DRC-2025-000105

State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of EnvironmentalQuality
Kimberly D. Shelley
Executive Director
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL
Douglas J. Hansen
Director
Date
Vern C. Rogers, Director of Regulatory Affairs
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111Subject:Stipulation for the Modification of the Open Cell Time Limitation, Class A West (CAW)Embankment; Groundwater Quality DischargePermit,Number UGW450005
(GWQDP):Request for Information.
Dear Mr. Rogers:
In a letter dated April 1, 2024 (CD-2024-066)EnergySolutions included an expanded Decontamination and Decommissioning Plan with limited details for the closure of its Class A West Embankment,related
to Condition 74 of Radioactive Materials License UT2300249. To the Division of Waste Management and Radiation Control (Division) this seems to be related to theOpen Cell Time Limitation
of the GWQDP, and the fact that EnergySolutionsis not, and will not be able to meet this limitation for some parts of the CAW Embankment.As part of the Divisions review, the Division
is unclear as to the use of RML UT2300249, Condition 74 for this purpose? In EnergySolutions and Division meeting on this subject, it appeared to the Division that a Stipulation and
Consent order was going to be used to resolve this issue.Is that EnergySolutions understanding, also? As you are aware, a modification of the 18-year open cell time limitation requirement
of the GWQDP requires Director approval with area-specific plans, schedules, and justification for Division review. These requirements for the modification of the 18-year open cell
time limitationhave not been met at this time.
Additionally, please provide:
A timeline, including when it was identified that the 18-year open cell time limit of Part I.E.6 of the Ground Water Quality Discharge Permit could not be met, of events concerning the
exceeded of theOpen Cell Time Limitation.
Correspondence concerning the CTC and delayed construction of final cover or the CAW.
If you have any questions, please call Charles Bishops at [phone]
Sincerely,
Lawrence Kellum, Low Level Radioactive Waste Section Manager
Division of Waste Management and Radiation Control
DJH/CB/wac:Jeff Coombs, Health Officer, Tooele County HealthDepartment
Bryan Slade, Environmental Health Director, Tooele County Health Department EnergySolutionsGeneral Correspondence Email
LLRW General Correspondence Email