November 12, 2013 

Ms. Jean Ridley, Director 

Waste Disposition Programs Division 

U.S. Department of Energy 

Savannah River Operations Office 

P.O. Box A 

Aiken, SC 29802 

SUBJECT: THE U.S. NUCLEAR REGULATORY COMMISSION AUGUST 27-28, 2013, 

ONSITE OBSERVATION VISIT REPORT FOR THE SAVANNAH RIVER SITE 

F-TANK FARM FACILITY (DOCKET NO. PROJ0734) 

Dear Ms. Ridley: 

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

observation visit on August 27-28, 2013, at the Savannah River Site (SRS) F-Tank Farm (FTF) 

Facility. That onsite observation visit was conducted in accordance with Section 3116(b) of the 

Ronald W. Reagan National Defense Authorization Act for Fiscal Year 2005 (NDAA), which 

requires NRC to monitor certain disposal actions taken by the U.S. Department of Energy 

(DOE) for the purpose of assessing compliance with the performance objectives set out in 

Title 10 of the Code of Federal Regulations (CFR) Part 61, Subpart C. 

The main activities conducted during the August 2013 onsite observation visit were: 

(1) technical discussion on the technical reviews related to FTF Tanks 5/6 closure; and 

(2) observation of grouting of FTF Tanks 5/6 with technical discussion on grout formula, 

development, and testing documentation. Those activities were consistent with those described 

in the NRC Observation Guidance Memorandum for the SRS FTF (dated July 29, 2013,) 

[available via the NRC’s Agencywide Documents Access and Management System (ADAMS) at 

Accession No. ML13196A134]. That Guidance Memorandum was developed using the 

following NRC documents: (1) FTF Monitoring Plan, Rev. 0 (dated January 2013) [ADAMS 

Accession No. ML12212A192]; and (2) three Technical Review Reports (TRRs) [ADAMS 

Accession Nos. ML13080A401, ML13100A230, and ML12272A082]. The FTF Monitoring Plan 

contains the monitoring areas and monitoring factors, which describe how NRC will monitor 

DOE FTF disposal actions to assess compliance with the performance objectives. The three 

TRRs contain follow-up action items that will be used in future monitoring activities and will be 

incorporated into future revisions to the FTF Monitoring Plan. 

This is the fourth FTF onsite observation visit since NRC began monitoring DOE FTF disposal 

actions under NDAA Section 3116(b) in March 2012. NRC does not expect to close any of the 

26 FTF monitoring factors, close any of the 8 FTF monitoring areas, or change the NRC staff 

Technical Evaluation Report overall conclusions in the early stages of the monitoring process. 

There were no FTF Open Issues before the August 2013 onsite observation visit and there were 

none opened during the onsite observation visit. Thus, there are currently no FTF Open Issues. 

NRC does expect to open and close follow-up action items during onsite observation visits and 

clarification teleconference calls. Most of those follow-up action items are specific short-term 
J. Ridley - 2 - 

actions to be performed by NRC or DOE. Usually, most of those follow-up action items are 

closed before the next onsite observation visit or clarification teleconference call. Therefore, in 

accordance with the requirements of NDAA Section 3116(b), NRC will continue to monitor DOE 

disposal actions at SRS. 

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

Harry Felsher of my staff at Harry.Felsher@nrc.gov, or at (301) 415-6559. 

Sincerely, 

/RA/ 

Aby Mohseni, 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 

Docket No.: PROJ0734 

Enclosure: 

NRC Onsite Observation Visit Report 

cc w /enclosure: 

WIR Service List 

SRS e-mail Contact List 
J. Ridley - 2 - 

actions to be performed by NRC or DOE. Usually, most of those follow-up action items are 

closed before the next onsite observation visit or clarification teleconference call. Therefore, in 

accordance with the requirements of NDAA Section 3116(b), NRC will continue to monitor DOE 

disposal actions at SRS. 

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

Harry Felsher of my staff at Harry.Felsher@nrc.gov, or at (301) 415-6559. 

Sincerely, 

Aby Mohseni, 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 

Docket No.: PROJ0734 

Enclosure: 

NRC Onsite Observation Visit Report 

cc w /enclosure: 

