DRC-2025-000667

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 [phone] ▪ Fax: [phone] ▪ www.energysolutions.com
February 20, 2025 CD-2025-035
Mr. Doug Hansen, Director Division of Waste Management and Radiation Control P.O. Box 144880 Salt Lake City, UT 84114-4880
Re: Groundwater Quality Discharge Permit Number UGW450005 (GWQDP): Groundwater Monitoring Well P3-95 SWC Tracer Dye Test Plan Dear Mr. Hansen:
The letter provides EnergySolutions’ plan (Plan) to conduct a tracer dye test to more definitively delineate the source and location of infiltration presumed to be the transport mechanism for uranium concentrations exceeding groundwater protection levels (GWPLs) in groundwater at well P3-95 SWC. The Plan is provided in accordance with a Division of Waste Management and Radiation Control (DWMRC) letter dated August
23, 2024 (DRC-2024-006236) requesting the Plan include: tentative dates, plans for application, plans for observation, and a copy of the BrightDyes® manufacturer instructions.
EnergySolutions acknowledged receipt of DRC-2024-006236 on September 11, 2024 (CD-2024-189). This Plan provides additional details for a tracer dye test proposed in submittal
CD-2023-204 (October 9, 2023), which was approved by DWMRC on March 15, 2024
(DRC-2024-004377). Submittal CD-2023-204 includes background information regarding EnergySolutions decision to perform a tracer test as the next step of the investigation.
In summary, the tracer dye test consists of the following:
• Physically divide, to the extent possible, the north-south ditch on the west side of the former LARW haul road into three segments.
• Following a suitable precipitation event, apply visual tracer dye to each of the
three ditch segments, each dye will be a different color.
• Monitor the surface water in the ditch, and remove additional surface water from subsequent precipitation events, as needed, to reduce mixing between segments.
• Sample well P3-95 SWC weekly to visually determine if dye is present in
groundwater, monitor field parameters, and collect a sample for possible total
Mr. Doug Hansen February 20, 2025 CD-2025-035 Page 2 of 5 uranium analysis. Monthly out-of-compliance (OOC) sampling will continue
throughout the test.
• Based on field observations, determine when to conclude the test.
• If total and/or isotopic uranium concentrations in well P3-95 SWC groundwater
exceed GWPLs at the conclusion of the test, based on results of tracer test determine the timing of groundwater extraction. Additional information and a tentative schedule are provided below. Pre-Test Preparation
• Procure tracer dye: Blue, red, and fluorescent yellow/green dyes have been selected based on their color contrasts and technical properties provided in the attached Bright Dyes® Technical Data Bulletins available at Bright Dyes® | Leak
Tracing Detection | Kingscote Chemicals. Ditch segments will be approximately 350 feet in length, equating to approximately 12,000 gallons of water in each segment. Generally, one pint of liquid dye is sufficient to provide strong visual evidence of breakthrough at well P3-95 SWC according to the information provided on Bright Dyes®’s website.
• Construct temporary dikes: Coordinate with Clive Facility Operations for the construction of temporary dikes between segments. The dikes will extend onto the haul road to divide the ditch into three segments:
o North segment - ditch segment north of approximately the north end of the
1995 Evaporation Pond.
o Central segment – ditch segment approximately between the north end of the 1995 Pond and center of the Containerized Waste Storage Pad.
o South segment – ditch segment south of approximately the center of the Containerized Waste Storage Pad.
The material used to construct the temporary dikes will be clean native material.
It is anticipated the dykes will extend 3 to 5 feet onto the haul road and will be the height of ditch berms – approximately 2 feet.
• Temporarily modify BAT stormwater collection: Coordinate with Operations to
modify collection of storm water from the north-south ditch. Currently, water in
the ditch is temporarily managed as Priority 1 in accordance with DWMRC approval (DRC-2023-071888; September 22, 2023). Enough water must be present to conduct the tracer test; however, water extending beyond the dikes onto the road should be removed to keep the segments isolated and prevent the different tracer dye colors from mixing. During the test, stormwater management
may be required to maintain isolation of the segments to the extent possible.
Mr. Doug Hansen February 20, 2025 CD-2025-035 Page 3 of 5
• Meteorological considerations: Ideally, a precipitation event would fill the ditch segments without overflowing the dikes. Equally important, significant precipitation events should not be forecasted to occur immediately following application of the dye.
