HomeMy WebLinkAboutDAQ-2025-0015971
DAQC-CI107170001-25
Site ID 10717 (B1)
MEMORANDUM
TO: FILE – ENERGYSOLUTIONS, LLC – Radioactive Material Disposal Site
THROUGH: Chad Gilgen, Minor Source Compliance Section Manager
FROM: Susan Weisenberg, Environmental Scientist
DATE: February 26, 2025
SUBJECT: FULL COMPLIANCE EVALUATION, Minor, Tooele County
INSPECTION DATE: February 13, 2025
SOURCE LOCATION: Clive Facility
Clive, UT 84029
DIRECTIONS: Located 70 miles west of Salt Lake City. Take the Clive Exit 49 on
west bound I-80. Turn left at the stop sign. Head south over the
bridge. Follow the road approximately 5 miles and then cross the
railroad tracks. Turn left at the intersection (heading east). Follow the
road until the EnergySolutions sign. Turn left onto the plant road.
Check in at the security gate.
SOURCE CONTACTS: Steve Gurr, Environmental Engineer
801-649-2043, sdgurr@energysolutions.com
Nick Clarke, Licensing and Compliance Specialist
801-649-2157, nwclarke@energysolutions.com
OPERATING STATUS: Normal operations.
PROCESS DESCRIPTION: EnergySolutions is a low-level radioactive and mixed waste
treatment, storage, and disposal operation. Radioactive or mixed
waste from various locations is transported to the source location via
over the road trucks or rail. Rail shipments arriving at the
source location are tested for moisture content at a rate of 20% with at
least one test being performed each day conveyances are unloaded.
Water is added to any shipment with moisture content less than 7%.
These shipments are then unloaded via a railcar rollover or by using a
hydraulic excavator. The waste is then loaded into large haul trucks
and transported to the source location's disposal embankments for
permanent burial. Low level waste placed into the embankment is
compacted using large sheep foot compactors to minimize future
settlement. Mixed waste is placed, compacted using any means
necessary, and tested using nuclear density gauge technology to
ensure minimal settling will occur. All over-the-road or rail
conveyances are decontaminated to meet specific DOT requirements
prior to being released back into service. The source is permitted to
treat and dispose mixed waste (radioactive waste with a hazardous
0 . ) $ . ) - "
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component). Mixed waste is treated to meet land disposal restrictions
using a variety of methods. These methods include stabilization,
macro encapsulation (encasing the waste in a proprietary concrete
mixture), and thermal desorption (indirect heating of the waste to
drive off organics). The thermal desorption unit is used to treat solid
and slurry wastes contaminated with both radioactive and hazardous
material. It employs a treatment system where the gases are filtered,
condensed, and discharged through the carbon adsorption system. The
waste stream is then routed through a primary filter and then to HEPA
filters before exiting to the air.
APPLICABLE REGULATIONS: Approval Order (AO) DAQE-AN107170021-19, dated
January 25, 2019
NSPS (Part 60) IIII : Standards of Performance for Stationary
Compression Ignition Internal Combustion Engines,
MACT (Part 63) -CCCCCC: National Emission Standards for
Hazardous Air Pollutants for Source Category: Gasoline
Dispensing Facilities,
MACT (Part 63) -ZZZZ: National Emissions Standards for
Hazardous Air Pollutants for Stationary Reciprocating Internal
Combustion Engines
SOURCE EVALUATION:
Name of Permittee: Permitted Location:
EnergySolutions, LLC
Radioactive Material Disposal Site
299 South Main Street, Suite 1700 Clive Facility
Salt Lake City, UT 84111 Clive, UT 84029
SIC Code: 4953: (Refuse Systems)
Section I: GENERAL PROVISIONS
I.1 All definitions, terms, abbreviations, and references used in this AO conform to those used in the
UAC R307 and 40 CFR. Unless noted otherwise, references cited in these AO conditions refer to
those rules. [R307-101]
Status: In Compliance.
I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401]
Status: In Compliance.
I.3 Modifications to the equipment or processes approved by this AO that could affect the emissions
covered by this AO must be reviewed and approved. [R307-401-1]
Status: In Compliance.
