DRC-2025-000284

CLIVE SITE
LETTER OF TRANSMITTAL DATE: 1/24/2025 ATTN: LLRW
CC; Treesa Parker Karen Kirkwood RE: Transmittal 2025-003
Description of Documents Transmitted Qty
See attached for update to LLRW Disposal. CL-LD-PR-704 Rev 4 Stormwater Management 1
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Please replace your current procedure revisions with the documents within this Transmittal. You are not required to sign any documents to verify receipt of this distribution. However, you should make every effort to ensure that your copy of the License is current. FROM: EnergySolutions
Document Control Clive Facility
Electronic documents, once printed, are uncontrolled and may become outdated. Refer to the Intranet or the Document Control authority for the correct revision.
CL-LD-PR-704

Stormwater Management
Revision 4

Authored By:
Roger Ekins, Lead, Disposal Cell Date
Reviewed By:
Curtis Kirk, Quality Assurance Director Date
Approved By
Thomas A. Brown, Radiation Safety Officer Date
Approved By
Brennon Dick, Operations Manager

Date

Non-Proprietary New
Proprietary Title Change
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Roger Ekins Digitally signed by Roger Ekins
Date: 2025.01.21 07:55:02 -07'00'
Digitally signed by Curtis KirkDN: C=US, OU=EnergySolutions, O=Quality Assurance, CN=Curtis Kirk,
E=[e-mail]: I am the author of this document
Location: your signing location hereDate: 2025-01-21 09:18:19
Foxit PhantomPDF Version: 9.7.5
Curtis Kirk
Digitally signed by Thomas Brown
DN: OU=Health Physics, O="EnergySolutions, LLC", CN=Thomas Brown, E=[e-mail]
Reason: I am approving this documentLocation: Clive
Date: 2025-01-21 09:21:25
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Thomas Brown
Brennon Dick Digitally signed by Brennon Dick
Date: 2025.01.24 06:56:55 -07'00'
Adobe Acrobat version: 2024.005.20320
CL-LD-PR-704 Stormwater Management Revision 4

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Table of Contents

1 PURPOSE AND SCOPE ........................................................................................................ 3
1.1 Purpose ............................................................................................................................ 3
1.2 Scope ............................................................................................................................... 3
2 REFERENCES ....................................................................................................................... 3
3 GENERAL .............................................................................................................................. 3
3.1 Definitions....................................................................................................................... 3
3.2 Responsibilities ............................................................................................................... 4
3.3 Precautions and Limitations ............................................................................................ 4
3.4 Document Control and Records ...................................................................................... 4
4 REQUIREMENTS AND GUIDANCE .................................................................................. 5
5 ATTACHMENTS AND FORMS........................................................................................... 8