Tracer Dye Test
• Application of Dye: Following a suitable precipitation event, dye will be added to each segment of the ditch. The dye will be applied in small volumes over the full length of the segment as opposed to applied all in one location. The dye will
subsequently disperse in the surface water.
• Monitoring and Sampling: As discussed in submittal CD-2023-204, groundwater extraction will not occur during the tracer test. This will allow natural groundwater flow conditions to exist during the test and will facilitate visual
detection of dye during sampling. Groundwater samples will be collected weekly during the duration of the test. The samples will be collected for the presence of dye, field parameters will be recorded, and a preserved 4-liter sample will be collected. Each sample will be documented on a Groundwater Sampling Sheet (GWQDP, Figure B.4-2). Monthly out-of-compliance (OOC) samples will
continue to be collected from well P3-95 SWC in accordance with GWQDP Part I.G.3. A monthly OOC sample will substitute for a weekly sample during the week it is collected.
• Duration of Tracer Test: Based on previous observation and sampling of well
P3-95 SWC, the timing of the arrival of tracer dye at the well is uncertain but
anticipated to be on the order of several weeks to two months. Although duration cannot be determined at this time, EnergySolutions will continue weekly observation and sampling for a minimum of three months. Continued monthly OOC sampling beyond three months will provide a safeguard if dye breakthrough
is slower than anticipated. The EnergySolutions Groundwater and Environmental
Program Manager will decide when to end the tracer test. DWMRC will be notified a minimum of 14 days before the test is ended.
Post-Test Activities
• Groundwater Extraction: If tracer dye breakthrough has been observed and monthly OOC sample results indicate uranium concentration exceedances are present, extraction of groundwater at well P3-95 SWC will begin within 14 days of the end of the test in accordance with submittal GW-2023-204. If tracer dye
breakthrough has not been observed and/or uranium concentrations are below
corresponding GWPLs, groundwater extraction will not be necessary.
• Weekly Groundwater Sample Analysis: Groundwater samples for isotopic uranium analysis have a six-month holding time (GWQDP Table B.4-2). Based
Mr. Doug Hansen February 20, 2025 CD-2025-035Page 4 of 5
on field observations, the EnergySolutions Groundwater and Environmental
Program Manager will select weekly samples to be shipped for isotopic uranium analysis. Any weekly samples not selected for analysis will remain in the custody of the sampling team until analytical results for the weekly and monthly OOC samples have been received and reviewed.
•Letter Report: A summary report will be prepared and submitted to DWMRC nomore than 30 days following completion of the tracer dye test and receipt of allassociated analytical data. This report will provide findings of the test and willpropose addition activities, as needed, to return well P3-95 SWC to in-compliance
status.
Schedule
Table 1 provides the schedule for the tracer dye test activities described above. Dates and
durations are estimated largely due to the unpredictable nature of precipitation events.
Please contact me at 801-649-2060 with any questions regarding this submittal.
Sincerely,
Mathew R. Schon
Manager, Groundwater and Environmental Program
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 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.
Mr. Doug Hansen February 20, 2025 CD-2025-035 Page 5 of 5 Table 1 P3-95 SWC Tracer Dye Test Estimated Schedule
Activity Approximate
Date a
Approximate
Duration a Comments
Pre-Test Preparation
Procure tracer dye 2/19/2025 NA In progress
Construct temporary dikes 3/10 to 3/14/2025 2 Days Includes notification to Clive Operations to temporarily modify stormwater collection in N-S ditch
Tracer Dye Test
Begin test 3/17 to 3/21/2025 1 Day Application of dye to surface water
Monitoring and sampling 3/24 to 6/13/2025 12 Weeks
End test 6/13/2025 NA
Post-Test Activities
Begin groundwater extraction 6/16 to 6/27/2025 2 Days See text for details
Ship selected weekly samples for Iso-U analysis 6/16 to 6/20/2025 1 Day
Letter report submittal 8/27/2025 NA Assume 5 weeks for receipt of data
a Dates are provided as an estimate of overall project duration and relative timing of events. These dates are approximate and partly dependent on the timing of precipitation events and analytical reporting (i.e., variables EnergySolutions cannot control). For this reason, EnergySolutions requests these dates do not become regulatory deadlines.
Kingscote Chemicals, 3334 S. Tech Blvd., Miamisburg, Ohio 45324
Telephone: [phone] Fax [phone] Web: www.brightdyes.com
Division of Kingscote Chemicals ®