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I.4 All records referenced in this AO or in other applicable rules, which are required to be kept by
the owner/operator, shall be made available to the Director or Director's representative upon
request, and the records shall include the two-year period prior to the date of the request. Unless
otherwise specified in this AO or in other applicable state and federal rules, records shall be kept
for a minimum of two (2) years. [R307-401-8]
Status: In Compliance.
I.5 At all times, including periods of startup, shutdown, and malfunction, owners and operators shall,
to the extent practicable, maintain and operate any equipment approved under this AO, including
associated air pollution control equipment, in a manner consistent with good air pollution control
practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source. All maintenance performed
on equipment authorized by this AO shall be recorded. [R307-401-4]
Status: In Compliance.
I.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns.
[R307-107]
Status: In Compliance.
I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150]
Status: In Compliance. Based on the observations during the inspection and a review of the
submitted records, the AO limits were not exceeded. No modifications to the permitted
equipment have occurred since the previous inspection. Records are maintained for a
minimum of two years and provided at the time of inspection. The source appears to
maintain and operate the equipment in a manner consistent with good air pollution control
practices. No breakdowns have occurred since the previous inspection. The source
submitted the 2023 Emission Inventory by the required date.
Section II: SPECIAL PROVISIONS
II.A The approved installations shall consist of the following equipment:
II.A.1 EnergySolutions, LLC
Radioactive Material Disposal Site
II.A.2 Bulk Reagent System
Includes five (5) baghouses
Each with an air to cloth ratio of 5:1
II.A.3 Mixed Waste Treatment Building
Includes the following:
Shredders
Vibrating screens
Pulvi-Mixer (Tiller)
Controlled by a reverse jet baghouse with HEPA filter
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Air to cloth ratio 2.5:1
II.A.4 Mixed Waste Operations Building
Controlled by a baghouse with HEPA filter
II.A.5 Thermal Desorption Operations System
Includes the following:
One (1) thermal desorption unit
One (1) refrigerated condensation unit
One (1) ambient temperature condensation unit
One (1) LPG furnace rated at 3.0 MMBtu/hr
Water treatment tanks
Nitrogen storage tanks
Miscellaneous material handling equipment
Controlled by three carbon filters (one HEPA filter and two prefilter)
II.A.6 Batch Plant
Includes the following equipment:
180 cubic yard per hour batch plant controlled by a baghouse
Cement storage silo controlled by a baghouse
Cement storage silo controlled by a bin vent
15 ton per hour screen plant
Conveyors and cement trucks
II.A.7 Process Equipment
One (1) 100 ton per hour shredder with water sprays
II.A.8 Mixed Waste Area Silo
1,100 cf silo with baghouse
II.A.9 Railcar Rollover Operations
Constructed with enclosures that minimize fugitive dust
II.A.10 Railcar Digging Operations
II.A.11 Diesel-Fired Emergency Generator Engine
242 kW (324 hp) engine provides emergency power to the Administration Building
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ
II.A.12 Diesel-Fired Emergency Generator Engine
242 kW (324 hp) engine provides emergency power for the fire suppression pump
NSPS Applicability: Subpart IIII
MACT Applicability: Subpart ZZZZ
II.A.13 Lime Kiln Dust (LKD) Silo
1,400 cf portable silo equipped with an Airmax dust collector
II.A.14 Process and Mobile Equipment
Includes the following equipment:
6-wheel trucks
Bulldozers
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Front-end loaders
Backhoes
Compactors
Water trucks/tractors
Dump trucks (10-18 wheel)
Graders
Scrapers
Diesel locomotives
Concrete mixers less than one cubic yard each
Propane fired heaters rated less than 5.0 MMBtu/hr
Forklifts, cranes, generators, etc
This equipment listed for informational purposes only
Status: In Compliance. II.A.3 - the baghouse with HEPA filter at the mixed waste treatment
building vents internally. II.A.4 - mixed waste operations building is periodically
used as storage, however the HEPA filter system is maintained. II.A.5, the thermal
desorption operations system is owned and operated by a subcontractor, TDX
Contracting. II.A.10 - The Railcar Digging Operations have been taken out of
service.
