over)

Enclosure: Federal Cell Facility Requests for Information #2 (DRC-2022-021351)

DJH/OHW/JK/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
DRC-2022-021351 Page 1 of 14

Federal Cell Application Review

Request for Information or Updates to the Application (RFI)

General
• Each of the RFIs has been assigned an identifier with a numbering convention as follows-
o Application/Appendix Section
▪ Section/Appendix Subsection
• Section/Appendix Subsubsection (when applicable)
o Sequential numbering
Example: A question in Section 1, subsection 1, subsubsection 1 -The first RFI # would
be 1.1.1-1, the next question in that section/subsection would be numbered 1.1.1-2
Please refer to the assigned RFI number when submitting a response.

Appendix B: Federal Cell Facility Engineering Drawings
• B-1
On Page B-2, the names of the engineering drawings list Drawings 0801-G04 and 07007-
J01 consecutively, i.e., with no named drawing listed between them. However, in the
actual drawings presented in the Appendix, immediately following Page B-3, an untitled
aerial photograph exists between Drawing 0801-G04 and Drawing 07007-J01. The
untitled photograph existing between Drawing 0801-G04 and Drawing 07007-J01 (near
the beginning of the photos and drawings) should be moved to the end of the list (i.e.,
after Map 111) and labeled as “2021 Aerial Photograph of the Clive Disposal Facility.”
• B-2
Map 111 is not a product of the United States Geological Survey, or USGS, as labeled in
the list of engineering drawings on Page B-3. A careful examination of Map 111 shows
that it is instead a product of the Utah Geological Survey, or UGS. The name of the map
should be updated to its proper name: “Map 111: UGS Flood Hazards of Lakes and
Failure of Dams in Utah.”

Appendix C: Federal Cell Construction Quality Assurance / Quality Control Manual
DRC-2022-021351 Page 2 of 14

• C-1
In the table of contents, it states that Annual As-Built Report Specifications section
contains specifications 281-183. The numbers seem to be in error, as the page range is
backwards, or a number is misrepresented. Please correct the numbers for the Annual As-
Built Report Specifications.
• C-2
Pages C-1 through C-99 have “Radioactive Material License Application / Federal Cell
Facility” in the headers. This includes (sub)Appendices A, B and C (of the Application
Appendix C), all of which are dated January 5, 2022. However, the next page is blank
and the subsequent pages, are unnumbered, and have headers and footers with “LLRW
and 11e.(2) CQA/QC Manual” in the title with a date of February 12, 2020, representing
a date from two years earlier, labeled Revision 28c.
• C-3
The section labeled with headers “LLRW and 11e.(2) CQA/QC Manual”, have been
created two years prior to the first section. The latter section is identified as applying to
the LLRW and 11e.(2) Cells, not to the Federal Cell. The two different versions of
(sub)Appendices A, B and C as presented in Appendix C of the Application are
confusing without explanation. If both references are intended to be presented, please
provide explanatory material in the overall introduction indicating their purpose.

Appendix D: Geotechnical
• D-1
The following are discrepancies for citations in this section and the accompanying
references and/or the associated electronic reference files:
Pages Citation in Text of
Appendix
Reference Listed in
REFERENCES
Electronic
Reference
3 (Neptune, 2015) Yes, but two different Neptune
(2015) references are given
Missing
3, 17,
25
(DWMRC, 2021) Yes Missing
4, 5, 6,
18, 26
(Bingham, 1992) Bingham Environmental (1992)
(Three different documents)
Missing
4, 17,
24, 25
(AMEC 2005) Yes Missing
4, 24,
25
(AMEC 2011) Yes Missing
4, 25 (AMEC 2012) Yes Missing
5, 6 (Stantec 2020) Yes Missing
DRC-2022-021351 Page 3 of 14

7, 8 (EnergySolutions, 2021) Missing Missing
9 (DWMRC 2005) Missing Missing
9 (DWMRC 2011) Missing Missing
11 (Lee and Kim 2014) Yes, but should be Lee, K-J,
Kim, S-K and Lee, K-H (2014)
Missing
11 (GEOSTUDIO, 2019) GEO-STUDIO International,
Ltd. (2019)
Missing
12,14 (Hynes-Griffin, 1984)
[2nd Author Missing]
Hynes-Griffin, Mary E. and
Franklin, Arley G. (1984)
Missing
12 USACE (1984) Missing Missing
11, 12 USACE (2003) Yes Missing
12 Makdisi & Seed (1978) Makdisi, F.I., and H.B. Seed
[1978] [no ampersand]
Missing
5, 12 (EnergySolutions, 2020) Yes Missing
16 Makdisi and Seed (1978) Yes Missing
17 Idriss and Boulanger (2008) Yes Missing
18 (D&M 1984) Missing Missing
18 (AGRA 1999) Missing Missing
18 (AMEC 2004) Missing Missing
19 (Qian et al. 2002) Yes, but out of order
alphabetically in REFERENCES
Missing
29 Missing ASTM International
(incomplete)
Missing

