DRC-2024-007380

Ground Water Quality Discharge Permit No. UGW450005
APPENDIX J:
Best Available Technology (BAT) Performance Monitoring Plan
Latest Revision Date: October 15, 2024
TABLE OF CONTENTS
1INTRODUCTION3
2DEFINITIONS3
3RESPONSIBILITIES6
4BAT PERFORMANCE MONITORING7
4.11995, 1997, 2000, Northwest Corner, and Mixed Waste Evaporation Ponds7
4.21995/1997 Evaporation Pond Lift Station8
4.32000 Evaporation Pond Transfer Pad8
4.4Northwest Corner Evaporation Pond Transfer Facility8
4.5Containerized Waste Storage Pad8
4.6Intermodal Unloading Facility (IUF)8
4.7Intermodal Unloading Facility Lift Station9
4.8Reserved.9
4.9Rail Wash Facility on Track No. 494.10Rail Digging Facility94.11East Truck Unloading Area94.12Decontamination Access Control Building104.13Intermodal Container Wash Building104.14Shredder
Facility104.15Rotary Dump Facility104.15.1Thaw Building114.15.2Rotary Building114.15.3Wash Building114.15.4Alternate Wastewater Management Area124.16East Side Drainage System124.16.1Decontamination
Access Control Building Wastewater Flow and Monitoring124.16.2Rail Wash Facility on Track No. 4 Wastewater Flow and Monitoring134.16.3Intermodal Container Wash Building Wastewater Flow
and Monitoring134.16.4Manhole No. 1 Wastewater Flow and Monitoring134.16.5Manhole No. 2 Wastewater Flow and Monitoring134.16.6Stormwater Lift Sump Flow and Monitoring144.16.7Annual Pipe
Pressure Testing144.17South Ditch174.18LLRW Operations Building174.19SRS DU Storage Building174.20Evaporation Pond Ancillary Equipment to Facilitate Evaporation174.21Stormwater Management184.22East
Side Rotary Facility194.22.1Rotary Dump194.22.2Upper Wash Area19
5QUALITY ASSURANCE/QUALITY CONTROL19
INTRODUCTION
EnergySolutions, LLC (EnergySolutions) has been granted a Groundwater Quality Discharge Permit, (GWQDP) Permit No. UGW450005 hereinafter called the Permit, by the State of Utah. The
Permit specifies the construction, operation, and monitoring requirements for all EnergySolutions facilities that have a potential of discharging pollutants that may move directly or
indirectly into groundwater. To cause the maximum reduction of pollutants achievable, the Permit specifies that “Best Available Technology” (BAT) be used in the construction of all
facilities and that facilities be operated according to “Best Management Practices”.
The Permit lists individual facilities that have BAT criteria associated with them. This BAT monitoring plan addresses the facilities and their BAT description and performance criteria
(Table 1).
The Permit requires that EnergySolutions develop and follow a monitoring, inspection and maintenance plan for permitted facilities. BAT inspections are required to be performed daily
for those BAT Compliance Monitoring Points noted on Form 1; weekly for those BAT Compliance Monitoring Points noted on Form 2; and monthly for those BAT Compliance Monitoring Points
noted on Form 3. Additional, daily inspections for those BAT Compliance Monitoring Points noted on Form 1a are required after precipitation events of greater than 0.1 inch, until such
time that all stormwater accumulation has been removed as required by Part I.E.7 of the Permit; and on Form 1b when managing PCB wastes at the shredder facility.
BAT inspections may be suspended at a facility that has been taken out of service for repairs, or due to lack of operational need to use the facility provided there has been no waste
handling or washing/decontamination activity for 48 hours prior to the facility being taken out of service. A “out of service” facility must be secured and inaccessible in such a manner
so as to minimize any potential threat to ground water while out of service. Any facility taken out of service is not permitted for waste storage or management and shall remain in a
dry and secure condition, while out of service, wherein BAT inspections are no longer applicable. The Division shall be provided at least 48 hour email notification previous to a facility
being taken out of service. Upon request, the Divisionshall be provided an opportunity to inspect the facility after it has been taken out of service. The Division will be notified
by email, and regularly schedule BAT inspections will resume on the day a facility returns to service.
If failure of BAT occurs at any facility, the BAT Contingency Plan located at Appendix K to the GWQDP shall be implemented.
DEFINITIONS
Access Pipe:
A pipe placed to provide access for the monitoring of leak detection system BAT performance criteria.
Allowable leakage rate:
Volume of fluid allowed to enter into leak detection systems through the upper flexible membrane liner of the evaporation ponds, averaged over a seven-day period. Volumes up to the allowable
leakage rate do not constitute a failure of BAT.
Best Available Technology (BAT):
The application of design, equipment, work practice, operation standard or combination thereof, at a facility to effect the maximum reduction of a pollutant achievable by available processes
and methods taking into account energy, public health, environmental and economic impacts and other costs.
BAT Compliance Monitoring Points:
Designated points of inspection, sampling, analysis, and monitoring to confirm compliance with the Permit.
Bor-o-scope:
Specialized equipment used to perform video inspection of the entire length of the drainage pipe of each collection lysimeter and inspection of other BAT piping as needed.
BAT Contingency Plan (Appendix K to the GWQDP):
Plan for regaining and maintaining compliance with Permit limits and for reestablishing compliance with best available technology. This plan will be implemented if any of the BAT Performance
Criteria specified in this plan are not met.
Contact Stormwater:

Stormwater that has contacted waste, such as storm water within the Disposal Cells, Rotary Dump Facility, or Intermodal Unloading Facility (IUF).
