DRC-2025-001813

2025 Decontamination and Wash 1-acilities Inspection
GWQDP Module 4 Inspection
EnergySolutions GWQD Permit, UGW ./50005
May 2025
EnergySolutions 2025 LLRW Decontamination and Wash Facilities Inspection
Groundwater Module 4 Inspection
Ground Water Quality Discharge Permit No. UGW 450005
INSPECTION REPORT FOR:
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
(801 )649-2000
DATE OF INSPECTION:
May 5, 2025
FACILITY ADDRESS:
EnergySolutions LLC
Clive Disposal Site
Interstate 80, Exit 49
Clive, UT 84029
The EnergySolutions LLC's (EnergySolutions) Clive Site is located in Tooele County, Utah,
approximately 2.5 miles south of Interstate 80, Exit 49;75 miles west of Salt Lake City; and 55
miles east of Wendover, Utah. The site occupies all of Section 32 and parts of Sections 29 and 33
of Township 1 South, Range 11 West Salt Lake Base and Meridian (SLBM), and part of Section
5, Township 2 South, and Range 11 West SLBM.
FACILITY CONT ACT:
Curtis R. Kirk
Clive Quality Assurance Manager, EnergySolutions
[phone]
Roger Ekins
Clive Disposal Supervisor, EnergySolutions
[phone]
Mat Schon
Groundwater and Environmental Program Manager, EnergySolutions
[phone]
NOTIFICATION:
This is an unannounced inspection, notice was given on May 5, 2025 upon arrival at the
EnergySolutions Clive Site.
UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -1-
GWQDP Module 4 Inspection May 202S
EnergySolutions GWQD Permit, UGW ./50005
APPLICABLE REQUIREMENTS:
The State of Utah has issued two Radioactive Material Licenses, UT2300249 and UT2300478, to
EnergySolutions' for its Clive Site. Additionally, because EnergySolutions' Clive Site has been
determined to have the potential to contaminate groundwater, requirements of Utah
Administrative Rules for Water Quality are applied. Provisions and requirements for
groundwater quality protection are found in UAC R317-6, Utah Administrative Rules for
Ground Water Quality Protection. The EnergySolutions' Clive Site has been issued a State of
Utah Ground Water Quality Discharge Permit, No. UGW450005.
The inspection is conducted under the authority of Ground Water Quality Discharge Permit, no.
UGW 450005 (hereinafter Permit). Specific Permit conditions that relate to the wash facilities
inspection are: Part I.E.l 4(b, c ); Part 1.E.8; Part 1.E.10.a; Part I.E.21; Part I.E.22; Part 1.E.24;
Part I.F.2 (f, g, j, k, and m); Part I.F.17; Part I.F.18; Part I.F.26; Part I.F.27; Part I.F.29; Part
1.F .31, and Part I.H.20. Appendix J of the Permit provides a facility description, BAT
performance criteria, compliance points, inspection requirements and frequency, and where
inspections are to be documented. Appendix K of the Permit provides direction or activities
required to maintain or regain compliance with BAT requirements of the Permit, if needed.
TYPE OF INSPECTION:
The Utah Division of Waste Management and Radiation Control (hereinafter Division) conducts
periodic inspections at EnergySolutions' Low Level Radioactive Waste (LLRW) disposal site at
Clive, Tooele County, Utah in accordance with the State issued Permit. This is a routine
inspection to assess facility conformance with BAT requirements of the Permit for LLRW
Decontamination and Wash Facilities; it verifies that wash facilities' maintenance and operations
are in accordance with the Permit and that measures installed or applied to protect groundwater
are effective.
PARTICIPANTS:
Roger Ekins
Clive Disposal Supervisor
Energy Solutions
[phone]
Bailey Anderson
LLR W Section, Hydrogeologist
Utah Division of Waste Management and Radiation Control
Andrew Zehr
LLR W Section, Hydrogeologist
Utah Division of Waste Management and Radiation Control
Lawrence Kellum
LLR W Section, Section Manager
Utah Division of Waste Management and Radiation Control
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -2-
GWQDP Module 4 Inspection :vtay 2025
1--,nergySolutions GWQD Permit, UGW -150005
WEATHER CONDITIONS:
At 9:45 on May 5, 2025 temperature 52.7 °F with 12.35 winds from the north, overcast.
TIME IN:
Arrival at Clive Site admin building 9:20 AM, opening meeting with David Booth and Curtis
Kurt starting at approximately 9:30 AM. At 10:00 AM, enter restricted area.
TIMEOUT:
Leave restricted area at 12:07 PM. Close out meeting with David Booth at approximately 1 :20
PM.
REPORT PREPARED BY:
Bailey Anderson, Hydrogeologist
LLRW Section, Utah Division of Waste Management and Radiation Control
SITE DESCRIPTION:
EnergySolutions is a Utah-based company that owns and operates a commercial Class A low
level radioactive waste (LLRW), 1 le.(2) byproduct (uranium mill tailings), and a mixed
radioactive and hazardous (Mixed) waste disposal site near Clive, Tooele County, Utah.
