DRC-2024-004819

~
. c' Naste Management
-r.d Rad:ation Control
l~AR O 7 2024
--------ENERGYSOLUTIONS ===============
March 7, 2024
Mr. Doug Hansen, Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880
CD-2024-046
Re: Response to the Request for Information (RFI) to the East Side Rotary Facility
As-Build Report Radioactive Material License (RML) UT 2300249
Dear Mr. Hansen:
EnergySolutions hereby responds to a Request for information received from the Director
of Waste Management and Radiation Control related to the new East Side Rotary Facility
(ESRF).1 The Director 's request includes a compilation of outstand legacy requests that
still require resolution by EnergySolutions for the Director 's consideration to approve the
East Side Rotary Facility (ESRF). Below are EnergySolutions' responses to the
Director's legacy requests.
LEGACY REQUEST FROM CD-2023-091 (DRC-2023-003771}
1. The narrative and record of the engineering as built is incomplete and needs
to be updated to include:
a. The three dry wells that were installed without Division
review/knowledge or plans being submitted for approval. The result of
dry well infill and removal/mediation from the plan set. Please update the
narrative to reflect the important distinction between an approved plan
to close the sumps while the construction of the sumps themselves were
not approved for construction.
Three Storm Water Drain Boxes (Dry Wells) were designed by Millcreek
Engineering under the direction of Energy Solutions in January 2022 to be located
around the northeastern, northwestern, and southwestern outside perimeter of the
ESRF at the low point of the side slopes around the entrance and exit ramps to the
facility . The original purpose of the Dry Wells was to capture precipitation for
storm water management. These wells were shown in earlier stamped revisions of
Engineer Drawing 1959-C310. These earlier drawings were not submitted to the
Director nor approved for construction by the same. Moreover, the construction
1 Hansen , D.J. "Request for Information (RFI) for the East Side Rotary Facility As-Built Report
Radioactive Material License (RML) UT 2300249" (DRC -2024-004291) Letter from the Division of
Waste Management and Radiation Control to Vern Rogers ofEnergySolutions, February 12 , 2024.
299 South Main Street, Suite 1700 • Salt Lake City , Utah 8411 1
(80 1) 649-2000 • Fax : [phone] • www .energysolutions .co m
~
ENERGY SOLUTIONS Mr. Doug Hansen
March 7, 2024
CD-2023-046
Page 2 of 10
of the Dry Wells in March/April 2022 was performed without the Director 's
knowledge nor review.
The environmental issues that quickly followed construction of the Dry Wells and
resultant Sump Closure Work Plan (Plan) submittal, Director 's Plan approval , and
Plan execution are detailed in Section 4.0 and Attachment B of the East Side
Rotary Facility As-Built Report submitted to the Director on April 25 , 2023 (CD-
2023-091 ).
Following completion of the Plan. The desired abandonment results were
achieved in that the Dry Wells were removed per the approved Plan protecting the
groundwater. Subsurface investigation work began to define the extents and work
with Energy Solutions and the Director on a path forward to address the spill, and
the ESRF contractor was allowed to proceed forward with facility construction.
The subsurface fuel investigation is ongoing as a separate project under the
direction of the Director
b. Please address the steel structure collapse during construction and the
steps taken to determine that the corrective actions ensure that the
building meets construction and safety standards.
Building collapse . On September 6 , 2022 , the southern (wash) steel building red
iron structure collapsed during steel erection due to the premature removal of
temporary steel member bracing by an erection subcontractor causing damage to
the steel and the concrete anchor attachments of that building. There was some
minor damage to other concrete and steel surfaces.
The Contractor Wollam , EnergySolutions , Millcreek Engineering, Heyl &
Patterson , and Building Inspectors from Thorton Tomasetti , inspected the facility
for damage and to provide recommendations on cleanup and the path forward.
Cleanup followed for the next several weeks in September 2022. Wollam
provided a detailed path forward , approved by Millcreek and EnergySolutions,
with enhanced safety recommendations for building erection in conjunction with
Millcreek 's analysis of the concrete anchoring areas and surfaces, and Heyl &
Patterson 's review and recommendations for a portion of the Dumper contacted
by some of the fallen steel. All plans and recommendations were followed , and
the new building erection and concrete anchor work began in late September
2022. Work was closely followed by Wollam , Millcreek , Heyl & Patterson , and
EnergySolutions to ensure that the erection and anchoring process was correctly
and safely followed. The minor damage to the concrete floor was also repaired.
The Tooele County Development department was informed of the collapse and
inspected and approved the repairs-ultimately issuing an Occupancy Permit.