Container Storage Compliance:
In accordance with Part I.E.10.a of the Permit, containers in storage at facilities other than the Class A West or 11e.(2) disposal cell shall be managed to prevent the contact of waste
with the ground surface and meet the following criteria:
Closed, strong tight container
Labeled with generator, waste stream number, and date received
Stored no more than 365 days before being taken to the disposal cell
Daily Inspection:
For purposes of this plan, daily inspections are required any day that waste or water management activities occur. The daily inspection is not required on weekends or holidays if water
and waste management activities are not being conducted. Waste management activities include shipment receipt, unloading, waste placement, or decontamination facility operation. Daily
inspection items are defined on Table 1 and Forms 1, 1a, and 1b.
Daily when stormwater is present inspection:
For the purpose of this plan inspected on days when there is storm water accumulation on site
Dry and Secure:
A facility will be dry and secure when all water has been removed from a facility, all water access to the facility is denied, and the facility is locked down and cannot be accessed/occupied
without the consent of the Manger, Waste Disposal Operations.
Exposed Pad:
The surface of pad or concrete surface not covered with containers or process material.
Freeboard:The vertical distance between the spillway elevation of fluid containment system and the water elevation.
Free Drainage:
The drainage of water from one designated area to another, including sloped surfaces and pipelines, in such a manner that water is not blocked or dammed by foreign material including
sediment, debris, and other items not approved in the design and construction of a facility. Free drainage includes the movement of water aided by mechanical means such as sumps, pipelines,
etc. Free drainage shall be maintained at all facilities as addressed in this plan.
Gravity Flow:
The free movement of water from a higher elevation to a lower elevation for water transfer to designated areas of the facility.
Head/pressure transducer:
An instrument used to detect, measure, and report the water level in a monitoring well or detection sump system.
Leak Detection System:
An engineered system designed to detect leaks in a low-permeability liner and capable of collecting and removing fluid present in the leak detection sump.
Leak Detection Sump:
A sump constructed between an upper and lower low-permeability liner that provides a collection point for detecting, measuring, and removing fluids that have leaked through the upper
liner. When fluid is detected in the sump, it is an indication that the upper liner may be leaking.
Monthly Inspection:
Monthly BAT inspections as defined in Table 1 and Form 3 are required to be performed once per month, whether the facility is in operation or not.
Non-contact Stormwater:
Stormwater that has not contacted waste that is within the restricted area.
Pad Integrity:
The physical integrity of a pad structure including but not limited to: the presence of cracks, ruptures, damaged or porous areas, areas of subsidence or thinning.
Pump-back system:
An automatic system that provides for the removal of liquids from the leak detection system and reconveyance of the liquids to the associated evaporation pond.
Pump controller:
An instrument that controls the activation and deactivation of the submersible pump.
Pump-down test:
A test that determines the accuracy of the leak detection system.
Submersible pump:
A pump specially designed and engineered for being submersed in water.
Surface Integrity Discrepancy:
Includes the cleanliness of the pad and either: 1) a crack in the asphalt or concrete with greater than 1/8 inch separation (width), or 2) any significant deterioration or damage of
the pad surface.
Transfer Sump:
A collection sump that is used to pump water from one point to another at the facility.
Weekly Inspection:
Weekly BAT inspections as defined in Table 1 and Form 2 are required to be performed once per week, whether the facility is in operation or not.
Weir:
A wall located in a settlement basin designed to control water flow to maximize sediment collection in the basin.
Weir Notch:
A notch located on a weir that allows water to flow from the settlement basin to an area in which water is collected for pumping.
RESPONSIBILITIES
The Quality Assurance Manager (QAM) or designee is responsible for performing surveillance and/or audit activities to verify implementation and compliance with the requirements of this
plan and review of all designated forms as part of the quality assurance review for accuracy and completeness. The QAM is also responsible for providing required verbal notifications

to regulatory agencies and the Manager, Compliance and Permitting.
The Manager, Waste Disposal Operations or designee is responsible for maintaining assigned facilities in compliance with BAT requirements of the Clive site at all times. The Manager,
Waste Disposal Operations (or designee) shall immediately notify the QAM when any BAT Failure occurs.
The Radiation Safety Officer (RSO) or designee is responsible for performing evaluations of any existing threat or potential threat to public health and the environment.
The Facility Operator or BAT Inspector performs the routine inspections and provides notification to the Manager, Waste Disposal Operations and Quality Assurance Manager, of any BAT
non-compliance. The Facility Operator or BAT Inspector has the authority to initiate repairs when needed.
The Site Hydrogeologist or designee is responsible for performing collection lysimeter measurements and determining compliance.
The Manager, Compliance and Permitting or designee is responsible for determining sampling parameters for free liquid if present in the collection lysimeters, reviewing all groundwater
sampling data, and reviewing video inspection of the lysimeters. The Manager, Compliance and Permitting is responsible for providing required written notification to the regulatory
agencies.
The Manager, Engineeringand Maintenance or designee is responsible for scheduling and oversight of pump down testing if required; and performing preventative maintenance on facility
equipment in accordance to the manufacturer specifications and guidelines, and ensuring that spare sump pump and replacement parts (including batteries for portable measuring devices,
etc.) are on site at all times for required repairs.
BAT PERFORMANCE MONITORING
EnergySolutions is responsible for implementing Best Available Technology, summarized in Table 1, BAT Monitoring and Performance Criteria Chart, to prevent discharge of fluids from the
following facilities to subsurface soils or groundwater. Table 1 provides a description of BAT for each facility, inspection requirements and frequency, performance criteria, and where
each inspection requirement is documented. Compliance with the performance standard(s) will be evaluated by performing and documenting inspections, performing equipment maintenance and
repairs as required, and by implementing corrective actions.
