DRC-2025-000117

January 7, 2025Vern C. Rogers, Director, Regulatory AffairsEnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
RE:State-issued Part B Permit EPA ID No. UTD982598898 – Condition V.F.13 and Ground Water Quality Discharge Permit UGW450005 - Condition I.H.6: 2024 Annual As-Built Report for the Radioactive
Material Licenses UT2300249 and UT2300478
Request for Additional Information (RFI)
DearMr. Rogers:
The Division of Waste Management and Radiation Control (Division) has received your letter dated November 25, 2024 (CD-2024-241/DSHW-2024-009345) submitting the 2024 Annual As-Built
Reports for the Mixed Waste Landfill, Class A West and 11e.(2) Disposal cells. The submission of these Reports are required per Condition V.F.13 of the state-issued Part B Permit for
EPA ID No. UTD982598898 and Condition I.H.6 of Ground Water Quality Discharge Permit No. UGW450005. The As-Built Reports included detailed calculations, drawings, and data to support
requirements set outout by the aforementioned Conditions in their respective compliance documents.
A Division representative has completed a review of each of the As-Built Reports. During the review, the representative encountered some anomalies that require additional information.
The Division requests for additional information prior to completing the review of the As-Built Reports. Below are the following RFIs organized by disposal cell:
2024 Annual As-Built Report: 11.e(2)
Figure “11E.(2) OPEN CELL AREA” within Attachment B indicates an updated date of November 14, 2021. Imagery date is not within a satisfactory range to be considered representative for
this report. Please update the figure to correspond with the appropriate 2024 period dialogue of the report.
2024 Annual As-Built Report: Class A West Embankment
The chart located in “VOLUME OF WASTE PLACEMENT” appears to document an “Embankment Overbuild Volume” in the year of 2022 and not 2024. Furthermore, the value indicated of 1,750 appears
to be the “Overbuild Volume (yd3)” value from Oct-23 based on the “ANNUAL AS-BUILT VOLUMES (RUNNING TOTALS)” located in Attachment C. Please revise values as needed or justify the use
of this value.
Please provide the raw data for the spreadsheets displayed within Attachment D.
“PERMITTED EMBANKMENT WASTE LIMITS” and “EMBANKMENT EARTHWORK BREAK LINES” are not shown in drawing 24007 C02 of Attachment E. Please revise the drawing to include these features.
Within Attachment E: Drawing 24007 C03; Section View for Sample Line 1 does not showcase the Clay Liner in the cross section, however, there is a leader drafted in the general area of
where it possibly be. Please revise the drawing to include these features.
Within Attachment E: Drawing 24007 C10;Section View for Sample Line 16 does not indicate the southern RUNOFF BERM for the CWF similarly indicated on Section View for Sample Line 15.
Please revise the drawing or provide a response to this RFI if the feature does not exist in this section.
Within Attachment E: Drawing 24007 C11; Section View for Sample Line 19 does not indicate the southern Final Ditch or Berm for the south edge of the CAW embankment.Please revise the
drawing or provide a response to this RFI if the feature does not exist in this section.
2024 Annual As-Built Report: Mixed Waste Embankment
Figure in Attachment B displays a light yellowish boundary line around the “Final Cover (Rock limits)”. Please clarify what this line indicates and revise the figure as needed.
Figure in Attachment B displays different hatching from Drawing 24009 C02 within Attachment D. Drawing 24009 C02 displays a section of “ACTIVE WASTE AREA” towards the south section of
the embankment that does not correspond to the figure in Attachment B. Please revise drawings to be consistent with one another.
Figure within Attachment B indicates an updated date of August 8, 2024 which is approximately two months prior dates used to create Drawing 24009 C02 (October 2, 2024). It is unclear
to the Division if the Figure is appropriate given the inconsistencies found in RFI 9. Please revise the figure and/or justify the use of this date.
Please provide a response to these RFIs and resubmit reports when revisions are made. Upon receipt of the revised reports, the Division will complete a follow-up review of the reports
and provide feedback. If you have any questions, please call Carlo Romanoat 385-977-7573.
Sincerely,
Larry Kellum, Section Manager
Division of Waste Management and Radiation Control
LK/CR/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