DRC-2025-001754

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com
June 2, 2025 CD-2025-109
Mr. Doug Hansen, Director Division of Waste Management and Radiation Control 195 North 1950 West Salt Lake City, UT 84114-4880
Subject: Radioactive Material Licenses No. UT 2300249: Response to Compliance Advisory No. 2504003 Compliance Evaluation Inspection
Dear Mr. Hansen: EnergySolutions respectfully responds to the May 14, 2025 Compliance Advisory issued by the Division of Waste Management and Radiation Control concerning the management of low-level radioactive waste with unanticipated free liquids at the Class A
West embankment.1 We value the Division’s thorough evaluation and welcome the opportunity to clarify compliance with Conditions 17 and 68 of Radioactive Material License UT 2300249 (License) and address the management of unanticipated free liquids. Director’s Request: Please provide the Division with the following: 1. Documentation supporting why the Class A West Disposal Cell is included in the procedure CL-CH-PR-252 definition of an Approved Unanticipated Liquid Management Facility. 2. Details of EnergySolutions’ training program for personnel performing 1% free liquid volume determinations as specified in procedure CL-CH-PR-252 section 4.1.1.6. Timeline and Factual Clarifications: To clarify events associated with the Compliance
Advisory, EnergySolutions provides the following timeline:
• February 17, 2025: A potential leak was identified during the Radiological Acceptance Survey of Shipment 9088-30-0215 (one intermodal container,
ESUU100666, in a set of six on a flatbed railcar that arrived February 13, 2025
from GSAP 0111000762). The generator was promptly notified, notification was provided to the Director via CD-2025-030 and CD-2025-038, the container was transferred to the Restricted Area, and an investigation commenced. Condition Report # CR-2025-0178 was written to track resolution of this discrepancy. The

1 Hansen. D.J. “Compliance Advisory No. 250400 - Compliance Evaluation Inspection: Radioactive Material Licenses No. UT 2300249 and No. UT 2300478” (DRC- 2025-001311) Letter from the Division of Waste Management and Radiation Control to Vern Rogers of EnergySolutions, May 14, 2025.
Mr. Doug Hansen CD-2025-109 June 2, 2025 Page 2 of 5
299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com
generator committed to reassessing seal and package integrity for subsequent
shipments to prevent recurrence.
• March 3, 2025: Intermodals from shipments 9088-30-0210 through 9088-30-0215, including intermodal ESUU100666 (the one previously identified as
leaking on February 17, 2025) were kept in storage awaiting license-required
incoming shipment analytical data. The data was received this day and confirmed to meet profile requirements. The intermodals were then prepared to be off-loaded the next day. Contrary to the Advisory’s claim, no containers were opened on March 3, 2025.

• March 4, 2025: Intermodals ESUU100585 and ESUU100454 from Shipment 9088-30-0215 that also arrived on February 13, 2025, did not indicate any leaks at the time of receipt or at any time while in storage. However, on March 4, 2025, as
operations was preparing these containers for disposal, small leaks were
identified. Liquid was dripping from the bottom seal of Intermodal ESUU100454 and from the floor of Intermodal ESUU100585. The Contingency Plan was implemented and the leaks contained.
EnergySolutions contacted the generator on March 4, 2025 to inform them of
similar discrepancies with Intermodals ESUU100585 and ESUU100454. The generator responded to this discrepancy and applied corrective actions that included additional amounts of absorbent in each container, both granular and mats, to mitigate the potential of free liquid generation during transport. The
generator also requested Clive operations assess the tightness of the door chains
and provide pictures and notes as the back door on the intermodal is opened, to identify any deformities or obstructions in the seals that may have caused these issues and to better focus tailored corrective actions prevent recurrence. Condition Report # CR-2025-0178 was expanded to include leaking intermodals
ESUU100585 and ESUU100454. Notification was provided to the Director via
CD-2025-047 and CD-2025-051. As there was no indication that the 3 leaking intermodals contained greater than one percent free liquid, all three were off-loaded in the Class A Embankment.
Approximately 40 gallons of unanticipated free liquids were observed from each
of these intermodals as they were off-loaded, and a trained technician, certified per CL-CH-PR-252, Section 4.1.1.6, conducted a 1% Free Liquid Volume calculation based on the estimated amount of unexpected free liquid released from each of the containers. Completed form CL-CH-PR-252 F1, 1% Volume
Freestanding Liquids Chart, from each of these intermodal containers is attached.
The liquid volume was confirmed to be below 1% of the manifested waste volume in all three containers. The waste was mixed with soil, compacted in a lift of the Class A West embankment. The “1% Volume Freestanding Liquids Charts” were archived in the Facility Record on March 11, 2025.
Mr. Doug Hansen CD-2025-109 June 2, 2025 Page 3 of 5
299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com