1995, 1997, 2000, Northwest Corner, and Mixed Waste Evaporation Ponds
Each Evaporation Pond is equipped with a leak detection and pump-back system that includes the following: Flow meter, pressure transducer, submersible sump pump, process controller/monitor,
and discharge line. Failure of any pumping or monitoring equipment not repaired and made fully operational within 24 hours of discovery is deemed a BAT failure.
In accordance with Part I.E.16 of the Permit, BAT for Mixed Waste facilities other than the Mixed Waste Evaporation Pond is defined by requirements of the State-issued Part B Permit.
Accordingly, the Mixed Waste Evaporation Pond inspection is required only on days that Mixed Waste Facility daily inspections are required under the State-issued Part B Permit.
1995/1997 Evaporation Pond Lift Station
The 1995/1997 Evaporation Pond Lift Station is designed and constructed to transfer wastewater from the IUFLift Station and the Containerized Waste Storage Pad into either the 1995 Evaporation
Pond or the 1997 Evaporation Pond.
2000 Evaporation Pond Transfer Pad
The 2000 Evaporation Pond Transfer Pad is designed and constructed with gravity flow to provide free drainage of water from the transfer pad to the 2000 Evaporation Pond.
Northwest Corner Evaporation Pond Transfer Facility
The Northwest corner Evaporation Pond Transfer Facility was constructed and designed for trucks to collect and discharge water on a containment surface. The concrete pad slopes towards
the pond and an HDPE apron/rub sheet attaches to the edge of the concrete pad. The rub sheet extends down the slope of the pond providing for water transfer over rub sheets thereby,
reducing any negative effects on the pond liner.
Containerized Waste Storage Pad
The Containerized Waste Storage Pad is designed and constructed with gravity flow to providing drainage of stormwater to the Pond Lift Station.
Intermodal Unloading Facility (IUF)
The IUF is designed with gravity flow to the IUF Lift Station collection manhole. A sump pump is located within the manhole and pumps to a drain line to the 1995/1997 Pond Lift Station.

The IUF is inspected annually during the second quarter to ensure integrity of the concrete surfaces. The inspection may occur one bay at a time. If discrepancies are noted per the
definition listed in this plan, repairs shall be made prior to resuming the use of the affected bay. The results of the bay inspections are documentedin an engineer’s report. The inspection
findings, any repairs required, and repairs completed are included in the Semi-annual BAT Monitoring Report.
Intermodal Unloading Facility Lift Station
The IUF Lift Station is designed and constructed to collect wastewater from the Rail Wash Facility on Track No. 2, theIUF, and the Railcar Digging Facilityfor transfer via gravity flow
to the 1995/1997 pond lift station. An alarm will activate when the water level within the lift station rises above the lowest level of the inlet pipe.
Reserved.
Rail Wash Facility on Track No. 4
The Rail Wash Facility on Track No. 4 is designed and constructed to provide free drainage of washwater from the rail wash floor and concrete trench to the floor sumps and through the
piping that discharges to the collection tank(s) of the adjacent equipment/mechanics building. The rail wash facility floor is inspected to ensure total containment of water and that
there is no direct or indirect discharge to subsurface soils or groundwater. The facility also includes an adjacent equipment/mechanics building that contains the collection tank(s)
for the washing operations.
Rail Digging Facility
The Rail Digging Facility located between Track No. 3 and Track No. 4 is designed and constructed to provide free drainage of stormwater from the asphalt containment pad and ramps to
three concrete collection basins, for a total of 4 sumps requiring inspection. Water from the collection basin drains to a settling basin. Water continues to drain through piping to
the digging facility manhole, continuing on to the IUF Lift Station. The Rail Digging Facility is designed for digging waste from rail cars and transferring it to hauling equipment.
No waste storage will occur.
East Truck Unloading Area
The East Truck Unloading Area includes the Container Holding Pads, Unloading Dock with Ramp and Unloading Area asphalt surfaces. The facility is designed with gravity flow to direct
stormwater accumulated on the asphalt surfaces away from the concrete container holding pads. The concrete container holding pads are designed with gravity flow to direct water that
accumulates on the concrete surface to collection troughs.
Overnight storage is prohibited at the dock and on asphalt surfaces within the facility. Storage and sampling are restricted to the concrete holding pads. Containers may be placed
temporarily on the asphalt surface to facilitate transfer. Temporary is defined as the current acceptance date on the Bates Label. Therefore, this prohibits overnight storage.

Decontamination Access Control Building
The Decontamination Access Control Building is designed and constructed to provide personnel access to the Restricted Area. The design provides for free drainage from the facility to
the wastewater collection tank buried outside the southwest corner of the building.
Intermodal Container Wash Building
The Intermodal Container Wash Building is used for the decontamination of containers. It was designed with a leak detection system and constructed in order to provide for the free drainage
of washwater from the bootwash, and washbays to the sediment basin.
Shredder Facility
The Shredder Facility is used to size-reduce debris wastes prior to disposal. It is designed to provide free drainage to seven catchbasins, which then drain to the sump in the Rotary
Dump Facility before being pumped to the Northwest Corner Evaporation Pond. Because the seven catchbasins are located at least 3.5 feet lower in elevation than the top of Manhole 1,
used to pump water to the tanks, inspecting each catchbasin also functions as an inspection for functionality of the submersible pump in Manhole 1.When PCB-Containing waste is stored
on the Shredder Pad, additional inspection criteria will be followed in accordance with the TSCA Approval for Shredding Polychlorinated Biphenyl (PCB) Wastes.
