DRC-2024-005438

April 25, 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 a meeting.
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.
Appendix O: Federal Cell Facility Waste Characterization Plan
O-40.a
NAC-0025 R4 indicates the chemical conditions (high ionic strength) in the saturated zone at Clive are not considered favorable for colloid transport. The Division agrees with the assessment
that discussions and assertations regarding colloid facilitated radionuclide migration are complex. However, the potential influence of colloids and the ionic strength of Clive groundwater
needs to be documented. While higher ionic strengths can facilitate aggregation and reduce colloid transport, there are conditions where colloids can move depending on the colloid composition,
pH, and presence of counter ions which can reduce aggregations. A summary of previous colloid transport work is included, but the studies are not explicitly compared to the conditions
at the Clive site. Thus, more detail is necessary to support the assumptions presented.
Please submit an evaluation of the role of colloid transport in terms related to the specific conditions at the Clive site.
O-40.b
The following statement is found on page 9 of NAC-0025 R4: “Using the data from the average of all wells shown in Table 7, the stoichiometric ionic strength is calculated at 0.73 M (mol/L)”.
It appears there are some errors in calculating the average values. The ionic strength of 0.73 M matches that for GW-19A with the highest Na+ and Cl- concentrations but is not the stoichiometric
ionic strength calculated for all wells shown in Table 7.
Please verify the stoichiometric ionic strength calculated for all wells shown in Table 7.
O-40.c
In section 5.1.9 of NAC-0025 R4 the solubility of radium is reported to be controlled by RaSO4(s), using surrogate values for barite (BaSO4(s)) and as a co-precipitate (Ra,Ba(SO4)(s)).
The assumption that radium can form a solubility limiting phase may not be justified or necessary if the concentrations of counter ions in the phase are insufficiently high to cause
saturation.
Please provide relevant barium and sulfate concentrations at the site to indicate which phases can be formed.