DRC-2024-006927

June 4, 2024
Jonathan Anderson
Environmental Compliance Program Manager
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
RE: 2023 BAT Field Accompaniment Inspection Module 7c Investigation Closeout Letter;Ground Water Quality Discharge Permit UGW450005.
Dear Mr. Anderson:
On December 12, 2023, a representative of Utah Department of Environmental Quality, Division of Waste Management and Radiation Control conducted an inspection of daily Best Available
Technologies (BAT) activities at your Clive facility in Tooele County, Utah.
The inspection was an examination of EnergySolutions' BAT inspector conducting LLRW/11e.(2) inspections of waste handling, wash, and waste water pond facilities against Permit requirements,
and a records review of EnergySolutions’ LLRW/11e.(2) inspected facilities with a potential to contaminate groundwater.
The following BAT concerns were observed and documented by Division inspectors and the Clive Site BAT Inspector during the December 12, 2023 BAT Field Accompaniment Inspection.
A non-functioning transducer on the 1995 Evaporation Pond (GWQDP Appendix K, 4.1.6)
Cracks identified in the floor of the Rail Wash Facility on Track No. 4 (GWQDP Appendix K, 4.10.3
A punctured drum in SRS DU Building (GWQDP Appendix K, 4.19.2)
Ice was found on top of the drum lid, inside the SRS DU Building (GWQDP Appendix K, 4.19.3)
In subsequent written notifications and responses from EnergySolutions following the inspection, the following corrective actions for each facility were taken.
The Clive BAT inspector notified the maintenance department regarding the suspected malfunctioning transducer the same day and the system was reset. After thereset, the process control
monitor displayed the correct value. This value wasrecorded on the LLRW/11e.(2) Daily Facility Inspection Form 1 for December12, 2024. There were no other issues with the leak detection
system.
Cracks in the floor of the Rail Wash Facility on Track No. 4 were repaired (Figure 8).
The Clive BAT inspector immediately notified her manager that a punctured drum in the SRS DU Building was found at the time of the inspection; after concluding the inspection inside
the SRS DU Building, a temporary patch was made using duct tape same day. The Environmental Compliance Manager later reported a caulking sealant was applied to the hole of the drum as
permanent repair later that day (Figure 9).
The ice was removed from the drum’s protective plastic, placed in a bucket andtransported to be placed into the 1997 Evaporation Pond. Water did not makecontact with the waste or drum.The
roofing contractor will be brought back on site to address roof leaks in the SRS DU Storage building in the spring. Winter weather may create ice on the roof causing a potential hazard
for working on the roof.
In addition to these concerns, Division staff recognized additional potential areas for discussion and improvement:
Completeness of Inspections – During the December 12, 2023 inspection, Division inspectors noted BAT inspections being conducted by Clive BAT inspectors were being completed as BAT inspectors
drove by/over facilities (inspectors drove past the East Truck Unloading Facility and over the Rail Digging Facility), and that BAT inspectors walked areas of facilities with BAT requirements
“at random” (randomly walked rows of SRS-DU Building). The Division requires Clive BAT inspectors to walk the entirety of BAT facilities to ensure the completeness of BAT inspections
and accuracy of facility conditions per Appendix J of the Permit.
Best Management Practices, Encountering Unknown Materials – the Division commends the awareness of the Clive BAT inspector in the discovery of a punctured drum in the SRS DU Building
during the December 12, 2023 inspection, and the consequent execution of protocol by the BAT inspector and site Health Physicist after exposure to powdered yellowcake that had accumulated
on the outer surface of the punctured drum. However, the Division recommends that staff are reminded of site procedures when encountering unknown materials and determining their source
to prevent any potential unnecessary exposure.
Best Management Practices, Disposal of PCB-Waste at the Rotary Dump Facility – While observing the BAT inspection at the Rotary Dump Facility on December 12, 2023, Division inspectors
noted the Clive BAT inspector drove through standing water on the dump floor containing PCB-waste and continued to drive through the site without performing any decontamination activities.
Best Management Practices while handling PCB-containing waste may require further discussion with EnergySolutions as it is potentially a site-wide concern. The Division recommends that
EnergySolutions update the internal procedure for PCB waste handling based on this observation.
Based on the findings identified during the inspection and items reviewed, the Clive facility was found to be in compliance with the BAT requirements of the Ground Water Quality Discharge
Permit.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/BMA/??
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