DRC-2025-001568

EnergySolutions 2025Gravel Resource Survey
Groundwater Module 12 Inspection
Ground Water Quality Discharge Permit, No. UGW 450005
INSPECTION REPORT FOR:
EnergySolutions, LLC
299South Main Street, Suite 1700
Salt Lake City, UT 84111
[phone]
DATE OF INSPECTION:
May 12, 2025
FACILITY ADDRESS:
EnergySolutions LLC
Clive Disposal Site
Interstate 80, Exit 49
Clive, UT 84029
The EnergySolutions LLC’s (EnergySolutions) Clive facility is located in Tooele County, Utah, approximately 2.5 miles south of Interstate 80, 75 miles west of Salt Lake City, and 55
miles east of Wendover Utah. The facility occupies all of Section 32 and parts of Sections 29 and 33 of Township 1 South, Range 11 WestSalt Lake Base and Meridian (SLBM), and part ofSections
5, Township 2 South, Range 11 West SLBM.
FACILITY CONTACT:
Mathew R. Schon
Manager, Groundwater and Environmental Program
EnergySolutions
[phone]
APPLICABLE REQUIREMENTS:The State of Utah has regulatory authority over the disposal of Low Level, Mixed, and 11e.(2) byproduct radioactive waste. Applicable requirements are found in
Utah Statute: Title 19, Chapter 3, Radiation Control Act, and Utah Administrative Code (UAC) R-313-24 and 25; Uranium Mills and Source Material Mill Tailings Disposal Facility Requirements,
and License Requirements for Land Disposal of Radioactive Waste, respectively. The State of Utah has issued two Radioactive Material Licenses, UT2300249 and UT2300478 to the EnergySolutions’
Clive Site. The Clive Site has also been found to have a potential to pollutant groundwater; therefore, enforcement authority under Utah Statute: Title 19, Chapter 5, Water Quality Act,
and UCA R317-6, Utah Administrative Rules for Ground Water Quality Protectionare also applicable. The State of Utah has issued a Ground Water Quality Discharge Permit, UGW 450005 to
the EnergySolutions’ Clive Site, under which this inspection module is conducted. The Utah Radiation Control rules have requirements regarding the use, maintenance, and performance
of an engineered cover. These regulations prescribe criteria for controlling waste and provide for adequate design to protect against waste exposure and embankment erosion. Licenses
and the Permit for the Clive Siterequire technologies based on the use of earthen materials;therefore, embankments are constructed with materials native to the site, or materials found
in close proximity to the site. The cover designed requires a reasonable assurance of containment of radiological hazards for a specified compliance period, to the extent practicable.
Design considerations for long-term stabilization of an embankment at the Clive Site are based on rock armor.
PARTICIPANTS:
Charles Bishop, P.G, Hydrogeologist
LLRW Section,
Utah Division of Waste Management and Radiation Control
Bailey Anderson, Hydrogeologist
LLRW Section,
Utah Division of Waste Management and Radiation Control
Andrew Zehr, Hydrogeologist,
LLRW Section
Utah Division of Waste Management and Radiation Control
Inva Braha, Health Physicist
LLRW Section,
Utah Division of Waste Management and Radiation Control
WEATHER CONDITIONS:
During the inspection on May 12, 2025, the temperature was approximately 90°F, with clear skies and heavy wind gusts.
REPORT PREPARED BY:
Bailey Anderson, Hydrogeologist
LLRW Section,
Utah Division of Waste Management and Radiation Control
SITE DESCRIPTION:
EnergySolutions owns and operates a commercial Class Alow level, l1e.(2)byproduct (uranium mill tailings), and a mixed radioactive and hazardouswaste (Mixed Waste) disposal site near
Clive, Tooele County,Utah. The EnergySolutions’ Clive site provides private long-term disposal for waste from Low Level, Mixed, and 11e.(2) radioactive sites. Waste disposal embankments
occupy part of Section 32, Township 1 South, and Range 11 West SLBM.The remainder of Section 32 is occupied by rail, unloading, and cleaning facilities; additional waste management,
administrative, and maintenance activities occur in parts of Section 29 and 33Township 1 South, Range 11 West SLBM. Clay mining has occurred south of Section 32 in part ofSections 5,
Township 2 South, Range 11 West SLBM, as well as in Section 29.
