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HomeMy WebLinkAboutDRC-2025-001970299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111 (801) 649-2000 ▪ Fax: (801) 880-2879 ▪ www.energysolutions.com June 10, 2025 CD-2025-123 Mr. Doug Hansen, Director Division of Waste Management and Radiation Control P.O. Box 144880 Salt Lake City, UT 84114-4880 Subject: Ground Water Quality Discharge Permit No. UGW450005 (GWQDP): Request to Modify GWQDP Appendix B Part 4-1 and Appendix C Part 2.3 Dear Mr. Hansen: EnergySolutions requests approval of a modification to the GWQDP Appendix B Part 4-1 and Appendix C Part 2.3. The sampling procedures in the tables of each referenced section are outdated. Occasionally lab volume requirements for specific analytical procedures change. Currently the volume referenced in the sampling procedures needed to run a LARW radiological suite is 12,000 milliliters (three 4-liter cubes) and is referenced incorrectly in each table. Enclosed are redlines with the corrected volumes. Should you have any questions regarding this request, 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. ENERGYSOLUTIONS WATER MONITORING QUALITY ASSURANCE PLAN GWQDP UGW450005 APPENDIX B August 30, 2011 June 6, 2025Revised February 18, 2014 EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-1 B.4 SAMPLING PROCEDURES As required by EnergySolutions’ various regulatory permits and licenses, surface water and groundwater elevation measurement programs and surface water and groundwater sampling and analysis programs will be conducted. Specifically, groundwater will be monitored at the LARW, Class A, and Class A North collection lysimeters; the Mixed Waste, Northwest Corner, and three LARW evaporation ponds; the Mixed Waste leachate collection sumps; and compliance monitoring wells (See Plate 1 for locations). This section describes the field procedures for monitoring these locations. COLLECTION LYSIMETER FIELD PROCEDURES Water Elevation Measurements. The collection lysimeters will be monitored by removing the manhole cover, implementing confined space entry procedures, and then removing the end plug from the top of the standpipe. The standpipe will then be probed for the presence of liquids using an electric well probe. Should free liquids exist, the depth to the free liquids will be recorded. If and when free liquids initially appear in the standpipe, the DRC will be notified in accordance with Part I.H.8 of the GWQDP. Immediately after free liquids are initially detected, the monitoring frequency will be increased to daily in order to assess the flow rate into the collection lysimeter. Daily monitoring will continue until the flow rate has stabilized or can be estimated to schedule periodic purging and sampling of the lysimeter standpipe. Free liquid monitoring frequency will then be decreased as approved by the Executive Secretary to an appropriate monitoring interval. Free liquids will not be allowed to build up in the standpipe to a level less than 12 inches below the invert of the transfer pipe. The standpipe will be purged of free liquids when they are detected unless a sampling event is planned and the volume is being accumulated to provide adequate sample volume for analysis. Purging will be performed using either a dedicated bailer or a peristaltic pump. EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-2 Sampling Procedures. Part I.F.6 of the GWQDP requires that water quality samples be collected within 24 hours after discovery. Because of the limited amount of water expected to be in the collection lysimeters, the number of radiological and chemical analyses will also be limited. Therefore, analytical samples will be collected using the following priority list. Priority Parameter Sample Volume (ml) 1 Field Parameters- Temperature, pH, Specific Conductivity 100 2 Radiologics – LARW Suite 12,0003,500 3 Metals/Inorganics – LARW Suite 500 4 TDS/TSS 500 5 Major Cations and Anions 500 6 Volatile Organic Compounds (VOCs) 3 X 40 Samples will be collected using either a dedicated bailer or a peristaltic pump. WASTEWATER POND FIELD PROCEDURES Water Elevation Measurements. Part I.F.13 of the GWQDP requires that the permitted Evaporation Ponds be monitored for freeboard. All inspection records shall comply with Part II.G. of the GWQDP, and a minimum of 24-inches of vertical freeboard shall be kept in the ponds. Sampling Procedures. Part I.F.13 of the GWQPD requires that water quality samples be collected on an annual basis in all five ponds (Mixed Waste, Northwest Corner, 1995 LARW, 1997 LARW, and 2000 pond). Samples shall be collected at each pond during the normal annual groundwater sampling effort. Samples will be collected using a peristaltic pump and 1-inch PVC pipe. The PVC pipe will be lowered into the ponds, and EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-3 the peristaltic tubing will be inserted inside the pipe. This will keep the peristaltic tubing from floating on the water surface. Samples will be analyzed in accordance with Parts I.F.5 and I.F.13 of the GWQDP. MIXED WASTE LEACHATE MONITORING FIELD PROCEDURES Sampling Procedures. Part I.F.15 of the GWQDP requires that