DRC-2018-005864 - 0901a068808496c3

Div of Waste Management
and Radiation Control
JUN 1 4 2018
ENERGYSOLUTIONS
June 14, 2018
Mr. Scott T. Anderson, Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880
CD18-0110
DgC -Z018-005664
Re: Groundwater Quality Discharge Permit Number UGW450005 (GWQDP) —
Resolution of BAT Concerns: 1995, 1997, and Northwest Corner Evaporation
Pond Leak Detection Systems
Dear Mr. Anderson:
This letter provides resolution of recent BAT concerns for the leak detection systems at
the 1995, 1997, and Northwest Corner Evaporation Ponds. Each is discussed separately
below.
1995 Evaporation Pond — On June 8, 2018, EnergySolutions notified the Division of
Waste Management and Radiation Control (DWMRC) via e-mail that the leak detection
system display unit of the 1995 Pond was reading "High." In accordance with Part 4.1.6
of the BAT Contingency Plan (GWQDP Appendix K), on June 11, 2018,
EnergySolutions maintenance personnel inspected the system and replaced the fluid-head
level transducer. At that time, EnergySolutions also performed a bore-scope video
inspection of the system to confirm proper placement of the pump and transducer. The
leak detection system is operational and the fluid head has remained below the 1-foot
level.
1997 Evaporation Pond — On March 27, 2018, the BAT inspector found that the 1997
Evaporation Pond leak detection system was not functioning. The fluid head level in the
sump was 1.98 feet, exceeding the GWQDP Part I.E.14.a.3 requirement to not exceed
1 foot. In accordance with Part 4.1.6 of the BAT Contingency Plan, EnergySolutions
maintenance personnel checked the pump and process control unit later the same day and
determined the pump was not operational, requiring repair or replacement. Maintenance
personnel were unable to complete the replacement the same working day, and therefore,
EnergySolutions notified DWMRC via e-mail of the concern on March 27, 2018. On
March 28, 2018, EnergySolutions maintenance personnel replaced the 1997 Pond leak
detection system pump. Maintenance personnel also confirmed the system was
operational and the fluid head level had dropped below the 1-foot level during that same
day. As discussed in submittal CD18-0066 (March 30, 2018), because the bore-scope
camera was not operational, EnergySolutions was unable to perform a video inspection of
the pump placement at that time. Since the pump replacement on March 28, 2018, the
system has functioned as designed and the fluid head level has remained below the 1-foot
level. On June 11, 2018, EnergySolutions performed a bore-scope video inspection of the
299 South Main Street, Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: [phone] • www.energysolutions.com
e
ENERGYSOLUTIONS Mr. Scott Anderson
June 14, 2018
CD18-0110
Page 2 of 2
1997 Pond leak detection system to confirm proper placement of the pump and
transducer.
Northwest Corner Pond — On January 18, 2018 (CD18-0011), EnergySolutions notified
DWMRC of a malfunctioning leak detection system process control unit at the Northwest
Corner Pond. Based on fluid head readings, the system was not pumping water from the
sump in the "Auto" position. Also, despite visual confirmation that the system was
pumping water, the fluid head reading remained above the 1-foot level when the system
was operated in the manual mode. Early in the week of January 22-26, 2018,
EnergySolutions maintenance personnel determined the pump and the pressure transducer
were operational. They repositioned the pump and transducer and checked the
programming of the control unit. Since that time, the leak detection system has
functioned as designed and fluid head readings have remained below the 1-foot level.
However, because the bore-scope camera was not operational, EnergySolutions was
unable to perform a video inspection of the pump placement at that time. On June 11,
2018, based on results of the annual evaporation pond pump inspection required by
GWQDP Part I.F.13.d, EnergySolutions replaced the Northwest Corner Pond pump.
EnergySolutions also performed a bore-scope video inspection to confirm proper
placement of the pump and transducer.
This notification is being made in accordance with UAC-R317-6-6.13. The leak
detection system BAT failures were not intentional or caused by Permittee negligence.
Contingency actions were implemented as required. The provisions of UAC 19-5-107
have not been violated. Therefore, no unlawful discharge to the groundwater occurred.
Please contact me at [phone] with any questions regarding this notification.
Sincerely,
Robert W. Sobocinski
Groundwater Program Manager
cc: Charles Bishop (DWMRC)
Don Verbica (DWMRC)
I certift 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 submitting false information, including the possibility of fine and imprisonment for knowing violations.