Appendix E: Federal Cell Facility Operating Environmental Monitoring Program
Section 2.0 of Appendix E is entitled REFERENCES, but the included items do not have
links to any associated electronic reference files. If the references are an integral part of
the Application, a reference file is needed for review.
The following are discrepancies for references and their citations as noted in italics.
2.0 REFERENCES
• E-1
Clive, Radiation Protection Program, Salt Lake City, EnergySolutions, Inc, Utah, As
Revised. This reference has no author or publication date listed. In addition, this
reference is not cited within the text.

• E-2
DRC-2022-021351 Page 4 of 14

Clive, Clive Facility Security Operations Protocol (CL-SE-PR-001), As Revised. This
reference has no author or publication date listed.
• E-3
Drawing 07007-J03, is referred in the text on Page 12, but does not have proper citation
and is missing from the REFERENCES.
• E-4
EPA, 2009 is cited in the text, but is missing in the REFERENCES.
• E-5
ICRP Publication 60, Recommendations of the International Commission on Radiation
Protection, Annals of the International Commission on Radiation Protection Vol. 21 No.
1-3, 1990. This reference is not cited within the text.
• E-6
ICRP Publication 65, Protection against Radon-222 at Home and at Work, Annals of the
International Commission on Radiation Protection Vol. 23 No. 2, 1993. This reference is
not cited within the text.
• E-7
ICRP Publication 66, Human Respiratory Tract Model for Radiation Protection, Annals
of the International Commission on Radiation Protection Vol. 24, 1994. This reference is
not cited within the text.
• E-8
ICRP Publication 68, Dose Coefficients for Intakes of Radionuclides by Workers, Annals
of the International Commission on Radiation Protection Vol. 24 No. 4, 1995. This
reference is not cited within the text.
• E-9
ICRP Publication 72, Age-dependent Doses to Members of the Public from Intake of
Radionuclides, Annals of the International Commission on Radiation Protection Vol. 26
No. 1, 1996. This reference is not cited within the text.
• E-10
MSI, 2013 is cited in the text, but missing in the REFERENCES.

DRC-2022-021351 Page 5 of 14

• E-11
Regulating the Disposal of Low-Level Radioactive Waste – A Guide to The Nuclear
Regulatory Commission’s 10 CFR Part 61, United States Nuclear Regulatory
Commission, 1989 This reference has no author listed.
• E-12
Regulatory Guide 1.86, Termination of Operating Licenses for Nuclear Reactors, United
States Nuclear Regulatory Commission, 1974 This reference has no author listed.
• E-13
NRC Staff Interim Guidance, Evaluations of Uranium Recovery Facility Surveys of
Radon and Radon Progeny in Air and Demonstrations of Compliance with 10 CFR
20.1301 – Revised Draft Report for Comment, March 2014. This reference is not cited
within the text.
• E-14
NUREG-1388, Environmental Monitoring of Low-Level Radioactive Waste Disposal
Facility, United States Nuclear Regulatory Commission, 1989. This reference is not cited
within the text.
• E-15
NUREG-1573, A Performance Assessment Methodology for Low-Level Radioactive
Waste Disposal Facilities, United States Nuclear Regulatory Commission, 2000. This
reference is not cited within the text.
• E-16
NRC Regulatory Guide 3.51, XXX, United States Nuclear Regulatory Commission,
19XX This reference is cited within the text but missing in REFERENCES.
• E-17
NRC Regulatory Guide 3.64, Calculation of Radon Flux Attenuation by Earthen Uranium
Mill Tailings Covers, United States Nuclear Regulatory Commission, 1989 This
reference is not cited within the text.
• E-18
NRC Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Programs
(Normal Operations) - Effluent Streams and the Environment, United States Nuclear
Regulatory Commission, 2007. This reference is not cited within the text.

