HALEY & ALDRICH, INC. 75 Washington Avenue Suite 1A Portland, ME 04101 207.482.4600 15 March 2018 File No. 128924‐004 Tim Zeichert Project Manager Wisconsin Department of Natural Resources Regional Remediation and Redevelopment Environmental Program 101 S. Webster Street Madison, WI 53703 Subject: Request to Perform Infiltration/Injection at the LaCrosse Boiling Water Reactor 4601 State Hwy 35 Genoa, Wisconsin 54632 Dear Mr. Zeichert: Haley & Aldrich, Inc. (Haley & Aldrich) is submitting this request on behalf of EnergySolutions to the Regional Remediation and Redevelopment (RR) Environmental Program to request permission to perform a limited Dye Tracer Test at the LaCrosse Boiling Water Reactor (LACBWR or Site). The cover letter and fee associated with the request and the Wisconsin Pollutant Discharge Elimination System (WPDES) permit are submitted concurrently with this letter. We are submitting these directly to the RR EPA person to expedite the process per discussions with Mr. Dave Rozeboom. A dye tracer study will be completed to supplement existing groundwater modeling data and to verify the conceptual site model. The purpose of this study is to evaluate if the Reactor Plant, Generator Plant Access (RPGPA) sump is the source for tritium recently detected in groundwater. To conduct this study, one of the following dyes will be introduced (i.e. injected) into an existing excavation along the west side of the reactor building where the sump was previously removed: Fluorescein (fluorescent yellow/green); Rhodamine WT (fluorescent red); Eosine (fluorescent red); or Sulforhodamine (fluorescent pink). A background evaluation will first be conducted to be able to select the dye. If no dyes are detected in the background evaluation, then Haley & Aldrich will select Eosine, as when it is diluted, it has a peach‐ like color that will have less of a visual impact, should it discharge to the Mississippi River. Carbon packets will be installed in up to eight monitoring wells/locations prior to introducing the dye. Once introduced, the sample packets will be replaced weekly and submitted under chain of custody to www.haleyaldrich.com Wisconsin Department of Natural Resources 15 March 2018 Page 2 Ozarks Underground Laboratory of Protem, Missouri for analysis. These data will then be used to evaluate groundwater flow paths and velocity. The dye tracer study is anticipated to begin immediately after permit approval with a one‐time dye introduction of up to 0.5 pounds of dye into the former sump, flushed by up to 200 gallons of potable, non‐chlorinated water. Groundwater and surface water will then be monitored for up to 2 months, or until data are sufficient to better understand groundwater flow paths. Attachment 1 describes the study in more detail and includes the Safety Data Sheets for each of the dyes being considered for this study. If you have any questions, please do not hesitate to contact Nadia Glucksberg at (207) 482‐4623 or Joseph Nowak at (608) 689‐4210. Sincerely yours, HALEY & ALDRICH, INC. Nadia Glucksberg, PG Senior Associate | Lead Hydrogeologist Attachments: Attachment 1 – Cover Sheet and Fee including form 4400‐237 Attachment 2 ‐ Dye Tracer Study Attachment 3 – WPDES General Permit Application HALEY & ALDRICH, INC. 75 Washington Avenue Suite 1A Portland, ME 04101 207.482.4600 15 March 2018 File No. 128924‐004 Tim Zeichert Project Manager Wisconsin Department of Natural Resources Regional Remediation and Redevelopment Environmental Program 101 S. Webster Street Madison, WI 53703 Subject: Cover Letter and Fee for Request to Perform Infiltration/Injection Dear Mr. Zeichert: Haley & Aldrich, Inc. (Haley & Aldrich) is submitting this cover letter and the requested fee of $700 to the Regional Remediation and Redevelopment (RR) Environmental Program Associate (EPA) to request permission to perform an injection test at LaCrosse Boiling Water Reactor (LACBWR). Site Information Site Name LaCrosse Boiling Water Reactor (LACBWR) Address S4651 State Road 35, Genoa, Wisconsin 54632 Responsible Party Contact Information Owner Name EnergySolutions; Joseph A. Nowak Address 4601 State Highway 35, Genoa, WI 54632 Phone Number 608‐689‐4210 Email Address [email protected] Environmental Consultant Contact Information Name & Nadia Glucksberg, PG, LEP Company Haley & Aldrich, Inc. Address 75 Washington Avenue Suite 1A Portland, ME 04101 Phone Number (207) 482‐4623 Email Address [email protected] Should you have any questions, please do not hesitate to contact Nadia Glucksberg at (207) 482‐4623 or Joseph Nowak at (608) 689‐4210. www.haleyaldrich.com Wisconsin Department of Natural Resources 15 March 2018 Page 2 Sincerely yours, HALEY & ALDRICH, INC. Nadia Glucksberg, PG, LEP Program Manager