DRC-2024-004808

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--------ENERGYSOLUTIONs --------
March 5, 2024
Mr. Doug Hansen, Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880
CD-2024-043
Re: Groundwater Quality Discharge Permit (GWQDP) No. UGW450005-
Amendment to the Semi-Annual Best Available Technology (BAT) Monitoring
Report for July 1 to December 31, 2023
Dear Mr. Hansen:
On February 27, 2024 the Second Semi-Annual BAT Monitoring Report for 2023 was
submitted (CD-2024-039) to DWMRC. It was brough to our attention that there was an
error in section 3.6 Out-of-Service Facilities, the Rail Digging Facility was not updated to
indicate it had been returned back to in-service. This letter is to provide the updated
Second Semi-Annual BAT Monitoring Report for 2023 with the statement for the
amendment below.
3.6 Out-of-Service Facilities:
Rail Digging Facility-The Rail Digging Facility was taken out of service on April 1,
2021. Notification was provided to the Division of Waste Management and Radiation
Control (DWMRC) on March 26, 2021 (submittal CD-2021-047). Following the
inspection of the surface integrity and repair of identified defects, the Rail Digging
Facility was placed back into service on October 2, 2023. Notification was provided to
the DWMRC on September 25, 2023 (CD-2024-187).
Please contact me at [phone] with any questions regarding this notification.
Sincerely,
Jon Anderson
Environmental Compliance Manager
cc: Charles Bishop (DWMRC)
Brandon Davis (DWMRC)
Bailey Anderson (DWMRC)
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
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ENERGYSOLUTIONS Mr. Doug Hansen
March 5, 2023
CD-2024-043
Page 2 of2
I certify 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
submittingfalse information, including the possibility affine and imprisonment for knowing violations.
ENERGYSOLUTIONS, LLC
BAT MONITORING REPORT
2ND SEMI-ANNUAL
JULY -DECEMBER 2023
(SECTION 3.6 OUT-OF-SERVICE FACILITIES AMENDED ON MARCH 5, 2023)
1.0 INTRODUCTION
EnergySolutions, LLC, (EnergySolutions) was granted a Groundwater Quality Discharge
Permit, No. UGW450005 (GWQDP), by the State of Utah Division of Water Quality. The
GWQDP details the construction, operation, and monitoring requirements for Clive, Utah
facilities that have a potential of releasing fluids to the groundwater. The GWQDP specifies
that "Best Available Technology" (BAT) be used in the construction of waste-and wastewater-
related facilities and that those facilities be operated according to "Best Management Practices."
Condition I.H.20 of the GWQDP requires EnergySolutions to submit a Semi-Annual BAT
Monitoring Report that provides results, calculations, and evaluations of daily BAT monitoring
data at the EnergySolutions Clive, Utah facility. This report provides the BAT monitoring data
for the period of July 1 through December 31, 2023.
2.0 BAT MONITORING DATA
BAT monitoring data are collected as described in Appendix J of the GWQDP. BAT
monitoring data for July to December 2023 are included in this report as follows:
• Appendix A-1, LLRW/1 le.(2) Daily Inspection Forms -documents the results of the
daily BAT inspections for LLRW and l le.(2) operations.
• Appendix A-2, LLRW/1 le.(2) Weekly Inspection Forms-documents the results of the
weekly BAT inspections for LLRW and 1 le.(2) operations.
• Appendix A-3, LLRW/1 le.(2) Monthly Inspection Forms-documents the results of the
monthly BAT inspections for LLRW and 1 le.(2) operations.
• Appendix B, Evaporation Pond(s) Leak Detection System Volume Weekly Calculation
Forms-provides weekly calculations of the average daily volume from the leak
detection sumps at the 1995, 1997, 2000, and Northwest Comer evaporation ponds.
• Appendix C, Mixed Waste Evaporation Pond Daily Inspection Forms-documents daily
measurements of fluid head and pumped water volume in the leak detection sump of the
Mixed Waste Evaporation Pond.