water quality samples be collected on an annual basis from the Mixed Waste leachate collection system (upper leachate collection access pipe. Samples shall be collected at each sump during the normal annual groundwater sampling event. If no leachate is present during the sampling event, no sample is required. This will be documented in the annual report. Samples will be collected using a peristaltic pump. Dedicated ¼” polyethylene tubing stored in each sump will be attached to the leachate withdrawal hose. Mixed Waste leachate will be sampled for VOCs, polychlorinated biphenyls (PCBs), and the radiologic constituents listed in tables IE and IF of the Ground Water Quality Discharge Permit, including complete gamma spectroscopic analysis. MONITORING WELL FIELD PROCEDURES Groundwater Elevation Measurements. Groundwater elevation measurements will be collected on a monthly basis at GW-37, GW-38R, PZ-1, PZ-2, I-1-100, I-3-30, I-3-100, GW-27D, GW-19B, and all compliance monitoring wells. These sites are shown on Plate 1, and are listed in the Groundwater Elevation Measurement Form shown in Figure B.4- 1. In addition, the specific gravity (SG) of groundwater from all locations listed above will be measured on-site on an annual basis. Samples for SG measurement will be obtained during groundwater sampling. For the wells without dedicated pumps (deep wells and piezometers), a disposable bailer will be used to collect samples for SG measurement. A hydrometer will be used to measure the SG. EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-4 Procedures. Depth to groundwater will be measured using an electric water level indicator. The groundwater elevation measurements will be made from a surveyed reference location at the top of the protective casing. Prior to insertion into the well casing, the electric water level probe will be triple rinsed with distilled or deionized water and inspected for foreign matter to ensure proper decontamination. A straight edge will be placed across the open protective casing and measurements will be determined at the bottom of the straight edge. After decontamination, the probe is then lowered until the signal is activated. The probe is then gently lifted and lowered as needed so that the probe is positioned at the surface of the water. The depth to groundwater value is determined by observing the place on the water level indictor’s line at the bottom of the straight edge when the probe indicates it is at the surface of the water. Depth to water measurements are recorded to the nearest 0.01’ in the Groundwater Field Notebook and on the Groundwater Elevation Measurement Form (Figure B.4-1). The measurements are repeated until at least two successive values are observed. The observed value is recorded. The probe is then removed from the well and rinsed thoroughly with distilled or deionized water and inspected for foreign matter. Total Well Depth Measurements. Total well depth measurements will be collected on an annual basis at all wells currently in the monitoring well network. These measurements will be made during the annual sampling event. The measured water column will be compared to the theoretical water column (based on monitoring well completion diagrams) to evaluate the amount of silt that has accumulated in the bottom of the monitoring wells using the following equation: 100 x DTW - TD DTW - TD =column Water ActualPercent t m where: TDm is the measured well depth EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-5 TDt is the theoretical well depth DTW is the measured depth to water If the measured water column is less than 90 percent of the theoretical water column, the monitoring well will be redeveloped prior to sampling. Procedures. Total well depth will be measured using an electric water level indicator. Prior to measuring the total depth of each well, the dedicated pumps will be extracted from the wells. The condition of each pump will be checked, and any maintenance will be performed to ensure proper operating conditions of the pumps. The total monitoring well depth measurement will be made from a surveyed reference location at the top of the protective casing. A straight edge will be placed across the open protective casing and measurements will be determined from the bottom of the straight edge. Prior to insertion into the well casing, the electric water level probe will be triple rinsed with distilled or deionized water and inspected for foreign matter to ensure proper decontamination. After decontamination, the electric water level indicator is turned off. The probe is then lowered slowly into the well until it hits the bottom of the well. The depth to the bottom of the well is determined by observing the place on the water level indictor’s line at the bottom of the straight edge when the probe indicates it is at the bottom of the well. Depth to the bottom of the well measurements are recorded to the nearest 0.01’ in the Groundwater Field Notebook. The measurements are repeated until at least two successive values are observed. The observed value is recorded. The probe is then removed from the well and rinsed thoroughly with distilled or deionized