September 30, 2009 

Mr. 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 JUNE 3, 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 June 3, 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 (Section 3116), which requires NRC to 

monitor disposal actions taken by 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). 

Though all performance objectives are considered during every monitoring event, this onsite 

observation at SRS was primarily focused on assessing compliance with the performance 

objective in 10 CFR 61.41, Protection of the general population from releases of radioactivity, by 

observing DOE’s ongoing construction of disposal cells at the Saltstone Disposal Facility (SDF). 

 

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

Section 3116 can be met if key assumptions made in DOE’s waste determination analyses 

prove to be correct. In accordance with the requirements of Section 3116 and consistent with 

NRC’s monitoring plan for the salt waste 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 Environment 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 Environment 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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DATE 08/26/09 08/26/09 08/27/09 09/14/09 09/14/09 09/17/09 09/ 21 /09 

OFFICIAL RECORD COPY
Enclosure 

U.S. NUCLEAR REGULATORY COMMISSION JUNE 3, 2009, ONSITE OBSERVATION 

REPORT FOR THE SAVANNAH RIVER SITE SALTSTONE FACILITY 

EXECUTIVE SUMMARY 

U.S. Nuclear Regulatory Commission (NRC) staff conducted its fifth onsite observation visit of 

the Saltstone Facility at the Savannah River Site (SRS) on June 3, 2009. This visit was intended 

to focus on one of the four performance objectives C 10 CFR 61.41, “Protection of the general 

population from releases of radioactivity,” C by obtaining information on construction of disposal 

Cells 2A and 2B of the U.S. Department of Energy (DOE) saltstone disposal facility. 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. 

There are no new open issues resulting from this observation, however, at the time of the 

observation, the revised performance assessment for the new vault design was not yet available 

for NRC staff review. As a result, staff was unable to fully assess risk significance of 

construction activities and materials used in construction. A summary of the staff’s observations 

and conclusions is provided below: 

Disposal Cell Construction 

• The staff observed ongoing construction at Saltstone Disposal Facility Cells 2A and 2B. At 

the time of the staff’s visit, all vertical wall panels were installed for both cells. Closure strips 

had been installed for disposal cell 2B and preparation was complete for the introduction of 

structural concrete between panel interstices. 

• The DOE has one follow-up action from this activity relating to NRC staff’s request for 

vendor-supplied historical documentation of the performance of various construction 

materials as well as documentation of materials testing performed by the disposal cell 

vendor. NRC staff also made a recommendation that DOE either verify that concrete quality 

assurance requirements in a required national code and standard is being met, or determine 

the effects of any deviations on performance of the concrete. 

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 Section 3116 criteria, including 

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

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

concluded that there was reasonable assurance that the applicable criteria of Section 3116 

could 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 (TER) issued in 
2 

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 

TER (DOE, 2006). 

To carry out its monitoring responsibility under Section 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 (PA) 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. 

On June 3, 2009, the NRC staff onsite observation visit at SRS focused primarily on the 

performance objective in 10 CFR 61.41, Protection of the general population from releases of 

radioactivity by observing DOE’s ongoing construction of disposal cells at the Saltstone Disposal 

Facility (SDF). Future visits will assess the performance objective in 10 CFR 61.42, Protection 

of individuals against inadvertent intrusion, and also continue to assess DOE compliance with 

the other performance objectives. 

Saltstone Facility Operational Status at the time of the Observation 

At the beginning of the visit, DOE and DOE contractor staff provided a brief overview of 

operations at the Saltstone Facility and the status of disposal cell 2 construction since the last 

onsite observation (NRC, 2009). The DOE contractor then led NRC staff accompanied by the 

South Carolina Department of Health and Environmental Control (SCDHEC) on a tour of the 

disposal cell 2 construction site. NRC staff observed construction activities associated with 

concrete placement in some of the 32 closure strips of Tank 2B. 

