DRC-2025-002168

2025 Annual Shredder Inspection, Module 15 2025
EnergySolutions' Ground Water Quality Discharge Permit, UGW./50005
EnergySolutions' 2025 Annual Shredder Floor Inspection,
BAT Requirements of Ground Water Quality Discharge Permit, No. UGW 450005,
Groundwater Module 15 Inspection
INSPECTION REPORT FOR:
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
[phone]
DATE OF INSPECTION (S):
On June 12, 2025, the concrete floors (Shredder pad) of the Shredder Facility were inspected.
Operation of the Shredder Facility was suspended on June 11 , 2025. Notification was received
by the Division on June 12, 2025, that the Shredder facility was to be put back into service on the
same day.
FACILITY ADDRESS:
EnergySolutions LLC
Clive Disposal Site
Interstate 80, Exit 49
Clive, UT 84029
The EnergySolutions LLC's (EnergySolutions) Clive facility is located in Tooele County, Utah,
approximately 2.5 miles south oflnterstate 80, 75 miles west of Salt Lake City, and 55 miles east
of Wendover, Utah. The facility 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 Sections 5,
Township 2 South, and Range 11 West SLBM.
FACILITY CONT ACT:
Roger Ekins
Clive Disposal Supervisor [phone]
Mathew Schon
Groundwater and Environmental Program Manager [phone]
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL
-1-
2025 Annual Shredder Inspection, Module 15 2025
EnergySolutions' Ground Water Quality Discharge Permit, UGW-150005
NOTIFICATION:
On June 5, 2025 , Nick Clarke notified the Division of Waste Management and Radiation Control
(hereafter, Division) that operations at the Shredder Facility would be suspended for annual
cleaning and repairs; the Division did not participate in the pre-inspection of the facility, and the
final inspection was scheduled to take place on June 12, 2025.
APPLICABLE REQUIREMENTS:
The State of Utah has regulatory authority over the disposal of Low Level, Mixed, and 11 e.(2)
byproduct radioactive waste materials. Applicable requirements are found in Utah Statute, Utah
Administrative Code (UAC) R-313-24 and 25 : Uranium Mills and Source Material Mill Tailings
Disposal Facility Requirements, and License Requirements for Land Disposal of Radioactive
Waste, respectively. The State of Utah has issued two Radioactive Material Licenses,
UT2300249 and UT2300478 to the EnergySolutions' Clive Site.
Because it has been determined that the Energy Solutions' Clive Site has a potential to pollute
groundwater, the Energy Solutions' Clive Site has been issued a State of Utah Ground Water
Quality Discharge Permit, UGW450005 (Permit). Provisions and requirements for the control of
contamination having a potential of being discharged directly or indirectly into groundwater are
found in UAC R317-6, Utah Administrative Rules for Ground Water Quality Protection.
Licenses require EnergySolutions to keep exposures to the public as low as reasonably
achievable, and provides for design, construction, and operations of facilities to contain and
isolate waste. The Permit protects groundwater from degradation as a result of waste
management practices and requires that facility design, construction, and operations be
established through an assessment of what is technologically and economically achievable.
Therefore, EnergySolutions operates and maintains the Clive handling, washing and waste water
facilities in accordance with Best Available Technology (BAT) requirements found in the Permit
to minimize potential risk to the public and environment associated with the operation. Part
I.E.20 of the Permit requires Energy Solutions to operate and maintain the Shredder Facility in
accordance with Appendix J (BAT Performance Monitoring Plan) of the Permit. Appendix J of
the Permit provides a description and BAT performance criteria for the Shredder Facility, and
requires that the Shredder Facility be inspected annually during the second quarter of the year to
ensure concrete integrity. EnergySolutions is required to repair or otherwise seal and render
impermeable any and all cracks, ruptures, and damaged or porous areas of the concrete surface to
ensure the integrity of th.e concrete prior to resuming use of the facility.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL
-2-
2025 Annual Shredder Inspection, Module 15 2025
EnergySolutions' Ground Water Quality Discharge Permit, UGW-150005
TYPE OF INSPECTION:
This is an annual inspection coordinated with EnergySolutions staff, during the second quarter of
the year, to ascertain the condition, rigidity, and concrete integrity of the Shredder Facility floors.
