DRC-2024-007947

Utah Department of Environmental Quality
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL
EnergySolutions' 2023 Second Semi-Annual BAT Monitoring Report,
BAT Requirements of the Ground Water Quality Discharge Permit, No. UGW 450005,
Groundwater Module 7b Inspection (2nd 2023 BAT Monitoring Report)
INSPECTION REPORT FOR
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
[phone]
DATE OF INSPECTION
In Office Review
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 parts of Sections 29 and 33 of Township 1 South, Range 11 West Salt Lake Base and Meridian (SLBM), and part
of Sections 5, Township 2 South, and Range 11 West SLBM.
FACILITY CONTACT
Vern C. Rogers
Director, Regulatory Affairs
[phone]
Curtis R. Kirk
Clive Facility Quality Assurance Manager
[phone]
NOTIFICATION
Condition I.H.20 of the of Ground Water Quality Discharge Permit (GWQDP), UGW 450005, requires EnergySolutions to submit a Semi-Annual BAT Monitoring Report that provides results, calculations,
and evaluation of Best Available Technology (BAT) monitoring at the EnergySolutions Clive, Utah facility. The submitted report provides the BAT monitoring data for the period July 1
through December 31, 2023.
APPLICABLE REQUIREMENTS
The State of Utah, as an U.S. Nuclear Regulatory Commission (NRC) Agreement State, has developed and adopted compatible requirements to the NRC for disposal of radioactive waste and
has regulatory authority over the disposal of Low Level, Mixed, and 11e.(2) byproduct radioactive waste materials. Applicable requirements are found in Title 10 Code of Federal Regulation
(CFR) Parts 40 and 61; and Utah Statute, Utah Administrative Code (UAC) R-313-24 and 25: Uranium Mills and Source Material Mill Tailings Disposal Facility Requirements, and License
Requirements for Land Disposal of Radioactive Waste, respectively. The State of Utah has issued two Radioactive Material Licenses, UT2300249 and UT2300478 to the EnergySolutions’ Clive,
Utah facility. Because the Clive facility has been determined to have a potential to contaminate groundwater, requirements of Utah Administrative Rules for Water Quality are applied.
Provisions and requirements for groundwater quality protection are found in UAC R317-6, Utah Administrative Rules for Ground Water Quality Protection and the EnergySolutions’ Clive
facility has been issued a State of Utah Ground Water Quality Discharge Permit, UGW 450005 (hereinafter GWQDP).
The GWQDP requires that Best Available Technology (BAT) be used in construction of and Best Management Practices be used in the operations of all facilities at Clive that have a potential
to impact groundwater. Individual Clive waste handling, washing, and waste-water facilities have BAT criteria associated with them. As reflected in Permit requirements, facility operations
are fundamental to protection of groundwater from potentially hazardous materials. To demonstrate compliance, Part I.E and Appendix J (BAT Performance Monitoring Plan) presents BAT
performance and management standards.Part I.F and Appendix J define inspection requirements for various facilities at Clive.Submittal of a semi-annual Best Available Technology (BAT)
monitoring report to document this compliance is required by Part I.H.20 of the GWQDP.
EnergySolutions operates and maintains the Clive disposal facilities in accordance with BAT requirements of Part I.E.7 through 27, Part I.F.2, and the currently approved Appendix J (BAT
Performance Monitoring Plan) of the GWQDP. Appendix J of the GWQDP provides a description of each facility, BAT performance criteria, compliance points, inspection requirements, frequency
of inspection, and where each inspection is to be documented. Part 1.E.14.a.3 of the GWQDP requires daily fluid head monitoring of evaporation pond leak detection systems be performed
each day that waste or water management activities occur. Conditions I.E.7.a and I.E.7.b of the GWQDP provide general storm water management requirements for identifying, collecting,
and disposing of storm water which may have potentially come in contact with waste (Contact Storm Water). Condition I.F.24 provides requirements for documenting Contact Storm Water removal
activities including date, time, and location of discovery of storm water accumulation, date and time when storm water removal was initiated at each location, date and time when storm
water removal was completed at each location, and volumes of storm water removed at each location as well as where the water was disposed of. Condition I.H.20.b of the GWQDP provides
requirements for reporting Storm Water Management activities, including the submittal of Storm Water Accumulation Inspection and Collection Forms.EnergySolutions demonstrates compliance
with BAT performance standards by performing and documenting inspections, performing equipment maintenance and repairs, and implementing corrective actions if needed. If a failure of
BAT occurs at any facility, the Permit Contingency Plan (Appendix K, BAT Contingency Plan) must be implemented.
TYPE OF INSPECTION
This is a review of waste handling, washing, and waste-water pond facilities (BAT inspected facilities) against BAT requirements of the GWQDP and its Appendix J.
PREPARED BY:
Andrew Zehr
Hydrogeologist
LLRW Section

Utah Division of Waste Management and Radiation Control
REVIEWED BY:
Bailey Anderson
Hydrogeologist
LLRW Section
Utah Division of Waste Management and Radiation Control
WEATHER CONDITIONS
Not applicable - this is an office review
FACILITY DESCRIPTION
EnergySolutions owns and operates a commercial Class A low level, l1e.(2) byproduct (uranium mill tailings), and a mixed radioactive and hazardous (Mixed) waste disposal facility near
Clive, Tooele County, Utah. EnergySolutions’ Clive facility provides private long-term disposal of waste from the cleanups of Low Level, Mixed, and 11e.(2) radioactive sites. EnergySolutions
began waste disposal operation at the Clive facility in 1988 on Section 32, Township 1 South, Range 11 West SLBM. Presently, waste treatment and waste 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 parts of Sections 29 and
32, Township 1 South, Range 11 West SLBM.Active clay mining is ongoing in Section 29 Township 1 South, Range 11 West SLBM and Section 5 of Township 2 South, Range 11 West SLBM, the whole
operation covering about two square miles. At the present time, waste is placed in one of three active above-ground engineered disposal embankments, which meet applicable regulatory
requirements to dispose of radioactive waste: 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. Currently, the facility has about 100 employees and operates a single ten hours shift, five days a week.