At the time of the observation, DOE was starting a transition to a new liquid waste contractor, 

Savannah River Remediation, LLC (SRR), which will succeed the Washington Savannah River 

Company (WSRC) on July 1, 2009 (DOE, 2009). 
3 

2.0 NRC ONSITE OBSERVATION ACTIVITIES 

2.1 Disposal Cell Construction 

NRC staff monitors ongoing construction of disposal cells, as described in section 3.2.3, “Vault 

Construction,” of the staff’s monitoring plan (NRC, 2007). 

2.1.1 Observation Scope 

The observation of DOE vault construction is related to Factor 1 – “Oxidation of Saltstone,” 

Factor 2 – “Hydraulic Isolation of Saltstone,” and Factor 3 – “Model Support,” which were 

identified in the NRC monitoring plan for the SRS SDF (NRC, 2007). The monitoring plan also 

states the importance of understanding potential mechanisms that could result in loss of vault 

integrity. The disposal cell system is comprised of a number of different engineering materials 

designed to properly interact to contribute to leak proof performance. These include reinforced 

concrete, steel, epoxy, caulk, HDPE liners, and rubber. Each of these materials, individually, 

has unique physical and chemical characteristics that will vary with time and changes in 

environment. Staff would like to gain a better understanding of how these materials will behave 

during the performance period of these cells. 

The general purpose of NRC staff observations of ongoing construction of Saltstone Facility 

disposal cells 2A and 2B is to identify noticeable deviations from the vault design, focusing on 

changes that could affect potential pathways for water to intrude into the vaults, such as 

penetrations or joints. In addition to material effects, NRC staff paid particular attention to those 

processes contributing to the assembly and installation the vault wall panels. 

2.1.2 Observation Results 

The staff observed ongoing construction at Saltstone Facility disposal cells 2A and 2B. At the 

time of the staff’s visit, the cell floors and all wall panels had been fully installed for disposal cells 

2A and 2B, most of the wall panel joints had been poured for disposal cell 2B. NRC staff also 

observed construction activities associated with concrete placement in some of the 32 closure 

strips of disposal cell 2B. 

2.1.2.1 Concrete Batch Accounting 

Staff reviewed a concrete batch ticket package that contained two documents. The documents 

were associated with the batch that was delivered and placed in the closure gaps. One 

document contained information regarding initial batch time, and the other document indicated 

the time that the truck left the batch plant. This batch was tested for slump, air content, 

temperature, and concrete cylinders were made for compressive testing. QORE Property 

Sciences is the subcontractor responsible for independent materials testing, which includes but 

is not limited to performing the on-site concrete receipt testing and making the concrete test 

cylinders to be used for compressive strength breaks. The QORE representative on-site 

performed the concrete receipt testing, made the concrete test cylinders to be used for 

compressive strength breaks, and recorded and reviewed the results of the tests. The batch 

ticket indicated that the concrete was initially batched (water added) at 11:40 a.m., the truck left 

the batch plant at 12:15 p.m. The QORE representative stated that the truck was finished 
4 

pouring at 1:47 p.m., which is in excess of 2 hours. ASTM C94 (ASTM, 2009) states the 

following: 

“Discharge of the concrete shall be completed within 11⁄2 hours or before the drum has 

revolved 300 revolutions, whichever comes first, after the introduction of the mixing water 

to the cement and aggregates or the introduction of the cement to the aggregates. 

These limitations are permitted to be waived by the purchaser if the concrete is of such 

slump after the 11⁄2-h time or 300-revolution limit has been reached that it can be placed, 

without the addition of water, to the batch.” 

Upon review of ASTM C94 (ASTM, 2009), staff believes that not meeting, by a small margin, the 

discharge time limit specified in the standard may not have a significant impact on long-term 

concrete strength and stability of the disposal cells, especially if the concrete had been 

determined to be “of such slump. . . that it can be placed without the addition of water.”. The 

staff have not identified any follow-up actions, open issues or recommendations associated with 

this observation. 

