DRC-2025-000239

RECEIVED
By Dlvlslon of Waste Managment and Rad/iaflon Coaf,,l at 7 13 am, Jan 22 2025
cD-202s-008
ExrncvSotwnrus
January 16,2025
Mr. Doug Hansen, Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880
Subject: Groundwater Quality Discharge Permit UGW450005: Response to the
Request for Information Related to a Request for Approval to Construct
an Evaporation Pond
Dear Mr. Hansen:
EnergySolutions is pleased to respond to the Request for Informationr issued by the Director of
the Division of Waste Management and Radiation Control concerning the proposed construction
ofa new evaporation pond.2 The Director has requested further details regarding the construction
process and the composition of the materials to be used in the project, to facilitate approval for its
development. EnergySolutions has addressed each of the Director's specific inquiries in the
responses provided below.
Engineering:
1. Please provide details for pressure reliefvalves or justify the need for no pressure
reliefvalves in the geosynthetics at the top ofthe pond.
EnergySo/n/ions'Response: The details for the inclusion offour gas vents are provided
in the attached Engineering Drawing 24003-C0l(1). A vent will be installed at each of
the four corners of the pond, positioned near the top of the interior face of the berms at
approximately elevation 4280.5 feet above sea level. These vents will be oriented towards
the pond to allow for effective gas release. During the filling process, precautions will be
taken to minimize gas pressure buildup within the pond. Any generated gas will be
directed towards the vents to ensure proper ventilation and prevent excessive pressure in
the pond. Consequently, the inclusion ofdedicated gas vents obviates the need for
pressure reliefvalves in the geosynthetics at the top ofthe pond.
Hansen, J.D. "RFI to the Request for Approval to Construct an Evaporation Pond Ground Water Quality
Discharge Permit (Permi| UGW450005 Radioactive Material License UT 2300249 (RML)." (DRC-
2024-006175). Letter to Jonathan C. Anderson of EnergySo/utions from Douglas J. Hansen of the
Division of Waste Management and Radiation Control. July 29,2025.
Anderson, J. "Groundwater Quality Discharge Permit UGW450005; Radioactive Material License UT
2300249: Request for Approval to Construct an Evaporation Pond." (CD-2024-080). Letter to Douglas J.
Hansen of the Division of Waste Management and Radiation Control from Jonathan Anderson of
Ener gy S o lut i ons. April 10, 2024.
299 South Main Street, Suite 1700 . Salt Lake City, Utah 8411I
(80 I ) 649-2000 . Fax: (80 I ) 880-2879 . www.energysolutions.com
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Mr. Doug Hansen
cD-2025-008
January 16,2025
Pase 2 of l3
The CQA/QC Plan needs a summary of the scope of work to be performed, similar
to what is found in other pond CQA/QC plans, including but not limited to a
summary of site preparation, borrow materials characteristics, excavation and
foundation preparation, project construction specification and CQA documents,
etc., or a reference to where this information can be found.
EnerSrSo/r.r/ions'Response: Please find attached Revision I of the Construction Quality
Assurance/Quality Control (CQA/QC) Plan. This document includes an introduction to
the project, details on lift thickness measurement methods (using grade poles or Global
Positioning System [GPS] survey), the construction QA/QC organization, the project
scope ofwork, equipment calibration procedures, project change control protocols,
documentation requirements, project submittal and hold points, and test failure protocols.
The project scope of work encompasses the following activities: site preparation, clay
borrow, excavation, foundation preparation, clay subgrade construction, berm
construction, liner surface preparation, anchor trenches, geosynthetics installation, pond
leak detection system, piping, valves, fittings, electrical connections, spillway, water
offload station pad, leak detection concrete, final grading, and cleanup.
Table I of the CQA/QC Plan outlines the specifications for the various pond material
components and their corresponding QC and QA requirements. The electrical power
source connections provided are preliminary and will be further defined and detailed as
the project progresses.
This revised CQA/QC Plan serves as a comprehensive reference for the scope of work,
like other pond CQA/QC plans, and includes the relevant details regarding site
preparation, borrow material characteristics, excavation and foundation preparation, as
well as project construction specifications and CQA documents.