• Appendix D, Mixed Waste Evaporation Pond Leak Detection System Volume Weekly
Calculation Forms -provides weekly calculations of the average daily volume from the
leak detection sump at the Mixed Waste Evaporation Pond
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BAT Monitoring Report
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• Appendix E, Rotary Dump Facility Inspection Forms -documents the presence of
ponded water at the facility. This is in addition to the daily inspection of the facility
performed as part of the LLRW/1 le.(2) daily BAT inspection.
• Appendix F, Correspondence-Contains correspondence from reportable incidents.
Correspondence referenced in this report are included in Appendix F.
• Appendix G, Annual Facility Inspection Reports
• Appendix H, Storm Water Collection Worksheets -provides documentation of storm
water management including collection locations, quantities, and discharge locations in
evaporation ponds.
3.0 SUMMARYOFDATA
3.1 Precipitation:
Precipitation data from the Clive facility meteorological monitoring station are provided in
Table 1. The total precipitation at the site for the period January 2023 through December 2023
was 11.24 inches (285.50 mm). Precipitation data for the Clive site show that for the current
year (2023), precipitation totals were above average. Total precipitation for the second half of
2023 was 4.07 inches, compared to a 30-year average of 3.12 inches. During July, precipitation
occurred on 2 days, with a monthly total of0.13 inches and the highest precipitation (0.08
inches) falling on July 19th . During August, precipitation occurred on 7 days, with a monthly
total of 0.66 inches and the highest precipitation (0.27 inches) falling on August 1st . During
September, precipitation occurred on 7 days, with a monthly total of 0.90 inches and the highest
precipitation (0.46 inches) falling on September 21 st . During October, precipitation occurred on
7 days, with a monthly total of 1.42 inches and the highest precipitation (1.05 inches) falling on
October 2nd (this information does not include 0.28 inches recorded on October 17th because of
semi-annual calibration of the weather station). During November, precipitation occurred on 5
days, with a monthly total of0.80 inches and the highest precipitation (0.26 inches) falling on
November 7th . During December, precipitation occurred on 2 days, with a monthly total of 0.16
inches and the highest daily precipitation (0.08 inches) falling on December 3rd .
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BAT Monitoring Report
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3.2 Evaporation Pond Fluid Head Monitoring:
In accordance with Part 1.E.14.a.3 of the GWQDP, daily fluid head monitoring of evaporation
pond leak detection systems is required to be performed each day that waste or water
management activities occur. The fluid head monitoring data for each pond are discussed in the
following sections.
1995 Evaporation Pond -Daily evaporation pond fluid head measurements are
documented in Appendix A-1. Table 2 lists the daily measurements. Figures 1 and 2
provide a comparison of the fluid head measurement to the allowable fluid head of one
foot as required by the GWQDP. During the reporting period, the recorded fluid head
measurements did not exceed the allowable limit. The information in Appendix A-1
documents compliance with the BAT performance standards for fluid head monitoring at
the 1995 Evaporation Pond.
1997 Evaporation Pond -Fluid head measurements were recorded on the Daily
Inspection Forms provided in Appendix A-1. Table 2 lists the daily measurements.
Figures 3 and 4 provide a comparison of the fluid head measurement to the allowable
fluid head of one foot as required by the GWQDP. During the reporting period, the
recorded measurements did not exceed the allowable limit. The information in
Appendix A-1 documents compliance with the BAT performance standards for fluid
head monitoring at the 1997 Evaporation Pond.
2000 Evaporation Pond -Fluid head measurements were recorded on the Daily
Inspection Forms provided in Appendix A-1. Table 2 lists the daily measurements.
Figures 5 and 6 provide a comparison of the fluid head measurement to the allowable
fluid head of one foot as required by the GWQDP. During the reporting period, the
recorded measurements did not exceed the allowable limit. The information in
Appendix A-1 documents compliance with the BAT performance standards for fluid
head monitoring at the 2000 Evaporation Pond.
