DRC-2025-001372

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com
April 23, 2025 CD-2025-081
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): Variance
Request Groundwater Monitoring Well P3-95 SWC Tracer Dye Test Plan
Dear Mr. Hansen:
EnergySolutions hereby submits a Variance Request to change the deadline to begin the
tracer dye test from April 25, 2025 to April 30, 2026. 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
was submitted February 10, 2025 (CD-2025-024). The Director established April 25,
2025 as the latest starting date for the tracer dye test (DRC-2024-006236).
The test has always been dependent on seasonal precipitation and the precise timeline out
of the control of EnergySolutions. Seasonably higher precipitation leading to stormwater
accumulation in the ditch west of the P3-95 SWC has been correlated with elevated
uranium levels occurring in groundwater and consistent with the hypothesis that higher
moisture levels in the vadose zone contribute to this transport. Due to a very dry spring,
and the ditch not filling with stormwater, it has not been possible to begin the test. While
it has been suggested to fill the ditch with saline water (from a water truck) and conduct
the test, EnergySolutions believes this adds too many additional variables, including
water salinity, infiltration, and unsaturated flow conditions that may not be representative
of the actual conditions that lead to uranium presence in the well. Historically, elevated
uranium concentrations mostly show up in the spring during seasonally wet periods. In
years with below average precipitation, they are sometimes entirely absent.
EnergySolutions intends to conduct this test when there is a precipitation event large
enough to fill the jettied ditches during a seasonably wet period, such as the spring, which
has historically been the time Total Uranium above GWPLs has been detected. A one-
year extension of the deadline for the Work Plan (CD-2025-024) will allow for needed
flexibility as we wait for the conditions to arise that facilitate transport of uranium to the
well. EnergySolutions plans to keep the constructed jetties in place and continue to
suspend the collection of stormwater in the ditch (in accordance with the requested
deadline extension). Leaving the ditches in place poses no additional risk and will allow
the test to begin when the correct conditions arise. Historically, even large precipitation
Mr. Doug Hansen
April 23, 2025
CD-2025-081
Page 2 of 2
events in the summer have not been enough to increase the Total Uranium concentration
in the well significantly. EnergySolutions will continue to be in close contact with
DWMRC before any test begins.
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
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inquiry of the person or persons who manage the system, or those persons directly responsible for gathering, the information the
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