DRC-2024-005476

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========-=-=--=--=--=--=--=ENERGYSOLUTIONS ================
April 29, 2024
Mr. Doug Hansen, Director
Division of Waste Management and Radiation Control
P .O. Box 144880
Salt Lake City, UT 84114-4880
CD-2024-093
Re: Response to the Request for Information (RFI) to the East Side Rotary Facility
As-Build Report Radioactive Material License (RML) UT 2300249
Dear Mr. Hansen:
EnergySolutions hereby responds to a Request for information received from the Director
of Waste Management and Radiation Control related to the new East Side Rotary Facility
(ESRF).1 Below are EnergySolutions' responses to the Director's requests.
REQUEST FROM CD-2023-091 {DRC-2023-005246)
1. The Division agrees with the narrative provided to this response. Please
update the As-Built Drawings to include the revisions in the narrative and in
the drawings where needed and resubmit.
Included in appendix A is drawing 1959-C3 l 0(8) showing the location of the
closed/remediated dry wells, drawing 2115-S432(1) and S434(3) that shows the location
of the affected steel members of the collapse along with a narrative of events and
corrective actions.
REQUEST FROM CD-2022-029 {DRC-2022-005246)
a. 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 of the Division (Director) reserves
the right to reevaluate potential "in-service status" of the ESRF.
EnergySolutions submitted a Request for Approval to Construct an Evaporation Pond
(CD-2024-080) on April 10, 2024.
1 Hansen, D.J. "Request for Information (RFI) for the East Side Rotary Facility As-Built Report
Radioactive Material License (RML) UT 2300249" (DRC-2024-005246) Letter from the Division of
Waste Management and Radiation Control to Jonathan Anderson ofEnergySolutions, April 17, 2024.
299 South Main Street , Suite 1700 • Salt Lake City, Utah 84111
[phone] • Fax: (80 I) 880-2879 • www.energysolutions.com
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ENERGY SOLUTIONS Mr. Doug Hansen
April 29, 2024
CD-2023-093
Page 2 of 5
b. 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.
EnergySolutions acknowledges an incoming letter from the Division.
REQUEST FROM CD-2023-196 (DRC-2023-005246)
1. Exhibit 1: East Side Rotary Facility Groundwater Well Monitoring
a. 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 Defmitions states, "Facility
means 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 defmed in R317-6-1.
EnergySolutions does not dispute the ESRF is a facility as defined by Utah
Administrative Code (U AC) R317-6-1. The intention of the discussion is to make clear
that substantial information exists regarding the hydrogeology, hydrostratigraphy, and
groundwater quality of the ESRF environment, and that monitoring, and BAT
requirements are addressed within the regulatory scope of GWQDP No. UGW450005.
b. Proposed Monitoring Well Locations
i. 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 U.S. EPA Unified Guidance,
"lntrawell background measurements should be selected from the
available historical samples at each compliance well and should
include only those observations thought to be uncontaminated."
(U.S. EPA pages 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.
Energy Solutions considers selection of the monitoring approach, i.e., intrawell vs.
interwell to be premature until groundwater analytical data are collected and evaluated.
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ENERGY SOLUTIONS Mr. Doug Hansen
April 29 , 2024
CD-2023-093
Page 3 of 5
As the primary GWQDP monitoring constituents are radiological , hydrocarbon
contamination should not be used to as evidence of radiological contamination to assume
an interwell approach is necessary. Given the locations of an upgradient monitoring well
and downgradient wells in the vicinity of the ESRF , the relationship of"background"
data from an upgradient well to data from downgradient wells is unpredictable.
Therefore, EnergySolutions proposes to collect and evaluate four (4) quarters of
groundwater monitoring data prior to proposing a monitoring approach.
1. Please update the proposed Monitoring Well locations to
include at least one upgradient well and two downgradient
wells. As per 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.
Figure 1 is the revised well location map that includes two down gradient wells (GW-155
& GW-156) and one upgradient well (GW-157).
ii. Please propose a timeline for the installation of the Compliance
Monitoring Wells.
EnergySolutions is actively seeking to secure well installation services and expects to
start drilling in mid-July. Energy Solutions will notify the Division of an installation
timeline prior to starting the drilling project. It is estimated that the well installation and
development time will be about one week.
iii. 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.
Energy Solutions acknowledges the use of the proposed wells to not be utilized for the
hydrocarbon investigation without prior approval from the Director.
c. Sampling and Analytical Program
i. A suite of analytes including VOCs, lle.(2) analytes, Metals,
PCBs, and Radioisotopes, in addition to the Field and Laboratory
parameters as outlined in Exhibit 1: 5. Sampling and Analytical
Program shall be conducted for eight samples due to potential
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ENERGYSOLUTIONS Mr. Doug Hansen
April 29, 2024
CD-2023-093
Page 4 of5
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.