Mixed Waste Evaporation Pond -Fluid head measurements were recorded on the Mixed
Waste Evaporation Pond Daily Inspection Forms provided in Appendix C. Table 2 lists
the daily measurements. Figures 7 and 8 provide a comparison of the fluid head
measurement to the allowable fluid head of one foot as required by the GWQDP.
During the reporting period, the recorded measurements did not exceed the allowable
limit. The information in Appendix C documents compliance with the BAT
performance standards for fluid head monitoring at the Mixed Waste Evaporation Pond.
Northwest Comer Evaporation Pond -Fluid head measurements were recorded on the
Daily Inspection Forms provided in Appendix A-1. Table 2 lists the daily
measurements. Figures 9 and 10 provide a comparison of the fluid head measurement to
the allowable fluid head of one foot as required by the GWQDP. During the reporting
period, the recorded measurements did not exceed the allowable limit. The information
in Appendix A-1 documents compliance with the BAT performance standards for fluid
head monitoring at the Northwest Comer Evaporation Pond.
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BAT Monitoring Report
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3.3 Evaporation Pond, Flow Monitoring:
In accordance with Part 1.E.14.a.2 of the GWQDP, monitoring of the leak detection system
flow volume is performed at evaporation ponds each day that waste or water management
activities occur. The flow volume monitoring data for each pond are discussed in the following
sections.
1995 Evaporation Pond -Average daily flow volumes from the leak detection sump at
the 1995 Evaporation Pond were calculated on Evaporation Pond(s) Leak Detection
System Volume Weekly Calculation Forms, provided in Appendix B. Table 3 provides
a summary of the average daily flow calculations for the reporting period. Average
daily flows for the 1995 Evaporation Pond did not exceed the pump-test limit of 155
gallons per day and did not exceed the maximum allowable flow of 162 gallons per day.
During the reporting period, there were no apparent trends that might forecast a potential
leakage to the groundwater from the facility. EnergySolutions has maintained
compliance with the GWQDP BAT performance standards for leak detection system
flow volume at the 1995 Evaporation Pond.
1997 Evaporation Pond -Average daily flow volumes from the leak detection sump at
the 1997 Evaporation Pond were calculated on Evaporation Pond(s) Leak Detection
System Volume Weekly Calculation Forms, provided in Appendix B. Table 3 provides
a summary of the average daily flow calculations for the reporting period. Average
daily flows for the 1997 Evaporation Pond did not exceed the pump-test limit of 160
gallons per day and did not exceed the maximum allowable flow of 171 gallons per day.
During the reporting period, there were no apparent trends that might forecast a potential
leakage to the groundwater from the facility. EnergySolutions has maintained
compliance with the GWQDP BAT performance standards for leak detection system
flow volume at the 1997 Evaporation Pond.
2000 Evaporation Pond -Average daily flow volumes from the leak detection sump at
the 2000 Evaporation Pond were calculated on Evaporation Pond(s) Leak Detection
System Volume Weekly Calculation Forms, provided in Appendix B. Table 3 provides
a summary of the average daily flow calculations for the reporting period. Average
daily flows for the 2000 Evaporation Pond did not exceed the pump-test limit of 355
gallons per day and did not exceed the maximum allowable flow of 382 gallons per day.
During the reporting period, there were no apparent trends that might forecast a potential
leakage to the groundwater from the facility. EnergySolutions has maintained
compliance with the GWQDP BAT performance standards for leak detection system
flow volume at the 2000 Evaporation Pond.
