DRC-2010-004283 - 0901a068801b24c3

State of Utah
GARY R. HERBERT
Governor
GREGORY BELL
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2010-004283
August 2, 2010
Mr. Sean McCandless
Director of Compliance and Permitting
Energy Solutions, LLC.
300 South 423 West, Suite 200
Salt Lake City, UT 84101
Subject: May 26, 2010 EnergySolutions LLRW CQA/QC Manual Revision 25b
Findings and Request for Information.
DRC
Dear Mr. McCandless
We have received your request for review and approval of Revision 25b to the LLRW Quality
Assurance/Quality Control (CQA/QC) Manual dated May 26, 2010. The Division of Radiation Control
(DRC) reviewed the following topics for approval to the (CQA/QC) and our findings follow. The
summary of each group of changes below is listed below in italics and taken directly from the February 4,
2010 ES letter, May 26, 2010 letter, and a June 3, 2010 Rev 25 meeting. In addition, two new CQA/QC
improvement have been add to the end of this request for information for rock cover sampling, testing
interval, and correcting the corresponding ASTM testing procedure.
The DRC requests additional revision to the following CQA/QC Plan item numbers and topics previously
outlined in the March 30, 2010 DRC Request for Information (RFI) letter. Specific infonnation needs for
each of these item is provided in the pages that follow:
16) Clarify Work Element - Waste Placement, specification "Frozen Material" (pages 44, and 47).
18) Permit vertical placement of drums at the Containerized Waste Facility in Work Element -
Containerized Waste Facility Waste Placement, specification ^'Containerized Waste Placement", item 7
(pages 57).
20) Clarify transition from top of waste buy-off to temporary cover construction in Work Element -
Temporary Cover Placement and Momtoring. (pages 64).
22) Revise Table 2, Material Specifications for Portland Cement CLSM to remove maximum range for
cement and to remove specification for pozzolan (pages 103),
23) Rock cover sampling interval specification from 100,000 yd'^3 to 10,000 yd'^3 in Work Element-
Filter zone, and Work Element - Rock erosion barrier.
24) Rock cover ASTM for sodium absorption from C-I28 to C-I27 in Work Element - Filter zone, and
Work Element - Rock erosion barrier.
195 North 1950 West - Salt Ulce City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
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For completeness, please include the complete Rev. 25c of the CQAQC in red/line PDF format in, i.e.,
Tables 2 and 3, Figures 1 thru 8, and Appendices B and C. The DRC would like the complete document in
PDF format for every revision submittal.
Specific DRC Findings
\) Appendix A, CQA/QC Documentation Forms, is replaced in its entirety.
EnergySolutions proposal is to replace forms in their entirety. The DRC feels that this is an acceptable
request and the new forms appear to meet compliance needs. Please carry these changes forward in
revision 25c.
2) Revise fding requirements under Work Element - Document Control (pages 4).
EnergySolutions proposal is to eliminate the current requirements in the CQAQC, and to send a copy of
the original documentation to EnergySolutions main office. The DRC feels that this is an acceptable
request because of license requirement of Utah Administrative Code (UAC R313-15-1101 thm 1111)
requires original documents be retained, but does not specify the exact physical location of said storage.
Further, the electronic database will still be available at the main office on-site, which appears to also
comply with the requirements. Please carry these changes forward in revision 25c.
3) Clarify cold weather re-testing requirements under Work Element - Clay Liner Placement, specification
"Cold Weather Placement of Clay Liner (pages 19)."
EnergySolutions proposes that density and permeability testing be appropriate in the situation that cold
weather re-testing is required in this "Cold Weather Placement of Clay Liner" CQA/QC work element.
The DRC feels that this is acceptable, because permeability of clay can be changed by frozen material.
Please carry these changes forward in revision 25c.
4) Update procedural references in Work Element - Waste Placement with Compactor (pages 24).
EnergySolutions proposes revision of their procedure numbering system (former SOP ENG 3.8). The DRC
feels that this is an acceptable revision to change the numbering system to SOP CL-QC-PR-038. No other
changes to the content of this document were apparent. Thank you for implementing this upgrade to the
CQA/QC. Please carry these changes forward in revision 25c.
5) Clarify the point of compliance for wheel passes in Work Element - Waste Placement with Compactor,
specification "Compaction with CAES" (pages 25).