The Clive disposal facility lies in west-central Utah at the eastern margin of the Great Salt Lake Desert, and west of the Cedar Mountains. The area has a semi-arid climate with an
average precipitation of about 9 inches per year, and an average pan evaporation of about 50 inches per year. The area is climatologically classified as a desert according to the Koppen
climate scheme. Surface water from the Cedar Mountains does not reach the site and any runoff originating in the area naturally drains to and collects in the Great Salt Lake Desert
playa, several miles to the west. The topography in the area varies from a high in the northern Cedar Mountains of about 5,600 feet and a low in the Great Salt Lake playa, located east
of the facility, of about 4,250 feet. The average elevation of the facility is 4,270 feet above mean sea level. The natural topography of the area slopes slightly toward the southwest
with approximately 10 feet of relief within Section 32.
Facilities within the restricted area with BAT requirements are divided into waste handling, wash (decontamination), and evaporation pond facilities for the purposes of the Division’s
BAT inspections (see Figure 1 below for the location of facilities with inspection requirements).
Facilities listed in the 2nd 2023 BAT Monitoring Report are:
Containerized Waste Storage Pad (CWSP): The CWSP is an open and exposed waste handling facility where intermodal and drum containers are temperately stored before being moved to one
of the embankments. It is located within the east central area of section 32.
Intermodal Unloading Facility (IUF): The IUF is an open and exposed waste-handling facility. At the IUF, waste from intermodal containers is dumped, and loaded into trucks to be hauled
to an embankment. It is located within the east central area of section 32.
IUF Lift Station: The IUF Lift Station collects wastewater from the IUF for transfer to the 1995/1997 pond lift station. The IUF Lift Station is located west ofthe IUF.
Intermodal Container Wash Building (ICWB): The ICWB is an enclosed wash facility where intermodal containers are washed (decontaminated) after being emptied. It is located within the
north-eastern area of section 32.
Rail Wash Facility on Track no. 4: The Rail Wash Facility on Track no. 4 is an enclosed wash facility used for washing and decontamination of rail cars. It is located within the north-eastern
area of section 32 near the ICWB.
Rail Digging Facility: The Rail Digging Facility is an open and exposed waste handling facility where railcars loaded with bulk waste can be unloaded into trucks before being moved
to an embankment.The Rail Digging Facility handles bulk waste, and dirt and debris that commonly ends up on the asphalt surface. It is located within the east central waste handling
area of section 32.
East Truck Unloading Area: The East Truck Unloading Area is an open and exposed waste handling facility where containers from trucks are unloaded and temperately stored before being
moved to one of the embankments. The facility includes container holding pads, an unloading dock with ramp, and an unloading area.It is located within the east central area of section
32. Decontamination Access Control Building (DACB): The DACB is used for the decontamination of workers, and for access to and from the restricted area. It is located within the
north-eastern area of section 32.
Shredder Facility: The Shredder Facility is an open and exposed waste handling facility. This facility is used for the size-reduction of debris waste prior to disposal. It is located
within the north-western waste handling area of section 32. Rotary Dump Facility: The Rotary Dump Facility is an enclosed waste handling and wash facility where railcars can be thawed,
dumped, and washed. It is located within the north-western waste handling area of section 32.
East Side Drainage System (ESDS): ESDS is a buried system that transfers wastewater (wash and storm) to the 1997 Pond from the DACB, ICWB, and Rail Wash Facility on Track No. 4.The
ESDS also provides for storm water collected from storm water catch basins at the ICWB, and between tracks 2 and 3. This system consists of two drainage subsystems: one for wastewater
from decontamination facilities, and a second drainage system for storm water from nearby catch basins. The waters from these subsystems are kept separate until they are discharged into
the 1997 Pond. The ESDS also has manhole 1 and 2, and IUF lift stations that allow monitoring of the system. The system corridor is from the north-eastern to east central area of section
32 ending at the 1997 evaporation pond.
Gray Water Tank in the LLRW Operation Building (LOB): The LOB provides for the decontamination of worker and access to and from the restricted area.Wastewater from the restricted area
used in worker decontamination drains to a 2,500-gallon double-walled collection tank (Gray Water Tank) outside of the building in the restricted area. The LOB is located within the
northern waste-handling area of Section 32.
Evaporation Ponds (EPs): Wastewater EPs at the Clive site with BAT criteria are the 1995, 1997, 2000, and Northwest Corner Ponds. The wastewater EPs used at the Clive site are a means
to remove excess water in an affordable and environmentally responsible way. Water used in decontamination operations, and water that falls within the restricted area is considered
contaminated water. All EPs are designed and constructed in a similar fashion, and they are subject to common BAT requirements. Each EP is equipped with leak detection and pump-back
systems designed to aid in the detection of leaks in the liner, and water level markings at two and three feet on the pond liner to indicate the freeboard level.
