Release Activities and Methodology Associated with Mixed Waste Landfill Expansion

1. Release Activities and Methodology Associated with Mixed Waste Landfill Expansion Tuesday, September 18, 2012

2. Purpose • Expansion and Cover – What Got the Ball Rolling • Permitting and Preparation – Need for Speed; Need for Efficiency • Historical Site Assessments • Mixed Waste Area Release – Scope and Requirements • MARSSIM: General Requirements • State of Utah: General Requirements • Instrumentation and Quality Assurance • Current Status

3. Expansion and Cover – What Got the Ball Rolling

4. Expansion and Cover – What Got the Ball Rolling

5. Expansion and Cover – What Got the Ball Rolling

6. Expansion and Cover – What Got the Ball Rolling

7. Expansion and Cover – What Got the Ball Rolling

8. Expansion and Cover – What Got the Ball Rolling • Mixed Waste: • Total volume increase: 256,691 cy3 • Total area under cover: 147,858 ft2

9. Permitting/Preparation • Permitting and release performed on parallel paths • Total Permitting time for both projects ran roughly 20 months. • Preparation: Historical Site Analysis – Doing the Detective Work! “By failing to prepare, you are Preparing to fail.” -Benjamin Franklin

10. Permitting/Preparation • Historical Site Analysis (HSA): • Takes place outside the boundaries of MARSSIM • Single most important part of the release! • A good HSA allows you to: • Establish Survey/Release Units. • Determine excavation extents. • Efficiently direct manpower. • Ensure release criteria are met the FIRST time. • Build trust with the Regulator. • Eliminate surprises!

11. Permitting/Preparation • Survey Units established from Mixed Waste Release HSA: • Mixed Waste Cover

12. Permitting/Preparation • Survey Units established from Mixed Waste Release HSA: • Mixed Waste Expansion

13. Mixed Waste Release Requirements • MARSSIM, NUREG 1575, Section 1.1: • “The demonstration of compliance with respect to conducting surveys is comprised of three interrelated parts: • Translate • Measure • Decide

14. Mixed Waste Release Requirements • MARSSIM, NUREG 1575, Section 1.1, continued: • “Translate: Translating the cleanup/release criterion (e.g., mSv/y, mrem/y, specific risk) into a corresponding derived contaminant concentration level (e.g., Bq/kg or pCi/g in soil) through the use of environmental pathway modeling.”

15. Mixed Waste Release Requirements • MARSSIM, NUREG 1575, Section 1.1, continued: • “Measure: Acquiring scientifically sound and defensible site-specific data on the levels and distribution of residual contamination, as well as levels and distribution of radionuclides present as background, by employing suitable field and/or laboratory measurement techniques.”

16. Mixed Waste Release Requirements • MARSSIM, NUREG 1575, Section 1.1, continued: • “Decide: Determining that the data obtained from sampling does support the assertion that the site meets the release criterion, within an acceptable degree of uncertainty, through application of a statistically based decision rule.”

17. Mixed Waste Release Requirements • Translate: • EnergySolutions Radioactive Material License; License Condition 26: • “The operational environmental monitoring program shall be conducted in accordance with the Environmental Monitoring Plan (dated: September 30, 2010).” • EnergySolutions’ Environmental Monitoring Program, Section 3: • Soil Action Levels: 5 pCi/g by gamma spectroscopy for a naturally occurring radionuclide (other than potassium-40), 3 pCi/g cesium-137, or 2 pCi/g for any other radionuclide.

18. Mixed Waste Release Requirements • Measure: • EnergySolutions’ Procedure CL-RS-PR-180, Rev. 01, “Restricted Area Release Surveys,” Sections 4.2 – 4.3: • Characterize the area by: • Delineating the boundaries of the release area. • Generate a release map • Scans: • Walk-over scan (Ludlum Model 193 or 193-6) • Direct Frisk readings using the Model 2360 with Model 43-93 Probe in any areas that were noted to have indication of potential for contamination • Visual Inspection and Soil Sampling

19. Mixed Waste Release Requirements • Decide: • Decision 1: Was characterization scanning and sampling adequate enough to guide comprehensive excavation and decontamination? • If yes, enter Final Status Survey. Upon completion of Final Status Survey: • Decision 2: Are the data consistent with the ability to release? • All soil sample results must meet 5, 3, 2 release criteria. • Soil sample results must be verified against results obtained from a different Lab/Instrument. Replicative Error Ratio (RER) Test.

20. Mixed Waste Release Requirements • A Little More on the Final Status Survey... • MARSSIM suggestion for a dirt release: • 1 sample for every 2000 m2 • EnergySolutions’ requirement for a dirt release: • 1 sample for every 100 m2

21. Instrumentation and Quality Assurance • Precision: A comparison of duplicate samples analyzed at both EnergySolutions and an offsite laboratory as an indicator of instrument precision with respect to sample analysis. • Accuracy: A comparison of split samples analyzed against the original samples, both at EnergySolutions’ internal lab, is an indicator of the accuracy of the sampling method and analysis.

22. Instrumentation and Quality Assurance • Replicative Error Ratio (RER) • There is a need to ensure the accuracy and precision of the machine being used to analyze samples. The data are only as good as the equipment used to measure it. • Where: X= analytical results for sample X Y= analytical results for sample Y sx= reported analytical uncertainty for sample X sy= reported analytical uncertainty for sample Y

23. Current Status • Mixed Waste Extension: • Completed: Report sent in to Utah Division of Radiation Control on May 21, 2012. • Mixed Waste Cover Support: • Releasing based on Survey Unit, as Operations requires. • Tentative completion date will fall around mid-October, 2012.

24. Questions? Thanks!