DRC-2025-001814

Inspection Report Review
EnergySolutions' 2024 Annual Groundwater Withdrawal Survey. May 2025
EnergySolutions' 2024 Groundwater Withdrawal Survey,
Part l.H.13 of Ground Water Quality Discharge Permit, No. UGW 450005,
Groundwater Module 11 Inspection
INSPECTION REPORT FOR:
Clive Disposal Site
EnergySolutions, LLC (EnergySolutions)
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
(801 )649-200031
SITE ADDRESS:
Energy Solutions
Clive Disposal Site
2-miles south of Interstate 80, Exit 49
Clive, UT 84029
SITE CONTACT:
Mathew R. Schon
Manager, Groundwater and Environmental Program
[phone]
.TYPE of INSPECTION:
A review of Energy Solutions' Annual Groundwater Usage Report, titled "2024 Groundwater
Withdrawal Survey". This report was received by the Division on January 8, 2025, and assigned
for review on February 26, 2025.
APPLICABLE REQUIREMENTS:
Requirements are found in Radioactive Material License UT2300478; and Ground Water Quality
Discharge Permits, UGW450005 (hereinafter Permit).
Part I.H.13 of the Permit requires EnergySolutions to:
"On or before March 1 of each calendar year the Permittee shall survey and
report the location of all ground water withdrawals within at least a I -mile radius
of the facility boundary. The purpose of this report will be to locate all points
near the facility where ground water is pumped or otherwise removed for any
consumptive use, including domestic, agricultural, or industrial purposes. This
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Inspection Report Review
EnergySolutions' 2024 Annual Groundwater Withdrawal Survey. May 2025
report shall include a survey of water right appropriations found in the area of
interest, identify the owners thereof, and disclose the physical location and depths
of all such ground water withdrawals."
License Condition 12.3 of Radioactive Material License UT2300478 requires Energy Solutions
to:
"The Licensee shall conduct an annual land use survey for a 5 km radius around
the site. The purpose is to assess population growth or industry growth in the
immediate vicinity of the Clive facility and provide an inventory of domestic and
agricultural wells within the survey area. The Licensee shall document this survey
in the 1 le. (2) Annual Report. "
INSPECTION REPORT PREPARED BY:
Charles Bishop, P.G, Hydrogeologist,
LLR W Section,
Utah Division of Waste Management and Radiation Control
SITE DESCRIPTION:
The Clive Site is approximately 2 miles south of Interstate 80, 7 5 miles west of Salt Lake City,
and 55 miles east of Wendover, Utah. The site occupies about four square miles in Tooele
County, Utah, including all of Section 32 and parts of Sections 29, 30, 31, and 33 of Township 1
South, Range 11 West, Salt Lake Base and Meridian (SLBM), and part of Sections 5, Township
2 South, Range 11 West SLBM. The climate of the Clive Site is arid to semi-arid, with wide
seasonal and diurnal temperature ranges and average annual precipitation of about 8.5 inches,
and annual evaporation can be as high as 60 inches. Most of the annual precipitation occurs in
late spring and early summer and is highly variable coming in the form of scattered convective
thunderstorms during the summer. The Clive Site is east of the Great Salt Lake Desert and is in
the Great Basin physiological province, a hydrologically closed region with no surface outlet to
an ocean; water leaves the Great Basin by evaporation. The Ceder Mountains rise to the east of
the Clive Site to an altitude of more than 6,000 feet. Surface runoff, which generally results from
intense summer thunderstorms have no distinct channels in the Clive area, but distinct ephemeral
stream channels from the mountains towards the Great Salt Lake Desert are recognized, but
channels vanish before reaching the Clive Site. Paleozoic carbonate and quartzite and Tertiary
age extrusive rocks are prominent in the higher surrounding areas. Paleozoic rocks protrude
through the valley sediments flanking the mountains. The valley sediments consist of varying
combinations of wind-blown, alluvial-fan deposits of pre and post-Bonneville lake-cycles that
were moderately reworked by lacustrine processes, and lacustrine deposited sediments in which
silt and clay predominate, and fine sand and marl are subordinate.
