DRC-2025-000280

January 27, 2025Vern C. Rogers, Director of Regulatory AffairsEnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
RE:Groundwater Quality Discharge Permit (GWQDP) UGW450005: Intermodal Unloading Facility Construction Report and As-Built Drawings
DearMr. Rogers:
The Division of Waste Management and Radiation Control (Division) has received your letter dated December 6, 2024 (CD-2024-241/DSHW-2024-009345) submitting the Intermodal Unloading Facility
(IUF) Construction Report and As-Built Drawings. The submission of this report and drawing packageis required per Part IV.C of Ground Water Quality Discharge Permit No. UGW450005. The
package included detailed accounts of the construction sequences and materialsfor the modifications of the IUFwith drawings depicting the results of construction. The Division has reviewed
the package for accuracy, consistency, and precision associated with the events of the construction of the modification of the IUF.
Discussion: Construction Timeline
EnergySolutionsDesign Proposal and Correspondence
EnergySolutionssubmitted a Request for Approval to Modify Facility and Request for Approval of GWQDP Modification (CD-2024-148/DRC-2024-006306) dated July 17, 2024. Prior to agreement
with the Division, the Division requested additional information(RFIs)which initiated correspondence between EnergySolutions and the Division to revise the initially submitted drawings
to provide clarity to the intentions of design elements for the modifications of the IUF. The chronological sequence of correspondence is listed below:
First Round of RFIs by the Division dated August 19, 2024 (DRC-2024-006544)
EnergySolutions’ Response dated August 21, 2024 (CD-2024-172/DRC-2024-006647)
Second Round of RFIs by the Division dated September 18, 2024 (DRC-2024-006740)
EnergySolutions’ Response dated September 26, 2024 (CD-2024-205/DRC-2024-006990)
The Division took into consideration the information and clarity provided by EnergySolutions and ultimately responded with an approval to proceed with construction via letter dated October
15, 2024 (DRC-2024-006995). The letter stated a list of conditions for construction and post-construction to lead to an approval of the modification of the GWQDP.
Division Site Visits & Key Events
During the course of construction, representatives of the Division,Bailey Anderson and Carlo Romano, conducted a number of site visits to confirm construction sequences correspond to
the submitted plans and responses to the RFIs. The representatives visited the site on the following days: October 28, October 30, November 5, and November 18. Wollam Construction was
the General Contractor hired by EnergySolutionsto complete this project with the addition of their subcontractors and EnergySolutions personnel.
Duringan initial site visit by the Division on October 28, 2024, EnergySolutions was operating on the North Wall installing reinforcement bars and formwork in preparation for a future
concrete pour. The Division observed a portion of the center dividing wall that was within the footprint of the modification. This was not observed or noted in the submitted approved
drawings and the Division was unaware of this existing structure as part of construction. The Division notified EnergySolutions to which EnergySolutions responded they would include
this anomaly in the As-Built reports submission. The Division agreed with this approach.
The Division conducted another site visit on November 18, 2024, to examine the results of the drainpipe installation.Drain holes were core-drilled from both walls without a pipe inserted
into the wall. The Division noted this to EnergySolutions in which this deviated from the originally submitted and approved drawings. EnergySolutionsproposed to sleeve the drain holes
with a 4-inch outer diameter – 3.5-inch interior diameter Schedule 40 PVC pipe and sealed to the concrete walls following insertion. The Division agreed with the approach and EnergySolutions
were to include this in the As-Built Report.
Construction concluded and the Division conducted a “Best Available Technology” (BAT) Inspection on December 3, 2024. The results of that inspection are included under a separate letterhead
sent to EnergySolutions.EnergySolutionsreturned the IUF to active service in December 2024.
Division Review of Submission
The Intermodal Unloading Facility (IUF) Construction Report and As-Built Drawings has been reviewed by the Division. The general sentiments of the Construction Report appear to accurately
reflect the construction sequences, materials, key events, and concluding dimensions of the newly constructed modification. Product data sheets, certifications from subcontractors, and
project photos were also included in the report and appropriately complement the report with omission of one concrete construction aspect (elaborated below). The As-Built Drawings were
attached at the end of the package that appear to appropriately detail current conditions of the newly renovated IUF as well as provide an update on the
The only information that was omitted from the report was the 28-day compressive strength data for the concrete poured for the South Wall. The omitted information was requested by the
Division on January 8, 2025 to which EnergySolutions promptly responded to by sending an electronic copy (DRC-2025-000261)of the updated compression strength data sheet that included
the 28-day strength values for the compression testing completed for the South Wall. The results showcased that the concrete did not meet the design criteria set forth by the supplier
and yielded a result less than 4500-psi. The results, however, were greater than the required design 28-day compressive strength of 4000-psi and meet the requirements of the project.
Conclusion
In conclusion, the submitted Intermodal Unloading Facility (IUF) Construction Report and As-Built Drawings appear to be in compliance with the conditions set forth by the GWQDP and conditions
set forth by pre-construction correspondence letter dated October 15, 2024 (DRC-2024-006995). The Modifications to the IUF are hereby approved and the GWQDP shall be modified to reflect
the renovations completed for the IUF North and South Walls.
If you have any questions, please call Carlo Romanoat 385-977-7573.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/CAR/wa
Enclosure(s):
c:Jeff Coombs, EHS, Health Officer, Tooele County Health DepartmentBryan Slade, Environmental Health Director, Tooele County Health DepartmentEnergySolutions General Correspondence EmailLLRW
General Correspondence Email