DRC-2024-004500

February 15, 2024
Mr. Jonathan C. Anderson
Environmental Compliance Manager
EnergySolutions, LLC
299 South Main Street, Ste 1700
Salt Lake City, UT 84111
RE:Request for Compliance Status Change and Request for Modification of the Groundwater Protection Level (GWPL) for Ra-226+Ra-228 in Monitoring Well GW-77Ground Water Quality Discharge
Permit (Permit) UGW450005
Dear Mr. Anderson:
In a letter dated October 7, 2022 (CD-2022-175, DRC-2022-021715), EnergySolutions requested that Groundwater Compliance Monitoring Well GW-77 return to compliance monitoring status from
Probable Out-of-Compliance (POOC) status for the Sum of Radiums (Ra-226+Ra-228). This letter also requested a modification to increase the Ground Water Quality Discharge Permit (Permit)
Groundwater Protection Level (GWPL) for GW-77 for Sum of Radiums from the currently approved 5.46 pCi/L to 5.66 pCi/L.
Previous requests to modify the GWPL for Sum of Radiums at GW-77 submitted by EnergySolutions were rejected by the Division of Waste Management and Radiation Control (Division) (then
DRC) due to an increasing trendin the time series plot of concentrationfirst noted in the 2007 Statement of Basis for the Permit modification. Before a determination can be made on the
GWPL for GW-77, please update the request to include the following information for review by the Division:
An up-to-date dataset including all samples from October 2022 until the present day.
Analysis comparing the variance of the currently accepted background dataset to the suggested additional dataset.
A time series plot of concentrationfor GW-77.
Formal outlier testing for the outliers removed from the dataset following the EPA Guidance as per the Permit (Rosner’s Test).
.csv file of raw data for verification of submitted results.
If you have any questions, please call Brandon Davis at 385-622-1783.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/BBD/[???]
c:Jeff Coombs, Health Officer, Tooele County Health Department
Bryan Slade, Environmental Health Director, Tooele County Health Department
EnergySolutions General Correspondence Email
LLRW General Correspondence Email