It is agreed that the (CQA/QC) Manual is in need of correction for a disconnect between the specification
and quality control section of the Waste Placement "Compaction with CAES" work element. Please re-
write the quality control section and/or the specification to resolve the disconnect in the CQA/QC. A
meeting was also held on March 17, 2010 wherein certain changes to the specifications for this section
were also negotiated. Thank you for incorporating all these changes into Rev. 25b submitted to the DRC
via email on March 22, 2010. In summary, those changes included:
• The percentage of green pixels on a given waste lift area, that meets the compliance criteria (paint green
with the CAES software / system) will increase to at least 90%.
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• The Specification section and the Quality control Section will be revised to be consistent with one
another
• The previous requirement of four machine passes will be replaced by the new 90% green pixels
requirement for each lift, listed above.
• Additional restriction(s) to prevent clustering of non-green pixels (visual observation of each waste lift
to determine a homogeneous condition for debris).
Please carry these changes forward in revision 25c.
6) Clarify acceptable materials to cover materials susceptible to wind dispersal in Work Element - Waste
Placement with Compactor, specification "Debris Placement with the Compactor" and to Work Element-
Waste Placement, specification "Debris Quantity in Soil Waste Lifts " (pages 27, and 33).
It is agreed that the (CQA/QC) Manual is in need of clarification between the two different reference
specifications found on pages 27, and pages 33. "In-Cell Bulk Disposal" (pp. 27 - 33?) includes a
requirement for soil (clean fill), soil like waste, and commercial fixatives, as approved cover, to control
waste material susceptible to wind dispersal. The referenced specification on pages 27- 33 was revised to
include these covers. The DRC feels the following language defining "secure" and explaining how QC
staff will verify "secure" in their inspections is an improvement to the QCA/QC. Therefore; at this time
work element can be approved as written in Revision 25b of the (CQA/QC). Please carry these changes
forward in revision 25c.
7) Add an allowance for bags of compressible debris to be larger than 10 inches in all dimensions before
compaction to Work Element - Waste Placement with Compactor, specification "Debris Size " and Work
Element - Waste Placement, specification "Debris Size . (pages 27, and 34).
It is agreed that when disposing of bags of compressible debris, covering with soil prior to compacting is
the preferred approach for reducing the potential for wind dispersal with the CAES system. However; it
appears impossible to determine if the content of a bag is compressible or uncompressible without opening
the bags. Considering both sides of this issue the DRC feels that it is appropriate to limit the allowance for
not opening bagged waste to only those bags clearly manifested by the generator with asbestos-containing
material. Therefore; at this time work element can be approved as written in Revision 25b of the
(CQA/QC). Please carry these changes forward in revision 25c.
8) Add specification "Snow Removal" to Work Element - Waste Placement with Compactor; and clarify
snow removal requirements under Work Element - Waste Placement, specification "Snow Removal"
(pages 27).
EnergySolutions proposes revision of the "Snow Removal" Work Element to clarify the point of
compliance for snow removal. In previous CQA/QC revisions, there was no such wording or requirement
to govern this situation. The DRC feels that this is an acceptable revision; however, during the June 3,
2010 meeting it was agreed that language on ice would be added to this work element to better address
frozen waste material. Thank you for implementing this upgrade to the CQA/QC in Rev. 25b.
9) Remove outdated reference lo a "lift summary form" from Work Element - Waste Placement,
specification "Lift Identification " (pages 28).
EnergySolutions proposes removal of outdated reference to a "lift summary form" from Work Element -
Waste Placement (specification "Lift identification") because no such form exits currently. The DRC feels
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that this is an acceptable revision because lift approval forms are used instead. Thank you for
implementing this upgrade to the CQA/QC. Please carry these changes forward in revision 25c.
10) Clarify re-testing requirements for failed compaction testing at Work Element -Waste Placement,
specification "Compaction " (pages 29-30)..
EnergySolutions proposes clarifying the testing location of where repeat testing is to be performed. The
DRC feels that this is an acceptable revision to test both locations. Thank you for implementing this
upgrade to the CQ/VQC. Please carry these changes forward in revision 25c.
11) Clarify fiill calculation requirements at Work Element - Waste Placement, specification "Debris
Quantity in Soil Waste Lifts" (pages 33).
The DRC requests specific information on how compacted volumes of final waste lots/lifts will be
calculated based on un-compacted non-uniform debris volumes. The DRC agrees that the specification can
be based on compacted volume and the way to show compliance with this speciation is to use un-
compacted waste volumes. Also, during our March 17, 2010 meeting it was agreed that the ES field
inspection and fill-volume calculation process, would ensure homogeneous debris distribution across the
lift by a visual observation process. Thank you for providing details on how this will be done and
documented. Therefore; at this time work element can be approved as written in Revision 25b of the
(CQA/QC). Please carry these changes forward in revision 25c.
