DRC-2024-007149

October 16, 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-2024-0038, Non-Conformance with Controlled Low Strength Material (CLSM) Wet Unit Weight Testing
Dear Mr.Gurr:
This letter is in response to EnergySolutions’ Non-Conformance Report (NCR) dated October 2, 2024. The NCR documented an event that occurred during CLSM pouring operations particularly
for CLSM Lift AWA17240215FF.According to the letter “Upon review of the load tickets and CLSM testing forms it was found that the load acceptance test for load # 264 did not meet specifications
for the Wet Unit Weight test (89.9 lb/ft³) for CLSM Lift (AWA17240215FF)” which does not conform to Specification 86.E of the LLRW and 11e.(2) Construction Quality Assurance/Quality
Control Manual (CQA/QC Manual). Specification 86.E requires that “[the] CLSM shall have a wet unit weight in all cases of at least 100lbs/ft³ as determined by ASTM D6023 “Standard Test
Method for Density (Unit Weight), Yield, Cement Content, and Air Content (Gravimetric) of Controlled Low-Strength Material (CLSM)”.Acceptance testing at the time of installation yielded
a result outside of this requirement, therefore, a Non-Conformance Report (NCR-2024-0038) 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 2,640th cubic yard pour, as well as all other tests conducted on August 22, 2024, confirmed in compliance with the required specifications in terms
of compressive strength. Comparisons between Load 264 and Load 750 to justify that despite a lower Unit Weight result observed in Load 264, the 28-day compressive strength value exceeded
Load 750. Furthermore, the justification elaborates on the discrepancy is potentially the result of an error during calculations by Quality Control. This hypothesis was assumed based
on recalculation considering the inclusion of the Weight of Measure where it should have been excluded in certain steps of calculation.
The Division agrees with the assessment to this NCR and corrective action, however, the Division has recorded several NCRs this year (2024) that have concluded with the corrective action
per Specification #23 of the CQA/QC Manual “Used as is”. The Division appreciates EnergySolutions’ intent to self-report to the Division of the non-conformance issue and the remoteness
of severity of this scenario and recommends continuing to do so.
If you have any questions, please call Carlo Romanoat385-977-7573.
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