DRC-2022-021470 - 0901a068810f5ed5

�-------ENERG SOLUTIONs--------
September 30, 2022
Mr. Doug Hansen, Director Division of Waste Management and Radiation Control 195 North 1950 West Salt Lake City, UT 84114-4880
S P 3 0 2"22 CD-2022-166
Subject: Federal Cell Facility Application: Responses to the Director's September 20, 2022 Request for Information
Dear Mr. Hansen:
EnergySolutions hereby responds to Utah Division of Waste Management and Radiation Control's, September 30, 2022 Request for Information (RFI) on our Federal Cell Facility Application. 1 A response is provided for each request using the Director's assigned reference number. Two revised copies of the Federal Cell Facility Radioactive Material License Application ( one with and one without confidential information redacted) reflecting responses to the Director's request are hereto attached and provided under the same Permanent Claim of Business Confidentiality previously asserted.2
General
a)Redacted Information-The phrase "REDACT/ED INFORMATION" is misspelled throughout theApplication.
The notation has been corrected in the attached Application.
b)Documents Still Under Review-Several documents listed throughout the application andappendices are still under review by the Division, including (i) the Basal Aquifer Study, and (ii) theCover Test Cell Study. The Division has not yet approved all the study content. Please update thereferences to indicate their status, using appropriate notation (e.g., "under review by theDivision'').
The "Under review by the Division" notation has been added to the Basal Aquifer Study citation in the attached Application. Neptune references the Cover Test Cell Study in their DU PA ( contained in Appendix O of the Application). The DU PA of Appendix 0, in its entirety, is still under review by the Director. However, the "under review" notation has been added at the beginning of the Cover Test Cell Study document that is included in the Clive DUP A Report References folder within Appendix 0. 1 Hansen, DJ. "Federal Cell Facility Application Requests for Information." (DRC-2022-021135), Letter from Utah's Division of Waste Management and Radiation Control to Vern Rogers of Energy Solutions, September 20, 2022. 2 Rogers, V.C. "Radioactive Material License Application for a Federal Cell Facility Submitted under Permanent Claim of Business Confidentiality." (CD-2022-142), Letter from EnergySolutions to Doug Hansen of Utah's Division of Waste Management and Radiation Control, August 4, 2022. 299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111 [phone] • Fax: [phone] • www.energysolutions.comDRC-2022-021470
� E. 'ERGYSOLUTJONS
Section 1 Mr. Doug Hansen CD-2022-166September 30, 2022 RFI: 1.2.2-1 On Page 1-11, the link "General Industrial District M-G type uses" is expired and gives a 403 Forbidden message Error.
The hyperlink has been replaced with an electronic/PDF version of the referenced website in the attached Application.
Section 2
RFI: 2.1.2-1 -On Page 2-5, the "Census 2020" link sends the user an authentication message from a company that indicates that it will collect information on the user. Please fu: the link so a user does not have to agree to unexpected privacy-release requirements.
The hyperlink has been replaced with an electronic/PDF version of the referenced website in the attached Application.
RFI: 2.2.-1 -On Page 2-8, in the last paragraph of Section 2.2 entitled "Meteorology and Climatology", itstates, "an independent firm evaluated on-site meteorological data collected from June 1993 to December 2020. " However, EnergySolutions does not provide a citation for this claim.
The requested reference citation has been included in the attached Application.
RFI: 2.3.1-1 -On Page 2-8, the "Hintze, 1980" link sends the user to a publication webpage, but access isnot granted to allow the user to view the materials. Also, the publication associated with the link is Bisdorf and Zohdy (1980), not Hintze (1980).
An electronic copy of the reference has been included with the attached Application Section 2 References.
RFI: 2.4.1-1 -On Page 2-19, it says, "A Probable Maximum Precipitation and Probable Maximum Flood have been considered for the Clive Facilities (Appendix Y,)." However, searches for each of the terms probable, maximum, precipitation, flood, PMP, and PMF in Appendix Y turned up zero results.
The Application has been corrected to point the reader to Appendix Z for the reference of interest.
