Release Activities and Methodology Associated with Mixed Waste Landfill Expansion Tuesday, September 18, 2012
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
Expansion and Cover – What Got the Ball Rolling • Mixed Waste: • Total volume increase: 256,691 cy3 • Total area under cover: 147,858 ft2
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
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!
Permitting/Preparation • Survey Units established from Mixed Waste Release HSA: • Mixed Waste Cover
Permitting/Preparation • Survey Units established from Mixed Waste Release HSA: • Mixed Waste Expansion
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
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.”
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.”
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.”
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.
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
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.
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
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.
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
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.