DRC-2024-006180

July8, 2024Steve D. Gurr, Environmental EngineerEnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
RE:Radioactive Material License UT2300249: LLRW & 11e.(2) CQA/QC Manual Specification 148 A, Radon Barrier Lift Thickness; Request for Variance to Verify Lift Thickness Using GPS Equipment
Request for Additional Information
DearMr. Gurr:
The Division of Waste Management and Radiation Control (Division) has received your letter dated June 27, 2024 (CD-2024-128) requesting a variance regarding Specification 148A in the
Low-Level Radioactive Waste & 11e.(2) Construction Quality Assurance/Quality Control Manual (CQA/QC Manual). The Specification recites the following:
Thickness for the lift will be established by installing grade poles on at least a 70-foot grid and at all control points (at a minimum, each corner of the area; also, at break lines).
The grade poles must be marked at the appropriate depth to establish the grade. After the grade for the lift has been checked and approved by QC personnel, the grade poles shall be removed.
The variance specifically requests thatEnergySolutionsincludeadditional means and methods to verifyfinal grade of the lift with the use of Global Positioning System (GPS) equipment.
EnergySolutions proposes to implement this technology not only to Specification 148A but also to “Specifications 164 through 180”. EnergySolutions states that utilizing the GPS equipment
is “being requested due to the safety hazards associated with Quality Control personnel (QC) walking around heavy equipment and uneven surfaces. This will not only help in minimizing
any potential injury but also enhance the efficiency of the process and the accuracy of the final product, thus improve overall productivity”. Finally, the letter concludes with a summary
of the methodologies for utilizing the GPS equipment and implementation of Quality Control.
The Division has reviewed the proposed variance. Prior to making a decision on the state of this request, the Division requires the following items/concerns that must be addressed to
support this variance proposal:
Please verify the signatures within variance requestthe letter. All these address Steve Gurr, however, the signature appears to address Nick Clarke.
Identify specific numbered specifications affected in this variance. Please do not include a range (i.e. “Specifications 164 through 180”).
More information is required regarding the GPS units being utilized. The minimum shall be addressed:
Identify the model GPS unit being utilized for “GPS survey equipment” and “GPS equipped dozer/grader” that will be utilized throughout this construction season. Please provide technical
specifications from the GPS unit for the specific make and model and (if applicable) how the GPS unit equips onto the dozer/grader.
Address the level of precision this machine and compare and contrast the use of this technology to the current status quo.
Identify methodologies Quality Control can deploy to verifythat the contractor is operating on properly functioning equipment duringfill operations. How will EnergySolutions prevent
a scenario where operations continue for a long duration to ultimatelyfind that there is an error in the lift thickness? It is understood that grade will be checked "at least five times
over a 10,000 sq ft area" and the “[elevation] shall be verifiedat a minimum of once per day or at any time there is a transition from onelayer or work element to another”. The five
(5) checks solely rely on the assumption that the GPS unit is properly calibrated upon the reading. The primary concern within this process is the lack of verifyingpotential error of
the GPS unit may have on the earthwork equipment during fill operation. This concern is particularly for material lifts that do not have a buy-off survey at the end of lift placement.
Define the “established surface point” used to verify GPS precision. Will there be a benchmark used everyday throughout the construction season to calibrate the GPS units?
The frequency differs for each of the material liftscurrent Specifications but consistently describes a "grid" approach to recording measurements. Please elaborate on the following aspects
regarding frequency and testing locations.
Is EnergySolutions considering a universal check of "at least five times over a 10,000 sq ft area" for all material lifts? The current Specifications consider different frequencies for
different material lifts.
Will lift thickness readings be gathered in a grid formation or a random 5 points within 10,000 sq ft of placed material? If at random points, please provide justifications to the deviation
from the original “grid”-styled method approach for taking measurements.
The letter states “QC will document allinspections and corrective actions on the Daily ConstructionReports”. Please provide an example of this documentation.
If you have any questions, please call Carlo Romano at 385-977-7573.
Sincerely,
Larry Kellum, Section Manager
Division of Waste Management and Radiation Control
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