RFI: 2.10-1 -The following are discrepancies for citations referenced in this section and the associatedelectronic link to a file (Moore and Sorensen 1979, Neptune 2021, DOE 1984 and 1989, Ryan and Elimelech 1996, DWR 2014, Envirocare 2004, Cronquist et al 1972, NRC 1980, Utah 2014).
Electronic copies of the available references have been included in the attached Application Section 2 References. The DWR 2014 reference has been renamed DWR 2003 and that file has been added to the Application. The information cited in Conquist, et al (which is copyrighted, but no longer in print) has been replaced with a more recent reference.
RFI: 2.10.1-2 -On Page 2-55, the link "General Industrial District M-G type uses" is expired and gives a403 Forbidden message Error.
The hyperlink has been replaced with an electronic/PDF version of the referenced website in the attached Application Section 2 References. Page 2 oflO
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Section 3 Mr. Doug Hansen CD-2022-166 September 30, 2022 RFI: 3.1-1 -On Page 3-4, the "Table 3-1: Conditions[" 1]" bracketed citation link sends users to Microsoftword and gives an error message.
The footnote link has been repaired in the attached Application.
RFI: 3.1-2 -On Page 3-10, a typo appears in the hyper/ink with the bracketed 1 "fl]", this typo breaks thehyper/ink.
The footnote link has been repaired in the attached Application.
RFI: 3.1.1-1 -On Page 3-12, the Application says, "In addition, Appendix Y, HAL PMF Tech Memo,Figure 2 depicts the flow path of the modeled Probable Maximum Flood draining to the southwest of the Clive Facility." However, the memo does not appear to be in Appendix Y.
The Application has been corrected to point the reader to Appendix Z for the reference of interest.
RFI: 3.2-1 -On Page 3-22, the Application addresses the cover as a principal design feature, and states that, efforts to "encourage runoff' on the cover design slope, velocities must still be limited, and indicates use of the following as bounding values: Maximum theoretical velocities from Appendices M and 0, Maximum drainage velocities during PMP: from Appendices M and 0. However, a review of Appendix M indicates that the text and tables of Appendix M pertain only to ditch calculations, not runoff occurring over the cover. Calculations or concepts presented for the cover design, cover slope, cover runoff and cover drainage velocities do not appear to exist within Appendix M.
An electronic copy/PDF of the velocity calculations has been included in Appendix M of the attached Application.
RFI: 3.2.9-1-On Page 3-32, the referenced "Part B Attachment 11-6 Contingency Plan" is an outdated plan from April 25, 2017. Multiple edits have taken place on the contingency plan since that date, including the list of emergency coordinators. Please replace the reference given with the current contingency plan dated February 23, 2022.
The reference has been updated to the February 23, 2022 plan and an electronic copy/PDF of the reference has been included in the attached Application Section 3 References.
RFI: 3.4.1-1 -On Page 3-44 the referenced "Part B Attachment 11-6 Contingency Plan" is an outdatedplan from April 25, 2017. Multiple edits have taken place on the contingency plan since that date, including the list of emergency coordinators. Please replace the reference given with the current contingency plan dated February 23, 2022.
The reference has been updated to the February 23, 2022 plan and an electronic copy/PDF of the reference has been included in the attached Application Section 3 References.
Page 3 oflO
� ENERGY SOLUTIONS Mr. Doug Hansen CD-2022-166 September 30, 2022
RFI: 3 .4.3-1-On Page 3-47, the referenced "Part B Attachment II-6 Contingency Plan" is an outdated plan from April 25, 2017. Multiple edits have taken place on the contingency plan since that date, including the list of emergency coordinators. Please replace the reference given with the current contingency plan dated February 23, 2022.
The reference has been updated to the February 23, 2022 plan and an electronic copy/PDF of the reference has been included in the attached Application Section 3 References.
RFI: 3.5.1-1-On Page 3-49, the referenced "Part B Attachment II-6 Contingency Plan" is an outdated plan from April 25, 2017. Multiple edits have taken place on the contingency plan since that date, including the list of emergency coordinators. Please replace the reference given with the current contingency plan dated February 23, 2022.