An alternate wastewater management system provides for the removal of water from manhole 1 via the use of a submersible pump and pipeline to water storage tanks located on the concrete
pad. This system will be used during the shredding of PCB waste and optionally when the drainage system to the Rotary Dump Facility or Northwest Corner Evaporation Pond is out of service.
When in use, the alternate wastewater management system and associated valves will be inspected to ensure that the associated valves are in the proper position, the pipeline is not leaking,
and the high water level alarms are not activated.
The Shredder Facility is taken out of service and inspected annually during the second quarter, to ensure integrity of the concrete surfaces and to ensure that system valves are operating
as designed. If discrepancies are noted per the definition listed in this plan, repairs shall be made prior to resuming the use of the facility. The results of the inspection are documented.
The inspection findings, any repairs required, and repairs completed are included in the Semi-annual BAT Monitoring Report. Additional reporting may be required in accordance with
the TSCA Approval for Shredding Polychlorinated Biphenyl (PCB) Wastes.
Rotary Dump Facility
The Rotary Dump Facility is designed and constructed for the thawing, emptying, and washing of railcars. It includes 4 sub-facilities. The Rotary Dump Facility is taken out of service
and all areas are inspected annually during the second quarter, to ensure integrity of the concrete surfaces. If discrepancies are noted per the definition listed in this plan, repairs
shall be made prior to resuming the use of the facility. The results of the inspection are documented. The inspection findings, any repairs required, and repairs completed are included
in the next Semi-annual BAT Monitoring Report.
Thaw Building
The railcars enter the Thaw Building where wall and floor heaters provide heat as necessary to thaw the material for dumping. The rail in the thaw building is underlain with a flexible
membrane liner covered with a granular surface. If any liquid is generated, the liquid drains into the granular surface, and is captured by the flexible membrane liner. The liquid
then gravity drains via perforated pipe installed above the flexible membrane liner to a collection pipe. The collection pipe located under the granular surface is covered with geotextile
material to prevent intrusion from material that may block the pipe. The wastewater free drains via a four-inch PVC pipe that discharges to the west side of the Rotary Building floor.
The pipe from the Thaw Building is located one foot off of the Rotary Building floor.
Rotary Building
The Rotary Building is designed for the dumping of waste from railcars onto the Rotary Building Floor. While dumping is in process, water cannons may be used to remove excess material
from the railcar. The Rotary Building floor is sloped for free drainage of wastewater to the sediment basin. Wastewater within the sediment basin is pumped via the use of a submersible
pump and pipeline to the Northwest Corner Evaporation Pond or wastewater storage tanks at the Alternate Wastewater Management Area. Routing of wastewater at the facility is controlled
by locking valves. When the valve in the pipeline to the pond is in the “Closed” position and the valve in the pipeline to the tanks is in the “Open” position, the wastewater is transferred
to the Alternate Wastewater Management Area. Notification to the Director is required. When the locking valve in the pipeline to the tanks is in the Closed” position and the valve
in the pipeline to the pond is in the “Open” position, the wastewater is pumped to the Northwest Corner Evaporation Pond. The pipeline to the Northwest Corner Evaporation Pond is dual
walled from the point where it exits the building to the discharge point in the pond.
Wash Building
The Wash Building is designed for the decontamination of railcars. Non-contaminated water is provided via four 2,500 gallon water storage tanks. Water used in the decontamination process
gravity drains via two trenches to a drain pipe. Water from the drain pipe gravity drains to the sediment tank located on the floor of the rotary dump building. The sediment tank is
designed with an overflow that drains from the sediment tank onto the Rotary Building floor surface to the sediment basin. Water within the sediment tank supplies the water cannons
within the Rotary Building.
Alternate Wastewater Management Area
The wastewater from the sediment basin is transferred via submersible pump and pipeline to two wastewater storage tanks or to the Northwest Corner Evaporation Pond. A locking valve
in the pipeline to the Alternate Wastewater Management Area (tanks) is openedand a locking valve in the pipeline to the pond is closed when the tanks are placed in service. Notification
to the Director is provided when the Alternate Wastewater Management Area is placed in service. Each tank is equipped with a float switch that triggers activation of a visual alarm when
the water level reaches two feet from the top of the tank. The pipeline transfers wastewater to both tanks. Reuse of the wastewater from these storage tanks at the wash building is
prohibited. The tanks are located on a concrete surface.
East Side Drainage System
The East Side Drainage System is comprised of two separate drainage systems; one for wastewater from decontamination facilities, and one for stormwater. A process flow diagram of the
system is provided as Figure 1.
The wastewater system is designed as follows: wastewater is pumped from the Decontamination Access Control Building, the Intermodal Container Wash Building, and the Rail Wash Facility
on Track No. 4 within a dual walled pipe system to the 1997 Pond.
The Decontamination Access Control Building Tank, Intermodal Container Wash Building, and the Rail Wash Facility on Track No. 4 are each equipped with shut-off (isolation) valves. These
valves when closed will isolate the respective facilities thereby preventing the flow of additional wastewater via the pipelines to the 1997 Pond. This allows for the isolation of facilities
and, upon notification to theDivision, manual removal of wastewater for continued operation if a BAT failure or maintenance outage exists at another facility connected to the drainage
system or during scheduled maintenance or inspection of the drainage system.
