DRC-2024-006586

August 14, 2024Steve D. Gurr, Environmental Engineer and ManagerEnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
RE:Radioactive Materials License UT2300249
Non-Conformance Report NCR-2024-0025, Non-Conformance with Controlled Low Strength Material (CLSM) TestingFrequency
Dear Mr.Gurr:
This letter is in response to EnergySolutions’ Non-Conformance Report (NCR) dated August 5, 2024. The NCR documented an event that occurred during CLSM pouring operations particularly
for CLSM Lift AWA17240215FF.According to the letter “On June 28, 2024, and July 1, 2024, acceptance testing was not performed for loads 229 and 260 during the pouring of CLSM Lift (AWA17240215FF)”
which does not conform to Specification 86.B.d of the LLRW and 11e.(2)Construction Quality Assurance/Quality Control Manual (CQA/QC Manual). Specification 86.B.d requires EnergySolutions
to test CLSM at a rate of one test per lot in which a lot is defined as 100 cubic yards of poured material. The acceptance testing was not performed within the confines of the delineated
frequency, therefore, a Non-Conformance Report (NCR-2024-0025) was produced to track items associated with the discrepancy. EnergySolutions has assessed the NCR and recommends the that
the CLSM installed during these pours to be “Used As Is”. The Engineer’s technical justification for this recommendation notes that subsequent testing of the 110th cubic yard pour, as
well as all other tests conducted on June 28, 2024, and July 1, 2024, confirmed compliance with the required specifications.
The Division agrees with the assessment to this NCR and corrective action. Due to EnergySolutions’ intent to self-report to the Division of the non-conformance issue and the remoteness
of severity of this scenario, this will not result in any further regulatory action. Although no regulatory action will be undertaken at this time, the Division has noted this occurrence
via internal recordkeeping and it is imperative that EnergySolutions should develop a solution to prevent reoccurrence. A repeat occurrence may result in regulatory action (dependent
on severity) and a review of facility operations may be necessary to reassess any potential systemic issues to cause a reoccurrence.
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/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