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Inspection Report Review
EnergySolutions' 2024 Annual Groundwater Withdrawal Survey. May 2025
CREDENTIALS, PURPOSE AND SCOPE:
Groundwater development could adversely affect the natural flow of groundwater in the vicinity
of the Clive Site and provide additional potential pathway for contamination to leave the site.
EnergySolutions maintains about 65 compliance monitoring wells that are used to determine
shallow groundwater head distributions, groundwater-flow rates, groundwater gradients,
groundwater flow directions, compliance with Permit conditions, and when referenced to time
reviles changes in groundwater flow brought about by natural or human influences.
Groundwater development near the Clive Site may affect these monitoring wells and may
necessitate a modification of the site groundwater monitoring system and/or the Permit. The
Division requires Energy Solutions to monitor groundwater development in the area of the Clive
Site on an annual basis.
MANAGEMENT ACTIVITIES:
Energy Solutions' Clive Site is permitted, licensed, and authorized to receive and dispose of Class
A LLRW, NORM/NARM waste, Class A mixed hazardous and radioactive (Mixed) LLRW
waste, l le.(2) Byproduct Materials, Special Nuclear Materials based on concentration limits, and
Polychlorinated Biphenyl (PCB) Radioactive LLRW Waste. The Clive Site currently consists of
three separate operable units: the lle.(2), Mixed, and Class A West 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. Currently, the facility has about
110 employees and operates a single ten hour shift, four days a week.
NARRATIVE:
EnergySolutions' 2024 Groundwater Withdrawal Survey was received by the Division on
January 8, 2025 , the Division completed field work on this inspection on May 12, 2025 . This
submitted report is the annual groundwater Module 11 inspection and is intended to identify, if
any, localities near the Clive Site where groundwater development is taking place.
The appropriation and distribution of water in Utah is regulated by the Division of Water Rights
(DWR). The DWR maintains public records pertaining to water appropriation, distribution, and
use, and provides a computerized water rights database for the State of Utah. Energy Solutions
accessed the DWR database at its on-line website, eventually reaching the query page
www.waterrights.utah.gov/wrinfo/quary.asp. A Point of Diversion Query of the database (within
the Water Rights Search folder), with a survey radius of 10,560 feet (2-miles) from the center of
Section 32 , Township 1 South, Range 11 West SLBM, this radius included Sections 29, 31 , 32,
and 33 ; and parts of Sections 28 , and 30; Township 1 South, Range 11 West SLBM; and Section
5 and parts of Sections 4, and 6; Township 2 South, Range 11 West SLBM was used by
Energy Solutions. Any active legal withdrawals of water, associated with a water right, occurring
in the search radius should show up using these parameters in this search of the water rights
database.
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Inspection Report Review
EnergySolutions' 2024 Annual Groundwater Withdrawal Survey. May 2025
Energy Solutions' I-mile search radius yielded two active water rights belonging to Clean
Harbors Environmental Services. This is the same result as the 2023 search. EnergySolutions
provided a DWR map indicating the two water rights (water appropriations) within the 10,560
feet search radius. The DWR website includes a notice about the accuracy of the data, including
water appropriation locations, indicating they do not verify the locations. Energy Solutions
reported that the two wells were actually located 1.4 miles west of the Clive Site, outside of the 1-
mile search radius, but the DWR search places them on the edge of the search radius. The
existing water rights reported within the I-mile radius of the Clive Site are listed in Table 1.
Table 1. Active water rights (appropriations) identified using the DWR database, within a I-
mile radius of the EnergySolutions' Clive Site.
# Water Right Owner Name Diversion Location *Status **Use Number Type (SLBM)
1 16-919 Clean Harbors Underground N73 ft, E286 ::::: 1.4 mile A 0
Environmental well ft from S4 west of
Services comer 36 IS Clive Site
T2WSLBM
2 16-917 Clean Harbors Underground N73 E286 S4 ::::: 1.4 mile A 0
Environmental well 36 TIS west of
Services R12WSLBM Clive Site
* Pis Perfected, A is Approved * * S is stock watering, 0 is other ***
The two wells owned by Clean Harbors Environmental Services, water right appropriation 16-
91 7 and 16-919, were for well drilled sometime in the 1990s that were allowed to expire in the
late 1990s. The newer water rights were established on March 4, 2021, and May 7, 2021,
respectively. Clean Harbors redeveloped the two wells because their traditional water source
became unreliable. To use the well water Clean Harbors had to build a reverse osmosis system to
treat the water and improve its quality, so it was adequate for use as process and fire-suppression
water. It appears that Clean Harbors Environmental Services is only using one of the wells, and
the other is a stand-by well (personal communication, Clean Harbors Environmental Services).
