DRC-2025-000011

EnergySolutions' 2024 Annual IUF Floor Inspection,
BAT requirements of the Ground Water Quality Discharge Permit, No. UGW 450005,
Groundwater Module 5 Inspection
INSPECTION REPORT FOR:
EnergySolutions, LLC
299South Main Street, Suite 1700
Salt Lake City, UT 84111
[phone]
DATE (S) OF INSPECTION:
July 26, 2024(North Bay, Bays 1 and 2 only)
December 3, 2024 (South Bay, previously Bays 3 and 4)
FACILITY ADDRESS:
EnergySolutions LLC
Clive Disposal Site
Interstate 80, Exit 49
Clive, UT 84029
FACILITY CONTACT:
Nick Clarke
Clive SiteCompliance Specialist
[phone]
[e-mail]
NOTIFICATION:
The southern half of the Intermodal Unloading Facility was initially taken out of service to assess conditions of the southern bay wall on June 3rd, 2024. In a letter dated June 26,
2023, EnergySolutions requested a variance to the GWQDP Appendix J requirement to complete the annual IUF floor inspection during the second quarter (DRC-2024-006059). This was approved
by the Division with the requirement that repairs and inspection of the north bay of the IUF would be completed by July 31, 2024, and that EnergySolutions would submit a Corrective Action
Plan (CAP) to make repairs to the southern half of the facility. On July 16, 2024,Nick Clarkeof EnergySolutions notified the Division via email that EnergySolutions’would take the north
bay of the Intermodal Unloading Facility (IUF) out of operationon July 18, 2024in preparation for the annual inspection of the IUF floors on July 26, 2024.
After the post-repair inspection of the north bay of the IUF Nick Clarke notified the Division via email that EnergySolutions’ would put thenorth bay of theIUF back into service on July
29, 2024. The Division received EnergySolutions’ CAP regarding modifications to the southern half of the facility and approved these modifications on October 15, 2024 (DRC-2024-006995).

Post-construction and annual inspections of the southern half of the IUF facility were performed bythe Division on December3, 2024 and the Division received a notification by email from
Nick Clarke that the facility would be put back into service December 10, 2024.
APPLICABLE REQUIREMENTS:The State of Utah has issued two Radioactive Material Licenses, UT2300249 and UT2300478, to EnergySolutions’ for its Clive Site. Additionally, because EnergySolutions’
Clive Site has been determined to have the potential tocontaminate groundwater, requirements of Utah Administrative Rules for Water Qualityare applied. Provisions and requirements for
groundwater quality protection are found in UAC R317-6, Utah Administrative Rules for Ground Water Quality Protection. The EnergySolutions’ Clive Site has been issued a State of Utah
Ground Water Quality Discharge Permit, No. UGW450005 (Permit).
Technologicaldesign and control measures are used in the construction of facilities at the Clive Siteto prevent discharges of potentially contaminated water to the ground and, ultimately,
togroundwater. EnergySolutions operates and maintains the IUF at the Clive disposal Site in accordance with Best Available Technology (BAT) requirementsas identified in Part 1.E.10 and
Appendix J of the Permit. Part 1.E.10 and theBAT Monitoring Plan(Appendix J) provides a description of the facility, performance criteria, compliance points, inspection frequency, and
requires documentation of inspections. Section 4.10 of Appendix J requires the IUFbe inspected annually during the second quarter of the year to ensure the integrity of concretesurfaces
(see Narrative).
TYPE OF INSPECTION:
This is an annual inspectionand is coordinated with EnergySolutions’ staff. The IUF floors are inspected against BAT requirements ofthe Permit as identified inPart 1.E.10 and Appendix
J of the Permit.
PARTICIPANTS:
Bailey Anderson
LLRW Section, Utah Division of Waste Management and Radiation Control
Charles Bishop, P.G, Hydrogeologist,
LLRW Section,Utah Division of Waste Management and Radiation Control
Tyler Hegburg
LLRW Section, Utah Division of Waste Management and Radiation Control
Carlo Romano
LLRW Section, Utah Division of Waste Management and Radiation Control
Andrew Zehr
LLRW Section, Utah Division of Waste Management and Radiation Control
Nick Clarke
Clive Site Compliance Specialist
[phone]
WEATHER CONDITIONS:
On July 26, 2024, temperature 77.47°F at 9:26 AM, wind 6.16 mph out of southwest, overcast skies and dry conditions.

