ML19351A677
| ML19351A677 | |
| Person / Time | |
|---|---|
| Issue date: | 11/30/1989 |
| From: | Hedges D, Pittiglio C, Starmer R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| References | |
| NUREG-1383, NUREG-1383-DRFT, NUREG-1383-DRFT-FC, NUDOCS 8912210144 | |
| Download: ML19351A677 (15) | |
Text
.
4 NUREG-1383 1
Guidance on the Application of Quality Assurance for Characterizing a Low-Level Radioactive Waste Disposal Site Draft for Comment i
i U.S. Nuclear Regulatory Commission l
Office of Nuclear Material Safety and Safeguards
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l AVAILABILITY NOTICE i
i Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications 'will be availabio from one of the following sources:
1.
The NRC Public Document Room. 2120 L Stroot NW, Lower Lovel, Washington, DC 20555 2.
The Superintendent of Documents, U.S. Government Printing Office, P.O. Box 37082, Washington, DC 20013 7082 3.
The National Technical information Service, Springfield, VA 22161 Although the listing that follows represents the majority of documents cited in NRC publica-tions, it is not intended to be exhaustivo, r
Referenced documents available for inspection and copying for a fee from the NRC Public Document Room includo NRC correspondonce and internal NRC memoranda: NRC Offico of Inspection and Enforcomont bulletins, circulars, Information noticos, inspection and investi-gation noticos; Licensoo Event Reports; vendor reports and correspondonce: Commission papors; and applicant and licensoo documents and cortospondonce.
The following documents in the NUREG series are available for purchase from the GPO Sales Program: formal NRC staff and contractor reports. NRC sponsored confarence proceed-ings, and NRC booklets and brochuros. Also available oro Regulatory Guidos NRC regula-tions in the Codo of Foderal Regulations, and Nuclear Regulatory Commission issuances.
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Nuclear Rogulatory Commission, Washington, DC 20555.
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Guidance on the Application of Quality Assurance for Characterizing a Low-Level i
Radioactive Waste Disposal Site Draft for Comment Manuscript Completed: November 1989 Date Published: November 1989 6
C, L Pittiglio, Jr., R. J. Starmer D. liedges Division of Low Level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Wcshington, DC 20555 l
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l ABSTRACT This document provides the Nuclear Regulatory Com-ance (QA) program and for the guidance provided herein.
mission's staff guidance to an applicant on meeting the QA guidance is specified for site characterization activi-quality control (QC) requirements of Titic 100f the Code ties necessary to meet the performance objectives of of federal Regulations, Part 61, Section 61.12 (10 CFR -
10 CFR Part 61 and to limit exposure to or release of ra-61.12), for a low level waste disposal facility. 'Ihe QC re.
dioactivity.
quirements are the basis for developing a quality assur-f i
I i
iii NUREG-1383 l
\\
r 3
CONTENTS i
Page Abstract...................................................................,.................
iii I
l I n t rod u Clio n...............................................................................
1 L
2 llegulatory llasis for Quality Assurance Program....,.......................,.,.................
1 l.
3 Identification of Parameters and Tests for livaluating a Disposal Site...............................
1 4 Documentation of 1.aboratory or Field Test Procedures...........................................
6 l.
5 Qualifications and 'thiining for Personnel Conducting Site Characterization Activities.................
7 6 Storage of Site Charact eritation Data..........................................................
7 7 Itecords for Site Characterization Activitics.....................................................
8 8 l i ibl iogra p hy...............................................................................
8 l
l$
t l
I Null 110-1383 v
r QA GUIDANCE FOR CilARACTERIZING A LLRW DISPOSAL SITE 1 1NTRODUCTION ments provide the bases for requiring the development of a OA program.
