DRC-2024-007869

2024 BAT FieldAccompanimentInspection
Groundwater Module 7C Inspection
Ground Water Quality Discharge Permit, No. UGW 450005
INSPECTION REPORT FOR:
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
[phone]
DATE OF INSPECTION:
November 5, 2024
FACILITY ADDRESS:
EnergySolutions LLC
Clive Disposal Site
Interstate 80, Exit 49
Clive, UT 84029
The EnergySolutions LLC’s (EnergySolutions) Clive facility is located in Tooele County, Utah, approximately 2.5 miles south of Interstate 80, 75 miles west of Salt Lake City, and 55
miles east of Wendover, Utah. The facility occupies all of Section 32 and part of Section 29of Township 1 South, and Range 11 West Salt Lake Base and Meridian (SLBM), and part of Sections
5, Township 2 South, and Range 11 West SLBM.
FACILITY CONTACT:
Dave Booth
Clive Site Manager
[phone]
Roger Ekins
Clive Disposal Supervisor
[phone]
Curtis R. Kirk
Clive Quality Assurance Manager
[phone]
NOTIFICATION:
EnergySolutions was notified on October 30, 2024 that this field accompaniment inspection would occur on November 5, 2024. The notification was given to EnergySolutions so the Clive
BAT inspector would be available to conduct the inspection with Division of Waste Management and Radiation Control (Division) inspectors.
APPLICABLE REQUIREMENTS:
The Division has issued two Radioactive Material Licenses, UT2300249 and UT2300478, to transfer, receive, possess, and use radioactive materials pursuant to Section 19-3-104 of the Utah
Code Annotated 1953 and Administrative Rules for the control of ionizing radiation; a State-issued Part B Permit, operated under EPA ID Number UTD982598898, to treat, store, and dispose
of radioactive hazardous waste pursuant to Utah Solid and Hazardous Waste Act 26-14-1 et. seq., Utah Code Annotated 1953 and Utah Administrative Code R315 as authorized by the U.S. Environmental
Protection Agency under Section 3006 (b) of the Resource Conservation and Recovery Act; and a Ground Water Quality Discharge Permit, no. UGW450005 (hereinafter Permit) pursuant to the
Utah Water Quality Act, Title 19, Chapter 5, Utah Code Annotated 1953 as amended to EnergySolutions and the Clive Site. Provisions and requirements for groundwater quality protection
are found in UAC R317-6, Utah Administrative Code for Ground Water Quality Protection.
EnergySolutions operates and maintains Clive disposal facilities in accordance with Best Available Technology (BAT) and Best Management Practices (BMP) requirements of Part I.D.1 through
30, Part I.E.7 through 27, Part I.F.2, and the currently approved Appendix J (BAT Performance Monitoring Plan) of the Permit.
TYPE OF INSPECTION:
The Division establishes EnergySolutions compliance and conformance with BAT requirements of the Permit with a two-fold approach: (i) an on-site inspection to observe the EnergySolutions’
BAT technician completing inspections of LLRW/11e.(2) waste handling facilities, wash facilities, and wastewater ponds against Permit requirements, and (ii) a random record review of
EnergySolutions BAT inspection reports for those facilities to verify facilities are maintained and operated according to their BAT performance standards.
PARTICIPANTS:
Drew Ovard
EnergySolutions’ Clive BAT Technician, site escort
[phone]
Bailey Anderson
LLRW Section, Utah Division of Waste Management and Radiation Control
[phone]
WEATHER CONDITIONS:
On November 5, 2024, temperature 39.37°F at 10:00 AM, wind 17.79 mph out of the north; overcast skies and windy.
SITE DESCRIPTION:
EnergySolutions is a Utah-based company that owns and operates a commercial Class A low level radioactive waste (LLRW), 11e.(2) byproduct (uranium mill tailings), and a mixed radioactive
and hazardous (Mixed) waste disposal site near Clive, Tooele County, Utah. EnergySolutions (formerly Envirocare of Utah, Inc.) began waste disposal operation at the Clive Site in 1988
on Section 32, Township 1 South, Range 11 West, SLBM. Presently, waste treatment and disposal occurs in Section 32 (approximately one square mile, less the DOE Vitro property), with
handling, rail operations, cleaning, maintenance, and administration also taking place in the rest of Section 32 and in parts of Section 29. Clay mining occurs in Section 29 and Section
5, Township 2 South, Range 11 West, SLBM. The whole operation covers about two square miles. There are three active above-ground engineered disposal embankments: the Class A West, Mixed,
and 11e.(2) waste embankments. There are two closed embankments: the LARW embankment (closed in 2006 by EnergySolutions), and the US Department of Energy's Vitro mill tailings embankment

(closed in 1988 by the US Department of Energy). Currently, the facility has about 100 employees and operates a single ten-hour shift, four days a week.