DRC-2022-021351 Page 6 of 14

• E-19
NRC Regulatory Guide 4.18, Standard Format and Content of Environmental Reports for
Near-Surface Disposal of Radioactive Waste, United States Nuclear Regulatory
Commission, 1983. This reference is not cited within the text.
• E-20
NRC Regulatory Guide 8.34, Monitoring Criteria and Methods to Calculate Occupational
Radiation Doses, United States Nuclear Regulatory Commission, 1992. This reference is
not cited within the text.
• E-21
NRC Regulatory Guide 8.37, ALARA Levels for Effluents from Materials Facilities,
United States Nuclear Regulatory Commission, 1993. This reference is not cited within
the text
• E-22
NRC Radon Presentation Oak Ridge Institute for Science and Education, 2011. This
reference is not cited within the text.
• E-23
Tables 1 through 3 and Drawing 07007-J01, while referred to in the text on Pages 12, 13
and 15, do not have citations and are missing from the REFERENCES list.
• E-24
10 CFR Part 20, Standards for Protection Against Radiation, United States Nuclear
Regulatory Commission, As Revised. This reference is not cited within the text.
• E-25
10 CFR Part 40, Domestic Licensing of Source Material, United States Nuclear
Regulatory Commission, As Revised. This reference is not cited within the text.
• E-26
10 CFR Part 61 is cited in the text but missing in the REFERENCES.
• E-27
49 CFR.173.428, Empty Class 7 (radioactive) materials packaging, United States
Department of Transportation, As Revised. This reference is not cited within the text.

• E-28
DRC-2022-021351 Page 7 of 14

49CFR 173.443, Contamination control, United States Department of Transportation, As
Revised. This reference is not cited within the text.
• E-29
United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR),
Volume I: Sources, 2006. This reference is not cited within the text.

Appendix G: Federal cell facility waste receipt and inspection procedures
• G-1
On Page 3 of 11 of the Federal Cell Facility Generator Certification, Section 3.1.4 says in
part,
Certified Federal Cell Facility Generator Approval - The Certified Federal Cell
Facility Generator Approval (Attachment 8.2) signifies EnergySolutions’ review
of the FCF-WPR has been satisfactorily completed.
The title of Attachment 8.2 is indicated here to be the “Certified Federal Cell Facility
Generator Approval.” However, on Page 3 of 33, in the FCF-CW-PR-203 section, it says:
Any deviation from the requirements of this procedure must be approved in
accordance with Attachment 8.2, WAC Variance Request Form.
The latter gives a different name, i.e., “WAC Variance Request Form” for the form
associated with Attachment 8.2 than the name referred to in Section 3.1.4. The
discrepancy needs corrected or clarified.
• G-2
An electronic search for Attachment 8.2 shows no attachment of this name associated
with Appendix G.
• G-3
On Page 5 of 11 of the Federal Cell Facility Generator Certification, Section 4.2 says:
“The federal generator provides EnergySolutions’ Director of Technical Services
with the information identified on the Federal Cell Facility WPR (Attachment 8.1)
regarding their waste types as well as their procedures for radioactive waste
characterization, management, and quality assurance/quality control:”
An electronic search for Attachment 8.1 shows no attachment of this name associated
with Appendix G.

DRC-2022-021351 Page 8 of 14

• G-4
On Page 23 of 33 of the FCF-CW-PR-203 section, item 4.21.9.2 says:
“Annotate the quantity of SNM on the scheduling form within Customer Portal or
on the Advanced Shipment Notification Form, CL-CW-PR-203-F1, (Attachment
8.3) as described in Step 4.11”.
A search for Attachment 8.3 shows no attachment of this name associated with Appendix
G.
• G-5
On Page 4 of 16 of the FCF-LB-PR-041 section, item 3.1.14 refers to:
SW-846 (Test Methods for Evaluating Solid Waste, Physical/Chemical Methods)
–A set of analytical methods with corresponding quality control requirements
specified by the Environmental Protection Agency for the purpose of testing
hazardous wastes for chemical composition. See Reference 2.10.
However, Reference 2.10 in the REFERENCES section of FCF-LB-PR-041 is the “FCF-
TN-PR-030 Qualification Procedure.” A search indicates that Appendix G does not include a
copy of this procedure.
• G-6
On Page 5 of 16 of the FCF-LB-PR-041 section, item 3.1.16 refers to:
Treatment Standards – The concentration limits that hazardous wastes must meet for
land disposal, as listed in reference 2.8. Underlying Hazardous Constituents (UHCs)
described in Reference 2.8 are also applicable if the waste contains characteristic
hazardous waste codes.
However, Reference 2.08 in the REFERENCES section of the FCF-LB-PR-041 section is the
“FCF-LB-PR-003, Sample Control.” A search indicates that Appendix G does not include a
copy of this reference.
• G-7
On Page 121 of 189 of Appendix G, labeled as Page 5 of 16 of the FCF-LB-PR-041 section,
item 3.2.2 refers to:
Environmental Engineer, or designee, documents analysis requirements in accordance
with Reference 2.11, and evaluates analytical data for compliance with the
requirements, licenses and permits, and Reference 2.7 and 2.8.
However, References 2.7 and 2.8 in the REFERENCES section of the FCF-LB-PR-041
section are, respectively, “2.7 CL-WM-PR-001, Waste Profile and Acceptance Process”
and “2.8 FCF-LB-PR-003, Sample Control.” And 2.11 is not found in the REFERENCES
section. A search indicates that Appendix G does not include any of these references.
DRC-2022-021351 Page 9 of 14

