DRC-2019-015062 - 0901a06880b7136e

Div of Waste Managernent
and Radiation Control
NOV 2 0 2019

ENERGYSOLUTIONS

D RC -201 9 - 01 50(0a
November 20, 2019 CD19-0234
Mr. Ty Howard, Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880
Re: Groundwater Quality Discharge Permit Number UGW450005 (GWQDP):
Monitoring Wells GW-64, GW-77, and GW-89 — Compliance Status Change
Dear Mr. Howard:
In accordance with Part I.G.2 of the GWQDP, EnergySolutions is providing notice of a
change from baseline annual status to probable out-of-compliance status for the sum of
radium-226 and radium-228 (Ra-226+Ra-228) in groundwater at compliance monitoring
wells GW-64, GW-77, and GW-89.
Table 1 lists the Groundwater Protection Level (GWPL), the Ra-226+Ra-228 concentration
from the 2019 annual sampling event, and the sample collection date for each well. The
radiological analytical data report for these wells was received by EnergySolutions on
August 20, 2019 (third quarter 2019).
Table 1 — Compliance Status Change to Probable Out-of-Compliance
2019 Annual Sampling Event, Ra-226+Ra-228
Compliance
Monitoring Well
Ra-226+Ra-228
GWPL
(pCi/L)
2019 Annual Event

Ra-226+Ra-228 Sample Collection

Concentration Date
(pCi/L)
GW-64 5.63 5.87 5/28/19
GW-77 5.46 6.15 5/28/19
GW-89 5.04 6.69 5/13/19
GWPL = Groundwater Protection Level
pCi/L = PicCuries per liter
Ra-226 and Ra-228 are naturally occurring radionuclides in Clive facility groundwater.
EnergySolutions believes the observed radium GWPL exceedances are related to potential
increased infiltration in the vicinity of the wells caused by the occurrence of above-average
precipitation at the Clive Facility during the first half of 2019. Under these conditions,
naturally occurring radium may dissolve and/or desorb from minerals and mineral coatings
present in the vadose zone and may subsequently be transported to the water table by
infiltration, leading to the observed concentrations at wells GW-64, GW-77, and GW-89.
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
ENERGYSOLUTIONS Mr. Ty Howard
November 20, 2019
CD19-0234
Page 2 of 2
Per GWQDP Part I.G.2.a, this notification is provided within 30 days of EnergySolutions '
initial discovery of the detection. Per Part 1.G.2.b, EnergySolutions will immediately
implement quarterly sampling and analysis for Ra-226 and Ra-228 at wells GW-64, GW-77,
and GW-89. The first quarterly sample will be collected during the fourth quarter 2019.
Should you have any questions regarding this submission please feel free to contact me at
[phone].
Sincerely,
AL491-11(/
Robert W. Sobocinski
Groundwater Program Manager
cc: Charles Bishop (DWMRC)
Don Verbica (DWMRC)
I certifr 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 offine and imprisonment for knowing violations.