DRC-2024-006532

DRC-2024-006532 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • 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

August 13, 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/wa

Enclosure: Federal Cell Application, Request for Information or Updates to the Application (RFI)

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 O: Federal Cell Facility Waste Characterization Plan

O-29.a

The response to RFI O-29 did not address the main concern of whether the uranium isotopic
composition in the Savannah River Site (SRS) Depleted Uranium (DU) accurately reflects the uranium
isotopic composition in pure Gaseous Diffusion Plant (GDP) DU.

The SRS receives pure GDP DU and creates targets out of it by exposing the GDP DU to a neutron flux
from within a reactor to create plutonium. The neutrons turn some of the U-238 into plutonium through
activation and beta decay. The initial U-238/U-235/U-234 composition of the targets is the same as the
GDP DU composition. It can also be observed that, based on the presence of fission products in the
SRS DU, the neutrons also cause some fission in the target DU. What is not known, however, is what
fraction of fission was due to U-238 and plutonium, versus U-235. Because the GDP DU has less
U-235, there is reason to believe that there is not a large fraction of U-235 fissioning. Moreover, there
may be other neutron induced uranium transformations happening while the targets are in the reactor.
Therefore, it may be concluded that the U-238/U-235/U-234 composition of the targets coming out of
the SRS reactors is different from the GDP DU composition. However, we do not know by how much
the two compositions differ.

Please demonstrate (within some calculated uncertainty) that the change in the U-238/U-235/U-234
composition is insignificant.

Section 1.2: General Facility Description

1.2.2-6.a

The RFI response stated the reference had been added to the text of the application; however, there is no
document Sobocinski (2020) reference included in the Section 1 Reference Folder of the Application.
If this was intended to reference the 2020 Groundwater Quality Report by Sobocinski, which has been
included in the Section 1.0 Reference Folder of the Application and discusses TDS at the site, the text in
the application should be changed to correctly reference this document.

Page 2 of 2

Section 2.7.2: Natural Resources

2.7.2-2.a

The RFI response stated the application had 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 have an effect on the site.