rml condition 35 compliance report

8/6/2019 RML Condition 35 Compliance Report

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; :? aENERGYSOLUTIONS

UTAH LOW-LEVEL RADIOACTIVE WASTEDISPOSAL LICENSE - CONDITION 35 (RML UT2300249)

COMPLIANCE REPORT

June 1, 2011

FoeUtah Division of Radiation Control195 North 1950 WestSalt Lake City, UT 84114-4850

EnergySo/lIti()Il.i, LLC423 West 300 South, Suite 200Salt Lake City, UT 84101


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ENERGVSOLUTIONSEXECUTIVE SUMMARV

In early 2009, (he U.S. N uclear Regulatory Commission voted to initiate rulcmaking to require a sitc-spec ific ana lysis for disposal of large quantities of depicted uranium. Since that lime, EncrgySo{utionshas received (and intends to di spose) 3,577 metric tons of depicted uranium waS le that has been declaredsurplus from the Savannah Ri ver Site. However, Utah Radiation Control Rule (UReR) Sec lion R313-25-8(5) proh ibits disposal of significant quantities of concentrated depicted uranium (more than one metricton in total accumulation) after June I , 2010, until the Utah Division of Radiation Control ExecutiveSecretary's approves a performance assessment that demonstrates Ihat EnergySolufions wi ll meet theperformance s tandards specified in 10 CFR Part 61 and corresponding provisions of Utah rules.As requ ired by URCR3 13-25-8(5) and in accordance with URCR313-25-8(2), EnergySolufions hascompeted and hereby submits to the Division's Executive Secretary for approval an in-depth site-specificperformance assessment before disposal of depleted uranium. Once approved, it is EnergySolufions'objec ti ve to file documentation requesting its Radioactive Materia l License be amended to includedisposal of depleted uranium.Because of the processes, depleted uranium from the Savannah River Site also contains small quantitiesof waste fission products and transuranic elements. The estimated mass of depleted uranium from theSavannah River Site proposed for disposal at EnergySollllions' Clive Facility is 3,577 metric tons, (5,408drums). Furthermore, this report also evaluates acceptance and di sposal of up to 700,000 metric tons ofsimilar depleted uranium waste from the gaseous diffus ion plants at Po rtsmouth, Ohio and Paducah,Kentucky.License Condition 35.B of EnergySolufions' Radioactive Ma terial License (UT 2300249) sCates,

"Peliormance assessment: A petformance assessmenl, in general conformance wi th Ihe approachused by fhe Nuclear Regula/OIY Commission (NRC) in SECY-08-0147, shall be submi/fedforExeculive Secretary review and approval no laler than June I, 2011. The peliormanceassessment shall be revised as needed /0 reflect ongoing gUidance an d rulemaldngfrom NRCFor purposes o f his petformance assessment, /he compliance period will be a minimum of10,000 years. AddiNona! simulations will be petformedfor a minimum I,OOO,OOO-year lime framefo r quali/afive analysis."

EnergySollllions supports their claims of compliance with the license condition through the developmentand execution of a dctailed, site-specific, probabilistic perf0n11anCe assessment us ing the GoldSim model.This model and the rcsulting findings demonstrate to the Division that EnergySolll/ions' proposcdmethods for disposal of depleted uranium will ensure that future opera tions, institutional control, and siteclosure can be conducted safcly, and that the site wi ll comply with the Di vis ion 's radiologica l criteriacontained in the Radioac tive Material License.

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While also included in Ihis Compliance Report as part of improving qual itative understanding of facilityperformance, EnergySolutions recognizes that events that are projected to broadly disrupt the disposal siteregion should generally be expected to drive human populations away from the affected areas.Accordingly, "an appropriate assumption under these conditions would be thai no individual is livingclose enough to the facil ity to receive a meaningful dose" (NRC, 2000).

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Section1.0

ENERGVSOLUTIONS

TABLE OF CONTENTS

INTRODUCT ION1. 1 Licens ing Overview1.21.31.4

Regulatory SummaryHistorical Management of Depleted UraniumBasis for Pcrfonmmcc Assessment

PageI - I1-11-31-41-6

2.0 REGULATORY COMPIANCE AND PERFORMANCE OBJECTIVE SATISFACTlON2 -12. 1 R313-15-101 Radiation Protection Program 2-42.2 R313-15-20 I Occupational Dose Limi ts for Adults 2-42.3 R3J3-1S-301 Dose Limits for Individua l Members of lhe Public 2-52.4 R313-15402 Radiological Criteria for Unrestricted Usc 2-52.5 R3\3- \S-60 I Control of Access to Hi gh Radiation Areas 2-52.6 R313-\5-80 I Security and Control of Licensed or Registered Sources of Radiation 2-62.7 R3J3-\S-902 Posting Requirements 2-62.8 R3J3-1S-906 Procedures for Receiving and Opening Packages 2-62.9 R313-15-1002 Method for Obtaining Approval of Proposed Disposal Procedures 2-72. 10 R313-15-1009 Waste Classification 2-72. 11 R313-18-12 Lnstruction to Workers 2-92. 12 R3 I 3-25-6(3) General Lnfonnation - Expected Sehedulcs 2-92. 13 R3 I 3-25-7 Specific Technical Information - Principal Des ign Features: Dcscrip tions,

Design Criteria, Justification, and Codes 2-102. 14 R3 I 3-25-8 Technical Analysis 2-162. 15 R313-25-10 Financial Qualifications to Carry Out Activitics 2-232. 16 R313-25-11 Requirements for Issuance of a License 2-242. 17 R3l3-25-18 Individual Exposurc Assurancc 2-272. 18 R313-25-19 Protection of the General Population from Releases ofRadioaetivity 2-272. 19 R3 I 3-25-20 Protection of lndi viduals From Inadvertent Intrusion 2-342.20 R3l3-25-2l Protection of Indi viduals During Operation 2-372.21 R3 I 3-25 -22 Stability of the Di sposal Site After Closurc 2-372.22 R3 I 3-25-24 Disposal Site Design for Ncar-Surface Land Disposa l 2-382.23 R313-25-31 Funding for Di sposal Site Closure and Stabi lization 2-382.24 R3 I 3-25-32 Financial Assurance for Institutional Control 2-392.25 R3l7-6 Groundwater Protection Limits 2-40


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Section3.0

4.0

CONCLUSIONS

REFERENCES

ENERGVSOLUTIONSTABLE OF CONTENTS (continued)

Page3-14-1

APPENDIX A - Final Report for the Clive DU PA Model version 1.0 [digital DVDl A-I

n


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Table2-12-22-32-42-5

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LIST OF TABLES

App licable Req ui rements Potentially Impacted by the Disposal of Dep icted UraniumSava nnah River Si te Depicted Uranium Drum Waste Conccntfal ionsPea k Total Effective Dose Equi valents to the Genera l Publ icPeak Groundwate rConcentrationsPea k Total Effective Dose Equivalents to the Inadvc rtcnI Imrudcr

m

Page

2-22-8

2-302-312-36


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FigureI-I2-1

ENERGVSOLUTIONSLI ST OF FIGURES

EncrgySollllions' Proposed Depicted Uranium Disposal LocationTypical De picted Uranium Storage Cylinder

PageI- I1-5


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Term

I Ic.(2)2008 LRA renewalABC ALAAcActALARAAmAMECASCEASTMBLMBqBWFCCECEDEeFReiem/seccmlY'CQAlQCCSFCSLMeSMCTCeWFDCFDDEDivisionDOEDOTDR CDUED ISEIS

ENERGVSOLUTIONS

AC RONYMS AND ABBEVlATlONS

Definition

Sec tion llc.(2) of the Atomic Energy Act of 1954, as amendedLicense Renewal Application dated 20 June 2005Application for License Amendment (Classes A, 8 & C waste), dated December13 ,2000actiniumUtah Radiation Control ActAs Low As Reasonably AchievableamericiumAMEC Earth and Environmental, fonnerly AGRA Eanh andAmerican Society of Civil Eng ineersASTM International, formerly American Socicty for Testing andBureau of Land ManagementbccqucrclBulk Waste Facilitycertified cost engineercommitted effective dose equivalentU.S. Code of Federal Regulationscuriecentimeters per secondcentimeters per yearConstruction Quality Assurance/Quality Controlcancer slope factorControlled Low Strength Materialconceptual si te modelCover Test CellContainerized Waste Fac ili tydose conversion factordeep dose equivalentUtah Division of Radiation ControlU.S. Department of EnergyU.S. Department of TransportationUtah Di vision of Radiation Controldepleted uraniumelectronic document imaging systemenvironmental impact statement

v


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Term

EPAETTPEW ISFE ISFE PFRftFtfUftft -Ibf/ll'gGOPGTCCGW PLGWQDPhahrIAEAICRPoninlyrkaK,kgkmkyLLA RWLLRWLRAmMaMCLMgmg

ENERGVSOLUTIONS

ACRO NYMS AND ABBE VI ATIONS (cont;nued)

Definition

U.S. Environmental Protection AgencyEast Tennessee Technology ParkElectronic Waste Information SystemFinal Environmental impac i Statementfeatures, events , and processesFederal Registerfoot/feetfeet; footfeet per footfoot-pound force per cubic foot (unit of energy density)gramgaseous diffusion pl antgreater than Class C wastegroundwater protection limit(s)groundwater quality d ischarge perm ithectarehour; hoursInternational Atomic Energy AgencyInte rnational Commission on Radiation Pro tectioninch; inchesinches per yearthousand years agosoiUwatcr partition coefficientki logramki lometerthousand yearsli tcrlow-act ivity radioactive wastelow-Ievcl radioactive wasteLi cense Renewal Applicationmetermi ll ion years agomaximum contaminant levcl(s)megagram (one metric ton)mi ll igram

vo


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Term

TEDETFThTSDUUACUDOGMUDSHWUDWQUMTRAUNFURCAURCSURCRUSACEUSGSUWQSY

ENERGVSOLUTIONSACRONYMS AND ABBEVlAT10NS (continued)

