DRC-2025-002133

June 26, 2025
EnergySolutions' 2025 Clive Site Annual Rotary Dump Floor Inspection,
BAT requirement of Ground Water Quality Discharge Permit, No. UGW 450005,
Groundwater Module 8 Inspection
INSPECTION REPORT FOR:
EnergySolutions, LLC (EnergySolutions)
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
(801 )649-2000
DATE OF INSPECTION(S):
On June 12, 2025 , final inspection of the Rotary Dump Facility's concrete floors.
FACILITY ADDRESS:
EnergySolutions LLC
Clive Disposal Site
South of Interstate 80, Exit 49
Clive, UT 84029
FACILITY CONTACT:
Nick Clarke
Compliance & Licensing Specialist II
Energy Solutions
[phone]
Mathew R. Schon
Manger, Groundwater and Environmental Program
Energy Solutions
[phone]
Roger Ekins
Clive Disposal Supervisor
Energy Solutions
[phone]
NOTIFICATION:
On June 3, 2025, Nick Clarke notified the Division of Waste Management and Radiation Control
(Division)by phone; and on June 5, 2025, in an email, the Rotary Dump Facility would be taken
out-of-service on June 9, 2025, to wash, and repair the floors. The Rotary Dump Facility would
be ready for its final inspection on June 12, 2025. At this time, Nick Clarke also notified the
Division that the Shredder Facilities would be taken out-of-service for annual cleaning and
repairs on June 11 and 12, 2025 and be ready for its final inspection in the afternoon of June 12,
2025.
UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -1-
EnergySolutions' 2025, Rotary Dump, Module 8 Inspection.
EnergySolutions' GWQD Permit, UGW -150005
APPLICABLE REQUIREMENTS:
June 26, 2025
The State of Utah has issued two Radioactive Material Licenses, UT2300249 and UT2300478 to
the Energy Solutions' Clive Site. Additionally, the Energy Solutions ' Clive Site has been issued a
State of Utah Ground Water Quality Discharge Permit, UGW450005 (Permit).
This inspection is conducted under the authority of the Permit. Conditions related to the Rotary
Dump Facility floor inspection are found in Part I.E.21, of the Permit. EnergySolutions is
required to operate and maintain the Rotary Dump Facility in accordance with Appendix J (BAT
Performance Monitoring Plan) of the Permit, which requires the Rotary Dump Facility be taken
out of service, and all areas of the floors inspected annually during the second quarter of the
year, to ensure the integrity of concrete floors and surfaces.
TYPE OF INSPECTION:
Annual site inspection conducted during the second quarter of the year to ascertain the condition
of Rotary Dump Facility concrete floors and surfaces.
PARTICIPANTS:
Charles Bishop
LLR W Section,
Utah Division of Waste Management and Radiation Control
Andrew Zehr
LLR W Section,
Utah Division of Waste Management and Radiation Control
lnva Braha
LLR W Section,
Utah Division of Waste Management and Radiation Control
Nick Clarke
Compliance & Licensing Specialist II
Energy Solutions
[phone]
Mathew R. Schon
Manger, Groundwater and Environmental Program
Energy Solutions
[phone]
WEATHER CONDITIONS:
On June 12, 2025, hot, dry, mostly clear skies with some cirrocumulus clouds.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -2-
EnergySolutions' 2025, Rotary Dump, Module 8 Inspection.
EnergySolutions' GWQD Permit, UGW ./50005
TIME IN:
On June 12, 2025 , enter restricted area 10:10 AM.
TIMEOUT:
Leave restricted area at 11 :37 AM.
REPORT PREPARED BY:
Charles Bishop
LLR W Section,
Utah Division of Waste Management and Radiation Control
SITE AND FACILITY DESCRIPTION:
June 26, 2025
The Energy Solutions ' Clive Site is located in Tooele County, Utah, approximately 2.5 miles
south oflnterstate 80, Exit 49; 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.