II.B Requirements and Limitations
II.B.1 Clive Facility Requirements
II.B.1.a The owner/operator shall control all process streams from the Mixed Waste Operations Building
with the Mixed Waste Operations Building baghouse and HEPA filter. Emissions from all
process streams from the Mixed Waste Operations Building shall be routed to the operating
baghouse and HEPA filter before being emitted to the atmosphere. [R307-401]
Status: In Compliance. The Mixed Waste Operations Building is only used sporadically.
The HEPA filters are maintained to specifications.
II.B.1.b The owner/operator shall control all process streams from the Mixed Waste Treatment Building
with the Mixed Waste Treatment Building baghouse and HEPA filter. Emissions from all
process streams from the Mixed Waste Operations Building shall be routed to the operating
baghouse and HEPA filter before being emitted to the atmosphere. [R307-401]
Status: In Compliance. Emissions from the Mixed Waste Treatment Building are routed to
the baghouse and HEPA filter.
II.B.1.c The owner/operator shall not allow visible emissions from the following emission points to
exceed the following values:
A. 0% opacity for:
Baghouses with HEPA filters
Thermal Desorption System exhaust
Thermal Desorption System fugitives
B. 10% opacity for:
All screens
All conveyor transfer points
Bulk Reagent System and Waste Receiver Tank
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Baghouses without HEPA filters
Concrete batch plant
All silos
Shredders with a rating greater than 50 tons per hour
Entry/exit and ventilation openings at the covered Railcar Rollover Facilities
Transfer points at the Railcar Digging Facility
C. 20% opacity for:
Conveyor drop points
All stationary diesel engines
Shredders with a rating less than 50 tons per hour
All other points
[R307-201]
Status: In Compliance.
II.B.1.c.1 Opacity observations of emissions from stationary sources shall be conducted according to 40
CFR 60, Appendix A, Method 9. [R307-401-8]
Status: In Compliance. No opacity was observed during the inspection. Visible emissions
were observed according to 40 CFR 60, Appendix A, Method 9. Refer to the VEO form in
the attachments.
II.B.1.d The owner/operator shall not allow visible fugitive dust emissions from haul road traffic and
mobile equipment in operational areas to exceed 20% opacity at any point. [R307-201]
Status: In Compliance.
II.B.1.d.1 Visible emission determinations shall use procedures similar to Method 9. The normal
requirement for observations is to be made at 15-second intervals over a six-minute period,
however, shall not apply. Visible emissions shall be measured at the densest point of the plume
but at a point not less than ½ vehicle length behind the vehicle and not less than ½ the height of
the vehicle. [R307-401-8]
Status: In Compliance. Snowy conditions were present at the time of this inspection. No
fugitive dust emissions were observed from any haul road traffic or mobile equipment.
II.B.1.e The owner/operator shall only use diesel fuel (fuel oil #1, #2, or diesel fuel oil additives) in the
diesel-fired emergency engines. All diesel burned shall meet the requirements of 40 CFR
80.510(b). [40 CFR 60 Subpart IIII]
Status: In Compliance.
II.B.1.e.1 To demonstrate compliance with the fuel oil requirements, the owner/operator shall keep and
maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel
meets the ultra-low sulfur diesel requirements, or the owner/operator shall obtain certification of
sulfur content from the fuel supplier. [40 CFR 60 Subpart IIII]
Status: In Compliance. The source only uses ultra-low sulfur diesel. This was determined
from a fuel purchase invoice provided by Hales Oil.
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II.B.1.f The owner/operator may operate emergency engines for the purpose of maintenance checks and
readiness testing, provided that the tests are performed between the hours of 8:00 am to 5:00 pm
Mountain Standard Time. Maintenance checks and readiness testing of such units is limited to
100 hours per rolling 12-month period per engine. There is no time limit on the use of the
engines during emergencies. [40 CFR 60 Subpart IIII, R307-410]
Status: In Compliance. The Compliance and Licensing Specialist, Nick Clarke, stated that
the testing and maintenance checks only occur between the hours of 8:00 AM and 5:00 PM.