Decontamination Access Control Building Wastewater Flow and Monitoring
Wastewater from the Decontamination Access Control Building drains to a double-walled collection tank outside of the building. A moisture leak detection sensor is located between the

walls (annular) of the tank to detect moisture or leakage from the primary wall of the tank. A strobe alarm is located on the outside of the building adjacent to the tank that is activated
by the sensor in the tank annular space. A second leak detection sensor is located within the containment pipe to detect a leak in the carrier pipe, which also activates the strobe alarm
mounted on the outside of the building adjacent to the tank. A high-water level float alarm set so as to maintain the water level in the tank below the level of the inlet pipe activates
strobe alarms located inside the building above the boot wash and the respirator wash sink. An isolation valve (P1-V01) is located at the collection tank of the Decontamination Access
Control Building. This isolation valve when closed will prevent additional wastewater from transfer to the Rail Wash Facility on Track No. 4.
Rail Wash Facility on Track No. 4 Wastewater Flow and Monitoring
Wastewater is pumped from the collection tank at the Decontamination Access Control Building to the Rail Wash Facility on Track No. 4 through a dual wall pipe designated as Pipeline
No.1. The inside pipe of the dual wall system is designated as the carrier pipe and the outer pipe is designated as the containment pipe. Pipeline No. 1 discharges into the wash water
collection tank at the Rail Wash Facility on Track No. 4. Wastewater from the Rail Wash Facility on Track No. 4 collection tank is pumped through a dual wall pipe (Pipeline No. 2) to
Manhole No. 1. An isolation valve (P2-V01), is located at the collection tank at the Rail Wash Facility on Track No. 4. This isolation valve when closed will prevent additional wastewater
transfer via Pipeline No. 2 to Manhole 1.
Intermodal Container Wash Building Wastewater Flow and Monitoring
Wastewater from the Intermodal Container Wash Building sump is pumped to Manhole No. 1 through a dual wall pipeline designated pipeline No. 3 where it connects (via manifold) with Pipeline
No. 4. An isolation valve (P3-V01) is located at the sedimentation sump in the Intermodal Container Wash Building. This isolation valve will prevent additional wastewater from transfer
via Pipeline No. 3 to Manhole No. 1 when closed.
Manhole No. 1 Wastewater Flow and Monitoring
Manhole No. 1 is a dry manhole (receives no storm or wastewater) that provides access to a manifold system connecting pipelines No. 2, 3, 4, and 4b. Manhole No. 1 is located in close
proximity to the Rail Wash Facility on Track No. 2 near the SW corner of the building. Within Manhole 1, dual wall pipelines No. 2 and No. 3 are joined with a manifold and exit the
manhole as dual wall Pipeline No. 4. routed to the 1997 Pond. Check valves prevent water from backflowing into Pipelines No. 2 and No. 3. Wastewater flows from Manhole No. 1 to Manhole
No. 2 via Pipeline No. 4 then to the 1997 Pond via the dual wall pipe designated as Pipeline No. 4a. A leak detection sensor and drip leg (2 total) are installed in each containment
pipe of Pipelines No. 2 and No. 3 at Manhole No. 1 to detect leakage from the carrier pipes. The sensors activate a strobe alarm mounted to the exterior of the adjacent Track 4 Rail
Wash Building. In addition, a sight canister is installed on each drip leg to collect any water, for visual detection, which may flow from the drip leg.
Manhole No. 1A Wastewater Flow and Monitoring
Manhole No. 1A is a dry manhole that provides access to pipeline No. 4b. It islocated inside of the East Side Rotary Facility and collects wastewater and storm water runoff from the
East Side Rotary Facility sedimentation basin. A check valve prevents water from backflowing from pipeline No. 4b into the East Side Rotary Facility sediment basin. A leak detection
sensor and drip leg are installed and the sensors activate a strobe alarm mounted on the outside of the East Side Rotary Facility.
Manhole No. 2 Wastewater Flow and Monitoring
Pipeline 4 carries wastewater to Manhole 2 located north of the 1997 Pond. Pipeline 5 carries stormwater from the stormwater collection/transfer sump to Manhole No. 2. Pipelines No.
4a and No. 5a carry wastewater and stormwater from Manhole 2 to the 1997 Pond. The carrier pipelines pass through Manhole 2, keeping Manhole 2 dry and the water streams separate. A
leak detection sensor and drip leg (4 total) are installed in each containment pipe of Pipelines No. 4, No. 4a, No. 5 and No. 5a at Manhole No. 2 to detect leakage from the carrier pipes.
The sensors activate a strobe alarm mounted on a post adjacent to Manhole 2. In addition, a sight canister is installed on each drip leg to collect any water, for visual detection,
which may flow from the drip leg.
Stormwater Lift Sump Flow and Monitoring
Stormwater is collected by the catchbasins located south of the Intermodal Container Wash Building, north and south of theIUF, and between Tracks 2 and 3 and routed to the stormwater
lift sump. The collected water is pumped from the sump and routed to the 1997 Pond through Pipeline No. 5.
A high-water level float alarm is installed in the stormwater lift sump to indicate high water conditions within the sump due to system failure. The alarm activates a strobe alarm mounted
to a post adjacent to the sump. If the high-water level alarm is activated at the stormwater lift sump, ponding will occur at the catchbasins before water will overtop the stormwater
lift sump.The alarm is inspected during the second week of each month.
Annual Pipe Pressure Testing
All carrier pipes (Pipelines No. 1, No. 2, No. 3, No. 4, No. 4a, No. 4b, No. 5 and No. 5a) within the East Side Drainage System will be pressure tested annually during the third quarter
of the calendar year to ensure integrity. The Time-Pressure Drop method described in ASTM F1417 shall be used to determine the test criteria. In addition, the leak detection probes
(8 total) will also be inspected and tested annually at the same time as the pipe pressure testing. The testing shall be conducted under the direction of a certified Professional Engineer
qualified to perform pipe integrity testing. Notification of shut down of the system for testing purposes will be provided at least 48 hours prior to the Director. A written report
including test results will be maintained in the operating record.