Definition

total effective dose equivalentTreatment Facilitytho riumTreatment , Storage and DisposaluraniumUtah Administrative CodeUtah Division ofOil, Gas and MiningUtah Division of Solid and Hazardous Was teUtah Division ofWater QualityUranium Mill Tailing Remedia l Actionused nuclear fuelUtah Radiation Control ActUtah Radiation Control BoardUlah Radiation Control Ru lesUS Army Corps of EngineersUnited States Geologic SurveyUtah Water Quality Boardyear

VIII


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I. INTRODUCTION

ENERGVSOLUTIONSEncrgySolulions, headquartered in Salt Lake City, is a worldwide leader in (he safe rccycling, processingand disposal of nuclear material, providing innovations and tech nologies 10 the U.S. Dcpanmcnt ofEnergy (DOE), commercial utilities, and medical and research faci li ties. Al lhc Clive Facility, located 85miles west of Salt Lake City, EncrgySo!ulions operates a commercial treatment, storage and disposalfac ility for Class A low-level radioactive waste and Class A low-level mixed was te.In early 2009, [he U.S. Nuclear Regulatory Commission (NRC) voted 10 ini tiate ru lcmaking to require as ite-spec ific analysis for the disposal of large quantities of depicted uranium (DU). Since that time ,EnergySolulions has received 3,577 metric tons (5,408 drums) of uran ium Irioxide (DUO l ) waste that hasbeen declared surp lus from the Savannah River Site (SRS). In Ihe future, EnergySolutions is alsoconsidering depleted uranium from the gaseous diffusion plants at Portsmouth, Ohio and Pa.ducah,Kentucky. As is illustrated in Figure I- I , EnergySollltions has evalualed a potential Federal Ce ll asultimate deslinalion for depleted uranium. In accordance with Utah Radiation Comrol Rule (URCR)Section R3 13-25-8(2), EnergySollltions is required to complete and submit to Ihe Division's ExecutiveSecretary fo r approval an in-depth site-specific performance assessment for the disposal of depicteduranium. Once approved, it is EncrgySoluliuns ' objective to fi le documentatio n reques ting itsRadioactive Malerial License be amended to include disposal of depleted uranium.1.1 Licensing OverviewDOE remedial activities began for the Salt Lake City Vitro mill s ite in February 1985 and activities werecompleled in May 1989. Contaminated materials that remained at the sile were excavaled and relocatedby the Slate of Utah to a newly acquired site, located 85 miles west of Sail Lake City at a location knownas Clive , Utah. Adjacent to this operation, EnergySolulions (then kn own as Envirocare of Ulah) begandisposa l operations at its Clive facility in 1988 under a State license (RML UT 2300249) to dispose ofNatura lly-Occurring Radioactive Materials (NORM). In 1990, EncrgySolulions submitted a licenseapplica tion to modify its license to allow disposal of low-activity radioactive waste (LAR W). In 1991 ,the Division gramed this amendment request by issuing a license fo r LARW disposal. From timc to time,the LARW disposa ll ieense has been amended to address EncrgySolurions ' changi ng needs and those ofthe public in tcrcst. Eventually, the license pennit ted disposal ofClass A low-leve l radioaeli ve waste(LLRW). In 2008, the Division renewed EnergySollilions ' license (2008 RML renewal).

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Figure I-I, EnergySo/lttiolls' Proposed Depleted Uranium Disposal Location

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ENERGVSOLUTIONS

EncrgySolulions conducts other treatment and disposal operations in arcas adjaccnI to its Class Aembankments. These activities include mixed hazardous waste under a Trea tment, Storage and Disposal(TSD) State-issued Part B RCRA Solid Waste Permit (re-issued by the Executive Secretary of the UtahSolid and Hazardous Waste Control Board on April 4, 2003). The nature ofmixed waSle managed at thefac ility includes contam inated soils, process waste, debris and sludges. The mixed waSle portion of theClive faci lity consists of a disposal cell, a treatment bu ilding, a storage bu ild ing and an operationsbui lding. The treatmen t building is used for stabilization and solidification of certain waste streams andthe operations bui lding is used for alternative treatment technologies, such as macro-encapsula tion andmicroencapsulation, as well as stabilization and storage of mixed waste.EnergySolulions also disposes of uranium and thorium by-product material {I I c.(2)} under a licenseissued by NRC as Byproduct Material License SMC- 1559. Ene rgySolllfions' l le .(2) license is nowadministcrcd by the Division (RML UT2300478).In conj unction with licensed activitics, EncrgySollifions ' opera tions arc also subject to the provisions ofGround Water Quality Discharge Pcnnit (GWQDP) UGW450005, issued by the Utah Division ofWatcrQuality (UDWQ). In 2008, EnergySollilions was awarded a renewal fo r this permi t. Th is pennit specificsthat groundwater quality protection levels for radioactive constituents must be met for no fewcr than 500years fo llow ing facility closure. Similarly, EnergySollifions also operates under Air Quality ApprovalOrders, iss ued by the Utah Di vision ofAir Quality (UDAW).1.2 Regulatory SummaryThe Di vision regu lates activities in the State of Utah that involve radioactive materials, some types ofradioac tive waste, and radiation. To assess whether Ene rgySolurions' Clive fac ility location andcontainment technologies are suitable for the disposal of depleted uranium and the continued pro tection ofhuman hea lth, specific perfonnance objcctives for land disposal of radioac tive waste have been set forthin the URCR. Additiona lly, EnergySollifions' Clive fac ility is govern ed by the Department ofEnvironmental Quali ty ' s groundwater and air regulatory requirements. Those rules potentia lly impactedby EncrgySolulions' intem to dispose of depleted uranium incl ude:

"General Provisions" - URCR R3l3-l2 "Violations and Escalatcd Enforcement" - URCR R3 13-14 "Standards for Protection Against Radiation" - URCR R3 13-15 "Administrative Procedures" - URCR R3l3-l7 "No tices, Instruc tions and Reports to Workers by Licensees or Registrants- Inspec tions" -

URCR R313- 18 "Requi rements ofGcneral Applicability to Licens ing of Radioactive Material" - URCR R313-19 "Specific Liccnses"- URCR R313-22 "License Requiremcnts of Land Disposal of Radioactive Waste" - URCR R3 13-25 "Genera tor Site Access Pennit Requirements for Access ing Utah Rad ioactive Waste Disposal

Facil ities" - URCR R313-26

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"Payments, Categories and Types of Fees" - URCR R3 13-70 "Ground Water Quality Protection Rules" - Utah Administ rative Code (UAC) Rule 317-6 "A ir Quality Protection Rules" - Utah Administrative Code Rule 307

1.3 Historical Management of Depleted UraniumLarge-scale uranium en richment in the United States began as part of atomic bomb development by theManhattan Project during World War II. Uranium enrichment activities were subsequently continuedunder the U.S. Atomic Energy Commission and its successor agencies, includ ing DOE. The K-25 plant inOak Ridge, Tennessee l was the first of three gaseous di ffusion plants constructed to produce enricheduranium. The K-25 plam ceased operations in 1985, but uranium cn richmcnl continues at fac ilitieslocated in Paducah, Kentucky and Portsmouth, Ohio. These two plants are now operated by the UnitedStales Enrichmcnt Corporation, created by law in 1993 to privatize uranium cn richmcnt.

In Ihc gaseous diffusion proccss, a strcam of heated uranium hcxafluoridc (UF6) gas is separatcd into astream of UF6 gas containing cnriched Um (EUF6) and a stream ofUF6 gas deplelCd in U235 (DUF6). Theenri ched uranium materials arc used for manufacturing commercial reaclor fuel , (typically contains 2 to5% UBS ), and military app lications (requiring up to 95% Um ). The DUF6 waS lC materials of intcrcst tothi s Compliance Repon typica lly contain Um concentrat ions as low as 0.2 to 0.4%. Since the 1950s,DUF6 waste materials have been stored at all three storage sites in large steel cy linders, similar to thatillustra ted in Figure 1-2.Depleted uranium was also produced at DOE 's Savannah River Site. The Savannah River Site produccddepleted uranium as a byproduct of the nuclear material produc tion programs, where irradiated nuclearfucls we re reprocessed 10 separate out the fissionable Pum. Uranium bi llels were produced at the DOEFernald, Ohio site, fa bricatcd into targets at Savannah Ri ver Site, and then irradiated in the SavannahRi ver Site production reactors to producc PUZ39. Thc irradiated largets were processed and fission productsseparated from Ihe pluton ium and uranium, which wcre then separated from each olher. After additionalpurification, the depleted uranium-bearing waste stream was then processed into uranium tri oxide(DU03). Whi le still classified as dep letcd uranium, this DU03a lso eOnlains small quant ities of wastcfiss ion products and transuranic elements. The Savannah River Site produced approximatel y 36,000 (55-gal) steel drums of DU03 during the production campaigns. This DU03, a so lid powder at roomtemperature and pressure, is considered to be relatively homogeneous, based on known process controlsand operations.

