DRC-2025-001311

April 22, 2025Vern Rogers, Director of Regulatory AffairsEnergySolutions, LLC299 South Main Street, Suite 1700Salt Lake City, UT 84111CERTIFIED MAILRETURN RECEIPT REQUESTED#### ####
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RE:Compliance Advisory No. ########
Compliance Evaluation Inspection
Radioactive Materials Licenses No. UT 2300249 and No. UT 2300478
Dear Mr. Rogers:
This Compliance Advisory is being sent to your attention as a representative of EnergySolutions, LLC(the Respondent). According to the Division of Waste Management and Radiation Control’s
(Division) records, you are the designated contact person for the Respondent. OnFebruary 25, 2025 through April 10, 2025, representatives of the Division conducted a compliance evaluation
inspection at the Respondent’s facility. The scope of the inspection was to verify compliance withLicenses No. UT 2300249 and No. UT 2300478(the Licenses),Utah Administrative Code R313
(the Rules),and the Utah Radiation Control Act (the Act).
Based on observations and information obtained during the inspection, the Director of the Division (Director) is issuing this Compliance Advisory to provide the Respondent with notice
of the followingcompliance issues as well as an opportunity to correct these apparent compliance issues: Radioactive Materials License No. UT 2300249, Condition 17 requires “…solid waste
received for disposal shall contain aslittle free standing and non-corrosive liquid as reasonably achievable, but shall contain no more freeliquids than one percent of the volume of
the waste.”
On March 3, 2025, Division staff conducted an inspection of the Respondent handling a leaking waste shipment from the generator;CH2M HILL B&W West Valley, LLC. During the unloading of
the waste from the intermodal on the Class A Cell, an unknown amount of liquid was viewed exiting the intermodal onto the Class A Cell with no secondary containment in place.
The Respondent’s procedure CL-CH-PR-252 requires verification of the liquid volume on the form“1% Volume Freestanding Liquids Chart”, which was filled out and signed on March 11, 2025.
Requested Corrective Action: Please provide the Division with:
Documentation supporting why the Class A Disposal Cells are included in the procedure CL-CH-PR-252 definition of an Approved Unanticipated Liquid Management Facility.
A detailed procedure in how the “1% Volume Freestanding Liquids Chart” form is completed to ensure that all liquid is being accounted for within a waste shipment.
Pursuant to this Compliance Advisory, the Director is providing the Respondentwith an opportunity to correct the apparent compliance issues. The Director will also consider any evidence
and additional information provided by the Respondent.
Within 30 days of the date of this Compliance Advisory, please submit the following requested documentation regarding each compliance issue and associated corrective actions to the Director:
the cause of each compliance issue;
the specific corrective actions taken, results achieved, and applicable dates;
if future corrective actions are proposed, the specific corrective actions and proposed completion dates, including intermediate milestones, as applicable; and
how the corrective actions will prevent similar compliance issues from recurring.
All information regarding corrective actions relating to this matter should be addressed to the Director at:
Douglas J. Hansen, DirectorDivision of Waste Management and Radiation ControlP.O. Box 144880Salt Lake City, UT 84114-4880or by email at: [e-mail]
DO NOT submit any documents or information through email that are protected,confidential, proprietary, orfor which you are claiming business confidentiality underUtah Code Section 63G-2-305.
To better ensure records are protected, all suchdocuments and information must be submitted using the mailing address above andin accordance with Utah Code Section 63G-2-309.
If the Respondent demonstrates that it has taken appropriate corrective actionsregarding the matters addressed in this Compliance Advisory, the Director will issue a closeout letter
and will consider this matter to be closed.However, if the Respondent fails to demonstrate appropriate corrective actions within the30day timeframe, the Director will consider taking
escalated enforcement actions, including seeking financial penalties. In all events, the matters addressed in this Compliance Advisory, including the Respondent’s corrective actions,
will become part of the Respondent’s compliance record and may be considered in connection with future enforcement matters.
If you have any questions, please contactBryan Woolf by email at [e-mail] by phone at 385454-8060.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/BMW/[???]
c:
Taylor Palmer, Tooele County Health DepartmentJalynn Knudsen, Assistant Director, Division of Waste Management and Radiation Control, UDEQ