On December 3, 2024, temperature 32.13°F at 10:34 AM, wind 2.09 mph out of the southwest, partly cloudy and dry conditions.
REPORT PREPARED BY:
Bailey Anderson
LLRW Section, Utah Division of Waste Management and Radiation Control
SITE and FACILITY 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 IUFis in the east-central area of section 32, Township 1 South, Range 11 West, SLBM (Figure 1). The IUFis an open and exposed facilityused forthe unloading of bulk waste fromstorage
containers and loading of bulk waste into trucks.IUFconcrete floors are found in the upper unloading/storage pads, four lower bays, waste loading area, and two sets of ramps that allow
rucks to get in and out of the facility. No water is utilized in operations at the IUF. Stormwater that falls on the IUF drainsfrom the concrete floors to a collection sump on the west
side of the facility, from which a sump pumppumps water through a drain line to the IUF lift station.
CREDENTIALS, PURPOSE AND SCOPE:
The IUFsupports operations at the Clive Site andis a potential source of contaminated water that could contact the ground and reach groundwater, causing deterioration of groundwater
quality in the vicinity of the Clive Site. The Permit requires facilities to use technology-based design, construction, and operations to minimize the potential release of contaminants.As
part of the Clive Site’s BAT requirements, EnergySolutions conducts inspections and maintenance programs at wastehandling, washing, and waste-water pond facilities.
The purpose and scope of this inspection is to verify the integrity of the IUF concrete floors andensure conditions do not allow contaminated water to contact the ground surface or infiltrateto
groundwater;therefore, this report provides an assessment of floor conditions at the EnergySolutions’ Clive IUF.
MANAGEMENT ACTIVITIES:
The IUFhandles bulk waste shipped in containers (containerized waste) to EnergySolutions’ Clive Site. IUF activities include containerized waste being placed on the concrete upper unloading
pads, dumping of container waste from theunloading pads onto one of four lower bays floors, and loading of waste into trucksfor disposal at an embankment. Container storage can occur
on concrete pads or in bays.
The IUFis taken out of service and inspected annually during the second quarter of the year to ensure the integrity offloor and ramp concrete surfaces. If areas needing repair are noted,
per definitions listed Appendix J of the Permit, repairs are made prior to resuming the use of the facility.
Figure 1. EnergySolutions’ facilities at the Clive Site. TheIUFis in the east central area of Section 32,Clive Waste Disposal Site.
NARRATIVE:
The south half of the IUF was placed out of service on June 03, 2024, in preparation for the 2024 annual inspection, at this time, cracks were observed in the concrete on the Southwest
wall of the south bay. In a letter dated June 26, 2023, EnergySolutions requested a variance to the GWQDP Appendix J requirement to complete the annual IUF floor inspection during the
second quarter in order to make necessary repairs to the facility (DRC-2024-006059). This was approved by the Division with the requirement that repairs and inspection of the north bay
of the IUF would be completed by July 31, 2024, and that EnergySolutions would submit a Corrective Action Plan (CAP) to make repairs to the southern half of the facility on August 10,
2024 (DRC-2024-006150).
North Bay Inspection
On July 16, 2024,Nick Clarke of EnergySolutions notified the Division via email that EnergySolutions’ would take the north bay of the Intermodal Unloading Facility (IUF) out of operationon
July 18, 2024 in preparation for the annual inspection of the IUF floors on July 26, 2024. EnergySolutions completed the pre-inspection of the IUF independently, which consisted of removing
all wastecontainers and bulk waste from the facility (upper unloading pads, and waste from all bays and loading area), cleaning the floors, and making any repairs needed to maintain
floor integrity. The Division participated in the post-repair inspection of the north bay of the IUF on July 26, 2024.
At 9:10AM on July 26, 2024, Division staff memberBailey Anderson and EnergySolutionsClive Site Compliance Specialist Nick Clarke conducted the opening meeting at the Clive Site administration
building, during which Bailey Anderson identified herselfas an inspector of the Division and provided an explanation for the purpose of the inspection. Division staffBailey Anderson,
Charles Bishop, and Tyler Hegburg were accompanied byNick Clarke inside the restricted area for the post-repair inspection of EnergySolutions’ IUF.Theinspection consisted of walking
the IUF’s cleaned and repaired concrete surfaces, walls and ramps, evaluating repairs made by EnergySolutions during the pre-inspection, and identifying any additional areas judged in
need of repair; floor areas needing repairs were identified and marked. Areas identified by Division staff as needing additional repairs were addressed by EnergySolutionsmaintenance
staff at the time of the inspection andrepairs were observed by Division staff.Repair material used during the repair of the IUFfloors consisted of a concrete and small gravel mixture,
and/orSikaflex elastic sealant. These have been used for several years to repair floors and seal cracks and small ruptures in concrete at Clive Site. Additional photos of repairs were
provided by Nick Clarke upon completion.After the post-repair inspection of the IUF by Division staff, Nick Clarke notified the Division via email that EnergySolutions’ would put the
North Bay of the Intermodal Unloading Facility on July 29, 2024.
South Bay Inspection
The Division received EnergySolutions’ CAP regarding modifications to the southern half of the facility and approved these modifications on October 15, 2024 (DRC-2024-006995). Post-construction
and annual inspections of the southern half of the IUF facility were performed by the Division on December 3, 2024. On December 3, 2024, at 10:10 AM, Division staff member Bailey Anderson
and EnergySolutions Operations Manager Dave Booth conducted the opening meeting at the Clive Site administration building. Bailey Anderson identified herself as an inspector of the Division
and provided an explanation for the purpose of the inspection.
Division staff Bailey Anderson and Andrew Zehr were accompanied byNick Clarke and Mike Van Wagoner inside the restricted area for the post-repair inspection of EnergySolutions’ IUF.
The inspection consisted of walking the IUF’s cleaned and repaired concrete surfaces, walls and ramps. Few areas requiring additional repair were identified by Division staff and repaired
using Sikaflex at the time of the inspection. The closeout meeting was conducted by Bailey Anderson and David Booth upon completion of the inspection before leaving the facility. The
Division received a notification by email from Nick Clarke that the facility would be put back into service December 10, 2024.
COMPLIANCE STATUS:
All areas needing repairs were repaired. The north bay and south bays of the Intermodal Unloading Facility werefound to be in compliance with the Permit during this BAT inspection and

were put back into service on July 29, 2024 and December 10, 2024, respectively.
ISSUES:
No compliance issues with the north bay of the IUF were discovered during the inspection. Therefore, there are no outstanding compliance issues as a result of GW Module 5 inspection.

SIGNATURE:
Prepared By:1/2/2025
_______________________________________________________
Bailey Anderson, Hydrogeologist,Date
LLRW Section
Utah Division of Waste Management and Radiation Control
Reviewed and ApprovedBy:
________________________________________________________
Larry Kellum, Program Manager Date
LLRW Section
Utah Division of Waste Management and Radiation Control