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1 PURPOSE AND SCOPE
1.1 Purpose
To establish a consistent method of identifying, tracking, and managing contact
storm water accumulation, collection, and disposal activities inside the LLRW Restricted Area and inside the boundary of the active portion of the Class A West and 11e.(2) embankments in accordance with the Ground Water Quality Discharge Permit (GWQDP) as amended.
1.2 Scope
This document applies to inspectors and facility personnel who perform inspection, collection, and disposal of storm water accumulations inside the LLRW controlled area including 11e.(2).
2 REFERENCES
2.1 UGW450005, Utah Ground Water Quality Discharge Permit (GWQDP), as
amended.
2.2 Appendix J: BAT Performance Monitoring Plan
2.3 LLRW/11e.(2) Facility Daily Inspection Form (GWQDP, Appendix J, Form 1a).
3 GENERAL
3.1 Definitions
3.1.1 Pumpable Accumulation Point – An area where storm water gathers resulting in above ground puddles or ponds greater than 6 inches in depth or capable of being removed by standard pumping equipment.
3.1.2 Non-pumpable Accumulation Point – An area where storm water gathers
resulting in above ground puddles or ponds less than 6 inches in depth not capable of being removed by standard pumping equipment.
3.1.3 Temporary Transfer Pump – A pump used to move accumulated water to a temporary storage tank or mobile tank mounted equipment. All
piping/tubing used to transfer contact storm water shall remain on
approved embankment liner or shall be free of leaks and located over containment at connection points.
3.1.4 Temporary Storage Tank – A portable tank (Frac tank, Baker Tank, or similar tank) placed over cell liner and isolated from the cell liner with
soil, sand, clay or other acceptable fill material. Ponded water may be
pumped into a temporary storage tank using a temporary transfer pump and pumped out using a mobile water tank.
3.1.5 Anticipated Accumulation Point – An area where stormwater typically accumulates during storm events. These areas include but are not limited
to the following: bermed areas near temporary cover, low spots, or areas
identified during previous storm events.
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3.1.6 Restricted Area - The area within the controlled area that requires control of access and occupancy for purposes of protection against radiation and
other hazardous materials.
3.1.7 DOE Vitro Ditch Line – The area bordering EnergySolutions Restricted, Contaminated Area property and the Department of Energy’s VITRO Disposal Embankment identified by a dirt berm and 6’ fence. The ditch line is used to prevent stormwater from flowing into the VITRO area from
EnergySolutions property. In most cases, the ditch line is between a small
soil berm and a facility haul road.
Note: The small soil berm along the DOE Ditch Line is not a site run-on or run-off berm and is not subject to the
design and maintenance requirements applicable to run-on and run-off berms.
3.2 Responsibilities
3.2.1 Manager, Waste Disposal Operations has overall responsibility for
ensuring this procedure is performed in accordance with requirements.
3.2.2 Lead, Disposal Cell or designee is responsible for ensuring this procedure is followed when storm water accumulation occurs.
3.2.3 The BAT Inspector is responsible for conducting a daily compliance
inspection of the site in accordance with GWQDP. Stormwater
accumulation shall be documented on the LLRW/11e.(2) Facility Daily Inspection Form (reference 2.3).
3.2.4 Water Management Facility Operators are responsible for removing stormwater by using temporary transfer pumps with temporary storage
tanks, mobile collection tanks, or a combination of both; and for tracking
storm water collection efforts on CL-LD-PR-704-F1 (Stormwater Accumulation Collection Form), attachment 5.1.
3.3 Precautions and Limitations
3.3.1 A three-point contact shall be maintained while climbing on equipment.
3.3.2 Operators and Inspectors may be working in extreme weather conditions;
Personnel shall dress appropriately.
3.4 Document Control and Records
3.4.1 Completed CL-LD-PR-704-F1, Water Collection Worksheets shall be forwarded to the Lead, Disposal Operations for review daily when
stormwater accumulation activities occur.
3.4.2 The Lead, Disposal Operations shall transmit the Water Collection Worksheets to Document Control on a monthly basis.
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3.4.3 Stormwater collection worksheets will be used to demonstrate compliance with GWQDP requirements.
4 REQUIREMENTS AND GUIDANCE
4.1 Compliance
4.1.1 All personnel performing management of stormwater shall be trained to this procedure.
4.1.2 Water Management Personnel shall ensure temporary transfer pumps,
temporary storage tanks, and other water management equipment are not
operated directly on the surface of finished clay liner or on the surface of temporary cover within an approved embankment. Prior to operating equipment within an approved embankment, a minimum one foot of waste or other fill material shall be placed over the debris free zone.
4.1.3 Up to a maximum of three (3) temporary storage tanks may be used at any
one cell to assist in managing stormwater.
4.1.4 Stormwater collection shall be performed in accordance with priorities established in condition 1.E.7.c of GWQDP and in accordance with section 4.21, Stormwater Management of GWQDP Appendix J: BAT
Performance Monitoring Plan.