Mixed Waste Evaporation Pond -Average daily flow volumes from the leak detection
sump at the Mixed Waste Evaporation Pond were calculated on Mixed Waste
Evaporation Pond Leak Detection System Volume Weekly Calculation Forms, provided
in Appendix D. Table 3 provides a summary of the average daily flow calculations for
the reporting period. The average daily flows for the Mixed Waste Evaporation Pond
did exceed the initial action level of 160 gallons per day the week of December 4-12,
2023 with an average pump rate of 165.42 gallons per day. Per GWQDP Appendix K
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BAT Monitoring Report
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4.1.4, a pump down test was completed on December 11, 2023 by pumping into a
container with a known 5-gallon capacity. The pump down test result matched the
reading results of the flow meter. Per GWQDP Appendix K 4.1.4.4.c this report
provides the written report for the accuracy of the pumping system. The Mixed Waste
Evaporation Pond did not exceed the maximum allowable flow of 171 gallons per day
for any weekly calculation during 2023. During the reporting period, there were no
apparent trends that might forecast a potential leakage to the groundwater from the
facility. EnergySolutions has maintained compliance with the GWQDP BAT
performance standards for leak detection system flow volume at the Mixed Waste
Evaporation Pond.
Northwest Comer Evaporation Pond-Average daily flow volumes from the leak
detection sump at the Northwest Comer Evaporation Pond were calculated on
Evaporation Pond(s) Leak Detection System Volume Weekly Calculation Forms,
provided in Appendix B. Table 3 provides a summary of the average daily flow
calculations for the reporting period. Average daily flows for the Northwest Comer
Evaporation Pond did not exceed the pump-test limit of 300 gallons per day and did not
exceed the maximum allowable flow of 326 gallons per day. During the reporting
period, there were no apparent trends that might forecast a potential leakage to the
groundwater from the facility. EnergySolutions has maintained compliance with the
GWQDP BAT performance standards for leak detection system flow volume at the
Northwest Comer Evaporation Pond.
3.4 Annual Facility Inspection Reports:
East Side Drainage System -The East Side Drainage System was pressure tested and
inspected on September 11, 2023. All system piping met test requirements. The testing
and inspection report is provided in Appendix G.
Containerized Waste Facility and Large Component Evaporation Basin-The annual
survey of the evaporation basin was completed on June 28, 2023. The inspection report
is provided in Appendix G.
LLRW Operations Building Gray Water Tank System -The gray water tank level alarm
and leak detection verification system was inspected August 10, 2023. The inspection
form is provided in Appendix G.
3.5 Storm Water Management Tracking:
Storm water accumulation and management is tracked each day storm water is present in the
Restricted Area. Conditions I.E.7.a and I.E.7.b of the GWQDP provide general storm water
management requirements for identifying, collecting, and disposing storm water which may
potentially come in contact with waste (Contact Storm Water). Condition I.F.24 provides
requirements for documenting Contact Storm Water removal activities including: date, time,
and location of discovery of storm water accumulation; date and time when storm water
removal was initiated at each location; date and time when storm water removal was completed
at each location; and volumes of storm water removed at each location as well as where the
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BAT Monitoring Report
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water was disposed. Condition I.H.20.b of the GWQDP provides requirements for reporting
Storm Water Management activities, including the submittal of Storm Water Accumulation
Inspection and Collection Forms, which are provided as Appendix H to this report.
Combined precipitation during third and fourth quarters of 2023 totaled 4.07 inches resulting in
collection of 429,800 gallons of storm water accumulation. For comparison, the 30-year (1993
to 2022) average precipitation total for the third and fourth quarters is 3.12 inches (MSI, 2023).
Management review of storm water collection documentation reveals that collection activities
occurred as required.
3.6 Out-of-Service Facilities:
Containerized Waste Storage Pad-The Containerized Waste Storage pad was taken out of
service January 17, 2013 due to cracks on the pad surface. Waste was removed from the pad,
and notification was provided to the Division of Radiation Control (DRC) on January 18, 2013
(submittal CD13-0028). Entrances to the pad are roped off, and the pad remained out of service
during the second half of 2022.