2.1.2.2 Closure Strip Deviations 

ACI 117-06, Section 2.3.1 (ACI, 2006) provides requirements for placement of embedded items 

and states “Clear distance to nearest reinforcement shall be the greater of the bar diameter or 

1 in.” The commentary section R2.3 provides further clarification on this requirement with 

diagrams showing the clear distance should be from the embedment and the stud (Figure 1 

shows the requirements designated by ACI 117-06 and Figure 2 shows a photograph of the 

closure strips used in disposal cell 2A [taken onsite during June 3 observation]). 

Figure 1: ACI 117-06 Requirements Figure 2: June 3, 2009 Photograph of Closure Strip

One of the intents of this requirement is to ensure proper concrete consolidation and bonding to 

all surfaces of the embedment and rebar and to prevent localized voiding issues. The steel 

closure strips were constructed with studs embedded in the concrete and rebar was placed less 

than 1” from these studs and in several instances actually in contact with the studs. Voiding 

issues of this sort could lead to preferential pathways within the disposal cell and could produce 

unforeseen weaknesses during the performance period. Given the potential for localized voiding 

created by this deviation, the staff recommends that DOE either confirm the absence of such 

voids or consider the potential for such voids in evaluating the performance of the cells. 
5 

2.1.2.3 Materials Performance 

Many engineering materials are being used in construction of the disposal cells. These 

materials have properties potentially affecting long-term performance of the disposal cells. NRC 

staff requested information from the vendor, which has decades of experience with the 

performance of these materials, in order to evaluate whether past experience with tanks of 

similar design might be useful in predicting long-term performance of the disposal cells. 

2.1.3 Conclusions and Follow-up Actions 

No open issues were identified during the observation of disposal cell construction. However, 

staff observed deviations of required concrete codes and standards. NRC staff would like to 

discuss these deviations in future meetings. NRC staff have identified one follow-up action and 

one recommendation at the close of this observation. 

DOE Follow-up Action

Provide vendor-supplied historical documentation of performance of various materials 

used in construction as well as documentation of materials testing performed by the 

disposal cell vendor. 

DOE Recommendation

DOE should either confirm the absence of voids caused by deviation from ACI 117-06, 

or consider the potential for such voids in evaluating the performance of the cells 
6 

3.0 PARTICIPANTS 

U.S. NRC (HQ)

Larry Camper 

Nishka Devaser 

Jim Shaffner 

U.S. NRC (Region II)

Anthony Masters 

SCDHEC

John McCain 

Jason Shirley 

Josh Yon 

U.S. DOE

Jeff Bentley 

Jim Folk 

Tom Gutmann 

Chun Pang 

Sherri Ross 

Linda Suttora 

SRNS

Kent Rosenberger 

SRR

Doug Bumgardener 

Seth Campbell 

Ginger Dickert 

Keith Liner 

Bruce Long 

Dave Olson 

Larry Romanowski 

F. Malcolm Smith 

BSRI

Bernie Eneroldsen 

Karl Weiss

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 2005. 

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

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

–––––. EQMD-09-032, “Savannah River Site (SRS) Liquid Waste (LW) Contract Transition.” 

Washington, DC: DOE. May 8, 2009 (ADAMS Accession No. ML091390680). 

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. (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) 

–––––. “Nuclear Regulatory Commission March 25-26, 2009 Onsite Observation Report for the 

Savannah River Site Saltstone Facility.” May 22, 2009 (ADAMS Accession No. ML091320439) 

ASTM Standard C 94/C 94M – 09, 2009, "Standard Specification for Ready-Mixed Concrete," 

ASTM International, West Conshohocken, PA, 2009, www.astm.org. 

American Concrete Institute (ACI) Standard 117-06, 2006, "Specifications for Tolerances for 

Concrete Construction and Materials and Commentary," ACI Committee, 2006, 

www.concrete.org/.