Rock aggregate for embankment cover used at the Clive Site comes from a quarry in the Grayback Hills(hereto referred to as the Section 24 gravel pit).The Grayback Hills are an elongated

sedimentary and volcanic knoll, with a relief of about 400 feet,located on the eastern side of the Great Salt Lake Desert, about 80 miles west of Salt Lake City, and north of the EnergySolutions,Clive
disposal operations.Carbonate (mostly limestone), siltstone, and extrusive volcanic rock are the indigenous sources of the aggregate in Gravel Pit 24. The Section 24 gravel pit aggregate
is lithologically variable, poorly sorted material deposited by high-energy lake currents, size ranging from silt to large boulders. The aggregate is granulated material that results
from the natural disintegration of rock and then reworked and transported by longshore currents associated with Lake Bonneville. Unconsolidated rock resources are widespread in the Grayback
Hillsand for the most part they areassociatedwith Lake Bonneville, but areas of pediment and alluvial fan gravels also exist. Rock materials have probably been mined from the Grayback
Hills since at least the early 1940s. These materials were used in local road and air strip construction for military purposes, and later in interstate highway construction as base
and surfacing gravels. Mining for cover materials used in waste embankment construction first occurred in the mid-1980s when the Vitro Tailings embankment was constructed. Thegravel
pit used for the Vitro Tailing’s cover was located at the south end of the Grayback Hills and gravel from this pit was also used for LARW waste embankment cover materials at the EnergySolutions’site
until about 2005.
Rock aggregate quality in the Grayback Hills is dependent on many attributes, including size distribution and dominant clast lithologies. The clast size distribution, dominant clast
lithology, and disintegration of rock in these deposits are dependent on local bedrock. Bedrock is at or near the surface in much of the northern Grayback Hills. At the Section 24 gravel
pit Lake Bonneville shoreline materials (clay to boulder size) are found associated with the Stansbury shoreline. Rocks along the shoreline were eroded and reworked during later transgressive
and regressive phases of Lake Bonneville.The rock aggregate in the Grayback Hills has beendetermined suitable as a protective cover based on physical characteristics and durability determinedwith
scoring criteria established by the U.S. Nuclear Regulatory Commission (NRC). Rock quality scores for materials in the Section 24 gravel pit met conventional quality requirements for
cover materialsin that they have a rock quality score greater than 50. Limestone clasts from the Section 24 gravel pit are determined to have a rock quality score of 55 (EnergySolutions,
12-26-2007).
CREDENTIALS, PURPOSE AND SCOPE:
Embankment cover materials used at the EnergySolutions’ Clive Site provide a protective barrier on the top and sideslopes of the waste embankments, to protect them from water action
and general erosion.Rock aggregate used in cover construction at the Clive Site has come from the Grayback Hills. However, land-use conflicts have developed as the Bureau of Land Management
(BLM), who controls the land and the resource, has placed limits on the development of new rock aggregate resources. Restrictions on mining of the rock aggregate resource reduces the
volume of rock aggregate that can be exploited.In 2008, the rock aggregate gravel resource development at the south end of the Grayback Hills were all leased, and the BLM was not willing
to allow new quarries or pits to extract rock aggregate; therefore, EnergySolutionswas required to relocate to an existing quarry in the northern Grayback Hills, in Section 24, Township
1 North, and Range 12 West SLBM. Later that year, the Division evaluatedrock aggregate materials in the new gravel pit to determine if sufficient quantities, quality, and size distribution
of rock were available. The Division determined the Section 24 gravel pit had enough resource to provide for cover of all embankments presently approved for construction at the Clive
Site. The purpose of this inspection is to verify there is enough rock aggregate resource at the Section 24 gravel pit to meet the needs of the Site.This report provides managers with
a summary of field observations and anideaof the resource available for cover constructionat the Section 24 gravel pit.