UAC R317-6.10B states:
Background water quality contaminant concentrations may be determined from
existing information or from data collected by the permit applicant. Existing
information shall be used, if the permit applicant demonstrates that the quality of
the information and its means of collection are adequate to determine background
water quality. If existing information is not adequate to determine background
water quality, the permit applicant shall submit a plan to determine background
water quality to the Director for approval prior to data collection .
The Director has not provided technical justification for a requirement for eight
background samples. UACR317-6.1 OB does not establish a minimum number of samples
required to determine background water quality. Given the extensive background
groundwater quality dataset collected and evaluated to date from the Clive Facility
shallow water bearing unit, in accordance with GWQDP UGW450005 Parts I.1.1.3 and
I.1.I.4, Energy Solutions proposes to collect four quarters of groundwater samples from
each well to refine and establish the background water quality dataset for these wells.
As discussed in Exhibit 1, the operational monitoring parameters are those required by
GWQDP UGW450005 for the waste managed at the ESRF (GWQDP UGW450005 Part
LC.I). In addition to the monitoring parameters required by GWQDP UGW450005, for
the four baseline samples Energy Solutions will include:
• VOCs (GWQDP UGW450005 Table B.4-lb LARW, Class A, 1 le.(2), and
Evaporative Pond List; plus BTEXN),
• SVOCs (GWQDP UGW450005 Table B.4-lb 1 le.(2) List),
• Pesticides (GWQDP UGW450005 Table B.4-lb 1 le.(2) List),
• Metals (GWQDP UGW450005 Table B.4-lb LARW, Class A, 1 le.(2), and
Evaporative Pond List; including Arsenic and Molybdenum), and
• PCBs (seven individual Aroclors reported by US EPA method SW-846 8082)
2. 4.0 Alarm Testing at Manhole MH-lA Leak Detection System
a. EnergySolutions may 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.
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ENERGY SOLUTIONS Mr. Doug Hansen
April 29, 2024
CD-2023-093
Page 5 of 5
The Initial Pressure Testing of Manhole MH-lA Leak Detections System report is found
in appendix B.
3. Attachment H: Sealing of Rail/RailSeal at Facility Entrances
a. 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.
In appendix A drawing 2 l l 5-S43 l (1) shows Energy Solutions' proposed corrective
engineering controls with the addition of a threshold on the concrete surfaces at the rail
doorways and a collection trench drain or trough placed just outside each rail door as
illustrated in the drawing.
Please contact me at [phone] with any questions regarding these responses.
Jon Anderson
Environmental Compliance Manager
cc: Charles Bishop (DWMRC)
Brandon Davis (DWMRC)
Bailey Anderson (DWMRC)
enclosure
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 th ose 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.
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ENERGYSOLUTIONS
APPENDIX A
DRAWINGS
C
B
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5 4 3
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PVC PIPE O 0.14:1:
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SI.OPE
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0 0.14,: SI.OPE L
r---=~' '-·-·-•·-
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-_FLEL=4252.65 __
j_,--== /;--=-~-~ lf 4"f PERF, PVC Pl~ -,_::
k ~, 11 " r FLEL = 4252.57
24.2 lf 4"f PERF. PVC
PIPE O 0.14,: SI.OPE I ----29.2 lf 4"f PERF. PVC PIPE
• ___ 0 0.14:1: SUPE ' -
I c ~-~/FL~~~252.~,-~. --;_,_
~ ......, . 19.7 lf 4•. f PERf. PVC ~~ • )',l _ , r _:. :....\:-_ Pl'!_ ~
1
0.14:1: st.OPE =--~ -•• -
.J.. :;::.--...,-=· • ~ -:7 1/ FL EL = 4252.88
.L __; "' ~ ~::: ----__ -,., ,,... '"'"'/ ~ • " ••• Pl< Pl'["·"'-"' '(y" -~ -1 GABIOO BASKET WAil 4 10'X4' 1• MINUS CRUSHED ::.._ -I • I I, 1 \/ -. -_ W/ GE01EXTIL£ FABRIC _ --_ -ROO( TO T/GRADE Yl11H -..:. _ ~ 4 f PERF. PVC PIPE, BEGIN SOOl PIPE
1 /-/ c • --._ SEE DETAIL 00 lHIS , -_ _ CLAY BEDDING r ., ,
r---,,,i ---_r; 1 SHEET 1 _ SEE DETAIL OO lHIS SHEET ' • BUILDING SUMP T/COOC EL = 4251.50
~.' j ,~ 1
.1..1 (SEE MECHANICAL DRAYl1NGS Fc:1l PUMP
,. D 1 ~ D ill -. 1 DETAILS 00 PIPING)
'( \ Ir'' -'_ . --, --~
~ -r -FL EL= 4252.54 -'-'"= ~ -L ½0 8.1 lf 4•· PERF. PVC PIPE I
FL EL = 4252.53
12.5 lf 4"f PERF. PVC PIPE
FL EL = 4252.TT \• ~.
