DRC-2024-005545

May6, 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 B: Federal Cell Facility Engineering Drawings
B-4.a
The B-4 RFI response provided details of the Federal Cell Facility air sampling program but did not address the additional requested information. The RFI requested details on all sampling
instrumentation to adequately determine the effectiveness of the Environmental Monitoring Program.
Please provide the information requested in the original RFI and outline where in the Application this information is located.
B-4.b
TheB-4 RFI response notes the "Groundwater Quality Discharge Permit UGW450005 has been requested to reflect depiction of the Federal Cell Facility on the applicable Engineering Drawings.
The modification requests that existing wells GW-57, GW-28, GW-58, and GW-63 be designated as upgradient to the Federal Cell Facility and existing wells GW-26, GW-94, GW-95, GW-27, and
GW-27-D considered for downgradient compliance monitoring of the Federal Cell Facility (in accordance with UAC R315-3082(2))."
Although the issue requires further evaluation of the Permit modification request mentioned in the response, a base monitoring well network plan should be included in the application.
The Monitoring Network Plan must distinctly identify the intent of the monitoring wells, their locations, and an evaluation of the adequacy of the network. The application is unclear
as to the intent for repurposing the wells as described in the RFI response.
Please resubmit the plan with technical justifications for the monitoring well network to facilitate a complete review.
B-4.c
Current Gamma Monitoring Stations F-27 and F-28 appear to be within the footprint of the proposed Federal Cell Facility.
Please clarify plans for these Gamma Monitoring Stations and if there is an intent to replace or supplement the stations affected by construction of the Federal Cell Facility.
B-11.a
The description of the “OUTFALL DISPERSION DITCH” in the southwest corner of the Federal Cell Facility is not adequately described. The application does not elaborate on the intent and
dimension of the “OUTFALL DISPERSION DITCH”. All drainage channels that line the embankment toes of the Federal Cell Facility, 11e.(2) Cell, and connecting drainages from the Northeast
connect to the “OUTFALL DISPERSION DITCH.”
In accordance with NUREG 1199, 5.1.1 and NUREG 1200, SRP 5.1.1; EnergySolutions must provide language within the application to describe the function and structure of the “OUTFALL DISPERSION
DITCH.” This cannot be accounted for in a "separate licensing action." Without elaboration on details of this structure to support NUREG 1199, 5.1.1 and NUREG 1200, SRP 5.1.1 the considerations
for the Surface Drainage and Erosion Protection remains an unanalyzed condition for the surface drainage of the Federal Cell Facility. This affects discussions within this section for
"The possible effects of upstream dam failures or downstream drainage blockages as accident conditions”.
Please provide a detailed description of this drainage system.
B-11.b
The B-11 RFI response states "Since no bulk DU will be managed at the Federal Cell Facility, current instrumentation and monitoring locations are appropriate to support the Federal Cell
Facility."
The waste will be "managed" in some form (i.e. transloading, placed, and backfilled) and therefore the Division requires additional information on EnergySolutions definition of "managed"
and why the Class A West Cell takes precedence in establishing the center for the wind rose.

Additionally, it is understood that "bulk waste" disposed of in the Class A West cell is not similar to Depleted Uranium waste that will be managed at the Federal Cell. However, it
is unclear why additional radiological monitoring is not required in a manner similar to other waste embankments.
Please provide technical justifications for the assumptions presented on this issue.
B-56.a
Font remains small and illegible. Engineering drawings need to be provided at a consistent format scale, so text is clear and legible.
Please resubmit these drawings in a legible format.
B-56.b
In response to the B-56RFI, EnergySolutions had an engineer sign and place a seal on every drawing but did not provide full sized drawings for verification. Some of the drawings in this
appendix could not be adequately reviewed because the scale could not be confirmed by the Division.
Please provide the drawings with appropriate scale so they can be verified.
B56.c
The B-56 RFI response states "fill characteristics are described in the Federal Cell Facility Construction Quality Assurance/ Quality Control Manual Appendix C to the Application". Language
elaborating on the requested information was not located in Appendix C.
Please provide a base characterization of the “Clean Fill” to determine its appropriateness in the design of the Federal Cell Facility. The response to this RFI should concur with the
response to RFI 56d.
B-56.d
It remains unclear to the Division what earthen fill material will be utilized for the embankment after Depleted Uranium placement and entombment. In Appendix C, Specification 73 of
the LLRW & 11e.(2) CQA Manual suggests that “Soil classification testing is not required for fill placed using this work element”.
Please determine and adequately justify the base assumptions and design of the earthen fill material that is labeled as “Clean Fill” in this application.
Appendix O: Federal Cell Facility Waste Characterization Plan
O-40.d
Please provide an evaluation of the minerology of hydrostratigraphic units 1 through 3. Please use the same methodology used for unit 4 in Table 6. Additionally, please clarify that
the bedrock was not included in the simulations and the rationale for excluding it.
O-40.e
Please provide a comparison of the partitioning coefficients from the references used in NAC-0025 R4 to the site-specific conditions found in hydrostratigraphic units 1 through 4.