WIR Service List 

SRS e-mail Contact List 

DISTRIBUTION: GAlexander CBarr CGrossman LParks JShaffner 

ML13267A452 

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

NAME HFelsher TMoon CMcKenney GSuber AMohseni 

DATE 09/30/13 10/01/13 10/04/13 11/05/13 11/12/13 

OFFICIAL RECORD COPY
WIR Service List 

Glenn Carroll, Coordinator 

Nuclear Watch South 

P.O. Box 8574 

Atlanta, GA 31106 

Tom Clements, Member 

Friends of the Earth 

1112 Florence Street 

Columbia, SC 29201 

Jim Hardeman, Manager 

Environmental Radiation Program 

Environmental Protection Division 

Georgia Department of Natural Resources 

4220 International Parkway, Suite 100 

Atlanta, GA 30354 

Karen Patterson, Environmental 

Appointment 

Governors' Nuclear Advisory Council 

 and Tetra Tech NUS 

900 Trail Road 

Aiken, SC 29803-5297 

Bobbie Paul, Executive Director 

Georgia Womens Action for New Directions 

250 Georgia Ave., SE 

Suite 202 

Atlanta, GA 30312 

Robert H. Pope 

Senior Remedial Project Manager 

U.S. Environmental Protection Agency 

Region 4, Superfund Division 

Federal Facilities Branch, Waste Division 

61 Forsyth Street 

Atlanta, GA 30303 

Jon Richards, Remedial Project Manager 

U.S. Environmental Protection Agency 

Region 4, Superfund Division 

Federal Facilities Branch, Waste Division 

61 Forsyth Street 

Atlanta, GA 30303 

Thomas Saporito, Executive Director 

P.O. Box 8413 

Jupiter, FL 33468 

John J. Schnabel 

Saltstone Project Inspector, 

 Professional Engineer 

Division of Mining and Solid Waste 

 Management 

Bureau of Land and Waste Management 

South Carolina Department of Health 

 and Environmental Control 

2600 Bull Street 

Columbia, SC 29201-1208 

Shelly Wilson 

Federal Facilities Liaison 

Environmental Quality Control 

Administration 

South Carolina Department of Health 

 and Environmental Control 

2600 Bull Street 

Columbia, SC 29201-1708 
U.S. NRC AUGUST 27-28, 2013, ONSITE OBSERVATION VISIT REPORT FOR THE 

SAVANNAH RIVER SITE F-TANK FARM FACILITY 

EXECUTIVE SUMMARY: 

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

visit, Observation 2013-02, to the F-Tank Farm (FTF) Facility at the Savannah River Site (SRS) 

on August 27-28, 2013. This is the second FTF onsite observation visit in Calendar Year 2013. 

On every onsite observation visit to SRS, NRC is focused on assessing compliance with four 

performance objectives in Title 10 of the Code of Federal Regulations (CFR) Part 61, 

Subpart C: (1) protection of the general population from releases of radioactivity (§61.41), 

(2) protection of individuals from inadvertent intrusion (§61.42), (3) protection of individuals 

during operations (§61.43), and (4) stability of the disposal site after closure (§61.44). 

For FTF Observation 2013-02 NRC focused on the monitoring areas and monitoring factors in 

the FTF Monitoring Plan, Rev. 0 (NRC, 2013b), as supplemented by the NRC issued Technical 

Review Reports (TRRs) [(NRC, 2013e), (NRC, 2013f), and (NRC, 2013h)] since DOE issued 

the FTF final waste determination. Starting with FTF Observation 2013-01, NRC involves U.S. 

Environmental Protection Agency (EPA) Region 4 in the monitoring activities at FTF because, 

for closed FTF tanks, South Carolina Department of Health and Environmental Control 

(SCDHEC) will have lead regulatory authority and EPA will also have regulatory authority. After 

the entire FTF Facility is closed, EPA and SCDHEC will share regulatory authority through the 

SRS Federal Facility Agreement (FFA). NRC performs monitoring activities in coordination with 

the State, so SCDHEC staff also participated in FTF Observation 2013-02. EPA Region 4 staff 

was invited to participate in FTF Observation 2013-02. 

As described in the Observation Guidance Memorandum for FTF Observation 2013-02 

(NRC, 2013l), NRC staff and DOE (i.e., includes DOE contractors throughout this report) 

discussed the following topics: (1) technical reviews for FTF related to FTF Tanks 5/6 closure, 

including the review of Tanks 5/6 Special Analysis and final inventory development; and 

(2) grout formula, development, and testing documentation for Tanks 5/6. In addition, NRC staff 

and DOE observed grouting of Tanks 5/6. Also, there were other items discussed, such as the 

status of other NRC TRRs and a review of follow-up action items. This report provides a 

description of the NRC activities during FTF Observation 2013-02, including observations made 

by NRC. 

NRC does not expect to close any of the 26 FTF monitoring factors, close any of the 8 FTF 

monitoring areas, or change the NRC staff Technical Evaluation Report overall conclusions in 

the early stages of the monitoring process. There were no FTF Open Issues before the August 

2013 onsite observation visit and there were none opened during the onsite observation visit. 

Thus, there are currently no FTF Open Issues. 

NRC staff received documentation and a DOE presentation (SRR-CWDA-2013-00116, Rev. 1) 

that pertained to the activities observed during FTF Observation 2013-02. The presentation that 

DOE provided to NRC staff is accessible via the NRC’s document repository, the Agencywide 

Documents Access and Management System (ADAMS), via Accession No. ML13253A270. 

Enclosure 

 
- 2 - 

1.0 BACKGROUND: 

Section 3116(a) of the National Defense Authorization Act for Fiscal Year 2005 (NDAA) 

authorizes DOE, in consultation with 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. 

NDAA Section 3116(b) requires NRC to monitor DOE disposal actions to assess compliance 

with the performance objectives in 10 CFR Part 61, Subpart C. 

On September 30, 2010, DOE issued the draft FTF Waste Determination (DOE/SRS-WD-2010-

001, Rev. 0), which was provided to NRC for consultation under NDAA Section 3116(a). The 

purpose of the draft Waste Determination was to demonstrate DOE compliance with the criteria 

in NDAA Section 3116(a), including compliance with the performance objectives in 

10 CFR Part 61, Subpart C. In its consultation role, the NRC reviewed the draft Waste 

Determination and highlighted a number of technical concerns during a series of public 

meetings and requests for additional information. In October 2011, NRC documented the 

results of its review in the FTF TER (NRC, 2011). In the TER, NRC made a number of 

recommendations that NRC believes, if implemented by DOE, will enhance the DOE 

demonstration that FTF disposal actions would meet the performance objectives in 

10 CFR Part 61, Subpart C during the FTF closure process. Taking into consideration the 

information and recommendations in the NRC TER, DOE completed a number of studies that 

were referenced in the final FTF Waste Determination that DOE issued in March 2012 

(DOE/SRS-WD-2012-001, Rev.0). DOE indicated that it predicated the final Waste 

Determination on extensive analyses and scientific rationale, including the final FTF 

Performance Assessment (SRS-REG-2007-00002, Rev. 1), as supplemented by the FTF Tanks 

18/19 Special Analysis (SRR-CWDA-2010-00124, Rev. 0). Taking into consideration the 

information in the NRC TER and the final FTF Waste Determination, NRC finalized and issued 

the FTF Monitoring Plan, Rev. 0 (NRC, 2013c), which was transmitted to DOE by letter dated 

January 23, 2013 (NRC, 2013b) and issued in a Federal Register Notice on February 21, 2013, 

(NRC, 2013c). 