The locations of Facilities with LLRW/11e.(2) BAT inspection requirements at the Clive Site are identified in Figure 1.
Figure 1. EnergySolutions’ Clive facilities with LLRW/11e.(2) BAT inspections.
CREDENTIALS, PURPOSE, AND SCOPE:
EnergySolutions conducts inspections at waste handling, washing, and wastewater pond facilities to ensure facilities are operated according to BAT and Best Management Practice requirements
in the Permit. The possible incidence of groundwater contamination and the resulting obligation for cleanup has influenced the design, operation, and monitoring of facilities at the
Clive Site.This inspection gives the Division an opportunity to determine how EnergySolutions implements BAT requirements, to verify facilities at Clive are operated according to performance
standards, assess if improvement/clarification of BAT inspections could be made, and evaluate the ability of their BAT inspectors to ensure compliance with Permit requirements.
MANAGEMENT ACTIVITIES:
Compliance withPermit performance standards are evaluated by performing and documenting equipment maintenance, and inspections. BAT inspections at each facility diminish the potential
risks to groundwater related to facility operations; each facility with LLRW/11e.(2) BAT requirements are summarized below.
LLRW Operations Building:This building is a controlled entrance and exit from the restricted area and provides services for site personnel. No waste-handling operations occur, waste
is not stored, and the water volumes used at the facility are very small. Drainage of the bootwash station, restricted area floors, and the collection tank leak detection and water
levelalarms are checked daily.The functionality of the alarms are checked annually.
East Side Drainage System:The East Side Drainage System is a drainage system for wastewater from wash facilitiesand stormwater from catch basins on the east side of the facility. Water
is transferred in both systems via a dual walled pipe (containment pipe surrounding a carrier pipe) to the 1997 Pond. Leak detection sensors and drip legs, in addition to sight canisters,
are installed in each containment pipe at manholes 1 and 2to detect leakage from the carrier pipes. Strobe lights at each manhole are activated by the sensors for the leak detection
and drip legs, and sight canisters are visually examined. Visual inspection of alarms (strobe lights)at manhole 1, manhole 2and the storm water lift station are examined daily, along
with a visual check of the sight canisters in manholes 1 and 2. Free flowing conditionsat the storm water catch basins are checked weekly, or when storm water is present. All carrier
pipes within the East Side Drainage System are pressure tested annually to ensure integrity.
Intermodal Unloading Facility (IUF):The intermodal unloading facility is used for unloading intermodal containers (dumping of intermodal containers) and loading bulk waste materials
into trucks. Waste containers are stored on exposed concrete container compliance pads and emptied into the lower concrete bays. Compliance pads are sloped to drain to the lower bays,
which ultimately drain to a collection sump on the west side of the facility. The Intermodal Unloading Facility lift station, located to the west of the IUF,contains a pump for the
transfer of water from the IUF to the pond lift station, where it is pumped to the 1995 evaporation pond. No water is utilized in the operation of the intermodal unloading facility,
therefore, daily inspections of the Intermodal Unloading facility for surface drainage conditions, sump water level, and floor cleanliness occur only when stormwater is present.
Inspection of surface pad integrity, container compliance, and floor cleanlinessis preformed weekly independent of weather conditions, as well as an annual floor inspection.
East Side Truck Unloading Pad: This facility is used for the unloading of waste containers from semi-trucks. Waste containers can be stored on exposed concrete holding pads, but not
on the exposed asphalt unloading area or unloading dock and ramp (temporary placement only). The container holding pads are sloped to drain to troughs on the west side of the facility.
The collection troughs are manually pumped out when they are ¾ full.No water is utilized in operations at the East Truck Unloading area, therefore, the East Truck Unloading Area undergoes
a daily inspection when storm water is present for surface drainage and trough water levels. Regardless of weather conditions, weekly inspections are conducted to ensure the pad’s surface
integrity and container compliance (leakage, proper storage, and labeling).
