DRC-2025-000561

February 19, 2025Vern C. Rogers, Director of Regulatory AffairsEnergySolutions, LLC
299 South Main Street, Suite 1700
Salt Lake City, UT 84111
RE:Engineering Inspection Module 9-2024 Close-out Letter – Class A West Embankment Phase 6Final Cover Construction
Radioactive Material License UT2300249
Dear Mr. Rogers:
Throughout this year’s construction season, engineering inspections were conducted by staff of the Division of Waste Management and Radiation Control (Division) at EnergySolutions’ (ES)
Class A West Phase 6 (CAWP-6) Final Cover project located in the Clive area of Tooele County, Utah. This letter summarizes the observations made during these inspection visits focusing
predominately on earthwork construction of the Final Cover design layers. The inspection visits occurred randomly as well as at the discretion of the Division to observe critical operations.
The visits occurred on the following days in 2024: August 22, August 29,September 5, September 23, October 1, October 10, October 28, and November 18. Also, an inspection and close-out
meeting preceded the preparation of this letter on January 24, 2025.
The Class A West embankment is a Low-Level Radioactive Waste embankment that is licensed to operate in accordance with Radioactive Material License UT2300249 issued January 25, 2008
and subsequently amended by Amendment 28 dated October 2024. Though amended during the course of this project, Amendment 28 did not affect the scope. The final cover plans for the CAWP-6Cover
Construction Project are dated February 19, 2024, and the specifications are contained in the LLRW and 11e.(2) CQA/QC Manual, Revision: 28c (CQA/QC Manual). Numerous Quality Control
/Quality Assurance activities occurred during placement of the embankment cover materials.
As mentioned above, in preparation of this engineering inspection close-out letter, the Division performed a series of site visits to observe both on-site construction staging, and placement
activity of the material listed above and to review pertinent quality documentation. While observing the field operations, the Division staff was primarily accompanied by Shauna Watkins,
Quality Assurance Specialist and often by Quality Control representativesMarissa Sotelo, Sherlie Gonzalez, and James Cason. EnergySolutions’CAWP-6 project manager, Todd Stewart, was
included during portions of past inspections as well. The contractor for CAWP-6 has been Broken Arrow Construction.
Radon Barrier Construction
The quality documentation reviewed for the radon barrier cover material addressed many quality specifications including clay borrow material qualification, lift placement, lift thickness,
lift compaction, lift permeability, and surface preparation of the individual radon barrier areas. Each site visit included a review of the most recently completed radon barrier surface,
and as-built survey documentation of the final surface elevation.
Once placement the radon barrier material was completed (or topped-out), a Request forDirector Approval (RFA) was requested by EnergySolutions per Specification 163 of the CQA/QC Manual.
RFAs were distributed by EnergySolutionsvia e-mail and the Division responded similarly. Below is a chart summarizing correspondence by date:
Lots
RFA Received
Approval Sent
DRC #
ARA8
September 30, 2024
October 2, 2024
DRC-2025-000458
J10 to H10
October 3, 2024
October 7, 2024
DRC-2025-000459
B10 to G10
October 3, 2024
October 7, 2024
DRC-2025-000460
ARA9 to ARA10
October 4, 2024
October 9, 2024
DRC-2025-000461
Filter and Erosion Protection Material
The erosion protection material layers were placed after the radon barrier construction was completed. Testing frequencies, placement activities, and other Specifications outlined in
the CQA/QC Manual were also periodically reviewed by the Division during construction.The Division also visually observed installation of each of the layers during each of the aforementioned
site visits.
EnergySolutions submitted a formal notification of completion of CAWP-6 construction activities on December 5, 2024 via email. During the closeout inspection conducted onJanuary 24,
2025, Division staff confirmed that placement of the erosion protective material for CAWP-6 was complete.
As-Built Submission
EnergySolutions submitted the “Class A West Phase 6 Final Cover Construction Report with As-Built Drawings” signed and sealed by Garrett Q. Dutson, PE on January 24, 2024. The Division
reviewed the submitted report to verify consistency of information portrayed and parallelism with observations by Division representatives throughout the course of this construction
project. Upon review, the report and appended drawings appear to accurately depict the construction project activities and completed product with exceptions listed below:
On page 4 of 15 under section 2.1.3, the report indicates, “Fifteen (15) proctors and fifteen (15) classification soil analyses were performed for the radon barrier clay material pertinent
to this Phase”.
The Division, in coordination with the EnergySolutions’ Quality Control and Quality Assurance team, has found that only fourteen (14) of both respective tests were performed for the
Radon Barrier Material. Based on the minimum testing required for 27,944 cubic yards of placed material per Specification 136 of the CQA/QC Manual, this amount of testing completed satisfies
the requirement.

On page 5 of 15 under section 2.1.5, the report indicates, “Sixteen (16) passing permeability tests were performed on the compacted radon barrier”.
The Division, in coordination with the EnergySolutions’ Quality Control and Quality Assurance team, has found that only fifteen (15) permeability tests were performed for the Radon Barrier
Material. Based on the minimum testing required for 27,944 cubic yards of placed material per Specification 151 of the CQA/QC Manual, this amount of testing completed satisfies the requirement.
Despite these anomalies within the text of the submitted report, the construction project was completed within compliance with the CQA/QC Manual. The Division noted of these anomalies
and did not require EnergySolutions to resubmit this package.
Concluding Remarks
In conclusion, the Class A West Cover Construction Project Phase 6 appeared to have operated within compliance with the CQA/QC Manual thus the Radioactive Material License UT2300249.
Due to the above anomalies found in the submitted As-Built Report, the Division recommends that EnergySolutions improves upon communication pipelines between personnel and establish
revision checkpoints to prevent this situation from reoccurring. Submissions will no longer be acceptable should there inconsistencies be identified future engineering reports and resubmission
with revisions will be mandatory.
No other issues were observed during this inspection period.The 2024 Engineering Module 9 CAWP-6Cover Construction inspections are considered closed.
If you have any questions, please call Carlo Romano at 385-977-7573.
Sincerely,
Douglas J. Hansen, Director
Division of Waste Management and Radiation Control
DJH/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