HomeMy WebLinkAboutDRC-2025-001750June XX, 2025
Vern RogersDirector, Regulatory AffairsCERTIFIED MAILEnergySolutions, LLCRETURN RECEIPT REQUESTED299 South Main, Suite 1700#### #### #### #### ####Salt Lake City, UT 84111
RE:Compliance Advisory No. XXXXXXX
2025 Decontamination and Wash Facilities Ground Water Module 4 Inspection,
Ground Water Quality Discharge Permit (Permit) No. UGW450005
Radioactive Material License UT2300249
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. OnMay 5, 2025, representatives of the Division conducted a compliance evaluation inspection at the Respondent’s
facility. The scope of the inspection was to verify compliance with Radioactive Material License UT2300249 (the License),Ground Water Quality Discharge Permit No. UGW450005 (the Permit),
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: Ground Water Quality Permit No. UGW450005 Part 1.E. 28 and Part 1.F.31 state:
“The Permittee shall operate and maintain the East Side Rotary Facility in accordancewith the BAT Performance Monitoring Plan and BAT Contingency Plan referenced inAppendices J and K
of this permit” and “The Permittee shall perform monitoring in accordance with the BAT PerformanceMonitoring Plan, Appendix J of this Permit”, respectively. Table 1 of Appendix J of
the Permit requires that a weekly inspection is performed at the East Side Rotary Facility – Manhole 1A for leak detection system operation, including absence of fluid in the drip leg.
During the Decontamination and Wash Facilities Ground Water Module 4 Inspection conducted on May 5, 2025, Division inspectors observed that EnergySolutions staff was unable to confirm
the absence of fluid in the drip leg at Manhole 1A due to visual obstacles in the manhole and spatial confinement. After the inspection,the Division confirmed with EnergySolutions staff
that they have been unable to perform this aspect of the leak detection system inspection at Manhole 1A since the East Side Rotary Facility went into service in November 2024. However,
weekly BAT inspection reports completed by EnergySolutions staff show check marks next to boxes labeled “Is the Manhole 1A leak detection system operational?”, indicating inspection
of the functionality of the leak detection systemhad been completed and found to meet the performance criteria identified in Table 1 of Appendix J. As required by the Permit, EnergySolutions
must have a way to visually inspect the absence of fluid in the drip leg to confirm the functionality of the leak detection system at Manhole 1A and should be accurately reporting whether
performance criteria identified in Table 1 of Appendix J have been achieved on all BAT inspection reports.
Requested Corrective Action: Please describe how EnergySolutions staff will visually confirm the absence of fluid in the drip leg in Manhole 1A at the East Side Rotary Facility.
Pursuant to this Compliance Advisory, the Director is providing the Respondent 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: dwmrcsubmit@utah.gov(25 MB limit)
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 contactBailey Anderson by email at bmanderson@utah.govor by phone at 3854606130.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/BMA/[???]
Enclosure(s):
c:Taylor Palmer, Tooele County Health Department
EnergySolutions General Correspondence EmailMathew R. Schon, Manager, Groundwater and Environmental Program, EnergySolutionsmrschon@energysolutions.com
LLRW General Correspondence Email
Jalynn Knudsen, Assistant Director, Division of Waste Management and Radiation Control, UDEQ