Leak detection system monitoring equipment consisting of a pump, pressure transducer, flow meter, discharge lines, and controller/monitoring panel that allow EnergySolutions to monitor
flow volumes and levels, collect and remove fluids every day that operations are being performed. The freeboard level is the vertical distance between the pond spillway elevation and
the evaporation ponds water level. EPs are shown in Figure 1 (below) in light blue.

Figure 1. EnergySolutions’ Clive facilities with BAT inspections.
CREDENTIALS, PURPOSE AND SCOPE
As part of Clive facility’s BAT requirements, EnergySolutions conducts inspections and maintenance programs at waste handling, washing, and waste-water pond facilities. The purpose
and scope of this review is to verify operations at the Clive facility are operated according to BAT design and performance standards to ensure conditions do not allow contaminated water
to contact the ground surface or infiltrate to groundwater. This report summarizes the results of a review of the 2023 2nd Semi-Annual BAT Monitoring Report and provides an assessment
of conditions at the EnergySolutions’ Clive waste handling, washing, and pond facilities for the period July 1 through December 31, 2023.
MANAGEMENT ACTIVITIES
EnergySolutions' Clive site is permitted, licensed and authorized to receive and dispose of Class A LLRW, NORM/NARM waste, Class A mixed LLRW, 11e.(2) byproduct material, special nuclear
material based on concentration limits, and wastes contained polychlorinated biphenyls (PCBs). The latter includes PCB/radioactive waste, and PCB/mixed waste. Waste is shipped to the
Clive Facility either by highway or by rail.Waste disposal embankments occupy part of Section 32, with the remainder of Section 32 being occupied primarily by rail, unloading, and cleaning
facilities. Additional waste handling, administrative, and maintenance occurs in Section 29 and Section 33 in Township 1 South and Range 11 West, SLBM. Waste handling and rail operations
occur in parts of Sections 29, 32 and 33 in Township 1 South and Range 11 West, SLBM. Section 32 is divided into five main disposal areas: Low-Active Radioactive Waste (LARW) embankment
(closed in 2006), Class A West embankment, lle.(2) embankment, RCRA Mixed Waste embankment, and the DOE Vitro tailings disposal embankment, occupying approximately 100 acres within Section
32. Raw-material (clay) mining occurs in Section 29, Township 1 South and Range 11 West, SLBM, and in Section 5, Township 2 South and Range 11 West, SLBM. Waste-treatment facilities
are located within the Mixed Waste area. These waste-treatment facilities are used for treating radioactive waste that requires treatment for RCRA constituents and for liquid radioactive
waste requiring solidification prior to disposal. Waste treatment is not allowed at the Class A West and lle.(2) embankments.
Waste shipped to the facility for treatment or liquid solidification prior to disposal must be treated in the Mixed Waste area and disposed of in the Mixed Waste embankment.
Waste-handling and washing facilities and wastewater ponds are used to support operations at the Clive facility and are potential sources of contaminated water. Facilities at Clive are
designed and operated to protect the environment in normal operations and include mechanisms and procedures limiting the discharge of fluids to the ground or groundwater. Components
at these sub-facilities are designed for periodic or continual monitoring and inspection, or testing. Wash facilities generally have daily BAT inspections associated with them because
water is commonly used there. The following describes facilities at Clive, their intended purposes, and how EnergySolutions performs BAT performance monitoring at these facilities in
accordance with the Permit.
The LLRW Operations Building: The LOB has two parts: a restricted part, and a non-restricted part. The restricted part of the building provides personnel with secured access to the restricted
area. The nonrestricted part of the building provides services for site personnel. No waste-handling operations occur in the LOB, waste is not stored in the building, and the water volumes
used at the facility are small. The small volume of wastewater from the restricted area goes to a gray water collection tank outside of the building. The gray water collection tank is
doubled lined, with an annular space between the liners. Strobe alarms are activated by sensors located in the annular space of the collection tank outside of the building if there is
fluid in the tank annular space. Other strobe alarms are activated by a high-level float sensor, which indicates when the tank is three-quarters full, and/or by a high-level float sensor,
set just below the maximum capacity of the tank. These strobe alarms provide for a visual check of the system. The Gray Water Tank at the LOB is inspected daily for the status of the
alarms, monthly inspections to evaluate drainage to the tank, and an annual inspection to evaluate if the alarms are operational.
The EastSide Drainage System: The ESDS consists of two drainage subsystems: one for wastewater from decontamination facilities, and another for storm water from nearby catch basins.
The wastewaterdrainage system obtains its water from the DACB, the ICWB, and the RWFTN4. The waters from these subsystems are kept separate until they are discharged into the 1997 Pond.
Alarms at Manholes 1 and 2 and the stormwater lift stations are checked daily, and The ESDS undergoes daily visual inspections of strobe alarms and dip canisters associated with manholes
1 and 2, and a strobe alarm associated with the storm water lift station. The storm water catch basins are checked weekly for free-flowing conditions. Working alarms are checked monthly
(strobe alarms are checked within a 30-day time period). An annual inspection is undertaken of the performance of the pipe connecting the system (annual pressure test of the system).
