DRC-2024-006175

July 8, 2024
Mr. Jonathan C. Anderson
Environmental Compliance Manager
EnergySolutions, LLC
299 South Main Street, Ste 1700
Salt Lake City, UT 84111
RE:RFI to the Request for Approval to Construct an Evaporation Pond: Ground Water Quality Discharge Permit (Permit) UGW450005; Radioactive Material License UT 2300249 (RML)
Dear Mr. Anderson:
In a letter dated April 10, 2024, (CD-2024-080, DRC-2024-005275) EnergySolutions requested approval to construct a new evaporation pond within the Restricted Area at the Clive, Utah
Site as required by the RML and Permit.Before a determination can be made, several questions and clarifications need to be answered because the Division of Waste Management and Radiation
Control (Division) intends to observe construction of the proposed Facility. To facilitate this, the Division must know what and how it is to be built and the composition of the materials.
These questions are outlined below.
Engineering:
Please provide details for pressure relief valves or justify the need for no pressure relief valves in the geosynthetics at the top of the pond.
The CQA/QC Plan needs a summary of the scope of work to be performed, similar to what is found in other pond CQA/QC plans, including but not limited to a summary of site preparation,
borrow materials characteristics, excavation and foundation preparation, project construction specification and CQA documents, etc., or a reference to where this information can be found.
Provide the manufacture’s QC/QA requirements for the various components of the liner for review, including requirements and specifications for the installation of the drainage net between
the liner layers.
Provide specification for the sump drain rock.
Please provide the Manufacturer QA/QCRequirements or Recommendations for geosynthetics testing, QA, QA/QC.
Will pressure testing be done on every long seam with a double seal?
Drawing 24003 L02Note 6 states that the East Side Drainage and Gray Water System has details for new storm water and wash water pipelines from Manhole #2, these are not included in the
package submitted. Please provide the Drawing Series or update the note.
Provide Leak Detection Rate calculations for both the Leak Rate Exceedance and Leak Rate at Initial Action Level including references.
Drawing 24003 C01 in Note #7 states that, “EnergySolutions reserves the right to use 80 mil HDPE in place of 60 mil HDPE.” Please include calculations for leakage rates based on 80 mil
HDPE or amend the sheet.
Surety:
Please justify or update the cost related to all material shredding.
For example, the shredder cost of operation for 2.82 hours for geosynthetics was calculated at $351.96, which seems very low operation costs for the shredder for 2.82 hours.
Justify or update disposal cost of shredder waste
For example, was hauling, and compaction of waste included in the cost estimate?
Environmental:
Exhibit G: Evaluation of the Adequacy of the Environmental Monitoring Plan. This was a restatement of the Environmental Monitoring Plan, not necessarily how the 2024 Evaporation Pond
will impact said Plan.
Please submit justification with analytical support for the statement that, “The proximity of this station [Air Monitoring Station A-19] to the proposed 2024 Evaporation Pond is sufficient
to monitor resuspended dust (generated at times when the 2024 Evaporation Pond is absent contact water) and external gamma radiation given off by contact water and pond sediments.”
A-19 does not appear to be“immediately east” of the 2024 Evaporation Pond as stated. Please update accordingly.
Please include a map with proximity to the nearest air monitoring stations.
Drawing 24003 L03
Note#2 after Gamma Monitoring Station F-35 is moved to the new Restricted Area Boundary, it should be differentiated from the current location of F-35 for data integrity purposes. Please
update where applicable and resubmit.
Soil Station S-24 should remain free of disturbances during construction. To facilitate this, the fencing should remain in place during construction.
Please address what impact, if any, construction will have on the S-24 Soil Sampling Location.
Please update drawings to include RA fencing with berms, where appropriate.
Provide specification for pump intended for use in leak detection system.
Prior to well drilling, please submit the Work Plan for review by the Division to ensure that accurate subsurface data are collected.
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