SEE DETAIL 00 lHIS :... ::::::----::_ -10'X4' 1· MINUS CRUSHED : --\ REMEDIATED AND CLOSED. & 1 / I I I ) 1 I I 'II)/ 10'X4 1 MINUS CRUSHED
/
~ -;---:--~~ B;,;ETw-:i.Y --~ __ --~ --.::: \ii\ \l Nairn EAST .DRY m 111 111 • Wl 1 .
W/ GE01EXTIL£ FABRIC ---10lf FRENCH DRAIN W/ I \ N 14,965.644 E 14,484.592 1 I I I ,,, r--10lf .~CH DRAIN W/
\
---_ SHEET/.._~_ ROCK TO T/raADE Yl11H ~ _ I I I I I I I 1 /, / , 1 I , /ROCK TOT/GRADE Yl11H -
7 -a.A Y BEDOING -NC1!1H 'llfST DRY YIEll SOUlH '11£ST DRY YIEll CLAY BEDlllNG _
INSTAl.l Dl'tffiSIOO BERM AT TOP OF SI.OPE _,--.A_ SEE DETAIL 00 lHIS SHEET N 14,961.124 E 14,442.531 N l4,B1 6_618 E 14,#1.2n -_. .,.-'SEE DETAIL 00 _!HS Sl£E1: 7; •
(SEE DETAIL 2 lHIS SHEET) "'LIMIT OF GRADING (TYP.) '\ \"' ·, --.> ~EDIA~ AND CL~~ REMEDIATED ,oo CLOSED~ _;: ,,-/. 1 /_; /;
-./ "-> ----.JL----/ ~ f' I l(t./ '-\ "-'--~ L J 'I, Jt-_ --,.--' /~ z;. . ' 1
"---/ ~ -_-~~---• , ___ J.C../}_------:...-~/' \ ( /
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REFER TO GEOTECH REPORT & GENERAL CIVIL NOTES DWGS 1959-C100 & C101. ! '------..... '-----z
NOOllO'.fN II:01EXTIL£ FlL TER FABRIC
1' MINUS
CRUSHED ROO<
• PERFC1!A 1ED PVC
PIPE (HOLES
DO~WARDS)
SEE PLAN Fc:1l
EIIVATlOOS
SUMP T/CetlC
EL = 4251.50'
,,,,--FINISHED GRADE FINISHED GRADE --......,
/ \
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// 6" DEEP ROCK ARMC1!ED SURFACE, BY O'ffR t ~: ,r \
ft!..... ,/ (TYP.) SOF8 I \A-lj ~ ~ __ ,,.,,-n<Tlll fl ~ ....d<:P"' .. --HHY m Ill/IN \
WATER SEAL
DRAIN BOARD
NOOllO'.fN GE01EXTILE FlL TER FABRIC
1' MINUS
CRUSHED ROO<
FLUSH Yl11H ,
1" MINUS CRUSHED ROO<, MIN . 4"
UNDER PIPE AND POURED TO
T /GRADE , MIN . 4' BACK FROM
WAil (TYP.)
,/(j.~
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GRADE
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TYP. LOW POINT OF FLOORlT/TRENCH GRATING EL4282'-10'
ACTUAL INVERTS OF TRENC ES VAAY. SEE TRENCH DRAIN
PLAN DRAWING 19$-$438 F R DETAILS
' _i ___________ l __________ _ _________ J ___________ J ____ _
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17-3' AT SOl/TH BAY
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THRESHOLD SEAi. STRIP PLACED INSIDE
RAIL ROllUP DOOR AT EACH SIDE OF
RAILS AND IN BETWEEN RAILS AND AT
EACH RAIL DOORWAY.
