DRC-2024-006260

July19, 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:
Second Round of Requests for Additional Information
DearMr. Gurr:
The Division of Waste Management and Radiation Control (Division) has received your letter dated July 16, 2024 (CD-2024-147) responding to the initial set of Requests for Information
(RFI) distributed by the Division via letter dated July 12, 2024 (DRC-2024-006180). The Division has reviewed the proposed variance and EnergySolutions’ response to the Division’s RFIs.
Listed below, the Division requires the following items/concerns that must be addressed to support this variance proposal. The numbering corresponds to the initial RFI creation in letter
DRC-2024-006180:
The response to this RFI appears to be sufficient.
See below for Division responses:
Technical specifications have been provided for the Quality Control (QC) Staff. The letter (CD-2024-147)contains the description of the equipment being used by the contractor (Broken
Arrow) and attached is an email correspondence describing the Global Positioning System (GPS) tolerances. Due to lack of a technical data sheets for the GPS guided equipment being utilized
by the contractor to support the claims in the initial variance request letter (CD-2024-128), “enhance the efficiency of the process and the accuracy of the final product”, this response
to the RFI is inadequate.
Due to lack of technical data sheet requested for RFI 2a or ananalysisdiscussing the advantages to support the claims in the variance request letter (CD-2024-128), this response to the
RFI is inadequate. The initial RFI requests a comparison between the current status quo and the proposed use of GPS equipment. The response shall include at a minimum a detailed description
of methodologies in which the GPS equipment will be used and resulting data (i.e. summary of precision of each of the equipment, example of how the contractor’s equipment will maintain
grade throughout operation).
The response to this RFIis inadequate.It is abundantly clear that QC staff will check material lift thickness at a rate of “5 times per 10,000 ft2”. The initial variance request letter
(CD-2024-128) states, “QC shall verify the initial offset of the GPS equipped dozer/grader by using the GPS survey equipment or a tape measure”. It is unclear if or when QC will utilize
GPS survey equipment or a tape measure to verify grade at the dozer. Furthermore, the process outlined in CD-2024-128 does not account for a methodology of verifying potential error
of the GPS unit may have on the earthwork equipment during fill operation. Should the dozer place material (primarily for material lifts that do not have a buy-off survey) for a long
duration without checking the precision at any point during the daily operation, there can be a consequential error in grade when attempting to verify grade on the material lift directly
above or upon completing the as-built survey at the Top of Cover.
The response to this RFI appears to be sufficient.
See below for Division responses:
The response to this RFI appears to be sufficient.
The response to this RFI is inadequate. It is unclear if the methodologies will be applied for “for each lift constructed in Phase VI of the CAW final cover” or “to be performed between
lifts of radon barrier clays”.
The response to this RFI appears to be sufficient, however, the response omits this statement, “An example Daily Construction Report is attached”.An example Daily Construction Report
does not appear to be attached to this CD-2024-147. Furthermore, the Division will discuss additional expectations prior to proceeding with Phase VI Cover Construction.
If you have any questions, please call Carlo Romanoat 385-977-7573.
Sincerely,
Larry Kellum, Section Manager
Division of Waste Management and Radiation Control
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