ESDS Manhole 1 contains drip legs 1 and 2, and ESDS Manhole 2 contains drip legs no. 3, 4, 5, and 6. Daily visual inspections evaluate and record the operation of Manhole 1, Manhole
2, and stormwater lift station alarms.
lntermodal Unloading Facility: The IUF is used for unloading of intermodal storage units (i.e., dumping of their contents onto the IUF's concretebay floors) and for loading of bulkwaste
materials into trucks. No water is utilized at the IUF. Stormwater, which may have contacted waste, drains by gravity flow from the concrete floors to a collection sump located on the
west side of the facility. A sump pump is installed within the sump. This pump moves water through a drain line to the IUF lift station. The IUF itself undergoes (i) daily inspections
occurring only when storm water is present, (ii) weekly inspections, and (iii) an annual inspection. The daily inspections, occurring only when stormwater is present, include inspections
of (a) drainage to the sump, (b) operation of the sump, (c) water level in the sump being half full or less, (d) cleanliness of the pad (absence of dirt, debris, etc.), and (e) integrity
of the pad. The weekly inspection is for water level in the sump, integrity of the concrete, and cleanliness of the pad. An annual inspection (during the second quarter) is made of concrete
integrity.
lntermodal Unloading Facility Lift Station: The IUF Lift Station collects wastewater from the IUF for transfer to the 1995/1997 pond lift station. The IUF Lift Station undergoes daily
visual inspections of its strobe alarm, and monthly inspections to evaluate whether the alarm is operating correctly.
East Truck Unloading Area: The East Truck Unloading Area is used for the unloading of waste containers from semi-trucks. This facility includes container holding pads, an unloading dock
with ramp, and an unloading area. The asphalt surface of the unloading area is not included as a BAT compliance area, and no storage of waste is allowed on that surface. Waste can only
be temporarily and briefly placed on the asphalt surface during operations. Containers with waste can be stored on the concrete holding pads. No water is utilized at the East Truck Unloading
Area. Storm water drains from the holding pads, by gravity flow, towards and into storm water collection troughs. The East Truck Unloading Area undergoes daily inspections when storm
water is present. Daily inspections occurring when storm water is present are to evaluate stormwater drainage to collection troughs, to determine that the water level in troughs is less
than three-quarters full, and to check the cleanliness of asphalt and concrete surfaces (dirt, debris, etc.).The concrete holding pads are the compliance points not the asphalt surface.
Weekly inspections are also conducted of containers on concrete holding pads and the pads' integrity.
The Rail Wash Facility on Track No. 4: The Rail Wash Facility on Track No. 4 is used for washing and decontamination of rail cars. Because the facility uses water in its washing operations,
a daily BAT inspection is performed for sump water level, free drainage of floor and trenches, and collection tank(s) water levels. Daily inspections evaluate trench drainage to a floor
sump and piping to storage tanks. Weekly inspections are conducted to evaluate whether the sump is operational, to ensure integrity of collection and storage tanks in the adjacent equipment/mechanical
building, and to monitor concrete-pad cleanliness (dirt, debris, etc.) and surface integrity.
The lntermodal Container Wash Building: The ICWU is used for decontamination/washing of large trailercontainers. Because the facility uses water in its cleaning operations, a daily inspection
for free drainage and sediment basin and sump water level is performed. The sediment basin has a leak detection system (two ports) for monitoring of fluids that might escape from the
wastewater collection sump or the sediment basin, the leak detection ports are checked weekly. The sediment basin/sump uses a pump to move water to Manhole 1 of the east side drainage
system through a double-lined transfer pipe system.The integrity of the leak detection system is also checked weekly. Daily inspections evaluate drainage from wash bays to troughs, boot

washes to troughs, troughs to a sediment basin, and water level below the grate of the sediment basin. Weekly inspections for presence of fluids in the sediment basin leak detection
ports (absence of fluids within leak detection system), as well as the integrityof exposed concrete surfaces.
The Rail Digging Facility: The Rail Digging Facility is a facility historically used for unloading bulk waste from rail cars. The Rail Digging Facility has not been employed for several
years. When in use, the waste is unloaded by track hoe from railcars directly into transport trucks. When the Rail Digging Facility handles bulk waste, dirt and debris end up on the
asphalt surface, so a daily inspection of the surface for cleanliness is performed. Daily inspection of the sump water level, when done, occurs only when storm water is present. Inspections
check drainage to collection basins, drainage to the Rail Digging Facility manhole, and pad cleanliness (dirt, debris, etc.). When done, weekly inspections evaluate exposed surface integrity
and ensure that surfaces are free of defects. Concrete and asphalt surface integrity are checked weekly.
The Rotary Dump Facility: The Rotary Dump Facility is used for the thawing, emptying and loading of waste, and for washing of railcars. In the dump building, bulk waste is emptied from
rail cars onto a concrete floor. The dump building floor, and for that matter all floors, are sloped so that there is no free-standing water on the floor at the end of operations. Ports
for a sediment basin located in the dump building (lower floor) use a leak detection system to monitor for sediment-basin leaks. Because the facility uses water in its daily washing
operations, daily BAT inspections are performed to document free drainage to the sediment basin, the water level in the sediment basin and, when in use, a functioning alternate wastewater
management area. Weekly inspections are conducted to evaluate the integrity of exposed concrete, water in the leak detection system of the sediment basin and sump operation. An annual
inspection during the second quarter is conducted to evaluate the integrity of concrete on the rotary building dump floor.
The Shredder Facility: The Shredder Facility is used for the size-reduction of waste debris prior to disposal. A minimal amount of water is used during Shredder Facility operation for
dust control and for cooling. Stormwater drains from the pad surface to catch basins and then to a manhole (Manhole 1). If the waste on the pad is not PCB waste, then the storm water
drains to the Rotary Dump Facility. lf, however, PCB waste is on the pad, then storm water drains from the catch basins to Manhole 1, where the water, using a submersible pump, is moved
to water storage tanks located on the SF concrete pad. Because the facility does not use water in its daily operations, a daily inspection is conducted only when storm water is present.