Provide the manufacture's QA/QC requirements for the various components of the
liner for review, including requirements and specifications for the installation of the
drainage net between the liner layers.
EnergySo/z/ions' Response: The manufacturer's requirements for the pond's
geosynthetics are incorporated into the CQA/QC Plan. Specifically, the specifications for
the Geomembrane materials (high-density polyethylene [HDPE] and linear low-density
polyethylene [LLDPE]) and their installation are detailed in specifications2l-46, as well
as in the chart in Appendix 3 of the CQA/QC Plan, which is based upon the latest
Geosynthetics Research Institute (GRI) specifi cations.
The specifications for the nonwoven geotextile wrap used for the leak detection piping
and associated rock are outlined in Specification 52 and Appendix 3. Additionally, the
drainage net materials and installation requirements are specified in CQA/QC Plan
Specifications 53-56, under the Leak Detection System Work Element, and are also
referenced in Appendix 3. The GRI standards referenced in the CQA/QC Plan are
consistent with those found in other approved EnergySolutions CQA/QC plans, such as
for Mixed Waste projects.
299 South Main Street, Suite 1700 . Salt Lake City, Utah 841 I I
(80 1) 649-2000 . Fax: (801 ) 880-2879 . www energysolutions.com
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Mr. Doug Hansen
cD-2025-008
January 16,2025
Page 3 of 13
The specifications for the installed geosynthetics, including HDPE liners, HDPE geonets,
and geotextiles, will conform to the standards. These specifications will be provided in
the As-Built documentation upon the completion of the pond construction.
4. Provide specification for the sump drain rock.
EnergySo/a/ions'Response: The specification for the sump drain rock is outlined in
Specification 47 of the CQA/QC Plan under Granular Fill. According to the specification,
"Granular fill shall consist of clean rock with 10094 passing a 2.5-inch (J.5. sieve and a
minimum of 90% passing a L|-inch U.S. sieve. Clean rock is defined as material
containing no more than 10.0% passing the number 40 sieve andfreefrom any other
materials not of the same mineralogical composition."
This specification aligns with the standards for rock material used in other
EnergySolutions evaporation ponds. The rock used during construction will meet these
specified requirements and will be documented in the As-Built documentation upon
completion.
5. Please provide the Manufacturer QA/QC Requirements or Recommendations for
geosynthetics testing, QA, QA/QC.
EnergySo/zfions' Response: The geosynthetics manufacturer's QA/QC testing
requirements are incorporated into the CQA/QC Plan specifications, including the
detailed specifications, QC, and QA requirements outlined in Table 1, as well as in
Appendix 3, which was referenced in the response to question 3 above for each material
type.
Geomembrane testing will adhere to current industry standards for fusion and extrusion
weld testing, ensuring that the results meet the requirements specified in Appendix 3,
based upon the GRI standards. These testing protocols will ensure that all geosynthetic
materials meet the necessary quality and performance criteria.
6. Will pressure testing be done on every long seam with a double seal?
EnergySo/z/ions'Response: All seams will be tested using either the "Seam Air Pressure
Test" or the "Vacuum Test," as outlined in Specifications 40 through 44 of the CQA/QC
Plan, and in accordance with the requirements in Appendix 3 under the various Liner
Seam properties.
It is understood that the Division's reference to a "double seal" pertains to seams
produced by fusion welding, where a small air pocket is created and subsequently tested
using the non-destructive "Seam Air Pressure Test," as specified in Specification 40. As
stated in the specification, "where practicable, production welding using the fusion
(welding) method shall be tested using the 'Seam Air Pressure Test."'Any fusion seams
that are not tested using the "Seam Air Pressure Test" (ASTM D 5820), as well as seams
welded by the extrusion method, will be tested using the "Vacuum Test" (ASTM D
5641). Additionally, seams may be divided into sections, with each section being tested
separately.
299 South Main Street, Suite 1700 . Salt Lake City, Utah 841I I
[phone] . Fax: [phone] . www energysolutions.com
-Err:ncl,SorwIoNS
Mr. Doug Hansen
cD-2025-008
January 16,2025
Page 4 of l3
7.Drawing 24003 L02 Note 6 states that the East Side Drainage and Gray Water
System has details for new storm water and wash water pipelines from Manhole#2,
these are not included in the package submitted. Please provide the Drawing Series
or update the note.