16'-V AT NORTH BAY
-64 WIDE X 5" DEEP TRENCH DRAIN WITH SAFETY GRATE PLACED
ADJACENT TO THE BUIL0ING WALL AT RAILROAD TIE HE IGHT AND
ATC~lnf'\c DAIi CCAI CTnt"ATNJl"VVJTA~WATS:'C>n.u:cn:~nu
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ENERGYSOLUTIONS
APPENDIXB
Initial Pressure Testing of Manhole MH-lA
Leak Detections System Report
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===============ENERGYSOLUTIONS ===============
INITIAL PRESSURE TESTING OF MANHOLE MH-lA LEAK DETECTION SYSTEM
BACKGROUND:
The leak detection system of Manhole MH-lA, was described in Section 5.0 and shown in
Drawing 2115-S443(1) of Attachment D of the submitted April 2023 (CD-2023-091) As-Built
report and in Section 4.0 of the Addendum submitted in October 2023 (CD-2023-196).
Briefly, the leak detection system of Manhole MH-lA is a dual wall drain line, hereafter to be
labeled Line 4B, that consists of a 4" DR 17 HDPE carrier pipe inside of a 6" DR 32.5 HDPE
containment pipe. It runs from new Manhole MH-lA inside the new East Side Rotary Facility
(ESRF) mechanical room to existing Manhole MH-1 where it is then tied into the existing Line 4
which discharges into the 1997 Evaporation Pond. The secondary containment pipe terminates
inside ofboth Manhole MH-lA and MH-1. The termination of the secondary containment is
accomplished by the installation of clamped boots.
This pressure test is to ensure compliance of Line 4B in accordance with Appendix J; BAT
Performance Monitoring Plan of the Ground Water Quality Discharge Permit UGW 450005 as
well as to respond to the RFI question of April 17, 2024, of the Utah Division of Waste
Management and Radiation Control (DWMRC).
TEST PROCEDURE FOR INITIAL TESTING:
• The carrier pipe is capped with a blind flange(s) fitted with an air pressure valve and
pressure gauge.
• The carrier pipe is pressurized to at least 5 psi . The pressure is allowed to stabilize
( approximately 20 minutes) and then the initial pressure and time are recorded.
• The pressure and time are then recorded after a minimum of 4 hours has passed. A
passing test occurs where the pressure drop is less than or equal to 1 psi over the
minimum 4-hour test period.
• If the pressure drops greater than 1 psi , the pipe(s) and fitting(s) are inspected and ifleaks
are identified , they are repaired . The pressure testing is restarted for an additional 4
hours .
• Moisture probes will be removed from their braces and touched to moisture to observe
that they are working and alarming .
OBSERVATIONS:
Pressure testing of Line 4B :
Line 4B was successfully tested on April 18 , 2024, by EnergySolutions and Wollam
Construction. The testing was observed by the Clive Facility Engineer. A temporary blind
flange was added to the upstream side of Line 4B at MH-lA in addition to the temporary blind
flange already installed during construction of the pipe in MH-1 in 2022 . The initial testing
began on April 18 , 2024 , at 10 :00 am and the pipe was pressurized to 6 psi. The pipe was
observed to hold pressure at 6 psi at 11 : 18 am. Following the 4-hour testing period the pressure
Page 1 of 3
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--------ENERGYSOLUTIONs --------
gauge was read at 2 :00 pm and again at 2:55 pm on April 18, 2024, by the Clive Facility
Engineer and found to still hold pressure at 6 psi. The pressure was then released.
The DWMRC was contacted to observe the testing and declined as well as stated in the RFI of
April 17, 2024, that testing could be conducted without the presence of the Division so long as it
was conducted in accordance with the testing of the East Side Drainage System pressure test and
done under the direction of a Professional Engineer.
Initial readings at 10:00 am and the verification at 11: 18 am.
Final readings at 2:00 pm and 2 :55 pm before the test was completed.
Page 2 of3
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--------ENERGY SOLUTIONS ================
Moisture Probe in Manhole MH-lA:
The moisture probe in Manhole MH-lA was tested on August 15, 2023, in the presence of the
Clive Facility Engineer by removing it from its brace and touching the probe to moisture
activating the alarm as designed. The probes were then reinstalled and readied for service. The
Line 4B was and continues to be flanged off from Line 4 in Manhole MH-1 so that no liquids
from Manhole MH-1 could enter Line 4B inside the ESRF.
The blind flange(s) are still in place and will be removed upon approval to operate the ESRF.
CONCLUSIONS:
The testing performed on the leak detection system of Manhole MH-lA of the East Side Rotary
Facility on April 18, 2024, demonstrated that new Line 4B and its moisture probe function as
designed and the carrier pipe of 4B does not leak. Therefore, it is concluded that the system is
functioning as required and is reliable for service.
Garrett Q. Dutson, PE
Clive Facility Engineer, EnergySolutions
Page 3 of3
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ENERGYSOLUTIONS
FIGURE 1
Well Locations