The reference has been updated to the February 23, 2022 plan and an electronic copy/PDF of the reference has been included in the attached Application Section 3 References.
Section 4
RFI: 4.1.12-1-On Page 4-5 of the Application, it indicates that a review of unplanned events that have operational safety significance will be performed in accordance with procedure ES-AD-PR-008 Condition Report (Appendix J-?. A copy of this procedure is not included in Appendix V. Please provide a copy of or a link to ES-AD-PR-008 and identify the correct Appendix location. Three similar statements pointing to ES­AD-PR-008 are found in paragraphs 4.4. 7.3, 8.5 and 9.1.16.
A PDF of the procedure has been included in Appendix V of the attached Application.
RFI: 4.1.13-1-On Page 4-6, the Application refers to Procedure FCF-SW-PR-203 in Appendix G. It is named inconsistently within the paragraph, and within Appendix G. This may cause confusion when trying to find the correct reference. The procedure is called by the following various names: J. Federal Cell Facility Waste Acceptance Criteria, 2. FCF Waste Acceptance Criteria, 3. FCF WAC, 4. Federal Cell Facility Acceptance Criteria (in headers), 5. Federal Cell Facility Containerized Waste Acceptance Criteria, 6. The Waste Acceptance Criteria (e.g., in tables), Please name these references and listings consistently to avoid potential confusion or difficulty in finding the cited procedure. An acronym in addition to the full name would be acceptable if properly introduced at the beginning.
The naming convention for the information cited has been unified and included in the Application's List of Acronyms.
RFI: 4.4.1.3-1-On Page 4-17, the Application refers to FCF-SH-PR-500 as the Federal Cell Facility Contingency Implementation Plan (Appendix G). However, that document does not appear to be found in AppendixG.
An electronic copy of the requested reference has been included in Appendix G of the attached Application.
RFI: 4.4.7-1 -On Page 4-24, the Application refers to FCF-SH-PR-500 as the Federal Cell Facility Contingency Implementation Plan (Appendix G). However, that document does not appear to be found in AppendixG.
An electronic copy of the requested reference has been included in Appendix G of the attached Application.
Page 4 oflO
ENERGY SOLUTIONS
Mr. Doug Hansen CD-2022-166 September 30, 2022
RFI: 4.4. 7.3-1 -On Page 4-25 of the Application, it indicates that a review of unplanned events that have operational safety significance will be performed in accordance with procedure ES-AD-PR-008 Condition Report (Appendix J1. A copy of this procedure is not included in Appendix V. Please provide a copy of or a link to ES-AD-PR-008 and identify the correct Appendix location.
A PDF of the procedure has been included in Appendix V of the attached Application. RFI: 4.4.7-2 -On Page 4-24, the "Attachment II-6 of the state-issued Part B Permit" hyper/ink sends users to the DEQ webpage for the Part B Permit, but it does not send them to the specified attachment. Hyper/ink should be updated to the specified attachment.
The reference has been updated to the February 23, 2022 plan and an electronic copy/PDF of the reference has been included in the attached Application Section 3 References.
RFI: 4.5.1-1 -On Page 4-26, the referenced "Part B Attachment 11-6 Contingency Plan" is an outdated plan from April 25, 2017. Multiple edits have taken place on the contingency plan since that date, including the list of emergency coordinators. Please replace the reference given with the current contingency plan dated February 23, 2022.
The reference has been updated to the February 23, 2022 plan and an electronic copy/PDF of the reference has been included in the attached Application Section 3 References.
Section 5
RFI: 5.1.2.2-1-On Page 5-4, NRC (1986) is cited, but no hot-link or printed reference is provided.
An electronic copy of the requested reference has been included in the attached Application.
RFI: 5.2 .7-1 -On Page 5-8, the hyper/ink "GWQDP" does not work or is broken.
An electronic copy of the requested reference has been included in the attached Application, and the hyperlink removed.
RFI: 5.3.8-1 -On Page 5-12, DOE (2019) is cited, but no hot-link or printed reference is provided.