Following the discovery of unanticipated free liquids in the intermodals managed on March 4, 2025, EnergySolutions halted management of further shipments under Profile 9088-30 and requested the generator investigate. The generator confirmed the waste contained friable asbestos, wetted and treated with absorbent and chemical fixative per Utah Administrative Code (UAC) R307-801, UAC R315-2, and 29 CFR
1926.1101. A check study performed by EnergySolutions and generator personnel revealed the fixative reduced absorbent efficiency by up to 50%, causing the unanticipated liquids. The generator adjusted packaging procedures to enhance container integrity.
Based on this evidence, there were several other intermodal containers that the generator could not certify met the 1% free liquid criteria. These containers were managed at the Intermodal Unloading Facility (IUF) which is authorized for waste with free liquids greater than 1%. Each of the containers that the generator could not certify contained less than 1% free liquids were set in the IUF, the back door cracked
open, and liquids allowed to be released. All free liquid from this operation were tested for pH and a 1% free liquid calculation was made on each intermodal. 36 intermodal containers were managed in this manner, and one was calculated greater than 1% free liquid. After all liquids were drained in the IUF, the intermodal containers were transported to the Class A West embankment and off-loaded into
disposal lifts. Response to Director’s First Request: The Class A West embankment is appropriately designated an Approved Unanticipated Liquid Management Facility under CL-CH-PR-252 due to operational realities and regulatory compliance. Free
liquids may enter the embankment via precipitation, dust suppression water, compaction water required by the LLRW and 11e.(2) Construction Quality Assurance/Quality Control Manual, or minimal aqueous content in received waste (<1%), which is neither prohibited by the License nor the Waste Characterization Plan. EnergySolutions employs run-on berms and prioritized surface water
management to minimize liquid accumulation within the embankment’s licensed footprint. Designating the Class A West embankment for unanticipated liquids (<1%) aligns with License Conditions 17 and 68, ensuring safe and compliant waste management.
Based on generator certification of the waste, Clive operations did not anticipate free liquids greater than 1% in the intermodals from Shipment 9088-30-0215. If greater than 1% free liquids are observed as waste containers are unloaded in the embankment, the liquids are solidified/removed as much as possible, a Condition Report written, and the Division notified. If a generator cannot certify their waste is
less than 1% free liquid, alternate management (such as was done for this waste in the IUF) is conducted.
Mr. Doug Hansen CD-2025-109 June 2, 2025 Page 4 of 5
299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com
Response to Director’s Second Request: EnergySolutions’ Clive Facility Training
Program rigorously prepares personnel for safe waste handling, exposure minimization, and contamination prevention, with initial training upon hire and annual refreshers. Per CL-TN-PR-100, all employees, regardless of experience, complete tailored training covering occupational safety, radiological safety, and specific procedures like CL-CH-PR-252, Section 4.1.1.6 for 1% free liquid
determinations. Training includes:
• New Employee Orientation: Covers site access (CL-TN-PR-100 F10), radiological security, and job-specific protocols (CL-TN-PR-100 F11,
F13). Trainees complete quizzes on topics including Hazardous Materials,
Personal Protective Equipment, and Compliance.
• On-the-Job Training (OJT): Supervisors verify competency before
independent work, documented via CL-TN-PR-100 F13.

• Annual HAZWOP Refresher: Ensures ongoing compliance with restricted area access and job-specific requirements.
• Quality Assurance Oversight: Regular reviews ensure training effectiveness, per CL-QA-PR-005. Training records are maintained per CL-TN-PR-060 in the Employee Training,
Qualification, and Medical Surveillance database, with hard-copy backups.
Technicians performing 1% free liquid determinations are specifically trained on CL-CH-PR-252 procedures. Commitment to Continuous Improve Free Liquid Management: Management of
free liquids commences with EnergySolutions’ receipt of a certification from the
generator that their waste will contain less than 1% free liquid (via the waste profile record established through EnergySolutions’ Customer Portal system). However, EnergySolutions underscores that the generator’s certification is verified when the manifested package is opened and content managed at the Clive Facility.
EnergySolutions recognizes that this process can be improved without significantly
impacting the methods and processes used to manage waste in the Class A West embankment. Even though these occurrences are atypical and unexpected, EnergySolutions is evaluating alternative contingencies to be formalized in procedure in cases where a shipment is unexpectedly discovered to have greater than 1% free
liquids when it is managed.
Mr. Doug Hansen CD-2025-109 June 2, 2025 Page 5 of 5
299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com
EnergySolutions further acknowledges the Director’s recommendation for enhanced
training and is evaluating enhancement of training and testing records per CL-TN-PR-060 of technicians performing 1% free liquid determinations. Revision of training and record-keeping for personnel assessing free liquids is being reviewed, reinforcing our commitment to regulatory excellence.
Please contact me at [phone] for further clarification. Sincerely,
Vern C. Rogers Director, Regulatory Affairs
enclosures

Vern C.
Rogers
Digitally signed by Vern C. Rogers DN: cn=Vern C. Rogers, o=EnergySolutions, ou=Waste Management Division,
email=vcrogers@energysolutions.c
om, c=US Date: 2025.06.02 09:36:35 -06'00'