DRC-2024-007117

EnergySolutions 2024 Waste Handling Facilities Inspection
Groundwater Module 1 Inspection
BAT requirements of the Ground Water Quality Discharge Permit, No. UGW 450005
INSPECTION REPORT FOR:
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
[phone]
DATE (S) OF INSPECTION:
September 17, 2024
FACILITY ADDRESS:
EnergySolutions LLC
Clive Disposal Site
Interstate 80, Exit 49
Clive, UT 84029
The EnergySolutions LLC’s (EnergySolutions) Clive Site is located in Tooele County, Utah, approximately 2.5 miles south of Interstate 80, Exit 49;75 miles west of Salt Lake City; and
55 miles east of Wendover, Utah. The site occupies all of Section 32 and parts of Sections 29 and 33 of Township 1 South, Range 11 West Salt Lake Base and Meridian (SLBM), and part of
Sections 5, Township 2 South, and Range 11 West SLBM.
FACILITY CONTACT:
David Booth
Clive Site Administration Manager
[phone]
APPLICABLE REQUIREMENTS:The State of Utah has issued two Radioactive Material Licenses, UT2300249 and UT2300478, to EnergySolutions’ for its Clive Site. Additionally, because EnergySolutions’
Clive Site has been determined to have the potential to contaminate groundwater, requirements of Utah Administrative Rules for Water Quality are applied. Provisions and requirements
for groundwater quality protection are found in UAC R317-6, Utah Administrative Rules for Ground Water Quality Protection. The EnergySolutions’ Clive Site has been issued a State of
Utah Ground Water Quality Discharge Permit, No. UGW450005. Waste handling facilities are subject to the requirements of thePermit for the Clive site. Specific regulations for waste handling
facilities are found in Parts I.E.10.a, b, d, e, and f; I.E.20; I.E.21; I.F.2; I.F.16; I.F.25; I.F.26; I.I.20; I.I.21; I.H.12; I.H.16; I.H.17; I.H.19; I.H.20; and II.E.Appendix J, Best
Available Technology (BAT) Performance Monitoring Plan, and Appendix K, BAT Contingency Plan, of the Permitalso apply to this inspection.
TYPE OF INSPECTION:
Waste Handling Facilities support operations at the Clive site. Waste Handling facilities
generally do not use water in their operations but are subjected to stormwater falling within
Section 32 and are a potential source of contaminated water that could reach groundwater.
EnergySolutions has developed and follows a monitoring, inspection, and maintenance plan for
all facilities that have a potential of discharging water. The Division establishes EnergySolutions
compliance and conformance with BAT requirements of the Permit with a two-fold approach: (i)
an annual site inspection of the Waste Handling Facilities, and (ii) a random record review of
EnergySolutions BAT inspection reports for those facilities to verify facilities are maintained and
operated according to their BAT performance standards.
PARTICIPANTS:
Bailey Anderson
LLRW Section, Utah Division of Waste Management and Radiation Control
Charles Bishop, P.G, Hydrogeologist,
LLRW Section, Utah Division of Waste Management and Radiation Control
Roger Ekins
EnergySolutions Disposal Supervisor
WEATHER CONDITIONS:
On September 17, 2024, temperature 54.28°F at 10:23 AM, wind 9.93 mph out of the northwest; overcast skies with scattered thunderstorms, wet conditions.
FACILITY DESCRIPTION:
EnergySolutions is a Utah-based company that owns and operates a commercial Class A low level radioactive waste (LLRW), 11e.(2) byproduct (uranium mill tailings), and a mixed radioactive
and hazardous (Mixed) waste disposal site near Clive, Tooele County, Utah. EnergySolutions (formerly Envirocare of Utah, Inc.) began waste disposal operation at the Clive Site in 1988
on Section 32, Township 1 South, Range 11 West, SLBM. Presently, waste treatment and disposal occurs in Section 32 (approximately one square mile, less the DOE Vitro property), with
handling, rail operations, cleaning, maintenance, and administration also taking place in the rest of Section 32 and in parts of Section 29. Clay mining occurs in Section 29 and Section
5, Township 2 South, Range 11 West, SLBM. The whole operation covers about two square miles. There are three active above-ground engineered disposal embankments: the Class A West, Mixed,
and 11e.(2) waste embankments. There are two closed embankments: the LARW embankment (closed in 2006 by EnergySolutions), and the US Department of Energy's Vitro mill tailings embankment
(closed in 1988 by the US Department of Energy). Currently, the facility has about 100 employees and operates a single ten-hour shift, four days a week.
