DRC-2025-000202

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com
January 15, 2025 CD-2025-010
Mr. Doug Hansen, Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880
Subject: Ground Water Quality Discharge Permit No. UGW450005 (GWQDP);
Radioactive Materials License UT 2300249: Response to Compliance Advisory
No. 2412004
Dear Mr. Hansen:
The two apparent compliance issues discovered during the compliance evaluation
inspection on November 5, 2024 which led to Compliance Advisory No. 2412004, dated
December 26, 2024, are addressed below within the 30-day time frame.
During the inspection the Division staff found that,
“…inspections of the East Side Truck Unloading Facility were included as part of
the BAT Monthly Inspection Forms and were being performed monthly, rather
than weekly, as required in Appendix J Table 1 of the Permit.”
The Director also stated that,
“Requested Corrective Action: Please return the inspection of the East Side
Truck Unloading Facility to a weekly basis.”
EnergySolutions acknowledges this as a clerical error and has revised the BAT
Inspections of the East Side Truck Unloading Facility to a weekly basis from a monthly
basis and has trained inspectors on the change so that they are consistent with Table 1 of
Appendix J.
For the second concern, the Director stated that,
“Upon reviewing the BAT records provided on November 5, 2024, Division staff
noted that the transducer and flow meter readings at the Mixed Waste Surface
Impoundment Facility were unchanged from the previous BAT Field
Accompaniment Inspection with Division staff on December 3, 2023. For this
reason, additional records were requested from the EnergySolutions Quality
Assurance Manager, and it was identified that the flow meter reading at the Mixed
Waste Surface Impoundment facility had not changed since an inspection by
EnergySolutions on October 28, 2019.”
Mr. Doug Hansen
January 15, 2025
CD-2025-010
Page 2 of 2
While also providing the following corrective action,
‘Please provide reasoning for why this issue at the Mixed Waste Surface
Impoundment Facility may be occurring, as well as verification that the Mixed
Waste Surface Impoundment Facility flow meter is functional and pump back
system is operating as designed.”
EnergySolutions appreciates the thorough evaluation however, the Mixed Waste Surface
Impoundment (Impoundment) primary purpose is used to store or treat, by evaporation,
hazardous waste in accordance with Module IV, Storage and Treatment in Tanks and
Surface Impoundments, of the Part B Permit. The Impoundment is unique as it does not
automatically receive storm water runoff from precipitation events and does not receive
contact water discharged from any facility. Any liquids placed into the Impoundment are
manually discharged by the Mixed Waste Vac Truck and typically consist of leachate
from the Mixed Waste leachate sumps. This limits the amount of liquids placed into the
Impoundment, and historically these amounts do not lend themselves to much change in
the water elevations within the impoundment. The Impoundment, constructed in 2012
and completed in 2013, is relatively new compared to other facilities (ponds) at the Clive
Site. The Impoundment has successfully maintained its integrity and continues to not
show signs of leaks and other deficiencies within its leak detection equipment and
containment.
EnergySolutions site procedure, Mixed Waste Site Inspection, CL-MD-PR-211 F4 records
the daily Inspection that includes verification of the of the leak detection system pump,
pump controller, head/pressure transducer, and flow meter equipment. By performing
these required inspections on a daily basis (when in operation), EnergySolutions can
confidently confirm that the Impoundment readings are accurate, and by continuing to
follow the Part B Permit approved inspection plan, any potential leaks or issues will be
detected at that time. To back up this claim, on January 13, 2025, Clive Maintenance
personnel performed an inspection using a borescope verifying that the Impoundment
leak detection sump head/pressure transducer was positioned correctly and the water
level within the sump remained below the head/pressure transducer. The inspection
revealed that there was no water in the sump. The display reading prior to the inspection
was 0.25 ft. The pump was moved and repositioned within the sump resulting in the
display reading changing to 0.17 ft. indicating the instrumentation is working.
EnergySolutions appreciates the Divisions attention to detail on this matter but finds the
current inspection requirements as satisfactory and sufficient in the future to remain
compliant and to continue to protect human health and the environment within the
Impoundment.
Mr. Doug Hansen
January 15, 2025
CD-2025-010
Page 3 of 2
Should you have any questions regarding this response, please contact me at (801) 649-
2060.
Sincerely,
Mathew R Schon
Manager, Groundwater and Environmental Program
cc: Charles Bishop (DWMRC)
Bailey Anderson (DWMRC)
Brandon Davis (DWMRC)
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.