EnergySo/z/lons'Response: Engineering Drawing 24003 L02(l), Note 6 has been
updated and is included in this response. Additionally, Engineering Drawings 24003-
L0l(l) and L03(1) have been revised to reference the future pipeline(s). EnergySolutions,
in collaboration with the engineering firm PSE, is currently finalizing the details for the
East Side Drainage and Gray Water System (Engineering Drawing Series 06007). These
details will be submitted to the Director under separate cover.
Provide Leak Detection Rate calculations for both the Leak Rate Exceedance and
Leak Rate at Initial Action Level including references.
a. Drawing 24003 C01 in Note #7 states that "EnergySa/a/iazs reserves the
right to use 80 mil HDPE in place of 60 mil HDPE.'Please include
calculations for leakage rates based on 80 mil HDPD or amend the sheet.
EnergySoirzlions'Response: The Leak Detection system will be monitored in
compliance with Groundwater Quality Discharge Permit (Permit) requirements,
consistent with other EnergySolutions ponds. Leakage rates will be included in
all necessary Permit documentation, including the tables in Appendix K: BAT
Contingency Plan, once the pond is constructed and in conjunction with the
permitting process.
The maximum water surface area is calculated to be 100,981 square feet, or 2.32
acres, as noted in Note 2 of Engineering Drawing 24003-C0l(1). The Allowable
Leak Rate, which represents the Average Leakage Rate Exceedance for the 60
mil HDPE Primarv Liner. is calculated as follows:
200 gallons per acre per day x2.32 acres : 464 gallons per day (l)
This calculation is detailed in Engineering Drawing 24003-C08(l).
The average Leakage Rate at the Initial Action Level will be calculated and
included in the Permit documentation following construction, in alignment with
the permitting process. A review of the Permit and analysis of the initial action
levels for the five existing EnergySolutions ponds reveals that the initial leakage
rates for these ponds are based on a percentage ofthe allowable average leakage
rates, ranging from 92%o to 96%o, with an overall average of 94Yo. As such, the
initial action level for the 2024 Evaporation Pond will be 94Yo of 464 gallons per
day, which equals 436 gallons per day. This figure has been incorporated into
Note 1 of Engineering Drawing 24003-C08(1) and will be reflected in the Permit
documentation after construction, prompting the necessary site response and
pump-down testing if this initial rate is reached.
299 South Main Street, Suite 1700 . Salt Lake City, Utah 841 I 1
(801 ) 649-2000 . Fax: (801 ) 880-2879 . www.energysolutions.com
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Mr. Doug Hansen
cD-2025-008
January 16,2025
Page 5 of 13
Regarding Drawing 24003-C0l(1), Note 7: The leakage rate calculation will
remain unchanged regardless of whether the Primary Liner is 60 mil or 80 mil
HDPE. No additional credit is taken for the increased thickness of the 80 mil
HDPE Liner. In the event of a leak in the Primary Liner, a pathway to the leak
detection system will be created. Note 7 has been updated accordingly.
Suretv:
1. Please justify or update the cost related to all material shredding.
a. For example, the shredder cost of operation for 2.82 hours for geosynthetics
was calculated at $351.96, which seems very low operation costs for the
shredder for 2.82 hours.
EnersySo/ztiors'Response: The shredder costs associated with cutting the liner
are included in line #48 of the closure cost spreadsheet. The total volume of liner
to be shredded at closure ofthe pond is 127.87 cubic yards, which has been
calculated to cost 52,971.26 before accounting for annual inflation. The
referenced amount of $351.96 corresponds to 2 cubic yards of debris materials
(e.g., leak detection, sump pipe, and leak detection system equipment) from lines
#17-19 of the spreadsheet. These materials will not require shredding but will
instead be cut into manageable sizes for direct placement in the embankment.
The calculated shredder operation cost for the geosynthetics over 2.82 hours may
seem low, but this reflects the specific materials and processes involved, which
are more cost-effective than shredding larger or more complex materials. Should
additional details be required, EnergrSolutions will further break down the costs
and provide more clarity.