1 Ille site of the K-25 plant is now called the East Tenness(:e Technology Park (E"ITP), but is rcfcrrcd \0 by its original name,the K-25 site, in this Compliance Report

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ENERGVSOLUTIONS

- - - - - -1648"

Figure 1-2, Typical Depleted Uranium Storage Cylinder (DOE, 1999)



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ENERGVSOLUTIONSBecause storage began in the early 1950s, many of the drums and cyl inders now show evidence ofexternal corrosion and increased breach risk. When a DUF6 container is breached, the contents react w ithmoisture in air to form caust ic hydrofluoric acid (HF) and solid uranyl fluoride (U 02F2). By 1998,breaches were identified in eight cylinders (two at Paducah, two at Portsmou th, and four at K25) ,gcncraJly aro und spots prev iously damaged by handling aClivities. Similarly, a significam number ofdrums alt he Savannah Ri ver Site have been placed in to overpacks as a mitiga ting action for corrosioncontrol and to prevent spills.In an effort to reduce risks associated with container breach, Pub lic Law 107206, the 2002 SupplementalApprop ria lions Act fOT Further Recovery from and Rcsponse 10 Tcrrorist Alt1cks on the United Statcs(co mmonly referrcd to as the "Terror ist Attack Response Act") requires DOE to des ign, co nstruct, andoperate facililies at Paducah and Portsmouth, for conversion of DUF6 10 the safcr form, depletedtriuranium oe taox ide (U30 S). As part of this revised management strategy, a ll K-25 DUF6 cy linders wereshipped in 2004 to Portsmouth to be eventually converted to U30 S. The Terrorisl Attack Response Actfurther required that the U30 g be stored at Paducah and Portsmouth until there is a determination that allor a po n ion ofl he depleted uranium is no longer needed. At Ihat point, Ihe U30 S is to be disposed of aslow-level radioac tive waste. DO E estimate s the inventory of U30 g thai will eventua lly require disposal tobe approximately 700,000 metric tons over a 20 to 25 year period (DOE, 2 007).Conversion to U30 s is a preferential management strategy, because DUF6 is a volatile, white , crystallinesolid. Conve rsely, U30 S is kinetically and thermodynamically stable and is the most common form ofuranium found in nature. U30 S can be produced in rotary kiln or fluidized-bed reaclOrs by a pplication ofsuperhea ted steam and hydrogen (from dissociated ammonia) to DUF6 (producing solid U0 2F2 powderand gaseous HF). The powder U02F2 is then defluorinated through heal and Sleam addition to createU30s .1.4 Basis for Performance AssessmentURCR R3l3-25-8 requires that a performance assessment be performed and approved by the Departmentof Env ironmcntal Quality prior to the d isposal of signi ficant quantities of dcpleled uranium. The requiredperformance assessment must meet the provisions of section 2(a) of R3l3-25-8 that requires that theperformance assessment:

"demonstrates that the performance standards specified in 10 CFR Part 61 and correspondingprovisions o/Utah rules will be met for the total quantities ofconcentrated depleted uranium andother wastes, including wastes already disposed ofand rhe quantities ofconcentrated depleteduranium the faCility now proposes to dispose. Any such performance assessment shalf be revisedas needed to reflect ongoing guidance and rulemakingfrom NRC. For purposes of hisperformance assessment, the compliance period shall be a minimum of 10,000 years. Additionalsimulations shall be peiformedfor the period wherepeak dose occurs and the results shall beanalyzed qualitatively . "

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ENERGVSOLUTIONSIn performance of the required performance assessment, it is useful to consider (he gu idance the NRC hasissued to assist app licants and licensees in applying these standards as they reflect years of experiencewith a variety of waste streams and disposal situations. NUREG-1573 is a key NRC guidance documentfor conduct ing pcrfonnancc asscssmcnts(NRC, 2000). More recent guidance is contained in NURG-1854, (NRC , 2007).In particular, there arc four areas to consider in applying the performance standa rds. First is thecompliance period. Second is the dose methodology. Third is the dose standard for the intruder. Fourthis s ite stabi li ty.Sec tion 2 (a) addresses the time period for compliance. It slales:

"For purposes of his performance assessment, the compliance period shall be a m;nimum of10,000 years. Additional simulations shall be performed for the period where peak dose occursand the results shall be analyzed qualitatively. "

From a compliancc pc riod perspcctive, 10,000 years is the timc period for a quamita li vc analysis and isconsisten t with Federal rules and guidance. Given the nature of depleted uranium, a qua litative analysisout to the peak dose period is also warranted to inform the perfonnance assessment Use of the 10 ,000year time period for comp liance is consistent with federal regulations (e.g., 40 CFR 19 1) and NRCguidance. Ex tending the analysis qualitatively until peak dose is also consistent with NUREG-1573recommendation s. The NRC has taken a similar approach with the NRC Decommissioning Critc ria forthe West Valley Demonstration Project at the West Va lley Site (NRC, 2002). It is noteworthy th at theonly Federal standard that goes beyond 10,000 years for comp liance is the standard for Yucca Mountain(NRC, 2002). That prov ision provides a two-level dose standard with a higher dose limit of 100 mremafter 10,000 years.Consequently, for purposes of applying the performance standards for protection of the generalpublic (URCR313-25-19) and for protection of individuals from inadve rtent intrusion (URCR313-25-20), th e Division s hould chosen to use th e 10,000 year compliance period with a qualitativeanalysis to cover the period beyond to the peak dose.The performance standard for protection of the general public (URCR3 13-25-19) is based on th e 1959standards of In ternational Commission on Radiological Protection (ICRP) Pub lication 2 methodology.URCR3 13- 15 rules arc based on newer ICRP guidance in Publications 26 and 30. Part 20 uses th e totaleffective dose equivalent (TEDE) rather than the whole body dose. NRC has recognized theinconsistency between the dose methodologies and has issued gu idance to allow the use of newerguidance. This approach was taken for Yucca Mountain in 10 CFR Part 63, NUREGs -1854 and 1573,and in the NRC Decommissioning Criteria for West Valley. As noted in NUREG-1573:

"As a mailer ofpolicy, the Commission considers 0.25 mSvlyear (25 TEDE as theappropriate dose limilto compare wilh the range ofpotential doses represented by the olderlimits thaI had whole-body dose limits of0.25 mSvlyear (25 mremlyear) (NRC, 1999, 64 FR8644; see Footnote 1). Applicants do not need 10 consider organ doses individually because the

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ENERGVSOLUTIONSlow value of/he TEDE shollid ensure thaI no organ dose will exceed 0.50 mSvlyear (50mremlyear). "

Consequent ly, the Division should use for purposes of applying the performance standards forprotection of the general public (URCR313-2S-19) the total effective dose equivalent rather than th ewhole body dose.The performance standard for protection of individuals from inadve rtent intrusion (URCR313-25-20)requires" . .protection ofany individual inadverremly intruding inlo rhe disposal site and occupying Ihesite or contacting the waste," However, these regulations arc si lent on the specific dose standard to appl y.Since Part 61 has been issued, the standard used by NRC and olhers for low-level radioactive wastedisposal licensing has been an intruder standard of 500 mrem/yr. The 500 mrem standard is also used inDOE's waS le determinations implementing the Part 61 performance objectives (NUREG -1 854). It isnoted that 500 mrem/yr was also the standard proposed in Part 6 1 in 1981 (46 FR 38081, July 24, 1981).Additionally, the Statement of Considerations for the fina l rule did not object to the numbe r. It wasremoved apparen tly at the request of EPA, because of its concern of how one wou ld monitor it ordemonslra le compliance w ith it, but not because EPA disagreed with it (47 FR57446, 57449, December27, 1982) . A dose standard of 500 mrem/yr is al so used as part of the license termination rule dosestandard for intruders ( 10 eFR 20.1403).Consequently, ORC should use for purposes of applying th e performance standard for protectionof individuals from inadvertent intrusion (URCR313-2S-20) a 500 mrem/yr th reshold fo r theintruder dose.The performance standard for stabi lity requires the facility must bc s itcd, designed, and closed to ach ievelong-term stab ili ty to eliminate to the extent practicable the need for ongo ing active maintenance of thesite following closure. The intcnt of this requiremcnt is to provide reasonable assurance that long-termstab ili ty of the disposed waste and the di sposal site will be achieved.Prior to implementing Part 61 , it had been a common practice at waste disposal fac ili ties to randomlydum p some waste. Thi s practice jcopardizcd package in tegrity and did not permit access to voidsbetween packages so that thcy could be properly backfilled. Consolidation of wastes would provide a lessstable support which could contribute to failure of the disposa l un it cover leading to increasedprecipitation infiltration and surface water intrusion.To help achieve stability, NRC noted that to the cxtent practicable the waste should maintain grossphysica l properties and identity over 300 years, under the conditions of disposa l. NRC believed that theuse of design features to achieve stability was consistent with the concept of ALARA and the usc of thebest available technology. It was NRC's view that to the extent practicab le , waste forms or containersshould be designed to be stable (i.e., maintain gross phys ica l properties and identity, over 300 years).NRC also noted that a site should be evaluated for at least a SOO-year time frame to addre ss th e potentialimpacts of natural events or phenomena should also be app lied.About me same lime as Pari 61 was promulgated, NRC also put in place requirements for design ofuranium mill tailings piles such as the Vitro si te whieh is righ l nex l 10 the Clive s ile. In addressing

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stability requirements for mill tailings, NRC recognized the need to set pract icable standards. NRCspec ified thai the design shall provide reasonable assurance afcontrol of radiological hazards to beeffective for 1,000 years, to the extent reasonably achievable, and, in any case, for allenst 200 years.In both cases (low-level radioactive waste and mill ta ilings disposal) NRC recognized (he need to setpractical standards that can be implemented. The design standards range from 200 up to 1,000 years.NRC recognized the design limitations and noted that reasonably ac hievable designs should be empl oyedto the extent practicable. It is not practical to set design standards beyond 1,000 years.Consequently, the Di vision should use for purposes of applying the performance standard forstability of the disposal site after closure (URCR313-25-22) an approach consistent with paststandard setting practice.EnergySolulions has demonstrated that its disposal site des ign and elosure will provide reasonableassurance that long-term stability will be achieved and that the usc o flhe best ava ilable leehnology insening design standards in the range from 200 up to 1,000 years is approp riale to provide si te stabi lity tothe extent practicable.URCR Ru le 3 13-25-8(2) , as amended, requi res Energy501lllions to demonstrate to the Division thatproposed methods for disposal of depleted uranium will ensure that future operat ions, institutionalcon trol, and si te closure can be conducted safely, and that the s ite will comply with the facility'sperformance objectives and the Division 's regulatory requircmenls. Toward Ihal end, EncrgySolulionshas conducted a detailed, s ite-specific, probabilistic performance assessment us ing GoldSim modelingsoftware (Gold Sim , 20 II).The GoldSim model, developed and managed by the GoldSim Technology Group, is a Monte Carlosim ulation software solution for dynamically modeling complex systems in business, engineering andscience. GoldSim supports decision and risk analysis by simulating future performance whilequantitatively representing the uncertainty and risks inherent in a ll complex systems. GoldS im is ageneral purpose simul ator that utilizes a hybrid of several simulation approaches, combining an extensionof system dynamics w ith Some aspects of discrete event simulation, and embedding the dynamicsim ulation engine with in a Monte Carlo simulation framework. As part of a jo int effort by NRC andDOE, the GoldS im model and the supporting sub-models have undergone ex tensive reviews concerningits use 10 demonstrate compliance with the individual protection standard s (pensado, et. ai, 2002).This Report demonstrates EnergySolutions' compliance with the URCR 313-25-8(2) and those otherregul atory requirements affected by the proposed depleted uranium di sposal.