Figure 1.Plan view and general layout of the Clive disposal site, showing the locations of the
Waste Handling facilities discussed in this report.
CREDENTIALS, PURPOSE AND SCOPE: Waste Handling Facilitiessupport operations at the Clive site and are a potential source of contaminated water that could reach groundwater, deteriorating
groundwater quality in the vicinity of the Clive site. To minimize the potential of groundwater contamination at Waste Handling facilities the Permit specifies that BAT be used in all
facilities design, construction, and operations, and that facilities operated under Best Management Practices to control the release of possible contaminated water. The Division establishes

EnergySolutions compliance and conformance with BAT requirements of the Permit with a two-fold approach: (i) an annual site inspection of the Waste Handling Facilities, and (ii) a random
record review of EnergySolutions BAT inspection reports for those facilities to verify facilities are maintained and operated according to their BAT performance standards.
EnergySolutions has developed and follows a monitoring, inspection, and maintenance plan for all facilities that have a potential of discharging water (see Appendix J, BAT Performance
Monitoring Plan, of the Permit) that provides facility descriptions, frequency of inspections, and performance criteria. If a BAT failure is identified during an inspection at any facility,
a contingency plan, specified in the Permit for each facility (see Appendix K, BAT Contingency Plan) furnishes EnergySolutions with requirements for maintaining, or attaining compliance
with the Permit. The Division confirms EnergySolutions compliance and conformance with BAT requirements of the Permit with this inspection and random record review of EnergySolutions’
BAT inspection reports for the Waste Handling facilities.MANAGEMENT ACTIVITIES:
The following management activities at each facility performed to maintain compliance are summarized below.
Containerized Waste Storage Pad
The Containerized Waste Storage Pad is in the east-central restricted area (Figure 1). No
water is utilized at the Containerized Waste Storage Pad, but the facility is uncovered and
storm water has the potential to contact waste on the pad. The pad is constructed for storage of
waste containers; bulk waste storage is not allowed. Containers collectively act as a primary
containment system for waste, and the asphalt pad acts as a secondary containment system. The
facility has a catch basin/sump with a pump in it to pump storm water to the Pond Lift Station.
EnergySolutions operates this facility to ensure: the exposed asphalt pad surface is relatively free
from dirt and debris; drainage is maintained to the sediment basin/sump station and water level in the sediment basin is below the grate; the sump pump is operationalso that accumulated
storm water is not maintained in the sump area of the sediment basin formore than 72 hours; the integrity of the asphalt is maintained; and that containers stored are characterized by
properlabeling, aisle spacing, and lid seals. Normally, the Containerized Waste Storage Pad undergoes weekly inspections and dailyinspections when storm water is present.
Intermodal Unloading Facility
The Intermodal Unloading Facility (IUF) is an open facility located in the east-central restricted
area, between Rail Track nos. 3 and 4 (Figure 1). No water is utilized at the Intermodal
Unloading Facility, but storm water has the potential to contact waste. The facility is designed
for the unloading (emptying) of intermodals from the concrete container compliance pads (upper
pads) onto the lower concrete-bay floors, and the loading of bulk waste materials on the lower
floor into trucks. The facility has a sump with a pump in it to pump storm water to the IUF lift
Station, which sends the storm water to the Pond Lift Station. EnergySolutions operates thisfacility to ensure concrete surfaces are relatively free from dirt and debris and drain to
thecollection basin/sump located on the west side of the facility, the collection basin/sump waterlevel is maintained below its grate, the sump pump is operational, and containercompliance
pads and other concrete surfaces retain their integrity. The Intermodal Unloading Facility undergoes dailyinspections, additional daily inspections when storm water is present, weekly
inspections, and anannual inspectiontoensure the integrity of its concrete surfaces.
