DRC-2025-000457

Deq submit <[e-mail]>
Fwd: CQA/QC Manual Specification 146, 48-hour Director Notification for Equipment
Change Equivalency
1 message
LLRW DWMRC <[e-mail]>Mon, Feb 10, 2025 at 3:32 PM
To: Deq submit <[e-mail]>
DRC-2024
---------- Forwarded message ---------
From: Carlo Romano <[e-mail]>
Date: Wed, Sep 18, 2024 at 10:36 AM
Subject: Re: CQA/QC Manual Specification 146, 48-hour Director Notification for Equipment Change Equivalency
To: Nick Clarke <[e-mail]>
Cc: Vern C. Rogers <[e-mail]>, Steve D. Gurr <[e-mail]>, Garrett Q. Dutson
<[e-mail]>, Kristina M. Garcia <[e-mail]>, Karen Kirkwood
<[e-mail]>, Treesa Parker <[e-mail]>, Shauna L. Watkins
<[e-mail]>, Todd L. Stewart <[e-mail]>, LLRW DEQ <[e-mail]>,
Larry Kellum <[e-mail]>, Douglas Hansen <[e-mail]>
Good morning Nick,
The Division of Waste Management and Radiation Control (Division) understands that EnergySolutions is requesting
approval for the use of alternate construction equipment to perform the placement of radon barrier material. Specific
equipment was previously approved by the Division based on the demonstration and outcome of rigorous testing and
observation. The approved equipment is described and adopted in two material placement standards identified as
Construction Method TP-2019-2 and Construction Method TP-2021-1. The details of Construction Method Test Pad TP-
2019-2 are described in the EnergySolutions’ report titled “Test Pad TP-2019-2, 1x10-6 cm/sec Radon Barrier and Clay
Liner” submitted by cover letter on August 7, 2019. The details of Construction Method TP-2021-1 are described in the
EnergySolutions’ report titled “Test Pad TP-2021-1, 5x10-8 cm/sec Radon Barrier Construction Report” submitted by
cover letter on February 3, 2022. The Division reviewed and accepted each construction method with a letter dated
August 16, 2019 (DRC-2019-008743) and August 16, 2022 (DRC-2019-008743), respectively.
The justification to utilize alternate construction equipment is based on an equivalency analysis prepared by a Utah
licensed Professional Engineer with EnergySolutions as described in the memos “TP-2019-2 Equipment Equivalency”
(TP-2019-2) and “TP-2021-1 Equipment Equivalency” (TP-2021-1), stamp dated September 11, 2024 (DRC-2024-
006845). The memorandum includes equipment comparison analyses and detailed discussion of how the differences
between the approved and the proposed equipment are equal to or better than the manufacturer reported specifications
for the approved equipment. It is understood EnergySolutions’ contractor, Broken Arrow, will be operating the equipment
discussed in this memorandum.
TP-2019-2
EnergySolutions has proposed replacing the John Deere 850K WLT dozer with the John Deere 950 P-Tier Standard/LGP
dozer. The comparison noted the John Deere 950 P-Tier Standard/LGP dozer provides a larger ground pressure of a
range 6.9 to 10.8 psi depending on the engine type. Based on the minimum projected ground pressure of 6.9 psi, the
ground pressure is approximately 1.11 psi greater than the John Deere 850K WLT at 5.79 psi. The John Deere 950 P-Tier
Standard/LGP dozer also features a similar blade type and travel speeds while boasting a higher SAE Net Rated Power
of approximately +46 KW/60 hp at 1,800 RPM and higher drawbar pull of +203 kN/46,300 lbs at 1.2 mph. Based on these
parameters published in the technical specifications for the equipment, EnergySolutions determined the John Deere 950
P-Tier Standard/LGP dozer is a qualifying equivalent equipment.
TP-2021-1
EnergySolutions has proposed replacing the John Deere 850L WLT dozer with the John Deere 950 P-Tier Standard/LGP
dozer. The comparison noted the John Deere 950 P-Tier Standard/LGP dozer provides a larger ground pressure of a
range 6.9 to 10.8 psi depending on the engine type. Based on the minimum projected ground pressure of 6.9 psi, the
ground pressure is approximately 1.0 psi greater than the John Deere 850K WLT at 5.9 psi. The John Deere 950 P-Tier
Standard/LGP dozer also features a similar blade type and travel speeds while boasting a higher SAE Net Rated Power
2/10/25, 3:43 PM State of Utah Mail - Fwd: CQA/QC Manual Specification 146, 48-hour Director Notification for Equipment Change Equivalency
https://mail.google.com/mail/b/AEoRXRTVTdiWjBZF1D_qm1uIo6l_bO7NRfgic76S8ClRsGCXYkrO/u/0/?ik=adf9d5e615&view=pt&search=all&permthid…1/3
of approximately +30 KW/40 hp and higher drawbar pull of +182 kN/41,000 lbs at 1.2 mph. Based on these parameters
published in the technical specifications for the equipment, EnergySolutions determined the John Deere 950 P-Tier
Standard/LGP dozer is a qualifying equivalent equipment.
EnergySolutions also must consider the Global Positioning System (GPS) technology that will be utilized on the new
dozer due to a variance currently in effect for the Phase 6 Cover Construction Project as approved by the Division via
letter DRC-2024-006508. Although EnergySolutions did not include the Specifications for the GPS equipment to be
utilized in the John Deere 950 P-Tier Standard/LGP dozer, the Division received confirmation from EnergySolutions via
email that the new dozer will be equipped with the exact GPS technology that was approved in DRC-2024-006508. In the
future should EnergySolutions provide an Equipment Equivalency Notification, EnergySolutions must provide language in
the letter to clarify this technical aspect of the dozer. Failure to do so will result in resubmission of the request.
In summary, the Division concurs with EnergySolutions’ equivalency analyses of the alternate equipment proposed are
equivalent or better to the original equipment used for TP-2019-2 and TP-2021-1 and are hereby approved. The Division
as well as the CQA/QC Manual (Revision: 28c) anticipates that alternate equipment can be utilized provided an adequate
engineering justification is prepared documenting the equivalency of the proposed alternate equipment. EnergySolutions
has not requested a change in pertinent materials, nor changes in the steps and procedures.
If you have any questions, please call Carlo Romano at 385-977-7573.
Thank you,