To carry out its monitoring responsibility under NDAA Section 3116(b), NRC, in coordination 

with the State site regulator – SCDHEC, performs three types of activities: (1) technical 

reviews, (2) onsite observation visits, and (3) data reviews. Those activities focus on both key 

modeling assumptions identified in the NRC FTF Monitoring Plan, Rev. 0 (NRC, 2013b), as 

supplemented by the NRC TRRs [(NRC, 2013e), (NRC, 2013f), and (NRC, 2013h)]; and the 

DOE disposal actions. Technical reviews generally focus on review of information generated to 

provide support for key assumptions that DOE made in the FTF Performance Assessment. 

Onsite observation visits generally are performed to either observe the collection of data and 

review the data to assess consistency with assumptions made in the FTF final Waste 

Determination; or observe key disposal or closure activities related to technical review areas. 

Data reviews supplement technical reviews by focusing on monitoring data that may indicate 

future system performance or reviewing records or reports that can be used to directly assess 

compliance with the performance objectives. 

 
- 3 - 

2.0 NRC ONSITE OBSERVATION VISIT ACTIVITIES: 

On July 29, 2013, NRC issued the Observation Guidance for the August 27-28, 2013, onsite 

observation visit, FTF Observation 2013-02 (NRC, 2013l). An Observation Guidance is a plan 

for what NRC expects to cover during an onsite observation visit, which may not be followed 

based on what happens during the onsite observation visit. The following two topics in the 

Observation Guidance for FTF Observation 2013-02 were not covered during FTF Observation 

2013-02 and will be covered in future onsite observation visits: (1) Technical Review of 10 CFR 

Part 61 As Low As Is Reasonably Achievable (ALARA) and (2) NRC Observation of DOE 

Implementation of the Radiation Protection Program, including ALARA. 

FTF Observation 2013-02 began with a short briefing on the agenda and site safety procedures 

presented by DOE contractor, Savannah River Remediation (SRR) that was attended by 

representatives from DOE, NRC, and SCDHEC. Afterwards, there were welcoming remarks 

and introductions. The following topics were technical discussions between NRC and DOE 

during FTF Observation 2013-02: (1) Technical Reviews for FTF related to Tanks 5/6 Closure, 

including the review of Tanks 5/6 special analysis and final inventory development; and (2) grout 

formula, development, and testing documentation for Tanks 5/6. In addition, NRC staff and 

DOE observed grouting of Tanks 5/6. Also, there were other items discussed, such as the 

status of other NRC TRRs and a review of follow-up action items. 

2.1 Technical Discussion – Technical Reviews for FTF related to FTF Tanks 5/6 Closure: 

2.1.1 Observation Scope: 

Using the NRC FTF Monitoring Plan, Rev. 0 (NRC, 2013b), NRC monitors DOE disposal 

actions to assess compliance with 10 CFR 61.41 and 10 CFR 61.42 performance objectives for 

tank closure activities through Monitoring Area 1 (Inventory) under: Monitoring Factor 1.1 (Final 

Inventory and Risk Estimates) for §61.41 and Monitoring Factor 1.1 (Final Inventory and Risk 

Estimates-Additional Considerations) for §61.42; Monitoring Factor 1.2 (Residual Waste 

Sampling) for §61.41 and Monitoring Factor 1.2 (Residual Waste Sampling-Additional 

Considerations) for §61,42; and Monitoring Factor 1.3 (Residual Waste Volume) for §61.41. 

2.1.2 Observation Results: 

NRC discussed with DOE the current development of the NRC technical reviews for FTF related 

to Tanks 5/6 closure in the following areas: special analysis and final inventory development. 

Highlights of that Technical Discussion are the following: 

Regarding the FTF Tanks 5/6 Special Analysis TRR: 

• NRC staff inquired about the development of site-specific Niobium distribution 

coefficients (Kds) that appear to be risk-significant. 

• DOE indicated that the site-specific analysis for Niobium Kds is in-progress and the 

results are expected in the near-term. 

• NRC staff indicated that the TRR was expected to be issued shortly. 

 
- 4 - 

Regarding the FTF Tanks 5/6 Final Inventory Development TRR: 

• NRC staff indicated that, in general, the sampling and analysis program and volume 

estimation program are technically sound and defensible. 

• NRC staff discussed the issues related to identification and quantification of tank waste 

variability and management of volume uncertainty, which NRC staff expects will be 

considered in future DOE analyses. 

In addition, NRC staff discussed with DOE the current development of the Grouting of FTF 

Tanks 18/19 TRR. Highlights of that discussion are the following: 

• NRC staff emphasized that the TRR conclusion will be that performance requirements 

for grout formulations recommended and tested for Tanks 18/19 closure are generally 

consistent with bulk initial properties assumed in the DOE FTF Performance 

Assessment. However, of primary importance, NRC expects that DOE would provide 

sufficient information, and testing to exclude alternative conceptual models reflecting 

preferential flow through the tank grout monolith from the DOE base case. 