water and inspected for foreign matter. After all depth measurements are recorded, a correction factor is added to each measurement. The correction factor represents the distance from the depth to water sensor (where the measuring tape is referenced) to the end of the steel probe (which contacts the bottom of the well). EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-6 Documentation. All data collected during this program will be recorded on the Groundwater Elevation Measurement Form (Figure B.4-1). The field personnel will also maintain a field logbook consisting of a weather resistant, bound, survey-type book, with non-removable, numbered pages. The logbook will be updated on a daily basis (during fieldwork) and will include the following information: Name of individual making entry Name and location of job Personnel on site Name and address of field contact person Date and time groundwater elevations were started and completed Equipment used for groundwater elevation measurements Weather conditions Any deviations from QAPP Groundwater well number Problems with monitoring wells All entries will be made in ink and any errors will be corrected by drawing a single line through the appropriate text and then adding the correct test. All changes will be dated and initialed. EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-7 GROUNDWATER SAMPLING Groundwater Sampling Locations and Frequency. This WMQAP applies to groundwater monitoring at five disposal areas at EnergySolutions’ Clive facility. These disposal areas include the LARW cell, the Class A cell, the Class A North cell, the 11e.(2) cell, and the Mixed Waste cell. Because these disposal areas fall under different regulatory agencies, wells monitored for these areas have different analyte suites. However, all radiological analyses are regulated by the DRC. The groundwater sampling programs for the EnergySolutions facility are indicated and described in Tables B.4-1a and B.4-1b. Figure B.4-1 lists the monitoring wells for which depth to water measurements are determined on a monthly basis and provides areas for recording:  Measurement dates  Depth to water measurements  Specific gravity and groundwater elevation (if applicable) Quality Assurance/Quality Control Samples. To ensure the comparability of data to previous sampling programs, quality control (QC) for the groundwater sampling programs will include the following samples: QC Samples Requirement Trip Blank One trip blank will be included in each cooler containing samples for Volatile Organic Compounds (VOC) analysis Field Blank For RCRA sampling, one field blank (pour blank) will be collected per sampling event when the event includes VOC samples EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-8 Blind Duplicate One blind duplicate will be collected for each scheduled analysis for each round of sampling (5 percent) Matrix Spike One sample for matrix spike analysis will be collected for each scheduled analysis for each round of sampling (5 percent) Matrix Spike Duplicate One sample for matrix spike duplicate analysis will be collected for each scheduled analysis for each round of sampling (5 percent) a a Except for dioxin/furan analysis by Method 8290 or equivalent, where isotopic dilution is used to assess the effects of matrix on method performance. Sample Designation. All environmental groundwater samples will be designated using their current EnergySolutions location identification. The QA/QC samples will be designated based on type. Trip blanks will be designated by “TB”, which indicates the sample is a trip blank, and the date it was submitted for analysis (e.g., TB-7/24/97). Field blank samples will be designated with “FB”, which indicates the sample is a field blank, and the date the sample was collected (e.g., FB-7/24/97). Blind duplicates will be designated with a fictitious sample identification (e.g., the blind duplicate for GW-29 may be labeled GW-301). Samples collected for matrix spike (MS) and matrix spike duplicate (MSD) analyses will have the same designation as their associated environmental sample, except that an MS or MSD will follow the sample designation, e.g., GW-29 MS or GW-29 MSD. GROUNDWATER SAMPLING EQUIPMENT AND PROCEDURES EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-9 Pre-Sampling Procedures. Prior to sampling, each monitoring well will be checked for proper identification, and the well head will be examined for signs of tampering or damage. All indications of tampering or damage will be recorded and reported to the DCP. The sampler will prepare a Groundwater Sampling Sheet (Figure B.4-2) and a complete set of sample containers prior to sampling each well. All of the samples will be collected in new, and certified clean (by manufacturer), sample containers provided by the analytical laboratory. The analytical methods, and the container types and preservatives for each analysis type are listed in Table B.4-2. A label will be placed on each sample container submitted for analysis and will include the following information:  Project name and location  Field sample identification  Date and time the sample was collected  Preservative (if