The Rotary Dump Facility is in the northwest comer of Section 32, Township 1 South, Range 11
West, SLBM, along the southern rail handling loop. The Rotary Dump Facility is designed,
constructed, and operated as a waste handling and wash facility. The Rotary Dump Facility
includes four sub-facilities: Thaw Building, Rotary Building, Wash Building, and Alternate
Wastewater Management Area. The concrete floors in the upper Rotary, Thaw, and Wash
Buildings are designed for the management of railcars, and the dump/loading areas of the Rotary
Building for bulk waste handling. The Alternate Wastewater Management Area consists of a
concrete pad with two wastewater storage tanks on it. The Rotary Dump Facility was constructed
in 2005 and 2006 and placed into operation on December 18, 2006.
CREDENTIALS, PURPOSE AND SCOPE:
The Rotary Dump Facility incorporated technologies in its design and construction to provide
protection of the environment and make it possible to routinely handle radioactive waste. To
preserve these technologies during operation EnergySolutions is required to inspect and if
necessary, repairs or otherwise seals and renders impermeable all concrete surface cracks,
ruptures, and damaged or porous areas of the floors. The concrete surfaces are inspected to
ensure the integrity of all concrete, including trenches, footings, and curbing. The Rotary Dump
Facility is taken out of service and all concrete compliance floors are cleaned and inspected
annually during the second quarter of the year to ensure the integrity of building and ramp
concrete surfaces. If discrepancies are noted per the definition listed in Appendix J of the Permit,
repairs are made prior to resuming facility operations. This inspection verifies the maintenance
and integrity of the Rotary Dump Facility's concrete floors and surfaces.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -3-
EnergySolutions' 2025, Rotary Dump, Module 8 Inspection.
EnergySo/utions' GWQD Permit, UGW -150005
MANAGEMENT ACTIVITIES:
June 26, 2025
Energy Solutions' Clive Site is permitted, licensed, and authorized to receive and dispose of Class
A Low Level Radioactive Waste (LLRW), natural occurring and accelerated produced
radioactive waste (NORM/NARM), LLRW waste that is also determined to be hazardous
(Mixed waste), 1 le.(2) Byproduct Material (uranium mill tailings), Special Nuclear Material
based on concentration limits, and Polychlorinated Biphenyl Radioactive Waste (PCB mixed
Waste).
The Rotary Dump Facility handles bulk waste shipped to the Clive Site by railcar. Activities at
the Rotary Dump Facility include thawing of railcar waste (if needed), rolling of the railcars and
dumping of waste onto the concrete dump/loading floor (impact area), loading of waste into
trucks and sending the waste to an embankment, and washing ( decontamination) of railcars. All
stormwater and wash water in the Rotary Dump Facility is conveyed to the Rotary Building
sediment basin across various concrete floors. Wastewater from the rotary building sediment
basin is transferred to the northwest corner evaporation pond, or the Alternate Wastewater
Management Area.
NARRATIVE:
The 2025 annual BAT floor inspection (post-repair field inspection) of the Clive Site's West
Side Rotary Dump Facility was conducted on June 12. 2025 . EnergySolutions finished the pre-
repair inspection and repairs of concrete floors and surfaces of the Rotary Dump Facility (Thaw
Building, Rotary Building (upper deck and dump/loading), Wash Building, east and west ramps,
and the Alternate Wastewater Management Area concrete floors and surfaces on June 10. 2025.
The inspection occurred during the second quarter of 2025 and was performed by
Energy Solutions ' staff of Nick Clarke and Mathew Schon, and Division's employees Charles
Bishop, Inva Brah, and Andrue Zehr. The inspection form used by the Division during the
inspection is Attachment 1 of this report.