Note: Non-pumpable accumulations of stormwater are not required to be managed.
4.1.5 Collected stormwater may be discharged at any approved evaporation
pond or for engineering and dust control within the Class A West
Embankment.
4.1.6 The DOE Vitro Ditch Line, upon inspection, should be free of debris, excess soil, and sediment build-up to allow for adequate containment of stormwater.
4.2 Procedure
4.2.1 On a daily basis (whenever the LLRW/11e.(2) Facility Daily Inspection is performed) the BAT inspector shall inspect the site in accordance with GWQDP requirements. Upon discovery of Stormwater Accumulation, the BAT Inspector (or designee) shall perform the following steps:
4.2.1.1 Notify the Lead, Disposal Cell and note the time of
discovery on the LLRW/11e.(2) Facility Daily Inspection Form (reference 2.3).
4.2.1.2 Inform Water Management personnel.
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4.2.1.3 Receive verbal confirmation from Water Management Personnel that stormwater collection will begin
immediately within 24-hours of notification in accordance
with permit requirements and note the confirmation on the LLRW/11e.(2) Facility Daily Inspection Form (reference 2.3).
4.2.2 The Lead, Disposal Cell shall adjust work schedules and ensure
availability of resources to ensure timely response to stormwater
accumulation in accordance with I.E.7.a of the GWQDP (reference 2.1).
4.2.3 The Water Management Facility Operators shall use one, or any combination of the following equipment to remove collected stormwater from the disposal embankments.
• Temporary Transfer Pumps.
• Mobile water trucks may be used to either directly remove water from the accumulation point OR from the temporary storage tanks.
Transfer from the temporary storage tanks to the mobile water
trucks does not need to occur over liner. However, the operator must remain present during the transfer operation.
• Temporary Storage Tanks. The Water Management Facility Operators shall ensure that temporary storage tanks are not
overfilled during transfer to the storage tanks or transfer from the storage tanks to the mobile water trucks.
4.2.4 Temporary Transfer Pumps and associated tubing/piping, when used to manage contact stormwater, shall be free of leaks and stationed over embankment liner or other containment device and connection points in
accordance with section 4.1.2 of this procedure.
4.2.5 Temporary Transfer Pumps can be used to transfer water from accumulation points to mobile equipment, temporary storage tanks, or directly to evaporation ponds. Temporary Transfer Pumps can also be used to transfer water from hard-to-reach accumulation points to areas
more accessible to mobile equipment.
Note: Contact stormwater shall only be transferred to mobile equipment, storage tanks, or facilities approved for contact water management.
4.2.6 Mobile Water Trucks used for management of contact stormwater
accumulation shall be free from leaks or other defects that may result in a spill outside of containment.
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4.2.7 Mobile Water Trucks can be used to collect and transfer stormwater accumulations to approved disposal locations including 1995, 1997, 2000,
Northwest Corner, and Mixed Waste Evaporation Ponds; Rotary Dump
Facility pit; and minimal dust suppression/engineering controls at the Class A West Disposal Embankment; and for dust suppression activities at the Shredder Facility in accordance with I.E.7.b. of GWQDP (reference 2.1)
Note: BAT Requirements shall be maintained during transfer at the Rotary Dump Facility (i.e. free drainage).
4.2.8 Temporary Storage Tanks may be used to assist with efficient and timely management of contact stormwater accumulation provided that tanks are free from leaks, used inside the active portion of a disposal embankment,
and are not placed in direct contact with the embankment liner in
accordance with section 4.1.2 of this procedure.
4.2.9 Water Management Facility Operators shall ensure that the temporary storage tanks are emptied on a continuous basis to ensure additional water may be transferred to the tanks as needed.
4.3 Documentation Instructions
4.3.1 Upon discovery of stormwater accumulation, the BAT Inspector shall ensure CL-LD-PR-704-F1, Water Collection Worksheet is initiated by water management personnel.
4.3.2 The form shall include the following information:
• Time when stormwater removal activities were initiated at each location (i.e. embankments, haul road, Vitro Ditch, etc).
• Type of stormwater (i.e. Contact, Non-Contact) accumulation
throughout the LLRW Restricted Area.
• Time when stormwater removal is complete at each location.
• First and Last names of all personnel managing stormwater.
• Unique identity of location where stormwater is removed.
• Equipment used to manage contact and non-contact stormwater
• Volumes of stormwater removed from each location.
• Location of stormwater disposal.
• First and last names of all personnel involved in stormwater removal activities.
• Equipment used for stormwater removal.
• Comments as applicable
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4.3.3 The form shall be signed by the equipment operator and submitted to the Lead, Disposal Cell for review.
5 ATTACHMENTS AND FORMS
5.1 Example of CL-LD-PR-704 F1 Stormwater Collection Load Sheet
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5.1 Example of CL-LD-PR-704 F1 Stormwater Collection Load Sheet

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