South Ditch
The Vitro drainage ditch culvert replacement (hereafter referred to as the South Ditch) was constructed to reduce a potential source of groundwater mounding near well GW-60. Since the
ditch does not entirely free drain, the ditch contains a sump to lift remaining water from the ditch to the Southwest Corner Pond. The Southwest Corner Pond is a non-contact water collection
and storage pond outside the restricted area and is not subject to the Ground Water Quality Discharge Permit. The pump may be removed from the sump during freezing weather. When the
pump is removed, manual water removal will begin within the same working day after water is discovered to be above the sump grate.
LLRW Operations Building
Wastewater from the restricted area of the LLRW Operations Building drains to a 2,500 gallon double-walled collection tank outside of the building. A moisture leak detection sensor
is located at the bottom of the tank between the walls (annular space) of the tank to detect moisture or leakage from the primary wall of the tank. A strobe alarm located adjacent to
the tank is activated by the sensor in the tank annular space. A high-level float alarm (orange strobe) is set to indicate when the tank is three-quarters full (approximately 625 gallons
remaining capacity). A high-high-level float alarm (red strobe) is set just below the maximum capacity of the tank (approximately 125 gallons remaining capacity). The bootwash and
sample prep room floor drains are the lowest elevation floor drains in the building, and therefore will provide the earliest indication if the tank is overfilled.
SRS DU Storage Building
The SRS DU Storage Building is designed to protect SRS DU waste from the elements. The storage building is a steel building on concrete foundation with an asphalt floor.
Evaporation Pond Ancillary Equipment to Facilitate Evaporation
Ancillary equipment intended to facilitate evaporation at all Evaporation Ponds will be constructed of UV resistant, PVC piping that is set a minimum of 2 feet from the top of berm.
The inlet pipe is located over a rub sheet to protect the liner. Water is conveyed to the piping and fed back into the pond.

24 hours prior to use of ancillary equipment at an approved evaporation pond, verbal or email notification will be provided to Divisionin order to provide opportunity for inspection.

Any proposed change in a test design or construction of ancillary equipment at an evaporation pond must adhere to the following BAT principles:
Equipment that conveys contact wastewater (such as pumps, pipe, hoses, etc.) and is not located directly on the pond liner shall be placed inside a watertight secondary containment system
that drains into the pond.
Equipment that is placed onto or over the pond liner shall be placed so that the integrity of the pond liner is protected; i.e., placed on rub sheets or otherwise arranged to minimize
the potential for the pond liner to be damaged.
Spillage of contact wastewater outside of the pond or secondary containment or damage to the pond liner shall be responded to in accordance with the BAT Contingency Plan.
Stormwater ManagementThe Clive facility is inspected daily for the accumulation of stormwater. Water management personnel collect and transfer stormwater from within the restricted area
to the evaporation ponds. Collected stormwater and water contained within the evaporation ponds may also be used for minimal engineering and dust control purposes at the Class A West
embankment and for dust suppression activities at the Shredder Facility. The management of stormwater at the facility shall occur according to the following requirements: Stormwater
runoff at the Class AWest, and 11e.(2) Disposal Cells which has contacted the waste (i.e. contact stormwater), shall be contained. The priority schedule listed below shall be followed
for removal of stormwater that falls inside the restricted area. This includes runoff from waste disposed in excavated, below grade areas of the Disposal Cells.Within 24 hours of discovery
of any accumulation of contact stormwater, removal of said wastewater shall commence. Wastewater removal shall occur in accordance with the priority list below. Contact stormwater inside
the footprint of the Class AWest, and 11e.(2) Disposal CellsContact stormwater at the Rotary Dump FacilityContact stormwater at the IUFContact wastewater at any facility (e.g. BAT Failures,
facility maintenance, etc.)Non-contact stormwater within the restricted areaIf water removal equipment is not effective for use at higher priority water accumulation areas, said equipment
may be used at the next lower priority location where it will be effective provided that higher priority collection is not interrupted. This is defined as a bypass of priority collection
(e.g., if water removal equipment cannot navigate the terrain in the embankments, it can be used to remove water from a priority two location, if necessary; or if a pump is not usable
to transfer water at a priority one location and cannot be used at a priority two location, it can be used at the priority three location, or the next lower priority, where it will be
effective). If conditions improve so that water removal equipment can now access or be used at the previous higher priority inaccessible area, the water removal equipment will return
to the high priority area immediately. Within 24 hours the Manager, Compliance and Permitting or designee shall provide notification and justification to the Director whenever equipment
bypasses a higher priority for use at a lower priority location. Approval must be obtained from the Director to interrupt (stop) collection from a higher priority location for the
purpose of collecting water from a lower priority location. If stormwater removal at a lower priority location interrupts listed higher priority collection without required approvals,
contingency actions shall be performed in accordance with the BAT Contingency Plan.
East Side Rotary Facility
Rotary Dump
The Rotary is designed for the dumping of waste from railcars onto the East Side Rotary Facility floor. While dumping is in process, water cannons (as designated by approved plans) may
be used to remove excess material from the railcar. The East Side Rotary Facility floor is sloped for free drainage of wastewater to the sediment basin. Wastewater and storm water within
the sediment basin is pumped to Manhole 1A and pipeline 4b of the East Side Drainage System to Manhole 1 which drains into the 1997 Evaporation Pond.
Upper Wash Area
The East Side Rotary Facility wash is designed for the decontamination of railcars. Noncontaminated water is provided to the Facility via four 3,000-gallon water storage tanks located
outside of the Restricted Area. Water used in the decontamination process, on either the North or South end of the Facility, gravity drains via two rail trenches to a drainpipe. Water
from the drainpipe gravity drains to the sediment basin on the floor of the East Side Rotary Facility.