Rail Digging Facility -The Rail Digging Facility was taken out of service on April 1, 2021.
Notification was provided to the Division of Waste Management and Radiation Control
(DWMRC) on March 26, 2021 (submittal CD-2021-047). Following the inspection of the
surface integrity and repair of identified defects, the Rail Digging Facility was placed back into
service on October 2, 2023. Notification was provided to the DWMRC on September 25, 2023
(CD-2024-187).
East Side Drainage System -Operations associated with the East Side Drainage System,
including the Intermodal Container Wash Facility (ICWF), were suspended on September 11,
2023, to perform the annual pipe pressure testing as required by Part 4.16.7 of GWQDP
Appendix J. System operation and the operation of associated facilities resumed on September
11, 2023, following the conclusion of the test.
4.0 BAT DISCREPANCIES AND RESOLUTIONS
Table 4 provides a summary of the discovery and resolution of BAT discrepancies. Each entry
summarizes the date a BAT concern is observed, the location and description of the concern,
associated findings/solutions, and the date the concern is resolved. When a BAT concern spans
multiple days and is resolved by a single action, the multiple observations are grouped in a
single entry (row) on Table 4. Table 4 also lists the completion of modifications of features
and/or facilities that have BAT criteria associated with them. As appropriate, Table 4 includes
tracking numbers ( e.g., CD-2023-:XXX) for notification letters submitted to DWMRC.
Documentation of correspondence related to the BAT discrepancies is included in Appendix F
of this report.
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BAT Monitoring Report
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Table 4
BAT Discrepancies and Resolution -LLRW and Mixed Waste Facilities
Date Location Occurrence Findings/Solution Observed
Modification of the Southeast & Dividing wall between southeast and southwest bays was
6/12/23 IUF South Bays Southwest Bays removed due to structural integrity issues. Placed back
into service 8/4/23 following repairs and inspection
Water was present in the northern portion of the building
8/4/23 SRS DU Storage Building Presence of water in building (CD-2023-162). The water was removed the same day.
Contractor made roofrepairs to fix leaks (CD-2023-182)
Water was present in the northern portion of the building
8/23/23 SRS DU Storage Building Presence of water in building (CD-2023-173). The water was removed the same day.
Contractor made roofrepairs to fix leaks (CD-2023-182)
A blockage caused a false alarm, the blockage was due to
9/21/23 IUF Lift Station Visual Alarm was activated 0.38 inches of precipitation on 9/21/23. Maintenance
removed the blockage and reset the alarm.
A second blockage caused a false alarm, the blockage
9/22/23 IUF Lift Station Visual Alarm was activated was due to 0.16 inches precipitation on 9/22/23.
Maintenance removed the blockage and reset the alarm.
Due to high precipitation, stormwater overwhelmed the
10/2/23 IUF Lift Station Visual Alarm was activated pumps. After the storm event (the same day) the water
level dropped, and the alarm deactivated.
Addressed in
Accordance
Date with BAT
Addressed Contingency
7/25/23
9/27/23
9/27/23
9/21/23
9/22/23
10/2/23
Plan Schedule
(YIN/NA)
NIA
ya
ya
y
y
y
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BAT Monitoring Report
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Table 4
BAT Discrepancies and Resolution -LLRW and Mixed Waste Facilities
Date Location Occurrence Findings/Solution Observed
Water was above the grate of the Due to high precipitation, stormwater overwhelmed the
10/2/23 Rotary Building sediment basin pump. After the storm event (the same day) the water
level dropped.
Water was present in the northern portion of the building
10/3/23 SRS DU Storage Building Presence of water in building (CD-2023-206). The water was removed the same day.
Resolution to prevent leaks is still ongoing at the time.