2. Justify or update disposal cost of shredder waste .
a. For example, was hauling and compaction of waste included in the cost
estimate?
Energy,Soiztions' Response: Hauling and compaction volumes, totaling
29,143.07 cubic yards, are included in the cost estimate under lines #58-60.
These volumes represent the sum of the quantities from lines #15, 20,30,43, and
56. These costs account for the transportation and compaction of waste materials,
ensuring that the disposal process is properly reflected in the overall estimate.
299 South Main Street, Suite 1700 . Salt Lake City, Utah 84 I I I
[phone] . Fax: [phone] . www.energysolutions.com
Err.nc'rSorwIaNS
Mr. Doug Hansen
cD-2025-008
January 16,2025
Page 6 of 13
Environmental:
1. Exhibit G: Evaluation of the Adequacy of the Environmental Monitoring Plan. This
was a restatement of the Environmental Monitoring Plan, not necessarily how the
2024Evaporation Pond will impact said Plan.
^. Please submit justification with analytical support for the statement that
"The proximity of this station [Air Monitoring Station A-191 to the proposed
2024Evaporation Pond is sufficient to monitor resuspended dust (generated
at times when the 2024 Evaporation Pond is absent contact water) and
external gamma radiation given off by contact water and pond sediments."
A-19 does not appear to be "immediately east" of the2024
Evaporation Pond as stated. Please update accordingly.
EnergvSo/z/ions'Response: The proximity of the new proposed2024
Evaporation Pond to Air and Soil Monitoring Stations has been updated
in Tables 1 through 4 ofthis response.
Please include a map with proximity to the nearest air monitoring
stations.
Energy^So/z/ions' Response: The Environmental Monitoring Plan
provides a comprehensive plan for monitoring radiation and radioactive
emissions from EnergySolutions 'bulk waste management operations to
the environment. Information gathered by implementing the Plan is used
to demonstrate regulatory compliance and evaluate the effectiveness of
measures to control the environmental impact of disposal operations and
the effectiveness of EnergySolutions 'ALARA philosophy.
Direct inhalation of radioactive airbome particulates and radon has the
highest potential for off-site dose. Sources ofinhalation exposure
particulates during active operations include the rotary dump, the
shredder, rail car unloading area, bulk waste storage areas, haul roads
and the Class A West disposal embankment.
Additional dust generated by operation of the 2024 pond will have
negligible impact on the emission readings collected via the
Environmental Monitoring Plan. As exemplified in the following
references, the U.S. Environmental Protection Agency (EPA) recognizes
that the nature of their design-particularly the presence of standing
water and the minimal disturbance to the pond surface----evaporation
ponds are unlikely to be substantial sources ofdust. These sources focus
on the moisture's binding effect and the containment features that
mitigate dust generation.
1. "Guidance on the Control of Air Emissions from Waste
Treatment, Storage, and Disposal Facilities" (EPA-450/3-9 l -
022):Evaporation ponds that are designed with proper
containment and managed with operational controls (e.g.,
minimal disturbance) reduce the risk of airborne particulate
299 South Main Street, Suite 1700 . Salt Lake City, Utah 841 I I
[phone] . Fax: [phone] . www.energysolutions.com
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Mr. Doug Hansen
cD-2025-008
January 16,2025
Page 7 of l3
matter and dust emissions. "Evaporation ponds are designed to
reduce exposure to wind and environmental factors that can
generate particulate matter. The design typically includes berms
and liners that contain water, preventing loose materials from
becoming airborne."3
"Air Quality Criteria for Particulate Matter" (EPA 600/P-
991002aF): EPA notes that large bodies of standing water (such
as those found in operational evaporation ponds) limit the
generation of dust because the moisture helps keep surface
materials in place. While not specific to evaporation ponds, the
