August 31, 2012 

Mr. Terry J. Spears 

Assistant Manager 

Waste Disposition Project 

U.S. Department of Energy 

Savannah River Operations Office 

P.O. Box A 

Aiken, SC 29802 

SUBJECT: ACKNOWLEDGEMENT OF U.S. DEPARTMENT OF ENERGY’S LETTER 

DATED JULY 12, 2012, REGARDING U.S. NUCLEAR REGULATORY 

COMMISSION’S LETTER OF CONCERN (TYPE IV) REGARDING DISPOSAL 

ACTIVITIES AT THE SAVANNAH RIVER SITE SALTSTONE DISPOSAL 

FACILITY 

Dear Mr. Spears: 

The purpose of this letter is to acknowledge U.S. Department of Energy (DOE) correspondence, 

dated July 12, 2012, regarding the U.S. Nuclear Regulatory Commission’s (NRC’s) Letter of 

Concern (Type IV) regarding salt waste disposal actions planned by DOE at the Savannah 

River Site (SRS) Saltstone Disposal Facility (SDF). Additionally, we provide our preliminary 

assessment of the information included in the DOE response. 

Section 3116(b) of the Ronald W. Reagan National Defense Authorization Act for Fiscal Year 

2005 requires the NRC to monitor certain disposal actions taken by the DOE for the purpose of 

assessing compliance with the performance objectives set out in 10 CFR Part 61, Subpart C. 

NRC monitoring activities of the Saltstone facility began following the 2007 completion of the 

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. These activities have included onsite observations, 

technical reviews, and meetings with DOE. 

On April 30, 2012, NRC issued both the Technical Evaluation Report (TER) [available via the 

NRC’s Agencywide Documents Access and Management System (ADAMS) at Accession 

Number ML121020140] and Type IV Letter of Concern [available via ADAMS at Accession 

Number ML120650576]. The TER concluded that the NRC does not have reasonable 

assurance that salt waste disposal at the SDF meets the performance objectives in 

10 CFR Part 61. The Type IV Letter of Concern formally communicated NRC’s concerns to 

DOE and the South Carolina Department of Health and Environmental Control. 

On May 29, 2012, NRC held a public meeting with DOE and discussed the results of the TER. 

In that meeting, DOE indicated that it would: (1) provide research results developed since 

August 2011 to NRC in June 2012; and (2) provide information in response to the Type IV Letter 

to NRC in July or August 2012. On June 13, 2012, DOE sent NRC the research results. 
T. Spears 2 

On July 12, 2012, DOE responded to the NRC Type IV Letter, which included the statement that 

further information in response to the Type IV Letter was expected to be provided to NRC later 

in July 2012. The June 13 and July 12, 2012, submittals included information about updated 

technetium-99 (Tc-99) inventory projection for SRS Saltstone Disposal Units (SDU) 2, 3, and 5 

as well as information about Case K and K1 uncertainty and sensitivity analyses. On 

July 26, 2012, DOE sent NRC additional information to supplement the previous letters of 

June 13 and July 12, 2012. The July 26, 2012, information has not yet been fully evaluated by 

the NRC and will not be discussed further in this letter. 

The NRC staff has evaluated the information DOE provided about the revised inventory of Tc-99 

in SDUs 2, 3, and 5 and finds the bases for the revision to be reasonable. Based on the NRC’s 

TER analyses and DOE’s revised Tc-99 inventory, the NRC staff concludes that a Type II Letter 

to the U.S. Congress is not needed at this time. The staff determined that, if DOE’s new 

projected Tc-99 inventory for SDUs 2, 3, and 5 is correct, then it is unlikely to cause an off-site 

peak dose exceeding the requirements of §61.41 (i.e., 0.25 mSv/yr (25 mrem/yr)). 

Therefore, based on the information provided, the NRC would offer no comments on the DOE’s 

plan regarding the placement of saltstone into SDUs 2, 3, and 5. We will continue to interact 

with DOE, address technical issues identified in the Type IV letter, and coordinate with the State 

of South Carolina. The NRC staff is continuing to evaluate the basis for DOE’s revised 

inventory projections and will later revisit the decision to send a Type II Letter if the staff finds 

that the projected inventory estimates are not well supported. 

The NRC staff is also in the process of evaluating the revised probabilistic model (from the DOE 

letter with enclosures dated June 13, 2012), which addresses some of the issues described in 

the NRC staff’s two requests for additional information [available via ADAMS at Accession 

Number ML100820101 and Accession Number ML103400571]. However, the staff anticipates 

that the utility of the model will be limited unless it can be further revised to address concerns 

outlined in the NRC’s TER, including the following three major concerns: (1) unsupported 

reconcentration of Tc-99 in the disposal unit concrete; (2) use of the average-Kd model; and 

(3) unsupported timing of saltstone fracturing. In addition, the remaining technical concerns in 

the TER include the following: (1) support for long-term performance of the closure cap in 

limiting infiltration and erosion; (2) the hydraulic performance of field-emplaced saltstone; 

(3) model support for saltstone physical degradation; (4) long-term saltstone chemical 

performance; (5) disposal unit performance; (6) subsurface sorption coefficients; and (7) effects 

of settlement on site stability. 

On August 6, 2012, NRC held a public meeting in Aiken, South Carolina to discuss waste 

disposal at the SRS. Included in the agenda for the meeting were the following two topics: 

(1) “DOE Presentation on DOE Path Forward to Resolve NRC’s Concerns”; and (2) “NRC 

Questions on DOE Path Forward.” In addition, NRC performed an onsite observation at SDF on 

August 7-8, 2012, where that same information was discussed. Separate summaries for both 

the meeting and the observation will be issued in the future and will not be discussed further in 

this letter. 

A copy of this letter will be available electronically for public inspection in the NRC Public 

Document Room or using its ADAMS accession number ML12213A447. ADAMS is accessible 

from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. 
T. Spears 3 

The NRC, like DOE, considers it to be in the public interest and important to dispose of the salt 

waste in a safe and timely fashion. If you have any questions or need additional information, 

please call me at (301) 415-7197, or call Nishka Devaser, the Saltstone Project Manager, at 

(301) 415-5196. 

Sincerely, 

/RA/ 

Mark A. Satorius, Director 

Office of Federal and State Materials 

 and Environmental Management Programs 

cc: 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. Spears 3 

The NRC, like DOE, considers it to be in the public interest and important to dispose of the salt 

waste in a safe and timely fashion. If you have any questions or need additional information 

please call me at (301) 415-7197, or call Nishka Devaser, the Saltstone Project Manager, at 

(301) 415-5196. 

Sincerely, 

/RA/ 

Mark A. Satorius, Director 

Office of Federal and State Materials 

 and Environmental Management Programs 

cc: S. Wilson 

Federal Facilities Liaison 

Environmental Quality Control 

 Administration 

South Carolina Department of Health 

 and Environmental Control 

2600 Bull Street 

Columbia, SC 29201-1708 

DISTRIBUTION: GAlexander ARidge HFelsher KPinkston RidsFsmeOd FSME r/f 

ML12213A447 

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

NAME NDevaser TMoon GSuber CMcKenney LLondon 

(via email)

DATE 8/1/12 8/1/12 8/1/12 8/1/12 8/23/12 

OFC DWMEP DWMEP:DD FSME: Tech Ed FSME:OD 

NAME 

APersinko LCamper CPoland 

(PTressler for) MSatorius 

DATE 8/16/12 8/23 /12 8/27 /12 08/31 /12 / /12 

OFFICIAL RECORD COPY