Field Inspection
Upon entering the Clive administration building on June 12, 2025 , the Division representatives
provided an explanation of their purpose there, too site personnel, and that they had made
arrangements with Nick Clarke to do the floor inspections of the Rotary Dump and Shredder
facilities. The site personnel informed the Division inspectors that Nick Clarke was at the
operation building waiting for the inspectors. The Division inspectors then went to the operation
building to connect with Nick Clarke and enter the restricted area to begin the inspection. During
the field inspection, Division staff were accompanied by Mat Schon, Nick Clarke, and Chris
Cook. Chris Cook was the EnergySolutions employee that had supervised the pre-inspection and
repairs of the Rotary Dump and Shredder Facilities floors.
Prior to the inspection of the Rotary Dump Facility, Energy Solutions had removed all waste and
cleaned and washed the upper and lower floors, and ramps. EnergySolutions performed the pre-
inspection and repairs on June 9, and 10, 2025. The pre-inspection reportedly consisted of
observing the concrete floors and other surfaces to identify cracks, raptures, damage, and/or
porous areas that needed repair. Floor areas needing repairs were repaired at the time of
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
· & RADIATION CONTROL -4-
EnergySolutions' 2025, Rotary Dump, Module 8 Inspection.
EnergySolutions' GWQD Permit, UGW 150005
June 26, 2025
identification. Energy Solutions want to refocus to an inspection where they repair what the
Division inspectors identify needing repairs at the time the repairs are identified. On June 12,
2025, Energy Solutions' staff of Mat Schon and Nick Clarke and Division staff of Charles
Bishop, lnva Braha, and Andrew Zehr did a final inspection (post-repair inspection) to ensure the
integrity of the concrete surfaces at the Rotary Dump Facility.
The June 12, 2025, post repair inspection consisted of walking the upper deck floors (Figures 1
and 2), dump/loading floor (Figure 3), the east and west ramps (Figures 4 and 5), and the
Alternate Wastewater Management Area pad observing the floors and their repairs. The upper
deck floors of the Thaw, Rotary, and Wash Buildings were in relatively good condition with
minor repairs to mostly pre-existing repairs using a polyurethane elastomeric sealant (Figure 1
and 2). Chris Cook accompted the inspectors and performed any addional repairs needed. There
is only a small amount of concrete floor in the Thaw building and that floor did not need any
repairs. The Rotary Building's dump/loading floor is usually one of the most abused floors at the
Clive Site and the dump floor impact zone was reported to have had the most damage, due to
spalling, gouging, and scrapings of the floor from the dumping and loading of waste. The
dump/loading floor (open floor in front of the dump bay) had been repaired using a substantial
amount of a pea-gravel concrete mixture (Figure 3). Damaged lower areas of the access ramps
were also repaired with the pea-gravel concrete mixture; cracks in the upper parts of the ramps
were sealed with a polyurethane elastomeric sealant. Some additional area needing repairs were
identified on both ramps; these were sealed with a polyurethane elastomeric sealant. Walls of the
ramps had extensive cracks, but they were still structurally sound. Water coming through the
wall cracks would end up on the ramp floors. The Alternate Wastewater Management Area
concrete pad looked good with no area needing additional repairs.
Figure 1. Upper deck of the Rotary Building (rotary platform), looking through the Wash
Building. There were some floor repairs in the Wash and upper platform of the Rotary
Buildings, but there was no significant damage to these floors.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -5-
EnergySolutions' 2025, Rotary Dump, Module 8 Inspection.
EnergySolutions' GWQD Permit, UGW 450005
June 26, 2025
Figure 2. The upper deck of the Rotary Building (rotary platform) showing repairs. The
concrete surfaces in the upper rotary platform, and wash buildings were found to be in
good condition with previous repairs still in place or having been replaced; no areas were
identified that needed additional repairs in these areas.
Figure 3. The dump/loading floor of the Rotary Dump Facility. The floor had been
cleaned on June 9, 2025, and repaired on June 10, 2025. The dump/loading floor (open
floor in front of the dump bay and dump bay) had been covered with substantial amounts
of a pea-gravel concrete mix.
UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -6-
EnergySolutions' 2025, Rotary Dump, Module 8 Inspection.