• G-8
On Pages 6 and 7 of 16 of the FCF-LB-PR-041 section, items 3.3.1.7, 3.3.1.8, 3.3.1.9, and
3.3.1.10 are shown with multiple emendations in red font, and/or underlined. Does
EnergySolutions wish the Division to evaluate these emendations as if they were in final
format?
• G-9
On Page 7 of 16 of the FCF-LB-PR-041 section, item 3.3.2.1 refers to “Samples for
radiological analysis shall be analyzed in accordance with reference 2.13.”
However, Reference 2.13 does not exist in the REFERENCES part of the FCF-LB-PR-041.
• G-10
On Page 7 of 16 of the FCF-LB-PR-041 section, item 3.3.2.3 refers to “Personnel performing
this procedure shall be qualified on the tasks or activities contained in this procedure
according to reference 2.14, Qualification Procedure.”
However, Reference 2.14 does not exist in the REFERENCES part of the FCF-LB-PR-041.
• G-11
On Pages 9, 10 and 11 of 16 of the FCF-LB-PR-041 section, items 3.3.2.9, 4.1.8, and 4.3.1.
are shown with multiple emendations in red font, and/or underlined. Does EnergySolutions
wish the Division to evaluate these emendations as if they were in final format?
• Text below refers to RFI G-12 through G-22.
On Page 17 of 36 of the FCF-WM-PR-001 Section, the following list of documents is
provided:
5.1 FCF-WM-PR-001 F2 (EC-0230), Federal Cell Facility Radioactive Waste Profile
Record
5.2 FCF-WM-PR-001 F3 (EC-0230-SNM), FCF SNM Exemption Certification
5.3 FCF-WM-PR-001 F5 (EC-2000), Pre-shipment Sample Authorization Record
5.4 FCF-WM-PR-001 F6 (EC-0675), Radiological Evaluation
5.5 FCF-WM-PR-001 F7 (EC-0025), Physical Properties Evaluation
5.6 FCF-WM-PR-001 F8 (EC-0325), FCF Evaluation
5.7 FCF-WM-PR-001 F10 (EC-1800), Federal Cell Facility Notice to Transport
5.8 FCF-WM-PR-001 F1, Federal Waste Shipment Authorization
5.9 FCF-WM-PR-001 F11, Safety and Health Evaluation Form

DRC-2022-021351 Page 10 of 14

• G-12
Attachment 5.1 is labeled as “Attachment 5.1 – Federal Cell Facility Waste Profile Record”
(without the word Radioactive immediately after Facility). The introductory list has a name
of “Federal Cell Facility Radioactive Waste Profile Record.” Naming/Titled documents need
to be consistent.
• G-13
Attachment 5.2 is labeled as “Attachment 5.2 SNM Exemption Certification” (without the
acronym FCF immediately before SNM). The introductory list has a name of “FCF SNM
Exemption Certification.” Naming/Titled documents need to be consistent.
• G-14
Attachment 5.3 is missing from the FCF-WM-PR-001 Section.
• G-15
Attachment 5.4 is labeled as “Attachment 5.4 – Pre-shipment Sample Authorization Record”.
The introductory list has a name of Attachment 5.3 Naming/Titled documents need to be
consistent.
• G-16
Attachment 5.5 is labeled as “Attachment 5.5 – Radiological Evaluation.” The introductory
list has a name of Attachment 5.4. Naming/Titled documents need to be consistent.
• G-17
Attachment 5.6 is labeled as “Attachment 5.6 – Physical Properties Evaluation.” The
introductory list has a name of Attachment 5.5. Naming/Titled documents need to be
consistent.
• G-18
Attachment 5.7 is labeled as “Attachment 5.7 – Non-RCRA LLRW Evaluation”. The
introductory list has a name of Attachment 5.6 or “FCF Evaluation,”. Note the errors in both
the attachment number and the attachment name. Naming/Titled documents need to be
consistent.
• G-19
Attachment 5.8 is missing from the FCF-WM-PR-001 Section.
• G-20
Attachment 5.9 is labeled as “Attachment 5.9 – Federal Cell Facility Notice to Transport”.
The introductory list has a name of Attachment 5. Naming/Titled documents need to be
consistent.