II.B.1.f.1 To determine compliance with a rolling 12-month total, the owner/operator shall calculate a new
12-month total by the 20th day of each month using data from the previous 12 months. Records
documenting the operation of each emergency generator or fire pump engine shall be kept in a
log and shall include the following:
A. The date and time of day the emergency generator or fire pump engine was used
B. The duration of operation in hours
C. The reason for the emergency generator or fire pump engine usage
[R307-401-8]
Status: In Compliance. The rolling 12-month totals for the period of February 2024
through January 2025 were reported as 40 hours minus 26 hours due to power outages for
the Fire Pumphouse and 54 hours minus 27 hours due to power outages for the
Administrative Building Emergency Generator. The emergency generator logs include the
date, time, meter read indicator, and reason for use. The standard maintenance and testing
schedule consist of 20 minutes a week per cycle run and 20 minutes a month for testing,
plus 4 hours annual testing for each generator. See the attached "Rolling 12-month diesel
engines" log.
II.B.1.f.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour
meter for each emergency generator and fire pump engine. [40 CFR 60 Subpart IIII]
Status: In Compliance. Non-resettable hour meters are installed on each engine. On the
day of this inspection, the Fire Pumphouse engine was read at 715.8. The Administrative
Building emergency engine was read at 502.7.
II.B.2 Production Limitations.
II.B.2.a The owner/operator shall not exceed the following process limits:
A. Amount of material disposed at the site shall not exceed 1,500,000 tons per
rolling 12-month period.
B. The total disturbed area shall not exceed 400 acres. Disturbed area shall be
all areas that have had the surface area mechanically altered. Total disturbed area
shall not include disturbed areas that have been inactive for at least six months or
that have been reclaimed by capping, chemical treatment, or revegetation. Total
disturbed area shall not include areas with buildings, parking lots, paved roads,
paved areas, evaporation ponds, or other areas with no emissions.
C. 100,000 cubic yards of concrete per rolling 12-month period.
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D. 7,300 hours of operation for bulldozing and compacting for cover/liner construction
per rolling 12-month period.
E. 250,000 tons of material for cover/liner construction per rolling 12-month period.
F. The total area for active storage piles shall not exceed 8.1 acres. All inactive
storage piles shall be those storage piles that have not had any material added to
or removed from them since the last time they were water sprayed and/or chemically
treated or they have not had any material added to or removed from them within the
last six months.
[R307-401]
Status: In Compliance.
II.B.2.a.1 To determine compliance with a rolling 12-month total EnergySolutions shall calculate a new
12-month total by the twentieth day of each month using data from the previous 12 months.
Material disposal and cover liner construction shall be determined by weigh scales and record
keeping. Compliance with total disturbed area shall be determined using engineering records.
Any time a change in total disturbed area exceeds 28 acres, the total disturbed area shall be
recalculated and recorded. The records shall be kept on a monthly basis and for all periods when
the plant is in operation. [R307-401-8]
Status: In Compliance. Calculations are made according to this condition. Refer to the
attachments for detailed totals. The totals for February 2024 through January 2025 were
submitted as follows:
A. Material Disposed: 116,060 tons
B. Total Disturbed Area: 241.8 acres
C. Concrete Produced: 14,670 cubic yards
D. Bulldozing and compacting for cover/liner construction: 430 hours
E. Material for cover/liner construction: 86,696 tons
F. Total Active Storage Pile Area: 4.4 acres
II.B.3 Road and Fugitive Dust Requirements
II.B.3.a The owner/operator shall maintain a spray bar or hose in place where bulk waste is being off-
loaded. The spray bar or hose shall operate whenever the moisture content of the material in the
rail cars is below 7%. If a spray bar or hose is used for all waste off-loaded at a specific area of
the site, moisture content testing shall not be required for waste entering that area. [R307-401-8]
Status: In Compliance.