EnergySolutions (formerly Envirocare of Utah, Inc.) began waste disposal operation at the Clive
Site in 1988 on Section 32, Township 1 South, Range 11 West, SLBM. Presently, waste
treatment and disposal occurs in Section 32 (approximately one square mile, less the DOE Vitro
property), with handling, rail operations, cleaning, maintenance, and administration activities
also taking place in the rest of Section 32 and in parts of Section 29. Clay mining occurs in
Section 29 and Section 5, Township 2 South, Range 11 West, SLBM. The whole operation
covers about two square miles. There are three active above-ground engineered disposal
embankments: the Class A West, Mixed, and 1 le.(2) waste embankments. There are two closed
embankments: the LARW embankment (closed in 2006 by EnergySolutions), and the US
Department of Energy's Vitro mill tailings embankment ( closed in 1988 by the US Department
of Energy). Currently, the facility has about 100 employees and operates a single ten-hour shift,
four days a week.
Wash facilities support the overall operations of the Clive Site and use water in daily operations.
Wash facilities place significant importance on design, construction, and operation to minimize
waste-water discharges to the ground, and use similar designed features, construction, and
equipment. The design and operation of each wash facility makes possible the essentially routine
cleaning of low-level radioactive waste containers and railcars. Wash facilities considered in this
inspection are the Rail Car Wash on Track No. 4, West Side Rotary Dump Facility, Intermodal
Container Wash Building, and the East Side Rotary Dump Facility. The East Side Drainage
System is included in this inspection because even though it is not a facility for washing, it
conveys wash-water from the wash facilities to the 1997 waste-water evaporation pond (see
Figure 1 for the location of facilities that were inspected).
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -3-
GWQDP Module 4 Inspection May 2025
EnergySolutions GWQD Permit, UGW '150005
Iner
f
Figure 1. Plan view and general layout of the Clive Disposal Site, showing the locations of
facilities with BAT requirements and the decontamination and wash facilities discussed in this
report.
UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -4-
GWQDP Module 4 Inspection :vtay 2025
hnergySolutions GWQD Permit, UGW ../50005
CREDENTIALS, PURPOSE, AND SCOPE:
The LLRW Wash Facilities routinely produce or transfer wastewater in support of operations at
the Clive Site and are a potential source of contaminated water to directly or indirectly contact
the ground and potentially reach groundwater. The Permit requires EnergySolutions to conduct
inspections and maintenance programs at wash facilities to prevent a discharge of fluids from a
facility to the ground or groundwater. Established management practices and operating
procedures to manage wastewater (wash water) are applied at the LLRW wash facilities to
minimize the potential release of contamination. Compliance with these commitments confirms
that wash facilities at the Clive Site are operated according to BAT design and performance
standards.
MANAGEMENT ACTIVITIES:
Wash facilities at the Clive Site are used for the decontamination of railcars and containers, and
for the management of wastewater produced during operation of these facilities. The Permit
stipulates BAT monitoring and operational activities for facilities with a potential to discharge
water directly or indirectly to groundwater. More stringent BAT requirements are utilized at
wash facilities because water is used in their operations and, therefore, have a greater potential
for the release of water. EnergySolutions demonstrates compliance with BAT performance
standards by performing and documenting inspections, performing equipment maintenance and
repairs, and implementing corrective actions if needed.
NARRATIVE:
This narrative summarizes the results of an inspection of Energy Solutions Decontamination and
Wash Facilities at the Clive Site, including the Rail Car Wash on Track No. 4, West Side Rotary
Dump Facility, Intermodal Container Wash Building, East Side Rotary Dump Facility, and East
Side Drainage System conducted on May 5, 2025 to assess facility conformance with BAT
requirements of the state-issued Groundwater Quality Discharge Permit. Inspections of
decontamination and wash facilities were conducted by Division staff Bailey Anderson and
Andrew Zehr. Lawrence Kellum, DWMRC LLR W Section Program Manager, was also present
to complete an annual NRC-required accompaniment inspection of Division inspector Bailey
Anderson.
Upon arrival at the Clive Site, Division staff members identified themselves as representatives of
the Division of Waste Management and Radiation Control and asked to speak to Mr. David
Booth, General Manager of the Clive Site, concerning the Decontamination and Wash Facilities
Groundwater Module 4 inspection they were about to perform. The opening meeting discussed
the purpose of the inspection, the facilities to be inspected, and general BAT requirements for the
decontamination and wash facilities. Daily, Weekly, and Monthly BAT inspection forms from
April 6, 2025 to April 20, 2025 were also requested for the records review associated with the
inspection. The inspection team then departed to the LLR W Operation building, where they met
with EnergySolutions Clive Disposal Supervisor Roger Ekins, who escorted Division Staff for
the duration of the inspection.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -5-
GWQDP Module 4 Inspection May 2025
f-<,nergySo/utions GWQD Permit, UGW c./50005
Inspection findings were recorded via the Decontamination and Wash Facilities Module 4
inspection form (Attachment 1) and are summarized below (Conclusions).
Upon the conclusion of the field investigation, Division staff discussed their findings with escort
Roger Ekins and general manager Dave Booth, which included a discussion concerning the
dampness observed under the wastewater tank at the Rail Wash on Track No. 4 Facility and the
inability of staff to confirm the functionality of the leak detection system alarm at Manhole 1 A at
the East Side Rotary Dump. Additionally, BAT inspection forms from April 6, 2025 to April 20,
2025 that had been requested by Division inspectors in the opening meeting were collected from
Curtis Kirk, EnergySolutions Quality Assurance Manager, at that time.