EnergySo/utions' GWQD Permit, UGW .:/50005
June 26, 2025
Figure 4. Looking up the east ramp from the dump/loading area. The lower part of the
ramp has been repaired with a pea-gravel concrete mixture.
Figure 5. Rotary Dump Facility west ramp looking east. Damage to lower sections of the
east and west access ramps were repaired with a pea-gravel concrete mixture.
EnergySolutions staff, on the ramp, are sealing some additional cracks with the
polyurethane elastomeric sealant.
Repair compounds used during the repair of the rotary dump facility consisted of Portland
cement compounds (pea gravel mixed with high strength concrete), and a polyurethane
elastomeric sealant (Sikaflex). These compounds had been used for a number of years to repair
large areas of the floor and to seal cracks and small ruptures in concrete at the Clive Site.
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -7-
EnergySolutions' 2025, Rotary Dump, Module 8 Inspection.
EnergySolutions' GWQD Permit, UGW ../50005
Conclusions
June 26, 2025
The Rotary Dump Facility was taken out of service by Energy Solutions on June 9, 2025.
Following completion of cleaning and repairs, the Division and Energy Solutions performed the
post-repair inspection on June 12, 2025. The Division's inspectors did identify some additional
areas needing repair that were fixed at that time. During the June 12, 2025, inspection it appeared
that the concrete surfaces have been sealed (rendered impermeable), to prevent any potential
discharges to subsurface soils or groundwater. As required in the Permit and Appendix J of the
Permit, Energy Solutions will document repair activities in the 1st semi-annual 2025 BAT
Monitoring Report submitted to the Division. The 2025 semi-annual BAT Monitoring Report
will be reviewed to ensure the repairs were documented as necessary. EnergySolutions informed
the Division in an email dated June 12, 2025, that the Rotary Dump Facility was put back into
service.
COMPLIANCE STATUS:
All areas needing repairs appeared to be repaired and the floors were rendered impervious. The
Rotary Dump Facility was found to be in compliance with the Permit during this concrete floor
and surface inspection on June 12, 2025. The facility was put back into service on June 12, 2025.
ISSUES:
No compliance issues were identified during the inspection that were not fixed. Therefore, there
are no outstanding compliance issues because of G W Module 8 inspection.
SIGNATURE:
Prepared By:
LLR W Section
Utah Division of Waste Management and Radiation Control
Reviewed and Approval By:
L~, ~dioactive Waste Section Manager
Utah Division of Waste Management and Radiation Control
Q UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL -8-
7-7 -25
Date
&/30 /vJvf:i
' I Date
EnergySolutions' 2025, Rotary Dump, Module 8 Inspection.
EnergySolutions' GWQD Permit, UGW ./50005
UTAH DEPARTMENT of
ENVIRONMENTAL QUALITY
WASTE MANAGEMENT
& RADIATION CONTROL
Attachment 1 to Report
2025 Division Inspection Form
-9-
June 26, 2025
Division of Waste Management and Radiation Control Inspection Form
Rotary Dump Facility Floor Inspection
Module 8 Page I
Utah Division of Waste Management and Radiation Control Inspection Form
Facility Inspected: EnergySolutions, LLC, Clive, Utah
:r \-\-"('e~~~w
"'~ -Jo: lo t}n
Regulatory Requirements Inspected Against: Ground Water Quality Discharge Permit, Appendix J l~.rt ~~
Permit-in-Force (date): Oc:t <j wt&{ c,.,~ ~11;J7~
Date Put Back Into Service Last Year: ____._'-l_-_.3"'-0:,,e__-....,,2=--'-I_:__ ______________ _
Previous ProblemsNiolations: _/J.;,~M~-----------------
This inspection consists of pre-repair and post-repair inspections and may take multiply days.