II.B.3.a.1 If required, the moisture content test shall be determined according to ASTM Method D-2216,
D-4643, or D-3017 on the 40 mesh portion of the sample. Moisture content testing shall be
performed on at least every fifth rail car that comes to the site and at least one test shall be run
every day that cars are unloaded at the site. The spur located south of the mainline shall be used
to store the cars that require spraying. Records of moisture content tests shall be kept for all
periods when the plant is in operation. [R307-401-8]
Status: In Compliance. The offloading site was not viewed during this inspection as direct
observations require additional personal protective equipment and training due to the low
levels of radiation. EnergySolutions maintains videos of the process which demonstrate that
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the bulk waste is sprayed with a water cannon when waste is off loaded. All rail cars are
sprayed out with hoses during offloading as well. For this reason, moisture content testing
has not been required.
II.B.3.b The owner/operator shall water spray and/or chemically treat all unpaved roads and other
unpaved operational areas that are used by mobile equipment to control fugitive dust. Treatment
shall be of sufficient frequency and quantity to maintain the surface material in a damp/moist
condition. The opacity shall not exceed 20% during all times the areas are in use or unless it is
below freezing. If chemical treatment is to be used, the plan must be approved by the Director.
[R307-401]
Status: In Compliance.
II.B.3.b.1 Records of water treatment shall be kept for all periods when the plant is in operation. The
records shall include the following items:
A. Date
B. Number of treatments made, dilution ratio, and quantity
C. Rainfall received, if any, and approximate amount
D. Time of day treatments were made
[R307-401-8]
Status: In Compliance. Unpaved roads are watered as necessary to control dust. The
records include the date, the time of day, the quantity in gallons, the water source, and the
specific location of the application. See the attached watering records.
II.B.3.d The facility shall have less than 30 miles of minimally maintained haul roads in use at any one
time. Haul roads are defined as those roads that waste and soil handling equipment (large
equipment) may use during the course of operations. Maintained haul roads are those paved
roads that are regularly cleaned (swept, scraped, washed down, etc.) when used as a haul road.
[R307-401]
Status: In Compliance.
II.B.3.c The owner/operator shall keep disturbed or stripped areas sufficiently moist or chemically treated
during the project to minimize fugitive emissions. These controls, or other equivalent control
methods, shall remain operational during the project cycle and until the said areas have been
reclaimed. The control methods used shall be operational as needed 24-hours per day, 365 days
per year or until the area has been reclaimed. If an equivalent control method or chemical
treatment is to be used, the plan must be approved by the Director. [R307-401]
Status: In Compliance.
II.B.3.d.1 Records of treatment and/or reclamation shall be kept for all periods when the plant is in
operation. [R307-401-8]
Status: In Compliance. The source currently has 12 miles of minimally maintained haul
roads. See the left side column on the Total area storage piles and haul road log.
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II.B.3.e The owner/operator shall install water sprays or chemical dust suppression sprays at the
following points to control fugitive emissions:
A. All screens
B. All unenclosed conveyor transfer points. Enclosed is defined as having three or more
sides and a top.
The sprays shall operate whenever dry conditions warrant or as determined necessary by the
Director.
[R307-401]
Status: In Compliance. Water sprays are installed and are used throughout the transfer
points. All conveyors entering processing buildings are enclosed.
II.B.3.f The owner/operator shall maintain a minimum moisture content of 2% by weight for the material
that will be disposed. The moisture content shall be tested if directed by the Director using the
appropriate ASTM method. [R307-401]
Status: In Compliance. The material disposed of is routinely sprayed when deposited. The
watering system includes spraying all rail cars as they are being offloaded which
sufficiently moisturizes the material above the 2% by weight threshold. Testing has not
been required.
II.B.3.g The owner/operator shall water the storage piles as dry conditions warrant or as determined
necessary by the Director to minimize generation of fugitive dust. [R307-401]
Status: In Compliance. The storage piles are routinely watered to control fugitive dust.
II.B.3.h The owner/operator shall install water sprays or chemical dust suppression sprays on the 100 ton
per hour shredder to control fugitive emissions. The sprays shall operate when necessary, to
ensure that the opacity limitations of this AO are not exceeded. If it is below freezing, then the
water sprays are not required but EnergySolutions shall implement other methods of controlling
fugitive emissions to ensure that the opacity limitations of this AO are not exceeded. [R307-401]
Status: In Compliance. Water sprays are installed on this shredder which is enclosed
within a building. The water sprays are used to cool the equipment as well as controlling
fugitive dust. Shredding is conducted at night due to the electrical draw required to
operate.