Due to findings by Division inspectors during the field inspection, subsequent records requests
were made by Bailey Anderson by telephone and email in the days following the inspection;
these were provided by EnergySolutions staff Roger Ekins, Curtis Kirk, and Matt Schon from
May 8, 2025 -May 19, 2025. The responses by Energy Solutions staff to these requests triggered
further evaluation of BAT requirements by the Division, specifically in reference to the leaking
wastewater collection tank at the Rail Car Wash Facility on Track No. 4. After completing this
evaluation, Division inspector Bailey Anderson scheduled a closeout meeting with Dave Booth
on May 28, 2025. On June 3rd at 10:00 AM, the closeout meeting was conducted virtually via
Google Meet and attended by Bailey Anderson, Dave Booth, and Lawrence Kellum. In this
meeting, the following items were identified and discussed:
1. Cracks in the curbing of the north and south ramps at the East Side Rotary Facility in
conjunction with the location of control joints. No cracks exceeding 1/8" were
observed, however, this will continue to be monitored by staff in future inspections.
2. Inability to confirm functionality of the leak detection system alarm at the East Side
Rotary Facility Manhole IA, and relative reporting issues on BAT inspection forms .
3. Leaking wastewater collection tank at the Rail Car Wash Facility on Track No. 4, and
the associated issues regarding BAT inspection report accuracy.
RECORDS REVIEW:
The Decontamination and Wash Facilities inspection includes a BAT record review to confirm
BAT inspections are occurring at the wash facilities; records from April 6, 2025 through April
20, 2025 were requested and received at the time of the inspection. The requested
EnergySolutions inspection forms included Daily, Weekly, Monthly, and Daily Stormwater
inspection forms. None of the wash facilities have additional inspection requirements related to
stormwater events, but they all have additional weekly and most have additional monthly
inspection requirements. The records inspection was conducted in-office by Division staff after
the field inspection on May 6, 2025 . Subsequent records requests were made by Division
inspector Bailey Anderson by telephone and email in the days following the inspection as a
result of observations during the field inspection, and were provided by Energy Solutions staff
Roger Ekins, Curtis Kirk, and Matt Schon from May 8, 2025 -May 19, 2025 .
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -6-
GWQDP Module 4 Inspection May 2025
1--,nergySolutions GWQD Permit, lJGW -150005
In preparation for the field inspection, Division staff also reviewed Energy Solutions' 2024 First
Semi-Annual BAT Monitoring Report (DRC-2024-004808), EnergySolutions' 2024 Second
Semi-Annual BAT Monitoring Report (DRC-2025-000369), as well as recent correspondence to
identify any BAT failures or problems since the last Decontamination and Wash Facilities
inspection on April 23 , 2024. From this review, it was noted there had been reoccurring
problems with the visual alarms and sight cannisters at Manholes #1 and #2 (East Side Drainage
System), therefore, inspectors planned to have these facilities opened and checked by
Energy Solutions on the day of the field inspection to verify these issues had been resolved.
CONCLUSIONS:
A short summary including field observations and any relative results of the records inspections
for each facility are provided below in the order the facilities were inspected:
Rail Car Wash Facility on Track No. 4
During the 2025 Track No. 4 Rail Car Wash Facility inspection, the facility was being used to
repaint a railcar before free release. At the time of the inspection, the Rail Car Wash Facility
floors were clean and free of any debris, which would allow for any wash water to drain to the
trench and sump with no restrictions (free drainage maintained). Cracks that had been patched
with Sikaflex during prior inspections appeared to remain in good condition and no new cracks
larger than 1/8" were observed by inspectors. The sump water level was below the grate and the
pump was assumed to be operational because water was below the grate (pump to the gray water
tank operational). The wash water collection tank and filtered water storage tank, along with the
concrete secondary containment vault in the adjacent equipment/mechanic building, appeared to
be in good condition; however, dampness was observed under the wastewater tank closest to the
building door. All tanks, concrete floor, trench, sump, and conveyance piping also appeared to be
in good condition, and the source of the dampness was not readily identifiable (Figure 1). Site
escort Roger Ekins told inspectors that there hadn't been a leak reported at the facility, and the
facility manager was not available at the time of the inspection to speak with Division staff.
Division inspectors followed up with site escort Roger Ekins following the field inspection to
determine if the cause of the dampness had been identified and resolved; on May 8, 2025, Roger
Ekins reported via phone call that maintenance staff did find a slow leak at the bottom of the
wastewater storage tank, and that repairs were still being completed. At that time, additional
BAT records were requested to determine whether the leak had been recorded by
Energy Solutions staff prior to the time of the inspection by Division staff on May 5, 2025, and to
confirm the documentation of the leak after identification during the field inspection. This
request included the weekly BAT inspection dated April 29, 2024, when the last inspection of
the collection tank would have been performed, and the daily BAT inspection conducted earlier
on the day of the inspection by EnergySolutions staff on Monday, May 5, 2025. Additionally, the
daily and weekly BAT records from the day following the Division inspection on Tuesday, May
6, 2025, were requested to confirm whether the dampness/leak had been noted by the
Energy Solutions BAT inspector during their weekly inspection of the storage tanks and to verify
maintenance activities.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -7-
GWQDP Module 4 Inspection May 2025
EnergySo/utions GWQD Permit, UGW -150005
Review of these records showed that the EnergySolutions BAT inspector failed to note any
dampness under the wastewater collection, the presence of a leak, or that Rail Car Wash Facility
on Track No. 4 had been taken out of service for maintenance/that maintenance activities were
taking place. In subsequent correspondence with Roger Ekins, the Division was provided with
an email forwarded from the Rail Facility Manager David Pitt, who confirmed the Rail Car Wash
Facility was taken out of service from May 7th -May 9th to repair the leak observed during the
inspection on May 5, 2025. However, in the email from David Pitt dated May 19th, 2025, it was
noted that on May 14th, 2025 another leak was identified "in proximity to the previous leak with
a similar rate but from a different point of the fitting" and "maintenance personnel were working
to seal the second leak".
