DRC-2024-006305

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com

July 16, 2024 CD-2024-147

Mr. Doug Hansen, Director
Division of Waste Management and Radiation Control
P.O. Box 144880
Salt Lake City, UT 84114-4880

Re: Response to the Request for Information (RFI) to the LLRW & 11e.(2) CQA/QC Manual
Specification 148 A, Radon Barrier Thickness; Request for Variance to Verify Lift
Thickness Using GPS Equipment Radioactive Material License Number UT2300249

Dear Mr. Hansen:

EnergySolutions hereby responds to a Request for Information received from the Director of
Waste Management and Radiation Control (DRC-2024-006180) related to EnergySolutions’ June
27, 2024 Request (via CD-2024-128) to vary with Specification 148, Verify Lift Thickness Using
GPS Equipment of the LLRW & 11e.(2) CQA/QC Manual (revision 28c).

DIRECTOR’S REQUEST 1: Identify specific numbered specifications affected in this
variance. Please do not include a range (i.e., “Specification 164 through 180”).

EnergySolutions’ Response: Individual specifications affected by this Variance are
provided.
i. Radon Barrier Placement Specification (148 A) 70-foot grid.
ii. Filter Zone (B-Filter & A-Filter) Specification (169) 50-foot grid.
iii. Sacrificial Soil Specification (174) 50-foot grid.
iv. Rock Erosion Barrier (A-Rap & B-Rap) Specification (179) 70-foot grid.
v. Drainage Ditch Specification (184A) 50-foot grid.
vi. Inspection Road Specification (194) 50-foot intervals.

Mr. Doug Hansen
July 16, 2024
CD-2024-147
Page 2 of 4

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com

DIRECTOR’S REQUEST 2: More information is required regarding the GPS units being
utilized. The minimum should be addressed:
a. 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.
EnergySolutions’ Response: The contractor constructing Phase VI of the Class A West
(CAW) Phase VI final cover will be using the following equipment:
1. John Deere 850L Smartgrade Track Dozer
2. John Deere 950K Smartgrade Track Dozer
3. John Deere 872 GP Smartgrade Motorgrader
As is demonstrated in the attached, construction of prior phases of CAW final cover
demonstrates that a tolerance of 0.05 feet can be consistently achieved (well within the
CQA/QC Manual tolerance of ± 0.10 feet and/or ± 0.20 feet, depending on the required
grading specifications).
EnergySolutions’ Quality Control (QC) staff will use the following equipment to verify
compliance with applicable tolerance specifications:
1. Trimble SPS985 GNSS Smart Antenna
2. Trimble SPS986 GNSS Smart Antenna
3. Trimble SPS881 Smart GPS Antenna
4. Trimble TSC7 Controllers (one for each antenna)
Tolerances for the equipment used by QC staff are described in the attached Technical
Specification sheets.
b. Address the level of precision of this machine and compare and contrast the use of
this technology to the current status quo.
EnergySolutions’ Response: QC staff thickness verifications and the precision of the
contractor’s construction equipment far exceed the tolerances historically observed with
the staking method required in the LLRW & 11e.(2) CQA/QC Manual Specification 148
B.

Mr. Doug Hansen
July 16, 2024
CD-2024-147
Page 3 of 4

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com

DIRECTOR’S REQUEST 3: Identify methodologies Quality Control can deploy to verify
that the contractor is operating on properly functioning equipment during fill operations.
How will EnergySolutions prevent a scenario where operations continue for a long duration
to ultimately find 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 verified
at a minimum of once per day or at any time there is a transition from one layer 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
verifying potential 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.

EnergySolutions’ Response: QC staff will daily verify the accuracy of the contractor’s
dozer/grader and verify that the material grade is being construction at a rate of 5 times
per 10,000 ft2.

DIRECTOR’S REQUEST 4: Define the “established surface point” used to verify GPS
precision. Will there be a benchmark used every day throughout the construction season to
calibrate the GPS units?

EnergySolutions’ Response: QC staff will daily compare the accuracy of
EnergySolutions’ and contractor’s equipment GPS systems with Clive’s Control Point
(located in the southwest corner of the Facility site, CP-1) before proceeding with cover
construction activities.

DIRECTOR’S REQUEST 5: The frequency differs for each of the material lifts current
Specifications but consistently describes a “grid” approach to recording measurements.
Please elaborate on the following aspects regarding frequency and testing locations:
a. 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.

EnergySolutions’ Response: QC staff will test all areas listed in the response to the
Director’s first request at a frequency of 5 times per 10,000 ft2.

Mr. Doug Hansen
July 16, 2024
CD-2024-147
Page 4 of 4

299 South Main Street, Suite 1700 ▪ Salt Lake City, Utah 84111
[phone] ▪ Fax: [phone] ▪ www.energysolutions.com

b. 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.