~
ENERGY SOLUTIONS Mr. Doug Han sen
March 7, 2024
CD-2023-046
Page 3 of 10
2. Placing the new facility into service will require expansion of the Licensed
Restricted Area boundary fence line beyond the East Side Rotary footprint.
a. Please provide clarification for the request to modify the Restricted
Area Boundary and include a standalone, updated drawing of this
proposed expansion in the Licensed Restricted Area for review
including section lines, property lines, and all relevant data for
review.
The ESRF was constructed within the situs of the previous
(Envirocare/EnergySo/utions) Rollover, demolished well over a decade ago. Both
the previous Rollover and the new ESRF are sited well within the approved
current Restricted Area boundary that has been approved for decades by the
regulating agencies .
During construction of the ESRF, the construction area was temporarily released
for outside access to assist most of the construction activities . Following this
construction, the Restricted Area Gate 94 was closed and secured and the entire
ESRF facility was brought into the approved Restricted Area .
The licensed Restricted Area for the ESRF should not require expansion as the
fenced boundary has not changed . Included is a copy of the stamped project
drawings from the original 2018 submittal , Engineering Drawings l 8004-L03(0)
and new stamped Engineering Drawing l 8004-L04(0) are included to show the
restricted area boundary status before and after construction .
LEGACY REQUEST FROM CD-2022-029 {DRC-2022-001741}
1. Request 6 states:
"Provide justification that there is sufficient water capacity in the existing East
Side Drainage System and pond to accommodate the East Side Rotary Facility
and all existing management needs.
Response: The existing 1995 and 1997 ponds do not have sufficient capacity to
efficiently manage water from both the current facilities and the ESRD.
EnergySolutions will be submitting a design for a new 8. 7 million gallon "East
Evaporation Pond" that will replace the 1995 Pond, which will provide an
additional 7.4 million gallons beyond the current capacity (~1.3 million gallons)
of the 1995 Pond. The new pond is schedule[d]for construction in 2023
(pending Director approval to construct)."
a. According to EnergySolutions' letter dated May 15, 2023, (CD-2023-106,
DRC-2023-004371) the request to construct an East Evaporation Pond
~
ENERGY SOLUTIONS Mr. Doug Hansen
March 7, 2024
CD-2023-046
Page 4 of 10
was rescinded. How will Energy Solutions ensure that capacity will be
met?
Regarding Request 6 : EnergySolutions is currently preparing the plans for
construction of a new East Side Evaporation Pond to be sited south of the Truck
Dock for construction outside of the Radioactive Material Area (RMA).
EnergySolutions will present the plans to the Director for approval with the intent
to construct in 2024. In the interim water from the ESRF will drain from
Manhole MH-IA within the facility to Manhole 1 and then to the 1997
Evaporation Pond where it can be managed through evaporation , transfer to the
1995 Pond, or trucked to other Energy Solutions Ponds in accordance with current
Contingency Plan(s).
2. The proximity of the waste handling that will occur near the Elevated Water
Tank on the North Side of the Restricted Area is a concern for the Division,
as standing water within the Restricted Area has been observed year-round
originating from the Elevated Water Tank. Please provide a plan that will
rectify this infiltration point pathway or provide updated drawings that
move the Elevated Water Tank to a different location.
ESRF waste handling near the Elevated Water Tank (Tank): Energy Solutions
recognizes the Director 's concern with standing water in this area and the
potential for an infiltration point pathway. As shown on Engineering Drawing
18004-Overview (in response to question 2 of CD-2023-091 above), the ESRF
operational plan is that haul trucks entering the northern ramp of the building will
be empty and that loaded trucks will exit the facility from the southern ramp
enroute to disposal.
In addition, rec ycled asphalt has been added to the haul routes for both the
northern and southern haul routes to improve the driving surface area as well as
add additional protection to subsurface soils and to improve the ability to pump
standing water with the pump truck. Energy Solutions is working on a solution to
the Tank that will include improvements including replacement of the Tank and
elevating the area under the Tank .
~
ENERGY SOLUTIONS
LEGACY REQUEST FROM CD-2023-196 {DRC-2023-074200)
1. In statement 3, EnergySolutions states:
Mr. Doug Hansen
March 7, 2024
CD-2023-046
Page 5 of 10
"Energy Solutions agrees to monitor the effectiveness of the clay-lined gabion
baskets via groundwater sample well(s). EnergySo/utions will coordinate well
installation with the Director regarding other unrelated investigations.
