DRC-2024-007164

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com

October 11, 2024 CD-2024-214 Mr. Doug Hansen, Director Division of Waste Management and Radiation Control P.O. Box 144880
Salt Lake City, UT 84114-4880 Subject: Radioactive Materials License UT 2300249; Groundwater Quality Discharge Permit UGW450005: Request for Clarification and Extension for Response to the Request for Information – East Side Rotary Facility Sump Construction Apparent Violation Dear Mr. Hansen:
EnergySolutions respectfully requests a 30-day extension to respond to the Director of the Division of Waste Management and Radiation Control regarding the self-identified non-
compliance with Condition 33 of Radioactive Material License UT2300249 and Parts I.E.3 and IV.A of Groundwater Quality Discharge Permit UGW450005.1,2 The planning, development, and construction of the East Side Rotary Facility have been ongoing since 2020. To ensure a comprehensive and accurate administrative record, EnergySolutions aims to provide detailed responses and complete an extensive root cause investigation by
November 15, 2024.
Recently, EnergySolutions received several independent requests from the Director, including directives to conduct Root Cause Analyses to determine reasonable descriptions of the root causes of potential non-compliance issues, corrective actions taken to address these issues, and measures to prevent future occurrences.
EnergySolutions’ Procedure ES-AD-PR-012, Cause Analysis, outlines rigorous requirements, training, and certifications for the Root Cause Analysis Team, including their approach, report format, and content. Assembling a qualified Root Cause Analysis Team in accordance with ES-AD-PR-012 demands significant time and effort from a select group of certified personnel.

1 Hansen, D.J. “East Side Rotary Facility Request for Information – Apparent Violation Radioactive Material License UT 2300249 Ground Water Quality Discharge Permit No. UGW450005” (DRC-2024-
00006705) Letter from the Division of Waste Management and Radiation Control to Vern C. Rogers of EnergySolutions. September 16, 2024.
2 Anderson, Jon. “Groundwater Quality Discharge Permit (GWQDP) Number UGW450005 and Radioactive Material License UT 2300249: Response to East Side Rotary Project Enforcement Concerns” (CD-2022-082). Letter from EnergySolutions to Mr. Doug Hansen of the Division of Waste Management and Radiation Control. April 25, 2022.
Mr. Doug Hansen CD-2024-214 October 11, 2024 Page 2 of 2

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com
While not strictly adhering to ES-AD-PR-012, the management at EnergySolutions’ Clive Facility possesses extensive experience in evaluating potential non-compliances, identifying causes, implementing corrective actions, and preventing recurrence. This
approach is less reliant on certified staff, allows for a more expedited schedule, and is
less burdensome on facility operations. EnergySolutions requests that the Director confirm that the required evaluations can be conducted under the direction of Clive Facility management, rather than following the stringent requirements of ES-AD-PR-012.
We appreciate the opportunity to respond to the Director’s request for corrected
information. If you have any questions regarding this request, please feel free to contact me at [phone].
Sincerely,
Vern C. Rogers Director of Regulatory Affairs

Vern C.
Rogers
Digitally signed by Vern C. Rogers DN: cn=Vern C. Rogers, o=EnergySolutions,
ou=Waste Management Division,
email=[e-mail], c=US Date: 2024.10.11 13:00:22 -06'00'