DRC-2022-021351 Page 11 of 14

• G-21
Attachment 5.10 is labeled as “Attachment 5.10 – Federal Cell Facility Waste Shipment
Authorization” (with the word Facility immediately before Waste). The introductory list has
a name of Attachment 5.8 or “Federal Waste Shipment Authorization”. Note the errors in
both the attachment number and the attachment name. Naming/Titled documents need to be
consistent.
• G-22
Attachment 5.1 is labeled as “Attachment 5.11 – Safety and Health Evaluation”. The
introductory list has a name of Attachment 5.9 or “Safety and Health Evaluation Form”. Note
the errors in both the attachment number and the attachment name. Naming/Titled documents
need to be consistent.

Appendix H: Federal cell facility waste handling and interim storage procedures
• H-1
For document FCF-LD-PR-020, this screenshot of the table of contents shows the following
errors:

• H-2
Section 4.5 is missing.

DRC-2022-021351 Page 12 of 14

• H-3
For document FCF-LD-PR-020, Page 14 of 18:
5 ATTACHMENTS AND FORMS
5.1 FCF-LD-PR-020 F1, Placed Waste Removal Record
5.2 Placed Waste Removal Record Completion Instructions
5.3 Example of Shredder Daily Start-Up Checklist
5.4 FCF-LD-PR-020 F2, Equipment and Facility Release Form
5.5 FCF-LD-PR-020 F3, Daily Truck Load Worksheet
For the document FCF-LD-PR-020, the attachment named Attachment 5.3 (Example of Shredder
. . .) on Page 14 of 18 is missing.

• H-4
For the document FCF-WT-PR-001, the same Attachment number 5.3 is shown for the two
separate attachments. No proper attachment number 5.4 is written on or associated with the
title of the last attachment.

Appendix I: Federal cell facility waste disposal procedures
• I-1
For the document CL-CH-PR-250 Revision 7, attachment documents having numbers 5.4
and 5.5 in their titles are shown incorrectly in the table of contents on Page 7 of 12 as
attachments 5.3 and 5.4.

Appendix K: Federal cell facility radiation protection programs and procedures
• K-1
On Page 32 of 45, in 4.4.1.1, the following two citations are made:
ANSI 1973
Kusnetz 1956
These are missing in the REFERENCES section.

DRC-2022-021351 Page 13 of 14

• K-2
On Page 34 of 45, Public Health Services (1957) is cited. This citation is missing in the
REFERENCES section.

Appendix L: Decontamination and Decommissioning Plan
• L-1
A REFERENCES section exists for Appendix L, but Appendix L contains no citations.
Please provide specific citations and references in support of any information from an
outside source provided in a submitted document. Specific citations are generally needed
instead of only broad references. Unless it is common knowledge being provided,
information in an Appendix taken or derived from a source other than EnergySolutions’
should be referenced using both citations and references.
The eighth reference, one that pertains to Standards for Protection Against Radiation,
Subpart E – Radiological Criteria for License Termination, does not contain a date.

Appendix O: DU PA Version 2.0
• O-1
On Page 9 of the User Guide for the Clive DU PA Model), it says:
“Duration: If Perform dose calculations is checked, then the user can select the
duration of the dose simulation, up to 10,000 yr, in accordance with UAC 313-25-
8.(2)(a)”.
However, UAC 313-25-8.(2)(a) does not exist.

Appendix Z: Rock Cover Design Calculations
• Z-1
Page Z-2 lists the third analysis provided in Appendix Z as being “Rock Cover Design
Calculations, Rev 2”. However, the document found at the end of Appendix Z does not
have a title or text that the Document version is Rev 2. This document is called “Class A
West (CAW) Rock Cover Design Calculations”, not “Rock Cover Design Calculations”
as referred to on Page Z-2. Because of different geometries, the two different
embankments described (i.e., the CAW and the Federal Cell) may require different
design calculations. Please correct revision titles and ensure that the citation and the
Appendix name are consistent.
DRC-2022-021351 Page 14 of 14

• Z-2
Jensen, 2002 is cited twice on Page 3 of 13 in CAW Rock Cover Design Calculations but
a corresponding reference is not provided.