DRC-2022-022207 - 0901a0688110cf7c

DRC-2022-022207 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 27, 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 Request for Information

Dear Mr. Rogers:

The Division of Waste Management and Radiation Control 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 identified 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
RFI’s 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

DJH/OHW/wa

Enclosure: Request for Information or Updates to the Application (RFI) (DRC-2022-022189)

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
Federal Cell Application Review

Request for Information or Updates to the Application (RFI)

General
• Each of the RFI’s 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 Y: Occupational Dose Calculations

• Y-1
EnergySolutions used the MicroShield computer software to determine reasonable worker
doses associated with operations involving DU waste. However, eight short-lived daughter
products from the decay of U-238, U-235 and Ra-226 were not included in the “DU Without
Grout” MicroShield case. Uranium-238 (U-238) has two short-lived daughter products: Th-
234 and Pa-234m; Th-230; Ra-226 has five short-lived daughter products: Rn-222, Po-218,
Pb-214, Bi-214, and Po-214; and U-235 has one short-lived daughter product. Th-231 short-
lived daughter products: Cs-137 and Sr-90 (i.e., Ba-137m and Y-90, respectively) were
included. Re-analyze the “DU Without Grout” case with all the short-lived daughter products
including Cs-137 and Sr-90.
• Y-2
In addition, the “DU With Grout” case will also need to be reanalyzed with all the short-lived
daughter products from above including Cs-137 and Sr-90.

• Y-3
EnergySolutions MicroShield source term assumes that activation and fission products are
present in all the DU waste (i.e., clean/unirradiated DU waste, as well as contaminated/
recycled DU waste). Appendix O, NAC-0023_R5 indicates that activation and fission
products are only present in contaminated/recycle DU and that contaminated/recycled DU
waste constitutes only about 3.92% of the DU waste. Provide justification for including
activation and fission products in the clean/unirradiated DU waste for Appendix Y.

• Y-4
EnergySolutions used a radiation weighting factor of 20, which is recommended in
International Commission on Radiological Protection (ICRP) 103 for alpha radiation, to
convert from rads to rems. Although many of the DU-waste radionuclides are alpha emitters,
the dose rate calculated by MicroShield is entirely due to gamma radiation. Therefore, the
ICRP 103 recommended gamma (i.e., photon) radiation weighting factor of 1 needs to be
used to convert to total equivalent dose equivalent (TEDE). Convert from rads to rems using
the ICRP 103 recommended gamma radiation weighting factor.

When the short-lived daughter products are included and the photon radiation weighting
factor are utilized, the “DU Without Grout” and “DU With Grout” occupational doses will be
about 3.4 and 0.49 rem/yr, respectively.
• Y-5
The “DU Without Grout” occupational annual dose is expected to be greater than the
EnergySolutions Administrative Control Limit of 1.5 rem/yr (FCF-RS-PG-002, Section
2.1.5). What precautions are EnergySolutions proposing to ensure that the annual
occupational dose does not exceed the Administrative Control Limit?
• Y-6
FCF-RS-PG-001, Section 5.3.1 indicates that EnergySolutions will “Investigate all
semiannual personnel radiation exposures that exceed a TEDE of 100 mrem.” Since there is a
high likelihood that occupational doses will exceed this level for “DU With Grout”, what
actions to reduce exposures will likely result from such investigations?
• Y-7
The DOE’s Environmental Impact Statement (DU-Waste EIS) indicates that DU waste may
be shipped in Bulk Bags (also referred to as Super Sacks) (DOE/EIS-0359-S1; DOE/EIS-
0360-S1, Section S.7). If Bulk Bags are used, it is assumed that the worker would be exposed
to a radon flux of 190 pCi/m2-s, as provided in Appendix AB. Since the EPA’s radon flux
limit is 20 pCi/m2-s, what actions will EnergySolutions take to reduce FCF worker exposure
to radon if DU is disposed of in Bulk Bags?

References:

EnergySolutions, 2022, “Federal Cell Facility Worker Dose Calculation,” Technical Basis
Document, From Vern C. Rogers, Director of Regulatory Affairs, to File, June 22.

Grove Software, Inc., 2009. MicroShield® User’s Manual, Version 8.03.

Neptune and Company, 2021a, “Radioactive Waste Inventory for the Clive DU PA – Clive
DU PA Model v2.0,” NAC-0023_R5, August 2.

Neptune and Company, 2021b, “Model Parameters for the Clive DU PA – Clive DU PA
Model v2.0,” NAC-0026_R5, September 24.