DRC-2024-007298

299 South Main Street, Suite 1700 Salt Lake City, Utah 84111
[phone] Fax: [phone] www.energysolutions.com
October 23, 2024 CD-2024-224
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: Responses to East Side Rotary Facility Outstanding
Issues
Dear Mr. Hansen:
EnergySolutions is providing this response to an electronic request for information from a
member of the Division of Waste Management and Radiation Control1 regarding
outstanding issues that need to be addressed before the new East Side Rotary Facility
(ESRF) at the Clive Facility can be commissioned. In 2022, EnergySolutions received
conditional approval from the Director to proceed with the construction of the new
ESRF.2 Access to the construction site was granted to the contractor on January 18, 2022,
and construction was completed in April 2023. Following the completion of construction,
As-Built engineering drawings were submitted to the Division on April 24, 2023 (CD-
2023-091) and October 11, 2023 (CD-2023-196).3,4 To ensure the ESRF is operational by
the target date of November 1, 2024, EnergySolutions is now addressing each of the four
specific unresolved issues raised by the Division.
Division’s First Issue: Gaps that exceed 1/8" around the rail line need to be sealed.
EnergySolutions’Response: As shown below, groundwater protection has been
improved by sealing rail line gaps greater than 1/8 inch in width with Sika
Construction Sealant. Further protection is ensured by the increased thickness of
1 Davis, B. “East Side Rotary Facility Outstanding Issues” Electronic message from the Division of Waste
Management and Radiation Control to Jonathan C. Anderson of EnergySolutions. October 8, 2024.
2 Rogers, V.C. “Utah Radioactive Material License UT2300249 and Groundwater Quality Discharge
Permit No. UGW450005; Request for Modification and Proposal to Construct an East Side Rotary
Facility” (CD-2021-045) Letter from EnergySolutions to Mr. Ty Howard of the Division of Waste
Management and Radiation Control. March 25, 2021.
3 Rogers, V.C. “Radioactive Material License UT 2300249; Condition 48.C - East Side Rotary Facility As-
Built Report” (CD-2023-091) Letter from EnergySolutions to Mr. Doug Hansen of the Division of Waste
Management and Radiation Control. April 24, 2023.
4 Rogers, V.C. “Radioactive Material License UT 2300249; Condition 48.C –East Side Rotary Facility As
Built Report Addendum” (CD-2023-196) Letter from EnergySolutions to Mr. Doug Hansen of the
Division of Waste Management and Radiation Control. October 10, 2023.
Mr. Doug Hansen
CD-2024-224
October 23, 2024
Page 2 of 5
299 South Main Street, Suite 1700 Salt Lake City, Utah 84111
[phone] Fax: [phone] www.energysolutions.com
the concrete beneath the rails and facility trench drains, which measures over 2
feet 3 inches, as detailed in Engineering Drawing 2115-S438(3).5
Figure 1 - Unsealed Rail Line Gaps
Figure 2 - Sealed Rail Line Gaps
5 Rogers, V.C. “Radioactive Material License UT 2300249; Condition 48.C - East Side Rotary Facility As-
Built Report” (CD-2023-091) Letter from EnergySolutions to Mr. Doug Hansen of the Division of Waste
Management and Radiation Control. April 24, 2023.
Mr. Doug Hansen
CD-2024-224
October 23, 2024
Page 3 of 5
299 South Main Street, Suite 1700 Salt Lake City, Utah 84111
[phone] Fax: [phone] www.energysolutions.com
Figure 3 - Sika Construction Sealant
Division’s Second Issue: Verification that the bolts that were drilled into the floor
surrounding the machinery on either side of the dumper mechanism (upper deck)
were sealed appropriately.
EnergySolutions’Response: As illustrated, the dumper guard’s bolted plates were
sealed with Kimball Midwest Kim-Bond Fast Cure Epoxy 80-1089 and then with
Sika Construction Sealant.
Figure 4 - Sealed Dumper Guard Bolted Plates
Mr. Doug Hansen
CD-2024-224
October 23, 2024
Page 4 of 5
299 South Main Street, Suite 1700 Salt Lake City, Utah 84111
[phone] Fax: [phone] www.energysolutions.com
Figure 5 - Kim-Bond Fast Cure 3 Minute Epoxy
Division’s Third Issue: Leak detection ports around the sump need to be accessible
and verification required.
EnergySolutions’Response: As depicted, the ESRF sump leak detection ports
have been sealed with six-inch lockable male and female caps, like those used on
other leak detection ports, such as those at the Intermodal Container Wash
Facility (ICWF) and West Rotary.
Figure 6 - Capped Sump Leak Detection Ports
Mr. Doug Hansen
CD-2024-224
October 23, 2024
Page 5 of 5
299 South Main Street, Suite 1700 Salt Lake City, Utah 84111
[phone] Fax: [phone] www.energysolutions.com
Division’s Fourth Issue: Provide documentation that the floor drains in the
auxiliary rooms are, in fact, operational and not capped.
EnergySolutions’Response: The floor drains were constructed using Smith
Manufacturer Co. Floor drains, as illustrated in the attached and in Engineering
Drawing 2115- S103(1).
6 The caps are part of the drain design and therefore do
not need to be removed.
EnergySolutions appreciates the Director’s efforts to bring the ESRF into service by
November 1, 2024. Please contact me at [phone] if you have questions regarding
this information.
Sincerely,
Vern C. Rogers
Director of Regulatory Affairs
enclosure
6 Rogers, V.C. “Radioactive Material License UT 2300249; Condition 48.C - East Side Rotary Facility As-
Built Report” (CD-2023-091) Letter from EnergySolutions to Mr. Doug Hansen of the Division of Waste
Management and Radiation Control. April 24, 2023.
299 South Main Street, Suite 1700 Salt Lake City, Utah 84111
[phone] Fax: [phone] www.energysolutions.com
EXHIBIT A
Floor Drain Specification
12” (305) Round Top Solid Free Standing Sediment Bucket
Jay R. Smith MFG. Co.