EnergySolutions acknowledges that the Director's permit modification is
prerequisite to placing the new East Side Rotary Facility into service ... "
a. Wells associated with investigations such as the Petroleum Hydrocarbon
investigation may require a well network that extends beyond the scope
of the ESRF. For the ESRF to go into service, a well-monitoring network
specifically designed for this facility must be proposed by
EnergySolutions. For guidance on the requirements, please reference the
Ground Water Quality Discharge Permit, Appendix B: Water
Monitoring Quality Assurance Plan and Utah Admin. Code R317-6-6.3
where additional information may be required.
The groundwater well monitoring plan for the ESRF is included as Exhibit 1.
2. 4.0 Alarm Testing at Manhole MH-lA Leak Detection System
a. Please provide the pressure testing methodology used to ensure pipe
integrity and resulting data collected as Division staff was not present for
this process.
Alarm Testing at Manhole MH-lALeak Detection System: Although the
Contractor successfully pressure tested the dual wall drain line (Line 4B) from
MH-lA to Manhole 1 during construction, EnergySolutions will perform an
independent pressure test in accordance with the methodology used for testing the
pipelines of the East Side Drainage area . Line 4B will be thereafter tested with
the testing of the annual East Side Drainage System.
The testing follows the process of blind flange fitting with air valve(s) and
pressure gage(s), pressurizing to 4-5 pounds per square inch (psi), holding
pressure for a minimum of 4 hours, and observing the pressure at the end of the
testing period to see if pressure dropped within the 1 psi allowance. Testing will
also include observing the working of the moisture probe . The Director will be
extended an invitation to observe this initial testing and the annual testing.
~
ENERGY SOLUTIONS
3. Attachment H Sealing ofRail/R.ailSeal at Facility Entrances
Mr. Dou g Hansen
March 7, 20 24
CD-202 3-046
Page 6 of 10
a. The sealing of the vertical joints at the ESRF entrances may solve some of
the potential for contact water to leave the facility and move into the
subsurface. Additionally, the following variables need to be addressed to
provide assurances to the Division:
Attachment H Sealing of Rail/RailSeal at Facility Entrances (Section 6.0
of the Addendum):
i. What steps will be taken to prevent contact water run-off from exiting
the facility at the gap caused from the rail line itself? This cannot be
sealed with Aquascape Pond and Waterfall Foam Sealant as it would
preclude the rail line from functioning as intended. Given the intended
design life of this facility, the Division is concerned about the long-term
potential for contamination to the groundwater through this pathway.
The proposed Best Available Technology (BAT) inspections of the Rail/Rail Seal
interface of the ESRF includes ;
a . that Energy Solutions proposes to inspect the integrity of the RailSeal at the
northern and southern rail entrances weekly (i .e . Appendix J , page 32)
b. a procedure if a discrepancy in the integrity of the RailSeal is noted (i .e.
Appendix K , page 46); and
c. a procedure if a discrepancy in integrity of concrete , including ramp curbing ,
is noted (i .e . Appendix K , page 47).
Moreover, decontamination operations will be instructed to be focused inwards
and away from the entrances and towards the floor drains located along the rails .
ii. What process will be put into place to ensure that the Aquascape Pond
and Waterfall Foam Sealant will continue to function as intended once
the facility is in operation as it will not be readily accessible for a visual
inspection?
The integrity of the Rail Seal will be inspected in accordance with the proposed
BAT Sections cited above , namely Appendix J , page 32 , and the procedure for
discrepancy of Appendix K , page 46.
Moreover, the RailSeal is readily visible for BAT inspection as shown in the
Figures 1 and 2.
~
ENERGY SOLUTIONS
Figure 1 -Southern Rail Entrance to the ESRF
Figure 2 -Northern Rail Entrance to the ESRF
Mr. Doug Hansen
March 7, 2024
CD-2023-046
Page 7 of 10
~
ENERGY SOLUTIONS Mr. Dou g Hansen
March 7, 2024
CD-202 3-046
Page 8 of 10
4. Redline Strikeout BAT Recommendations provided by EnergySolutions
a. The recommendations for non-substantive changes such as
grammatical errors, etc. are appreciated; however, the review of the
requested changes to the GWQDP have only been reviewed as they
relate directly to the ESRF. No additional changes will be considered
and must be submitted under a separate request for consideration
from the Director.
b. Once the RFis above have been satisfied, a Redline Strikeout Version
of the GWQDP with relevant appendices will be provided to
Energy Solutions.
c. As a reminder, no request for PCB wastes to be handled at the ESRF
has been received. Therefore, no consideration can be given to any
requests to handle PCB waste at the ESRF at this time.