TECHNICAL DATA BULLETIN

Bright Dyes Standard Blue products are specially formulated versions of the dye Acid Blue 9. This
dye is used for visual detection only and cannot be seen under ultraviolet light or detected by
fluorometry. However, when used visually, its color is often thought to be more acceptable to
public view than the fluorescing red or yellow green Bright Dyes products. In this respect, it is
sometimes used in fountains, ponds and streams for decorative effect. Visually, the dye appears as
aqua to royal blue depending on its concentration and activity of the water.

Based on biochemical oxygen demand (BOD) studies, the dye is biodegradable with 77% of the
available oxygen consumed in 7 days. Bright Dyes Standard Blue products have been certified by
NSF International to the ANSI/NSF Standard 60 for use in drinking water at specific levels. As
always the suitability of these products for any specific application should be evaluated by a
qualified hydrologist or other industry professional. Store product out of sunlight, in a cool and dry
location. Shelf life is 4 years from date of purchase.

General Properties Tablets Liquids Powders
Detectability of active ingredient 1 Visual <100 ppb Visual <100 ppb Visual <100 ppb
Maximum absorbance wavelength 2 630 nm 630 nm 630 nm
Appearance Lt. Blue speckled
1.6cm diameter
Clear, dark blue
aqueous solution
Dark blue fine
powder
NSF, max use levels in potable water 2000 ppb 1200 ppb 100 ppb
Weight 1.25 gms + 0.05
Dissolution Time 3 50% < 3 minutes
95% < 6 minutes
50% < 3 minutes
95% < 6 minutes
Specific Gravity 1.04 + 0.03 @ 25 C
Viscosity 4 1.8 cps
pH 5.2 + 1.0 @ 25 C

Coverage of Products One Tablet One Pint Liquid One Pound
Powder
Light Visual 200 gallons 125,000 gallons 1,200,000 gallons
Strong Visual 20 gallons 12,500 gallons 120,000 gallons
Caution: These products may cause irritation and/or staining if allowed to come in contact wit the skin. The use of gloves and goggles is
recommended when handling this product, as with any other dye or chemical.

To our best knowledge the information and recommendations contained herein are accurate and reliable. However, this information and
our recommendations are furnished without warranty, representation, inducement, or license of any kind, including, but not limited to
the implied warranties and fitness for a particular use or purpose. Customers are encouraged to conduct their own tests and to read the
material safety data sheet carefully before using.

1 In deionized water in 100 ml flask. Actual detectability and coverage in the field will vary with specific water conditions.
2 Smaller peak at 405 nm.
3 (One tablet, 1 gram of powder), in flowing deionized water in a 10 gallon tank.
4 Measured on a Brookfield viscometer, Model LV, UL adapter, 60 rpm @ 25 C.
WATER TRACING DYE

STANDARD BLUE PRODUCTS
Kingscote Chemicals, 3334 S. Tech Blvd., Miamisburg, Ohio 45342
Telephone: [phone] Fax: [phone] Web: www.brightdyes.com
Division of Kingscote Chemicals®

TECHNICAL DATA BULLETIN

Bright Dyes Yellow/Green products are specially formulated versions of Xanthene dye, certified by
NSF International to ANSI/NSF Standard 60 for use in drinking water. This dye is the traditional
fluorescent water tracing and leak detection material and has been used for labeling studies from
the beginning of the century. It may be detected visually, by UV light and by appropriate
fluoremetric equipment. Today it is most often used visually. This dye has been used by the
military to mark downed pilots for search and rescue operations over large water bodies. Visually
the dye appears yellow/green, depending on its concentration and under UV light as lime green.

Based on biochemical oxygen demand (BOD) studies, the dye is biodegradable with 65% of the
available oxygen consumed in 7 days. The dye is resistant to absorption on most suspended matter
in fresh and salt water. However, compared to Bright Dyes FWT Red products it is significantly
less resistant to degradation by sunlight and when used in fluoremetry, stands out much less clearly
against background fluorescence. As alwayss the suitability of these products for any specific
application should be evaluated by a qualified hydrologist or other industry professional. Store
product out of sunlight, in a cool and dry location. Shelf life is 4 years from date of purchase.