• NRC staff indicated that DOE appears to not have plans for shrinkage testing of the 

grout formulations regarding preferential pathways. DOE responded that there are 

currently no plans for additional shrinkage testing. 

• NRC staff indicated that the TRR will include both observations of potential segregation 

of grout during tank grouting and the remaining questions on segregation that were sent 

to DOE for the May 1, 2013, NRC/DOE clarifying teleconference on grouting. 

• NRC staff indicated items of secondary importance, including the expectation that DOE 

would provide additional information on: (1) thermal cracking evaluations, (2) estimation 

of emplaced void volumes, (3) consideration of degradation from alkali-silica reactivity, 

and (4) impact on pH buffering from limestone substitutions in the grout formulation. 

• NRC staff indicated that it will continue to evaluate the potential for preferential flow 

through the tank grout due to shrinkage and cracking under Monitoring Factor 3.3 

(Shrinkage and Cracking). 

The other three topics covered during this Technical Discussion were: (1) NRC staff questions 

sent on August 21, 2013, about two DOE documents; (2) review of follow-up action items since 

FTF Observation 2013-01, including the DOE methodology for doing inventory adjustments, and 

(3) NRC staff discussion of the major findings and conclusions in both the NRC issued Tanks 

18/19 Special Analysis TRR and Waste Release TRR. Below are some highlights of those 

topics: 

On August 21, 2013, NRC staff provided DOE with follow-up questions on both the Liquid 

Waste Tank Residuals Sampling and Analysis Program Plan (SRR-CWDA-2011-00050, Rev. 1) 

[SAPP] and the Liquid Waste Tank Residuals Sampling-Quality Assurance Program Plan, 

(SRR-CWDA-2011-00117, Rev. 0) [QAPP]. DOE provided responses to those questions during 

Observation 2013-02. NRC staff questioned the DOE decision criteria for the collection and 

analysis of additional samples based on heterogeneity. DOE indicated that it will use expert 

judgment and knowledge of tank cleaning history to determine if additional samples should be 
- 5 - 

taken or if discrete samples should be analyzed. That decision will be informed, in part, by DOE 

historical knowledge of mound formation and movement during the cleaning process, as well as 

by the practicality of sampling access to certain tank locations. NRC staff questioned DOE 

about the frequency of validation (i.e., every tenth waste tank for a limited suite of radionuclides 

and chemicals). DOE indicated that the frequency was decided between DOE and SCDHEC 

with SCDHEC’s approval. Regarding the inconsistent uncertainty terminology between the 

SAPP and QAPP, DOE will attempt to address those inconsistencies in future revisions to both 

the SAPP and QAPP. DOE is not planning on revising those two documents in the near future 

to address the terminology issue. 

During FTF Observation 2013-02, DOE provided information in Followup In Support of U.S. 

Nuclear Regulatory Commission Monitoring Activities for F-Tank Farm, (SRR-CWDA-20130-

00103, Rev 0), in response to all but one follow-up action item from the three clarifying 

teleconference calls that NRC held with DOE on May 1, 8, and 15, 2013. DOE led the 

discussion about the DOE methodology for doing inventory adjustments and examples of using 

that methodology, such as for I-129 and for Tc-99. NRC staff questioned DOE regarding details 

of the methodology and examples. NRC staff questioned the basis for assuming a volume of 

1,700 gallons (6,435 liters) of residual waste for Type I Tanks that have not been cleaned when 

Tanks 5/6 had higher final residual volumes. DOE indicated that the basis for that volume was 

a factor of 10 times higher than the 0.0625 inches (0.15875 cm) height assumed in the FTF 

Performance Assessment. 

Regarding the FTF Tanks 18/19 Special Analysis TRR and the Waste Release TRR, NRC staff 

reiterated its expectation that DOE would perform waste release experiments to better 

understand plutonium solubility. That is particularly important given the NRC staff observations 

of risk-significant plutonium solubility observed in Tank 18 following Tank 18 cleaning. NRC 

staff discussed its expectations that DOE would perform additional analyses to address the 

performance impact of higher mobility forms of plutonium that may exist in SRS subsurface 

environments, which were based on site-specific research and data. 

2.1.3 Conclusions and Follow-up Actions: 

NRC staff will continue to perform technical reviews on topics related to monitoring FTF 

activities. The following five follow-up actions resulted from that technical discussion: 

• DOE to provide NRC with Followup In Support of U.S. Nuclear Regulatory Commission 

Monitoring Activities for F-Tank Farm, (SRR-CWDA-20130-00103, Rev. 0). 

• NRC to provide DOE with an external computer hard drive for the FTF Tanks 5/6 Special 

Analysis PORFLOW files. 

• DOE to provide NRC with the FTF Tanks 5/6 Special Analysis PORFLOW files on the 

NRC previously provided external computer hard drive. 

• DOE to provide NRC with both Liquid Waste Tank Residuals Sampling and Analysis 

Program Plan (SRR-CWDA-2011-00050, Rev. 2) and Liquid Waste Tank Residuals 

Sampling-Quality Assurance Program Plan, (SRR-CWDA-2011-00117, Rev. 1). 
- 6 - 

• DOE to provide NRC with Task Technical and Quality Assurance Plan for Determining 

the Radionuclide Release from Tank Waste Residual Solids (SRNL-STI-2013-00203, 

Rev. 0). 