The Shredder Facility floors are inspected against BAT requirements of the Permit and its
Appendix J.
PARTICIPANTS:
Andrew Zehr, Hydrogeologist
LLR W Section
Utah Division of Waste Management and Radiation Control
Charles Bishop, P.G, Hydrogeologist
LLR W Section
Utah Division of Waste Management and Radiation Control
Inva Braha, Health Physicist
LLR W Section
Utah Division of Waste Management and Radiation Control
Nick Clarke
Compliance & Licensing Specialist II
Energy Solutions
[phone]
Mathew Schon
Groundwater and Environmental Program Manager
Energy Solutions
[phone]
WEATHER CONDITIONS:
Dry, sunny. At 0949 -temperature 78.49 °F, winds 5.2 mph out of the west.
TIME IN:
Arrived on site at approximately 0937, enter restricted area 1005.
TIMEOUT:
Left restricted area at 1130, left site at approximately 1400.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QIJALITY
WASTE MANAGEMENT
Ji,.~ & RADIATION CONTROL
-3-
2025 Annual Shredder Inspection, Module 15
EnergySolutions' Ground Water Quality Discharge Permit, UGW450005
REPORT PREPARED BY:
Andrew Zehr, Hydrogeologist
LLR W Section
Utah Division of Waste Management and Radiation Control
FACILITY DESCRIPTION:
2025
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 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 ~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.
The Shredder Facility is located in the north-central area of section 32, Township 1 South, Range
11 West, SLBM (Figure 1). The Shredder Facility is used to size-reduce bulk construction and
demolition wastes prior to disposal in a Clive Site embankment. The shredding of large bulk
waste is a process wherein a hammer-mill reduces large materials into fist-size pieces. Common
in-feed to the shredder consists oflarge pieces of scrap steel, non-ferrous materials, concrete,
textile, rubble, metal rebar, and plastic. The Shredder Facility sits on a large pad designed for
bulk waste storage. Pad surfaces slope to seven catch basins that drain to a manhole north of the
pad. Water from the manhole goes to the Rotary Dump Facility or water storage tanks located on
the concrete shredder pad. Waste is stockpiled in the shredder containment area and once sized,
is moved to the in-feed pad. This waste sits for weeks or longer prior to shredding; there is no
time restriction on this, since it usually takes several weeks or more to accumulate and size
enough material for a shredder run. The facility has concrete floors that were constructed during
2006 and was placed into operation in December of 2006.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL
-4-
2025 Annual Shredder Inspection, Module 15 2025
EnergySolutions' Ground Water Quality Discharge Permit, UGW-150005
Figure 1. Energy Solutions' Clive Site and location of the Shredder Facility.
CREDENTIALS, PURPOSE AND SCOPE:
The Shredder Facility supports operations at the Clive Site and is a potential source of
contaminated water. Water has the potential to contact waste at the shredder facility and then
infiltrate into groundwater, degrading the quality of the groundwater at the Clive Site. An
assessment of what was technologically and economically achievable was used in the design and
construction of the Shredder Facility to minimize the potential release of contaminants. This
assessment results in BAT and Best Management Practices requirements in the operations of the
Shredder Facility. EnergySolutions conducts inspections and maintenance programs at the
Shredder facility to meet BAT requirements listed in the Permit. This inspection verifies the
maintenance and integrity of the Shredder Facility concrete floors to ensure conditions do not
allow contaminated water to contact the ground surface or infiltrate to groundwater.
UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL
-5 -
2025 Annual Shredder Inspection, Module 15 2025
EnergySolutions' Ground Water Quality Discharge Permit, UGW../50005
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 LLRW, 1 le.(2) Byproduct Material, Special
Nuclear Material based on concentration limits, and Polychlorinated Biphenyl (PCB)
Radioactive Waste. Waste is received at the Clive Site as bulk, containerized, or enclosed waste
shipped by trucks or rail. The waste disposal embankments occupy part of Section 32, with the
remainder of Section 32 being occupied by rail, unloading, and cleaning facilities. Additional
waste handling, rail operations, administrative, and occurs in Section 29. Raw material (Clay)
mining occurs in Section 29 and has occurred in Section 5. Waste treatment is not allowed at the
Class A West, and 1 le.(2) embankments. Treatment facilities are located within the Mixed
Waste area. Treatment facilities for radioactive waste that requires treatment for RCRA
constituents and for liquid radioactive wastes requiring solidification prior to disposal are
available. Waste shipped to the facility for treatment or liquid solidification prior to disposal
must be treated in the Mixed Waste area and disposed of in the Mixed Waste embankment unless
RCRA constituents are removed during treatment.
The Shredder Facility handles large pieces of bulk waste shipped to the Energy Solutions' Clive
facility and reduces their size significantly. Shredder Facility activities include bulk waste being
placed in the staging/in-feed area, sorting and sizing of waste in the in-feed area, loading of
waste onto a shredder conveyer belt to move waste to the shredder mechanism, the shredding of
the waste, a conveyer belt moving waste to the out-feed area, and loading of waste into trucks for
disposal at an embankment.
During the second quarter of the year, shredder Facility operations are suspended and all
concrete compliance floors are cleaned and inspected to ensure the integrity of building floors. If
discrepancies are noted per the definition listed Appendix J of the Permit, repairs are made prior
to resuming the use of the facility.
NARRATIVE:
The 2025 BAT annual floor inspection of Energy Solutions' Clive Site's Shredder Facility was
conducted on June 12, 2025. The inspection consisted of walking the Shredder Facility's in-feed,
mid-section and out-feed floor areas. Floor areas needing repairs were previously identified,
marked, and repaired (Figl,lre 2), and additional repairs requested by inspectors were made at the
time of the inspection. Overall, the concrete surfaces of the in-feed floor, the mid-section floor,
and out-feed floor areas were found to be in acceptable condition. The integrity of exposed
concrete surfaces in the in-feed, mid-section, and out-feed floor areas of the Shredder Facility
meet the requirements of the Permit.
Repair compounds used during the repair of the Shredder Facility consisted primarily of a
general-purpose elastic joint sealant, Sikaflex (Figure 2). Sikaflex has been used for a number of
years to repair areas of the floor and to seal cracks and small ruptures in concrete at Clive.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL
-6-
2025 Annual Shredder Inspection, Module 15 2025
EnergySolutions' Ground Water Quality Discharge Permit, UGW-150005
CONCLUSIONS:
The Division's inspection did not identify any items of concern during the visit to the Shredder
Facility on June 12, 2025. Upon completion of the post-repair inspections, Energy Solutions
placed the Shredder Facility back into service the same day.
Figure 2. Example of areas identified, marked, and repaired by EnergySolutions at the Shredder
Facility with Sikaflex.
COMPLIANCE STATUS:
The Shredder Facility was found to be in compliance with the Permit during this BAT
inspection. All areas needing repairs were repaired in a satisfactory manner. The facility was
put back into service on June 12, 2025.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL
-7-
2025 Annual Shredder Inspection, Module 15
EnergySolutions' Ground Water Quality Discharge Permit, UGW450005
ISSUES:
No compliance issues were discovered during the inspection. Therefore, there are no
outstanding compliance issues as a result of the Module 15 inspection.
