DRC-2025-000616

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--------ENERGYSOLUTIONS ===============
February 20, 2025 CD-2025-034
Mr. Larry Kellum, Section Manager
Div of Waste Management
and Radiation Control
Division of Waste Management and Radiation Control
195 North 1950 West FEB 2 0 2025
Salt Lake City, UT 84114-4880
Subject: State-Issued Part B Permit EPA ID No. UTD982598898 -Condition
V.F.13 and Ground Water Quality Discharge Permit No. UGW450005 -
Condition I.H.6: 2024 Annual As-Built Reports for Radioactive Material
Licenses UT 2300249 and UT 2300478: Responses to a Request for
Additional Information
Dear Mr. Hansen:
EnergySolutions is pleased to respond to the Request for Information (RFI) 1 received
from the Low-Level Radioactive Material Section Manager regarding the 2024 Annual
As-Built Reports for the Mixed Waste Landfill, Class A West, and 11 e.(2) Disposal
Cells (submitted via CD-2024-241 ). These reports are submitted in accordance with
Condition V.F.13 of the state-issued Part B Pem1it for EPA ID No. UTD982598898 and
Condition I.H.6 of Ground Water Quality Discharge Permit No. UGW450005. The
reports include detailed calculations, drawings, and supporting data to meet the
compliance requirements outlined in these permits.
2024 Annual As-Built Report: lle.(2)
RFI 1) Figure "llE.(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.
Energy Solutions' Response: The referenced Engineering Drawing,
"11E.(2) OPEN CELL AREA," is dated February 4, 2025, accurately
reflecting the most recent update. Since the physical geometry of the
11 e.(2) embankment has remained unchanged for some time, this
drawing appropriately represents the conditions corresponding to the
2024 period. This update is included in the complete package for the
11 e.(2) Annual As-Built Report. No change in the most recent revision
date is waITanted.
1 Kellum, L. "State-Issued Part B Permit EPA ID No. UTD982598898 -Condition V.F.13 and Ground
Water Quality Di scharge Permit No. UGW450005 -Condition I.H.6: 2024 Annual As-Built Reports for
Radioactive Material Licenses UT 2300249 and UT 2300478 Req uest for Additional Information
(RFI)." (DRC-2025-000117). Letter to Vern Rogers of EnergySolutions from the Division of Waste
Management and Radiation Control. Salt Lake City, January 30, 2025.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 8411 I
[phone] • Fax: [phone] • www.energysolutions.com
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ENERGY SOLUTIONS
2024 Annual As-Built Report: Class A West (CAW) Embankment
Mr. Larry Kellum
CD-2025-034
February 20, 2025
Page 2 of 5
RFI 2) 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.
Energy Solutions' Response: The chart in "VOLUME OF WASTE
PLACEMENT" has been updated to reflect the correct "Overbuild
Volume (yd3)" for 2024. This update is included in revision 1 of the
CAW Annual As-Built Report.
RFI 3) Please provide the raw data for the spreadsheets displayed within
Attachment D.
Energy Solutions ' Response: The raw data for the Temporary and Final
Settlement analyses in Attachment D is electronically attached as an
Excel spreadsheet alongside the complete package for the CAW Annual
As-Built Report.
RFI 4) "PERMITTED EMBANKMENT WASTE LIMITS" and
"EMBANKMENT EARTHWORK BREAK LINES" are not shown
in drawing 24007 CO2 of Attachment E. Please revise the drawing to
include these features.
Energy Solutions ' Response: Engineering Drawing 24007-C02(1) has
been updated to include the waste limits and break lines. This revision is
included in the complete package for the CAW Annual As-Built Report.
RFI 5) 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 could be. Please revise the drawing to include these features.
Energy Solutions' Response: Engineering Drawing 24007-C03(1) has
been updated to explicitly show the Clay Liner in the cross-section of
Sample Line I. This revision is included in Revision 1 of the complete
package for the CAW Annual As-Built Report.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www .energysolutions.com
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ENERGY SOLUTIONS
Mr. Larry Kellum
CD-2025-034
February 20, 2025
Page 4 of5
RF/ 9) Figure in Attachment B displays different hatching from Drawing
24009 CO2 within Attachment D. Drawing 24009 CO2 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.
Energy Solutions ' Response: Engineering Drawing 24009-C02(1) has
been updated to align with field conditions and the Mixed Waste Active
Waste Placement Area figure in Attachment B. This revision is included
in the complete package for the Mixed Waste Annual As-Built Report.
RFl 10) Figure within Attachment B indicates an updated date of
August 8, 2024, which is approximately two months prior to dates
used to create Drawing 24009 CO2 (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.
EnergySolutions ' Response: The figure in Attachment B, "Mixed Waste
Active Waste Placement Area," has been updated as described in the
response to RFI 9. The revi sed figure, dated January 9, 2025, aligns with
the aerial imagery from October 2, 2024, used in the Annual Report and
associated drawings. This update is included in Revision 1 of the
complete package for the Mixed Waste Annual As-Built Rep011.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
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ENERGY SOLUTIONS
Mr. Larry Kellum
CD-2025-034
February 20, 2025
Page 5 of 5
Energy Solutions appreciates the Section Manager's ongoing review of the 2024 As-Built
Reports. Please contact me at [phone] with any questions regarding these
responses.
Sincerely,
Vern C.
Rogers
Yem C. Rogers
Digitally signed by Vern C. Rogers
ON: cn=Vern C. Rogers, o=EnergySolutions,
ou=Waste Management Division,
email=[e-mail], c=US
Date: 2025.02.20 08:24:1 0 •07'00'
Director, Regulatory Affairs
enclosures
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance
with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.
299 South Main Street, Suite 1700 • Salt Lake City , Utah 84111
[phone] • Fax: [phone] • www .energysolutions.com