The Rail Wash Facilityon Track No. 4: This facility uses water in washing operations; therefore, a daily inspection is performed for floor and trench drainage, and sump and collection
tank water levels. Aweekly inspectionof floor integrity, operational sump pump in the sump, and integrity of the storage tanks is also performed. Alarm functionally is checked monthly.

Intermodal Container Wash Building: This building is used for the decontamination and washing of emptied intermodal containers. The facility employs sloped concrete surfaces and trenches
to move wash water from bootwashes, the upper deck floor, and lower wash bays, to a sediment basin and sump in the lower floor. The sediment basin/sump pump pumps water from this facility
to manhole 1 of the East Side Drainage System through a double lined transfer pipe. The sediment basin/sump has a leak detection system (two ports) for monitoring of fluids in its annular
space. This facility uses water in its cleaning operations; therefore, a daily inspection for free drainageconditions and the sediment basin/sump water level is performed. The sediment
basin leak detection system (two ports) for monitoring of fluids is checked weekly, as well asexposed concrete surface integrity and the integrity of the double lined transfer pipe to
manhole 1 (via the sight canister in manhole 1).
Rail Digging Facility: This asphalt pad between rail track no. 3 and rail track no. 4 is used for the unloading of bulk waste from rail cars into transport trucks. Waste is not stored
at this facility. Three concrete collection basins in the asphalt surface drain to a settling basin, then to the IUF Lift Station.Because dirt and debris commonly end up on the asphalt
surface from other site operations, a daily inspection of surface cleanlinessis performed at this facility. The facility does not use water in its operations, therefore, when storm water
is present, inspection of collection basin water levels, settling basin water levels, and drainage occurs daily. Regardless of weather conditions, a weekly inspection is preformed to
ensurethe integrity of exposed surfaces.
Rotary Dump Facility:This facility is used for the thawing, emptying, and washing of railcars, as well as loading waste into trucks. The thaw and wash building floors drain to the lower
floor of the rotary building; compliance floors slope so that there is no free-standing water at the end of operations and all water ultimately drains to a sediment basin located on
the lower rotary building lower floor.
The sediment basin has a leak detection system (two ports) for monitoring of fluids in its annular space. The sediment basin pump moves water to the Northwest Corner Pond through double
lined pipe; the annular space of this pipe is also monitored via a leak detection system. Daily inspections are performed to assess surface drainage conditions and the sediment basin
water level. A weekly inspection is conducted to ensure the integrity of exposed concrete surfaces, check for water in the sediment basin leak detection system, and confirm the sediment
basin pump is operational.Several storage tanks are utilized in the rotary dump building and the surrounding area.Four 2,500 gallon water storage tanks for wash water are located next
to the wash building, as well as two wastewater storage tanks used as part of the Alternative Wastewater Management System. The Alternative Wastewater Management System storage tanks
have sensors to indicate water levels in the tanks. Strobe lights are activated by the water level sensors to provide a visual check of the system. Monthly inspections of the Alternate
Wastewater Management System alarms are done. An inspections of all floors at the Rotary Dump Facility is completed annually, during which time the facility is required to be taken out
of service.