Figure I. Equipment Room at the Rail Car Wash Facility on Track No. 4, dampness due to a
slow leak was observed under the wastewater collection tank (right).
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -8-
GWQDP Module 4 Inspection May 2025
EnergySo/utions GWQD Permit, UGW ../50005
The inspection record review from April 6 to April 20, 2025 , indicated there were no problems
with the daily ( operational sump, free draining, and tank pump operational), weekly (floor
integrity), and monthly (alarm check) inspection of the Track No. 4 Rail Car Wash Facility
during that time. No other BAT compliance issues were reported since the last inspection and all
reports appeared to be complete.
Intermodal Container Wash Building
At the time of the inspection on May 5, 2025, Bays 1 and 2 of the Intermodal Container Wash
Building were in use, but operations were suspended and EnergySolutions' Health Physicists
accompanied inspectors so the facility could be inspected. During the inspection, concrete
surfaces were found to be in good condition. Floor boot washes and trenches were clean, and free
draining, and the inspector observed little water on the floors and clean trenches. The water level
in the sediment basin was below the grate, so it was assumed the pump and automatic
discharging system were operational. There is no longer a pump below the grate in the sediment
basin; the pump has been moved to the concrete floor next to the sediment basin. The leak
detection annulus of the sediment basin, leak detection system ports # 1 and #2 were checked and
found to contain no fluids. A check in Manhole #1 of the East Side Drainage System showed
there were no fluids within the leak detection annulus of the dual-walled wastewater transfer
pipe.
The inspection record review, from April 6 to April 20, 2025, showed there had been no
problems during the daily, weekly (look at floor integrity and water in the leak detection ports)
inspections during that time. A review of Energy Solutions BAT notifications indicates that no
BAT issues had occurred since the last inspection and all records appeared to be complete.
East Side Rotary Dump
Operations at the East Side Rotary Dump were suspended at the time of the inspection on May 5,
2025. Observations during the inspection showed exposed concrete surfaces on the upper wash
area to be in good condition and free of dirt and debris to allow for drainage of the wash building
floor to trenches (trenches leading ultimately to the sediment basin). Wash water collection
storage tanks in the equipment room adjacent to the upper wash area appeared free of any leaks
in good condition. Dirt on the rotary dump floor and the grate of the sediment basin was
observed, but free drainage conditions were maintained. The water level in the sediment basin
was below its grate so it was assumed the pump and automatic discharging system were
operational. The leak detection annulus of the sediment basin (ports #1 and #2) were checked
and confirmed by Division staff to contain no fluids (Figure 2). The visual alarm indicating the
presence of fluids in the leak detection annulus within the secondary pipe of the wastewater
transfer system piping system (at Manhole IA, pipeline 4b) was not active, however, the sight
cannister in Manhole IA is not accessible, and Division/EnergySolutions staff were not able to
confirm functionality of the alarm. Additionally, upon inspection of the north and south ramps of
the facility, it was noted by Division staff that minor cracks in the curbing of the ramps appeared
to occur in conjunction with the location of control joints (Figures 2 and 3). No cracks exceeding
1/8" were observed, however, this will continue to be monitored by staff in future inspections.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -9-
GWQDP Module 4 Inspection May 2025
f:<.nergySolutions GWQD Permit, UGW -150005
Figures 2 and 3. Curbing cracks at the location of control joints on the north and south ramps at
the East Side Rotary Facility.
The inspection record review from April 6 to April 20, 2025, reported there were no problems
with the daily (free draining, water below grates), weekly (floor integrity, sump operations, leak
detection ports), and monthly (alarm check) inspection of the East Side Rotary Dump Facility
during that time. The records review appears to indicate that despite being unable to confirm the
functionality of the leak detection system alarm at Manhole 1 A, Energy Solutions BAT inspectors
have marked this is as complete on weekly and monthly inspection forms. No BAT failures have
been reported since the facility went into service on November 14, 2024.
East Side Drainage System
During the 2025 East Side Drainage System inspection, the wash and storm water systems
appeared free draining, because no water was backing up into any facility or in Manholes # 1 and
#2, indicating no restrictions in the system. No visual alarms were observed at the time of the
inspection, indicating there were no problems at Manholes #1 and #2; however, due to BAT
issues at Manholes #1 and #2 in the year since the last inspection, Division inspectors requested
the manholes be opened to verify sight canisters in both Manholes #1 and #2 indicated no fluids
in the leak detection annulus and confirm each sight cannister was functional and in good
condition (Figure 3).
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -10-
GWQDP Module 4 Inspection '.Vlay 2025
1--,nergySo/utions GWQD Permit, UGW -150005
The inspection record review, from April 6 to April 20, 2025, indicates there had been no
problems during the daily (activated alarms, free drainage to catch basin), weekly (leak detection
system) and monthly (alarm check) inspections during that time. A review of Energy Solutions
BAT reports since the last Decontamination and Wash Facilities inspection on April 23, 2024
was completed prior to the field inspection, and indicated several BAT issues were observed at
Manholes #1 and #2 from August 19, 2024 to September 16, 2024. For this reason, a closer
inspection of the leak detection systems at Manholes # 1 and #2 were performed on the day of the
field inspection. All BAT failures at Manholes # 1 and #2 (East Side Drainage System) since the
last inspection were confirmed to have been resolved by Energy Solutions staff and reported to
the Division in accordance with the requirements of the Permit.