applicable)  Sampler’s initials  Analysis type Equipment. All compliance groundwater monitoring wells at the EnergySolutions facility have dedicated PVC and Teflon® bladder pumps with Teflon® lined, polyethylene tubing. Should additional monitoring wells be required for future monitoring, these new monitoring wells also will be equipped with dedicated bladder pumps and tubing. Depth to groundwater will be measured and recorded as previously discussed. Pre-Sampling Purging. To ensure the groundwater samples are representative of the aquifer, a minimum of three casing volumes of groundwater will be purged using the EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-10 dedicated bladder pump. The following procedures will be used to calculate the volume of water to be purged from each monitoring well:  The height of the water column in the well will be determined by measuring the static water level and the total well depth according to the methods previously described.  The volume of water to be purged from the monitoring well will be calculated using the height of the water column in the well casing as follows: Total Purge Volume: V = 3(V ) x 7.48 gal /fttc3 where: Vt = Total Purge Volume (gallons) Vc = Volume of water in well casing (ft3) Casing Volume: Vc = r12h1 where: Vc = Casing Volume (ft3) r1 = Inside radius of monitoring well casing (ft) h1 = Height of water column (i.e., total well depth minus static water level depth) (ft) If there is insufficient groundwater recharge to evacuate three casing volumes from the well, it will be evacuated to dryness, then sampled after the well has recovered to 80 percent of the static water level. If the well becomes dry before all sample containers are filled, then the remaining sample containers will be filled after the well recharges sufficiently. Purge volume calculations and the actual purge volume removed from each well will be recorded on the Groundwater Sampling Sheet. EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-11 Water Quality Parameter Measurements. To ensure the groundwater samples are representative of the aquifer, specific conductivity (SC), pH, temperature, dissolved oxygen (DO), and reduction/oxidation (redox) potential (Eh) will be monitored using a flow-through cell during pre-sampling purging. In addition, SG will be measured on an annual basis after purging is complete in each well. SG measurements will be made in the field using a hydrometer. Before sampling is initiated, a minimum of three casing volumes will be purged from the well and three consecutive water quality measurements will meet the following criteria:  Specific conductivity =  3 percent  pH =  0.1 units  Temperature =  1C If the criteria listed above are not met after three casing volumes have been removed from the well, the Groundwater Manager will be contacted to determine what corrective actions, if any, should be taken prior to sampling, or purging can continue until water quality measurements stabilize. All of the water quality measurements will be recorded on the appropriate Groundwater Sampling Sheet. The appearance of the discharge water will also be recorded on this sheet. Purge Water Disposal. Purge water evacuated from all wells is to be discharged into the Mixed Waste Wash Pad sump or into one of the Mixed Waste Evaporation Tanks. EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-12 ENVIRONMENTAL AND QA/QC SAMPLE COLLECTION Environmental Samples. Groundwater samples will be collected directly into the appropriate sample container from the discharge line of the dedicated bladder pump. For all samples, the sample bottles will be filled in the order of compound volatility or stability as follows: 1. Volatile Organic Compounds (VOC) 2. Semi-Volatile Organic Compounds (SVOCs) 3. Inorganics/Anions 4. Total Dissolved Solids (TDS), Total Suspended Solids (TSS) 5. Sulfides/Cyanide 6. Metals/Cations 7. Radiological Parameters The analytical methods for this program, and the associated sample containers and preservatives are listed on Table B.4-2. For groundwater samples collected for VOCs from the bladder pumps, the discharge rate of the pump will be reduced to the extent possible to allow gentle filling of the sample bottles without aeration. The VOC sampling flow rate will be measured and documented on the sampling field sheet immediately prior to sample collection for VOCs, at least once daily, on all days when VOC samples are collected. Immediately after VOC sample collection, sample containers will be placed in a cooler containing ice in order to meet the VOC preservation requirements. Quality assurance/quality control samples for these sampling programs include trip blank, field blank (for RCRA sampling), blind duplicate, matrix spike, and matrix spike duplicate samples. These samples will be collected as described below. Trip Blanks. Trip blanks will be prepared by the laboratory prior to sampling and will consist of three 40 ml glass bottles filled with preserved reagent grade (High Pressure Liquid Chromatography [HPLC]) water. The bottles will be filled so that there is no EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-13 headspace and