An electronic copy of the requested reference has been included in the attached Application.
RFI: 5.3.9-1-On Page 5-12, DOE (2019) is cited, but no hot-link or printed reference is provided.
An electronic copy of the requested reference has been included in the attached Application.
Section 6
RFI: 6.1.1.1-1-On Page 6-2, there is a reference to Clive DU PA CSM v2.0. Yet no previous citation or reference appears to be given for the CSM acronym.
CSM has been added to the Application's List of Acronyms. Page 5 oflO
� ENERGY SOLUTIONS
Mr. Doug Hansen CD-2022-166 September 30, 2022
RFI: 6.1.1.1-2 -On Page 6-2, there is a reference to Clive DU PA CSM v2.0. While the citation in each case does make a reference to Appendix 0, Appendix O contains 1,131 pages, and it provides no index to its contents.
Appendix O of the Application contains individual documents separated into unique electronic folders, subfolders, and files. The Clive DU PA CSM v2.0 document is 90 pages long and is located in the Appendix O subfolder named "Clive DU PA Report Appendices."
RFI: 6.1.3-1 -On Page 6-6, there is a reference to Clive DU PA CSM v2.0. While the citation in each case does make a reference to Appendix 0, Appendix O contains 1,131 pages, and it provides no index to its contents.
Appendix O of the Application contains individual documents separated into unique electronic folders, subfolders, and files. The Clive DU PA CSM v2.0 document is 90 pages long and is located in the Appendix O subfolder named "Clive DU PA Report Appendices."
RFI: 6.1.3-2 -On Page 6-7, there is a reference to Clive DU PA CSM v2.0. While the citation in each case does make a reference to Appendix 0, Appendix O contains 1,131 pages, and it provides no index to its contents.
Appendix O of the Application contains individual documents separated into unique electronic folders, subfolders, and files. The Clive DU PA CSM v2.0 document is 90 pages long and is located in the Appendix O subfolder named "Clive DU PA Report Appendices."
RFI: 6.1.4.2-1-On Page 6-10, the Application refers to FCF-SH-PR-500 as the Federal Cell Facility Contingency Implementation Plan (Appendix G). However, that document does not appear to be found in AppendixG.
The document has been added to Appendix G of the Application.
RFI: 6.1.5-1 -On Page 6-11, there is a reference to Clive DU PA CSM v2.0. While the citation in each casedoes make a reference to Appendix 0, Appendix O contains 1,131 pages, and it provides no index to its contents.
Appendix O of the Application contains individual documents separated into unique electronic folders, subfolders, and files. The Clive DU PA CSM v2.0 document is 90 pages long and is located in the Appendix O subfolder named "Clive DU PA Report Appendices."
RFI: 6.1.5.1-1 -On Page 6-13, there is a reference to Clive DU PA CSM v2.0. While the citation in each case does make a reference to Appendix 0, Appendix O contains 1,131 pages, and it provides no index to its contents.
Appendix O of the Application contains individual documents separated into unique electronic folders, subfolders, and files. The Clive DU PA CSM v2.0 document is 90 pages long and is located in the Appendix O subfolder named "Clive DU PA Report Appendices."
Page 6 oflO
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Mr. Doug Hansen CD-2022-166 September 30, 2022
RFI: 6.1.5.2-1-On Page 6-15, there is a reference to Clive DU PA CSMv2.0. While the citation in each case does make a reference to Appendix 0, Appendix O contains 1,131 pages, and it provides no index to its contents.
Appendix O of the Application contains individual documents separated into unique electronic folders, subfolders, and files. The Clive DU PA CSM v2.0 document is 90 pages long and is located in the Appendix O subfolder named "Clive DU PA Report Appendices."
RFI: 6.1.5.3-1 -On Page 6-19, there is a reference to Clive DU PA CSM v2.0. While the citation in each case does make a reference to Appendix 0, Appendix O contains 1,131 pages, and it provides no index to its contents.
Appendix O of the Application contains individual documents separated into unique electronic folders, subfolders, and files. The Clive DU PA CSM v2.0 document is 90 pages long and is located in the Appendix O subfolder named "Clive DU PA Report Appendices."
RFI: 6.1.6.2-1-On Page 6-23, there is a reference to Clive DU PA CSM v2.0. While the citation in each case does make a reference to Appendix 0, Appendix O contains 1,131 pages, and it provides no index to its contents.