West Side Rotary Dump
At the time of the inspection on May 5, 2025 , high contamination waste was being rolled at the
West Side Rotary Dump Facility, therefore, Division inspectors were only able to make
observations from the control room. Sediment and waste were observed on the dump floor, but
free drainage of the wash building floor to trenches (ultimately leading to the sediment basin),
and the lower floor of the Rotary Building to the sediment basin was maintained. No significant
amount of standing water was observed on any compliance surface and the water level in the
sediment basin was below the grate, indicating functionality of the drainage system. Due to the
nature of waste being rolled, Division inspectors were not permitted to access the rotary dump
floor at the time of the inspection, so the sediment basin leak detection ports were not checked.
The wastewater pressurized piping system alarm was not activated, indicating that there was no
water in the pipe annulus space.
The inspection record review from April 6 to April 20, 2025, indicated no problems with the
daily (free draining, water below grates, drain from thaw building clear), weekly (look at floor
integrity, sump operations, leak detection ports), and monthly (alarm check) inspection of the
Rotary Dump Facility during that time. A review of Energy Solutions BAT notifications indicates
that on January 24, 2025 , water was observed to be above the sediment basin grate at the West
Side Rotary Facility due to a frozen drain line, and again the following day due to a subsequent
drainpipe break. The required 24-hr and 7-day notifications to the Division was provided on
January 24, 2025 and January 31 , 2025, respectively. No further issues were reported.
COMPLIANCE STATUS:
On May 5, 2025 Division staff performed the 2025 Decontamination and Wash Facilities
Groundwater Module 4 Inspection at the Clive Site. As a result of this inspection, issues
confirming the functionality of the leak detection system at the East Side Rotary Facility
Manhole IA, and a leaking wastewater collection tank at the Rail Car Wash Facility on Track
No. 4, as well as associated issues regarding BAT inspection report accuracy, were observed and
documented by Division staff.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -11-
GWQDP Module 4 Inspection May 2025
EnergySolutions GWQD Permit, UGW ./50005
ISSUES:
1. Upon inspection of the north and south ramps of the East Side Rotary Facility, it was
noted by Division staff that minor cracks in the curbing of the ramps appeared to occur in
conjunction with the location of control joints. No cracks exceeding 1/8" were observed,
however, this will continue to be monitored by staff in future inspections.
2. Manhole No. IA is a dry manhole that provides access to pipeline No. 4b. It is located
inside of the East Side Rotary Facility and collects wastewater and storm water runoff
from the East Side Rotary Facility sedimentation basin. A leak detection sensor and drip
leg are installed and the sensors activate a strobe alarm mounted on the outside of the
East Side Rotary Facility. While completing the inspection of the East Side Rotary
Facility on May 5, 2025, Division inspectors observed that EnergySolutions staff was
unable to confirm the absence of fluid in the drip leg in Manhole IA due to visual
obstacles in the manhole and spatial confinement.
Inspection of the drip leg in Manhole 1 A by EnergySolutions BAT staff is required in the
Ground Water Discharge Permit on a monthly basis as identified in Appendix J, Table 1.
Division inspectors confirmed with EnergySolutions staff that they have been unable to
perform this aspect of confirming the functionality of the alarm since the Facility went
into service; however, monthly BAT reports completed by EnergySolutions staff show no
indication that the drip leg in Manhole IA was unable to be observed, and have been
marking that the inspection of the functionality of the alarm was completed.
EnergySolutions must have a way to visually inspect the absence of fluid in the drip leg
to confirm the functionality of the system and should be accurately reporting if the
performance criteria identified in Table 1 of Appendix J have been achieved on the
monthly BAT inspection reports.
3. During the inspection on May 5, 2025, Division inspectors observed dampness under the
wastewater storage tank at the Rail Car Wash Facility on Track No. 4, which was
determined to be caused by a leak in the wastewater storage collection tank. Because
water from this leak was prevented from discharging to the ground by the drain within
the secondary containment wall, and water was not observed by EnergySolutions to rise
above the level of the grate in the sump, this event did not constitute a BAT failure
(Appendix J, Table 1) and EnergySolutions was not required to provide notification to the
Division following discovery. However, observation of the leaking wastewater storage
tank, which serves as primary containment for the contact water generated at the Rail Car
Wash Facility, prompted further discussion by Division staff regarding the performance
criteria listed in Appendix J of the Permit. Results of this discussion suggest the
performance criteria listed in Table 1 of Appendix J, which identifies a BAT failure as
the failure of the secondary containment of the system ( water level rises above the level
of the grate in the sump) is not adequate. The functionality of secondary containment is
listed as the criterion of a BAT failure at several Facilities. It is suggested here that
modification of the performance criteria as listed in Table 1 of Appendix J to identify
failure of the primary containment system as the constitution of a BAT failure is more
appropriate and conservative of the protection to human health and the environment.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -12-
GWQDP Module 4 Inspection May 2025
EnergySolutions GWQD Permit, UGW ../50005
In making this modification, failure of the primary containment system would trigger
consequential 24-hour and 5-day notification to the Division if the failure is not able to be
resolved within 24 hours of observation, and the implementation of the appropriate BAT
Contingency Plans as identified in Appendix K. This change would require
EnergySolutions to address failures of primary containment systems within 24 hours and
prevent secondary containment systems from operating as primary containment systems
for prolonged periods of time. Furthermore, modification to these criteria ( and
subsequent requirements for reporting) would provide the Division with a more accurate
idea of conditions at the Site and the functionality of systems to operate as designed.