General Properties Tablets Liquids Powders
Detectability of active ingredient 1 Visual <100 ppb Visual <100 ppb Visual <100 ppb
Maximum absorbance wavelength 2 490/520 nm 490/520 nm 490/520 nm
Appearance Orange convex
1.6cm diameter
Reddish, brown
aqueous solution
Orange fine
powder
NSF (Max use level in potable water) 6.0 ppb 10.0 ppb 1.0 ppb
Weight 1.35 gms + 0.05
Dissolution Time 3 50% < 3 minutes
95% < 6 minutes
50% < 3 minutes
95% < 6 minutes
Specific Gravity 1.05 + 0.05 @ 25 C
Viscosity 4 1.8 cps
pH 8.5 + 0.5 @ 25 C

Coverage of Products One Tablet One Pint Liquid One Pound
Powder
Light Visual 605 gallons 125,000 gallons 1,200,000 gallons
Strong Visual 60 gallons 12,500 gallons 120,000 gallons
Caution: These products may cause irritation and/or staining if allowed to come in contact wit the skin. The use of gloves and goggles is
recommended when handling this product, as with any other dye or chemical.

To our best knowledge the information and recommendations contained herein are accurate and reliable. However, this information and
our recommendations are furnished without warranty, representation, inducement, or license of any kind, including, but not limited to
the implied warranties and fitness for a particular use or purpose. Customers are encouraged to conduct their own tests and to read the
material safety data sheet carefully before using.

1 In deionized water in 100 ml flask. Actual detectability and coverage in the field will vary with specific water conditions.
2 No significant change in fluorescence between 6 and 11 pH.
3 (One tablet, 1 gram of powder), in flowing deionized water in a 10 gallon tank.
4 Measured on a Brookfield viscometer, Model LV, UL adapter, 60 rpm @ 25 C.
WATER TRACING DYE

FLT YELLOW/GREEN PRODUCTS
Kingscote Chemicals, 3334 S. Tech Blvd., Miamisburg, Ohio 45342
Telephone: [phone] Fax: [phone] Web: www.brightdyes.com
Division of Kingscote Chemicals ®

TECHNICAL DATA BULLETIN

Bright Dyes FWT Red liquid products are specially formulated versions of Rhodamine WT dye for
convenient use in water tracing and leak detection studies. This bright, fluorescent red dye is
certified by NSF International to ANSI/NSF Standard 60 for use in drinking water. It may be
detected visually, by ultraviolet light and by appropriate fluoremetric equipment. Today it is most
often used visually. Visually the dye appears bright pink to red, depending on its concentration and
under ultraviolet light as bright orange.

The dye is resistant to absorption on most suspended matter in fresh and salt water. However,
compared to Bright Dyes FLT Yellow/Green products it is significantly more resistant to
degradation by sunlight and when used in fluoremetry, stands out much more clearly against
background fluorescence. As always the suitability of these products for any specific application
should be evaluated by a qualified hydrologist or other industry professional.

General Properties Tablets Liquids (50) Powders
Detectability of active ingredient 1 Visual <100 ppb Visual <100 ppb Visual <100 ppb
Maximum absorbance wavelength 2 550/588 nm 550/588 nm 550/588 nm
Appearance Dark red convex
1.6cm diameter
Clear dark red
aqueous solution
Dark red fine
powder
NSF (Max use level in potable water) 0.3 ppb 0.4 ppb 0.1 ppb
Weight 1.35 gms + 0.05
Dissolution Time 3 50% < 3 minutes
95% < 6 minutes
50% < 3 minutes
95% < 6 minutes
Specific Gravity 1.03 + 0.05 @ 25 C
Viscosity 4 1.3 cps
pH 8.7 + 0.5 @ 25 C

Coverage of Products One Tablet One Pint Liquid

One Pound
Powder
Light Visual 604 gallons 62,500 gallons 600,000 gallons
Strong Visual 60 gallons 6,250 gallons 60,700 gallons
Caution: These products may cause irritation and/or staining if allowed to come in contact wit the skin. The use of gloves and goggles is
recommended when handling this product, as with any other dye or chemical.

To our best knowledge the information and recommendations contained herein are accurate and reliable. However, this information and
our recommendations are furnished without warranty, representation, inducement, or license of any kind, including, but not limited to
the implied warranties and fitness for a particular use or purpose. Customers are encouraged to conduct their own tests and to read the
material safety data sheet carefully before using.

1 In deionized water in 100 ml flask. Actual detectability and coverage in the field will vary with specific water conditions.
2 No significant change in fluorescence between 6 and 11 pH.
3 (One tablet, 1 gram of powder), in flowing deionized water in a 10 gallon tank.
4 Measured on a Brookfield viscometer, Model LV, UL adapter, 60 rpm @ 25 C.
WATER TRACING DYE
FWT RED PRODUCTS