12) Clarify construction and testing sequence at Work Element - Waste Placement, specification "Resin
Lifts " (pages 34).
EnergySolutions proposes revised language that is more restrictive than it was written previously, and
reflects standard engineering field practices. The DRC feels that this is an acceptable revision to require
resin and soil compaction, lift approval after at least 2-inches of native soil cover has been placed; and
removal of words "synthetic soil" replaced with the more descriptive "blended resins" in the work element.
Therefore; at this time work element can be approved as written in Revision 25b ofthe (CQA/QC). Please
carry these changes forward in revision 25c.
13) Clarify CLSM pyramid controls at Work Element - Waste Placement, specification "CLSM pyramid"
(pages 36).
EnergySolutions proposes editorial change to the CQA/QC manual to better describe "CLSM pyramid"
lift locations. The DRC feels that this is an acceptable revision, because the revised language better
describes the 19.5 foot pyramid offset between one CLSM hft and the lift immediately below it. Thank
you for implementing this upgrade to the CQA/QC. Please carry these changes forward in revision 25c.
14) Clarify minimum CLSM testing requirements in Work Element - Waste Placement, specification
"Portland Cement or Fly Ash CLSM Design Specifications", item d. (pages 38).
EnergySolutions proposes a change to the QC language to require at least one set of compressive strength
cylinders be cast for lifts smaller than 200 cubic yards. The DRC feels that this is an acceptable revision.
Thank you for implementing this upgrade to the CQA/QC. Please carry these changes forward in
revision 25c.
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15) Incorporate prior worker safety andALARA variances relating to asbestos, beryllium, and hot particle
wastes for debris-filled containers placed in CLSM at Work Element - Waste Placement, specification
"CLSMPours with Debris-Filled Containers " (pages 39).
EnergySolutions has proposed several past variances to the CQA/QC Manual for "CLSM Pours with
Debris-Filled Containers" specific to asbestos, beryllium, and hot particle wastes in debris-filled containers
placed in past CLSM pours. In these cases, ES asked that asbestos, beryllium, and hot paticle have special
requirements for disposal of asbestos and beryllium bearing wastes, the DRC feels that this is an acceptable
revision considering approval of past requests for variances. Also, considering "hot particle" wastes, and
maximum contact dose rate terms are now defined in the CQA/QC. Thank you for implementing this
upgrade to the CQA/QC. Please carry these changes forward in revision 25c.
16) Clarify Work Element - Waste Placement, specification "Frozen Material" images 44, and 47).
EnergySolutions proposed that the prior language was outdated, since no waste is placed directly on clay
liner. The DRC agrees that waste is not allowed directly on clay liner; however, the DRC feels that
placement of frozen material shall not be allowed on clay liner because frozen material will not compact
properly (and lead to excess void space later), and large ice pieces could damage the liner below.
Therefore; at this time work element is recommended to maintain all the "Frozen Material" language
(found in Revision 24e) but also include language for all frozen material (not just waste). In addition,
please add language about ice in the snow removal for waste placement work element. Please modify the
CQA/QC manual or address and resolve these issues in Rev. 25c.
17) Remove minimum height requirement for standard liners from Work Element -Containerized Waste
FacUity Waste Placement, specification "Definitions" (pages 53).
EnergySolutions proposes that the minimum height requirement for standard liners in Work Element -
Containerized Waste Facility Waste Placement be changed from between 5 to 6.65 feet tall to up to 6.65
feet tall. The DRC agrees that previously approved test pads on standard liners achieved 85% sand
compaction when the volume of the container was under 215 cubic feet threshold set by the AMEC report
of October 2, 2001. As a result, the DRC feels that this is an acceptable revision. Thank you for
implementing this upgrade to the CQA/QC. Please carry these changes forward in revision 25c.
18) Permit vertical placement of drums at the Containerized Waste Facility in Work Element -
Containerized Waste Facility Waste Placement, specification "Containerized Waste Placement", item 7
(pages 57).