After the inspection on May 5, 2025, Division staff requested additional BAT records to
determine whether the leaking waste water collection storage tank at the Rail Car Wash
Facility on Track No. 4 had been recorded by EnergySolutions BAT staff prior to the
Division inspection/confirm it had been documented in the EnergySolutions BAT
inspections following the inspection on May 5th. Division inspectors did not find that any
leak had been observed during the weekly inspection of the storage tank in the time
before the inspection. The limited amount of dampness observed under the storage tank
during the inspection on May 5th would suggest that it would be reasonable the leak could
have occurred after the EnergySolutions weekly BAT inspection the week prior and
would not have been noted on the associated inspection form. However, on the weekly
inspection form dated May 6th, 2025 , which took place the day after the Division
inspection, EnergySolutions BAT inspectors failed to document that there was an
identified leak at the facility or record any maintenance activities that were occurring.
Again, the Division expects BAT forms completed by EnergySolutions staff to accurately
reflect the conditions of inspected facilities during daily, weekly, and monthly BAT
inspections.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -13-
GWQDP Module 4 Inspection
EnergySolutions GWQD Permit, UGW ./50005
SIGNATURE:
Prepared By:
Bailey Anderso
LLRW Section, Hydrogeologist
Utah Division of Waste Management and Radiation Control
Reviewed and Approved By:
~ ~
Lawrence Kellum
LLR W Section, Section Manager
Utah Division of Waste Management and Radiation Control
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -14-
May 2025
Date
Date
GWQDP Module 4 Inspection
1--,nergySolutions GWQD Permit, lJGW -150005
UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL
Attachment 1 to Narrative
2025 Division Inspection Form
-15-
May 2025
Division of Waste Management and Radiation Control lnspedic)n Form:
Module 4 Inspection
-LLRW Wash Facilities
Pagel
INSPECTION ITEM~ LLRW Wash Facilties (Module 4): (j\ec:-,On, 0\ CC S S cof\tro, '0\/\\\a,,l'Q ~
IO :4o • LLRW Rail Car Wash Facility on Track No. 4~ \ \ ~4~ • LLRWRotaryDumpFacility~S\C1ie.5
\0: ()Q • LLRW Intermodal Container Wash Building I • ,
t, ~.aJ>•_ Easts_ ~de Jmmage s!~tem'f -3P MOlf).nO\eS \ 11 __ -~ 1~~ \-t \ -~ • East Side Rotary Fac1hty 3 ,-l MOnrt,~ J..A • .
. CfJr\~\J S V\OSh V'Oet +ram ~O\C) Uffl~ tO Oil POt\C\
LLRW 8-:d Car Wash Fac11Ity on Track No. 4 . . . . _ . _ ,
I. Facility BAT Performance Standards and Compliance Monitoring Points (Parts I.E.14(c), f.F.2{g),
and I.F.18) -did Permittee operate and maintain the Rail Car Wash Facilities to: • • •
a. Provide free~g of the concrete containment rail floor, to concrete trenches and floor.sump?
• ' • • • • •• • • hes· □ No □ Violation: •
f\-''
b. Water level in!l_l11A.1N ·:~low grate and pump is operaµonal
-~ \l)-r £>fYC,.-'C,\) -M:Yes □ No □ Violation
c. Maintain integrity of the concrete floor, floor sumps, and conveyance pipes, to prevent
discharge~YD_c C \{\I"\~ Of C\J1 rbS@ cantrV\. J()\t )tS'(S rC\mp P\C) ¥Yes □No □ Violation
d. Maintain integrity of the Collected Water Receiver Tank, Filtered Water Storage Tank, and
concrete secondary containment vault around the tanks J!iJhx.~jacent ~PIR~¼nec~c~ I'\
building to prevent disc~~x7 d Q\mpn-es-s l,.\{ Ut1 \'\JoS~ V\j~t S1':j IV\I) ¥.
bf no I\'. te{X) r ~ \RE.) □ Yes □ No □ Violation
2. Records Review
a. Maintain written records of all daily inspections?
"f'Yes □No • □Violation,.
b. Have daily inspection records comply with Part 11.G of P~nnit? 7' Yes □ No · . . □ViolatiQn
Decontamination Facilities, GW Module 4, Version 9 DRAFT, updated 4-30..2025
Division of Waste Management and Radiation Control Inspectiun Form
Module 4 Inspection
c. Maintain written records of all -weekly inspections?
~Yes □No
d. Have weekly inspection records comply with Part 11.G of the Permit?
J(Yes □No
e. Maintain written records of all monthly inspections?
-rf._Yes □No
f. • Have monthly inspection records comply with Part II.G of the Permit?
"A.Yes □No
LLRW Wasb Facilities
Page2
□ Violation
□ Violation
□ Violation
□ Violation
3. Rail Car Wash Facility on Track 4 BAT Reportjng (Pa,rt i.H.20) ~ since last inspection, did
Permittee discover any BAT failure, including: free draining conditions at floor sumps, free
draining conditions through wastewater drainage pipes, integrity of concrete workiJ.1:g_ surfape,
Collected Water Receiver T~ Filtered Water StorageTaruc: and concrete secondary ,. •
containment vault? • •
o Yes ·' ,)QNo
lfYES: didPermittee report said BAT failure within14-hours (verbally)and 5;..~s (written),
pursuant to Part 111?