Shredder Facility:This facility is used for the size-reduction of debris waste prior to disposal. Waste is allowed to accumulate in the infeed area of the shredder, as it can take weeks
to accumulate enough material for a shredder run. The facility consists of a concrete pad with drainage to seven catch basins. The catch basins drain to a manhole, where water may be
diverted to either the Rotary Dump facility sediment basin, or to water storage tanks located on the concrete pad. If the waste on the pad is not PCB waste, storm water gravity drains
to the Rotary Dump facility; if PCB waste is on the pad, then storm water is pumped, using a submersible pump in the manhole, to the water storage tanks on the Shredder pad. Strobe lights

are activated by water level sensors to provide for a visual check of the system.Minimal water is used during shredder operations for dust control and cooling, but this minimal water
is consumed during operations and does not contribute to drainage.Because storm water is considered the only source of water, a daily inspection is preformed when storm water is present
for catch basinand sump water levels. Independent of weather conditions, daily inspections occurto evaluate free drainage conditions and cleanliness (dirt, debris, etc.) of the pad,
andweekly inspections are conducted to ensure the integrity of the pad’s concrete surface. A daily inspection for wastewater tanks strobe alarms activation is done when the tanks are
in use; operation of the wastewater tanks alarms are checked monthly.The facility is taken out of service and the entire floor is inspected annually. Containerized Waste Storage Pad:The
Containerized Waste Storage Pad is used for the storage of waste containers. The pad consists of an asphalt surface that acts as secondary containment, only containerized waste can be
stored there. The asphalt surface is sloped for drainage to a sump on the west side of the facility. The sump has a pump in it to convey water to the Pond Lift station, which pumps
water into the 1995 Evaporation Pond.The facility does not use water in its operations. When stormwater is present, a daily inspection of sump water levels, drainage, and pad cleanliness
is conducted. Inspection of pad containercompliance(leakage, proper storage, and labeling) and pad integrity occurs weekly, independent of weather conditions.Decontamination Access
Control Building:This building provides access to and from the restricted area. Floor trenches, sinks, bootwashes, and a shower in the building drain to a collection tank buried outside
of the southwest corner of the building in the restricted area. The collection tank is doubled walled and has water level and leak detection sensors. The collection tank’s wastewater
is pumped through doubled walled pipe (pipeline 1 of the East Side Drainage System) to the Rail Wash on Track 4 collection tank. The Decontamination Access Control Building undergoes
weekly inspections to ensure drainage to the wastewater collection tank,and activation of strobe alarmsindicating wastewater levels within the tank and/or the presence of fluids in the
tank leak detection system.Monthly inspections of strobe alarm operations also occur.
SRS DU Storage Building:The SRS DU Storage Building is used for the storage of Savanna River Site (SRS) DU oxide waste in 55-gallon drums. No water is utilized at this facility, but
storm water has occasionally entered the building; therefore, a daily inspection is conducted when storm water is present for the presence of any water in the building,storage container
integrity, and floor integrity. A monthly inspection is conducted to assess storage container integrity, floor integrity, and the presence of any water in the building, independent
of weather conditions.
Wastewater Evaporation Ponds:The LLRW/11e.(2) evaporation ponds, including the 1995, 1997, 2000, and Northwest Corner Ponds, are used at the Clive site to remove excess site water by
evaporation. All of the Evaporation Ponds are designed and constructed in a similar fashion, and are equipped with leak detection, water level, and pump-back systems. Sensors in the
leak detection and pump-back systems activate strobe lights when the system is not operating and provide for a visual check of the system. The 2000 and Northwest Corner Ponds have transfer
pads for the loading and unloading of water from and to the ponds.Evaporation ponds are visually inspected daily for pond freeboard levelsand activated alarms. Flow meter and fluid head
readings are also taken daily. Monthly the ponds are inspected for operational pumps and pipe condition. Pumps are checked annually for reliability/accuracy.
Note: The Mixed Waste Evaporation Pond and Mixed Waste Impoundment are not LLRW Facilities, so their relative BAT requirements are not included in the Ground Water Quality Discharge
Permit. However, due to their potential to impact groundwater, the Mixed Waste Evaporation Pond and Impoundment have BAT requirements that are evaluated as part of this inspection module.

The Mixed Waste Evaporation Pond and Mixed Waste Impoundment are visually inspected daily for spills or leaks, wind dispersal of waste, berm conditions, structural integrity of containers
and surfaces, and leachate collection systems for the presence of leachate.
***The following facilities are not LLRW/11e(2) facilities, but have the potential to impact groundwater and, therefore,have BAT requirements identified in Appendix J of the Ground Water
Quality Discharge Permit and are evaluated as part of this inspection module.
Southwest Corner Fresh Water Evaporation Pond
BAT requirements at the Southwest Corner Pond confines water within the pond to prevent water from infiltrating into the ground.
South Ditch Lift Station
The South Ditch Lift Station's pump sends water through a hose to the Southwest Corner Pond; BAT requirements at the South Ditch Lift Station minimize the accumulation of water around
the lift station that can infiltrate into the subsurface.
