DRC-2024-005362

April 18, 2024
Jonathan C. Anderson
Environmental Compliance Manager
EnergySolutions, LLC
299 South Main Street, Ste 1700
Salt Lake City, UT 84111
RE:Request for Information,2023 Annual 11e.(2), LARW, Class A West, and Mixed Waste Groundwater Monitoring Report:Ground Water Quality Discharge Permit, No. UGW450005
Dear Mr. Anderson:
On February 26, 2024, the Division of Waste Management and Radiation Control (Division) received the 2023 Annual 11e.(2), LARW, Class A West, and Mixed Waste Groundwater Monitoring Report
(Report) (CD-2024-036) in accordance with Part I.H.1 of the Ground Water Quality Discharge Permit (Permit).
A preliminary review of this document indicates that the nested well pair GW-27/GW-27D is not compliant with Permit conditions. Part 1.E.26 of the Permit, Vertical Hydraulic Gradient
Performance Standard directsthat, “The Permittee shall maintain a neutral or upward hydraulic gradient in all nest or paired monitoring wells as the facility required by Part I.H.2(c)…”.
The submitted Reportshows GW-27/GW-27D does not meet this performance standard. Furthermore, dewatering activities near GW-19A/19B have notreducedgroundwater mounding in a significant
way in this area. While the vertical hydraulic gradient performance standard exempts GW-19A/GW-B for the time being, the intent of the exemption is not to allow the vertical gradient
to be out of compliance in perpetuity.
Therefore, the Division requests EnergySolutionssubmit a Corrective Action Plan (CAP) to correctthisvertical hydraulic gradient performance standard failure and return to the vertical
hydraulic gradient performance standards as outlined in Part I.E.26 of the Permit. This CAP shall address the downward vertical hydraulic gradient at GW-27/GW-27D and shall also include
a comprehensive analysis of actions taken at GW-19A/GW-19B, including year-to-year analysis, since the installation of the mound removal well, of groundwater elevations to evaluate the
efficacy of the existing dewatering plan.
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