October 1, 2009 

Thomas Gutmann, Director 

Waste Disposition Programs Division 

U.S. Department of Energy 

Savannah River Operations Office 

P.O. Box A 

Aiken, SC 29802 

SUBJECT: U.S. NUCLEAR REGULATORY COMMISSION AUGUST 10-14, 2009 ONSITE 

OBSERVATION REPORT FOR THE SAVANNAH RIVER SITE SALTSTONE 

FACILITY 

Dear Mr. Gutmann: 

The enclosed report describes the U.S. Nuclear Regulatory Commission’s (NRC’s) onsite 

observation activities on August 10-14, 2009, at the Savannah River Site (SRS) Saltstone 

Facility. This onsite observation was conducted in accordance with Section 3116 of the Ronald 

W. Reagan National Defense Authorization Act for Fiscal Year 2005 (Sect. 3116), which 

requires NRC to monitor disposal actions taken by the U.S. Department of Energy (DOE) for the 

purpose of assessing compliance with the performance objectives set out in 10 CFR Part 61, 

Subpart C. The activities conducted during the site visit were consistent with those described in 

the NRC’s monitoring plan for salt waste disposal at SRS (dated May 3, 2007) and NRC’s staff 

guidance for activities related to waste determinations (NUREG-1854, dated August, 2007). 

This onsite observation at SRS was focused on assessing compliance with all four of the 

performance objectives in 10 CFR Part 61, by observing DOE’s review process of the 

performance assessment for the Saltstone Disposal Facility at the SRS. 

 

NRC continues to conclude that there is reasonable assurance that the applicable criteria of 

Sect. 3116 can be met if key assumptions made in DOE’s waste determination analyses prove 

to be correct. In accordance with the requirements of Sect. 3116 and consistent with NRC’s 

monitoring plan for the Saltstone Disposal Facility, NRC will continue to monitor DOE’s disposal 

actions at SRS. The monitoring activities are expected to be an iterative process. Several 

onsite observation visits and technical reviews may be necessary in order to obtain the 

information needed to close all of the current open issues, as well as issues that may be opened 

in the future. 
T. Gutmann 2 

If you have any questions or need additional information regarding this report, please contact 

Nishka Devaser of my staff at (301) 415-5196. 

 Sincerely, 

 /RA/ 

 Patrice Bubar, Deputy Director 

 Environmental Protection 

 and Performance Assessment Directorate 

 Division of Waste Management 

 and Environmental Protection 

 Office of Federal and State Materials 

 and Environmental Management Programs 

Enclosure: 

NRC Observation Report 

cc w /encl: 

S. Wilson 

Federal Facilities Liaison 

Environmental Quality Control Administration 

South Carolina Department of Health 

 and Environmental Control 

2600 Bull Street 

Columbia, SC 29201-1708
T. Gutmann 2 

If you have any questions or need additional information regarding this report, please contact 

Nishka Devaser of my staff at (301) 415-5196. 

 Sincerely, 

 Patrice Bubar, Deputy Director 

 Environmental Protection 

 and Performance Assessment Directorate 

 Division of Waste Management 

 and Environmental Protection 

 Office of Federal and State Materials 

 and Environmental Management Programs 

Enclosure: 

NRC Observation Report 

cc w /encl: 

S. Wilson 

Federal Facilities Liaison 

Environmental Quality Control Administration 

South Carolina Department of Health 

 and Environmental Control 

2600 Bull Street 

Columbia, SC 29201-1708 

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ML092710477 

OFC DWMEP:PM DWMEP:LA DWMEP:BC DWMEP:BC DWMEP:PM 

NAME NDevaser AWalker-Smith CMcKenney GSuber NDevaser 

DATE 9/29/09 9/29/09 9/29/09 09/30/09 09/30/09 

OFFICIAL RECORD COPY
Enclosure 

U.S. NUCLEAR REGULATORY COMMISSION AUGUST 10 - 14, 2009 ONSITE 

OBSERVATION REPORT FOR THE SAVANNAH RIVER SITE SALTSTONE FACILITY 

EXECUTIVE SUMMARY 

The U.S. Nuclear Regulatory Commission (NRC) staff conducted its sixth onsite observation visit 

to the Saltstone Facility at the Savannah River Site (SRS) on August 10-14, 2009. The intention 

of this visit was to focus on all four performance objectives by observing the onsite portion of the 

Low-Level Waste Disposal Facility Federal Review Group (LFRG). The LFRG performs an 

extensive review of each performance assessment (PA) prepared by a U.S. Department of 

Energy (DOE) facility and as such is a critical step in the process of preparing the PA. This 

report provides a description of NRC onsite observation activities and identifies NRC 

observations from the visit. Based on the results of the visit, the NRC continues to have 

reasonable assurance that the performance objectives of 10 CFR 61 can be met in the areas 

reviewed. 