2.2 Observation of Grouting of Tanks 5/6 and Technical Discussion – Grout Formula,

Development, and Testing Documentation: 

2.2.1 Observation Scope: 

Using the NRC FTF Monitoring Plan, Rev. 0 (NRC, 2013b), NRC monitors DOE disposal 

actions to assess compliance with 10 CFR 61.41 and 10 CFR 61.42 for grout performance 

through Monitoring Area 3 (Cementitious Material Performance) under Monitoring Factor 3.4 

(Grout Performance) for §61.41 and Monitoring Factor 3.4 (Grout Performance-Additional 

Considerations) for §61.42. 

2.2.2 Observation Results: 

NRC staff and DOE observed grouting of Tanks 5/6 and participated in related technical 

discussions. NRC staff asked DOE questions and DOE provided both overall and specific 

answers to those questions related to the following topics: grout formulations, grout testing, 

grout acceptance, and grout placement. Highlights of that Observation and Technical 

Discussion are the following: 

Before observing the grouting of Tanks 5/6, DOE provided information regarding: FTF Tanks 

5/6 Grouting Strategy, Status of Tanks 5/6 Grouting (through August 22, 2013), Tanks 5/6 

Grouting Equipment, Tanks 5/6 Bulk Fill Grout Pumps, Tanks 5/6 Cooling Coil Fill Grout Skid, 

Tanks 5/6 Bulk Grout Fill, Grout Testing Protocol, Tanks 5/6 Bulk Grout Fill, Cooling Coil Grout 

Fill, Tanks 5/6 Field Observation, Tanks 5/6 Grouting Schedule, Equipment Fill, Equipment Fill 

Grout, Coiling Coil Fill, Coiling Coil Fill Grout, Annulus Grouting, and Riser Grouting, and Status 

of Tank Closure Progression. 

After observing the grouting of Tanks 5/6, NRC staff and DOE watched video of specific Tanks 

5/6 grouting activities: Primary Tank Grout (Lift 1), Annulus Grout Fill (Lifts 2 and 3), and 

Cooling Coil Grout Fill (Broken Coils). 

• NRC staff inquired about the change in grout formulation from Tanks 18/19, which would 

allow the grout to flow more easily around cooling coils in Type I Tanks, such as Tanks 

5/6. NRC staff inquired about the maximum water-to-cement ratio and if a higher waterto-cement ratio was used in Tanks 5/6 versus Tanks 18/19 to achieve greater flowability. 

• DOE indicated that the maximum water-to-cement ratio of 0.58 for Tanks 5/6 was 

calculated based on the values in the table in Attachment 5.5 to C-SPP-F-00055. That 

value is similar to the water-to-cement ratio for Tanks 18/19. 

o The amount of high range water reducer was increased to achieve greater 

flowability, as reflected in the slump. The targeted slump range is 26 – 30 inches 

[66 - 76 cm] for Type I Tanks 5/6 and 24 – 28 inches [61 – 71 cm] for Type IV 

Tanks 18/19. 
- 7 - 

o DOE also has some control of slump in the field. A quantity of water is reserved 

until the grout is delivered to the work site. That additional water can then be 

added to achieve the desired slump, if needed. 

• NRC staff inquired as to whether DOE planned to formally document the lessonslearned from grouting Tanks 18/19. 

• DOE indicated that it did not have plans to develop such lessons-learned documentation 

at this point in time, but that there is potential for formally documenting lessons-learned 

after Tanks 5/6 are grouted. One of the DOE lessons-learned from Tanks 18/19 

grouting was that 90-day compressive strength measurements were not needed 

because the 28-day tests showed sufficient strength. Another one was the need for 

more flowable grout to avoid mounding of tank grout underneath risers used as access 

points for grouting. 

• NRC staff inquired as to whether DOE plans to do testing on shrinkage compensating 

grout formulas, as recommended by Savannah River National Laboratory (SRNL). 

• DOE indicated that no additional testing beyond that documented in “Tanks 18 and 19-F 

Structural Flowable Grout Fill Material Evaluation and Recommendations” (SRNL-STI2011-00551, Rev. 1) was planned. 

• DOE highlighted that, for tanks with cooling coils, when compared to tanks without 

cooling coils, shrinkage around the cooling coils could potentially aid in the reducing 

capability of the grout mixture because the water pathways would likely be throughout 

the interior of the tank, as opposed to along the tank walls. NRC staff acknowledged the 

potential for that phenomenon. 

• NRC staff indicated that the primary concern related to tank grouting is shrinkage of 

grout away from the tank wall, which will accentuate the potential for by-pass flow of 

infiltrating water around reducing tank grout. 

• NRC staff indicated that more contact of infiltrating groundwater with reducing grout is 

expected for tanks with cooling coils (i.e., shrinkage concentrated at the tank wall in 

Type IV Tanks may be more risk-significant), but the main concern is that the DOE 

reference case does not account for by-pass flow for any tank. 

• NRC staff and DOE agreed that a preferential pathway case may represent a bounding 

scenario and discussed different methods of adding realism to the performance 

assessment calculations. 

• NRC staff indicated that segregation of grout could lead to higher porosity, higher 

permeability, and less reductive grout at the periphery of the Type IV Tanks. Higher 

water-to-cement ratios at the periphery of Type IV Tanks, due to the delivery of grout in 

the center riser, could also lead to greater shrinkage along the tank walls. With regard to 

shrinkage in Type I Tanks, such as Tanks 5/6, shrinkage away from cooling coils and the 

tank wall could lead to by-pass flow. 
- 8 - 

• NRC staff indicated that shrinkage compensating formulations may be more successful 

in tanks with internal restraints (e.g., coiling coils), such as Type I Tanks. 

