DRC-2024-006508

August12, 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
DearMr. Gurr:
The Division of Waste Management and Radiation Control (Division) has received your letter dated August 6, 2024 (CD-2024-168/DRC-2024-006456) responding to the initial set of Requests
for Information (RFI) distributed by the Division via letter dated July 12, 2024 (DRC-2024-006180), and the second round of RFIs (DRC-2024-006260) dated July 29, 2024. The Division has
reviewed the proposed variance and EnergySolutions’ responses to the Division’s RFIs.
EnergySolutions has provided in multiple letters details regarding a request for variance to verify lift thicknesses for the geotechnical material lifts for the Phase 6 Class A West
Final Cover Project. Listed below are the letters from both parties during this correspondence in chronological order:
CD-2024-128/DRC-2024-006118 dated June 27, 2024; initial variance request
DRC-2024-006180 dated July 12, 2024; First round of RFIs from the Division
CD-2024-147/DRC-2024-006305 dated July 16, 2024; EnergySolutions Response to the first round of RFIs
DRC-2024-006260 dated July 29, 2024; Second round of RFIs from the Division
CD-2024-168/DRC-2024-006456 dated August 6, 2024; EnergySolutions Response to the second round of RFIs
The Division requested additional information over the course of the review and has conducted in-person meetings with EnergySolutions to discuss this topic. As a result, EnergySolutionsdefined
their intentions, utilized technology, methodology, and justifications to support this variance.
It is understood that the primary intention for this variance will only apply to the material lifts defined as the “Radon Barrier” as defined in the “Class A West Final Cover – Phase
6” drawing set signed and sealed on April 9, 2024. Furthermore, the variance directly affects Specification 148A – Radon Barrier Placement: Lift Thickness and Specification 184 – Drainage
Ditch Imported Borrow: Lift Thickness within the LLRW & 11e.(2) CQA/QC ManualRev 28c (CQA/QC Manual) in that it will include an additional means and methods to verifying lift thickness.
These means and methods will be utilizing construction earthwork equipment equipped with Global Positioning System (GPS) technology to verify “uncompacted thickness” of the material
lifts as required by the CQA/QC Manual. Technical Specifications have been provided throughout this correspondence and EnergySolutions’ has identified the specific technology that will
be implemented. The letter dated August 6, 2024 (CD-2024-168/DRC-2024-006456) exhibits “Method 1” that closely elaborates EnergySolutions’ process for utilizing these means and methods.
“Method 1” also highlights Quality Control efforts to limit errors upon placement of Radon Barrier material. An example Daily Construction Reportwas provided with this letter showcasing
a draft version of recordkeeping Quality Control will be conducting to monitor progress.
The Division agrees with the methodologies and technologies described within this variance request. The Division also agreesEnergySolutions’ claims that “usage of verified GPS guidedequipment
has the ability to ensure uniform lift thickness placement […] Also, the proposed variance will improve the field safetyconditions for the QC Technicians byeliminating the need for the
technicians to walk over loose,slippery surfaces and in proximity with working heavy equipment to place and remove gradestakes”. Due to existing redundancies within the process for final
grading/lift thickness confirmation via a buy-off survey as specified in Specification 159 within the CQA/QC Manual, the Division agrees that discrepancies within the final grade of
the Radon Barrier lifts can be captured and addressed even post-compaction of the lifts.
The variance request is hereby approved with the following understanding and conditions for additional Phase V Final Cover Construction Project requests:
The equipment shall be inspected by the Division during Phase VI Cover Construction for conformance analogouslyto all Specifications within the CQA/QC Manual. Should the Contractor change
equipment during the project, Specification 146 applies with an additional requirement to provide that the equipment conforms to or exceeds the minimum specifications provided within
this variance request.
Letter dated July 16, 2024 (CD-2024-147/DRC-2024-006305) states, “Furthermore, EnergySolutions will demonstrate the proposed process prior to proceedingwith Phase VI final cover construction
(if so desired by the Director)”. A Division representative shall inspect the Daily ConstructionReports for compliance with the CQA/QC Manual and this variance request. The representative
shall provide requests for clarification during the course of the project should the reports not sufficiently highlight this particular construction sequence for verifying lift thickness
in which EnergySolutions shall consider refining their documentation to provide consistent language for future reports.
Should EnergySolutions fail to exercise the processes described within the variance request, the original methodologies described in Specification 148 and 184 of the CQA/QC Manual Rev.
28c remain applicable and shall be exercised.
This variance request shall only be applied to the Radon Barrier material lifts. Other material lifts (i.e. Sacrificial Soil, Filter Zone, Riprap, etc.) within the Final Cover Construction
will not be subjected to this variance.
This variance request shall only be applied to the Phase VI Final Cover Construction Project and will not be an accepted practice in any other construction operation within the facility.
Should EnergySolutions request this particular variance in future phases, the CQA/QC Manual shall be revised, reviewed by the Division, and approved to include these changes.
All other specifications concerning construction and post-construction of theradon barrier and final cover as presented in the referenced plans and specifications remain applicable and
are required to be followed.
If you have any questions, please call Carlo Romano at 385-977-7573.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/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