Daily inspections evaluate whether (i) water drains to catch basins, (ii) water in each catch basin has a level below the grate, (iii) water drains to a manhole and then through a pipeline
from the manhole to water storage tanks, (iv) the pipeline has integrity and (v) the high-water alarm in the water-storage tanks works. Weekly inspections evaluate the integrity of exposed
concrete.
An annual inspection during the second quarter is conducted to evaluate the concrete surface (any concrete surface repairs are conducted during or shortly after the annual inspection).
Containerized Waste Storage Pad: The Division of Radiation Control received notice that the CWSP was going to be taken out of service as a waste storage facility due to cracks on the
pad surface on January 17, 2013. The CWSP was taken out of service relative to waste storage or other operations on January 18, 2013. When a facility is out of service in this regard,
storage of waste is not associated with thefacility, and inspections of the facility regarding waste storage are not conducted. The CWSP is now used only for temporary storage of empty
waste containers. The facility furthermore does not use water for its operations, so stormwater is the only source of water there. A daily inspection of the sump water level occurs at
times when stormwater is present. A daily inspection is conducted for drainage and pad (floor) cleanliness (dirt, debris, etc.). Weekly inspections check for pad integrity and for leakage,
proper storage, and labeling of containers on the pad.
Decontamination Access Control Building: The DACB is designed for free drainage of water in floor trenches to a collection tank buried outside of the southwest corner of the building.
The collection tank is fitted with water-level alarms and a transfer-pipe system connected to the Rail Wash Facility on Track No. 4 which is fitted with a leakdetection system.
The DACB undergoes weekly inspections to evaluate whether there is adequate drainage to a wastewater-collection tank, wastewater level within the tank, and the presence of fluids in
the tank's leakdetection system. Monthly inspections check strobealarm operation.
Evaporation Ponds: Wastewater EPs at the Clive site with BAT criteria are the 1995, 1997, 2000, and Northwest Corner Ponds. All EPs are designed and constructed in a similar fashion,
and they are subject to common BAT requirements. EPs are visually inspected for pond freeboard levels and activated alarms. Because the EPs are physically distributed around the Clive
site, daily inspections are done in the order that the ponds are encountered. Each pond has a maximum allowable daily leakage rate and a calculated flow rate for the initiation of a
required pump-down test.
The pump-down test is used to determine the accuracy of the leakdetection system, and the removal of fluids from the leakdetection system. Flow rates are averaged over a week to determine
the calculated daily leakage rate. Weekly calculated flow volumes are documented on the Evaporation Pond(s) Leak Detection System Volume Weekly Calculation form. EP freeboard levels
are determined by viewing the compliance markings on the liner that indicate freeboard levels. Monthly inspections are performed at each EP to evaluate pump and pipe integrity. The leakdetection
system pump is inspected annually.
Management of the individual EPs, in line with their BAT requirements, is summarized below:
1995 Evaporation Pond: The 1995 EP freeboard level, leak-detection alarms, flow rates, and fluid heads are inspected and/or recorded daily. At the 1995 EP, the flow meter reading is
recorded. It should not exceed the seven-day average maximum allowable flow rate of 162 gallons/day (gal/d) or pumping-test-trigger flow rate of 155 gal/d. A pressure transducer is used
to measure fluid head in between the liner layers. The head is not to exceed a 1-foot level. The freeboard is to be maintained below 2 feet.
1997 Evaporation Pond: The 1997 EP freeboard level, leak-detection alarms, flow rates, and fluid heads are inspected and recorded daily. The recorded flow rate at this EP is not to exceed
a seven-day average maximum allowable flow rate of 171 gal/d or a pumping-test-trigger flow rate of 160 gal/d. The measured fluid head is not to exceed a 1-foot level, and the freeboard
level is to be maintained at more than the 2-foot minimum.
2000 Evaporation Pond: The 2000 EP freeboard level, leak-detection alarms, flow rates, and fluid heads are inspected and/or recorded daily. At the 2000 EP, the flow rate is not to exceed
a seven-day average maximum allowable flow rate of 382 gal/d or pumping-test-trigger flow rate of 355 gal/d. The measurement of fluid head is not to exceed the 1-foot level, and the
freeboard level is to be maintained at more than the 2-foot minimum.
Mixed-Waste Evaporation Pond: The Mixed-Waste EP freeboard level, leak-detection alarms, flow rates, and fluid heads are inspected and/or recorded daily. At the Mixed-Waste EP, pumping
tests must be implemented when seven-day average flow rates exceed 160 gal/d. Flow rates are not to exceed a seven-day average maximum flow rate of 171 gal/d. The fluid head measurement
(using the pressure transducer) is not to exceed a1-foot level. The freeboard level is to be maintained at the 2-foot minimum or greater.
Northwest Corner Evaporation Pond: The Northwest Corner Evaporation Pond freeboard level, leak-detection system alarms, flow volume, and fluid head are inspected and/or recorded daily.
Daily flow volumes are not to exceed a seven-day average maximum allowable flow rate of 326 gal/d or a flow rate of 300 gal/d that would require a pumping test. Fluid head (measured
using a pressure transducer) is not to exceed a 1-foot level. The freeboard level is to be maintained at more than the 2-foot minimum.