II.B.4 Volatile Organic Compounds and Hazardous Air Pollutants Limitations
II.B.4.a The emissions of VOCs and HAPs from the Thermal Desorption Unit System and associated
operations shall not exceed:
A. 2.37 tons per rolling 12-month period for VOCs
B. 2.33 tons per rolling 12-month period for total HAPs
C. 1.41 tons per rolling 12-month period for bis(2-ethylhexyl)phthalate
D. 0.45 tons per rolling 12-month period for benzene
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E. 0.88 tons per rolling 12-month period for carbon disulfide
F. 0.14 tons per rolling 12-month period for polychlorinated biphenyls
G. 0.24 tons per rolling 12-month period for vinyl chloride
H. 56.00 pounds per rolling 12-month period for p-phenylenediamine
I. 1.41 tons per rolling 12-month period for dibutyl phthalate
J. 1.41 tons per rolling 12-month period for dimethyl phthalate
K. 27.00 pounds per rolling 12-month period for heptachlor
L. 0.14 tons per rolling 12-month period for antimony
M. 1.23 tons per rolling 12-month period for cyanide
N. 0.14 tons per rolling 12-month period for lindane
O. 1.09 tons per rolling 12-month period for methyl bromide
P. 6.00 pounds per rolling 12-month period for mercury
Q. 5.00 pounds per rolling 12-month period for arsenic
R. 0.027 pounds per rolling 12-month period for beryllium
S. 1.84 pounds per rolling 12-month period for chromium
T. 18.00 pounds per rolling 12-month period for nickel
U. 0.05 tons per rolling 12-month period for selenium
[R307-401]
Status: In Compliance.
II.B.4.a.1 Compliance with the VOC and HAP limitations shall be determined on a rolling 12-month total.
Before the twentieth day of each month, a new 12-month total shall be calculated using data from
the previous 12 months. [R307-401-8]
Status: In Compliance.
II.B.4.a.2 The VOC and HAP emissions shall be determined by maintaining a record of VOC and HAP
emitting materials processed through the Thermal Desorption System each month. The
following records shall be retained:
A. Specific waste stream identification for each waste stream processed through the
thermal desorption system.
B. The total amount of waste material associated with each waste stream, prior to
processing through the thermal desorption system.
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C. The time required to process each waste stream.
D. Estimated weight percentages of known and/or expected HAPs within the waste
stream based on generator process knowledge and/or waste profile records.
E. Amounts (concentrations) of VOCs within the waste stream based upon laboratory
analysis of the waste prior to thermal desorption processing.
F. The calculated amount of HAP/VOC emitted based upon calculations assuming a
carbon filter efficiency of 0.95 and a HEPA efficiency of 0.999.
G. The amount of VOCs or HAPs may be adjusted by quantifying and subtracting the
amount of condensate collected from the system.
[R307-401-8]
Status: In Compliance. The required records of VOCs and HAPs from the Thermal
Desorption Unit System are kept and calculated according to this condition. The rolling
12-month totals from February 2024 to January 2025 are as follows:
A. VOCs calculated emissions: 0.163 tons
B. Total HAPs: 4.04E-04 tons
C. bis(2-ethyhexyl)phthalate: 8.31E-05 tons
D. benzene: 1.77E-06 tons
E. carbon disulfide: 0.0 tons
F. polychlorinated biphenyls: 0.000170038 tons
G. vinyl chloride: 0.0 tons
H. p-phenylenediamine: 0.0 pounds
I. dibutyl phthalate: 7.16E-09 tons
J. dimethyl phthalate: 0.0 tons
K. heptachlor: 6.02E-23 tons (1.204E-19 pounds)
L. antimony: 9.03E-06 tons
M. cyanide: 5.82E-06 tons
N. lindane: 0.0 tons
O. methyl bromide: 0.0 tons
P. mercury: 2.36E-05 tons (0.0472 pounds)
Q. arsenic: 8.71E-05 tons (0.1742 pounds)
R. beryllium: 9.59E-07 tons (0.001918 pounds)
S. chromium: 8.97E-06 tons ((1.794E-10 pounds)
T. nickel: 1.12E-05 tons (0.0224 pounds)
U. selenium: 2.63E-06 tons (0.00526 pounds)
See the attached individual pollutant emissions spreadsheets for more information.