EnergySolutions proposed vertical placement of drums at the containerized waste facility - Containerized
Waste Facility Waste Placement. The DRC agrees that vertical placement of liners is acceptable through
the previously approved test pads on standard and large liners to achieve 85% sand compaction. However,
the DRC approved past test for drums was done with horizontal drum (pyramid-style) placement at the
perimeter of the first CWF layer per the October 2, 2001 CWF- Response to Interrogatories page 2. Hence,
your proposal is outside the analyzed condition. However, the DRC would consider drum and B-25
placement in the center of the pyramid provided the drums and B-25 boxes are placed in a CLSM pour
Therefore; at this time work element can not be approved as written in Revision 25b ofthe (CQA/QC).
Another option would be to provide additional geotechnicai engineering justification and a new test pad
demonstration to show how a vertical drum geometry would provide equivalent, long-term embankment
stability (as shown by previous ES geotechnicai engineering analysis and horizontal drum test pad work,
later approved by the DRC).
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19) Permit broader use of CLSMfor fill within the initial lift of the container pyramid at Work Element -
Containerized Waste Facility Waste Placement, specification "Pyramid Controls" (pages^SS).
EnergySolutions proposed that the following language, "(for any larger debris and oversized DOT
containers)" be deleted. The DRC accepts the proposed change to simply replace the backfill sand element
of the CWF pyramid with CLSM. In addition, no change is proposed to the specifications for other CWF
work elements; and replacement of backfill sand with CLSM is not expected to have any effect on these
elements. Thank you for implementing this upgrade to the CQA/QC. Please carry these changes
forward in revision 25c.
20) Clarify transition from top of waste buy-off to temporary cover construction in Work Element -
Temporary Cover Placement and Monitoring, (pages 64).
EnergySolutions proposes that language be changed from the current requirement that the temporary cover
be placed within 90 days of"... any survey that determines top of waste elevation and grades for each lot."
Instead ES proposes the trigger be within 90-days of DRC approval (under Work Element - Waste
Placement, specification "DRC Approval"). . In addition, the DRC is satisfied with the language "DRC
shall be notified in writing at least 48 hours in advance of the start up of temporary cover placement.
Please note that EnergySolutions controls and tracks the current waste elevations trigger compared to top
of waste elevations. The DRC recommends staying with the original Rev 24 language or no change to the
CQA/QC.
21) Add reference to ASTM C-l36 at Work Element - Rock Erosion Barrier, specification "Gradation "
(pages 88).
EnergySolutions proposes adding reference ASTM G-136 to Work Element - Rock Erosion Barrier,
specification "Gradation" that is better applicable method, as it applies to smaller aggregates. The DRC
feels that this is an acceptable revision, because ASTM C-l36 is a standard test method for Sieve Analysis
of Fine and Coarse Aggregates. Thank you for implementing this upgrade to the CQA/QC. Please carry
these changes forward in revision 25c.
22) Revise Table 2, Material Specifications for Portland Cement CLSM to remove maximum range for
cement and to remove specification for pozzolan (pages 103).
EnergySolutions proposes eliminating the maximum range for cement and all ranges for pozzolan (fly-
ash), which will provides greater operational flexibility in mix design to met flowability and strength
requirements. The DRC feels that this is an acceptable revision, in terms of cement content, because
cement is a controlling factor for CLSM strength. However, after review ofthe May 26, 2010 response,
the DRC requests the maximum limit on Pozzolan be retained in Table 2 (375 Ib/CY) to control the
maximum allowed fly ash in the mix design, and avoid unnecessary loss in CLSM strength. Ahematively,
the DRC would also consider additional ES justification for how high percentage of fly ash can be without
adverse effects on the performance of the CLSM material.
23) Rock cover sampling interval specification 100,000 yd^3 to 10,000 yd''3 in Work Element - Filter
zone, and Work Element - Rock erosion barrier.
The DRC requests an improvement to Work Element - Filter zone, and Work Element - Rock erosion
barrier to change the specification column from 100,000 yd^3 to 10,000 yd^3 sampling interval. This
change will make the QCA/QC consistent with the Quality Control column, and the NRC design basis.
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24) Rock cover ASTM for absorption from C-l 28 to C-l27 in Work Element - Filter zone, and Work
Element - Rock erosion barrier.
The DRC request an improvement to Work Element - Filter zone, and Work Element - Rock erosion
barrier to change the ASTM specification for sodium absorption from C-128 to C-127. ASTM C-128 is a
testing procedure for fme aggregate and ASTM C-127 is a coarse aggregate specification. The DRC feels
that the coarse aggregate specification is more appropriate for filter zone and rock erosion barrier.
If you have any questions or comments, please contact David Esser at [phone].
Sincerely,
David Esser
DICE: de
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