• NRC staff agreed with DOE that in the case of shrinkage away from walls and internal 

restraints, infiltrating groundwater may contact more of the tank grout in Type I Tanks 

compared to Type IV Tanks. That is because shrinkage in Type I Tanks would be more 

widely distributed. Shrinkage in Type I Tanks would occur along the interface of the tank 

grout and either the surface of the tank wall or the surfaces of internal structures, such 

as cooling coils. Shrinkage in Type IV Tanks may be concentrated along the tank wall. 

• NRC staff inquired about the basis for the 10 feet (3.048 meters) drop height of grout 

into the tanks. 

• DOE indicated that the drop height is actually 5 feet (1.524 meters) and believed that the 

basis for the allowable drop height is found in an American Concrete Institute standard, 

which allows a drop height of up to 10 feet (3.048 meters) without additional evaluation. 

DOE added that the drop height was evaluated by SRNL. However, it was not clear to 

NRC staff that SRNL evaluated the acceptability of the drop height for Tanks 5/6. 

• NRC staff inquired about the grout testing protocol, including which tests and how the 

results of the tests are used to make acceptance decisions for the grout. 

• DOE indicated that only the time, drum rotations, and slump test results are used for 

grout acceptance decisions. 

o Grout mixes may be rejected if they do not meet the specified slump flow. The 

grout must also be discharged within 90 minutes and 300 drum revolutions. 

o The results of the bleed water test would not impact grout acceptability. 

However, failing a bleed water test would cause DOE to investigate the reasons 

and make any necessary adjustments with the grout supplier. Similarly, results 

of the temperature test would not impact grout acceptability, but will be used in 

recommending adjustments to the supplier. 

o At the time of the observation, all results for time, drum rotations, and slump tests 

had been documented and all grout had been accepted. The tests are carried 

out in compliance with American Society for Testing and Materials Standards. 

• NRC staff questioned the representativeness of test samples for emplaced grout for the 

7-day and 28-day compressive strength tests.

• NRC staff observed that the tapping and molding actions performed by the testing staff 

may not mimic what occurs within a tank. However, generally, the grout significantly 

exceeded the required strength by the 28-day test and compressive strength may not be 

as risk-significant as other concerns. 

• NRC staff inquired about which risers DOE has access to for grouting Tanks 5/6. 
- 9 - 

• DOE clarified that there are preferred access points (i.e., Risers 1, 3, 5, 8) and only one 

of those risers will be used at any given time. Any of the other risers could be used with 

approval from the Engineering Team and after retrofitting that riser to accept the grout. 

• NRC staff watched video of grouting Tanks 5/6 to observe flowability of grout, potential 

for mounding/lumping, and coverage capability of the video. 

o Some color differentiation (i.e., marbleizing) of grout introduced to the Tank 5 

annulus was observed, which indicated a potential lack of mixing in some places. 

o The video of grouting of failed cooling coils clearly showed the residual water and 

water/grout mixture exiting the broken end of the coil, followed by the grout until it 

reached a constant consistency/color. 

o The video showed the injection of the ‘pig’ (i.e., foam ball used to clean the grout 

delivery hose) at the completion of a grout pour. 

• NRC staff inquired about the annulus risers that would be used for grouting. 

• DOE clarified that the annuli have four risers (i.e., North, South, East, West) and both an 

intake and outtake for the ventilation duct system. The North and South annulus Risers 

will be used to place grout and all four annulus risers will be used to support videotaping. 

• NRC staff inquired as to how DOE ensures that the inside of the ventilation duct is 

grouted. 

• DOE explained how the interior structure of the ventilation duct at the connection with 

the top of the tank is similar to pants legs, where the grout will be introduced to one side 

of the leg and flow around the circular duct to the other side. DOE confirmed that the 

grout has flowed to the opposite side through video showing the grout flowing within the 

duct beneath the open register. NRC staff observed video of flow within a duct. 

2.2.3 Conclusions and Follow-up Actions:

The NRC staff will continue to monitor FTF activities related to observing grout-filling tanks. 

There are no follow-up actions that resulted from that observation. The NRC staff will continue 

to monitor FTF activities related to the grout formula, development, and testing documentation. 

The following two follow-up actions resulted from that technical discussion: 

• DOE to provide NRC with Idaho grout drop report, Grout/CLSM Testing and Selection 

for the INTEC Tank Farm Closure (EDF-6715, Rev. 0). 

• DOE to provide NRC with basis for the 10-foot grout drop height. 

 
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3.0 OVERALL CONCLUSIONS, STATUS OF MONITORING AREAS, MONITORING 

FACTORS, OPEN ISSUES, AND OPEN FOLLOW-UP ACTION ITEMS; AND 

ISSUANCE OF NRC TECHNICAL REVIEW REPORTS: 

3.1 Overall Conclusions: 

The information gathered during FTF Observation 2013-02 will be used for multiple NRC 

Technical Review Reports via memoranda and future onsite observation visits, based on the 

topics discussed. There is no change to the NRC staff overall conclusions from the FTF TER 

regarding compliance of DOE disposal actions with the 10 CFR Part 61 performance objectives 

3.2 Status of Monitoring Areas in FTF Monitoring Plan, Rev. 0: 

FTF Observation 2013-02 is the second onsite observation visit under the FTF Monitoring Plan 

(NRC, 2013b). NRC staff did not close any monitoring areas during FTF Observation 2013-02. 