EnergySolutions concurs with the Director 's comments.
5. Please provide the expected facility life of the ESRF.
Millcreek Engineering has designed and constructed the ESRF for a usable
lifecycle of at least 30 years with proper maintenance and usage .
6. Technical Basis Document ESRF Environmental Monitoring Plan (EMP)
Analysis
a. The submitted ESRF Environmental Monitoring Plan Analysis is too
limited in scope and lacking in technical analysis to be considered a
viable document that supports the proposal of no additional
environmental monitoring be added because of the addition of the
ESRF.
b. The Division does not agree with the statement purported by
EnergySolutions that" ... no new, or unanalyzed condition is created
by operating the East Side Rotary Facility," in part because the
construction of a new waste-handling facility designed explicitly to
handle bulk-radioactive waste creates an unanalyzed condition.
c. As part of the analysis, Energy Solutions states that " ... the northern
perimeter fence-line is within EnergySo/utions Owner-Controlled
Property (secured by a 6-foot fence and 24-hour security) and not
easily accessible to the public." This claim does not have merit when
considering dose at the fence line. According to §10CFR20.1301(2)(b)
and Utah Adm in. Code R313-15-301(2), "If the licensee or registrant
permits members of the public to have access to controlled areas, the
~
ENERGY SOLUTIONS Mr. Doug Hansen
March 7, 2024
CD-2023-046
Page 9 of 10
limits for members of the public continue to apply to those
individuals." To maintain compliance with NRC and State
regulations, the Northern Fence line of the Restricted Area should be
the reference point as it is the closest boundary.
d. The licensee cited NUREG/CR-3332 as guidance that was utilized
during the airborne particulate sample locations. However, this
guidance is not listed in the currently approved Environmental
Monitoring Plan associated with RML UT 2300249. If this is an
oversite, please provide the specific citations within the currently
approved EMP that utilizes NUREG/CR-3332.
i. Please include the atmosphere transport modelling used in
previously approved EMPs to include the in-service load of the
ESRF and provide input and output values.
EnergySolutions includes as Exhibit 2, analysis that demonstrates that the
positions of the current Environmental Monitoring Stations located around the
Restricted Area perimeter are adequate to measure dust loading generated by in-
service ESRP operations. During routine ESRF operations , low-level radioactive
waste arriving in railcars will be removed and dumped into the ESRF subgrade
waste pit where it will be transferred to haul trucks for disposal in the Class A
West embankment. Dust will be generated during railcar dumping and haul truck
loading. Specifically , the Director has required EnergySolutions examine the
potential environmental impacts of ESRF operations at the " ... the Northern Fence
lin e of the Restricted Area should be the reference point as it is the closest
boundary," in accordance with § l 0CFR20. l 30 I (2)(b) and Utah Administrative
Code R313-15-301(2).
Exhibit 2 confirms that Environmental Monitoring Station A-18, currently located
north of the ESRF , will intercept 99. 7% of the dust that would be observed at a
new Station positioned immediately north of the ESRF. Similarly , existing
Environmental Monitoring Station S-19, located northeast of the ESRF , will
intercept 330% more ESRF-generated dust than would be observed at a new
Station positioned immediately east of the ESRF (due to the higher frequency of
wind in that general direction). Concentrations measured by additional
Environmental Monitoring Station located further east and north of the Restricted
Area Fence would only intercept 24% -25% of the atmospheric dust
concentrations observed by current Environmental Monitoring Stations .
~
ENERGY SOLUTIONS Mr. Doug Hansen
March 7, 2024
CD-2023-046
Page 10 of 10
Therefore , the positions of the current Environmental Monitoring Stations located
around the Restricted Area perimeter are adequate to conservatively measure dust
generated by in-service ESRP operations. No additional perimeter Environmental
Monitoring Stations are necessary to observe any dust transported from a point of
generation in the ESRF waste pit.
Please contact me at [phone] with any questions regarding these responses.
Sincerely ,
J th C Digitally signed by Ona an • JonathanC.Anderso n
Anderson Date: 2024.03 .07
10:59:39 -07'00'
Jon Anderson
Environmental Compliance Manager
cc : Charles Bishop (DWMRC)
Brandon Davis (DWMRC)
Bailey Anderson (DWMRC)
enclosures
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry
of th e person or persons who manage th e system, or those persons directly responsible for gathering the information, the information
submitted is, to the best ofmy knowledge and belief, true, accurate, and complete . I am aware that there are significant penalties for
submitting false information, including the possibility of fine and imprisonment for knowing violations.