DRC-2024-005246

April 11, 2024
Jonathan C. Anderson
Environmental Compliance Manager
EnergySolutions, LLC
299 South Main Street, Ste 1700
Salt Lake City, UT 84111
RE:Request for Information for the East Side Rotary Facility As-Built Report:Radioactive Material License UT 2300249
Dear Mr. Anderson:
On March 7, 2024,EnergySolutionsprovided responses (CD-2024-046) to the outstanding questions that the Division of Waste Management and Radiation Control (Division) raised concerning
the request to put the East Side Rotary Facility (ESRF). Specific questions that remain unanswered, or where clarification is still needed, are listed below.
Generally, the inclusion of the term “Legacy” throughout the responses provided to the Division may be misleading or unclear to the public record. To clarify this potential miscommunication,
there is no legacy program involved with the ESRF that relates to, or should be confused with, the Department of Energy (DOE) Legacy Management Program. For clarity of the record, please
refrain from using the term “Legacy” when referring to the ESRF unless referencing a DOE Legacy Management Site.
CD-2023-091 (DRC-2023-003771)
The Division agrees with the narrative provided to this response. Please update the As-Built Drawings to include in the narrative and in the drawings where needed and resubmit.
The Division agrees with the narrative provided to this response. Please update the As-Built Drawings to include in the narrative and in the drawings where needed and resubmit.
CD-2022-029 (DRC-2022-001741)
The submittal for an East Side Evaporation Pond will be considered independently from the ESRF when submitted. If no submittal is received for the 2024 construction year, the Director
reserves the right to reevaluate potential “in-service status” of the ESRF.
Waste handling will occur near the Elevated Water Tank and it continues to be an infiltration pathway. This issue will be addressed independently of the ESRF and a letter will be forthcoming
from the Division.
CD-2023-196 (DRC-2023-074200)
Exhibit 1: East Side Rotary Facility Groundwater Well Monitoring
In the introduction, EnergySolutions states that, “The ESRF is a new facility within the existing Clive Facility; it is not a new facility from the perspective that its monitoring and
BAT requirements are addressed within the scope of GWQDP UGW450005.” This is incorrect. R317-6 Ground Water Quality Protection in part 1 Definitions states, “Facilitymeans any building,
structure, processing, handling, or storage facility, equipment or activity; or contiguous group of buildings, structures, or processing, handling or storage facilities, equipment, or
activities or combination thereof.” The ESRF is a Facility as defined in R317-6-1.
Proposed Monitoring Well Locations
Intrawell analysis was proposed for determining background Ground Water Protection Levels (GWPL) at the ESRF which has been the method used for the Permit at previous locations. However,
in accordance with EPA Unified Guidance, “Intrawell background measurements should be selected from the available historical samples at each compliance well and should include only those
observations thought to be uncontaminated.” (EPA pg 5-6) The ongoing hydrocarbon investigation, which is evaluated separately, encompasses the footprint of the ESRF, therefore, intrawell
methodology cannot be used. Interwell monitoring may need to be implemented for the ESRF.
Please update the proposed Monitoring Well locations to include at least one upgradient well and two downgradient wells.R317-6-6.10 B One or more up-gradient, lateral hydraulically equivalent
point, or other monitoring wells as approved by the Director may be required for each potential discharge site.
Please propose a timeline for the installation of the Compliance Monitoring Wells as these need to be installed and developed before operations as the ESRF can begin.
Monitoring Wells for the ESRF may not be utilized for the hydrocarbon investigation unless written approval from the Director is received and in no way shall impact the efficacy of the
well as Compliance Monitoring Wells.
Sampling and Analytical Program
A suite of analytes including: VOCs, 11e.(2) analytes, Metals, PCBs, and Radioisotopes, in addition to the Field and Laboratory parameters as outlined in Exhibit 1: 5. Sampling and Analytical
Programshall be conducted for eight samples due to potential anthropogenic impacts to groundwater at the ESRF. After the initial sampling period, EnergySolutions shall submit a groundwater
evaluation report to the Division within 60 days for review.
4.0 Alarm Testing at Manhole MH-1A Leak Detection System
EnergySolutionsmay conduct a pressure test without the presence of the Division if it follows the procedures outlined for the East Side Drainage System pressure test, which must be done
under the direction of a Professional Engineer. A report of this pressure test will be submitted to the Division after completion of the test.
Attachment H Sealing of Rail/RailSeal at Facility Entrances
The statement, “Moreover, decontamination operations will be instructed to be focused inward and away from the entrances and towards the floor drains located along the rails.” does not
meet BAT requirements. Please provide engineered controls to prevent water from leaving the facility from the ends of the facility or out of the rail line.
Please respond to this request within 30 days of receipt. If you have any questions, please call Brandon Davis at385-622-1873.
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
Jonathan C. Anderson, Environmental Compliance Manager, EnergySolutions, LLC
EnergySolutions General Correspondence Email
LLRW General Correspondence Email