Therefore, all eight monitoring areas (i.e., 1-Inventory, 2-Waste Release, 3-Cementitious 

Material Performance, 4-Natural System Performance, 5-Closure Cap Performance, 

6-Performance Assessment Maintenance, 7-Protection of Individuals During Operations, and 

8-Site Stability) in the FTF Monitoring Plan, Rev. 0 remain open. 

3.3 Status of Monitoring Factors in FTF Monitoring Plan, Rev. 0: 

FTF Observation 2013-02 is the second onsite observation visit under the FTF Monitoring Plan 

(NRC, 2013b). NRC staff did not close any monitoring factors during FTF Observation 2013-02. 

Therefore, all 26 Monitoring Factors (i.e., 1.1 – 1.5, 2.1 – 2.2, 3.1 – 3.6, 4.1 – 4.3, 5.1 – 5.3, 6.1 

– 6.3, 7.1 – 7.3, 8.1), including similar ones for different performance objectives, in the FTF 

Monitoring Plan, Rev. 0 remain open. 

3.4 Status of Open Issues for FTF Monitoring: 

Previously, there were no FTF Open Issues. NRC staff did not open any new Open Issues 

during FTF Observation 2013-02. Therefore, there are currently no FTF Open Issues. 

3.5 Status of Open Follow-up Action Items from Previous FTF Onsite Observation Visit 

Reports: 

There were three previous NRC FTF onsite observation visits. The status of open follow-up 

action items from the publicly available reports for those onsite observation visits is listed below: 

• Report for FTF Observation 2012-01 (June 12, 2012) (NRC, 2012b) with Guidance 

issued on June 4, 2012, (NRC, 2012a): All Action Items completed.

• Report for FTF Observation 2012-02 (September 26-27, 2012) (NRC, 2012d) with 

Guidance issued on August 23, 2012, (NRC, 2012c): All Action Items completed.

• Report for FTF Observation 2013-01 (March 27-28, 2013) (NRC, 2013h) with Guidance 

issued on February 25, 2013, (NRC, 2013d): All Action Items completed.

 
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3.6 Status of Open Follow-up Action Items from Clarifying Teleconference Calls: 

Between FTF Observation 2013-01 and FTF Observation 2013-02, NRC held three clarification 

teleconference calls with DOE. The status of open follow-up actions items from those publicly 

available teleconference call summaries is listed below: 

• Summary of May 1, 2013, Clarifying Teleconference Call – Tank 18 Grouting Operation 

Videos from FTF, May 24, 2013, (NRC, 2013g). One Action Item not yet completed: 

DOE to provide in writing or in another NRC telecon a response to the NRC main points 

about water segregation and the NRC observations of Tank 18 grouting videos.

• Summary of May 8, 2013, Clarifying Teleconference Call – FTF Tanks 5/6 Special 

Analysis, June 3, 2013, (NRC, 2013i). All Action Items completed.

• Summary of the May 15, 2013, Clarifying Teleconference Call – FTF Volume Mapping 

and Inventory, June 18, 2013, (NRC, 2013j). All Action Items completed.

3.7 Issuance of NRC Technical Review Reports: 

Between FTF Observation 2013-01 and FTF Observation 2013-02, NRC issued the following 

FTF Technical Review Reports via memorandum, which are publicly available: 

• Technical Review – “Tanks 18 and 19 Special Analysis for the Performance Assessment 

for the F-Tank Farm at the Savannah River Site,” (SRR-CWDA-2010-00124, Rev. 0), 

April 10, 2013, (NRC, 2013f) 

• Technical Review – Waste Release and Solubility Related Documents Prepared by 

United States Department of Energy to Support Final Basis for Section 3116 

Determination for the F-Area Tank Farm Facility Savannah River Site, May 31, 2013, 

(NRC, 2013h) 

4.0 PARTICIPANTS:

U. S. NRC SCDHEC U.S. DOE SRR

Cynthia Barr Byron Amick Dan Ferguson Greg Arthur 

Harry Felsher Leigh Beatty Sherri Ross Ben Dean 

Christopher Grossman Barry Mullinax Linda Suttora Mark Layton 

Christepher McKenney Scott Simons Amada Watson Mark Mahoney 

Leah Parks Bruce Martin 

 Rana O’Bryant 

 Joe Pavletich 

 Larry Romanowski 

 Kent Rosenberger 

 James Rush 

 Steve Thomas 

 Skip Wiggins 

 
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5.0 REFERENCES:

10 CFR Part 61, Federal Register, “Licensing Requirements for Land Disposal of Radioactive 

Waste,” Code of Federal Regulations, Office of the Federal Register, January 2001. 

U.S. Congress, “Public Law 108-375, Ronald W. Reagan National Defense Authorization Act for 

Fiscal Year 2005, Section 3116, Defense Site Acceleration Completion,” October 2004. 

U.S. Department of Energy (DOE), DOE Manual 435.1-1, “Radioactive Waste Management 

Manual, Change 1,” June 2001, ML110800193. 

_____, DOE Order 435.1, “Radioactive Waste Management,” August 2001, ML101590125. 

_____, SRS-REG-2007-00002, Rev. 1, “Performance Assessment for the F-Tank Farm at the 

Savannah River Site,” March 31, 2010, ML102850339. 

