DRC-2024-006997

October 2, 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-2024-0024, 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 21, 2024. The NCR documented an event that occurred during CLSM pouring operations particularly
for CLSM Lift AWE18190415FF.According to the letter “OnJuly 18, 2024, upon review of the batch tickets for the 150 psi CLSM poured onAWE18190415FF on September 17, [2019], it was found
that acceptance testing was notperformed for load 20 or at least mistakenly not recorded” 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-2024-0024) 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 10th, 100th and 210th cubic yards poured, as well as all other tests conducted on September 12, 2019 and September 19, 2019 for flow
consistency and compressive strength confirmed in 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 Romanoat385-977-7573.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/CAR/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