There are no new open issues resulting from this observation. A summary of the staff’s 

observations and conclusions is provided below: 

Performance Assessment Process Review 

• The staff observed the LFRG review of the revised performance assessment for the 

Saltstone Disposal Facility. The review team consisted of relevant subject matter experts 

employed by DOE, either as federal employees at DOE (Headquarters or another DOE 

facility) or as technical experts, contractors, or academics associated with one of these 

locations. The team reviewed the draft PA and associated documents for 30 days prior to 

the start of the onsite review, which consisted of four days of additional review, in which team 

members conducted interviews with involved subject matter experts and began preparing 

their respective parts of the LFRG final report. 

• The process observed by the staff seemed thorough and comprehensive. The LFRG vetting 

process provided the NRC staff assurance that public health and safety were appropriately 

considered during the review. The NRC staff, however, will have a better understanding of 

the effectiveness of the LFRG review process once the revised PA has been released and 

provided to NRC. 

1.0 BACKGROUND 

Section 3116 of the Ronald W. Reagan National Defense Authorization Act for Fiscal Year 2005 

(Section 3116) authorizes the DOE, in consultation with the NRC, to determine that certain 

radioactive waste related to the reprocessing of spent nuclear fuel is not high-level waste, 

provided certain criteria are met. Section 3116 also requires NRC to monitor DOE disposal 

actions to assess compliance with the performance objectives in 10 CFR Part 61, Subpart C. 

On March 31, 2005, DOE submitted a “Draft Section 3116 Determination, Salt Waste Disposal 

Savannah River Site” to demonstrate compliance with the Sect. 3116 criteria including 

demonstration of compliance with the performance objectives in 10 CFR Part 61, Subpart C 

(DOE, 2005a). In its consultation role, the NRC staff reviewed the draft waste determination and 

concluded that there was reasonable assurance that the applicable criteria of Sect. 3116 could 
2 

be met, provided certain assumptions made in DOE's analyses are verified via monitoring. NRC 

documented the results of its review in a technical evaluation report issued in December 2005 

(NRC, 2005). DOE issued a final waste determination in January 2006 taking into consideration 

the assumptions, conclusions, and recommendations documented in NRC’s Technical 

Evaluation Report (DOE, 2006). 

To carry out its monitoring responsibility under Sect. 3116, NRC plans to perform three types of 

activities: (i) technical reviews, (ii) onsite observations, and (iii) data reviews. These activities 

will focus on key assumptions—called “factors”—identified in the NRC monitoring plan for 

saltwaste disposal at SRS (NRC, 2007). Technical reviews generally will focus on obtaining 

additional model support for assumptions DOE made in its performance assessment that are 

considered important to DOE's compliance demonstration. Onsite observations generally will be 

performed to (i) observe the collection of data (e.g., observation of waste sampling used to 

generate radionuclide inventory data) and review the data to assess consistency with 

assumptions made in the waste determination, or (ii) observe key disposal (or closure) activities 

related to technical review areas (e.g., slag and other material storage, grout formulation and 

preparation, and grout placements). Data reviews will supplement technical reviews by focusing 

on monitoring data that may also indicate future system performance or by reviewing records or 

reports that can be used to directly assess compliance with performance objectives. 

1.1 LFRG PA Review Process 

During the week of August 10-14, 2009, the NRC staff onsite observation visit at SRS focused 

on all four of the performance objectives. The staff attended the Low-Level Waste Disposal 

Facility Federal Review Group (LFRG) Review Team site visit for the review of the Performance 

Assessment (PA) for the Saltstone Disposal Facility at the Savannah River Site (LWP-RIP-2009-

00011). The LFRG consists of Federal employees from DOE Headquarters and DOE field 

organizations and typically includes technical experts subcontracted from other DOE sites. The 

group performs a review of all DOE LLW disposal facilities PAs and composite analyses and 

supports the process of granting Disposal Authorization Statements. DOE Office of 

Environmental Management tasks the LFRG with providing the information necessary to 

determine whether the design, construction, operation, maintenance, and closure of DOE’s LLW 

disposal facilities sufficiently protect public health and safety. 

2.0 NRC ONSITE OBSERVATION ACTIVITIES 

2.1 Performance Assessment Process Review 

NRC staff monitors ongoing revision of the PA for the Saltstone Disposal Facility at the SRS, as 

described in Section 3.1.9, “Performance Assessment Process Review,” of the staff’s monitoring 

plan (NRC, 2007). 

2.1.1 Observation Scope 

The observation of the LFRG PA review is related to the Technical Review Factors identified in 

the NRC monitoring plan for the SRS Saltstone Disposal Facility (NRC, 2007). The monitoring 

plan states the importance of NRC staff evaluating revisions and updates made to the PA to 
3 

determine if the PA continues to provide reasonable assurance that the long-term performance 

of the wasteform and its surrounding system will maintain public health and safety. 

The general purpose of NRC staff review of the Saltstone Disposal Facility PA revision is to 

continue to verify compliance with the performance objectives listed in 10 CFR Part 61, Subpart 

C. 

2.1.2 Observation Results 

During this review, the LFRG review team evaluated the PA and supporting documentation to 

confirm that the PA is complete, thorough, and technically supported, and the conclusions are 

valid and acceptable. The review team members included technical experts from other DOE 

sites with various areas of relevant technical expertise. Team members were given 30 days to 

review the PA and associated documents prior to the onsite portion of the review. 