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ENERGVSOLUTIONS2. REGULATORY COMPLIANCE AND PERFORMANCE OBJECTIYE SATlSFACTIONAs pan of (he renewal of its Radioactive Material License in 2008 (RML UT2300249), the Divisioncertified Ihat EncrgySo{utions' is in compliance with all appl icable regulatory requirements (2008 RMLrenewa l). As such, activities conducted at EnergySollilions ' Clive site are designed to protect the healthand safety of facility wo rkers, the general public, and the environment. EncrgySolutions ' operations arcconducted under the ongoing regulatory scrutiny of the Di vision, Utah Division of Solid and HazardousWaste, Utah Division ofAi r Quality, and Utah Division of Water Quality. These inspectors providecominuing assurance that the interests of radiological and cnvironmenlal safety arc prope rly addressed.Additionally, EnergySolufions continues to demonstrate that it is financially eapablc to carry out alllicensed activities. Ene rgySolllfions provides financial assurances sufficient to fund the safe closure ofthe fac ility, as we ll as the long-term monitoring an d maintenance of the facility. Ene rgySo/lifions alsoprovides infonnation about the required qualifications of those persons who will operate the faci lity andabout irs existing naining program.Fo r the maj ori ty of applicable regulatory requirements, disposal of depleted uranium does not impact the prior certi fica tion of EnergySoluliom complianct:. Howt:ver, a ofa desire to of depleted ura nium and in compliance with URCR Rul e 313-25-8(2), EnergySolufions has conducted adetailed, s ite-spcc ific, probabilistic perfonnance assessment to demonstrate to the Di vision that:

I) its proposed methods for disposal of depleted uranium w ill ensure that future operations,institutional contro l, and site closure will continue to be conducted safel y,

2) the site w ill continue to comply with its perfonnance objectives, and3) it wi ll continue to be in compliance with applicable Di vision requirements.

In addi tion to URCR R3 I 3-25-8(2), other regulatory requirements affected by the proposed depletedurani um disposal with which EnergySollifions must also demonstrate compliance a re listed in Table 2-1and addressed in further detail in this Section.

Standards for Protection Against Radiation" - URCR R3 13-l5 Notices, InSlfuctions and Reports to Workers by Li censecs or Registrants" - URCR R313-l8 License Requirements of Land Di spo sal of Radioactive Waste" - URCR R3 13-25 Ground Water Quality Protection Rules - R3 I 7-6 Air Quality PrOiection Rules - R307

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App licable Requirements Potentially Impacted by the Di sposal of Depleted Ura nium

URCRR3 13-IS- 10 IR3 13- IS-20 IR3 13- IS-30 IR3 13- IS-402R313- IS-60 IR3 13-IS-S0 IR3 13-IS-902R3 13-IS-906R313-IS- 1002

R313-IS- 1009R3 13- IS-12R3 13-2S-6(3)

R313-2S-7

R31 3-2S-S

R313-2S-1 1

R3 13-2S-18R3 13-2S-19R3 13-2S-20R313-2S-21R3 13-2S-22R3 13-2S-23R3 13-2S-24R3 13-25-3 1R3 13-25-32

Radiation Protection ProgramsOccupational Dose Limits for Adults

REASON

Dose Limits for Individual Members of the PublicRad iological Criteria for Unrestricted UscControl of Access to Hi gh Radiation AreasSecurity and Control of Li censed or Registered Sources of RadiationPosting RequirementsProcedures for Receiving and Opening PackagesMethod for Obtaining Approval of Proposed Di sposal ProceduresWaste ClassificationInstruction to WorkersGeneral Information - Disposal Location and Expected SchedulesPrinc ipal Design Features Potentially Impacted by the Disposal of Depleted Uranium(e.g., Waste Em placement and Backfi ll, Land Di sposal Facility Construc tion andOpcration, and Classification and Spccifications)Technical Analysis for the Protection of the General Population, Protec tion ofInadvertent Intruders, Protection during Normal and Abnormal Operations, andDemonstration of the Long-Ternl Disposal Site Stability.Requirements for Issuance of a License demonstrating no unreasonable risk to theGeneral Public, Training and Qualification of Li censee Staff, Adequacy of Site toProtect the Public during operations and after closure, and the adequacy of financialresources to operate, close, and provide for appropriate institutional control of thefac ili ty.Licensee's facility shall be sited, designed, operated, closed, and controlled so thatindividual exposures arc limited.Licensee's facility shall be sited, designed, operated, closed, and contro lled so Ihatgeneral population exposures arc limited.Licensee's facility shall be sited, designed, operated, closed, and controlled to limitexposures to individuals inadvertently intruding.Licensee's facility shall be sited, designed, and operated to limit exposures to individualsduring ope rations.Licensee's facility shall be sited, designed, operatcd, closed, and controlled to achie velong-term stability of the site without ongoing active maintenance.Disposal Site Suitability Requirements for ncar-surface land disposal.Disposal si te design requirements for ncar-sur face land disposa l.Lic ensee's assurance of financial capability to conduct necessary site closure andstabilization activities.Licensee's assurance of financial capability to conduct necessary institutional controls,fo llowing facility closure.

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Table 2-1Applicable Requirements Potentially Impacted by the Disposal of Depleted Uranium

URCRR313-25-33

R3 13-25-34

R3 13-25-35

R3 13-R3 17-6

REASONSpecifics record keeping and reporting rcquircmcnls of a pe rso n licensed for low-levelrad ioac live waste disposal under URCR R313-25. As such, thi s is an issue forcompliance monitoring rather than a criterion for granting a license amendment.However, the information and procedures provided in the 2008 LRA renewal and othersubmittals demonstrate that EncrgySollilions intends to maintain information and recordsthat arc required by this regulation and that w ill be necessary to develop the requiredreports.Requires that EncrgySo!ulions perform or allow the Executive Secretary to perform teststhat thc lattcr considers ncccssary. Tests may addrcss any of (I) wastcs, (2) faci liticsuscd for rcccipt, storage, treatment, handling or di sposal of waS lcs, (3) radia tiondctection and monitoring instruments, and (4) othcr equipmcnt and devices used inconnection with the rcceipt, posscssion, handling, Ircatmcnt, slO ragc, or disposal ofwaste. As such, this is an issue for compliance monitoring rather than a critcrion forini tial licensing.Rcquircs that EncrgySollllions allow thc Execu livc Sccrclary access to the disposalfac ili ty for facility and records inspections. As such, this is an issue for comp liancemonitoring rather than a criterion for granting a liccnsc amendmen l.Groundwater protection limits

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2.1 R313-1 5-101; Radiation Protection ProgramsRequirement: Licensee shall develop, document, an d implement a radiation pro tection program sufficientto ensure comp liance, including operational procedures and eng ineering controls to achieve occupationaldoses and doses to members of the public that arc as low as is reasonably achievable. Licensee'sRadialion Protec tion Program shall constra in air emissions of radioactive malcriai from operations to theenvironment, excluding radon-222 and its decay products, suc h thai a member of the public likely toreceive the hi ghest dose will not be expected to receive a total dose equi va lent in excess of 10 mrem peryear from these emi ssions.Compliance Basis: EnergySo{utions' 2008 RML renewa l references several plans and programdescriptions that control operational activities that are carried on at the facility and whic h constitute thefac ility 's Radiation Protection Program, including the Waste Characterization Plan, CQAJQC Manual,Radiation Safcty Manua l, ALARA Plan , Health and Safety Plan, Emergency Response and ContingencyPlan, S ite Radiological Security Plan, Environmental Monitor ing Plan, and Q ua lity Assurancc Manua l.Management and disposal practiccs documcnted therein do n ot require alteration to accommodatedcpleted uranium in a manncr compliance with the R313- 15-1O I ALARA standa rds. Simila rly, the 2008RML renewal ineludes models demonstrating that atmospheric-pathway doses to the gencral publicdur ing operations wi ll remain below regulatory required levels. Furthermore, EnergySolutions'Environmental Monitoring Program ineludes provisions to actively measure atmospheric radioactivecontaminant concentrations at their Cl ive facility property boundary and to notify the Division in theevent these concentrations approach levels of non-compliance.2.2 R313-1S-201; Occupat ional Dose Limits for Ad ultsRequirement: Liccnsee shall control the occupational dose to individual adults, except for planned specialexposures, to the more limiting of a total effective dose equi valent of S rem or the sum of the deep doseequiva lent and committed dosc cquivalent to any individual organ or tissue ot her than the eye of 50 rem.Furthermore, the Licensee shall control the occupational doses to the lens of the eye to IS rem and skin to50 rem of individual adults. Notwithstanding the annual dose lim its, the Licensee shall limit the so lubleuranium in take by an individual to 10 mg in a week in consideration of chemical toxicity.Compliance Basis: EnergySolutions' 2008 RML renewal references sevcral plans and programdescriptions that control exposures from operational activities that arc carried on at the facility, includingthe Radiation Safety Manual, ALARA Plan, Health and Safety Plan, Emergency Response andContingency Plan, and Environmental Monitoring Plan. Management and disposal practices documentedtherein do not require altcration to accommodate depleted uranium in a manner compliance with theR313-IS-20 I occupational standards. As is documented therein , EnergySo/ulions regu larly monitors andreports to the Division occupational exposures. EnergySolufions' Radiation Protec tion Program alsoincludes provisions to notify the Division in the event these occupational exposures approach levels ofnon-compliance.



