DRC-2025-001963

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com
June 18, 2025 CD-2025-129

Mr. Doug Hansen, Director Division of Waste Management and Radiation Control P.O. Box 144880 Salt Lake City, UT 84114-4880

Subject: Ground Water Quality Discharge Permit No. UGW450005 (GWQDP): Response to Compliance Advisory No. 2506005
Dear Mr. Hansen:
This letter serves as EnergySolutions’ response to the compliance issue identified during
the Division’s compliance evaluation inspection conducted on May 5, 2025, which led to the issuance of Compliance Advisory No. 2506005 (DRC-2025-001750), dated June 12, 2025. This response is submitted within the required 30-day timeframe.
The Advisory states,
Division inspectors observed that EnergySolutions staff was unable to confirm the
absence of fluids in the drip leg at Manhole 1A due to visual obstacles in the
manhole and spatial confinement.
Requested Corrective Action: Please describe how EnergySolutions staff will visually confirm the absence of fluid in the drip leg of Manhole 1A at the East
Side Rotary Facility.
In accordance with Ground Water Quality Discharge Permit No. UGW450005 (GWQDP) Appendix J: Table 1, Manhole 1A of the East Side Rotary Facility (ESRF) requires weekly inspection of the leak detection system, which includes verifying there is no fluid in the drip leg of the sight canister. EnergySolutions previously acknowledged
this Advisory concern with the Director and has maintained open communication while
diligently working toward a resolution, even prior to the issuance of Compliance Advisory No. 2506005.
Manhole 1A of the East Side Rotary Facility is a deep and narrow confined space that presents significant safety risks to BAT Inspectors. Currently, BAT Inspectors enter the
manhole weekly to confirm system operation and to inspect the drip leg for fluid, as
required by Appendix J. However, visual confirmation is impeded by structural obstructions within the manhole, making accurate inspection of the drip leg difficult.
The sight canister in Manhole 1A serves as a secondary safeguard to monitor for fluid from the outer containment of Pipeline 4B, which drains by gravity into Manhole 1A.
Mr. Doug Hansen June 18, 2025 CD-2025-129Page 2 of 2
Any fluid entering the outer containment of Pipeline 4B ultimately returns to the manhole
and is contained there. Manhole 1A is also equipped with an alarm system, which is checked daily as required by Appendix J. Inspection of the drip leg is a redundancy and not typically part of standard engineering practice.
Nonetheless, EnergySolutions is committed to full compliance and continuous
improvement. After careful evaluation, the company has developed a corrective action:
an elbow extension will be installed on the drip leg of the sight canister. This modification will allow for verification of the drip leg’s condition from outside the manhole, thereby eliminating the need for weekly confined space entry. Future confined space entries will be reduced to once per month, solely for the required functionality
testing of the water moisture sensor.
Should you have any questions or require additional information regarding this response, please do not hesitate to contact me directly at [phone].
Sincerely,
Mathew R Schon Manager, Groundwater and Environmental Program
I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.