DRC-2024-004659

February 22, 2024
Mr. Jonathan C. Anderson
Environmental Compliance Manager
EnergySolutions, LLC
299 South Main Street, Ste 1700
Salt Lake City, UT 84111
RE:Response to Proposed Modification of Best Available Technology (BAT) Contingency Plan (Appendix K), SRS Depleted Uranium (DU) Storage Building
Ground Water Quality Discharge Permit (Permit) UGW450005
Dear Mr. Anderson:
In a letter dated November 3, 2023, EnergySolutions submitted a request to modify the BAT Contingency Plan of the Permit for the SRS DU Storage Building (DU Building) via CD-2023-224.
This proposal requested that the compliance point for water identified inside of the DU Building be changed from “presence of water on the asphalt surface” to “water in contact with
waste containers” as outlined in the Redline Strikeout Version of Form 1a of Appendix K which was submitted via CD-2023-196 “East Side Rotary Facility As Built Addendum”. The request
continues that repairs have been made to theroof and that since that time, no water from leakage has contacted the stored DU drums.
The request to modify the BAT Contingency Plan, Appendix K of the Permit is hereby denied for the following reasons:
The leaking roof at the DU Building continues to leak directly onto the stored DU drums. While EnergySolutions has placed a plastic barrier over DU drums to minimize contact with water,
it is neither a long-term nor approved solution. Since January 1, 2024,nine separate notifications of BAT Failure due to water in the DU Building and on the DU drums have been provided
to the Division of Waste Management and Radiation Control (Division) for the following days:
January 8, February 2, February 6, February 7, February 8, February 9, February 15, February 20, February 22
The DU drums continue to degrade as evidencedby the failure of a DU drum observed by Divisioninspectors on December 12, 2023 as outlined in DRC-2024-004029.The design and purpose of
the DU Building, according to Appendix J 4.19 of the Permit, is to protect SRS DU waste from the elements which includes precipitation.
In the future, the DU drums will need to be relocated either into an approved waste cell or returned to Savannah River Site and must be in good condition to be transported safely. Additional
humidity retained in the DU Building from a leaking roof does not preserve the integrity of the DU drums.
Asphalt is a porous material and is not intended to be an infiltration barrier. As DU drums continue to degrade and fail, the requested changes to Appendix K give no assurances that
infiltration will not occur.
Given the frequency of the continued BAT Failures, the Division is requesting that EnergySolutions provide an engineered solution to the leaking DU Building roof. Please respond to this
response within 30 days of receipt of letter.
If you have any questions, please call Brandon Davis at 385-622-1783.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/BBD/[???]
c:Jeff Coombs, Health Officer, Tooele County Health Department
Bryan Slade, Environmental Health Director, Tooele County Health Department
EnergySolutions General Correspondence Email
LLRW General Correspondence Email