Date taken out of Service b -'l -.J 5 Date put back into Service ', -t '7. -2·-S-
Date(s) of Current Inspection(s): -~b~-~• '.l_-_i _,r-~--------------
/t'-'" alvl tk-Sbu o\.~,y-f'lttv-c 1nyevtu:-(t'.'.tlo..J. l't) d:hi S4-"'"'1 ,-
INSPECTION ITEM -Annual Floor Inspection (Module 8)
• Integrity of concrete surfaces at the Rotary Dump Facility
Upper-level concrete floors,
Lower dump floor (Pit area) concrete,
East and west concrete ramps
Rotary Dump Floor
General Rotary Dump Floor Inspection Requirements (Part 4.15 of Appendix J). this inspection can
occur in stages, and is tied to the floors in the Rotary Dump Building being cleaned.
1. Facility taken out of service during the second quarter of the year.
0"'Yes
Comments: T~ ~ -l 7. -~s-, O"}fe-ut)h\<\ •\µ(l,S. ::t:W: fuM,A
±k '02:b ca J b,t 1), -v14, "'°'" J,..;.,A, r\,o t: frl.f>\.S, ~ bte. 1 ~
c,.,\ e i,, "'°'1')',o~w\,o,,,., (Ltl.V,t
2. Has all Waste been removed?
D No D Violation
f\DP'( t""'~~ fvy-
t:k. pe '(4 ..Pt Nr t Wz,O ~ ,
D No D Violation
Comments: ------------------------------
Modular Pennit Inspection Fonn Version 2, created May 16, 2018, modified June 3, 2025
Division of Waste Management and Radiation Control Inspection Form
Rotary Dump Facility Floor Inspection
Module 8
3. All floors cleaned and pressure washed?
i Yes D No D Violation
4. Are waste off-loading ( dumping), and handling (loading) operations occurring:
D Yes ri No D Violation
If yes
Is waste still on Dump Floor? D Yes D No , if Yes where
Is loading operations occurring? D Yes D No , if Yes where
Rotary Dump Facility Requirements (Parts I.E.26, I.F.26, and Appendix J) -inspect facility:
1. Is this the Initial Inspection, pre-repair inspection?
Comments: 'T""' \V'\ ~Vv\ .\\~ :\"'-'ipe.c.h""-'\ vJ ~
QY'\ to-10-2 ,S:
□Yes
~
Page 2
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 concrete
surface identified.
~es □No
Modular Permit Inspection Form Version 2, created May 16, 2018, modified June 3, 2025
Division of Waste Management and Radiation Control Inspection Form
Rotary Dump Facility Floor Inspection
Module 8
b. Discrepancy marked (identified) to indicate repairs needed
Comments: '6,)9-4 .
2. Is this the final Inspection, post-repair inspection?
Page 3
□Yes □No
rfYes □No
Comm en ts: f l uc-r> \IS(.,!", ~ p...\ < t...,\ • B H c.o,,c, e,k ~ ~... ""'--YN. '<)~ "\,,,\."~ ½>~
\\'\ 'fO'ev\ ,'4,. fl-. I lo.,, Wo,/b. ,, E -h-,.., l''-bhtf' \t\.4itt £a~ \ ... ll:1e f '('(4,\J,<; ( f#1V ttjj
lY\ sev-e -t&\ ~\,CLC.£4 1 1o .... -'1 m.rt £.h.\\ \II\~ (MIV\ fu.V'--'-:t:loV\.\.~.
a. Repairs made to all marked areas
t.!Yes □No
b. Facility put back into service, and date put back into service
6 Yes □No
Date fu -t'.l. -'2£
Comments: --------------------------------
3. Exposed pad integrity, does it appear it 's maintained.
i Yes □ No □ Violation
Comments:
Modular Permit Inspection Form Version 2, created May 16, 2018, modified June 3, 2025
Division of Waste Management and Radiation Control Inspection Form
Rotary Dump Facility Floor Inspection
Module 8
Modular Permit Inspection Form Version 2, created May 16, 2018, modified June 3, 2025
Page4