DRC-2024-006740

September 3, 2024Jon Anderson, Environmental Compliance ManagerEnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
RE:Groundwater Quality Discharge Permit Number UGW450005 (GWQDP) Intermodal Unloading Facility: Request for Approval to Modify Facility and Request for Approval of GWQDP Modification:
Second Round of Requests for Additional Information
DearMr. Anderson:
The Division of Waste Management and Radiation Control (Division) has reviewed your letter dated August 21, 2024 (CD-2024-172/DRC-2024- 006647) responding to the initial set of Requests
for Information (RFI) distributed by the Division via letter dated August 19, 2024 (DRC-2024-006544).Listed below, the Division responses to CD-2024-172/DRC-2024-006647 as well as follow-up
RFIs to be addressed to support these modifications. The numbering corresponds to the initial RFI creation in letter DRC-2024-006544:
The Division acknowledges the root cause of concrete degradation and declared primary function the modification will provide.The Division contacted representatives from EnergySolutions
to gather additional background of the design intent of the modification. It was confirmed that the modification will primarily, “[…] buttress the adjacent walls and provide additional
wear surface for waste handling heavy equipment operations for an expected three-to-five-year period”. Furthermore, EnergySolutions does not deem the wall to be in a state of failure
regarding structural integrity thus the additional reinforced concrete structure will not be subjected to additional external forces as a result of wall deformation/settlement during
the design life of the structure. Please confirm the Division’s understanding of the purpose of the modification so this RFI can be resolved and closed.
The response to this RFI is insufficient, however, the response to RFI #1 states, “[…] waste handling heavy equipment operations for an expected three-to-five-year period”. The assumed
use for this modification will be within the quoted three-to-five year period, therefore, the Division accepts this notion and this RFI is resolved and closed.
Utah Admin. Code R317-6-6.3 (C.) states, “The name of the facility and the type of facility, including the expected facility life.” are required for application for a Ground Water Discharge
Permit, therefore thismodification of the IUF requires this information to be provided. The Division seeks to understand EnergySolutions’ intent to use this modification which includes
acknowledging structural design aspects at a basic engineering level to review if the proposed structure is suitably designed for its intended use.This acknowledgment of performance
objectives for any structure to be constructed within the Clive Facility isfurther specified in UAC 313-25-8.
The Division does not agree with this response, however, the design ofthe reinforced concrete structure does not need to account for additional loading due to failure of the existing
wall according to the response to RFI #1. Since EnergySolutions does not assume that the existing wall is failing, and the primary function of this modification is to “buttress the adjacent
walls and provide additional wear surface for waste handling heavy equipment operations for an expected three-to-five-year period”, the Division no longer seeks supporting documentation
and calculations to justify the design of proposed reinforced concrete structure. Please confirm the Division’s understanding of this RFI response for the purpose of the modification
so this RFI can be resolved and closed.
The request for documentation to be signed and sealed by a registered Professional Engineer is to provide the Division confirmation that a licensed Professional Engineer has performed
the due diligence as stated in Utah Code § 58-22-201, Utah Code § 58-22-302, and UAC R156-22-601. The submittal from EnergySolutions’ (CD-2024-172/DRC-2024- 006647) did not include a
signed and sealed copy and the Division had no assurances that a Professional Engineer had reviewed the submitted drawings.The response to this RFI further states that “any enforcement
of penalties or consequences for design or technical errors in the certified construction package
falls under the jurisdiction of [Utah Division of Occupational and Professional Licensing]”. The Division does not seek to identify penalties due to misuse of licensure. The intent of
this RFI was to gather information for the Division’s understanding if the proposed modifications were reviewed by a registered Professional and is fully aware of the aforementioned
jurisdiction. Furthermore, any “design or technical errors” are not subjected to penalties from the Division rather evaluated forthe effectiveness of the modification on the performance
of discharge controls and containment systems employed at the IUF as they relate to License and Permit conditions for the Clive Site.
The response states “[…] proposes to enhance the adhesion between the existing IUF concrete structure and the new wall by using intertwined steel rebar that will weave through both the
new and existing concrete and be epoxy anchored into the existing concrete”. The Division is aware of the mechanical mechanisms utilizing reinforcement bars doweled between each of the
structures to adjoin the proposed reinforced concrete structure to the existing structure. Although the Division agrees with the general statement regarding doweled reinforcement, the
main concern within the RFI exists in constructability issues regarding new concrete bonding to existing concrete during the curing phase of the new concrete. It is common industry knowledge
(i.e. American Concrete Institute Specifications) that new concrete poured atop old concrete does not adequately bond due to innate poor adhesion characteristics of concrete, therefore
chemical bonding or other methods are deployed to aid bonding of the two structures. The proposed modifications do not showcase methods to prevent formation of voids between the interface
of the old concrete and new concrete due to poor concrete chemical adhesion. The response to this RFI is insufficient.Please provide a response to this RFI for the purpose of the modification,
so this RFI can be resolved and closed.
The response to RFI #4 states “[…] Additionally, water stop will be installed in accordance withmanufacturer’s recommendations near the leading horizontal and vertical seamsof the new
wall where the existing and new concrete structures meet consistentwith industry practices”. It was unclear to the Division that a waterstop was proposed to be installed for the vertical
seam of the new wall as well as the interface of the new concrete to the bounding east and west walls. Additionally, minimum dimensions are called out in 9705-2, however, the callout
requires additional clarification.Please revise drawings and provide a response to this RFI for clarification.
The Division acknowledges the response to RFI #6, therefore this RFI is resolved and closed.
The Division acknowledges the response to RFI #7, however, this RFI will remain open for discussion concerning construction of the modification. The Division’s primary concern is for
the potential of water to seep around an inadequately sealed drainpipe. EnergySolutions shall deploy their stated methodologies with the Division’s concerns in mind.
The Division acknowledges the response to RFI #8, however, this RFI will remain open for discussion concerning construction of the modification. Should EnergySolutions encounter an issue
due to interference during the dowelling process, EnergySolutions must develop a solution to patching and clearing debris of the drilling error.
The Division accepts the response to RFI #9, therefore this RFI is resolved and closed.
If you have any questions, please call Carlo Romano at 385-977-7573.
Sincerely,
Larry Kellum, Section Manager
Division of Waste Management and Radiation Control
LK/CR/wa
Enclosure(s):
c:Jeff Coombs, EHS, Health Officer, Tooele County Health DepartmentBryan Slade, Environmental Health Director, Tooele County Health DepartmentEnergySolutions General Correspondence EmailLLRW
General Correspondence Email