QUALITY ASSURANCE/QUALITY CONTROL
The Quality Assurance Manager or designee will conduct surveillance activities to ensure the requirements of the BAT Performance Monitoring Plan have been implemented, as required.
Surveillance activities will be performed in accordance with the currently approved Quality Assurance Program Document. The Quality Assurance Manager or designee will also review inspection
forms for accuracy and completeness.
The Manager, Waste Disposal Operations or designee will conduct a monthly assessment of the daily and weekly inspections to ensure inspection activities are performed in accordance with
this plan. Assessments will be conducted in accordance with currently approved procedures in accordance with ES-QA-PR-002, Quality Assurance Surveillances. The applicable site director
or designee will also perform reviews of inspection forms for accuracy and completeness.
FACILITY
BAT DESCRIPTION
INSPECTION AND MAINTENANCE
PERFORMANCE CRITERIA
DOCUMENTATION
1995, 1997, 2000, Northwest Corner, and Mixed Waste Evaporation Ponds
Freeboard between pond water level and spillway elevation, measured vertically
Daily – visual inspection
Minimum of 24 inches of freeboard.
Form 1 (Form 4 for MW Pond)
Leak detection system and monitoring equipment including: leak detection system pump, head pressure transducer, and flow meters
Daily – Record water flow meter reading.
Daily – Record fluid head reading from pressure transducer.
Weekly – Calculate seven-day average flow rate.
Pressure transducer ≤ 1.0 foot.
Flow rate initial action levels for each evaporation Pond:
1995 Pond – 155 gal/day
1997 Pond – 160 gal/day
2000 Pond – 355 gal/day
NW Pond – 300 gal/day

MW Pond – 160 gal/day
Form 1(Form 4 for MW Pond)
Form 2
Pump functionality and return pipe integrity
Monthly – inspect piping from leak detection system to pond through the manual removal of water.
Pump operational; no leakage from piping
Form 3
1995/1997 Evaporation Pond Lift Station
Water level within the lift station
Daily – Inspect for visual alarm activation.
Monthly – Confirm alarm function
Water level not to exceed the lowest level of the inlet pipe (set point for alarm)
Alarm trips manually
Form 1
Form 3
2000 Evaporation Pond Water Transfer Pad
Gravity flow from the pad to the collection sump.
Daily when stormwater present – free drainage; sump water level
Weekly – Surface integrity
Free drainage; water below grate of sump
See definition “Surface Integrity Discrepancy”
Form 1a
Form 2
Northwest Corner Evaporation Pond Transfer Facility
Concrete pad with HDPE apron for water transfer and collection.
Monthly – Surface integrity; inspect pad apron for signs of cracks, tears, or holes
No holes, cracks, or tears at the seam between the concrete apron and HDPE liner.
See definition “Surface IntegrityDiscrepancy”
Form 3
Containerized Waste Storage Pad
Minimize stormwater from contacting waste
Daily when stormwater present – free drainage; sump water level; cleanliness of pad surface
Weekly – Surface integrity; container storage compliance cleanliness of pad surface
Free drainage; water below grate of sump
See definitions “Surface Integrity Discrepancy” and “Container Storage Compliance”
Form 1a
Form 2
Intermodal Unloading Facility (IUF)
Minimize stormwater contact with waste
Daily - free draining conditions for unloading pad and stormwater drainage pipeline system. Daily when stormwater present – free drainage; sump water level, and cleanliness of pad surface
Weekly – Surface integrity; container storage compliance, and cleanliness of pad surface
Annual – Clean entire surface for detailed surface integrity inspection (see section 4.7)
Free drainage; water below grate of sump
See definitions “Surface Integrity Discrepancy” and “Container Storage Compliance”
Form 1
Form 1a
Form 2
Engineer’s report of annual inspection
IUF Lift Station
Contain contact water within facility
Daily – Inspect for visual alarm activation.
Monthly – Alarm function
Water level not to exceed the lowest level of the inlet pipe (set point for alarm)
Alarm trips manually
Form 1
Form 3
Rail Wash Facility on Track No. 4
Contain contact water within facility
Daily-Sump water level; free drainage (including concrete trench); and water level in collection and storage tanks. Weekly – surface integrity, sump pump operational; inspection of collection
and storage tanks.

Monthly – Alarm function
Sump water level below grate; free drainage; see definition “Surface Integrity Discrepancy”
Alarm trips manually
Form 1
Form 2
Form 3
Rail Digging Facility
Minimize stormwater contact with waste
Daily- cleanliness of asphalt and concrete surface. Daily when stormwater present – free drainage; sump water level.
Weekly – Surface integrity
Free drainage; water below grate of sump (4)
See definition “Surface Integrity Discrepancy”
Form 1
Form 1a
Form 2
East Truck Unloading Area and Container Holding Pads
Minimize stormwater contacting waste
Daily when stormwater present – free drainage; collection trough water level
Weekly – Surface integrity; container storage compliance
Free drainage; water level ≤ ¾ full
See definitions “Surface Integrity Discrepancy” and “Container Storage Compliance”
Form 1a
Form 2
Decontamination Access Control Building
Contain contact water within facility
Weekly – Free drainage to the wastewater collection tank; level of wastewater in the tank; leak detection system check
Monthly – Alarm function
Free drainage; water level not to exceed the lowest level of the inlet pipe (set point for alarm); no fluid in drip leg 7
Alarm trips manually
Form 2
Form 3
Intermodal ContainerWashBuilding
Contain contact water within facility
Daily-Sediment basin water level; free drainage; Weekly – surface integrity; leak detection system
Sump water level below grate; free drainage from bootwashes to troughs, from washbays to troughs through to the sediment basin; see definition “Surface Integrity Discrepancy”; no fluids
in leak detection system
Form 1
Form 2
Shredder Facility
Minimize stormwater contact with waste
Daily- free drainage. Daily when stormwater present – free drainage; sump water level; water level of catchbasins
Weekly – surface integrity
Annual – Clean entire surface for detailed surface integrity inspection
Free drainage to catchbasins; water below grate of sump (7)
Shredded material removed from the outfeed pad by the end of shift.