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2.3 R313-1 5-301; Dose Limits fo r Individual Members of the PublicRequirement: Licensee shall conduct operations so that the annual lolal effective do se equivalent toin di vidual members of the public during operations docs not exceed 0.1 rem. Ad ditionall y, the dose inany unrestricted area from external sources does not exceed 2 mrcm in anyone hour.Compliance Basis: EnergySolutions' 2008 RML re newal references several plans and programdescriptions that co ntrol exposures to members of the public from operationa l activities that arc carried onallhc fac ili ty , including the Radiation Safety Manual, ALARA Plan, Health and Safety Plan, EmergencyRe spo nse and Contingency Pl an, Site Radiological Security Plan, and Environme ntal Monitoring Pl an.Management and disposal practices documented therein do not requ ire altera tion to accommodatedepleted uranium in a manner compliance with the R313- 15-30 I operational standards. As isdocumented therein, EnergySoilllions regularly monitors and reports to the Division offs ite contaminantconccntrations and exposure levels. EnergySollilions' Radiation Protection Program also includesprovisions to notity the Di vision in the event these occupa tio nal exposures app roach levels of non-compliance.2.4 R313-1S-402; Radiological Cri teria for Unrestricted UseRequircment: By statute (R313-1 5-401), radiological criteria for unres tr icted use apply to anci llarysurfac e fac ilities that support radioactive waste disposal activ ities. As such, a s ite will be cons ideredacceptable for unrestricted usc if the residual radioactivity that is distinguishable from backgroundradiation resu lts in a total cffec tivc dose equivalent to an average member of the critical group that docsnot exceed 25 mrem per year, including no greater than 4 mrcm committed effective dose eq uivalent ortotal effective dose equiva le nt to an average member of the c ri tical group from ground water so urces, andthe residual radioacti vity has been reduced to levels that are as low as reasonably ac hievable (ALARA).Compliance Basis: Chapter 6.4 of Appendix A and EnergySollllions' 2008 RML renewal referencespo licies and procedures for decommiss ioning and re leasing of anci llary surface faci lities used in supportof di sposal operations, including the CQAJQC Manual, Radiation Safety Manual, ALARA Plan, Healthand Safety Plan, and Quality Assurance Manual. EnergySo/ulions is currently storing drums containingdepleted ura nium from Savannah Ri ver Site's operations in a Depleted Uranium Storage Building builtafter the 2008 RML renewal. Prior to its construction, the Division reviewed and approved the StorageBuilding construction plans, usc management, and eventual decommiss ioning and unrestricted relcaseplans. No additional infonnation is required to demonstrate compl iance.2.5 R313-1S-601; Co ntrol of Access to High Radiation AreasRequirement: The Licensee shall ensure that each entrance or access point to a hi gh radiation area ha s I) acon trol device that, upon entry into the area, causes the level of radi ation to be reduccd below th atlevcl atwhich an individ ual might rcceive a deep do se equivalent of 0.1 rem in one hour at 30 centimeters fromthe source of radiation or from any surface that the radiation penetrates; 2) a control device that energizesa conspicuous visible or audible alarm signal so that the individual enterin g the high radiation area and

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the supervisor of lhc activ ity arc made aware oflhc entry; or 3) cntryways tha t arc locked , except duringperiods when access to the areas is required, with positive con trol over each individual entry.Compliance Basis: EnergySolutions' 2008 RML renewal references unrestricted and restr icted area accessprotocols and protections contained in the Radiation Safety Manual, ALARA Plan, Health and SafetyPlan, Emergency Response and Contingency Plan, and Site Radiological Security Plan. As wassubmitted to the Division prior to their approval ofils construc tion, EncrgySo/lIlions continues to applybui lding access restric tion controls to their Dep leted Uran ium Storage Building. No fu rther informationis necessary to demonstrate compliance.2.6 R313-15-801; Security And Control Of Licensed Or Registered Sources Of RadiationRequirement: The licensee sha ll secure licensed radioactive material from unauthorized remova l oraccess.Compliance Basis : EnergySolutions' 2008 RML renewal references security protocols and p rotections forradioac tive materials in unrestricted and restricted area contained in their Radia tion Safety Manual,Hea lth and Safety Plan, Emergency Response and Contingency Plan, and Sile Radiological Sccurity Plan.As was submitted to the Division prior to their approval of its construction, EnergySo/lIlions continues toapply material security and access controls to their Depleted Uranium Storage Build ing. No furthcrinforma tion is necessary to demonstrate compliance.2.7 R313-15-902; Posting Requirem entsRequirement: The licensce shall post cach radiation area with a conspicuous sign or signs bearing theradiation symbol and the words "CAUTION, RAD IATI ON AREA."Com pl iance Basis: EnergySolutions' 2008 RML renewal references radiation sign post ing protoco ls andprocedures fo r radioact ive materials in unrestricted an d restricted area contained in their Radiation SafetyManua l. In compliance with these posting protocols and procedures, EnergySolllfions has posted therequired caution signs on its Depleted Uranium Storage Building. No furthe r information is necessary todemonstrate compliance.2.8 RJI3-15-906; Procedures for Receiving and Opening PackagesRequirement: The Licensee shall monitor the external surfaces of a labeled package for radioactivecontamina tion, monitor the external surfaces of a labeled package for radiation levels, and monitor allpackages known to contain radioactive material for radioactive contamination and radiation levels if thereis evidence of degradation of package integrity, such as packages Ihal arc crushed, wei, or damaged.Compliance Basis: EnergySofulions' 2008 RML renewal references waste receipt policies and proceduresfor radioactive materials reecivcd via rail and truck as contained in their Waste Characterization Pl an,Radiation Safety Manual, ALARA Plan, and Health and Safety Plan. The Savannah River Site depleted

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uranium drums curren tl y in storage in EncrgySoilllions' Depleted Uranium Storage Building and anyfuture depleted uranium packages will continue to be received and inspected accord in g to these approvedprocedures.

2.9 R3 13-1S- 1002; Method fo r Obtaining Appr ova l of Propose d Di sposal ProceduresRequirement: The Licensee shall apply to the Executive Secretary for approval ofp roposcd procedures todispose of licensed or registered material.Compliance Basis: EnergySolutions' 2008 RML renewal references waste disposal policies andprocedures fo r radioactive materials contained in their CQNQC Manual. Disposal of depicted uraniumwi ll be conducted according to these a pproved procedures. No further infonnat ion is required todemonstrale compliance.2.10 R313-1S- I009; Wa ste ClassificationRequirement: The Licensee shall only disposal ofwaste classified as "C lass A" , as defined by Iheprocedures contained in Ihis requirement. The dcfinitions in this section arc essentially identical to thoscin 10 CFR 61.55, with one exception: Utah adds Ra 226 to the li st of long-l ived radionuclides in thereg ulat ions' Tabl e I with a concentration limit of 100 nanoCuries per gam (nCilg). Additionally, on April13 , 20 I 0, the Utah Rad iation Control Board approved a Depleted Uranium Perfonnance AssessmentRule, R3 I 3-25-8, "Technical Analysis." The rule allows, subjeello approval of lhe infonnation containedin this Compliance Re port, the Licensee to accept and disposal of depleted uran iu m as Class A waste.Compliance Basis: URCR R313-15-1009 defines specific classifications (e.g., Class A, Class B, andClass C), based on a waste's source tenn. The Division has included Ra 226 to the list of long-livedradionucl ides in this regulations, with a concentration limit of 100 nCilg (Utah, 20 I 0). Since Ra n6 is adecay product of uranium-238 (Um), the principal component of depleted uranium, it is of directrelevance to the disposal of dep leted uranium waste. EnergySollilions' C live fac ility is licensed by theDi vision 10 dispose ofClass A wastc and has disposed of small qua nti lies of depleted uranium wastcunder that license. However, as is presented in Table 2-2, the Savannah River Site wastes underconsideration fo r disposal in this Compliance Report contain more than isotopes of uranium. Inparticu lar, the depleted uranium contains technetium-99 (Tc99) and strontium-90 (Sr90). Because of this,R313-15 -1 009 dictates that the detennination ofwaste classification is dri ven not by the presence ofuranium, but by the presence of radio nuclides identified in the regulatory requiremen t. Based on therela tive concentrations of isotopes other than uranium, the Savan nah River S ite wastes are Class A.Fu(ure shipments of other depicted uranium wastes thaI also contain isotopes Olhe r than uranium wi ll beeva luated for waste classification purposes in accordance with the Radioactive Material License andWaste Characterization Pl an, with wastes that are greater than Class A to be rejected for receip t.

