DRC-2024-004571

February 21, 2024
Mr. Jonathan C. Anderson
Environmental Compliance Manager
EnergySolutions, LLC
299 South Main Street, Ste 1700
Salt Lake City, UT 84111
RE:RFI for the 1995/1997 Evaporation Pond Lift Station Backflow Valve Failure
Ground Water Quality Discharge Permit (Permit) UGW450005
Dear Mr. Anderson:
In a letter dated February 6, 2024 (CD-2024-021) and February 8, 2024 (CD-2024-024) EnergySolutions provide the five and the seven-day notifications required for a spill of approximately
1,000 gallons of contact water that occurred on February 2, 2024,at the 1995/1997 Evaporation Pond Lift Station (Lift Station). This Best Available Technology (BAT) Failure occurred
because of a failed backflow valve above the Lift Station. Some uncertainty regarding the exact location, cause, and timing of the spill was communicated to Division of Waste Management
and Radiation Control (Division). To remove this uncertainty Division and EnergySolutions staffinspected the spill locationon February 9, 2024. From conversation with staff onsite and
verification of pump capacity and volume collected from the pump truck used to remove the contact water from the site, it isreasonable that the release lasted less than five minutes.

The Division is concerned about this release for multiple reasons. For clarity throughout this process references to Permit, rules, or guidance have been included below.
EnergySolutions did not submit a 24-hour notification of the BAT Failure as required by the Permit Part I.G.4.(b). Notification is required for BAT Failures regardless of any additional
notifications that may be triggered.
CD-2024-024 states that the reason for the failure was, “Due to heavy rainfall that day…”. How did EnergySolutions determine that the cause for the failure was excessive precipitation
and how much precipitation occurred leading up to the BAT Failure?
Please provide Condition Report#CR-2024-0068 and provide details, where applicable, as to how the tracking of actions will prevent recurrence.
Thefailure of the backflow value did not trigger the alarm system designed to alert EnergySolutions’ staff of a BAT Failure at the Lift Station.To ensure that potential future BAT failures
will be collected in the sump and not discharged to the ground surface,please update the design of the Lift Station and submit the plans for review.
Where was the contact-water sample collected? If collected out of the Vacuum truck, was the truck empty prior to collection of the spill and subsequent sample collection?
In letter CD-2024-024 EnergySolutions states that, “Results from the onsite gamma spectroscopic analysis of the solids detected minimal activitysimilar to those expected in the contaminated
Restricted area at Clive.” Please expand and substantiate this claim to include:
a narrative that supports the statement written by qualified technical staff, as per Condition 31 of the Radioactive Materials License UT 2300249 (License).
the rules or guidance used to make the determination of expected contamination in the Restricted Area at Clive.
In Part I.E.19 Management of Evaporation Ponds Waste Material of the Permit, the Permittee is required to dispose of all Waste Material generated during the operation of evaporation
ponds. Waste Material includes soil contaminated from spills or releases. How does EnergySolutions intend to address the contaminated soils?
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