DRC-2023-000527 - 0901a0688115f958

DRC-2023-000527 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. 711
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

January 25, 2023

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 (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
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//JK/wa

Enclosure: Federal Cell Application Review, Requests for Information or
Updates to the Application (RFI) (DRC-2023-000644)

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
Page 1

DRC-2023-000644
Federal Cell Application Review

Request for Information or Updates to the Application (RFI)

General
• Each RFI 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 O:

SRS DU Radioactive Waste Inventory

▪ O-19
Please clarify which units are to be used in the heading of NAC-0023_R5, Table 2;
“(pCi/g of DU waste)” or “(pCi/g of DUO3 waste)” as used by Beals, et al and GEL.

▪ O-20
Please modify GoldSim v2.0 to use the appropriate units for the SRS DUO3 concentration
means and standard deviations.
▪ O-21
Please justify why the data standard deviation is used for Tc-99 but the standard deviation
of the mean is used for all other radionuclides.
▪ O-22
Please clarify the use of ‘mean’ and ‘standard deviation’ when analyzing several
radionuclides in Table 2 from Neptune 2021 versus use of the term, ‘standard error’ as
applied in Table 5 and Table 6 from the same document.

Page 2

DRC-2023-000644

▪ O-23
Please provide justification for continuing to utilize Beals, et al 2000 Ra-226 data when
newer, more refined data is available. Continued use of the 1,000 pCi/g detection limit
from Beals et al will result in erroneously high calculated dose rates versus using a more
appropriate detection limit of about 0.6 pCi/g from Nielson & Sandquist (2011).
▪ Nielson & Sandquist (2011) report that a 2010 EnergySolutions sampling
program that collected 22 samples and found 11 sample with Ra-226
activities above a much lower detection limit (GEL 2010d).
▪ O-24
Please clarify the continued use of Sr-90, I-129, and Cs-137 in the DU PA, as their
contribution to dose is very small over the performance period.

▪ O-25
If Am-241 is to be included in the DU PA, then consider applying the following ratio to
determine the amount present:
▪ Using the Am-241 to Tc-99 ratio given in Hightower, et al (2000), as
(i.e., 4.55 pCi/g Am-241 to 270.3 pCi/g Tc-99).

GDP Clean DU Radioactive Waste Inventory

▪ O-26
Please correct errors found in Section 2.1 of NAC-0023 R5.
1. In section 2.1 of NAC-0023 R5 regarding depleted uranium, the second paragraph
above Table 3 and Table 3 itself are incorrect in their description of the isotopes
that occur in uncontaminated (clean) depleted uranium.
2. U-232, U-233, and U-236 are formed via the following reactions:
235U (n,γ) → 236U (n,γ) → 237U(β−) → 237Np (n,2n) → 236Np(β−) → 236Pu (α) → 232U
232Th (n,γ) → 233Th (β−) → 233Pa (β−) → 233U
235U (n,γ) → 236U

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DRC-2023-000644
After making the corrections requested for O-26 above in section 2.1, the following items
need to be changed FCF License Application:

▪ O-27
Section 6.1.1.1 and Table 6-1.

▪ O-28
The GoldSim v2.0 model needs to be corrected and re-run.

▪ O-29
Consider using the following table to utilize for the GDP Clean DU Uranium
Distributions:
Table 1: Recommended GDP Clean DU Uranium Distributions
Uranium
Isotope
Weight Percentage
Low-Low DOE-Middle High-High
U-235 0.16 0.25 0.33
U-234 0.00024 0.0005 0.00129 NAC-0023_R5,
Mean
U-238 99.8398 99.7495 99.6687 Table 2 Corrected
Concentration (pCi/g)
U-235 3.46E+03 5.41E+03 7.14E+03 2.97E+03 3.57E+03
U-234 1.50E+04 3.14E+04 8.10E+04 3.31E+04 3.98E+04
U-238 3.373E+05 3.370E+05 3.367E+05 2.72E+05 3.27E+05
i. For ease of comparison, Table 1 also provides the mean uranium
concentrations from NAC-0023_R5 both as they appear in Table 2 and
corrected from “(pCi/g of DUO3 waste)” to “(pCi/g of DU waste)”, as
discussed above.
ii. The Table 1 concentrations could be used to form a distribution, e.g.,
uniform, triangular. However, if this is done, then specifying the U-235
Weight Percent determines not only the U-235 concentration but also the
concentrations of U-234 and U-238.

GDP Recycle DU Radioactive Waste Inventory

▪ O-30
Please clarify the continued inclusion of U-236 in the DU PA.