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Savannah River Site Depleted Uranium Dru m Waste Concentrations

Mea n Sta ndardConcentration Dev iationRadionu clide (pCi/g)" (pCi/g)S,,,, 47 75

To" 23,800 11,000,,, I 19 9m CS 12 4226 Ra 3 17 110m U 5,290 480",U 33,100 2,170235U 2,970 750236U 4,910 1,17023SU 272,000 6,640m Np 6 723SPU 0.2 0.3239PU I I240PU 0.3 0.3241 PU 4 4241Am 14 5

Radiolluclidc Concentra tions in Savannah River Site drums in storage at EncrgySollilions arc gCllcmllynonnally distributed - See Appendix A, Chapter 9 lor development methodology.



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ENERGVSOLUTIONS2.11 R313-18-12; Instruction to WorkersRequirement: All individuals who in the course of employment with the Licensee arc likely to receive in ayear an occupational dose in excess of 100 mrem a) shall be kept in fonned of the storage, transfer, or useof sources of radiation in the licensee's or registrant's workplace; b) shall be instructed in the healthprotection considcralions associated with exposure to radial ion or radioactive malcriailo the individualand potential offspring, in precautions or procedures to minimize exposure, and in the purposes andfunctions ofprOlcctivc devices employed; c) shall be instructed in, and instructed to observe, to the extentwithin the wo rker's control, the applicable provisions of these rules and licenses for the protection ofpersonnel from exposure to radiation or radioactive material; d) sha ll bc instructed as to thei rresponsibi lity 10 repon promptly to the licensee or registrant a condition which may constitute, lead to, orcause a viola lion of Ihe Act, these rules, or a condition of the licensee's license or unnecessary exposure toradiation or radioactive material; e) shall be instructed in the approp riate response to warnings made inthe event of an unusua l occurrence or malfunction that may involve exposure to radial ion or radioactivematerial; and f) shall be advised as to the radiation exposure reports which wo rkers shall be furnished.Compliance Basis: EnergySo{ufions' 2008 RML renewal referenc es employee lra ining requirements forthe ir plans and program descriptions that control operational activities that are carried on at the fac ilityand wh ich constitute the facility 's Radiation Protection Program, including (he Waste CharacterizationPlan, CQAlQC Manual, Radiation Safety Manual, ALARA Plan, Hea lth and Sa fety Plan, EmergencyResponse and Cont ingency Plan, Site Radiological Security Plan, Environmental Monitor in g Plan, andQuality Assurance Manual. EnergySo{Ulions' Employee Training Program for management and disposalpractices docum ented therein docs not require alteration to accommodate depleted uranium.2.12 R313-2S-6(3); General Information - Expected SchedulesRequirement: The general information sha ll include the expected schedules for construction , receipt ofwaste, and first emplacement of waste at the existing land disposa l fac ility.Compliance Basis: As has been documented herein, EnergySollilions is currently in possession ofdepleted uranium from DOE 's Savannah River Site, waiting a final disposal solu lion. It isEnergySolulions' target within 120 days of acceptance by the Division's Execu ti ve Secretary of thePerfonnanee Assessmem (as documented herein), to apply for its Radioactive Ma terial License beamended 10 include disposal of the depleted uranium wastcs currently in slorage at the ir Clive Facility.Within 120 days fo llow ing successfully amending their Radioactive Mate rial License, EnergySollilionsintends to begin disposing of the Savannah River Site depleted uranium. Furthermore, subject to ongoingcontract negotiations with DOE, EnergySollilions expects to receive and dispose of depleted uraniumfrom th e deeonversion plants within onc year of regu latory approval.



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2.13 R313-2S-7j Specific Technical Information - Principal Design Features: Descriptions,Design Cr iteria, Justification, and CodesRequirement: The regulatory requirements of URCR R313-25-7(2) -7(3) , -7(4) , and -7(5) form asystem of requirements that apply to numerous principal design features allhc existing low-levelradioac tive waste disposal facility and ensure that they will continue 10 perform adequately with thedisposal of depicted uranium to achieve the performance objectives stated in URCR R3 13-25-18 through26. The Licensee shall include the following information to dctcrm ine whethe r or not they ca n continue tomee t the performance obj ec tives and the applicable technical requirements of URCR R3 1325 indisposing of depleted uranium.Descriptions of the design features of the land disposal facility and of the disposa l un its fo r ncar-surfacedisposal shall include those design features rel ated to infiltrat ion of waler; integrity of covers for disposalunits; structu ral stability of backfill, wastes, and covers; contact of wastes w ith stand ing water ; disposals ite drainage; disposal site closure and st abilization; climination to the extent practicable of long-termdisposal site maintenance ; inadvertent intrusion; occupationa l exposures; disposal site monito ring; andadequacy of the size of the buffer zone for monitoring and potentia l mitigative measures. [URCR R313-25-7(2)] Descriptions of the principal design criteria and their rel ationship to the performancc objcctives.[U RCR R3 13-25-7(3)] Descriptions of the natural events or phenomena on which the design is based andtheir relationship to the princi pal design criteria. rURCR R313-25-7(4)] Descriptions of codes andstandards which EnergySollllions has applied to the design, and wi ll apply to construction of the landdisposal facilities. [UR CR R313-25-7(5)]Compliance Basis: EnergySolllfions recognizes that the safe storage and disposa l of depleted uraniumwaste is essen tia l for mitigating releases of radioactive materials and reducing exposures to humans andthe environment. EnergySollllions' C live Facility design fe atures are described in detail in the 2008 RMLrenewal. In its acceptance of EnergySolufions' 2008 RML rcnewal, the Di vision has determined that theprincipa l design features identified perfonn the required func tions (meaning that at least onc requiredfunction is performed by each pr incipal design feature). The pr incipal design features potentiallyimpacted by the intended disposal of depleted uranium, and for which satisfac tory functional performancemust herein be addressed arc Waste Placement and Backfi ll , Land Di sposal Facil ity Co nstnlction andOperation, and Classification and Specifications.As they are potentially impacted by the intended disposal of depleted uranium, Waste Placement andBackfi ll , Land Di sposal Facility Construction and Operation, and C lassification and Specifications aredescribed below, their design criteria identified, justification that they will perform as requi red ispresented, and the codes and standards applicable arc summarized. In review of the principal designfeatures, the required func tions that the principal design features must perform, as identified in URCRR3 13-25-7(2), include:

Minimize infilt ration of wate r.Ensure integrity of covers for disposal units.Ensure structural stability of backfill, wastes, and covers.Minimize contact of wastes with standing water.

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ENERGVSOLUTIONSProvide disposa l site drainage.Ensure disposal site closure and stabilization.Eliminate to the extent practicable long-term d isposal site ma in tenance.Protect against inadvertent intrusionLim it occupational exposures.Provide fo r disposal site monitoring.Provide a buffer zone for monitoring a nd potentia l mitigati ve measures.

Was te Em placement and Backfill - Description of Design FeatureRequirement: Descriptions of the design features afthc land disposal facility and of lhc disposal units forncar-surface disposal of depicted uranium shall include those design fea tures related to infiltration ofwater; in tegrity of covers for disposal units; structura l stability of backfi ll , wastes, and covers; contact ofwastes with standing water; disposal site drainage; disposal s ite elosure and stabil ization; elimination tothc cxtCnl practicable of long-term disposal site maintenance; inadvertent int rusion; occupat ionalexposures; disposal site monitoring; and adcquaey of the size of the buffer zone for monitoring andpotential mitigalive measures. [URCR R3 I 3-25-7(2)]Compliance Basis EnergySolutions proposes to dispose of depleted urani um in the western fraction ofthc Federal Cel l. The eastern section is occupied by the I le.(2) cell, which is dedicated to the disposal ofuranium processing by-product waste , and which is not considered in the ana lysis. The general des ignaspect is that of a hipped cover, with relatively steep sloping s ides nearer the edges. The upper part of theembankme nt has a more moderatc slopc than the sides. Only the top slope region is modeled in AppendixA, s ince no depleted uranium will be placed beneath the embankment' s side slopes.

The 2008 LRA renewal addresses the pertinent characteristics of the principa l design features for generalwaste placement and backfi ll including thc waste typcs to be disposed in the existing embankments.Waste in cl uded in this analysis may takc a variety of physical forms, including so il or soil-like material,compressible debris , incompressible debris, oversized debr is, containerized Class A LLR W, and depleteduranium. Liquid waste may not be disposed in the embankmenls. Revisions to the waste pLacementmanagement program for pl acement of depleted uranium are addressed in Chap ters 4 and 6 of AppendixA and will be conductcd in accordance with the CQAlQC Manual. As with Olhe r wastes, de pleteduranium wi ll be are disposed at EnergySollltions' Disposal Emba nkments in accordance with theprovisions of the CQNQC Manual. However, depleted uranium placemenl is expected to be subject tocontrols and license conditions.With downward contaminant transport pathways influencing groundwaler eoncenlrations, and upwardcontaminant transport pathways influencing dose an d uranium hazard, a balance is achieved in theplacemenl of different k inds of wastc. Thc Performance Assessmenl examined three different options forcon figuration of the depleted uranium waste within the emban kment. The vo lume within theembankment that is available for waste disposal is 44.3 ft deep be low the engineered cover. No depleteduranium waste is modeled bcneath the cmbankment's side slopes in the Pe rformance Assessment.

