DRC-2024-007017

October 2, 2024 CD-2024-209

Mr. Doug Hansen
Director
Division of Waste Management and Radiation Control
195 North 1950 West
Salt Lake City, UT 84114-4880

Subject: Radioactive Materials License UT2300249
Non-Conformance with Controlled Low Strength Material (CLSM) Wet Unit
Weight Testing

Dear Mr. Hansen,

EnergySolutions hereby notifies the Director of the Division of Waste Management and Radiation
Control (Director) of a non-conformance with Specification 86.E of the LLRW and 11e.(2)
Construction Quality Assurance / Quality Control Manual (CQA/QC Manual), revision 28c.
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). Specification 86.E of the CQA/QC Manual reads:

“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)””

A Non-Conformance Report (NCR-2024-0038) has been created to document and track the
corrective actions (attached) associated with this non-conformance. The Clive Facility Engineer
has assessed the non-conformance and recommends that the out of specification Wet Unit Weight
Test be "Used As Is," in line with Specification 23 of the CQA/QC Manual. 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.

If you have any questions about this notification, please contact Nick Clarke at [phone] or
myself at (801)-649-2043.

Sincerely,
For: Steve D. Gurr
Environmental Engineer and Manager

Enclosure
Digitally signed by Nick Clarke
DN: dc=com, dc=energysolutions, ou=North America, ou=Users,
ou=CLUT, cn=Nick Clarke, email=[e-mail]
Date: 2024.10.02 08:25:55 -06'00'
AWA17240215FF CLSM weight out of compliance.
Owning Organization: Waste Management Project/Site: Clive
Initiate Completed By: Cason, James on 09/30/2024
Initiated By: Cason, James Initiated On: 9/30/2024
Submitted On Behalf Of: James M Cason
Procurement Document Number?: No
Hold Tags Applied?: No
Hold Tag Justification:
This is a CLSM lift so a hold tag doesn't apply.
Responsible QA Manager: Curtis R Kirk
NonConforming Item/Service:
PO Line Item Description Serial Number
N/A N/A N/A
Nonconformance:
Number Item/Serial Number Technical Requirement Discrepancy
1 N/A
LLRW and 11e.(2) Construction Quality
Assurance/Quality Control (CQA/QC) Manual:
specification 86.E.
As per specification 86.E in the CQA manual "The
CLSM shall have a wet unit weight in all cases of at
least 100lbs/ft3", the test on 7-3-2024 was under
100lbs/ft3.
QA Validation Completed By: Kirk, Curtis on 09/30/2024
QA Validation: Valid
Resposible Manager: Garrett Quayle Dutson
Disposition Due Date: 10/30/2024
QA Validation Questions:Yes/No Screening Notes Person Notified Date Notified
Licensed Item or Service (NRC, DHEC)?No N/A N/A
10 CFR 71 or 10 CFR 72 Potentially
Reportable?No N/A N/A
10CFR21 Potentially Reportable?No N/A N/A
Significant Condition Adverse to
Quality?No N/A N/A
PAAA Applicable?No N/A N/A
NCR-2024-0038
1 of 9 (NCR-2024-0038)
Implement Completed By: AUTO-GENERATED on 10/01/2024
Licensing Review Task Skipped
QA Review Task Skipped
RM Closure Approval Task Skipped
Disposition Completed By: AUTO-GENERATED on 09/30/2024
NCR Actions
NCRAC-2024-0051 Due Date: 10/30/2024
Date Closed: 10/1/2024
Title: NCR-2024-0038: Action 1
Technical Requirement:
LLRW and 11e.(2) Construction Quality Assurance/Quality Control (CQA/QC) Manual: specification 86.E.
Issue:
As per specification 86.E in the CQA manual "The CLSM shall have a wet unit weight in all cases of at least 100lbs/ft3", the test on 7-3-
2024 was under 100lbs/ft3.
Item or Serial Number(s): N/A
Disposition By: Garrett Quayle
Dutson Disposition: Use As Is
Technical Justification:
The average 28-day compressive strength of CLSM Load 264 of Lift ID AWA17240215FF was 1,018 psi which was over twice the
required CQA/QC value of a minimum 500 psi. A review of the CLSM Testing Form shows that all other required testing (i.e. load
acceptance and flow consistency testing) and the mix amounts were acceptable.
Looking closer at Load 264, the weight of the Measure with CLSM was over 10 lbs lighter than the expected weight. A potential reason
for the low CLSM unit weight could have been potentially the failure to include (i.e. tare out) the weight of the Weight of Measure (i.e.