concept of moisture stabilization in large water bodies is
discussed. "Larger bodies ofstandingwater, such as ponds,
reduce the potential for dust generation due to the binding ffict
of the water on particulate material."a
"Best Management hactices for Control of Fugitive Dust"
(EPA-456/B -06-00 I ) : EPA emphasizes that evaporation ponds
with standing water do not typically generate significant dust
because the water creates a binding effect on materials that
would otherwise be loose and prone to airbome transport. "When
large bodies ofwater qre present, such as in evaporation ponds,
the likelihood offugitive dust emissions is reduced. This is
because the moisture in the water binds particulate matter to the
surface, preventing it from becoming airborne."s
"Design and Operation of Evaporation Ponds for Hazardous
Waste Disposal" (EPA-530-SW-87-02 I ): EPA provides
guidelines on the design and operation ofevaporation ponds
used for the disposal ofhazardous waste. EPA notes that
evaporation ponds are designed with impervious liners and
berms to prevent leakage, and the presence ofwater reduces the
potential for dust formation. EPA discusses how the evaporation
process minimizes disturbance to the pond surface, reducing dust
emissions. "Evaporation ponds are generally designed to
minimize disturbance to the surface of the pond. The pond
surface remains wet due to the water, which helps prevent dust
formation by stabilizing the material within the pond."6
3 U.S. Environmental Protection Agency (EPA). (1991). Guidance on the Control of Air Emissions from
Waste Treatment, Storage, and Disposal Facilities. EPA-450/3-91-022. July 2007.a U.S. Environmental Protection Agency (EPA). (1999). Air Quality Criteria for Particulate Matter. EPA-
600/P -99 l002aF. October 1 999.
5 U.S. Environmental Protection Agency (EPA). (2006). Best Management Practices for Control of
Fugitive Dust. EPA-456/B-06-001. April 2006.6 U.S. Environmental Protection Agency (EPA). (1987). Design and Operation of Evaporation Ponds for
Hazardous Waste Disposal. EPA-530-SW-87-021. April 1987.
299 South Main Street, Suite 1700 . Salt Lake City, Utah 841 I I
[phone]. Fax: [phone] . www.energysolutions.com
2.
3.
4.
Errincr^9olwIaNS
Mr. Doug Hansen
cD-2025-008
January 16,2025
Page 8 of l3
5. "Technical Document on Landfill Gas Emissions" (EPA/600/R-
071122): This technical document addresses emissions from
landfills, but it also touches on the role of water bodiei lite
evaporation ponds in controlling dust and particulate emissions.
It suggests that ponds with significant water volumes are not
significant sources of atmospheric dust because the water's
presence inhibits the release of particulate matter. "llater-/illed
containment systems, such as evaporation ponds, limit the
potentialfor dust generation because the water helps to keep
particulate matter in place."1
As is illustrated in Engineering Drawings 07007-J01 and 07007-J03
Figure Airbome radioactive particulates and gasses are continuously
monitored at designated monitoring stations (one station per 30-degree
compass sector). The monitored locations are situated near the fenced
boundaries that surround waste management areas. The overall sampling
pattern is designed to intercept airbome radioactive effluents leaving the
licensed Restricted Area in any direction. The airbome exposure
measured at these monitoring stations is used to calculate the dose
received from the airborne effluents.
As is illustrated in Table 1, the average distance from the proposed new
2024Evaporation Pond to air monitoring stations is 3,904.3 feet, which
is comparable with the distances from EnergySolutions 'other operating
evaporation ponds to air monitoring stations (e.g., where the average
distance from the operating 95 Pond to air monitoring stations is greater
at 4,922.3 feet and the average distance from the operating NW Comer
Pond is lower at 3,199.9 feet). Therefore, the distance from the new
proposed 2024 Evaporation Pond to the existing air monitoring stations
is appropriate and within the range of those already considered.