Rail Digging Facility
The Rail Digging Facility is an open facility located in the north-east part of the restricted area,
between Rail Track nos. 3 and 4, along the Rail Digging Track (Figure 1). No water is
utilized at the Rail Digging facility, but storm water could contact waste when the facility is
operating and therefore indirectly affect groundwater. Operations at the facility allow for the digging of bulkwaste from rail cars and its placement into trucks. The facility is managed
during operations tominimize waste contacting the asphalt pad; waste storage is not allowed at this facility. At the Rail Digging Facility there are three concrete catch basins within
the asphalt surface of the pad that drains to asedimentation basin before draining to the Storm Water Lift Station of the East Side DrainageSystem. EnergySolutions manages this facility
to ensure: the asphalt surface is relatively cleanfrom dirt and debris and drains freely to each of the three concrete catch basins; water levels in each catch basins are below its outlet
pipe; and the integrity of the asphalt pad surface, concretecatch basin, and concrete settling basin. The Rail Digging Facility undergoes daily inspections,additional daily inspections
when storm water is present, and weekly inspections.
East Truck Unloading Area
The East Truck Unloading Area is an open facility located in the east-central restricted area, east
of Rail Track no. 4 (Figure 1). No water is utilized at the East Truck Unloading Area, but
storm water can contact waste and potentially affect groundwater. This facility is designed for
the unloading of containers from semi-trucks and includes concrete container holding pads, an
unloading dock with ramp, and an unloading area with an asphalt surface. The asphalt surface of
the unloading area and dock is not a BAT compliance area, and no storage of waste is allowed on
that surface; waste may temporarily/briefly placed on the asphalt surface during operations.
EnergySolutions manages this facility to ensure:surfaces are relatively free of dirt and debris; holding pads drain to either one of two storm watercollection troughs and water levels
in the troughs do notexceed a ¾-full mark (if exceeds, must be pumped out anddisposed of in an evaporation pond); integrity of concrete surfaces are maintained; andcontainers stored
at the facility are goodcondition, properly labeled, aisle spacing maintained, and lids sealed.
Waste incontainers can be stored on the holding pads, but not on the asphalt surface. The East TruckUnloading Area undergoes daily inspections when storm water is present and otherwise
weeklyinspections.
Shredder Facility
The Shredder facility is an open facility located in the north-central restricted area (Figure 1)
and is used for the shredding of large bulk materials. The shredder facility utilizes a limited
amount of water for cooling and dust control in its operations, but this water is usually consumed
in the shredding process; however, the facility is susceptible to storm water contacting waste.
Seven catch basins are located within the shredder pad that drains to a manhole (Manhole 1) to
remove storm water from the pad. The manhole drains to the Rotary Dump facility unless there

is PCBs waste on the pad. If the facility is handling PCB waste, or PBC waste is on the concrete
pad, then water drains from the catch basins to the manhole, where it is removed/pumped, using
a submersible pump, to specially marked water storage tanks located on the Shredder facility
concrete pad. Water from the storage tanks is eventually disposed at the Mixed Waste operations.
EnergySolutions operates this facility to ensure: drainage to catch basins/manhole, water levels are below catch basin grates, the pipeline from the manhole to the waterstorage tanks
is functional (no pipe leakage, etc.), concrete pad integrity, and proper measures are being taken if PCB waste is stored on the infeed pad (facility labeled for PCB waste, wastewatervalve
to the Rotary Dump in closed position, and wastewater valve to water storage tanks in theopen position). The Shredder facility undergoes daily inspections, daily inspectionswhen storm
water is present, weekly inspections, and an annual inspection to ensure its concrete integrity.
Rotary Dump Facility
The Rotary Dump facility is an enclosed facility located in the north-west section of the
restricted area (Figure 1). The Rotary Dump facility is both a waste handling facility and a wash
facility and uses water in its daily operations, mostly for the cleaning of railcars. The Rotary
Dump facility is also inspected as a wash facility as part of the GWQDP Module 4 inspection. The facilityis designed for the thawing of bulk waste in railcars, emptying (unloading)
of bulk waste fromrail cars, and washing of railcars. The facility produces waste water from the thawing process,from cannons used to clean out railcars in the dumping process, and from
rail car washing. Thefacility includes concrete floors in each of its three component buildings (thaw, rotary, and wash)that drain to a sediment basin in the rotary building floor where
a sump pump pumps wastewaterfrom the sediment basin to the Northwest Corner Pond through dual walled pipe.EnergySolutions manages this facility to ensure: all surfaces are relatively
free from dirt and debris; all water on the concrete floors freely drains to the sediment basin in the lower dump floor; thesediment basin water level is below its grate; no fluids are
found within the pipeline leakdetection system extending from the from the Rotary Building to the Northwest CornerEvaporation Pond; and concrete surfaces retain their integrity in all
buildings. The Rotary Dump Facility undergoes daily inspections,weekly inspections, monthly inspections, and an annual inspectionensure the integrity of its concrete.
SRS DU Storage Building
The SRS DU Storage Building is an enclosed building located in the north-eastern restricted area
(Figure 1). The SRS DU Storage Building is not a waste handling facility but is a waste
storage building. No water is utilized at the SRS DU Storage Building, but storm water entering
the building has the potential to contact waste. The facility is specifically for the temporary
storage of SRS DU waste in drums pending a decision regarding the acceptability or not of SRS
DU for disposal. In December of 2009 EnergySolutions received 5,408 drums of DU from the
U.S. Department of Energy’s Savannah River Site. In 2011 the SRS DU Storage Building was
designed and built to shelter SRS DU waste from the weather. The SRS DU Storage Building is
included in the waste handling facility inspection because it has BAT requirements that are
similar to the waste handling facilities. Once a decision is made regarding the acceptability or not
of SRS DU for disposal, the DU will be removed from this building. The SRS DU building is a
steel building set on a concrete foundation with an asphalt floor. The DU drums act as a primary
containment system for waste, and the asphalt floor acts as a secondary containment system. The
SRS DU building undergoes daily inspections when storm water is present, and otherwise a monthlyinspection. EnergySolutions manages this facility to ensure the integrity of the containers
and floor,and for the presence of storm water. The SRS DU building is not used to support any other wastemanagement operations at the Clive Site.
NARRATIVE:
This narrative summarizes the results of an inspection of the EnergySolutions’ Waste Handling Facilities, including the LLRW Containerized Waste Storage Pad, LARW Intermodal Unloading
Facility, Rail Digging Facility, East Truck Unloading Area, Shredder Facility, Rotary Dump Facility, and SRS DU Storage Building, on September 17, 2024. Inspection of the Waste Handling
Facilities was conducted by Division Staff Bailey Anderson and Charles Bishop; inspection findings were recorded via the GW Module 1 inspection form (Attachment 1) and are summarized
below (Conclusions).
After arriving at the Clive Site, Division staff had an opening meeting with EnergySolutions’ Clive General Manager, David Booth. The inspectors explained what inspection was being
done, the applicable Permit conditions, and what would be involved in the inspection. To confirm EnergySolutions’ BAT inspections had been occurring regularly, David Booth was informed
that staff would request BAT records dated August 1, 2024 through August 15, 2024, (chosen prior to the inspection). The inspection team then departed to the LLRW Operation building,
where they met up with EnergySolutions’ Disposal Supervisor, Roger Ekins, who escorted Division Staff for the duration of the inspection.
Upon the conclusion of the field inspection, Division staff met with David Booth to preform the closeout meeting and discuss the findings of the field inspection. Additionally, the requested
BAT records were collected from Curtis Kirk, Quality Assurance Manager at this time. The requested records contained all daily and weeklyinspections that took place from August 1 to
August 15, 2024.
RECORDS INSPECTION:
The requested BAT records provided a summary of the daily conditions at EnergySolutions Waste Handling Facilities for each day that operations were being performed. For much of 2024,
few, if any, operations were performed on Wednesdays, as most of the EnergySolutions staff were then working four ten-hour shifts, which took place on Monday, Tuesday, Thursday, and
Friday. Also, few, if any, operations were performed on weekends as these are traditionally non-work days.Additionally, the Second Semi-Annual Best Available Technology (BAT) Monitoring
Report for July 1 to December 31, 2023 (DRC-2024-004808) and the Semi-Annual Best Available Technology (BAT) Monitoring Report for January 1 to June 30, 2024(DRC-2024-006693) were also
reviewed.
Review of these records indicate the Waste Water Evaporation Ponds are generally operated in accordance with the BAT Performance Monitoring Plan (Appendix J of the Permit). A review
of EnergySolutions’daily and weekly BAT inspections at the Waste Handling Facilitiesindicated no problems were reportedfrom August 1 to August 15, 2024, and no issues that the Division
was not already aware of since the last Waste Handling Inspection on November 2, 2023. For all documented incidents since the last inspection, EnergySolutions provided the necessary
maintenance and notifications to the Division within the 24-hour and 7-day timeframes as required by the Permit.This records review indicate Waste Handling Facilities are for the most
part being maintained and operated in accordance with BAT requirements of the Permit.
CONCLUSIONS:
A short summary including field observations and any relative results of the records inspections for each waste handling facility are provided below in the order the facilities were

inspected:
Containerized Waste Storage Pad
The Containerized Waste Storage Pad is currently out of service, as noted in EnergySolutions’ BAT inspection reports from August 1 to August 15, 2024.The facility was taken out of service
on January 17, 2013, with notification provided byEnergySolutions to the Division of Radiation Control on January 18, 2013. During theSeptember 17, 2024inspection, no waste containers,
excessive dirt, or debris were present on the storage pad. There were no areas of concern identified during the inspection. Records provided by EnergySolutions indicate theContainerized
Waste Storage Pad was out of service and no waste handling activities occurred since the last inspection on November 2, 2023; no BAT concerns were reported during that time.
Intermodal Unloading Area
The south half of the IUF was placed out of service on June 3, 2024, in preparation for the 2024 annual inspection of the Intermodal Unloading Facility (GWQDP Module 9). At that time,
cracks were observed in the concrete on the southwest wall of the south bay. On June 25, 2024 EnergySolutionssubmitted a request for an extension to complete the annual inspection, the
Division partially approved this request on July 10, 2024. The annual inspection of the north bay of the IUF was completed on July 26, 2024, in accordance with this approval, however,
the south bay remains out of service until further repairs to the southwest wall can be made.
Currently, EnergySolutions is requiredto complete construction of the south bay of the IUF by December 30, 2024. At the time of the inspection onSeptember 17, 2024,intermodal containers
were located on thelower floor of the IUF.The area was designated an active rad area with signage, “Caution Radioactivity” posted around the facility. Division inspectors looked at exposed
concrete surfaces and checked for cracks or breaks, drains from the upper level to the concrete-bay floors were clear, and there were free draining conditions across the concrete bay
floors to the sump. All concrete surfaces appeared to be in good condition, and it appears that the sump pump was operational, as the water level in the sump was observed to bebelow
the grate.No issues were recorded in theEnergySolutionsBAT inspection reports from August 1 to August 15, 2024. Except for correspondence regarding the southwest wall of the south bay,
no BAT problemswere reported concerning the Intermodal Unloading facility since the last inspection on November 2, 2024.
Rail Digging Facility
No rail digging operations have taken place for at least 19 years at the rail digging facility. On October 2, 2023 Energy/solutions requested that the Rail Digging facility be put back
into service, however, no rail digging operations have occurred since being put back into service on October 11, 2023. Examination of the facility showed the integrity of the asphalt
surface remained in good condition and appeared to be free draining to catch basins; the pad was relatively free of dirt and debris. The water levels in all catch basins, and the sedimentation
basin were below the outlet pipes, as required. No BAT concerns were reported at the Rail Digging Facility in the period for which daily and weekly BAT records were requested, or since
the last inspection on November 2, 2024.
East Truck Unloading Area
During the inspection of the East Truck Unloading Areaall surfaces were relativity clean;the integrity of the concrete surfaces of the holding pads, including the trough, curbing, and
unloading dock appeared generally to be in good condition; drainage appeared to be maintained towards the stormwater collection troughs on the west side of the facility, and the water
level in both troughs were below¾-full mark.There were containers on the concrete container holding pads during the inspection that appeared to be spaced correctly and non-leaking, and
in overall good condition. No issues were identified in theEnergySolutions BAT inspection records for the East Truck Unloading Area from August 1 to August 15, 2024, or since the last
inspection on November 2, 2024. SRS DU Storage BuildingOn September 17, 2024, aisles between the drums of theSRS DU Storage Building were walked to inspect the exposed asphalt floor,
integrity of the DU container, to look for water within the building, and to verify that only SRS DU was stored in the building. No damage to the floor of the SRS DU Storage Building
was identified; container storage appeared to meet requirements, and it was verified that only SRS DU waste was stored in the building. However, at the time of the inspection, the Clive
site was experiencing a precipitation event, and standing water was observed on tarps covering several drums in the northwest corner of the DU Building. The precipitation event on September
17, triggered an inspection of the SRS DU Building by EnergySolutions staff on September 18, and the Division received the required 24-hr BAT notification for this incident on September
19 and 7-day written notification on September 23, 2024. Since the last inspection on November 2, 2024, the Division has received multiple notifications regarding issues with the presence
of water in the SRS DU Building after storm events due to leaks in the roof of the facility. This an ongoing issue that the Division and EnergySolutions staff have continued to address.
In a letter dated September 3, 2024EnergySolutionsoutlined their most recent plans to address the SRS DU Building leaking roof. This includes a more robust repair, in which a membrane
will be installed over the entire roof of the building; this work is scheduled to be completed by the end of October, 2024.Shredder FacilityExamination of the facility showed the asphalt
surface of the pad was generally good condition, relatively free of dirt and debris,and appeared to be free draining to each catch basin. The water levels in all catch basins were below
the inverts to the outlet pipes, as required. No problems were identified at the Shredder Facility for the time BAT records were requested, and a review of BAT notifications for theShredder
facility indicated there had been no problems since the last inspection on November 2, 2024.
Rotary Dump Facility
Waste operations were taking place at the Rotary Dump facility at the time of the inspection on September 17, 2024. Due to the nature of the waste being handled, inspectors were not
able to examine the integrity of the asphalt surface on the rotary dump floor or check the leak detection annulus at this time. However, operations at the Rotary Dump Facility were visible
from the observation deck. As waste was actively being worked,mud and debris covered the lower floor of the rotary dump.As water levels in the sediment basin were observed to be below
the grate covering the sump pump, inspectors were able to conclude that the surface of the rotary dump floor was free draining, and the sump pump was operational.No issues were reported
in the EnergySolutions’ BAT inspection records for the Rotary Dump facilityfromAugust 1, 2021to August 15. Since the last inspection on November 2, 2024, the Division received one notification
regarding a BAT problem at the Rotary Dump Facility on February 20, 2024, summarized in Table 1 below.
Table 1. Summary of BAT discrepancies and resolutions at the Rotary Dump Facility since the last inspection on November 2, 2024.
Date Observed
Occurrence
Findings/Solution
Date Addressed,
Notification Provided?
02/20/2024 -02/21/2024
Water above grate in sediment basin
Maintenance replaced a cracked float preventing the sump pump’s auto mode from operating correctly
02/22/2024 - 02/23/2024, Y
COMPLIANCE STATUS:
The Waste Handling facilities were found to be in general compliance with the BAT requirements of the Permit during the field inspectionand the record review also indicated compliance.
The Division will continue to monitor ongoing maintenance and efforts to achieve compliance at the south bay of the IUF and SRS DU Buildings in the forthcoming months.

ISSUES:
There are no outstanding compliance issues as a result of GWQDP Module 1 inspection on September 17, 2024.
SIGNATURE:
Prepared By:
_____________________________________________10/10/2024_________
Bailey Anderson, Hydrogeologist, Date
LLRW Section
Utah Division of Waste Management and Radiation Control
Reviewed and Approval By:
________________________________________________________
Lawrence Kellum, Program Manager Date
LLRW Section
Utah Division of Waste Management and Radiation Control
Attachment 1 to Narrative
2024 Division Inspection Form