will be capped with a Teflon® septum. Trip blanks will be included in each cooler containing samples scheduled for VOC analysis. Field Blanks. Field blanks (Pour Blanks) are collected during RCRA sampling and consist of laboratory provided reagent grade water. During the sampling process, water supplied by the laboratory in a certified clean, new bottle is poured into at least three, 40 ml VOC bottles. The VOC bottles should then be capped so that no air is present. Field blanks are stored in the same sample cooler as other VOC samples. Blind Duplicates. A blind duplicate sample is a single grab sample that is split into two samples during collection. For samples collected for VOC analysis, the environmental sample will be collected from one pump cycle of water, and then the additional vials will be collected from the next two pump cycles. For all other samples, the environmental sample will be collected by alternately filling the environmental sample and the duplicate sample. Typically, the environmental bottle will be filled to one-third the total volume, and then the duplicate bottle will be filled to one-third of the total volume. The bottles will be alternated in this fashion until both bottles are filled. The frequency of collection of blind duplicates will be 1 per 20 samples, or 5 percent. Matrix Spike and Matrix Spike Duplicate Samples. Samples for MS/MSD analysis will be collected for five percent of the total number of samples for each analytical method. The same procedures used to collect blind duplicate samples will be used to collect samples for MS/MSD analysis. CHAIN OF CUSTODY A project-specific Chain-of-Custody (COC) form will be completed and accompany each sample cooler. The COC includes:  Project identification  Project location EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-14  Sample location identification  Sample designation and analysis type  Sample collection date and time  Sample collection technique  Sample matrix All entries will be made in ink and unused portions of the COC form will be crossed out and initialed. Any errors will be corrected by drawing a single line through the appropriate text and then adding the correct text. Any changes will be dated and initialed. An example of the COC that will be used for this project is provided as Figure B.4-3. The original copy of the COC will be signed, placed in a plastic bag, and placed inside of the shipping container used for sample transport. When the laboratory receives the samples, the appropriate laboratory personnel will sign the COC. After the laboratory logs in the samples, the COC will be completed and a copy of the completed COC will be faxed or e-mailed to the DCP or designee within 48 hours. SAMPLE PACKAGING PROCEDURES All groundwater samples will be packaged in coolers containing ice and transported or shipped for next-day delivery to the appropriate laboratory on the same day of collection. In the event that the samples require shipping, the following procedures will be used for packing samples:  The samples will be placed upright in a waterproof metal (or equivalent strength plastic) ice chest or cooler provided by the laboratory.  Ice will be placed in double Ziploc bags (to prevent leakage) and arranged around, among, and on top of the sample bottles. Sufficient ice will be used so that the samples will be chilled and maintained at approximately 4C. EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-15  To prevent the sample containers from sliding around the cooler, the cooler will be filled with inert cushioning material, such as shipping peanuts, additional bubble pack, or cardboard dividers.  The completed COC form will be placed in a waterproof plastic bag and taped to the inside of the cooler lid.  The lid will be secured with strapping tape by wrapping it completely around the cooler.  Signed and dated custody seals will be placed on the cooler in two locations across the opening of the cooler lid. SAMPLE SHIPPING Samples will be hand delivered to AWAL laboratories and shipped to Test America laboratories. The delivery address for AWAL is: American West Analytical Laboratories (ATTN: AWAL Project Manager) 463 West 3600 South Salt Lake City, UT 84115 EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-16 Samples will be shipped to TAR and TAD via overnight delivery service. The delivery address for radiological samples is: Test America Richland (ATTN: STL Project Manager) 2800 George Washington Way Richland, WA 99352 (509) 375-3131 The delivery address for potentially contaminated conventional chemistry samples is: Test America Denver (ATTN: STL Project Manager) 4955 Yarrow Street Arvada, CO 80002 (303) 736-0100 FIELD EQUIPMENT CALIBRATION PROCEDURES Field Parameter Meters. All meters will be calibrated on a daily basis prior to their use, in accordance with the manufacturer’s directions. The meters will also be recalibrated any time drift in the meter is suspected, and the calibration will be checked in the middle of the day (mid-day calibration check) and at the end of each day of use. All calibration information will be recorded on the Groundwater Monitoring Field Instrument Calibration