DRC-2024-006804

September 16, 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
Larry Kellum at 385-622-1876 to schedule a meeting.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/LK/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.
Application: General
Application General.a
The submittal of draft procedures in conjunction with the Application is, in part, to outline how EnergySolutions intends to meet various regulatory requirements. While the intent of
the Division is not to dictate a specific method of reaching compliance, neither will it reactively address compliance issues that could have been avoided through procedural reviews.
Please submit a Compliance Matrix that identifies each procedure intended to meet a regulatory requirement and the rule reference (State or Federal). This list will be utilized by the
Division to assist with potential license conditions.
Section 2: Site Characteristics
2.7.2-2.a
The application has been updated to identify that the wells to the east of the site were used to water livestock and had no effect on the site. In this update, the application now states
that one of the wells to the east has been destroyed. Please provide justification that the remaining well to the east of the site does not influence the site. 
Appendix O:Erosion Modeling
O-2
Data from Siberia rerun necessary for confirmation of RFI closure.
O-3
Data from Siberia rerun necessary for confirmation of RFI closure.
O-4
Data from Siberia rerun necessary for confirmation of RFI closure.
O-5
Data from Siberia rerun necessary for confirmation of RFI closure.
O-6
Data from Siberia rerun necessary for confirmation of RFI closure.
O-7
Data from Siberia rerun necessary for confirmation of RFI closure.
O-8
Data from Siberia rerun necessary for confirmation of RFI closure.
O-25.a
The responsediscusses the increased uncertainty associated with using the concentration values listed in table 2 of Hightower et al. (2000) as bounding values. Please quantify the uncertainty
that would be introduced to this analysis by subjecting the maximum concentrations values listed in table 2 of Hightower et al. (2000) to ratio statistics.
O-31
Data from Siberia rerun necessary for confirmation of RFI closure.

O-32
Data from Siberia rerun necessary for confirmation of RFI closure.
O-33
Data from Siberia rerun necessary for confirmation of RFI closure.
O-36
Data from Siberia rerun necessary for confirmation of RFI closure.
O-39
Data from Siberia rerun necessary for confirmation of RFI closure.
Appendix T:Federal Cell Facility Personnel Monitoring Procedures
T-4.a
The response indicates “reference 2.5 has been added to FCF-EN-PR-011” and, “The citation in section 3.1.24 has been revised to point to Reference 2.5;” However, in section 2 References
reference 2.5 has not been included additionally, the citation in 3.1.24 has not been updated to reflect these changes, please amend.