DRC-2024-004029 2023 BAT Accompaniment Inspection RFI

January 12, 2024
Jonathan Anderson
Environmental Compliance Program Manager
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
RE: Follow-Up Request for Information (RFI) to the 2023 BAT Field Inspection Module 7c: Ground Water Quality Discharge Permit Number (GWQDP) UGW450005
Dear Mr. Anderson:
On December 12, 2023,representatives of Utah Department of Environmental Quality, Division of Waste Management and Radiation Control (hereinafter, Division) conducted an inspection of
daily, weekly, monthly, and stormwater Best Available Technologies (BAT) activities at the Clive site in Tooele County, Utah.The inspection examined BAT activities conducted at the site
as they relate to compliance with the Ground Water Quality Discharge Permit and consisted of selective observations by inspectors, personnel interviews, and a review of representative
records.
As a result of the inspection, the Division requests more information be provided regarding the findings inspectors identified during the December 12, 2023, field accompaniment, as well
as the records review, which were obtained from EnergySolutions at the time of the field inspection. As the Division has determined it necessary that more information be provided, this
inspection module will remain open.
Following the December 12 inspection, in accordance with requirements of the BAT Contingency Plan identified in Appendix K of the GWQDP, EnergySolutions notified the Division of BAT
failures via e-mail on December 13, 2023, and provided the required 7-day written notification on December 19, 2023 (CD-2023-255, DRC-2023-078-698). In the December 19 correspondence,
four issues identified by the BAT inspector during the December 12 inspection and their respective corrective actions were listed; these included a non-functioning transducer on the
1995 Evaporation Pond, cracks in the floor of the Rail Wash Facility on Track No. 4, a punctured drum in the SRS DU Building, and the presence of ice on tarps covering drums inside the
SRS DU Building. While the issues identified during the inspection were comprehensive, the Division found the summary of corrective action taken to address these concerns unsatisfactory,
and requests that more information be provided.
Please see the examples of the BAT failure description and summary of corrective action listed below:
A non-functioning transducer on the 1995 Evaporation Pond, GWQDPUGW450005 Appendix K, 4.1.6 – The transducer for the 1995 Pond has been fixed.
When providing evidence of corrective action, please include as much information as possible to assist the Division in determining the extent of the BAT failure and the effectiveness
of corrective action taken. For example, in this instance, information helpful to the Division in addressing this concern would include how long the transducer was out of operation,
the date and time the transducer was repaired, how the transducer was repaired, how the dysfunctional transducer was accounted for in weekly leakage rates (how many gallons were pumped),
etc.
Cracks identified in the floor of the Rail Wash Facility on Track No. 4, potentiallya discrepancy in exposed pad integrity, GWQDP UGW450005 Appendix K,4.10.3. The building at the Rail
Wash Facility on Track No. 4 has been taken outof service until repairs are complete. Per GWQDP UGW450005 Appendix K,.10.3, if the repairs are expected to exceed the 10-working day limit,EnergySolutions
will provide a written just cause.
– Per the letter dated December 13, 2023 (DRC-2023-077910), this issue was determined to be within compliance. The cracks of concern found in the floor have been addressed.
Please provide photographs showing evidence that the cracks of concern are within compliance.
A drum with a small hole in the SRS DU Building was found, GWQDP UGW450005 Appendix K, 4.19.2. The small hole in the drum located in the SRSDU Building was temporarily patched the same
day and a permanent repair isplanned for December 14th, 2023 – The small hole found in the drum has been repaired to prevent any material from leaking out.
Again, when providing evidence of corrective action, it is appropriate to include as much detail as possible. In this example, information provided to the Division shouldinclude what
the temporary and permanent patches consisted of, whether or not the permanent repair planned for December 14, 2023, took place, and photos of both the temporary and permanent repairs
attached to the correspondence for thoroughness.
Ice was found on top of the drum lid, inside the SRS DU Building, GWQDPUGW450005 Appendix K, 4.19.3 – The ice found on the drums was on top of a protective cover, this cover prevents
water from coming in contact with the drum.
In a letter from EnergySolutions dated November 3, 2023 (CD-2023-224, DRC-2023-075570), EnergySolutions requested a modification of the BAT Contingency Plan (GWQDP Appendix K) for the
SRS Depleted Uranium (DU) Building; however, this proposed modification has not yet been reviewed by the Division. Therefore, the BAT requirements for the SRS Depleted Uranium Building
are still subject to the criteria currently listed in Part 1.E.27 of the GWQDP, and Part 4.19 of Appendices J and K of the GWQDP. These criteria include the requirement of the DU building
to prevent stormwater from contacting waste, and the removal of any stormwater observed. Please provide justification for how this corrective action meets these requirements.
The Division requests an updated and more detailed report of the BAT failures observed on the December 12 inspection and their respective corrective actions be submitted for review.
Additionally, in future correspondence, the Division asks that this level of detail and completeness is considered when providing notifications, reports of corrective actions, etc.
As part of the BAT Field Inspection Module 7c, inspection report records dated from October 30, 2023, to November 14, 2023, were provided by EnergySolutions to the Division for review.
Upon review of the BAT inspection records provided, it was noted in everydaily inspection report that holes were observed in the 1995, 1997, 2000 and NWC Evaporation Ponds. On December
14, 2023, the Division received written confirmation that all repairs to the 1995, 1997, 2000 and NWC Ponds had been completed on October 24 and 25,2023, (CD-2023-253, DRC-2023-078622).
Please provide a copy of the BAT failure notification provided to the Division following the identification of these new holes in the listed locations.
Additionally, it was noted by the BAT inspector on October 30, 2023, that the 1995 Evaporation Pond exceeded the initial action level of the allowable leak detection difference. The
Division requests EnergySolutions provide the7-day average pond flow rate records for this time period.
Again, as the Division requires more information to be provided, this inspection module will remain open. Please provide the requested information 30 days from the date of this letter.
If you have any questions, please call Brandon Davis at [phone].
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/BD/??
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