See definition “Surface Integrity Discrepancy”
Form 1
Form 1a
Form 2
Engineer’s report of annual inspection
Shredder Facility Alternate Wastewater Management System
Minimize stormwater contact with waste
Daily when in use – free drainage; pipeline integrity; high water level alarm; surface integrity
Monthly – Alarm function
Free drainage; water below grate of sump (7); pipeline not leaking; high level alarm off; see definition “Surface Integrity Discrepancy”
Alarm trips manually
Form 1b
Form 3
Rotary Dump Facility –
Thaw Building

Minimize stormwater contact with waste and contain contact water within all facilities. Consists of the Thaw, Rotary, and Wash buildings.
Contain contact water within facility
Weekly – free drainage (within Thaw Building and at discharge pipe); surface integrity
Free drainage; discharge pipe not blocked; see definition “Surface Integrity
Form 2
Rotary Dump Facility –
Rotary Building
Contain contact water within facility
Daily– free drainage; sediment basin water level
Weekly – surface integrity; leak detection system
Annual – Clean entire surface for detailed surface integrity inspection (includes Thaw Building and Wash Building concrete surfaces)
Free drainage; water below grate of sediment basin
See definition “Surface Integrity Discrepancy”; no fluids in leak detection system
Form 1
Form 2
Engineer’s report of annual inspection
Rotary Dump Facility –
Wash Building
Contain contact water within facility
Daily-free drainage; water in trenches below grates. Weekly – surface integrity (including east curb and seals around stairway footing)
Free drainage; see definition “Surface Integrity
Form 1
Form 2
Rotary Dump Facility –
Alternate Wastewater Management Area
Contain contact water within facility
When in use, Daily inspection for leakage in the pipeline from sediment basin to wastewater storage tanks; activation of visual alarms at wastewater storage tanks Weekly – free drainage;
pipeline integrity; high water level alarm; surface integrity
Monthly – Alarm function
Free drainage;; pipeline not leaking; high level alarm off; see definition “Surface Integrity Discrepancy”
Alarm trips manually
Form 1
Form 2
Form 3
East Side Drainage System
Contain contact water within system
Daily – Manhole 1, 2, and stormwater lift station alarms
Weekly –
Monthly – Leak detection system check ; Alarm function
Annual – Pressure test
Alarms off
No fluid in drip legs 1-2 (manhole 1) or 3-6 (manhole 2)
Alarm trips manually
See section 4.17.7
Form 1
Form 3
Engineer’s report of annual inspection
South Ditch
Reduce a potential source of groundwater recharge via timely transfer of water to Southwest Corner Pond
Daily when stormwater present – pump operating
Monthly – Alarm function
Pump operates while water in sump or manual removal
Alarm trips manually
Form 1a
Form 3
Southwest Corner Pond
Freeboard between pond water level and spillway, measured vertically
Daily – visual inspection when water is present above the sump grate at the South Ditch lift station
Minimum of 12 inches of freeboard
Form 1a

LLRW OperationsBuilding
Contain contact water within facility
Daily – Alarm status
Monthly – Free drainage to the wastewater collection tank; Annual - Alarm function
Alarms off
Bootwash and sample prep room floor drains free drain
Alarm trips manually
Form 1
Form 3Engineer’s report of annual inspection
SRS DU Storage Building
Prevent stormwater from contacting waste
Daily when stormwater present – Surface integrity; container storage compliance; check for presence of water.
Monthly – Surface integrity; container storage compliance, check for presence of water
See definitions “Surface Integrity Discrepancy” and “Container Storage Compliance”; remove any water observed
Form 1a
Form 3
Evaporation Pond Ancillary Equipment to Facilitate Evaporation
Contain contact water within the pond
Daily – pond liner integrity; system containment
Maintenance of pond liner integrity and prevention of spillage outside of pond or secondary containment.
Form 1
East Side Rotary Facility-
Lower Level (Dump Floor)
Contain contact water within facility
Daily- free drainage; sediment basin water level
Weekly- surface integrity; leak detection system; north and south ramp curbing
Annual- Clean entire surface for detailed surface integrity inspection (interior concrete surfaces and stairwell near sediment basin)
Free drainage: water below grate of sediment basin See definition “Surface Integrity Discrepancy”: no fluids in leak detection system
Form 1
Form 2
Engineer’s report of annual inspection
East Side Rotary Facility-
Manhole No. 1A
Contain contact water within facility
Daily- Manhole 1A alarm
Weekly- Leak detection system operation
Monthly- Leak detection system check: Alarm function
Alarms off
No fluid in drip leg
System is operational
Alarm trips manually
Form 1
Form 2
Form 3
East Side Rotary Facility-
Upper Wash Area
Contain contact water within facility
Daily- free drainage: water in trenches below grates (including north and south rail grates)
Weekly- surface integrity (including north and south rail seals and seals around stairway footing)
Annual- Clean entire surface for detailed surface integrity inspection
Free drainage: water below grate of sediment basin See definition “Surface Integrity Discrepancy”
Form 1
Form 2