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HomeMy WebLinkAboutDRC-2025-002200July 15, 2025Matthew R. Schon, Manager, Groundwater and Environmental ProgramEnergySolutions, LLC 299 South Main Street, Suite 1700 Salt Lake City, UT 84111 RE:Groundwater Quality Discharge Permit (Permit) UGW450005 (GWQDP): East Side Drainage Improvements Requests For additional Information DearMr. Schon: The Division of Waste Management and Radiation Control (Division) has reviewed your letter dated June 4, 2025 (CD-2025-118/DRC-2025-001795) seeking approval to construct a new pumping facility located at the existing 1995/1997 Evaporation Pond Lift Station and an additional pipeline to the 2024 Evaporation Pond.Listed below, the Division has generated RFIs to be addressed to support themodifications. Please provide a Construction Quality Assurance/Quality Control (CQA/QC)Plan associated with this design. It should include but not be limited to: abandoning and removing existing outlets (see Sheet C-003), installation of rubsheets, Specifications for the construction of the new “ENVIROBUILDINGS MODULAR BUILDING” and integration with the existing 95/97 Lift Station, specifications for the ball float at the suction pump intake, and CQA/QC processes and personnel involvement. The “TYPICAL DETAILS” exhibited on Sheet C-004 appear to be general specifications regarding pipe installation and burial and do not cover site specific requirements. Please provide clarification within the design that would satisfy Best Available Technology (BAT) requirements and provide proposed language changes within the GWQDP and applicable Appendices: The proposed new pipe layout does not appear to contain a leak detection system nor does the design provide a means for EnergySolutions to detect leakage during operations. Please provide clarification or revise the drawings to satisfy similar requirements set forth in Appendix J within the Permit.Please specify where specifically you intend to incorporate leak the leak detection systems in the new proposed pipes 4a, 5a, and new outfall line 6 to best align with Best Available Technology (BAT) requirements of the Permit. Please provide information regarding the contamination containment within the enclosure. It is not clear within the design drawings where the potential leakage can be managed and discharged. Please provide plans for maintaining the proposed new pipes (new pipes 4a/ 5a, 4C/5B and new pipe 6 outfall lines), and for maintaining BAT requirements to prevent potential wastewater leakage into groundwater. Given the underground location of the pipes, rendering them inaccessible for visual inspection, please outline: How remediation of any leakage would be performed in accordance with BAT. The planned BAT performance criteria for the pipelines. The BAT inspection criteria and frequency for the pipelines. Please revise the drawings or provide a detailed description of the extents of the rubsheets to be used on each of the ponds for the piping to set on. There does not appear to be additional pumps included for the new pipelines from manhole #2 to the 95 and 97 Pond (pipelines 4A/5A to 4C/5B). Please provide justificationsthat have led to this design intention. Please provide additional specifications and details on the enclosure. It is unclear to the Division how this enclosure is designed and how it can achieve BAT contamination containment requirements and provide a structurally sound enclosure for operations within the building. Additionally on Sheet C-006, multiple leaders note “PROPOSED ENVIROBUILDINGS MODULAR BUILDING (CONTACT MIKE WILLIS (800) 521-2665”. Please provide clarification of the purpose of this callout. It is unclear how the proposed additions will integrate with the existing 95/97 Lift Station. Please provide narrative and drawings of how you intend to integrate the proposed new pipes (4a, 5a, and outfall line 6) with the existing infrastructure. Please submit your responses and appropriate reviseddrawing sheets for the Division to complete an assessment of the request. If you have any questions, please contactCarlo Romanoemail at cromano@utah.gov or by phone at 385-977-7573. Sincerely, Jalynn Knudsen, Assistant Director Division of Waste Management and Radiation Control JK/LK/CR/wa Enclosure(s): c:Jeff Coombs, EHS, Health Officer, Tooele County Health DepartmentBryan Slade, Environmental Health Director, Tooele County Health DepartmentEnergySolutions General Correspondence EmailLLRW General Correspondence Email