NARRATIVE
This narrative reviews the 20232nd Semi-annual BAT Monitoring Report (hereinafter BAT Report) submitted by EnergySolutions LLC (EnergySolutions) to the Division of Waste Management and
Radiation Control (hereinafter Division) on February 27, 2024, which is before the Permit required due date of May 1, 2024. The time period covered by this BAT Report is July through
December 2023. The Division is beginning its inspection/review of this report on November 20, 2024.
The handling of low level radioactive waste at the EnergySolutions Clive site is protective of groundwater and the public health and safety if facilities are operational and procedures

are properly conducted. The Permit accordingly places conditions on the design and operation at the Clive site, since these factors have a potential to impact groundwater or public health
and safety. To demonstrate compliance with Part I.E, Part I.F, and Appendix J, the BAT Performance Monitoring Plan, inspections are required for various facilities at Clive, and the
submittal of a semi-annual Best Available Technology (BAT) monitoring report to document this compliance is required by Part I.H.20 of the Permit. EnergySolutions has a monitoring plan
describing internal inspections to be performed to document compliance with BAT requirements of the Permit.The BAT Report provides an evaluation of BAT monitoring at various EnergySolutions
Clive operational facilities. Data provided in the BAT Report includes:
Precipitation data for the time period of the BAT Report.
Daily inspection data for facilities when storm water is present, and daily PCB inspection forms, used to record the results of the daily BAT inspections.
Weekly inspection forms, used to record the results of the weekly BAT inspections.
Monthly inspection forms, used to record the results of the monthly BAT inspections.
Weekly calculations of daily average volume of water from leakdetection sumps for each pond, recorded on Evaporation Pond(s) Leak Detection System Volume Weekly Calculation Forms.
Daily inspection forms of Mixed Waste Evaporation Pond, used to record daily measurements of fluid head in the Mixed Waste Evaporation Pond leakdetection sump.
Weekly calculation of daily average volume from the leakdetection sump at the Mixed Waste Evaporation Pond, recorded on the Mixed Waste Evaporation Pond Leak Detection System Volume
Weekly Calculation Forms.
Rotary Dump Facility Forms, which record the presence of ponded water in the dump floor.
Reported incidents.
Storm water activities, and Accumulation Inspection and Collection Forms.
EnergySolutions submitted BAT inspection forms electronically as PDF files. These PDF files were reviewed for inspection details and other items of interest identified in the BAT Report.
A review of the BAT monitoring data at the EnergySolutions facility is provided below.
PRECIPITATION
A total of 4.09 inches of precipitation fell in the period of July through December of 2023; a monthly breakdown of precipitation is summarized in Table 1 below.
Precipitation from individual and spatially distributed storms can vary greatly over time and space in western Utah; therefore, precipitation comparisons are generally considered more
meaningful when compared to longer periods.
Precipitation from historical Clive data (20+ years of precipitation data) indicates an average of about 2.78 inches of precipitation for the months of July to December; about 47 percent
more precipitation fell during this period in 2023.
Precipitation data at the Clive site has an inherent variability or a large statistical spread (standard deviation), thus the different between the two precipitation amounts may not
be statistically significant.
Comparing the BAT Report's precipitation to Closed-Cell Modeling conducted for the embankments indicates that the 2nd half of 2023 had slightly more (16%) precipitation than the amount
used as an average case in the modeling (3.54 inches). The precipitation reported in the BAT Report could be cause for concern for the open cell time limitation extensions that have
been allowed at the Clive facility for the CAW embankment, if the amount of precipitation in 2024 is also above the base-case precipitation amount used in the Open Cell modeling.
Table 1. Precipitation Reported in the 2023 2nd Semi-Annual BAT Monitoring Report
Month
Amount (inches)
Comment
July
0.13
2 days of precipitation; highest precipitation on July 19th @ 0.08 inches
August
0.66
7 days of precipitation; highest precipitation on August 1st @ 0.27 inches
September
0.90
7 days of precipitation; highest precipitation on September 21st @ 0.46 inches
October
1.42*
7 days of precipitation; highest precipitation on October 2nd @ 1.05 inches
November
0.80
5 days of precipitation; highest precipitation on November 7th @ 0.26 inches
December
0.16
2 days of precipitation; highest precipitation on December 3rd @ 0.08 inches
*This does not include 0.28 inches recorded on October 17th because of semi-annual calibration of the weather station.
STORM WATER MANAGEMENTEnergySolutions reported storm water accumulations occurred during the 2ndhalf of 2023, with a total of 429,800 gallons of storm water being managed during this
period, in accordance with the requirements of the GWQDP.
FACILITIES
This narration documents facility activities within the restricted area through the second half of 2023. For the most part, these are divided into (i) waste-handling facilities, (ii)
wash (decontamination) facilities, and (iii) evaporation ponds for the purposes of Division BAT inspections.A brief review of the BAT records for each facility is provided below.
Containerized Waste Storage Pad: The CWSP was taken out of service on January18, 2013. When a facility is out of service it is not used for any waste operations, and since waste is not
associated with the facility at that time the BAT inspections are not conducted. It remained out of service during the second half of 2023.
Intermodal Unloading Facility: In June, the dividing wall between southeast and southwest bays of the IUF were observed to have structural integrity issues. In July the dividing wall

was removed and repaired. Following repairs and inspection, the IUF was put back into service on August 8, 2023. All other information provided in the 2ndSemi-Annual Best Available Technology
Monitoring Report for July through December 2023 documents compliance with BAT performance standards.
