DRC-2025-000240

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com
January 16, 2025 CD-2025-011
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): Water
Level Monitoring Documentation Review
Dear Mr. Hansen:
EnergySolutions has recently performed an audit of our water level monitoring program.
After reviewing all water level monitoring related documents and procedures for 2024 we
found some discrepancies. GWQDP Part I.F.5.a requires that we change monitoring
frequency of wells with greater than 0.4 feet difference from the baseline measurement from
quarterly to monthly and notify the Director within 15 days of discovery.
We have documented our findings in ‘Table 1’ and below:
•GW 56R: Went out of compliance in Q3 2024. Back in compliance Q4
2024.
•GW-102: Went out of compliance in Q2 2024. Back in compliance Q4 2024.
•GW-106: Went out of compliance Q3 2024 (we suspect a measurement
error). Back in compliance Q4 2024.
•GW-127: Went out of compliance Q3 2024. Out of compliance and placed
into monthly monitoring.
•GW-134: Went out of compliance in Q3 2024. Back in compliance Q4 2024.
•I-3-100: Went out of compliance Q3 2024. Out of compliance and placed
into monthly monitoring.
•P3-97-NECR: Went out of compliance Q3 2024. Out of compliance and
placed into monthly monitoring.
The water level variations observed in the wells above are related to elevated precipitation.
The precipitation rate for February through April 2024 was 165% of the 31-yr average
precipitation.
In accordance with the requirements of GWQDP Part I.H.2, this information will be
documented in the annual monitoring report to be submitted on or before March 1, 2025.
Mr. Doug Hansen
January 16, 2025
CD-2025-011
Page 2 of 2
Should you have any questions regarding this notification, please feel free to contact me at
[phone].
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.
Table 1. Depth to Water (DTW) Levels
Well DTW
(ft)
DTW
(ft)
Delta DTW
(ft)
Delta DTW
(ft)
Q1-24 Q2-24 Q3-24 Q4-24
GW-56R 30.03 29.72 0.3 30.20 0.5 Y 30.08
GW-102 25.78 25.32 0.5 Y 25.33 0.0 25.44
GW-106 25.87 25.95 0.1 26.70 0.8 Y 25.98
GW-127 26.98 26.73 0.3 27.18 0.4 Y 27.44
GW-134 36.49 36.44 0.1 36.89 0.5 Y 36.85
I-3-100 32.35 32.11 0.2 32.65 0.5 Y 32.62
P3-97
NECR
33.54 33.21 0.3 33.89 0.7 Y 33.96
Y – Depth-to-water measurement exceeded 0.4 ft from the previous quarter’s measurement.