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I. 3m Model

ENERGVSOLUTIONSClean Fill from cover to 9.9 ftGOP contaminated waste from 9.9 ft to 11.6 ftSRS waste from 11.6 ft to 13.23 ftGOP uncontaminated waste from 13.23 ft to 44.65 ft

2. Sm ModelClean Fill from cover to 16.54 ftGOP contaminated waste from 16.54 ft to 18.19 ftSRS waste from 18.19 ft to 19.84 ftGOP uncontaminated waste from 19.84 ft to 44.65 ft

3. 10m ModelClean Fill from cover to 33.07 ftGOP contaminated waste from 33.07 ft to 34.72 ftSRS waste from 34.72 ft to 36.38 ftGOP uncontaminated waste from 36.38 ft 1044.65 ft

These op tions cover a fai rly wide range of possible disposal options, from disposal below grade only todisposal throughout most of the system, exploring the range o f possible op tions for disposal of depicteduranium waste.The des ign of the faci lity enables isolation of each embankment afler it has been fi lled and covered.Thus, once Ihe embankment is closed, it will not be disturbed by eOnl inuing operations at the site. Thefina l embankment cover integrates long-tenn water and erosion control methods into the overa ll design,thus C\iminal ing the need for active maintenance of a closed embankment. Comp liance w ith thisrequircmcni has Ihcrefore becn sufficiently demonstrated.W as te Emplacement a nd Backfill - Principal Design Cr iteriaRequirement: Deseriplions of the principal design criteria and their rc\alionship to the performanceobject;ve, . [URCR R313-25-7(3)JComp liance Basis: The principal design criteria pertinent to the design of the depleted uranium wasteplacement and backfi ll are justified in Chapter 4 of Appendix A. A key des ign cr iterion is the limitationof a llowable d islOrtion in the cover to less than 0.02 ftlfl. Tha i is, the depleted uran ium waste pl acementand backfill must not result in a magnitude of differential settlement w ithin the Disposal Embankmentthat wo uld eomribute to a distortion that exceeds 0.02 ftlfl in the cover. Practica lly, this means that coversystem settlement is acceptable so long as it is less than I foot of vertical displacement in less than any50-foo t ho rizon tal distance. Based on the foregoing summary of infonnation contained in the 2008 RMLrenewa l and the fact that waste placement procedures will not change, Ihis rcpon doeumenls Compliance

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ENERGVSOLUTIONSby EncrgySolufions with the requirements of URCR R3 13-25-7(3 as they pertain to the disposa l ofdepleted uranium in the disposal embankments.Wa ste Emplacement and Backfill - Design Basis Conditions and Design Criteria JustificationRequirement: Descriptions oflhc natural events or phenomena on which the design is based and theirrela tionship to the principal design criteria. lURCR R3 13-2S-7(4)JCompliance Basis: In development of the projected performance oflhc depleted uranium waste placementand backfill as presented and justified in Appendix A, EnergySo/lIlions uti lized applicable guidanceissued by the NRC, including those described in SECY -08-0 147, NRC NUREG-1199 and NUREG-1200,pertain ing to normal, abnonnal , and accident (where applicable) conditions that shoul d be considereddur in g design of NRC-licensed 10wlevc1 radioactive wastc disposa l facilities. Chaptcr 4 of Appendix Asummarizes the conditions considered in the design of the depleted uranium waste placement and backfillprincipa l design feature and the relationship between the norma l, and abnorma l, and accident (asapplicab le) conditions evaluated to the principal design criter ia.Factors of safety associated with all of thc normal and abnomla l conditions evalu ated represent thc dcsigncriteria distortion of 0.02 ftlft divided by the calculated distortions. Overall , the average safety fac torassociated with the three norma l conditions and thc average safety factor associated with the fiveabnormal conditions were ascertained. The safety factor is grea ter than or equal to 1.00 under abnormalconditions.Based on the foregoing summary of information, this Report demonstrates EnergySolllfions ' compliancewith requirements of URCR R3l325-7(4) , as they pertain to thc dep letcd ura nium wastc cmplacementand backfill of the disposal embankment.Was te Emplacement and Backfill - Applicable Codes and StandardsRequirement: Descri ptions of codes and standards which EnergySollilions has app lied to the design, andwi ll apply to construction of the land disposal facilities. [URCR R31325-7(5)]Compliance Basis: The 2008 RML renewal provides a summary of the codes , standards, and guidelinesthat EncrgySollllions considercd and applied to the design. The primary standa rds considcred byEncrgySollllions in the design of the depleted uranium waste placement and backfi ll are those cod ified inURCR R3 I 3-25-24 and R313-25-25. EnergySollllions has also incorporated by reference minimumdesign criteria safety factors of 1.5 for static conditions and 1.2 fo r dynamic conditions from UtahStatu tes and Administrative Rules for Dam Safety, Rule R625- 11-6.The CQA/QC Manual provides specifications for constructing the Class A Disposal Embankments(inelud in g sections associated with the disposal of depleted urani um). The CQAlQC Manual alsoin el udes QC and QA procedures to be used during its construction.

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ENERGVSOLUTIONS

Based on (he foregoing summary of information, this Report demonstrates EncrgySolufions' compliancewith requirements of URCR R31325-7(5) , as they pertain to the waste emp lacement and backfi ll of thedisposal embankment.

Land Disposal Facility Co nstruction and OperationRequirement: The Licensee shall provide certain technical in fannat ion. The fo llowing infommtion isnceded to dctcnninc whether or not EnergySoilllions can meet the performance objectives and theapplicable technical requi rements of URCR R313-25: Descriptions of the co nstruction and operation ofthe land disposa l fac ility. The description shall include as a minimum the methods of construction ofdisposa l units; waste emplacement; the procedures for and areas of waste segregation; types of intruderbarriers; ons ite traffic and drainage systems; survey control program; methods and areas of waste storage;and methods to control surface water and ground water access to the wastes. The description shall alsoinclude a description of the methods to be employed in the hand ling and disposa l of wastes containingchclating agents or other non-radiological substances which might affect meeting the performanceobjecti ves of URCR R313-25. IURCR R3 13-25-7(6)]Compliance Basis: This Re port demonstrates Compliance wi th thc requirements ofUR CR R3 I 3-25-7(6)have been met. EnergySolutions' methods for constructing and operating the depleted uranium disposalembankment are those already approved as part of the 2008 RML renewal. Cons lTuction of the disposalunit wi ll involve a continuous cut , backfill, and cover conslTuetion. To ensure that the depleted uraniumdisposal embankment is built to design requirements, construction ac tivities wi ll be perfonned under aQAlQC program and conform to the requirements of the CQAlQC Manua l. The primary activitiesinvolved in construction of the disposal embankment (as target location for dep leted uranium) include:

Excavation.Preparation of the disposal area FoundationConstru ction of liner.Constru ction of run-on and runofTprotection.Waste emplacement and backfillConstru ction of Temporary Cover over completed portions of disposal embankmentsSettlement mon itoring to determine compliance with waste compaction / stabili ty requiremcnt s.May include su rcharging efforts to ensure embankment is stable for final cover,Construction of Final Cover, as per CQAlQC Manual requirement s, andConstru ction of permanent drainage ditches surrounding the disposa l unit(s).

Of par ticular interest is the placement of depleted uranium waste. Depleted uranium procedures for wasteemplacement arc the same as those already described in the 2008 RML renewa l. After the Liner has beenconstructed over a specific area of the disposal embankment, at least 12 inches of deb ri s-free soil will beplaced on top of the liner; fo llowed by another l 2-inches of waste as a protec tion to the in tegrity of theliner. Both of these laycrs of protective soil will be compacted with rubber tired equipment.



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The protec tion of inadvertent intruders from radiation exposures during facil ity operations focuses onpreven tion ofinadvcrlcnt intrusion. Depleted uranium opera tional areas will be surround ed by fencing asdescribed in EnergySollilions' CQAJQC Manual. Additional security features are presented in theEncrgySo/ulions' Site Radiological Security Plan. Several features of lhe fac ility design have the effectofp rolecting an inadvertent intruder from exposure to the disposed dep icted uranium materials and theeffects of radial ion. These features include:

Lack of nearby residential populationEmbankment cover system

Ons ile carth-roadways arc continuously changing to meet [he demands of current disposa l needs. As theheight of an act ive disposal cell increases, as the activity in a portion of the embankmcnt decreases, or asthe activity fo r a new portion of the embankment increases, access roads are constructed or removed tofac ilita te safe hauling and disposal of materials. Roadways a re const ru cted to ensure thar water properlydrains off from them, thus minimizing ponding or ponded road condi tion s. Haul roads to disposal unitsgenerally arc sloped at no greater than 3: I in accordance with safety guidelines.EnergySolUlions describes the onsitc drainage systcms in the 2008 RML renewal. EncrgySolulions hasdeveloped a bcrm system to direct watcr flow from precipitation, wintcr runo ff, away from the site andstored materials. It also has developed an embankment drainagc system surrou nding each emba nkment tohelp minimize any watcr accumulation. The drainage systems arc constructed of an erosion barricr rock ofthe same type used to cove r the embankments. The design of the berms is suffic ient to withstand theProbab le Maximum Flood (PMF) without ovcrtopping. The ditches wi ll have rriangular cross sectionswith side s lopes of I :5, and w ill have gentle longitudinal slopes, with depths g reat enough to carry thcrunoff from the lOa-year, I-hour storm event without exceed ing their bounds.

Surveys at the disposal si te wi ll be tied to both the United States Geological Survey (USGS) survey ofSection 32 T IS, R I I E and to the state plane coordinate system. EnergySolulions performs an annua l as-bui lt survey of each embankment which is accomplished by a Utah licensed land surveyo r. Surveycon trol is the responsibility of the li censed land surveyor, in accordance with Utah licensing standards.EnergySoilllions' plans for controlling the access of surface water to the depleted uranium wastes arethose already authorized as part of the 2008 RML renewal. The vert ical minimum separation between thebottom of the disposed depleted uran ium and the historic high water table is determined as being 13 feet.This va lue is based on: I) the groundwater contour map, and 2) the minimum depth from the base of theliner to the groundwater below the liner for the disposal embankment over the past fi ve years isapproximately 13 fee t.Based on the information summarized above, this Report documents EnergySolllfions' regulatorycompliance in its methods for emplacing the depleted uranium waste in the disposal embankment.