Sheet (Figure B.4-4). Water-Level Sounder. The electric water-level sounder will be checked daily before the beginning of field activities to ensure that it is in good working order. The sounder will be checked for overall appearance (cleanliness, cuts in the tape) and the sounder probe will be placed in water to check for operation. This information will be recorded on the Calibration Sheet. DOCUMENTATION PROCEDURES EnergySolutions Water Monitoring QAP, Revision 98 February 18, 2014June 6, 2025 B.4-17 As discussed in the above paragraphs, all data collected during groundwater sampling will be recorded on the Groundwater Sampling Sheet (Figure B.4-2). The sampling personnel will also maintain a field logbook consisting of a weather resistant, bound, numbered, survey-type book, with non-removable pages. The log book will be updated on a daily basis (during field work) and will include the following information:  The name and location of the job  Personnel onsite  Name and address of the field contact person  The date(s) groundwater sampling was started and completed  Weather conditions  Sampling methodology  Photograph numbers and descriptions (if applicable)  Any deviations from the WMQAP  Observations that may be relevant to the field program. All entries will be made in ink and any errors will be corrected by drawing a single line through the appropriate text and then adding the correct text. Any changes will be dated and initialed. Collection Lysimeter Operation, Maintenance, and Closure Plan June 4, 2025 April 2, 2025June 27, 2011 1.0 GENERAL This plan outlines the procedures for the operation, maintenance, and closure of the collection lysimeters as required by Part 1.E.11 of Ground Water Quality Discharge Permit No. UG W450005 (Permit). The primary purpose of collection lysimeters is to monitor the performance of the bottom liner of the LLR W and Class A cells. If free liquid is detected in the collection lysimeters, it will provide an early warning of leachate migrating toward Groundwater. Collection lysimeters will be constructed using the plans and specifications approved by the Utah Division of Waste Management and Radiation Control (UDWMRC)Radiation Control ( DRC). General collection lysimeter design incorporates a 20 to 25-foot deep manhole with a standpipe or riser just beyond the edge of a disposal cell and a collection pan situated approximately 300 feet from the edge of waste, under the clay liner of a disposal cell. A transfer pipe connects the collection pan to the standpipe. 2.0 OPERATION PLAN 2.1 Monitoring for Free Liquids The standpipe in the manhole will be monitored as follows for the presence of free liquids. • Weekly for the first year after the date of initial waste placement over the lysimeter pan. • Twice per month (on approximately the 1st and 15th of the month) for the second year after the date of initial waste placement. • Monthly thereafter until the final cover is completed over the collection lysimeter. • Annually for the first 5 years after final cover construction; then • Every other year throughout the post-closure monitoring period. The collection lysimeter will be monitored by removing the manhole cover and standpipe end plug. The collection lysimeter is then probed for free liquids using an electronic water level meter. The depth to water measurement is recorded on the Collection Lysimeter Free Liquids Monitoring fom1 form (the Form) provided as Attachment 4 of Appendix J of the Permit if free liquids are detected. Completed forms will be maintained at the site and made available for State inspections as required by Part 11.H and 11.K.2 of the Permit. EnergySolutions Clive Facility Collection Lysimeter Operation, Maintenance, and Closure Plan .April 2, 2025lune 27, 2011 Page 2 of 4 If and when free liquids are detected in a standpipe, the DRC UDWMRC will be notified verbally within 24 hours and in writing within 7 calendar days. Immediately following the initial detection of free liquids, the monitoring frequency will be increased to daily in order to assess the flow rate into the collection lysimeter. Free liquid samples will be taken in accordance with Section 2.3 below. Daily monitoring will continue until otherwise approved by the DirectorExecutive Secretary. Considerations for a request to reduce monitoring frequency will include if the flow rate has stabilized, and quarterly purging and sampling of the lysimeter standpipe are scheduled. The free liquids monitoring frequency will then be decreased to an appropriate monitoring interval following the Director’sExecutive Secretary's approval. Note: Some of the older collection lysimeters have settled since construction, leading to isolated low spots where standing water may collect without draining. Removal of this water to facilitate video inspections does not trigger the increased monitoring frequency requirements. Free liquids will not be allowed to accumulate iIn the standpipe to a level less than 12 inches below the intersection of the transfer pipe. The standpipe will be purged of free liquids when they are detected unless a sampling event is planned, and the volume is being allowed to accumulate