Carlo Romano, PE
Environmental Engineer III
Division of Waste Management and Radiation Control
Phone: [phone] |
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus subject to
Utah GRAMA requirements.
Statements made in this email do not constitute the official position of the Director of the
Division of Waste Management and Radiation Control. If you desire a statement of the
Division Director’s position, please submit a written request to the Director, including copies of
documents relevant to your request.
On Thu, Sep 12, 2024 at 11:25 AM Nick Clarke <[e-mail]> wrote:
See attached letter.

Please let me know if you have any questions.

Thank you,

Nick Clarke
Compliance & Licensing Specialist II
2/10/25, 3:43 PM State of Utah Mail - Fwd: CQA/QC Manual Specification 146, 48-hour Director Notification for Equipment Change Equivalency
https://mail.google.com/mail/b/AEoRXRTVTdiWjBZF1D_qm1uIo6l_bO7NRfgic76S8ClRsGCXYkrO/u/0/?ik=adf9d5e615&view=pt&search=all&permthid…2/3
ENERGYSOLUTIONS
D: 801-649-2157
C: 801-718-5421
[e-mail]

2/10/25, 3:43 PM State of Utah Mail - Fwd: CQA/QC Manual Specification 146, 48-hour Director Notification for Equipment Change Equivalency
https://mail.google.com/mail/b/AEoRXRTVTdiWjBZF1D_qm1uIo6l_bO7NRfgic76S8ClRsGCXYkrO/u/0/?ik=adf9d5e615&view=pt&search=all&permthid…3/3