These wells are pumping water from a greater depth ( deeper aquifers), than the monitored
shallow aquifer at the Clive Site.
EnergySolutions also performed a larger search to meet the requirement of License Condition
12.2 of Radioactive Material License UT2300478, using a 4-miles radius from the center point of
Section 32. This information is not required by Part I.H.13 of the Permit, but License Condi.tion
12.3 requires an annual land survey for a 5 km (3 .1 miles) radius around the site to identify
domestic and agricultural wells. EnergySolutions used the Point of Diversion Query, with a
survey radius of 21,120 feet (4-miles) from the center of Section 32, Township 1 South, Range
11 West SLBM. This radius encompasses a minimum 3 .1 miles ( 5-kilometers) radius from the
site boundary, and included parts of Township 1 South, Range 11 West; Township 2 South,
Range 11 West; Township 1 South, Range 12 West; and Township 2 South, Range 12 West
SLBM.
This Energy Solutions' 4-mile search radius yielded four additional water rights, three of the
water rights are active and were the same water rights that were identified previously in other
Groundwater Usage Reports. These are outside of the I-mile radius from the site boundary
search required by Part I.H.13 of the Permit. EnergySolutions provided a DWR map indicating
4
Amount
(ACFT)
100.0
11.201
Inspection Report Review
EnergySolutions' 2024 Annual Groundwater Withdrawal Survey. May 2025
the water rights (water appropriations) within the search radius. The Division did a similar search
of the DWR database and verified Energy Solutions findings. Additionally, existing water rights
within a 4-mile radius of the Clive Site, excluding the two water rights reported with the I-mile
radius search of the site, are listed in Table 2.
Table 2. Additional, active water rights (appropriations) identified within a 4-mile radius of the
E S l t" 'CZ-s·t nerf! v, o u wns 1ve le.
# Water Right Owner Name Diversion Location *Status **Use Number Tvoe (SLBM)
I 16-190 Skull Valley Underground Sl56 ft, E800 ft ::::: 3 miles p s
Company LTD well NW comer of sec. east of
36 ofT2S, Rl2 W Site
2 16-702 Utah School and Surface N700 ft, E770ft :::::2.5 p OS
Institutional from SW comer of miles east
Trust Land sec.IO TIS, RI I W southeast
Administration of Site
3 16-772 Energy Solutions Underground S2100 ft, E 1100 ft ::::: 2.5 A 0
LLC well Wl4 NE 18 TIS, miles
RIIW northwest
of Site
4 16-761 AMAX Underground Sl200, W200 6 miles O*** 0
well TIS, Rl2W NE of
Knolls
* Pis Perfected, A is Approved ** Sis stock watering, 0 is other *** well was temporary approved in 1987 for I-year
Water Right 16-190 is for a 6-inch well (sometimes referred to as the Deseret well) used for
livestock watering, but no production information was available. EnergySolutions is the owner of
the well associated with water right 16-722, and uses the well water for dust abatement, and soil
and waste compaction at the Clive Site. Water Right 19-702 is for a small surface impoundment
to collect surface runoff used for livestock watering that was previous attributed ( owned) to the
U.S. Bureau of Land Management. There is not a well associated with Water Right 19-702
Water Right 16-761 was owned by Amax (Amax Great Salt Lake (GSL)). Amax GSL recovers
minerals from the brines associated with the Great Salt Lake Desert. Amax GSL has extensive
operation near Wendover, Utah on the west side of the Great Salt Lake Desert where it recovers
brine and operates some large brine evaporation ponds. Amax GSL in the late 1980s began
developing some additional brine recovery operation on the east side of the Great Salt Lake
desert, about 10 miles northwest of the Clive Site that is still in operation. Amax GSL (through
Morrison-Knudsen Engineering) received approval for a temporary well to provide water for
dust control and dike compaction. The well was drilled in late 1988 and was completed to a
depth of 452 feet, with a 14-inch casing at the surface. The location for the well on the driller
report places it within a 5-km radius of the Clive Site. A search on May12, 2025 of the area
where the well was supposed to be located found no such well (Figure 1). Correspondence
between Morrison-Knudsen Engineering and the DWR indicates the well is on property owned
by Amax GSL. A review of the land status on the south end of the Gray Back Hills indicates no
land belonging to Amax GSL, only land belonging to the Bureau of Land Management is found
in the area (Figure 2). It is possible that a well was located in the area, and since it was only
temporarily approved by DWR, the well could have been completely removed after one year.
