DRC-2025-001604

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com
May 16, 2025 CD-2025-103
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 (Permit): Response to the
Request for Information related to the 2024 Second Semi Annual Best
Available Technology (BAT) Monitoring Report
Dear Mr. Hansen:
EnergySolutions hereby responds to the Request for Information (via DRC-2025-001315;
May 6, 2025) issued by the Director of the Division of Waste Management and Radiation
Control (Director) related to the 2024 Second Semi-Annual Monitoring Report. The
Director states,
“On the LLRW/11e.(2) daily facility inspection report for August 15, 2024, the
BAT inspector listed that “95 for some reason pumped backwards supervisor
notified.” No further mention of this was found anywhere else in the report, nor in
Table 2. Please provide more clarification on the manner of this issue and
if/how it was resolved.” [emphasis added]
EnergySolutions’ Response: All observations made by BAT inspectors are documented
on BAT field forms. In accordance with Permit requirements, the presence of a field
observation does not inherently make it reportable. The criteria and procedures for
incident reporting are outlined in Appendix K: BAT Contingency Plan of the
Groundwater Quality Discharge Permit UGW450005.
On August 15, 2024, an observation was made indicating that the pump to the 1995 Pond
pumped appeared to operate in reverse, based on a -9 reading from the leak detection
system’s flow meter differential. According to Section 4.1 of Appendix K, this
observation did not require notification. Flow meter readings from that day are presented
in Table 2 and corroborated by the daily BAT inspection report referenced by the
Director.
This phenomenon has been observed previously and is believed to result from a vacuum
effect in the pipeline between the leak detection pump and flow meter. This can occur
when water in the pipe flows back into the sump under the influence of gravity.
Additionally, wind conditions at the Facility have been identified as a contributing factor.
Importantly, this effect is not caused by the pump reversing its flow direction.
Mr. Doug Hansen
May 16, 2025
CD-2025-103
Page 2 of 3
The Director also states,
“Two instances of BAT Failures were noted during the review; however, neither
of these were captured in Table 2. Even if these were resolved by the end of shift,
they should be captured in Table 2.
a. On the daily for December 30, 2024, there was noted to be ponded water in the
DU building and that it was subsequently cleaned up.
b. On the December monthly facility inspection, it was noted that a hole was
found in a DU drum with “exposed DU” and that it was patched by the end of
shift.”
EnergySolutions’ Response: It appears the Director is referring Table 4, not Table 2.
Table 4 includes BAT occurrences that require a 24-hour notification and a 7-day
response letter. BAT occurrences that do not meet the notification criteria outlined in
Appendix F, of the BAT Semi-Annual Report. This approach supports transparency and
appropriately categorizes such events as minor routine repairs.
According to Appendix K, it is inconsistent to include issues resolved by the end of the
shift in Table 4. In the past, some of these items were included in Table 4 for
informational purposes; however, there is no requirement for all observations noted on
the BAT forms to be reported there.
Appendix K Section 4.19.3 specifies that if water is present on the asphalt surface, a 24-
hour notification and 7-day response letter are required. On December 30, 2024, the roof
replacement of the DU Storage Building was in progress due to previously identified
leaks. These issues had already been reported to the Division in prior notices. During the
roof replacement, water was not observed on the asphalt surface. Tarps were used to
cover leaking areas, preventing water from contacting the floor or DU drums. Further
details on the roof replacement can be found in CD-2025-018.
Regarding question ‘b,’ Appendix K Section 4.19.2 states that if evidence of a leak is
found, it must be corrected on the same business day or a 24-hour notice and 7-day
response letter is required. In this case, corrective actions were completed the same day
and documented on the BAT inspection sheet. EnergySolutions complied fully with the
BAT Contingency Plan requirements; therefore, no additional notification or
documentation was necessary.
Mr. Doug Hansen
May 16, 2025
CD-2025-103
Page 3 of 3
Should you have any questions regarding these responses, please contact me at (801)
649-2060.
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.