□Yes □No □ Violation
Comments: ----------------------------
Part 11.G of the Penn.it, Records Contents
Where applicable,-~ of monitoring information shall include:
1. The date, exact place, and time of sampling or measurements,
2. The individual(s) who performed the sampling or measurements,
3. The date(s) and time(s) analyses were performed, • •
4. The individual(s) who performed the analyses,
5. The analytical techniques or methods used, and
6. The results of such analyses.
Decontamination Facilities, OW Module 4, Version 9 DRAFT, updated 4-30.2025
Division of Waste Management and Radiation Control Inspection Form. · LLRW Wash Faciliu.
Module 4 Inspection . e
f T V\J
LLRW West Side Rotary Dump Facility VV Sh
1. Facili BAT Performance Standards arid Com liance Monitorin Points arts I.E.21 I.F .2 • an Pf-EC\
I.F. 26) -did Permittee operate and main~ibs7'f~ ~cntto\ rl't) ( \" \'\I \') Cent)
~ Provide free drainage and integrity of all compliance concrete surfaces (including curbing at east
end of building?
□Yes □No o Violation
X Maintain the water level in the sediment basin below the grate over the pump?
□ Yes o No □ Violation
~. De~the presence of fluids in the Sediment Basin leak detection system? ~5\~:sr) · o Yes o No o Violation
d. Maintain free draining conditions in all wastewater transfer piping?
}(Yes □ No o Violation
~· Detect the presence of fluids in the leak detection annulus within the secondary pipe of all dual-
wall~ wastewater transfer piping systems?
l G'\ \U\tffi) □ Yes □ No o Violation
2. Records Review
a. Maintain written records of all daily inspections?
j.J. Yes □No
b. Have daily inspection records comply with Part 11.G of Permit?
~Yes □No
c. Maintain written records of all weekly inspections?
'A.Yes □No
d. Have weekly inspection records comply with Part 11.G of the Permit?
y...Yes □No
e. Maintain written records of all monthly inspections?
J-Yes □No
f. Have monthly inspection records comply with Part 11.G of the Permit?
~Yes □No
Comments:
□ Violation
□ Violation
□ Violation
□ Violation
o Violation
o Violation
---------------------------
Decontamination Facilities, OW Module 4, Version 9 DRAFT, updated 4-30-2025
Division of Waste Management and Radiation Control lmpeetion Form '
M:odule 4 Insrction
LLRW Wash Facilities
Page4
3. Rotary Dump Wash Facility BAT Reporting (Part l.l:l,io) -since.fast inspect,ion, djd::Per111ittee. ,
discover any JJATfailure, .. including: ~ d.rauµng,conditions at floor sum.ps, free ~g conditi9ns
through wastewater drainage pipes, integrity. of concrete working surface, and Jeak d~ection systems
free of fluid? ••
~Yes
If YES: did Permittee report said BAT failure within 24-hours (verbally) and 5-days (written),
pursuant to Part Ill?
Decontamination Facilities, OW Module 4, Version 9 DRAFT, updated 4-30-2025
Division of Waste Management and Radiation Control Inspeetion Form .
Module 4 Inspection
LLRW Wash Facilities
Pages
LLRW lntermodal Container Wash· Building
1. Facility BAT Performance Standards and Compliance Monitoring Points (Parts 1.E.22, I.F.2(k), and
I.F .27) -did Permittee operate and maintain the Intermodal Container Wash Building to:
a. Provide free-drainage and integrity of concrete floor and floor trenches?
)dYes □No □ Violation
b. Maintain the water level in the sediment basin below the grate over the sump?
)(Yes □ No □ Violation
c. Maintain .the leak detection annulus of the sediment basin free of liquids? l~,ror tX)rtS1 ~Yes ~o
d. Maintain free draining conditions. in all wastewater transfer piping?
~Yes .JstNo
e. Prevent the presence of fluids in the Sediment Basin leak transfer piping?
□ Violation
□ Violation
'J( Yes • □ No □ Violation
f. ~ the presence of fluids in the leak detection annulus ~.thi.u ~e ~on~ pipe of all dual-
~~astewater transfer piping systems to manhole 1? t'Y' fV\\J{')f\\J\--e .1) ~ ~ es □ No □ Violation
2. Records Review
a. Maintain written records of all daily inspections'?
").i_Yes □No □ Violation
b. Have daily inspection records comply with Part 11.G of Permit?
JlYes □No □ Violation
c. Maintain written records of all weekly inspections?
'p...Yes □No □ Violation
d. Have weekly inspection records comply with Part 11.G of the Permit?
'f!._Yes o No o Violation
e. Maintain written records of all monthly inspections?
liJ.._Yes □No □ Violation
f. Have monthly inspection records comply with Part 11.G of the Permit?
'f.,Yes □No o Violation
Comments: ----------------------------
Decontamination Facilities, GW Module 4, Version 9 DRAFT, updated 4-30-2025
Division of Waste Management and Radiation Control Inspection Form
Module 4 Inspection
LLRW Wash Facllitift
Page·6
3. lntermodal Container Wash Building BAT Reporting {Part I.H.20) .~ since last inspection. .did
• • J>ermittee discover any BAT failure, including: free draining conditions.at floor sediment basin.1;1nd
sump~ free draining conditions through wastewater drainage trenches~ .and integrity of concrete •
working surface?
