DRC-2024-004344

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com

January 30, 2024 CD-2024-015

Mr. Doug Hansen, Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880

Subject: Ground Water Quality Discharge Permit UGW450005 – Temporary
Variance Request for Augmented Decontamination Equipment
Authorization

Dear Mr. Hansen:
In accordance with Condition IV.P.1 of the Groundwater Quality Discharge Permit
UGW450005 (GWQDP), EnergySolutions hereby requests temporary authorization from
the Director of the Division of Waste Management and Radiation Control to
operationally vary from the wash water systems depicted in Engineering Drawings 9906-
02 and 9906-02A of Table 5 in Condition I.D of the GWQDP. As depicted in the Figure
1, EnergySolutions seeks to temporarily install a 40K Pressure Wash System to augment
authorized railcar decontamination activities in the Rail Wash Facility on Track No. 4.

Figure 1- 40K Pressure Wash System Layout

Mr. Doug Hansen
CD-2024-015
January 30, 2024
Page 2 of 2

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com

EnergySolutions has temporarily installed a clean wash water supply tank and pressurizer
outside of the Restricted Area (licensed under authority of the Radioactive Material
License UT2300249) to support the improved decontamination capability provided by a
40K Pressure Wash System. A hose has been run from the pressurizer, through the
Restricted Area boundary fence, into the north end of the Rail Wash Facility on Track
No. 4. A 2-inch polyvinyl chloride (PVC) or equivalent sleeve, secured with zip ties, will
protect the integrity of the hose connecting the pressurizer to the Rail Wash Facility on
Track No. 4. The section of the transfer hose between the Restricted Area fence and the
Rail Wash Facility on Track 4 will be protected by molded protective crossovers in the
event emergency access is needed. Additionally, vehicle travel over the hose will be
limited via signage and physical barriers. The improved decontamination efficiency of
the 40K Pressure Wash System reduces the amount of waste-contact water generated
during railcar decontamination. Therefore, no additional wastewater management
capacity is necessary to support temporary use of the 40K Pressure Wash System.

During the period of this variance, EnergySolutions will include inspection of the source
water tank, pressurizer, sleeved hose, and Rail Wash Facility on Track No. 4 connection
to the pressurized wands with those Best Available Technology inspections required by
Condition 4.9 of Appendix J to the GWQDP. To minimize discharge of non-contact
water to subsurface soils, the sleeved connection hose will be isolated from the source
water tank until repairs can be completed in the unlikely event that leaks, or other non-
contact water discharges are observed.

Detailed calculations and a running table of capacity used per year are provided within
each As-Built Report (provided electronically). Additionally, updated site utility and
savage site maps are separately included. Please contact me at 385-418-3044 if there are
any questions regarding this submittal.

Sincerely,

Jonathan C. Anderson
Environmental Compliance Manager
Jonathan C.
Anderson
Digitally signed by
Jonathan C. Anderson
Date: 2024.01.30
14:53:54 -07'00'