NARRATIVE:
This narrativeprovides the results of the 2024 BAT Field Accompaniment Inspection at EnergySolutions’ Clive facilityon November 5, 2024, and results of the records review associated
with that inspection. This is a routine inspection to assess compliance and the implementation of BAT performance requirementsat the Clive site. The BAT Field Accompaniment Inspection
was conducted by Division staff member Bailey Anderson; inspection findings were recorded via the GW Module 7C inspection form (Attachment 1) and are summarized below (Conclusions).
After arriving at the Clive Facility, Division staff member Bailey Anderson identified herself as a representative of the Division of Waste Management and Radiation Control and asked
to speak to Mr. Brennon Dick,EnergySolutions’ Clive Operations Manager, concerning the inspection she was about to perform.The opening meeting discussed the purpose of the inspection,
areas to be inspected and general BAT management requirements.To confirm EnergySolutions’ BAT inspections had been occurring regularly, Brennon Dick was informed that staff would request
BAT records dated October 1, 2024 through October 15, 2024, (chosen prior to the inspection). Bailey Anderson then met with Clive BAT Technician Drew Ovard, who accompanied Division
Staff for the duration of the inspection.
Upon the conclusion of the field inspection, Bailey Anderson met with Brennon Dick to discuss the findings of the field inspection. Additionally, the requested BAT records were collected
from Curtis Kirk, Quality Assurance Manager at this time. The requested records contained all daily, weekly, monthly, and Mixed Waste inspections that took place from October 1 to October15,
2024. These records were evaluated over the next several days.
Upon conclusion of the records review, Bailey Anderson conducted a virtual close out meeting for the BAT Field Accompaniment Groundwater Module 7C Inspection with Brennon Dick and Dave
Booth, EnergySolutions’ General Manager of Operations, on November 26, 2024.
RECORDS INSPECTION:
The requested LLRW/11e.(2) and Mixed Waste BAT records provided a summary of the daily, weekly, and monthly BAT inspections, activities, and conditions at EnergySolutions for each day
operations were performed from October 1, 2024 to October 15, 2024.
The Second Semi-Annual Best Available Technology (BAT) Monitoring Report for July 1 to December 31, 2023 (DRC-2024-004808) and the Semi-Annual Best Available Technology (BAT) Monitoring
Report for January 1 to June 30, 2024 (DRC-2024-006693) were also reviewed as part of this inspection.Review of these reports indicated no incidents had occurred that the Division was
not already aware of for the timerecords were requested, or since the last BAT Field Accompaniment inspection on December 12, 2023. For all documented incidents since the last inspection,
EnergySolutions provided the necessary maintenance and notifications to the Division within the 24-hour and 7-day timeframes as required by the Permit.However, the following issue was
identified as part of the records review.
Upon reviewing the BAT records provided on November 5, 2024, Division staff noted that the transducer and flow meter readings at the Mixed Waste Surface Impoundment Facility were unchanged
from the previous BAT Field Accompaniment Inspection with Division staff on December 3, 2023. For this reason, additional records were requested from the EnergySolutions Quality Assurance
Manager, and it was identified that flow meter readings at the Mixed Waste Impoundment Facility have remained unchanged since October 28, 2019, during which time transducer readings

also appear almost identical to the readings recorded during the inspection on November 5, 2024.
Note: For much of 2024, few, if any, operations were performed on Wednesdays, as most EnergySolutions staff were then working four ten-hour shifts, which took place on Monday, Tuesday,
Thursday, and Friday. Also, few, if any, operations were performed on weekends as these are traditionally non-work days.
CONCLUSIONS:
On November 5, 2024, daily and weekly BAT inspections were performed by the Clive BAT Technician. A short summary including field observations and any relative results of the records
inspections for each facility with BAT requirements are provided below in the order the facilities were inspected:
LLRW Operations Building:BAT requirements at the LLRW Operations Building maintain wash water within the facility and the collection tank; water collection tank alarms were observed
during the inspectionand the alarms were not activated.No issues were noted at the LLRW Operations Building.
ESRF:BAT requirements at the East Side Rotary Facility ensure contact water is contained within the facility.The ESRF was not yet put into operation and all floors were observed to have
free draining conditions and water levels below trench and sediment basin grates (although it was noted by the BAT technician that once operations began, water in the sediment basin
would need to be pumped out). The alarm at Manhole 1A was not activated.
Surface integrity appeared to be in good condition throughout the facility. Leak detection systems were checked and reported to be dry. This was the first day BAT inspectors conducted
a BAT inspection of this facility. The BAT technician appeared to be unsure of alarm and leak detection system locations, and told the inspector that they had not yet received BAT training
specific to the new facility.
