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Home My WebLink AboutDRC-2024-005704 DRC-2024-005704 Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 • 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 May 31, 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/wa Enclosure: Federal Cell Application Review – Request for Information or Updates to the Application 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 of 2 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 AB: Operational Period Modeling AB-7.a In the previous version of Appendix AB, it does not appear that the radionuclide inventory was time averaged, but in this most recent version provided, EnergySolutions changed the approach to time averaging. Please provide clarification as to why the approach has changed. AB-7.b The revised Appendix AB states that the inventory used in the December 2023 RESRAD model was derived from the DU PA v2.0 GoldSim model. However, the most recent version of the GoldSim model v3.0 appears to have had changes to the assumed radionuclide inventory. Any changes made to the assumed radionuclide inventory in the DU PA v3.0 model should also be reflected in the RESRAD model. Please update the RESRAD model accordingly. AB-7.c The Division was unable to reproduce the concentrations used in the revised RESRAD model. Please provide additional information as to how these concentrations were calculated. AB-10.a The Division reviewed Ground Water Quality Discharge Permit No. UGW450005 as well as Engineering Drawing 0801-G03 but was unable to locate the dimensions of the 2000 stormwater retention pond to confirm the dimensions used in the RESRAD model. The dimensions of this surface water body in RESRAD were 100 meters by 105 meters; however, it appears to be more rectangular in shape upon review of the 2000 stormwater retention pond in Engineering Drawing 0801-G03. Please provide the engineering drawing, with dimensions, that was used to determine the dimensions of the pond used in RESRAD. Page 2 of 2 AB-23.a In consideration of RFI AB-7.a and AB-7.b, please reevaluate the most current RESRAD model and determine if a new run of the RESRAD model is required. Appendix O: Federal Cell Facility Waste Characterization Plan O-40.f NAC-0025 R4, Page 16, indicates litter information was identified for the determination of sorption values for Protactinium. The Division concurs with sorption values/data for protactinium being understandably sparse but would like EnergySolutions to review reference “Sakamoto, Y., et al., Sorption characteristics of Actinium and Protactinium onto soils; Journal of Nuclear Science and Technology, 2002, 39(sup 3): P. 481-484.” and provide additional discussion on this matter. O-40.g The following statement is found in section 4.1.2 (Americium), on page 13 of NAC-0025 R4: “This rare earth element will have a large sorption coefficient.” Americium is an actinide element, not a rare earth element. Please refer to americium as an actinide element in section 4.1.2 and along with any other placement of the reference. O-40.h 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 phase are insufficiently high to cause saturation. Please provide relevant barium and sulfate concentrations at the site to indicate which phase can be formed. O-40.i In section 5.1.11 of NAC-0025 R4, the solubility of strontium is reported to be controlled by comparable phases to calcium minerals including celesite (Sr, SO4(s) ) and strontianite (SrCO3(s) ). Please indicate whether sulfate and carbonate concentrations are sufficiently high to approach saturation of these minerals. O-40.j In section 5.1.7 of NAC-0025 R4, the reported dominant aqueous Plutonium species is tetravalent hydroxycarbonate complex Pu(OH)2(CO3)2-3, but section 4.1.7 of NAC-0025 R4 indicates that Pu(V) and Pu(VI) are the most likely states. Assumed aqueous species for sorption partitioning and solubility control should be consistent. Please clarify the discrepancy between the Plutonium species reported in section 5.1.7 and section 4.1.7 of NAC-0025 R4.