_____, DOE/SRS-WD-2010-001, Rev. 0, “Draft Basis for Section 3116 Determination for 

Closure of F-Tank Farm at the Savannah River Site,” September 30, 2010, ML102790078. 

_____, SRR-CWDA-2010-00124, Rev. 0, “Tank 18/Tank 19 Special Analysis for the 

Performance Assessment for the F-Tank Farm at the Savannah River Site,” February 2012. 

_____, DOE/SRS-WD-2012-001, Rev.0, “Basis for Section 3116 Determination Closure of FTank Farm at Savannah River Site,” March 2012, ML121140051. 

_____, SRR-CWDA-2013-00051, Rev. 1, “Presentation for Savannah River Site F-Tank Farm 

NRC Onsite Observation Visit on March 27-28, 2013,” March 28, 2013, ML13093A159. 

U.S. Nuclear Regulatory Commission, NUREG-1854, “NRC Staff Guidance for Activities 

Related to U.S. Department of Energy Waste Determinations – Draft Final Report for Interim 

Use,” August 2007, ML072360184. (NRC, 2007) 

_____, “Technical Evaluation Report for F-Area Tank Farm Facility, Savannah River Site, South 

Carolina, Final Report,” October 2011, ML112371715. (NRC, 2011) 

_____, “Onsite Observation Guidance for June 11-12, 2012, Waste Monitoring Visit to the 

Savannah River Site, F-Area Tank Farm,” June 4, 2012, ML12135A666. (NRC, 2012a) 

_____, “U.S. Nuclear Regulatory Commission June 12, 2012, Onsite Observation Report for the 

Savannah River Site F-Tank Farm Closure,” September 5, 2012, ML12191A210. (NRC, 2012b) 

_____, “Observation Guidance for September 26-27, 2012, Waste Monitoring Visit to the 

Savannah River Site, F-Area Tank Farm,” August 23, 2012, ML12228A631. (NRC, 2012c) 

_____, “U.S. Nuclear Regulatory Commission September 26-27, 2012, Onsite Observation 

Report for the Savannah River Site F-Tank Farm Closure,” December 5, 2012, ML12299A190. 

(NRC, 2012d) 
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_____, Letter from L. Camper to M. Gilbertson transmitting the NRC’s F-Area Tank Farm 

Monitoring Plan, Rev. 0, to DOE, “The U.S. Nuclear Regulatory Commission Planned 

Monitoring Activities for F-Area Tank Farm at the Savannah River Site,” January 23, 2013, 

ML12345A318. (NRC, 2013a) 

_____, “U.S. Nuclear Regulatory Commission Plan for Monitoring Disposal Actions Taken by 

the U.S. Department of Energy at the Savannah River Site F-Area Tank Farm Facility in 

Accordance With the National Defense Authorization Act for Fiscal Year 2005,” January 2013, 

ML12212A192. (NRC, 2013b) 

_____, Federal Register Notice (FRN) – Notice of Issuance for NRC Plan for Monitoring 

Disposal Actions taken by DOE at the Savannah River Site F-Area Tank Farm,” February 21, 

2013, ML13046A192. (NRC, 2013c) 

_____, “Onsite Observation Guidance for March 27-28, 2013, Monitoring Visit to the Savannah 

River Site, F-Area Tank Farm,” February 25, 2013, ML13046A374. (NRC, 2013d) 

_____, “Technical Review – Updated Cost-Benefit Analysis for Removal of Additional Highly 

Radioactive Radionuclides from Tank 18,” March 21, 2013, ML13080A401. (NRC, 2013e) 

_____, “Technical Review – ‘Tanks 18 and 19 Special Analysis for the Performance 

Assessment for the F-Tank Farm at the Savannah River Site,’ (SRR-CWDA-2010-00124, 

Rev. 0),” April 10, 2013, ML13100A230. (NRC, 2013f) 

_____, “Summary of May 1, 2013, Clarifying Teleconference Call between the U.S. Nuclear 

Regulatory Commission and the U.S. Department of Energy Regarding Tank 18 Grouting 

Operation Videos from F-Area Tank Farm at the Savannah River Site,” May 24, 2013, 

ML13127A291. (NRC, 2013g) 

_____, “Technical Review – Waste Release and Solubility Related Documents Prepared by 

United States Department of Energy to Support Final Basis for Section 3116 Determination for 

the F-Area Tank Farm Facility Savannah River Site, May 31, 2013,” ML12272A082. 

(NRC, 2013h) 

_____, “Summary of May 8, 2013, Clarifying Teleconference Call between the U.S. Nuclear 

Regulatory Commission and the U.S. Department of Energy Regarding F-Area Tank Farm 

Tanks 5/6 Special Analysis for the Savannah River Site,” June 3, 2013, ML13133A125. 

(NRC, 2013i) 

_____, “Summary of the May 15, 2013, Clarifying Teleconference Call between the U.S. 

Nuclear Regulatory Commission and the U.S. Department of Energy Regarding F-Area Tank 

Farm Volume Mapping and Inventory for the Savannah River Site,” June 18, 2013, 

ML13150A219. (NRC, 2013j) 

_____, “U.S. Nuclear Regulatory Commission March 27-28, 2013, Onsite Observation Report 

for the Savannah River Site F-Tank Farm Facility,” July 2, 2013, ML13113A322. (NRC, 2013k) 

_____, “Onsite Observation Guidance for August 27-28, 2013, Monitoring Visit to the Savannah 

River Site, F-Area Tank Farm,” July 29, 2013, ML13196A134. (NRC, 2013l)