Table 1 - Distances from Air Monitoring Stations to Evaporation Ponds
COMPASS
snaTr|R
AIR
STATIf|N
DISTANCf,
TONW
CORNER
Pf|NTI /fA
DISTANCE
TO97
PflNI! /ffl
DISTANCf,
TO 9spnNn lfA
DISTANCE
TO2024
POND (fr)
AVERAGE(fr)
N A-35 911.3 3,5s0.0 4,616.4 47\r)3Js7.5
NNW A-30 382.7 45655 51033 s.384 5 3.E59.0
wNw A-29 (r45 45061 5.2t0.2 5.327 6 t.922.3
w A-28 1.t24.0 4.369.s 5.216.2 5.180.s 3.972.s
wsw A-22 2.147.8 4.319.4 5.224 8 5-078.4 4.192-6
SSW A-13 4.s64 2 5.014.4 5-166.0 5.536.8 5.070.4
s A-lt 5.049.7 45140 4.717.2 4.925.4 4.E06.6
SSE A-10 6.153.0 3.2s9.1 4.553.3 3.13l l 4.274.2
ESE A,-17 5.5t7.7 t.4t4 4 5.005.9 791.4 3.182.4
E A-19 4.888.8 1.224.0 s_03s 0 1.045.0 3,048.2
ENE A-18 4.254.6 2.226.4 47980 2.494.0 3.443.2
NNE a-16 1.799.7 2.839.1 4.421 5 3.604 6 3.166.2
AVERAGE 3.1 19.9 3.485.2 4.922.3 3.904.3
U.S. Environmental Protection Agency (EPA). (2007). Technical Document on Landfill Gas Emissions.
EPA/600/R-07 I 122. July 2007 .
299 South Main Street, Suite 1700 . Salt Lake City, Utah 84 I I I
[phone] . Fax: [phone] . www.energysolutions.com
-Eruncr;,SolwIoNS
Mr. Doug Hansen
cD-2025-008
January 16,2025
Page 9 of l3
Similarly, the nearest and farthest distances from the new proposed2024
Evaporation Pond to Air Monitoring Stations (791 feet from Air
Monitoring Station A-17) and 5,537 feet from Air Monitoring Station A-
13) are comparable to bounding distances from EnergySolutions 'other
operating evaporation ponds to Air Monitoring Stations. (See Table 2).
Table 2 - Bounding Distances from Air Monitoring Stations to Evaporation Ponds
NW
CORNER
POND 97 POND 95 POND
2024
POND
Average Distance to Air
Stations (ft)
3,120 3,485 4,922 3,904
Closest Air Station
(Compass Sector from which
Wind blows)
A-30
(I.rNW)
A-19
(E)
A-36
(NNE)
A-r7
(EsE)
Distance to Closest Air
Station (ft)
383 1,224 4,421 791
Farthest Air Station
(Compass Sector from which
Wind blows)
A-10
(ssE)
A-13
(ssw)
A-22
(wsw)
A-13
(ssw)
Distance to Farthest Air
Station (ft)
6,153 5,014 5 1)\
Environmental samples are also collected and analyzed from Soil
Monitoring Stations that are stationed around the perimeter of the
licensed Restricted Area (with two stations per 30-degree compuss
sector). Samples are collected from the top one inch of soil to evaluate
the degree of long-term dust deposition that may be occurring from
waste operations.
As is illustrated in Table 3, the average distance from the proposed new
2024 Evaporation Pond to soil monitoring stations is 3,844.3 feet, which
is comparable with the distances from EnergySolutions 'other operating
evaporation ponds to soil monitoring stations (e.g., where the average
distance from the operating 95 Pond to soil monitoring stations is greater
at 4,881.5 feet and the average distance from the operating NW Corner
Pond is lower at 3,147.9 feet). Therefore, the distance from the new
proposed 2024Evaporation Pond to the existing soil monitoring stations
is appropriate and within the range of those already considered.