□Yes ~No
If YES: did Permittee report said BAT failure within 24-hours (verbally) and 5-days (written),
pursuant to Part Ill? □ Yes □ No □ Violation
Comments: ----------------------------
Decontamination Facilities, GW Module 4, Version 9 DRAFT, updated 4-30-2025
Diviskm of .W:aste Ma"3gement and Ra®atic>n Contr~ Inspection Form . ·
Module 4 Inspection
East Side Drainage System
LLR\V-Wasb Facilittes
Pagc7
1. Facility BAT Performance Standards and.Compliance Monitoring Points {Parts I.E.24, I.F.2(m), and
LF.29) -did Permittee operate and maintain the East Side Drainage System to:
a. Contain all contact water within the system?
'f</.Y es □ No □ Violation
b. Detect fluids in the leak detection annulus within the secondary pipe of all .dual-walled
wastewater transfer piping systems?
o Yes 9<No □ Violation
){Yes
)(Yes
2. Records Review
a. Maintain written records of all daily inspections?
}(Yes
b. Have daily inspection records comply with Part 11.G of Permit?
~Yes
c. Maintain written records of all weekly inspections?
□No o Violation
□No o Violation
o No o Violation
□ No o Violation
1' Yes o No □ Violation
d. Have weekly inspection records comply with Part II.G of the Permit?
'}(.Yes o No o Violation
e. Maintain written records of all monthly inspections?
-,..Yes □ No □ Violation
f. Have monthly inspection records comply with Part 11.G of the Permit?
)l Yes □ No □ Violation
L\ <0100 \
Deconlamination Facilities, GW Module 4, V er.iion 9 DRAFT, updated 4-30-2025
Division· of Waste Management and Radiation Control Inspection Form
Module 4 Inspection
f.LRW Wash Facilities
• 'Pages
3. East Side Drainage System BAT Reporting (Part I.H.20) -since last'inspet;fio1'i did Permittee : •
• discover any BAT failure,· including:. free draining. conditions in all wastewater transfer piping,
absence of fluids in the leak detection annulus within the secondary pipe of the dual-walled piping
system, and absence of discharge to the ground or groundwater?
, ')qYes □No
If YES: did Perminee report said BAT failure within 24-hours (verbally) and 5-days (written),
pursuant to Partlll? ;
• . o Violation
Decontamination Facilities. GW Module 4, Version 9 DRAFT, updated 4-30-2025
Divisioa of Waste Management and Radiation Control (Qpeetion Form . LLRW, Wash Facilities
Module 4 Inspection . Page 9
~ D\ s~ D\'00\At ~\C:Ot \f 1.SP *
LLRW East Side Rotary Dump Facility
1. • Facility BAT Performance Standards and Compliance Monitoring Points (Parts I.E.28, I.F.2; and lF.
31} -did Permittee operate and maintain the East Side Rotary Dump ·Facility to:
f. Provide free drainage and integrity of all compliance concrete surfaces (including curbing at east
end of buildin8f
• y....Yes □No a Violation
g. Maintain the water level in the sediment basin below the grate over the pump?
• ~ Yes □ No □ Violation
~-Detect the presence of fluids in the Sediment Basin leak detection system?
o Yes ~o □ Violation
i. Maintain free draining conditions in all wastewater transfer piping?
~Yes □No □ Violation
j. Detect the presence of fluids in the leak detection annulus within the secon<!m.Y pipe of all dµal-
walle.sl ~&tf transfer piping systems? \\/Pl'l DO le \A ( N'OnhO \e 1. cqqrJS~ 4C!0 ~,
Q\Utl\J' \1,....-t\'\er~ \S f\O O Yes O No □ Violation y,?8\\De, •/
s-Q'tli-canf\ro~\' \f\ MB1 .o-ccessb~ ~ iA ~ f)() NO.y "\O ..JO\\CX«r,
2. Records Review 49 9\~\f)Q ~ r'O¼-~
g. Maintain written records of all daily inspections?
~Yes □No
h. Have daily inspection records comply with Part II.G of Permit?
)(Yes □No
i. Maintain written records of all weekly inspections?
7lYes □No
J. Have weekly inspection records comply with Part Il.G of the Permit?
J Yes □No
k. Maintain written records of all monthly inspections?
'jJ.Yes □No
1. Have monthly inspection records comply with Part 11.G of the Permit?
o Violation
o Violation
□ Violation
o Violation
o Violation
"j,! Yes □ No □ Violation
Comments: ( $00 j 1')
Decontamination Facilities, GW Module 4, Version 9 DRAFT, updated 4-30-2025
Division of Waste Management and Radiation Control Inspection Form
• Module 4 Inspection
LLRWWash Facilities
Page 10
3. Rotary Dump Wash Facility BAT Reporting (Part I.H.20)-si'nce.last inspection, did.-Permittee
discover any BATfailure,. including: free draining conditions at floor sumps, free ~ning conditiQns
through wastewater drainage pipes, integrity of concrete working surface, and leak detection systems
free of fluid?
.□Yes ~No
If YES: · • did Permittee report said BAT failure within 24-hours (verbally) and 5-days (written),
pursuant to Part Ill?
□Yes □NO.· □ Viola:tion
Comments: ----------------------------
Deconmmination Facilities, GW Module 4, Version 9 DRAFT, updated 4-30-2025
'l . .
.
: I
V •
Division of Waste Management and Radiation Control Inspection Form
Module 4 Inspection
Deconlamination Facilities, GW Module 4, Version 9 DRAFT, updated 4--30-2025
LLRW Wash Facilities
Pagell
..