At the beginning of the week, prior to start of the review, SRS staff gave the LFRG review team a 

tour of the Saltstone Disposal Facility, including the existing vaults as well as the new vaults 

currently under construction. Site staff also gave an overview presentation describing their 

performance assessment methodology and results. Members of the review team also had an 

opportunity to discuss the PA with the subject matter experts who were involved in the 

development of the PA or research that supported the PA. These technical experts provided the 

review team with additional information on the methodology used in the performance 

assessment and the technical basis for assumptions made in the PA. The technical areas 

discussed included topics such as the methodology used in the PORFLOW and GoldSim 

computer modeling codes, the possible degradation mechanisms of the saltstone, the potential 

for oxidation of Tc in saltstone, the development of the inventory included in the performance 

assessment, and the uncertainty and sensitivity analyses performed. 

The review team used the information presented in the PA and supporting documents and the 

information gathered in discussions with site staff to evaluate if the PA met the criteria identified 

in the respective LFRG Review Plan. In cases where the criteria were not met, the review team 

identified causality. Issues identified were then categorized into key issues and secondary 

issues. Key issues require resolution as a condition of acceptance of the PA. Secondary issues 

are important, but not critical to PA acceptance, and describe areas for improvement that should 

be tracked and resolved through the site maintenance plan (DOE, 2005b). 

The review team discussed the potential issues identified and reached a consensus on the lists 

of key and secondary issues. The LFRG Review Team developed a report documenting the 

team’s consensus opinion. Individual review team members were also provided an opportunity 

to submit a separate description of their review that provides additional details about their 

evaluation of the performance assessment. 

At the conclusion of the review, the LFRG Review Team briefed the SRS site staff and 

management on conclusions reached during the review. The LFRG Review Team is also 

providing a copy of the draft Review Team report to the SRS staff for a review of factual 

accuracy. Once finalized, the report will be submitted to the LFRG. 
4 

NRC staff appreciated the invitation and the opportunity to observe the process and was 

impressed at the rigorousness of the review. The team was both technically diverse and 

consisted of members highly regarded in their respective fields. Points of interest, concerns, 

and conclusions identified by the team were typically consistent with those identified in NRCs 

review(s) of similar subject matter. The NRC staff must acknowledge, however, that a 

comprehensive assessment of the process must include analysis of process output as well as 

input. The LFRG Final Report and the PA will be the outputs to this process, with greater 

emphasis put on the PA. 

2.1.3 Conclusions and Follow-up Actions 

No NRC issues were identified during the observation of LFRG review. The NRC staff still has 

reasonable assurance that the performance objectives are currently being met. However, the 

staff recognizes that the evaluation of the effectiveness of the LFRG process review can only be 

fully complete at the release of the revised PA. 

3.0 PARTICIPANTS 

U.S. NRC

Nishka Devaser 

Karen Pinkston 

Gregory Suber 

U.S. DOE

Jeff Bentley 

Jim Folk 

Tom Gutmann 

Maureen O’Dell 

Chun Pang 

Sherri Ross 

LFRG Review Team

Bob Andrews, (Jason Assoc.) 

Eric Pierce, (PNNL) 

John Walton, (Univ. of Texas) 

Vefa Yucel, (NTS) 

Amanda Anderson, (U.S. DOE) 

Jhon Carilli, (U.S. DOE) 

Joel Case, (U.S. DOE) 

Martin Letourneau, (U.S. DOE) 

Joe Rustick, (U.S. DOE) 

Linda Suttora, (U.S. DOE) 

Marc Wood, (CH2MHill) 

Howard Pope, (PEC) 

SRR

Ginger Dickert 

Keith Liner 

Bruce Long 

Dave Olson 

Larry Romanowski 

F. Malcolm Smith 

Kent Rosenberger 

SRNL

Dan Kaplan 

Christine Langton 

Miles Denham 

Greg Flach 

Mark Phifer 
Enclosure 

4.0 REFERENCES 

U.S. Department of Energy (DOE). DOE-WD-2005-001, “Basis for Section 3116 Determination 

Salt Waste Disposal at the Savannah River Site.” Washington, DC: DOE. March 2005a. 

–––––. CBU-PIT-2005-0146, “Saltstone Performance Objective Demonstration Document.” 

Westinghouse Savannah River Company. June 2005b. 

–––––. DOE-WD-2005-001, “Basis for Section 3116 Determination Salt Waste Disposal at the 

Savannah River Site.” Washington, DC: DOE. January 2006. 

U.S. Nuclear Regulatory Commission (NRC). “Technical Evaluation Report for Draft Waste 

Determination for Salt Waste Disposal.” Letter from L. Camper to C. Anderson, DOE. 

December 28, 2005. (Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML053010225) 

–––––. “U.S. Nuclear Regulatory Commission Plan for Monitoring the U.S. Department of 

Energy Salt Waste Disposal at the Savannah River Site in Accordance with the National 

Defense Authorization Act for Fiscal Year 2005.” Washington, DC: NRC. May 3, 2007. 

(ADAMS Accession No. ML070730363)