10/10/23 East Side Drainage Water in the manhole Water was removed the same day (CD-2023-214) System Manhole #1 Vault
10/10/23 East Side Drainage Visual Alarm light was burn out Maintenance replaced the light bulb (CD-2023-214) System Manhole #1 Vault
Pond leak detection system fluid The leak detection system pump was replaced (CD-2023-10/16/23 1995 Pond head process unit displayed an 219) error
Small liner defects in the 1995, 1997, 2000 and
Northwest Pond were repaired within the corrective
1995, 1997,2000,Mixed action plan (CAP) (CD-2023-115). To address average
10/24-Waste, Northwest Holes in pond liners leakage rate exceedances, the Mixed Waste (MW) pond
25/23 Evaporation Ponds was inspected and repaired in accordance with the CAP.
To address average leakage rate exceedances, the 1997
pond was inspected with the CAP, no defects were
observed.
Addressed in
Accordance
Date with BAT
Addressed Contingency
Plan Schedule
(YIN/NA)
10/2/23 y
10/3/23 ya
10/10/23 y
10/12/23 y
10/17/23 y
10/24-25/23 y
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BAT Monitoring Report
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Table 4
BAT Discrepancies and Resolution -LLRW and Mixed Waste Facilities
Addressed in
Accordance
Date Location Occurrence Findings/Solution Date with BAT
Observed Addressed Contingency
Plan Schedule
(YIN/NA)
East Side Drainage Water observed in the sight glass Leak detection sensors were replaced, water was
11/7/23 removed, and the canister was cleaned. Water was 11/9/23 y
System Manhole #2 canister believed to be from condensation (CD-2023-231).
12/12/23 1995 Pond Transducer failed The transducer was reset and put back into service (CD-12/13/23 y
2023-255).
DWMRC determined this not to be out of compliance
12/12/23 Track No. 4 Rail Decon Cracks in the floor (DRC-2023-077910). Seek-a-flex was applied to the 12/15/23 y
cracks (CD-2023-255).
A temporary patch was applied the at the time of the
12/12/23 SRS DU Storage Building A hole was found in a drum inspection. The drum was permanently fixed with 12/12/23 y
caulking the same day (CD-2023-255).
Water was present in the northern portion of the building
12/12/23 SRS DU Storage Building Presence of water in building (CD-2023-255). The water was removed the same day. 12/12/23 ya
Resolution to prevent leaks is still ongoing at the time.
a Reporting of the occurrence of water in the building and subsequent inspection was performed in accordance with GWQDP Appendix K Part 4.19.3.
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BAT Monitoring Report
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5.0 QUALITY ASSURANCE
As required in Appendix J of the GWQDP, the Operations Manager and the Quality
Assurance Manager, or designees, reviewed each LLRW/1 le.(2) Daily, Weekly, and
Monthly Inspection Form; each Mixed Waste Evaporation Pond Daily Inspection Form;
each Evaporation Pond(s) Leak Detection System Volume Weekly Calculation Form;
each Mixed Waste Evaporation Pond Leak Detection System Volume Weekly
Calculation Form; and each Rotary Dump Facility Inspection Form for completeness,
accuracy, and compliance with BAT requirements. The Operations Manager and the
Quality Assurance Manager, or designees, also reviewed each Storm Water Collection
Worksheet for completeness, accuracy, and compliance with BAT requirements.
Additionally, the Manager, Compliance and Permitting, or designee, reviewed all forms
for completeness, accuracy, and compliance with BAT requirements in the preparation of
this report. As part of the quality assurance review of BAT compliance, the Operations
Manager or designee also performs a monthly assessment of daily and weekly BAT
inspection activities.
6.0 CONCLUSION
During the period of July to December 2023, EnergySolutions performed BAT
performance monitoring in accordance with the GWQDP for facilities that have a
potential to release pollutants to the groundwater. During this reporting period,
EnergySolutions noted relatively infrequent discrepancies with the BAT performance
plan. Discrepancies were addressed in compliance with the GWQDP. All facilities were
operated in accordance with Best Management Practices and in compliance with Part
I.H.20.
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