'the United States Congress passed laws in 1980 and 1985 that require States to take specific actions to deal with the lhe regulatory requirements for managerial controls, low-levet radioactive waste gencruted by facilities operat, audits, and quality control apply to the preoperational ing within their boundaries.1hc 1980 law (Public law phase, the operational phase, the site closure phase, and 96-573, The low Level Radioactive Waste Policy Act) the post closure institutional control phase. 'these re.
specifies that each State will be responsible for disposing quirements cover all activities, structures, systems or its own radioactive waste after January 1,1986; authorizes cornponents whose failure could result in not meeting the States to join together to form regional compacts; and performance objectives of 10 CI R Part 61 or not limiting authorizes those compacts to prohibit disposal of low, the exposure to or tclease of radioactivity. 'lhe applicant level radioactive waste generated outside of the regional should develop and implement an effective QA program compact.The 1985 amendment (Public law 99-240,'Ihe before starting site characterization activities and, as the low level Radioactive Waste Policy Amendmcrits Act) licensee, should continue an effective QA program until extended the date to January 1993. This amendment im.
the license has been transferred or terminated. Site char-poses intermediate milestones that the States are re.
acterization is one of the initial and most significant activi-quired to meet to demonstrate progress and authorizes ties for determining the suitability of a site and demon-the States accepting this waste for disposal to impose a strating performance of an iIJtW disposal site; surcharge on the existing waste disposal costs.
therefore, it is important that proper quality assurance procedures are developed and applied to all site charu-terization activities.
In an attempt to assist the States in meeting these mile-stones, the Nuclear Regulatory Commission (NRC) has developed and issued several documents providing guid.
To ensure that the site meets regulatory r equirements, an ence on the development of a low level radioactive waste applicant should have management controls in place at disposal facility,'this document provides guidance to an the beginning of thc investigathm of the disposal site's tpplicant on the quality assurance principles for charac.
characteristics and before performing the analyses to es-terizing a disposal sitet it is not a regulatory requirement.
tablish a base for its suitability 'lhe applicant must be lhis document does not address all of the 18 criteria de.
prepared to demonstrate in the license application that fined in NUREG-1293, Quality Assurance Guidance for the proposed LLRW disposal site, disposal site design, Low Lew/Radioactin Waste Dispowl facility; however, it land disposal facility operations (including equipment, fa-provides some additional guidance on the criteria com.
cilities, and procedures), disposal site closure, and post-mon to all site characterization activities, in addition, the closure institutional control are adequate to demonstrate NRC is in the process of developing quality assurance that the performance objectives and technical requirc-j (QA) guidance in several other related areas and is con-ments of 10 CI R Part 61 will be met. The applicant tinuing to conduct workshops on the QA principles to be should crpect that the validity ofinformation contained in used by an applicant for license of a low-!cvel radioactive the license application will be challenged during licensing waste disposal facility as well as planning such workshops review and hearing, and the applicant must be prepared for site characterization activities.
to defend the validity of the data, the analyses, and the conclusions reached. A wc!!-designed and effectively im-P '*C"' d d^. program provides the disciplined ap.
2 REGULATORY HASIS FOR proach, verification of results, and records to support the l
l QUALI,N, ASSURAN,Ch, positio,s taken in the license application.
PROGRAh!
3 IDENTIFICATION OF Title 10 of the Code of federal Repdations. Part 61, Sec-PARAh1ETERS AND TESTS FOR tion 61.12(j)(10 Cl R 61.12(j)), requires that a license ap-plication for a low-level radioactive waste (LLRW) dis.
D,ALUA,FING A DISPOSAL SITE posal facility include a description of the quality control program to be applied to determining the natural charac.
As part of defining the quality assurance procedures for a teristics of a disposal site. The regulation also requires a license application,it is first necessary to identify the most QC program during design, construction, operation, and significant parameters for characterizing a site. This will closure of the LIJtW land disposal facility and thc re-provide an insight into the magnitude of wor k required for ceipt, handling, and emplacement of waste. Audits and site characterization. Table I lists the tests and proce-managerial controls must be included. These require-dures necessay to evaluate or document approximately 1
NURl!G-1383 I
f l
70 important site parameters for licensing an LLWR dis-including ecology, social economics, land use, cultural re-posal site, sources as wc!! as those listed in Table 1.