SIGNATURE:
Prepared By:
ehr, Hydrogeologist,
LL W Section
Utah Division of Waste Management and Radiation Control
Reviewed By:
Charles Biship, P.G., Hydrogeologist
LLR W Section
Utah Division of Waste Management and Radiation Control
Reviewed and Approval By:
t:!t= Millliger
LLR W Section
Utah Division of Waste Management and Radiation Control
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL
-8-
2025
Division of Waste Management and Radiation Control Inspection Form
Shedder Facility floor Inspection
Module 14
Utah Division of Waste Management and Radiation Control Inspection Form
Page I
Rt\ :]:",-J : 10 v'""°
Facility Inspected: EnergySolutions, LLC, Clive, Utah IZA-ov>-: 11 3 u
Regulatory Requirements Inspected Against: Ground Water Quality Discharge Permit, Appendix J
Permit-in-Force (date): ____________ _
Date Put Back Into Service Last Year:
Previous ProblemsNiolations: I\/ I A. ~~--------------------
This inspection consists of pre-repair and post-repair inspections and may takes multi
Date taken out of Service ________ Date put back into Service 1.,/rzJ, .. <
Date(s) of Current Inspection(s): /p/11... -ti.0to-ry ~/o..:J<' (Mo.I! 'a') ~ 0h.rc.A.\.e..r
~\OCH" ( _fAo,). 1'-1) ,oe.r+Q,rA\_e,J ~Ol.,WI.(., u\~ ; .-.o re,°N,rll\ ;(\1)r c,e,,-n'o.-. V\U-t-~S-~
Inspection Staff: 11>/rZ. -A~. c-5 . r13 D€0..
N V: I"\ ~· e.. s
INSPECTION ITEM -Annual Floor Inspection {Module 14)
• Integrity of concrete surfaces at the Shredder Facility
Storage/staging
area
lnfeed
Pad Shredder Building Outfeed
contains the Shredder Mill (Mechanism) Pad
Concrete surfaces at the Shredder Facility, inspected as part of the Floor Inspection, are found in the
storage/staging area and, the in-feed Pad of the in-feed concrete floor,.)llid-section (shredder mechanism)
concrete floor, and the out-feed concrete floor. i-tu....
Modular Permit Inspection Form Version 2, created May 16, 2018, modified June 7, 2023
Division of Waste Management and Radiation Control Inspection Form
Shedder Facility floor Inspection
Module 14
Shredder Floors
Page2
General Shredder Floor Inspection Requirements (Part 4.14 of Appendix J). this inspection can occur in
stages.
1. Is waste storage still occurring?
□ Yes ~o □ Violation
If yes, where
2. Facility taken out of service during the second quarter oft~ year.
IM"'Yes □ No □ Violation
Comments:
3. Has all Waste been removed?
□ No □ Violation
Comments: -------------------------------
4. All floors cleaned and pressure washed?
□ No □ Violation
Comments: -------------------------------
Modular Permit inspection Form Version 2, created May 16, 2018, modified June 7, 2023
Division of Waste Management and Radiation Control Inspection Form
Shedder Facility floor Inspection
Module 14 Page 3
Shredder Facility Requirements (Parts I.E.20, I.F.25, and Appendix J) -inspect facility to determine:
1. Is this the Initial Inspection, pre-repair inspection?
□Yes
Comments: --------------------------------
a. Discrepancy related to floor integrity -Where there cracks in concrete with greater than 1/8
inches separation, and/or significant deterioration or damage, rupture, or porous areas of floor
surface identified.
□Yes □No
Comments: N A ~+-------------------------------
b. Discrepancy marked to indicate repairs needed.
□Yes □No
Comments: ~+'--'-------------------------------
2. Is this the final Inspection, post-repair inspection?
□No
Comments:
a. Repairs made to all marked areas.
~es □No
Comments: :iik°' B t.)C <A\'f l,-J. -lo $j'r64_ P.o;""\.<J w-(.('X.s ; ~,-.iu~+lt1.M '-'1t s
vi,,o.x-W ~-}(u( e.,1 ,si.fe.. lo y I,!_$ l)U$M'l<..-( en'\ :'.>~""t., d ~\/
b. Facility put back into service, and date put back into service
Comments:
Modular Permit Inspection Form Version 2, created May 16, 2018, modified June 7, 2023
Division of Waste Management and Radiation Control Inspection Form
Shedder Facility floor Inspection
Module 14
3. Exposed pad integrity, does it appear it is maintained.
ri'Yes
Comments:
Page4
□ No □ Violation
----------------------------------
Modular Permit Inspection Form Version 2, created May 16, 2018, modified June 7, 2023