Section III: APPLICABLE FEDERAL REQUIREMENTS
In addition to the requirements of this AO, all applicable provisions of the following federal programs have
been found to apply to this installation. This AO in no way releases the owner or operator from any liability
for compliance with all other applicable federal, state, and local regulations including UAC R307.
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NSPS (Part 60) IIII: Standards of Performance for Stationary Compression Ignition Internal Combustion
Engines
Status: In Compliance. The fire pump engine (II.A.12) is a Cummins, November 25, 2013 mfg. date,
that is Tier 3 certified. The Administrative building emergency engine (II.A.11) is a Cummins, July 28,
2016 mfg. date, that is Tier 3 certified. The engines are operated as emergency only and the
testing/maintenance operation durations are less than 100 hours for each 12-month period. Refer to the
engine operation log for more information. Maintenance is performed on a routine scheduled basis and
the records are maintained on site. Each engine is equipped with a non-resettable hour meter.
MACT (Part 63) -CCCCCC: National Emission Standards for Hazardous Air Pollutants for Source Category:
Gasoline Dispensing Facilities
Status: In Compliance. The source has a 10,000-gallon gasoline tank installed at this location. On site
fuel records indicate a throughput for gasoline between 2,600 to 3,200 gallons per month. Since this
range is under 10,000 gallons a month, Section 63.11116 applies. No visible emissions or uncovered
containers were observed during the inspection. Gasoline spills are minimized and any spills are cleaned
as expeditiously as possible. Gasoline storage tanks are fitted with a gasketed seal.
MACT (Part 63) -ZZZZ: National Emissions Standards for Hazardous Air Pollutants for Stationary
Reciprocating Internal Combustion Engines
Status: In Compliance. Both emergency engines are Tier 3 certified, therefore NSPS Subpart IIII
applies. Refer to this federal standard for more information.
AREA SOURCE RULES EVALUATION:
The following Area Source Rules were evaluated during this inspection:
Emission Standards: Sulfur Content of Fuels [R307-203]
Status: In Compliance. Only ULSD fuel is used in the permitted engines. See Condition II.B.1.e -
II.B.1.e.1 for more information.
Emission Standards: Fugitive Emissions and Fugitive Dust [R307-205]
Status: In Compliance. No fugitive emissions or dust were observed during this inspection. Water
sprays, water tanks, and dedicated watering trucks are maintained on site. Watering records
document appropriate dust suppression. Several employees are reportedly Method 9 certified.
Stationary Sources [R307-210]
Status: In Compliance. This Rule incorporates federal NSPS Subparts and applies to IIII for the
emergency generators. See the above federal requirement section for more information.
National Emission Standards for Hazardous Air Pollutants [R307-214]
Status: In Compliance. This Rule incorporates the MACT federal subparts and incorporates
Subparts ZZZZ for the emergency generators and CCCCCC for the gasoline dispensing equipment.
See the above federal requirement section for more information.
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EMISSION INVENTORY:
Listed below are the Actual Emissions Inventory provided from EnergySolutions, LLC – Radioactive Material
Disposal Site for the activity year 2023. A comparison of the estimated total potential emissions (PTE) on
AO: DAQE-AN107170021-19, dated January 25, 2019, is provided. PTE are supplied for supplemental
purposes only.
Criteria Pollutant PTE tons/yr Actuals tons/yr
Carbon Monoxide 37.26 19.21356
Nitrogen Oxides 2.24 1.91136
Particulate Matter - PM10 5.06 76.38965
Particulate Matter - PM10 (Fugitives) 106.60 75.5309
Particulate Matter - PM2.5 105.94 14.60692
Particulate Matter - PM2.5 (Fugitives) 29.18 13.67916
Sulfur Dioxide 28.84 0.2234
Volatile Organic Compounds 0.45 0.59753
PREVIOUS ENFORCEMENT
ACTIONS: No enforcement actions have occurred during the last five years.