MANAGEMENT ACTIVITIES:
EnergySolutions’ Clive site is permitted, licensed, and authorized to receive and dispose of Class A LLRW, NORM/NARM, Class A Mixed LLRW, 11e.(2) Byproduct Material, Special Nuclear
Material based on concentration limits, as well as Polychlorinated Biphenyl (PCB) Radioactive Waste, and PCB mixed Waste. The facility is accessed by highway and rail transportation.

At the Section 24 Gravel Pit, rock aggregate is mined from the surface in areas with relatively thick accumulation of unconsolidated sediments near the surface. These types of deposits
are suitable for surface operations. Surface mining is performed withexcavators, power shovels, front end loaders and conveyors.The aggregate material is excavated, cleaned of debris,
screened, roughly separated by size, and stockpiled in the pit area. Tufa masses (cemented gravels and boulders) are moved out of the wayand not processed further.Stockpiled aggregate
material may then be trucked to the Clive site for further processing.After transportation to the Site, raw feed is stockpiled in Section 5 where it will be further processed and sorted
into the final-sized material.
Figure 1. Access and locations of gravel pits in the Grayback Hills.
Access to the Section 24 gravel pit is afforded by improved and unimproved roads. The Section 24 gravel pit is located at an elevation of about 4500 feet(see Figure 1).
NARRATIVE:
This inspection report subjectively evaluates the volume and spatial occurrence of rock aggregate at the Section 24 gravel pit. Rock aggregate resources are distributed through the Grayback
Hills,but where they can be exploited is limited due to land use conflicts.
The Division determinedin 2008 that the Section 24 gravel pit could potentially cover an area of about 27 acres (1,200,000 square feet) with a conservative exploitable material amount
of about 1,100,000 cubic yards (yd3). This was based on field observations and 27 exploration trenches developed within the boundaries of the gravel pit in 2007. The Division used Google
Earth images as an analytical tool to identify spatial relationships on the images to estimate the disturbed area in the section 24 gravel pit.Since that time, surface operations have
expanded to about 11 acres and is considerably greater in depth.
2009 image of Section 24 gravel pit. The surface operation was relatively small and at very shallow depth. There is about 5 acres of land disturbance.
2024 Google Maps image of the Section 24 Gravel pit.
2025 Google Maps image of the Section 24 Gravel pit.
Conditions at the Section 24 Gravel Pit on May 12, 2025 appeared unchanged from conditions observed during the inspection the year prior, on April 9, 2024. Estimates of exploitable rock
materials in the Section 24 gravel pit appeared adequate to meet surety requirements of the EnergySolutions facility in 2025.The Divisions’ review of the Section 24 gravel pit showed
that there appear to be enough gravel materials to meet the individual requirements for all the waste embankment covers.
Figure 2. Section 24 Gravel Pit facing Weston May 5, 2025, inspector for scale. The excavated face of the surface operations is about 60 feet high.
COMPLIANCE STATUS
No compliance issues identified for this inspection.
ISSUES
No outstanding compliance issues as a result of GW Module 12 inspection.
REFERENCES
Black, B.D., Solomon, B.J., and Harty, K.M., 1999, Geology and Geologic Hazards of Tooele Valley and the West Desert Hazardous Industry area, Tooele County, Utah: Utah Geological Survey,
Special Study 96.
Davies, S.F., 1980, Geology of the Grayback Hills, north-central Tooele County, Utah: University of Utah, M.S. thesis, 206 p., 2 plates, scale 1:7000.
Doelling, H.H., Solomon, B.J., and Davies, S.F., 1994, Geologic Map of the Grayback Hills Quadrangle, Tooele County, Utah: Utah Geological Survey, Map 166.

EnergySolutions email, dated 12-26-2007, Sean McCandless to Charles Bishop
SIGNATURE:
Prepared By:
_______________________________________________________
Bailey Anderson, HydrogeologistDate
LLRW Section
Utah Division of Waste Management and Radiation Control
Review and ApprovalBy:
_________________________________________________________
Lawrence Kellum, Section Manger Date
LLRW Section
Utah Division of Waste Management and Radiation Control