to provide adequate sample volume for analysis. Purging will be performed using a dedicated bailer or a peristaltic pump. The volume of water removed from a collection lysimeter will be recorded on the Fonnform. Other information required on the fForm includes the date, time, monitoring personnel, collection lysimeter identification number, the presence of free liquids, a depth to water measurement, the collection lysimeter total depth, and the total volume of water removed. The formFonn must be signed and dated by appropriate monitoring personnel and reviewed by the ManagerDirector of Compliance and Pe1111itting Permitting or designee, prior to transferring custody to Document Control. Water removed from a collection lysimeter and not included in samples will be disposed in an evaporation pond permitted under Part I.E.1 4 of the Permit. or in the Mixed Waste evaporation tanks. 2.2 Confined Spaced Entry Collection lysimeter manhole entry is to be made following applicable procedures as determined by the Safety and Health Department. Collection Lysimeter Operation, Maintenance. and Closure Plan EnergySolutions Clive Facility April 2, 2025June 27, 2011 Page 34 of 4 2.3 Sampling of Free Liquids Free liquid samples will be collected within 24 hours of initial detection as specified in Part l. F.6 of the Permit. Because of the limited amount of water expected to be in the collection lysimeters, samples for analysis will be collected using the following priority list, if less than 1334,720 milliliters (ml) are present. Priority Parameter Sample Volume (ml) 1 Field Parameters - Temperature, pH, Specific Conductivity 100 2 Radiologicals - LARW Suite 1223,000 3 Metals/Inorganics - LARW Suite 500 4 TDS/TSS 500 5 Major Cations and Anions 500 6 Volatile Organic Compounds (VOCs) 3 X 40 TOTAL 3413,720 Any deviation from this priority list must be approved by the DirectorExecutive Secretary. Samples will be collected using either a dedicated bailer or a peristaltic pump. 3.0 MAINTENANCE PLAN The inspection/maintenance procedures for the collection lysimeters will consist of a visual inspection performed annually, starting in the year construction is completed, which includes visually checking the leachate collection manhole and exposed piping for cracks, end plug leaks, shitting, or other damage. The visual inspection will include a video inspection of the transfer pipe that will be accessed from the cleanout port. The video inspection will be recorded on magnetic or optical media and will include checking the transfer pipe for leaking joints, penetrations in the pipe, and cracked or otherwise damaged pi pe sections. If damaged or leaking pipes are discovered, these sections will require repair unless otherwise approved by the DirectorExecutive Secretary. Details of the inspection and maintenance activities will be recorded in a groundwater field notebook containing waterproof paper that will be kept on file at Clive for at least three years following the date of the inspection as required by Part I I.H of the Penni tPermit. These documents shall be made available to State inspection as required by Part 11.K.2 of the Permit. Any observation of structural failure or upset that would compromise the function or performance of the collection lysimeter system shall be reported to the DirectorExecutive Secretary verbally within 24 hours and in writing within 7 calendar days, as required by Part I I.I of the Permit. Collection Lysimeter Operation, Maintenance. and Closure Plan EnergySolutions Clive Facility April 2, 2025June 27, 2011 Page 34 of 4 4.0 CLOSURE PLAN Lysimeter closure will be performed only when one of the following criteria is met, as approved by the DirectorExecutive Secretary: l) Post-closure monitoring has been completed, or the 2) The Lysimeter collection system is damaged beyond repair or the 3) The Lysimeter collection system is permanently abandoned. DRC UDWMRC will be notified at least 7 calendar days prior to lysimeter closure. Any deviation from the following closure method will be approved by UDWMRCDRC prior to lysimeter closure. Lysimeter closure will be accomplished by pressure grouting using a sand, cement, and bentonite slurry mixture. Grouting will be performed from the cleanout port back into the transfer pipe. The volume of the slurry mixture pumped will be measured to determine the extent of the slurry injected into the collection pan and transfer pipe. The standpipe will then be cut off of the transfer pipe and be disposed as Class A waste. The entire manhole shall be removed. The transfer pipe shall be cut off from the outside of the manhole so that manhole removal does not pull it out from beneath the liner. Radiological sampling will be performed to demonstrate that the excavated area meets the release criteria of operating procedure CL-RS-PR-115180, Radiological SurveysRestricted Area Release Surveys, prior to backfilling. Any soils that exceed the limits of this procedure shall be excavated and disposed in the Class A cell. The excavated area where the manhole was removed shall be backfilled in accordance with the LLRW and 11e.(2) CQA/QC Manual, work element "Foundation Preparation".