DRC-2024-004652

State of Utah
Department of
Environmental Quality
Ki~berly D. Shelley
Executh•e Director
SPENCER J, COX
Governor
• .DJVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
DEIDRE HENDERSON
.Lieutenant Governor
Jonathan C. Anderson
Environmental Compliance Manager
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
Douglas J. Hansen
Director
March 6, 2024
RE: Request for Infonnation for Non-Contact Water Management Improvement Plan
Ground Water Quality Discharge Pennit (Pennit) UGW450005
J
Dear Mr. Anderson:
In a letter dated November 1, 2023 (CD-2023-222), EnergySolutions submitted a request to modify the non-~
contact water management at its Clive, Utah site .. Non-contact water that originates within the clean
restricted area flows South via a stonnwater culvert, a catch basin, and a lift station (Southwest Lift Station)
to the South of the 1 le.(2) embankment then in an uninterrupted manner to the Southwest Comer Pond (Part
I.E.25 of the Permit). This system is maintained to reduce additional anthropogenic groundwater mounding
that has been documented onsite and to maintain an upward, vertical hydraulic gradient that is monitored, in
part, at GW-19A and GW-19B (Part I.E.26). The Southwest Comer Pond is undersized based on the current
collection area and as a result, the Southwest Comer Pond consistently overflows during seasonal
precipitation events, which has the potential to contribµte to groundwater mounding in the Southwest
Restricted Area. To rectify these concerns, EnergySolutions' solution is to pipe non-contact water via
pumping out of the Southwest Corper Pond and move it approximately 2,950 linear feet to the West
Northwest into Section 31, which is also owned by EnergySolutions.
The Division of Waste Management and Radiation Control (Division's) concerns are the following:
• The potential non-contact water is proposed to be a surface discharge. Given the location iil Section
31, which may be utilized in future operations, how will EnergySolutions determine background soil
and water chemistry as this discharge will potentially alter background chemistry?
o .Additionally, as infiltration occurs at the site, how will groundwater elevation levels be
monitored to detennine background groundwater levels and flow direction?
DRC-2024-004652 195 North 1950 West• Salt Lake City,-UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. 711
w1viv.deq.11t11ll.gov
Printed on 100% recycled paper
· (Over)
• To characterize the effects of placing water in Section 31, please include a flowmeter to measure the
volume of water discharged to the surface and record at regular intervals. Please address this, where
appropriate, in the plans submitted.
• The non-contact surface water has not previously been evaluated for contamination because it has
been contained in the Southwest Corner Pond. Please submit a sampling plan to ensure that the
non-contact water does not have contamination at the point of discharge, in this case monitoring at
both 1) the South Lift Station and 2) the end of the proposed discharge pipe will be required.
• Provide justification that the current infrastructure from the Southwest Lift Station to the Southwest
Pond is adequate for current and future needs based on surface area to be included in the (
Non-Contact Water Management Improvement Plan.
If you have any questions, please call Brandon Davis at 3 85-622-1783.
Sincerely,
Dou~~~~¾.
Division of Waste Management and Radiation Control
DJH/BBD/jk
c: Jeff Coombs, Health Officer, Tooele County Health Department
Bryan Slade, Environmental Health Director, Tooele County Health Department
Jonathan C. Anderson, Environmental Compliance Manager, EnergySolutions, LLC
EnergySolutions General Correspondence Email
LLR W General Correspondence Email