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C lass ification and Specification s

ENERGVSOLUTIONSRequirement: The application shall include certain technical information. The fo llowing information isneeded to determine whether or not EncrgySo/lltions can meet the performance objectives and theapplicable technical requi rements of URCR R313-25: Desc riptions ofl he kind, amount, class ification andspccificalions of the radioactive material expected to be received, possessed. and disposed of at the landdi sposal fac ility. lURCR R3 13- 25-7(9)JCompliance Basis: The infonnation contained in Chapter 9 of Appendix A demonstrate that therequirements of URCR R3 I 3-25-7(9) have been met. Appendix A a lso describes the types and volumesof depicted uranium waste 10 be receivcd for di spo sal, including thc phys ical, chcmical, and radiologicalproperties of the waste. All depleted uranium waste accepted for disposal w ill be at or below the Class Aconcentration limits. Radionuclidc release characteristics of the depleted uran ium waste may vary, butthe rad ionucl ide release rates in the perfonnance assessment are modeled in a conserva tive manner thatdocs not take credit for package or improved waste fomls.In summary, the waste information presented arc sufficiently complete and detailed to support thenecessary calculations and analyses to show that the facility wi ll meet the depleted uranium performanceobjectives and the applicable technical requirements of URCR 2.14 Technical AnalysisGenera l Populat ion ProtectionRequirement: The Licensee's specific technical infonnation sha ll include the following analyses neededto demonstrate that the performance objectives of URCR R3 13-25 will be me t: Analyses demonstratingthat the general population will be protected from releases of radioactivity shal l consider the pathways ofair, soil, ground water, surface water, plant uptake, and exhumat ion by burrowing animals. The analysessha ll clearly identify and differentiate between the roles perfo rmed by the natural disposal sitecharacteristics and des ign features in isolating and segregating the wastes. The analyses sha ll clearl ydemonstra te a reasonable assurance that the exposures to humans from the release of radioactivity wi ll notexceed the limits set forth in URCR 19 [URCR Compliance Basis: Thc infonnation containcd in Appcndix A and other relevant documentsEnergySolulions has submitted indicate that the requirements of R3 13-25-8( I) have been met. Each ofthe major media pathways of this requirement is addressed in the fo llow ing paragraphs. The principalsources of informa tion fo r the exposure assessment arc Sections 4, 6, and 9 of Appendix A. Originaleva luations contained in EnergySollllions' 2008 RML renewal demonstra te continued comp liance forexposures from no rmal opcrating conditions and accident scenarios.



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Air Pathway

ENERGVSOLUTIONSAnalysis conducted in support of the 2008 RM L renewal demonstrated that the transport of dust to thes ite boundary during operations (affected mainly by the natural site characteristics, in cl uding wind speed,wind direc tion, and atmospheric stability conditions) is well below regulatory limits. Similarly, thePcrfonnancc Assessment documented in Chapters 4, 6, and 9 of Appendix A projects potential releases ofdepleted ura nium through the air pathway have been assessed for the faci lity far below regulatory limits.As stated in the 2008 RML renewal, EncrgySolulions' engin ee ring and operational controls prevent theresllspcnsion and dispersion of particulate depicted urani um during operations. DOE is required to shipthe ir dep leted uranium in containers. Depleted uranium wi ll not be dumped in bulk, but rather disposedin its shipping conta iner, in CLSM. Water spray is used in the eell s as need to prevent resuspension ofradioac ti vity.Haul roads arc also wetted and maintained to prevent the resuspension and d ispersion of particulatedepleted ura nium. Polymers are spread on inactive, open areas to bin d the surface and preventresuspension. Ene rgySo/lIlions also perfonns routine air monitoring to identify if an airborne situation isdevclopin g that may require corrective actions.Aft er final placement of the depleted uranium waste and closure of the disposal embankment. the fac ili tydesign prevents any further migration of radioactivity through the air pathway because all waste will bebeneath a thick earthen cover. Analysis presented in Chapter 6 of Appendix A demonstrates that themaximum dose to a member of the public following sitc closure and institutional control is far belowapplicable regulatory limits.During opera tions, radon releases arc projected to be negligible because of low Ran6 parent wasteconcentrations and the cover design includes a clay radon barrier designed to limit the surface radon fl uxto less than 20 pCi/m2-s , resulting in potential radon exposures we ll within li mits. The design is based onthe disposal of uranium mi ll tailings, which are initially higher in Ra m than the depleted uran ium (whichrequire time periods exceeding the 10,OOO-year regulatory limit to in-grow due to uranium chain decay).For accident conditions, depicted uranium dust or particulate ma tter could be released to the atmosphereand in haled by individuals. The 2008 RML renewal and the analysis doc umented in Chapter 6 ofAppendix A evaluate to rn ado and severe winds, train derailment, truck turnover or co lli sion, and truckfi re. All analyses show that the maximum dose to a member of the public is less than 25 mrem/yr, evcn ifthe indiv id ual is continually present at the disposal site boundary.Soil PathwayAs summarized in Chapter 6 of Appendix A, the soi l pathway involves the exposure of the pub lic tocontaminated dcplcted uranium from the facility. Ifa n exposure occurred, doses could result fromexternal radiation or ingestion of soil on dirty hands. The primary site characte ri stic that prevents thelikelihood of such exposures during operations and institutional control is the site's remote location (the



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ENERGVSOLUTIONS

low population density in the site vicinity, and the lack of natural resources to provide for populationexpansion). Therefore, this pathway was not considered.The des ign of the disposal embankment also contributes to minimiz ing exposures to contaminated soi l bymembers of the public. After closure of the embankment, all depleted uranium waS le will be covered inthe disposal cells. The cover system contains a surface layer of rip rap 10 prolect against erosion andhuman in trusion. Be neath the riprap, the cover system contains a dra inage layer and a clay radon barrier.During operation, the facility will be monitored as described in the 2008 RML renewal andEnvironmental Mon itoring Program, to ensure that no releases or doses have occurrcd via the soilpathway.Groundwater PathwayAs is dcscribed in Cha pters 4 and 6 of Appcndix A, the groundwaler pathway is assessed using EPA' sHydrologic Evalua tion of Landfill Pc rfo nnanee (HELP) mo del and Go ldSim. The primary sitecharacteristics that prevent public cxposures via the groundwater pathway arc the very poor groundwatcrquality at the si te, the low population density, and the relatively slow groundwate r flow velocities. Thcgroundwater is not potable because of its very high concentration of dissolved salts. Thi s characteristicalone prevents any appreciable consumption of the water by humans or livestock. The horizontalgroundwater flow ve loc ity is approximately 0.5 meters per ycar, resulting in groundwater travel times ofapprox imately 60 years from the toe of the side slope region of the embankment to the compliance wcll.Several embankment des ign features provide additional protection of the public from exposure todepleted uranium via the groundwater pathway. The cover system to be placed over thc disposal wasteallows very little water to flow into the disposed waste. This lim its the contamination of the groundwaterby minimiz ing the contact of water with the depleted uranium waste. Another design feature of thedisposal embankment is the bottom clay liner bclow the disposed depleted uranium waste. The clayabsorbs many of the radionucl ides and slows their potential release from the ce ll and subsequent transportto the wa ter ta ble aquife r.Thc infi lt ra tion model for the embankment cover uscs calculations with EPA' s Hyd rologic Evaluation ofLa ndfill Performance (HELP) model (Schrocder et al ., 1994) as a gu ide to defining the vertical and lateralflow ratcs in the individuallaycrs of the cover, as a func tion of limc. Additionally, annual watcr balancesfor the di sposal embankment have been computed with the HELP mode l. By using HELP as input toGo ldSim , EnergySolulions demonstrates that the infiltration and radionucl id e transport mode ls show thatany depletcd uranium waste disposed will satisfy al l of the gro undwalcr pro(ec tion criteria, provided thatthe concentrations ofTc99 arc limited to the concentrations used in the transpo rt modeling. A ll otherradionucl ide concentra tions arc limited only by what is necessary for the waste to quali fy as Class A.This groundwater model ing provides a conservative estimate for the groundwater exposure scenario.

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ENERGVSOLUTIONS

Radionuclidc transport wa s modeled with the GoldSim model assuming a 4 mrcm/ycar groundwaterprotect ion leve l. The mode l calculated the release and transport of depicted uranium radionucl ides fromthe waS le cell , through the unsaturated zone, and horizontally through the shallow unconfined aquifer to acomp liance-moni toring we ll located 90 feet from the edge of the disposal faci lity. The groundwatermodeling included many conservative assumptions that helped to ensure that the radionucl ideconcentrations at the compliance monitoring well were not undcrcstimalcd. For example, the distancefrom the bottom of the waste to the aquifer was decreased from its actual value by 1.3 feet toconserva tively account for the effects of the capillary fri nge at the water table and to account forvariations in the water table level. No delay factors for waste container life were used to delay the onset ofradionucl ide releases from depl eted uranium waste under side slopes. The tra nsport modeling shows that,for most depleted uran ium radionuclides at the Class A limits , groundwater protection levels are met for500 years after disposal of the waste. Groundwater protection levels are met for a ll rad ionuclides presentin the depleted uranium wastes.Surface Water Pat hwayDue mainly to the natural site eharactcristics, thcre are no radioactive relcases expccted through thesurface water pathway from non-intruder scenarios. Thc annual prec ipitation is low and the cvaporationis high . No permanent surface water bodies exist in the site vicinity. In addition, the site is far frompopula ted areas. The disposal embankment design features also minimize the potential for releases by thesurface water pathway. Embankment design includes dra inage ditches around the waste disposa l areas.Aft er precipitation events, these ditches divert runoff from the disposal ce ll cover to areas away from thedisposal cells.VegetationVegetation models developed for the depleted uranium disposa l evaluate the redistribution of soils, andcontaminants within the soil, by native flora and fauna. The biOl ic models are consistcnt with observedflora and fauna on and ncar the Clivc facility, with flora and fauna characteristic ofGreat Basin alkali flatand Gr

rml condition 35 compliance report

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