East Side Drainage System: BAT requirements for the East Side Drainage System maintain wash and storm water within the system. The status of alarms at manhole 1 and 2, and the lift station
were observed during the inspection and the alarms were not activated.No issues were noted for the East Side Drainage System.
Intermodal Unloading Facility:BAT requirements at the Intermodal Unloading Facility minimize storm water contacting waste. Due to ongoing construction activities at the IUF, the IUF
has remained out of service since June 3, 2024 and was not inspected as part of the BAT Field Accompaniment inspection on November 5, 2024.
Rail Digging Facility: The Rail Digging Facility’s BAT requirements minimize storm water contacting waste. The surface was clean and water levels were below all grates. The BAT technician
identified a few minor cracks in the concrete surface and notified maintenance staff at the time of the inspection. No issues were noted at theRail Digging Facility.
Rail Wash Facilityon Track No. 4: BAT requirements at the Rail Wash Facility on Track no. 4 ensure water is contained within the facility. Operations were ongoing at the time of the
inspection on November 5, 2024, but were suspended to allow Division staff and the BAT technician to conduct an inspection of drainage conditions and surface integrity. The rail wash
floor was relatively clean, free of cracks, and would drain to the sump; water level in the sump was below the grateand the sump was operational. As part of the weekly facility inspection,
the BAT technician is required to evaluate the condition of the collection and storage tanks located mechanical room of the Rail Wash Facility. At the time of the inspection on November
5, 2024, maintenance activities were ongoing to manage an overflow of the freshwater storage tank that had resulted in water levels above the grate. The Division inspector was informed
by staff that the overflow was due to an incorrect setting to “manual” from “automatic” and was identified and corrected by EnergySolutions staff earlier that morning. Maintenance staff
reported that the water that contacted the ground had been above the level of the grate but was limited to the area immediately surrounding the storage tanks by a concrete wall that
serves as the secondary containment system. At the time of the inspection, a pump was actively being used to pump water out of the area, and water levels had returned to below the level
of the grate. Because this issue was identified and corrected on the same day, notification for the BAT failure was not required. After the on-site inspection, the Division requested
a copy of the BAT records from the day of the inspection. It was noted by the inspector that although the BAT technician was correct in recording that water levels were below the grate
at this facility at the time of the inspection, it should have been noted that maintenance activities were being conducted at the facility during the inspection as the result of a BAT
failure.
Again, due to the timeliness of the failure correction, BAT failure notification to the Division for this incident was not required; however, BAT technicians should strive to accurately
describe facility conditions at the time they are completing their inspection, and the incident should have been recorded in the notes section of their inspection form.
Intermodal Container Wash Building:The Intermodal Container Wash Building’s BAT requirements ensure wash water is contained within the facility. The Intermodal Container Wash Building
was not in use at the time of the inspection. All floors appeared to be in good condition. The sump water level was below its grate and the leak detection system of the sediment basin/sump
was checked found to be dry. The bays appeared to maintain free draining conditions and water levels in the concrete trenches were observed to be below the grate and relatively clear
of debris. Examination of the bootwash stations indicated free draining conditions, however, the BAT technician noted a buildup of sediment and proactively notified maintenance that
they would need to be cleaned out. No issues were noted at theIntermodal Container Wash Building.
Wastewater Evaporation Ponds:The LLRW/11e.(2) evaporation ponds, including the 1995, 1997, 2000, and Northwest Corner Ponds, are used at the Clive site to remove excess site water by
evaporation. During the inspection on November 5, 2024, the evaporation ponds were visually inspected for pond freeboard levels and activated alarms. All ponds were observed to be below
the required freeboard levels and no alarms were activated. Flow meter and fluid head readings were taken and recorded below:
Evaporation Pond
Date of Reading
Head Reading (feet)
Flow Meter Reading (gal.)