Intermodal Unloading Facility Lift Station: Three instances were noted of the visual alarm being activated. A blockage caused a false alarm on September 21, 2023, due to 0.38 inches
of precipitation; maintenance removed the blockage and reset the alarm. A second blockage caused a false alarm on September 23, 2023, due to 0.16 inches of precipitation; maintenance
removed the blockage and reset the alarm. On October 2, 2023, high precipitation overwhelmed the pumps, triggering the visual alarm. After the storm event (the same day), the water level
dropped, and the alarm deactivated. This was done in accordance with the BAT contingency plan, Appendix K of the GWQDP. All other information provided in the 2ndSemi-Annual Best Available
Technology Monitoring Report for July through December 2023 documents compliance with BAT performance standards.
Intermodal Container Wash Building:The 20232ndSemi-Annual BAT Monitoring Report indicates that for this period free drainage conditions were found throughout the facility, water was
maintained below the grate of the sediment basin, and the integrity of the concrete floor was good.Operations associated with the East Side Drainage System, including the Intermodal
Container Wash Facility, were suspended on September 11, 2023, to perform the annual pipe pressure testing as required by Part 4.16.7 of GWQDP, Appendix J. System operation and the operation
of associated facilities resumed on September 11, 2023, following the conclusion of the test.Information provided in the 2ndSemi-Annual Best Available Technology Monitoring Report for
July through December 2023 documents compliance with BAT performance standards.
Rail Wash Facility on Track No. 4: During a December inspection, cracks in the floor of the facility were observed by facility staff. DWMRC determined this to not be out of compliance.
Seek-a-flex was applied to cracks. This was done in accordance with the BAT contingency plan, Appendix K of the GWQDP. All other information provided in the 2ndSemi-Annual Best Available
Technology Monitoring Report for July through December 2023 documents compliance with BAT performance standards.
Rail Digging Facility:The Rail Digging Facility was taken out of service on April 1, 2021.Following the inspection of the surface integrity and repair of identified defects, the Rail
Digging Facility was placed back into service on October 2, 2023.Information provided in the 2ndSemi-Annual Best Available Technology Monitoring Report for July through December 2023
documents compliance with BAT performance standards.
East Truck Unloading Area: Daily EnergySolutions inspections reported that free-draining conditions existed from the concrete containment pad to the collection troughs, that the pads
were always free from dirt and debris, that integrity of pad and other exposed surface in the East Truck Unloading Area was good, and that dates on all containers stored on the concrete
pads had the current Bates label.Information provided in the 2ndSemi-Annual Best Available Technology Monitoring Report for July through December 2023 documents compliance with BAT performance
standards.
Decontamination Access Control Building:The Decontamination Access Control Building was taken out of service in late 2013 and was out of service for the duration of the 2023 2nd Semi-Annual
BAT Monitoring Report.
Shredder Facility: Daily EnergySolutions inspections of this facility documented that water drained to the shredder facility's catch basins (which were relatively free from dirt and
debris), that water levels were below the catch basins' grates, that no leakage existed in pipes from the manhole to water storage tank, and that alarms were not activated during an
inspection. The integrity of the concrete surface was noted in all inspections. The water-storage tank alarms were checked within a 30-day time period.Information provided in the 2ndSemi-Annual
Best Available Technology Monitoring Report for July through December 2023 documents compliance with BAT performance standards.
Rotary Dump Facility:During a high precipitation event on October 2nd (October’s highest day of precipitation – see Table 1), stormwater overwhelmed the pump’s capacity, resulting in
water levels rising above the grate of the sediment basin. Water levels dropped after the storm even (the same day). This was done in accordance with the BAT contingency plan, Appendix
K of the GWQDP. All other information provided in the 2ndSemi-Annual Best Available Technology Monitoring Report for July through December 2023 documents compliance with BAT performance
standards.
Gray Water Tank in the LLRW Operation Building:EnergySolutions inspections indicated no problems with drainage or with the tank at the LLRW Operation Building.Annual inspection of the
gray water tank level alarm and leak detection verification system was performed on August 10, 2023.Information provided in the 2ndSemi-Annual Best Available Technology Monitoring Report
for July through December 2023 documents compliance with BAT performance standards.
East Side Drainage System:During EnergySolutions inspections in October, two issues were reported. First, water was noted in Manhole #1 and was removed that same day. During the same
inspection, it was noted that the visual alarm light was burned out and was replaced two days later on October 12, 2023. During a November inspection of the Manhole #2 Vault, water was
observed in the sight glass canister, believed to be a result of condensation. The leak detection sensors were replaced, water was removed, and the canister was cleaned. These were done
in accordance with the BAT contingency plan, Appendix K of the GWQDP. Annual inspection/pressure test of East Side Drainage System was performed on September 11, 2023. All other information
provided in the 2ndSemi-Annual Best Available Technology Monitoring Report for July through December 2023 documents compliance with BAT performance standards.
Evaporation Ponds:Narrative for the individual EPs and results from BAT inspections reported in the BAT report are summarized below.
1995 Evaporation Pond:During the reporting period, the recorded fluid head measurements did not exceed the allowable limit. Average daily flows did not exceed the pump-test limit and
did not exceed the maximum allowable flow. During the reporting period, there were no apparent trends that might forecast a potential leakage to the groundwater from the facility. EnergySolutions
has maintained compliance with the GWQDP BAT performance standards for leak detection system flow volume at the 1995 Evaporation Pond. On October 16, the pond leak detection system fluid
head process unit displayed and error – this was resolved by replacing the leak detection system pump. On December 12, it was noted that the Transducer had failed, it was reset and put
back into service. Both incidents were corrected in compliance with the BAT contingency plan, per Appendix K of the GWQDP.
