DRC-2024-004818

March 8, 2024
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 follow up Requests for Information (RFI) regarding the Federal Cell Facility Application dated August
4, 2022.
Each RFI in the attached document represents a follow up to an RFI issued earlier in the application review process. The numbering system ties the additional questions to the initial
RFI with an added letter designation. When responding to an RFI, please use the assigned number representing the question.
With this round of follow up RFIs, the Division recommends that appropriate staff from the Licensee, the Division and consultants meet to discuss each matter for clarity. Please contact
Otis Willoughby at 385-622-2213 to schedule ameeting.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/OHW/JMK
Enclosure:Federal Cell Application, Requests for Information.
c:Jeff Coombs, EHS, Health Officer, Tooele County Health Department
Bryan Slade, Environmental Health Director, Tooele County Health Department EnergySolutions General Correspondence EmailLLRW 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-
Application/Appendix Section
Section/Appendix Subsection
Section/Appendix Subsubsection (when applicable)
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.
Section 1:
Section NAME
1.2.2-1.aThe link is giving us an error. Link is not to Hazardous Industrial District MG-H is now generating a “General Industrial District M-G type uses Link Error.”
1.2.2-4.a
Elevation lines added, no numerical readouts. Include elevations on Figure 1-2.
1.2.3(5)-2.a
Mentioned license amendment but did not specify number 3. Revise for approved Amendment 3 reference.
Section 2:
Section NAME
2.1.2-1.a
“Census 2020” link requires privacy acceptance.
2.3.1-1.a
Link Removed but Hintze, 1980 still referenced. It now generates a “Hintze, 1980” link error.
2.3.1.5-1.a
Is this meant for 2.3.1.2 Geology section? there is no 2.3.1.5. Revise reference for "3000 feet of basin fill sediment..."
2.4.2-1.a
Revised to shallow unconfined aquifer. Revise "unconfined aquifer" to shallow aquifer for consistency.
2.4.2-3.a
Map renamed to "shallow unconfined aquifer." Based off of RFI question 2.4.2-1 is there significance for this being labelled unconfined compared to not using that terminology? Revise
map name to specify it is for the shallow aquifer.
2.4.2-4.a
Map renamed to "shallow unconfined aquifer." Based off of RFI question 2.4.2-1 is there significance for this being labelled unconfined compared to not using that terminology? Revise
map name to specify it is for the shallow aquifer.
2.4.2-5.a
Map renamed to "shallow unconfined aquifer." Based off of RFI question 2.4.2-1 is there significance for this being labelled unconfined compared to not using that terminology? Revise
map name to specify it is for the shallow aquifer.
2.4.2-6.a
Map renamed to "shallow unconfined aquifer." Based off of RFI question 2.4.2-1 is there significance for this being labelled unconfined compared to not using that terminology? Revise
map name to specify it is for the shallow aquifer.
2.4.2-8.a

Did not revise aquifer classification but changed "Lone Mountain" to "Cedar Mountains." Revise "confined aquifer" to shallow aquifer for consistency.
2.4.2-10.a
EnergySolutions explained there is not a specific appendix to cite, instead they include the full reference title with the specific sections referenced. Add appendix citation for "Numerical
Analyses" section.
2.10-1.a
Electronic references still missing for Moore and Sorensen 1979, NUREG-1476, and NRC 1980. Discrepancies for citations referenced in this section and the associated electronic link to
a file.
Section 3:
Section NAME
3.1-2.aLink removed. Link with the bracketed 1 “[1]”, this typo breaks the hyperlink.
3.1.1-1.a
Memo not added in Appendix Y for figure 2. Found in Appendix Z. Appendix Y, HAL PMF Tech Memo, Figure 2- Does not appear in noted Appendix.
3.2.9-1.a
Link removed but Part B reference remained. Dated February 23, 2022, additionally there was an added contingency plan quick reference guide. A2-6-1 that accompanies the current contingency
plan. Would this need to be added to this application as a reference? Referenced “Part B Attachment II-6 Contingency Plan” is an outdated plan. Current Dated 2/23/22.
3.4.1-1.a
Link removed but Part B reference remained, additionally there was an added contingency plan quick reference guide. A2-6-1 that accompanies the current contingency plan. Would this need
to be added to this application? Referenced “Part B Attachment II-6 Contingency Plan” is an outdated plan. Current Dated 2/23/22.
3.4.3-1.a
Link removed but Part B reference remained, additionally there was an added contingency plan quick reference guide. A2-6-1 that accompanies the current contingency plan. Would this need
to be added to this application? Referenced “Part B Attachment II-6 Contingency Plan” is an outdated plan. Current Dated 2/23/22.
3.5.1.1.a
Link removed but Part B reference remained, additionally there was an added contingency plan quick reference guide. A2-6-1 that accompanies the current contingency plan. Would this
need to be added to this application? Referenced “Part B Attachment II-6 Contingency Plan” is an outdated plan. Current Dated 2/23/22.
Section 4:
Section NAME
4.4.7-2a
Link removed but Part B reference remained, additionally there was an added contingency plan quick reference guide. A2-6-1 that accompanies the current contingency plan. Would this need
to be added to this application? “Attachment II-6 of the state-issued Part B Permit” does not link to the specific attachment.
4.5.1-1.a
Link removed but Part B reference remained, additionally there was an added contingency plan quick reference guide. A2-6-1 that accompanies the current contingency plan. Would this need
to be added to this application? Referenced “Part B Attachment II-6 Contingency Plan” is an outdated plan. Current Dated 2/23/22.
4.5.1-X.a
Broken hyperlink leads to error when clicking on link. RFI follow up. Found 2/15/24, Page 426 "NRC 1980" link is hyperlink is broken.
Section 5:
Section NAME
5.1.2.2-1.a
RFI Follow Up. No hotlink provided. Found In Appendix M, referencing NUREG/CR 4620. Section language should be updated to include complete reference for 4620 and not state "NRC (1986)".
Additionally, Section 5 references doesn't contain NUREG 4620. NRC (1986) is cited, but no hot-link or printed reference is provided.
5.2.7-1.a
Hyperlink is removed. Hyperlink “GWQDP” does not work or is broken.
5.3.8-1.a
No link, reference not defined in section nor searchable in Appendix C. DOE (2019) is cited, but no hot-link or printed reference is provided.
5.3.9-1.a
No link, reference not defined in section nor searchable in Appendix C. DOE (2019) is cited, but no hot-link or printed reference is provided.
8.4-1.a
Will need to keep an eye on as the contingency plan updates yearly. Current plan is dated 5-23-23. ES additionally added a quick reference guide. Do we need to see if this is applicable
to add to the federal cell project? Referenced “Part B Attachment II-6 Contingency Plan” is an outdated plan. Current Dated 2/23/22.
Section 8:
Section NAME
8.8.1-1.a
Will need to keep an eye on as the contingency plan updates yearly. Current plan is dated 5-23-23. ES additionally added a quick reference guide. Do we need to see if this is applicable
to add to the federal cell project? Referenced “Part B Attachment II-6 Contingency Plan” is an outdated plan. Current Dated 2/23/22.
Section D:
Section NAME
D-1RFI response stated a subfolder would be added appendix D titled "references cited", no folder exists, nor does a tab in FCF revision 3 application exist with the title "references
Cited in Geosyntec 2021." The following are discrepancies for citations in this section and the accompanying references and/or the associated electronic reference files.
Section K:
Section NAME
K-1EnergySolutions deleted the ANSI 1973 reference and corrected the Kusnetz reference. On Page 32 of 45, in 4.4.1.1, the following two citations are made: These are missing in the REFERENCES

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