A detailed discussion of each of these parameters is pro-Section 5 provides guidancc on qualifications and training vided in NUREG/CR-2700, Parametersfor Characteri:ing for personnel conducting site characterization activities.
Sitesfor Disposal oflow Lcirl Radioactive li'aste. hiost of it is important to emphasize that characterization activi-the tests and procedures given in Table 1 are accepted tics-such as mapping, logging, sampling, testing, inter.
standard methods-such as those endorsed by the Ameri-pretation, and analysis-be conducted by technically can Society for Testing and hiatcrials (ASThi)-that are qualified personnel.
used nationwide and are listed in the column designated
" standard method." Other tests, designated as " formal-The most common (and most costly) error applicants ized guidance," provide documented direction for con-make is to not carefully plan the investigations needed to ducting activities related to site characterization. In addi.
characterize the site with a goal of assuring that the 11-l tion to the standard methods and formalized guidance, an cense application will be complete technically, procedur-additional category of methodsinvolves the usc of existing ally defensible, and supported by fully traceable docu-data sources or recognized correlations used in place of mentation of the quality of the technical work. A new testing or documentation. It may be necessary to well. planned and implemented QA program will ensure develop unique procedures for site-specific testing and that organizational responsibilitics are assigned, person.
measuring. NUREG/CR-3038, Testsfor Evaluating Sites nel are adequately trained, and plans and procedures are for Disposalo/ Low LewlRadioactiir IVaste, provides a de-written before site characterization activitics are started, scription of rnost of the tests idemified in Table 1. *lhe U.S. Depanment of Energy Site Characteri:ation Hand-In planning the tests to be conducted during site charac-book, DOE /11W-670, also provides information on terization, the applicant must assure that the resulting parameters and tests for characterizing an LLRW data will provide the information required to conduct a ll-disposal site.
censing assessment. 'lhe licensing assessment includes the initial step in site characterization of establishing the in anticipation of much diversity in materials and condi-present level of understanding about the site followed by tions between rnany sites across the country, many special identification of the issues related to meeting perform-parameters have been included for completeness, llow-ance objectives and technical requirements of 10 CFR ever, for a specific site, it may not be necessary to identify Part 61, and finally, collecting data required by regulation all the parameters listed in Table 1. Table 1 is only a par-and needed to support a complete and technically defen-tiallisting of parameters that characterire an LLRW dis-sible license application.The QA program should be an posal site, NUREG-0902, Site Suitability, Sclection and integral part of the test program to ensure adequate plan-Charactcriration. provides detailed guidance on all ning, equipment selection and use, training of personnel, parameters required to characterize a disposal site, sample handling and storage, and records of testing.
Table 1 Testing and other information to characterize LLRW slics Standard Parameter method
- Formalired guidance Existing data Air pressure ASThi Ilarometeric observations Weather records Air temperature
'Ihermometric obsenations Weather records Anisotropy Geological criteria Permeabilitics Tracer studies Apnarent velocity Atterberg limits ASThi CE I
'See foo. note at est of tabic.
1
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N Table 1 (Continued)
Standarxl Parameter smethod' Formalized guidance Esisting data I
Hurial unit boundaries Planc surveying Collapse susceptibility CE Geological criteria Grain-size data j
Compaction relation AS'IM Consolidation relation Cil Dispersion Ilreakthrough curves Electrical resistivity Total salinity of soil Surface resistivity survey llorchole resisthity sun'cy l
Specific conductance Erodibility Cil Agronomical criteria I!vapotranspiration livaporirneteric or lysimetric observations Weather records lhtended site boundary Technical review flow direction Tracer studies Well data Geological criteria Frost heaving Grain-size data Gascous con >tituents APil A ASTM Geological criteria Geomorphology Grain size distribution CII ARIM Groundwater chemistry APIIA EPA ASTM GS Gas chromatography for organic materials Geological criteria
- