DRC-2024-007200

Octoberxx, 2024
Vern C. Rogers, Director of Regulatory Affairs
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
RE:Request for Clarification and Extension for Responseto the Request for Information (RFI) - East Side Rotary Facility SumpConstruction Apparent Violation
Radioactive Material License UT 2300249
Ground Water Quality Discharge Permit No. UGW450005
Dear Mr. Rogers:
On October 11, 2024 EnergySolutionsrequested via DRC-2024-007164 (CD-2024-214),an extension to the response request timeline requested from the Division of Waste Management and Radiation
Control (Division) concerning the East Side Rotary Facility (ESRF) Apparent Violation. EnergySolutions requested an additional 30 days to respond to the Director of the Division (Director)
to “… provide detailed responses and complete an extensive root cause investigation”. The letter also requested that EnergySolutions be allowed to deviate from their internal procedure
ES-AD-PR-012, Cause Analysis, because 1) multiple recent requests from the Director to conduct root cause analyses and 2) ES-AD-PR-012 demands significant time and effort from aselect
group of certified personnel.
After reviewing the request to deviate from internal procedure ES-AD-PR-012 for a Root Cause Analysis the Director does not support or confirm EnergySolutions’ approach for the following
reasons:
One purpose of a root cause analysis is to provide insight into how similar apparent violations like this can be prevented in the future after careful scrutinization from certified personnel.
No documentation, work plan, or outline was submitted with the request to demonstrate how EnergySolutions intended to deviate from the procedure.
This RFI is associated with an Apparent Violation and consequently has the potential for further compliance actions. It is therefore concerning to the Director that the letter states,
“EnergySolutions requests that the Directorconfirm that the required evaluations can be conducted under the direction of CliveFacility management, rather than following the stringent
requirements of ES-AD-PR-012.”
The Director has determined to provide a one-time extension of 30 days for these RFIs, with the responses to be provided no later than November 15, 2024 but does not agree to the deterioration
of the procedure.
If you have any questions, please contact Brandon Davisat385-622-1873.
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