the weight of the test bucket) or a mistake in recording the value. If that weight of 10.8 lbs is added into the equation the CLSM Unit
Weight becomes 131.5 pcf which is more of an expected CLSM unit weight based upon site experience particularly with such a high
compressive CLSM strength.
By way of comparison, the average 28-day compressive strength of accepted Load 750 of Lift ID AWA17240215FF, poured several
weeks later on 8/22/24, was 900 psi and had a Weight of Measure with CLSM of 43.92 lbs and a CLSM unit weight of 126.2 pcf with
higher flowability than Load 264 and mix characteristics of more sand and cement and pozzolan than the Load 264 sample.
In sum, it appears that the Weight of Measure with CLSM of Load 264 was not accurately recorded on the CLSM Testing Form and the
CLSM unit weight would have passed the CQA 100 psf unit requirement. Regardless, the high and compliant compressive strength of
the load justifies a Use As Is justification for this CLSM load of Lift ID AWA17240215FF.
QA Closure Approval Task Skipped
NCR-2024-0038
2 of 9 (NCR-2024-0038)
NCR-2024-0038: Action 1
Generated From: NCR-2024-0038 Due Date: 10/30/2024
Date Closed: 10/1/2024
Responsible Person: Garrett Quayle Dutson
QA Approval Completed By: Kirk, Curtis on 10/01/2024
Responsible Manager Approval Completed By: Dutson, Garrett on 10/01/2024
QA Review Completed By: Kirk, Curtis on 09/30/2024
Licensing Review Task Skipped
Engineering Approval Completed By: Dutson, Garrett on 09/30/2024
Engineering Review Completed By: Dutson, Garrett on 09/30/2024
EETP Prepare Completed By: Dutson, Garrett on 09/30/2024
Responsible Manager Review Completed By: Dutson, Garrett on 09/30/2024
Initiate Completed By: Kirk, Curtis on 09/30/2024
Issue:
As per specification 86.E in the CQA manual "The CLSM shall have a wet unit weight in all cases of at least 100lbs/ft3", the test on 7-3-2024
was under 100lbs/ft3.
Item or Serial Number(s): N/A
Technical Requirement:
LLRW and 11e.(2) Construction Quality Assurance/Quality Control (CQA/QC) Manual: specification 86.E.
Disposition By: Garrett Quayle Dutson Disposition: Use As Is
Technical Justification:
The average 28-day compressive strength of CLSM Load 264 of Lift ID AWA17240215FF was 1,018 psi which was over twice the required
CQA/QC value of a minimum 500 psi. A review of the CLSM Testing Form shows that all other required testing (i.e. load acceptance and flow
consistency testing) and the mix amounts were acceptable.
Looking closer at Load 264, the weight of the Measure with CLSM was over 10 lbs lighter than the expected weight. A potential reason for
the low CLSM unit weight could have been potentially the failure to include (i.e. tare out) the weight of the Weight of Measure (i.e. the
weight of the test bucket) or a mistake in recording the value. If that weight of 10.8 lbs is added into the equation the CLSM Unit Weight
becomes 131.5 pcf which is more of an expected CLSM unit weight based upon site experience particularly with such a high compressive
CLSM strength.
By way of comparison, the average 28-day compressive strength of accepted Load 750 of Lift ID AWA17240215FF, poured several weeks
later on 8/22/24, was 900 psi and had a Weight of Measure with CLSM of 43.92 lbs and a CLSM unit weight of 126.2 pcf with higher
flowability than Load 264 and mix characteristics of more sand and cement and pozzolan than the Load 264 sample.
In sum, it appears that the Weight of Measure with CLSM of Load 264 was not accurately recorded on the CLSM Testing Form and the CLSM
unit weight would have passed the CQA 100 psf unit requirement. Regardless, the high and compliant compressive strength of the load
justifies a Use As Is justification for this CLSM load of Lift ID AWA17240215FF.
Implementation Task Skipped
Additional Details
Attachments
NCR-2024-0038 CLSM Load 264 support documentation.pdf
NCRAC-2024-0051
3 of 9 (NCRAC-2024-0051)
4 of 9 (NCRAC-2024-0051)
5 of 9 (NCRAC-2024-0051)
6 of 9 (NCRAC-2024-0051)
7 of 9 (NCRAC-2024-0051)
8 of 9 (NCRAC-2024-0051)
9 of 9 (NCRAC-2024-0051)