DRC-2024-007488

November 12, 2024
Mr. Vern Rogers,
Director of Regulatory Affairs
EnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111Subject:Request for Compliance Status Change, Ra-226+Ra-228 in Compliance Monitoring Well GW-77; Groundwater Quality Discharge Permit, Number UGW450005.
Dear Mr. Rogers:
The Division of Waste Management and Radiation Control (Division) has completed its review of your May 17, 2024 (CD-2024-110), and October 16, 2024 (CD-2024-219) letters regarding the
Probable Out-Of-Compliance (POOC) status in Compliance Monitoring Well GW-77.EnergySolutions’ requested that Compliance Monitoring Well GW-77 be return to baseline monitoring from POOC
monitoring status (quarterly sampling). This POOC monitoring began in the fourth quarter of 2019 due to an exceedance of a Sum of Radium Groundwater Protection Level (GWPL)Compliance
Monitoring Well GW-77, with an additional non-consecutive exceedance in February of 2022.Also, the Division reviewed your request that the procedure contained in a May 25, 2006 request
for information from the Division, for calculating the Sum of Radium be rescinded.
The reported exceedances appear to be unique results, based on the last ten consecutive sample results, which were received with the October 16, 2024 letter, that were below the Ground
Water Protection Level. Additionally, there appears to be no observed increasing concentration trend associated with the Sum of Radium data for Compliance Monitoring Well GW-77, since
the original exceedance.Sum of Radium in Compliance Monitoring Well GW-77 is below the Ground Water Protection Level and more typical of the period before the well went into accelerated
monitoring. Based on the review of the May 17, 2024, and October 16, 2024 letter requests, the Division is granting the request to return Compliance Monitoring Well GW-77 to a baseline
monitoring frequency (annual). In reviewing the sum of radium procedure reference in the October 16, 2024 letter, the Divisions agrees with EnergySolutions that the methodology contained
in a Division of Radiation Control, May 25, 2006 letter has no justification and it is not a requirement of theGroundwater Quality Discharge Permit. Therefore, EnergySolutions is not
compelled to use the May 25, 2006 letter’s Sum of Radium equation.
If you have any questions, please call Charles Bishops at [phone]
Sincerely,
Lawrence Kellum,Low Level radioactive waste Section Manager
Division of Waste Management and Radiation Control
LK/CB/wa
c:Local health Department (go to U:\HW General Folders\Local Health Depts and Dist. Engineers and insert correct health department file)