Operating Mode
1995 LARW
November 5, 2024
0.57
80183
Automatic
1997 LARW
November 5, 2024
0.56
486874
Automatic
2000 LARW
November 5, 2024
0.54

49415
Automatic
NWC
November 5, 2024
0.32
11108
Automatic
Rotary Dump Facility: BAT requirements at the Rotary Dump facility minimizes storm water contacting waste and maintains water within the facility. At the time of the inspection on November
5, 2024, operations at the Rotary Dump Facility were ongoing and inspection of the required the use of a respirator, therefore, Division staff observed the BAT technician perform the
BAT inspection from shielded areas. Operations were temporarily suspended while the BAT inspection took place. The lower floor of the facility was covered in debris as the facility was
in use, but appeared to be free draining as no standing water was observed on the dump floor. Water levels in the sediment basin appeared to be below the grate and the BAT technician
checked the leak detection ports, which were reported to be dry. The BAT technician walked the upper floors of the of the thaw building and rotary building to confirm free draining conditions
and inspect surface integrity. No issues were noted at theRotary Dump Facility.
Shredder Facility: The Shredder Facility’s BAT requirements minimize storm water contacting waste. The floor was determined to be clean and free draining, and all seven catch basins
were checked to insure they were assessable and that the water levels in the catch basins were below their respected grates. No issues were noted at the Shredder facility.
Decontamination Access Control Building:The Decontamination Access Control Building’s BAT requirementsensure wastewater is contained within the facility and its wastewater storage tank.
The facility was taken out of service in late 2013. During the November 5, 2024 inspection the Decontamination Access Control building was still out of service and there were no activities
occurring there. No issues were identified at the Decontamination Access Control Building,
Mixed Waste: Mixed waste daily inspection records from October 1, 2024 through October 15, 2024 were requested as part of the inspection on November 5, 2024, but there was no accompaniment
of the Mixed Waste BAT inspector. (See Records Inspection.)
East Side Truck Unloading Pad: BAT requirements at the East Side Truck Unloading Pad minimize storm water contacting waste and confirm container compliance. Before returning to the
LLRW Operations building to conclude the BAT Field Accompaniment Inspection on November 5, 2024, it was noted by the Division inspector that the BAT technician had not completed an inspection
of the East Side Truck Unloading Pad. The Division inspector inquired as to whether or not an evaluation of the facility needed to be performed that day, to which the BAT technician
responded that the East Side Truck Unloading Pad was inspected on a monthly basis. While conducting the records review after the on-site inspection, the Division inspector confirmed
that East Side Truck Unloading Pad inspections had been documented on EnergySolutions inspection forms as occurring monthly. This is not consistent with the inspection frequency requirements
identified in Appendix J (Table 1) of the Permit for this facility, which state that inspections for surface integrity and container storage compliance at the East Truck Unloading Pad
should be conducted weekly. This discrepancy was identified during the closeout meeting with EnergySolutions staff on November 26, 2024. Later that same day, the Division received correspondence
from EnergySolutions which stated that the discrepancy in inspection frequency was due to a clerical error as an artifact of the October 10, 2013 GWQDP modification, and referenced a
letter dated May 21, 2013 which discussed the results of a meeting between EnergySolutions and Division staff regarding proposed modifications to Appendices J and K of the GWQDP (CD-2024-243,
CD13-0148). Division staff identified the document referenced by EnergySolutions in their November 26, 2024 correspondence as a request by EnergySolutions in 2013 to modify the inspection
frequencies of several BAT facilities at the Clive Site; however, this request was not a document that had been evaluated by staff or approved by the Director. In 2013, the Division
evaluated EnergySolutions’ request to reduce inspection frequencies of BAT facilities at the Clive Site on a case-by-case basis, and in an internal memo written in June 2013 it was determined
that while reducing the frequency of inspections at the East Truck Unloading Facility to a monthly basis would not be appropriate, daily inspections could be reduced to a weekly basis
(DRC-2013-002725). This determination was recorded in the Statement of Basis for the October 10, 2013 GWQDP modification, and was subsequently changed in the approved Permit modification.

***After leaving the restricted area two other facilities with BAT requirements were inspected by the Division inspector.
Southwest Corner Fresh Water Evaporation Pond:BAT requirements at the Southwest Corner Pond confines water within the pond to prevent water from infiltrating into the ground. At the
time of the inspectionthe Southwest Corner Pond was more than 12 inches below the discharge point.
South Ditch Lift Station:BAT requirements at the South Ditch Lift Station minimize the accumulation of water in the area of the lift station that can infiltrate into the subsurface.
At the time of the inspection water wasobserved to be below the sump grate and the alarm wasnot activated.