EnergySolutions’ Response: Utilizing AutoCAD® and a previously approved digital
surface, QC staff will daily generate a grid set with 5 points for every 10,000 ft2 for use
by the Trimble TSC7 Controller to verify activities for each lift constructed in Phase VI
of the CAW final cover. QC staff’s list verifications will be document in Daily
Construction Reports. QC staff verification surveys will continue to be performed
between lifts of radon barrier clays.

DIRECTOR’S REQUEST 6: DRC-2024-006180 states “QC will document all inspections
and corrective actions on the Daily Construction Reports.” Please provide an example of this
documentation.

EnergySolutions’ Response: An example Daily Construction Report is attached. Daily
Construction Reports will include statements, such as
• “QC staff verified that GPS-located material was satisfactorily placed by
Dozer (ID here).”
• “Using EnergySolutions’ equipment (ID here), QC staff verified at a rate of 5
times per 10,000 ft2 of material placed, the grade constructed with Contractor
Dozer (ID here).”

Furthermore, EnergySolutions will demonstrate the proposed process prior to proceeding
with Phase VI final cover construction (if so desired by the Director).

Should you have any questions regarding this submission please feel free to contact Nick Clarke
at [phone] or myself at [phone].

Sincerely,

For Steve D. Gurr
Environmental Engineer and Manager

enclosures

Digitally signed by Nick Clarke
DN: dc=com, dc=energysolutions, ou=North
America, ou=Users, ou=CLUT, cn=Nick Clarke,
email=[e-mail]
Date: 2024.07.16 13:39:07 -06'00'
From:[e-mail]
To:Nick Clarke
Cc:Todd L. Stewart; Garrett Q. Dutson; James M. Cason; Vern C. Rogers; [e-mail]; Steve
D. Gurr
Subject:[EXTERNAL] RE: Variance Request for Radon Barrier Thickness Verification
Date:Monday, July 15, 2024 5:26:51 PM
Attachments:image001.jpg
EXTERNAL: This message is from a NON-EnergySolutions sender, please ensure it is from
a legitimate source.
DO NOT click links or open attachments if sender is unknown or the message seems
suspicious in any way.
Nick,

Broken Arrow Inc. will utilize GPS Earthwork Equipment during the Energy Solutions Phase
6 Cover project. Our GPS Equipment as approved by the Clive Site right now is listed
below:

John Deere 850L Smartgrade Track Dozer
John Deere 950K Smartgrade Track Dozer
John Deere 872 GP Smartgrade Motorgrader

Related tolerances reflect GNSS Real-Time Kinematics (RTK) which is 0.10 feet and the
above referenced equipment is RTK enabled. Moreover, our experience shows that we
repeatedly meet 0.05 feet on a consistent basis. This accuracy is still well within the QA
manual tolerance of +/- 0.10 feet and/or +0.20 feet depending on the required grading
specification.

As future projects develop, other equipment will be proposed for use as technology
advances and the manufacturers release updated versions within the arena of Earthwork
Grading Technology. Simply stated, we will only become more accurate with time.

Please call us with any questions.

Regards, Dave

David Cummings | SR. Vice President | Broken Arrow Inc.
8960 Clinton Landing Road | Lake Point | Utah | 84074
O: [phone] | F: [phone] | M: [phone]

From: Nick Clarke <[e-mail]>
Sent: Monday, July 15, 2024 11:26 AM
To: [e-mail]; [e-mail]
Cc: Todd L. Stewart <[e-mail]>; Garrett Q. Dutson
<[e-mail]>; James M. Cason <[e-mail]>; Vern C.
Rogers <[e-mail]>; Steve D. Gurr <[e-mail]>
Subject: Variance Request for Radon Barrier Thickness Verification

Hello Dave & Kirc,

EnergySolutions has requested a variance to the DWMRC for verifying thickness of the
Radon Barrier which includes the clay, rock layers, ditch, and inspection road by the use of
GPS equipped dozer/graders. This variance is being requested due to the safety hazards
associated with QC personnel walking around heavy equipment and uneven surfaces. This
should not only help in minimizing any potential injuries but also enhance the efficiency of
the process and the accuracy of the final product, thus improving overall productivity.

The DWMRC has requested more information on this variance. Some of the information
that they are requesting is to identify the model GPS unit being utilized for the GPS
equipped dozer/grader that will be utilized throughout the construction project. Do you have
this information for what dozer or grader you will be using on the project? We would like to
submit the response letter by tomorrow so if you could please provide this information as
soon as possible that would be great.

Please let me know if you have any questions or concerns.

Thank you,

Nick Clarke
Compliance & Licensing Specialist II
ENERGYSOLUTIONS
D: 801-649-2157
C: 801-718-5421
[e-mail]