Appendix O of the Application contains individual documents separated into unique electronic folders, subfolders, and files. The Clive DU PA CSM v2.0 document is 90 pages long and is located in the Appendix O subfolder named "Clive DU PA Report Appendices."
RFI: 6.1.6.3-1-On Pages 6-26, there is a reference to Clive DU PA CSMv2.0. While the citation in each case does make a reference to Appendix 0, Appendix O contains 1,131 pages, and it provides no index to its contents.
Appendix O of the Application contains individual documents separated into unique electronic folders, subfolders, and files. The Clive DU PA CSM v2.0 document is 90 pages long and is located in the Appendix O subfolder named "Clive DU PA Report Appendices."
RFI: -6.1.6.4-1 -On Pages 6-27, there is a reference to Clive DU PA CSM v2.0. While the citation in each case does make a reference to Appendix 0, Appendix O contains 1,131 pages, and it provides no index to its contents.
Appendix O of the Application contains individual documents separated into unique electronic folders, subfolders, and files. The Clive DU PA CSM v2.0 document is 90 pages long and is located in the Appendix O subfolder named "Clive DU PA Report Appendices."
RFI: 6.1.4.2-2 -On Page 6-10, NRC (1980a) is cited but no hot links,printed references or digital references are provided.
An electronic copy of the requested reference has been included in the attached Application Section 6 References.
Page 7 oflO
� ENERGY SOLUTIONS
Mr. Doug Hansen CD-2022-166September 30, 2022
RFI: 6.3.1-1 -On Pages 6-35, there is a reference to Clive DU PA CSM v2.0. While the citation in each case does make a reference to Appendix 0, Appendix O contains 1,131 pages, and it provides no index to its contents.
Appendix O of the Application contains individual documents separated into unique electronic folders, subfolders, and files. The Clive DU PA CSM v2.0 document is 90 pages long and is located in the Appendix O subfolder named "Clive DU PA Report Appendices."
RFI: 6.4.2-1 -On Page 6-45, a reference is given/or "Bingham Environmental, "Hydrogeologic Report Mixed Waste Disposal Area at Envirocare of Utah Waste Disposal Facility, South Clive, Utah." Parts 1 & 2, July 1992. (Bingham Environmental, 1992)." But the citation is given on Page 6-42 as "(Bingham 1992a, b, and c). "In other words, in the citation, (i) instead of "Bingham Environmental" only "Bingham" is used, (ii) instead of "1992", "1992a, b and c" is used, and (iii) instead of references to only Parts 1 and 2, references are given to 1992a, 1992b and 1992c (three documents compared with two, and letters instead of numbers used to differentiate references from the same year). In addition, the associated electronic files included in the Application include only a single, unindexed file called Bingham.pd/ consisting of 3,127 pages.
The naming convention for the information cited has been corrected in the attached Application. Additionally, the PDFs provided were prepared by Bingham Environmental and are fully indexed/bookmarked.
RFI: 6.4.2-1-On Page 6-46, a reference is given/or DOE (1989). However, there appears to be no citation or electronic file submitted for that reference.
The DOE, 1989 reference has been removed from Section 6 of the Application.
Section 7
RFI: 7.1.3-1-On Page 7-3, the Application refers to FCF-AD-PR-100 as the Federal Cell Facility License Compliance (Appendix J). However, a document having this name does not appear in Appendix J. A
document having a similar but slightly different name and having the same numerical identification code does exist in the Appendix.
The naming convention for the referenced procedure in Appendix J has been unified in the attachedApplication.
RFI: 7.3.4-1-On Page 7-9, NRC (1993b) is cited. However, NRC (1993b) is not referenced in Section 7 as a reference, nor is it provided as an electronic file in the Application. However, there is a reference in the section/or NRC (1993a), along with an electronic file/or NRC 1993a.pdf, but no citation in the text/or NRC (1993a). Please adjust the citation and/or re/erence(s) to make the items mutually consistent.
The referenced NRC (1993b) document has been added to the attached Application Section 7 References.
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Mr. Doug Hansen
CD-2022-166
September 30, 2022
Page 9 of 10