C:\Users\rbansal\Documents\Projects\LaCrosse\Attachment A1 ‐ HAI‐Cover Sheet_DF.docx Dye Tracer Study LaCrosse Boiling Water Reactor Genoa, Wisconsin SCOPE OF WORK A dye tracer study will be completed at the LaCrosse Boiling Water Rector (LACBWR) site to supplement existing groundwater modeling data and to verify the conceptual site model. Specifically, this study will be performed to monitor the groundwater flow direction and rate in the shallow aquifer in the areas from the reactor building to the Mississippi River. The purpose of this study is to confirm if the Reactor Plant, Generator Plant Access (RPGPA) sump is the source for tritium detected in monitoring wells MW‐202A and MW‐203A. These data will also be used to calibrate the groundwater model with respect to the groundwater velocity as well as the potential flux of tritium towards the Mississippi River. The location of the sump and the site’s groundwater monitoring wells are shown on Figure 1. DYE TRACER STUDY PROCEDURES The dye tracer study will be completed to assess the groundwater flow direction and velocity, specifically in the areas between the reactor building and the Mississippi River. This study will supplement the groundwater modeling effort to further refine the existing conceptual site model. To first establish that there are no background dyes present, carbon packets were placed in three of the wells onsite on March 8, 2018. The carbon packets contain granular activated carbon placed in a cloth bag. (Additional description of these packets is presented in Appendix A). The carbon packets will be removed after being submerged for a minimum of seven days, dried to remove residual tritium, and submitted to the laboratory to evaluate background conditions and support dye selection. To monitor the extent the dye travels in the subsurface, carbon packets will then be installed in up to eight monitoring wells/locations, split between shallow‐ and deep‐screened wells, as shown on Figure 2. Prior to introducing the dye to the aquifer, new packets will be installed and replaced at least weekly for approximately four weeks. To introduce the dye into the aquifer, up to 0.5 pounds of dye will be introduced into the existing excavation along the west side of the reactor building where the sump was previously removed. If the excavation still contains standing water, the dye will be added directly to the water and the study will commence. If the excavation is dry, the dye will be added to the soils at the base of the excavation and flushed with a minimum of 200 gallons of potable, unchlorinated water. The selected dye will be one of the following: Fluorescein (fluorescent yellow/green) Rhodamine WT (fluorescent red) Eosine (fluorescent red) Sulforhodamine (fluorescent pink) Page | 1 If no dyes are detected in the background evaluation, then Haley & Aldrich will select Eosine, as when it is diluted, it has a peach‐like color that will have less of a visual impact, should it discharge to the Mississippi River. Safety Data Sheets for each are provided in Appendix B. The carbon packets will absorb the dye in the groundwater. When the packets are removed from the wells, they will be dried onsite to remove any residual tritium. Once surveyed and free‐released by the Radiation Protection group, they will be sent to Ozarks Underground laboratory (OUL) of Protem, Missouri, and analyzed for the type of dye as well as the concentration present within the packet via fluorescence technology. If the groundwater is visibly stained, then there is no need for the lab analysis, and new packets will be installed in down gradient locations. The dye will be introduced to the aquifer by Haley & Aldrich personnel experienced in both handling dyes and working at nuclear power stations. SCHEDULE AND COORDINATION The dye tracer study will begin in March 2018 with a duration of approximately 4‐6 weeks. Haley & Aldrich will work with LACBWR personnel for site access requirements and ensure these activities do not interfere with ongoing site demolition and decommissioning work. STUDY COMPLETION This study will be considered complete once the leading edge of the dye has reached the targeted wells. Additional samples may be collected but will not be required to meet the intentions of this study. It is anticipated that this will take four to six weeks (based on current tritium concentrations) but this time will be confirmed during the study. It is also possible that some dye may become visible along the shore line. Because of this potential, a FAQ sheet has been developed (Appendix C) to support LACBWR public outreach. Please note that the dyes are non‐toxic and photosensitive, therefore they will not be persistent in the Mississippi River. At the conclusion of this Study, Haley & Aldrich will document