299 South Main Street, Suite 1700 . Salt Lake City, Utah 841I I
[phone]. Fax: [phone] . www.energysolutions.com
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Mr. Doug Hansen
cD-2025-008
January 16,2025
Page 10 of13
Table 3 - Distances from Soil Monitoring Stations to Evaporation Ponds
COMPASS
SECTOR
SOIL
STATION
DISTANCE
TONW
CORNER
POND (fr)
DISTANCE
TO97
POND (fr)
DISTANCf,,
TO 95
POND (ft)
DISTANCE
TO2024
POND {fO
AVERAGE
(fi\
N s-72 6s2.1 3;777;l 4.707 tl 4s8s9 3,430.9
s-73 r.068.0 3.413.8 4.568.7 4.211."1 3315.6
NNW s-66 3't0.7 4.354 0 5.095.2 5.176.4 3.749.1
s-71 306.2 4.146.8 4.877.6 4.96r.3 3.573.0
wNw s-6s 696.6 4.282.0 120 2 5.10 L9 3.800.2
s-66 370.7 4_3s4 0 5.095.2 5.176.4 3-749.1
w s-s9 t.404.6 4.32t.3 5-2 15. l 5.122.0 4.015.7
s-64 | 0630 4.203.5 5.127.4 5.015.4 3.Es2.3
wsw s-s6 2.s48 8 4.367.9 s.226.4 50964 4309.9
s-57 2.t46 1 4.316.3 5.223.2 5.075 4 4.190.3
SSW s-39 4.015.7 4.734 3 5-165.0 5.314.8 4.807.4
s-40 3.469.1 4.506.6 5. r 65.0 5.144.7 4.571.3
S s-36 5.2922 3.91',t.6 4.449.7 4.r 81.9 4.460.3
s-17 5.129.7 4.271.9 4_585. I 4.61'7.3 4.65t.0
SSE s-28 6.579.4 3.326 5 4.759.0 3.040.8 4.426.4
s-29 5.958.4 3.610.s 4.416.2 3.635 8 4.405.2
ESE s-26 5.8"t7.9 910 0 5.031.I 1.362 8 3.545.4
s-27 6,650.8 3,014.3 5.021.4 2,s70'7 4,314.3
E s-22 4.862.0 203 6 5021 I I .041 .7 3.032.3
s-24 5.2421 1.049 3 5.01 1.7 245 7 2,8E7.2
ENE A-18 3.400.2 1.838 0 4.525;7 2-388. I 3.038.0
s- 19 4.550.3 21179 4.930.6 t-2 tu.J 3.467.3
NNE s-74 1.826.5 2.820 2 4.418.4 3,162.3
s-77 2.067.3 2-590.5 4.397 8 3.342.2 3.099.4
AVf,RAGf,3.147.9 3.435.4 4.881.s 3,E44.3
Similarly, the nearest and farthest distances from the new proposed2024
Evaporation Pond to Soil Monitoring Stations (246 feet from Soil
Monitoring Station S-24) and 5,315 feet from Soil Monitoring Station S-
39) are comparable to bounding distances from Enerry Solutions ' other
operating evaporation ponds to Soil Monitoring Stations. (See Table 4).
299 South Main Street, Suite 1700 . Salt Lake City, Utah 841 I I
(801 ) 649-2000 . Fax: (801 ) 880-2879 . www energysolutions.com
-Err"ncl'^SorwIaNS
Mr. Doug Hansen
cD-2025-008
January 16,2025
Page ll of13
Table 4 - Bounding Distances from Soil Monitoring Stations to Evaporation Ponds
NW
CORNER
POND 97 POND 95 POND
2024
POND
Average Distance to Soil
Stations (ft)
3,148 3,435 4,881 3,844
Closest Soil Station
(Compass Sector from which
Wind blows)
s-71
o.rNw)
s-24
(E)
s-77
(I.INE)
s-24
(E)
Distance to Closest Soil
Station (ft)
306 1,049 4,398 246
Farthest Soil Station
(Compass Sector from which
Wind blows)
s-27
(ESE)
s-39
(ssw)
s-56
(wsw)
s-39
(SSW)
Distance to Farthest Soil
Station (ft)
6,65r 4,734 5,226 5,31 5
2. Drawing 24003 L03.
a. Note#2 after Gamma Monitoring Station F-35 is moved to the new
Restricted Area Boundary, it should be differentiated from the current
location of F-35 for data integrity purposes. Please update where applicable
and resubmit.
EnergySo/z/ions'Response: Gamma Monitoring Station F-35 has been added to
Subsection 2.2.5 of the CQA/QC Plan to address how Station F-35 will be
protected and addressed during and after construction. As shown in the revised
Engineering Drawing 24003-L03(l), Station F-35 will remain in its current
location during Pond construction and an additional temporary Gamma
monitoring station will be located near the south/southeastern side of the project
during construction. Station F-35R will be relocated to the new restricted area
fence line upon project completion. EnergySolutions will follow all policies and
procedures regarding the data. A revised Engineering Drawing 24003 L03(1) is
attached.