COMPLIANCE STATUS &
RECOMMENDATIONS: In regards to Approval Order (AO) DAQE-AN107170021-19, dated
January 25, 2019, the overall status is: In Compliance. The source
provided the necessary records on site and also provided a CD with
detailed records. The site appears to be well-maintained and operated.
HPV STATUS: Not Applicable.
RECOMMENDATION FOR
NEXT INSPECTION: Contact source prior to inspection due to security concerns. The
source contact is located in Salt Lake City and may not be at the Clive
site. Steel-toed boots, safety vest, glasses, hard hat, and leather gloves
are required to tour the facility.
NSR RECOMMENDATIONS: Consider removing II.A.10, the Railcar Digging Operations, on the
permitting equipment list during the next AO modification as this
operation is no longer used.
ATTACHMENTS: VEO, directions and map to the site, 12-month rolling totals for
individual HAP pollutants, submitted watering records, 12-month
rolling totals for production limitations, roads and disturbed area
totals, and SLEIS Summary Report for 2023.
Cover/Liner Material -12-month Rolling Average AAO Condition 11.B.2. ~.: The following limits shall not be exceeded:
(11.B.2.a.E. -limit= 250,000 tons) E. 2.50,000 tons c f material for cover/liner construction per rolling 12-month period.
Tons of Rolling CY of Month Material Average Material Used (tons I
January 0 130,739 0
February 0 130,739 0
March 0 130,739 0
April 0 130,739 0
May 0 130,739 0
2024 June 0 130,739 0
July 0 130,739 0
August 14,000 132,766 43078.415 * Phase 6 Cover Construction
September 14,000 122,567 45650.23 • Phase 6 Cover Construction
October 51,649 149,838 48222.044 • Phase 6 Cover Construction
November 7,047 87,036 50793.859 • Phase 6 Cover Construction
December 0 86,696 0
January 0 86,696 0
2023 Emissions Inventory Report
EnergySolutions, LLC Radioactive Material Disposal Site (10717)
Emissions Summary
CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Emissions
(tons,
excluding
tailpipe)
Tailpipe
Emissions
(tons)
Total Emissions
(tons)*
PM10-PRI PM10 Primary (Filt + Cond)76.38965 1.38935 77.779
PM10-FIL PM10 Filterable 75.5309 <.00001 75.5309
PM25-PRI PM2.5 Primary (Filt + Cond)14.60692 1.34767 15.95459
PM25-FIL PM2.5 Filterable 13.67916 <.00001 13.67916
PM-CON PM Condensible 0.82381 <.00001 0.82381
SO2 Sulfur Dioxide 0.2234 0.02652 0.24992
NOX Nitrogen Oxides 1.91136 27.86343 29.77479
VOC Volatile Organic Compounds 0.59753 2.48449 3.08202
CO Carbon Monoxide 19.21356 9.26258 28.47615
7439921 Lead 0.00004 <.00001 0.00004
HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS #Pollutant Name Is VOC/PM? Total Emissions
(tons)*
75070 Acetaldehyde (HAP)VOC 0.01519
107028 Acrolein (HAP)VOC <.00001
7440382 Arsenic (HAP)PM 0.00002
71432 Benzene (HAP)VOC 0.01336
7440417 Beryllium (HAP)PM 0.00001
7440439 Cadmium (HAP)PM 0.00003
18540299 Chromium (VI) (HAP)PM <.00001
7440473 Chromium (HAP)PM 0.00003
100414 Ethyl Benzene (HAP)VOC 0.10443
50000 Formaldehyde (HAP)VOC 0.03513
7439965 Manganese (HAP)PM 0.00033
7439976 Mercury (HAP)- 0.00002
91203 Naphthalene (HAP)VOC 0.00172
7440020 Nickel (HAP)PM 0.00014
130498292 PAH, total (HAP)PM 0.00002
106514 Quinone (HAP)VOC 0.01282
7782492 Selenium (HAP)PM 0.00002
108883 Toluene (HAP)VOC 0.04749
1330207 Xylenes (Mixed Isomers) (HAP)VOC 0.12817
91576 2-Methylnaphthalene (HAP)PM 0.00337
*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.
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