Currently there is no evidence of a 14-inch well in this area.
5
Amount
(CFS)
0.38
-
0.720
0.45
Inspection Report Review
EnergySolutions' 2024 Annual Groundwater Withdrawal Survey. May 2025
Figure 1. View of the southern end of the Gray Back Hills, the area where the Amax GSL well
is supposed to be located. A search of this area on May 12, 2025, located no large diameter well.
Roads
TCRoads Funding Class
Multilevel
TCRoads
DOT Funding Class
Class A -State
Class B -
County
Class C -
Municipality
Parcels
Parcels 40k-8k
MiliraryAreas
Military
Municipalities
Incorporated Municipalities
□
County Unicorporated Areas
Tooele County Interactive Map
Figure 2. Land status at the south end of the Gray back Hills showing the land belongs to the
BLM.
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0.4mi
Inspection Report Review
EnergySolutions' 2024 Annual Groundwater Withdrawal Survey. May 2025
Summary
The report was received on January 8, 2025, before the March 1 submittal date specified by Part
I.H.13 of the Permit. The survey required by Part I.H.13 of the Permit included all of, or parts of
sections 28, 29, 30, 31, 32, and 33 of Township 1 South, Range 11 West; and section 4, 5, and 6
of Township 2 South, Range 11 West SLBM, ensuring a minimum I-mile radius from the site
boundary. The report also includes an annual submittal using a 5-km search radius as specified
by Condition 12.2 of Radioactive Material License UT 2300478
Groundwater usage near EnergySolutions' Clive Site has changed in the last couple of years, with
the addition of the Clean Harbors Environmental Services wells. These wells are the closest
operating wells to the I-mile radius of the site. With the relatively small amount of water
production from the main well, and much less from the stand-by well and their distance from
EnergySolutions Clive Site's operations it is not likely that the wells are affecting the Clive Site
itself. Based on this water right descriptions, well locations, distances from the EnergySolutions
Clive Site, and their water production, they probably have no effect on ground-water levels at the
EnergySolutions Clive Site.
Requirements of Part 1.H.13 of the Permit and Condition 12.2 ofRML UT23000478 appear to
have been satisfied by the submittal of the EnergySolutions' 2024 Groundwater Withdrawal
Survey.
Reference
EnergySolutions, January 8, 2025, 2024 Groundwater Withdrawal Survey, Part I.H.13
Groundwater Quality Discharge Permit (GWQDP) No. UGW450005: letter to, Director of
Division of Waste Management and Radiation Control from, Energy Solution's Environmental
Compliance Manager, DRC-2025-000132.
COMPLIANCE STATUS:
The 2024 Annual Groundwater Withdrawal Survey meets the requirements of Part I.H.13 of the
Permit.
ISSUES:
No outstanding compliance issues as a result of GW Module 11 inspection.
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Inspection Report Review
Energy Solutions' 2024 Annual Groundwater Withdrawal Survey.
SIGNATURE:
Prepared By:
I
,, {V"i,~ ~ ,M th •r?
Charles Bishop, P.G, Hydrogeologist,
LLR W Section
Utah Division of Waste Management and Radiation Control
Reviewed and Approval By:
~um,f1f::l Radioactive Waste Section Manager
Division of Waste Management and Radiation Control
8
May 2025
~ -3 ... 20 2 :;-
Date