299 South Main Street, Suite 1700 . Salt Lake City, Utah 841 I I
(80 I ) 649-2000 . Fax: (80 I ) 880-2879 . www.energysolutions.com
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Err:nc;l^SorwIaNS
Mr. Doug Hansen
cD-2025-008
January 16,2025
Page 12 of l3
b. Soil Station $24 should remain free of disturbances during construction. To
facilitate this, the fencing should remain in place during construction.
i. Please address what impact, if any, construction will have on the S-
24 Soil Sampling Location.
EnergySo/z/ions' Response: Existing Soil Monitoring Station S-24 has
been added to Subsection2.2.26 of the CQA/QC Plan to address how
Station S-24 will be sampled prior to construction, protected by covering
the station area with a plate during construction due to its expected
proximity to construction and the expected need in that comer of the
project for construction equipment access, and re-established following
construction. Note I in Engineering Drawing24003-L03(1) has been
updated, as well (attached).
Please update drawings to include RA fencing with berms, where appropriate.
EnergySo/zlions'Response: New Restricted Area fencing and gtade-work next to the
new RMA fencing are shown in Engineering Drawings 24003 L02(l),24003 L03(l),
and 24003 C09( I ) (attached).
Provide specification for pump intended for use in the leak detection system.
EnergySo/ztions' Response: EnergySol*ions intends to use a Grundfos stainless-
steel SP submersible pump with % hp MS 402 motor or its owner approved
equivalent to be consistent with monitoring in the other EnergSolutions ponds.
Engineering Drawing 24003-C08(l) (attached) has been updated to include reference
to this pump (or owner approved equivalent).
Prior to well drilling, please submit the Work Plan for review by the Division to
ensure that accurate subsurface data are collected.
EnersySo/zlions'Response:EnergySolutions will submit the Well Drilling Work
Plan for the Director's review prior to equipment mobilization.
Enclosed with this request are the following supporting documents submitted in accordance with
applicable Permit and License requirements:
A. Engineering Drawing 24003-C0l(1);
B. Revision I of the Construction Quality Assurance / Quality Control Plan for the 2024
Evaporation Pond;
C. Engineering Drawing 24003-L01(l);
D. Engineering Drawing 2a0$-L02(l);
E. Engineering Drawing 2a003-L03(l);
F. Engineering Drawing 2a003-C08(1);
299 South Main Street, Suite 1700 . Salt Lake City, Utah 841 I I
[phone]. Fax: [phone] . www.energysolutions.com
3.
4.
3.
--
Exnncl',SorwIoNS
Mr. Doug Hansen
cD-2025-008
January 16,2025
Page 13 of 13
Engineering Drawing 2a003-C09(l );
Revised Closure Surety Calculations;
Engineering Drawing 07007-J0l ; and
Engineering Drawing 07007-J03.
Within 30 days of completion of construction of the nevr 2024 Evaporation Pond EnergySolutions
will submit a set of i'As-Built" drawings for the Director's review (per License Condition 48.C).
The As-Built drawings will be marked as "As-Built" in the final entry in the revision block and
will indicate as-built conditions as they exist upon construction completion. To make available
additional evaporative storage capacity for operation of the new East Side Rotary Facility,
EnergySolutions requests that the Director complete review and authorize construction on or
before May 1,2025.
Should there be any questions regarding this request, please feel free to contact me at (801)
649-2000.
Sincerely,
Manager, Groundwater and Environmental Program
I certifu under penalty of law that this document and all attachments were prepared under my direction or supemision
in accordance l4tith a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry ofthe person or persons who manage the system, or those persons directly responsible
for gathering the information, the information submitted is, to the best ofmy knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submittingfalse information, including the possibility of
/ine and imprisonment for knowing violations.
299 South Main Street, Suite 1700 . Salt Lake City, Utah 841 I I
(801 ) 649-2000 . Fax: [phone] . www.energysolutions.com
G.
H.
I.
J.
Mathew R. Schon