1997 Evaporation Pond:During the reporting period, the recorded fluid head measurements did not exceed the allowable limit. Average daily flows did not exceed the pump-test limit and
did not exceed the maximum allowable flow. During the reporting period, there were no apparent trends that might forecast a potential leakage to the groundwater from the facility. EnergySolutions
has maintained compliance with the GWQDP BAT performance standards for leak detection system flow volume at the 1997 Evaporation Pond.
2000 Evaporation Pond:During the reporting period, the recorded fluid head measurements did not exceed the allowable limit. Average daily flows did not exceed the pump-test limit and
did not exceed the maximum allowable flow. During the reporting period, there were no apparent trends that might forecast a potential leakage to the groundwater from the facility. EnergySolutions
has maintained compliance with the GWQDP BAT performance standards for leak detection system flow volume at the 2000 Evaporation Pond.
Mixed Waste Evaporation Pond:During the reporting period, the recorded fluid head measurements did not exceed the allowable limit.The average daily flows for the Mixed Waste Evaporation
Pond did exceed the initial action level of 160 gallons per day during the week of December 4- 12, 2023 with an average pump rate of 165.42 gallons per day. Per Appendix K of the GWQDP,
this was handled in accordance with the BAT contingency plan. The Mixed Waste Evaporation Pond did not exceed the maximum allowable flow of 171 gallons per day for any weekly calculation
during 2023. During the reporting period, there were no apparent trends that might forecast a potential leakage to the groundwater from the facility. EnergySolutions has maintained compliance
with the GWQDP BAT performance standards for leak detection system flow volume at the Mixed Waste Evaporation Pond.
Northwest Corner Evaporation Pond:During the reporting period, the recorded fluid head measurements did not exceed the allowable limit. Average daily flows did not exceed the pump-test
limit and did not exceed the maximum allowable flow. During the reporting period, there were no apparent trends that might forecast a potential leakage to the groundwater from the facility.
EnergySolutions has maintained compliance with the GWQDP BAT performance standards for leak detection system flow volume at the Northwest Corner Evaporation Pond.

Other BAT Monitored Facilities of Note
SRS Depleted Uranium Storage Building:The SRS DU Storage Building is designed to protect DU drums from the weather. The SRS DU Storage Building undergoes a daily inspection when storm
water is present to determine ifwater is within the building, to check to see if containers are compliant, and to verify surface integrity. The SRS DU Storage Building undergoes a monthly
inspection for surface integrity, container compliance, and the presence of water within the building. Multiple BAT issues were identified during the second half of 2023 at the SRS DU
Storage Building (See Table 2).
BAT DISCREPANCIES
The daily BAT records appear to be in accordance with the BAT Performance Monitoring Plan.
The content of the Report was compared to Appendix K, BAT Contingency Plan, of the Permit. Discrepancies identified in the Report (Table 2) were cross-checked with the daily inspection
forms and correspondence letters to verify that problems were addressed and corrected in accordance with Appendix K of the GWQDP.
Of note, uponreview of the BAT inspection records provided from October 30 toNovember 14, it was noted in every daily inspection report that holes wereobserved 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. In response to the Division’s February 7 RFI regarding thecurrent conditions of these facilities, it was found that the BAT Inspectorshad not received communication that the
holes had been repaired and therepairedholes were out of sight below the water surface. In their March 5response, EnergySolutions stated: EnergySolutions will work onimproving communication
between Compliance andInspectors regarding BATfacility repairs and the importance of accurate details on the BAT inspectionforms.
All incidents report in Table 2 were reported and no unidentified incidents were found.
Table 2. BAT Discrepancies and Resolution – LLRW and Mixed Waste Facilities
Table 2. BAT Discrepancies and Resolution – LLRW and Mixed Waste Facilities
COMPLIANCE STATUS
The 2nd Semi-Annual BAT review (Groundwater Module 7b) indicates compliance with GWQDP requirements, and no further action is required of EnergySolutions. During the period of July
to December 2023, EnergySolutions performed BAT performance monitoring in accordance with the GWQDP for facilities that have a potential to release pollutants to the groundwater. During
this reporting period, EnergySolutions noted relatively infrequent discrepancies with the BAT performance plan. Discrepancies were addressed in compliance with the GWQDP. All facilities
were operated in according to Best Management Practices andreported in compliance withPart I.H.20.
ISSUES
No compliance issues were discovered during the review. Therefore, there are no outstanding compliance issues as a result of GW Module 7b inspection.
REFERENCE
Review of EnergySolutions' 20232nd Semi-Annual BAT Monitoring Report, BAT Requirements of the Ground Water Quality Discharge Permit, No. UGW 450005, was submitted by Jon Anderson of
EnergySolutions to Douglas Hansen of the Division of Waste Management and Radiation Control. This document is identified internally within the Division in the D2 database as DRC-2024-004808
(pre-corrected version of report is DRC-2024-004694).EnergySolutions Reference Number is CD-2024-039.
SIGNATURE
Reviewed and Approved By:12/27/2024
____________________________________________________ _____________
Bailey Anderson, Hydrogeologist Date
Utah Division of Waste Management and Radiation Control
____________________________________________________ _____________
Larry Kellum, Program Manager Date
Utah Division of Waste Management and Radiation Control