RFI: 7.3.4-2 - On Page 7-10, NRC (1993b) is cited. However, NRC (1993b) is not referenced in Section 7
as a reference, nor is it provided as an electronic file in the Application. However, there is a reference in
the section for NRC (1993a), along with an electronic file for NRC 1993a.pdf, but no citation in the text for
NRC (1993a). Please adjust the citation and/or reference(s) to make the items mutually consistent.

The referenced NRC (1993b) document has been added to the attached Application Section 7
References.

RFI: 7.4.5-1 - On Page 7-17, the “49 CFR 173” link takes a user to a 49 CFR overview chapter rather than
directly to Part 173.

The hyperlink has been removed and an electronic version/PDF of 49 CFR 173 added to the attached
Application Section 7 References.

RFI: 7.4.5-2 - On Page 7-17, the “49 CFR 173.443” link works, but it is only underlined, not highlighted
in blue. A user might not find the link name easily.

The hyperlink has been removed and an electronic version/PDF of 49 CFR 173 added to the attached
Application Section 7 References.

RFI: 7.5.1-1 - On Page 7-19, the “49 CFR 172.450” link has a blue highlight, but the hyperlink is not
working.

The hyperlink has been removed and an electronic version/PDF of 49 CFR 172.450 added to the
attached Application Section 7 References.

Section 8
RFI: 8.4-1 - On Page 8-24 the referenced “Part B Attachment II-6 Contingency Plan” is an outdated plan
from April 25, 2017. Multiple edits have taken place on the contingency plan since that date, including the
list of emergency coordinators. Please replace the reference given with the current contingency plan dated
February 23, 2022.

The reference has been updated to the February 23, 2022 plan and an electronic copy/PDF of the
reference has been included in the attached Application Section 3 References.

RFI: 8.4.3-1 - On Page 8-25, the “NRC Regulatory Guide 4.20” hyperlink does not work.

The hyperlink has been replaced with an electronic version/PDF of the referenced NRC guide in the
attached Application Section 8 References.

RFI: 8.5 - On Page 8-26 of the Application, it indicates that a review of unplanned events that have
operational safety significance will be performed in accordance with procedure ES-AD-PR-008 Condition
Report (Appendix V). A copy of this procedure is not included in Appendix V. Please provide a copy of or a
link to ES-AD-PR-008 and identify the correct Appendix location.

A PDF of the procedure has been included in Appendix V of the attached Application.

RFI: 8.8.1-1 - On Page 8-30 the referenced “Part B Attachment II-6 Contingency Plan” is an outdated
plan from April 25, 2017. Multiple edits have taken place on the contingency plan since that date,
� ENERGYSOLUTIONS
Mr. Doug Hansen CD-2022-I 66September 30, 2022
including the list of emergency coordinators. Please replace the reference given with the current contingency plan dated February 23, 2022.
The reference has been updated to the February 23, 2022 plan and an electronic copy/PDF of the reference has been included in the attached Application Section 3 References.
Section 9
RFI: 9.1.2.3-1 -On Page 9-7, the last paragraph cites "Nonmandatory Appendix 2A-1" and"Nonmandatory Appendix 2A-3. "No hot-linked files or printed references appear to be associated with these file or document names.
The referenced ASME NQA documents have been added to the Application's Section 9 References.
RFI: 9.1.16-On Page 9-27 of the Application, it indicates that a review of unplanned events that have operational safety significance will be performed in accordance with procedure ES-AD-PR-008 Condition Report (Appendix V). A copy of this procedure is not included in Appendix V. Please provide a copy of or a link to ES-AD-PR-008 and identify the correct Appendix location.
A PDF of the procedure has been included in Appendix V of the attached Application.
If you have further questions regarding these responses and revision 2 to the Application, please contact me at(801) 649-2000. �r· r:0 ��ers 'r �Director, Regulatory Affairs
digital enclosures (via compact discs)
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