COMPLIANCE STATUS:
As a result of the field inspection on November 5, 2024 at the Clive Site and the subsequent records review, two facilities were found to be potentially out of compliance.
East Side Truck Unloading Facility: Appendix J Table 1 of the Ground Water Quality Discharge Permit No. UGW450005 requires weekly BAT inspections of the East Side Truck Unloading Facility,
or daily inspections when stormwater is present.
As a result of the field inspection on November 5, 2024, and the subsequent records review, Division staff identified that EnergySolutions has been completing monthly inspections of
the East Truck Unloading Facility, as opposed to weekly as required in Appendix J Table 1 of the GWQDP. This discrepancy was identified during the closeout meeting with EnergySolutions
staff on November 26, 2024. EnergySolutions responded to this concern in a correspondence to the Division later the same day, in which EnergySolutions which stated that the discrepancy
in inspection frequency was due to a clerical error as an artifact of the October 10, 2013 GWQDP modification, and referenced a letter dated May 21, 2013 which discussed the results
of a meeting between EnergySolutions and Division staff regarding proposed modifications to Appendices J and K of the GWQDP (CD-2024-243, CD13-0148). Division staff identified the document
referenced by EnergySolutions in their November 26, 2024 correspondence as a request by EnergySolutions in 2013 to modify the inspection frequencies of several BAT facilities at the
Clive Site; however, this request was not a document that had been evaluated by staff or approved by the Director. EnergySolutions’ request to reduce the inspection frequency at the
East Side Truck Unloading Facility was evaluated by Division staff and documented in the Statement of Basis for the October 10, 2013 GWQDP modification, at which time it was determined
by staff that a weekly inspection of the East Side Truck Unloading Facility would be more appropriate.
Mixed Waste Surface Impoundment: Attachment II-3 Part 4.g of the Part B Permit requires a daily inspection of the Mixed Waste Surface Impoundment for “(the) operational status of leak
detection system pump, pump controller, head/pressure transducer, and flow meter equipment”.Part 1.E.14.d of the Ground Water Quality Discharge Permit No. UGW450005 states “Pursuant
to Part I.E.16 of this Permit the Permittee shall operate and maintain the Mixed Waste Surface Impoundment in accordance with the State-issued Part B Permit”; due to the potential of
the Facility to impact groundwater, the Mixed Waste Surface Impoundment has BAT requirements (Part B Permit Attachment II-3 Part 4.g) that are evaluated as part of the BAT Field Accompaniment
Groundwater Module 7C Inspection Module. As a result of the records review associated with this inspection, it was identified that the flow meter reading at the Mixed Waste Impoundment
Facility have remained unchanged since October 28, 2019, during which time transducer readings also appear almost identical to the readings recorded during the inspection on November
5, 2024.

With these exceptions, the facilities inspected on November 5, 2024 were found to be in general compliance with the BAT requirements of the Permit.
ISSUES:
Upon the conclusion of the inspection, the Division inspector discussed the need for additional training of BAT technicians at the closeout meeting with EnergySolutions staff on November
26, 2024. While the EnergySolutions BAT technician leading the inspection on November 5, 2024 was not the primary EnergySolutions BAT technician, it was noted that there was some uncertainty
about the locations of some of the BAT facilities being inspected, especially at the new East Side Rotary Facility. During the closeout inspection, the Division inspector recommended
that a walk through of the new facility with staff that will complete BAT inspections may be helpful, and regular walk throughs of facilities with BAT requirements are conducted with
technicians so that regardless of whether they are the primary BAT inspector, EnergySolutions staff is confident in their ability to identify those facilities on-site. Additionally,
the Division inspector reminded EnergySolutions staff in the closeout meeting that BAT technicians should strive to accurately describe facility conditions at the time they are completing
their inspection, including recording any maintenance activities, etc. that are occurring at the time of inspection.
SIGNATURE:
Prepared By:12/17/2024
____________________________________________________________________
Bailey Anderson, Hydrogeologist, Date
LLRW Section
Utah Division of Waste Management and Radiation Control
Review and Approval By:
_____________________________________________________________________
Lawrence Kellum, Program Manager Date
LLRW Section
Utah Division of Waste Management and Radiation Control
Attachment 1 to Narrative
2024 Division Inspection Form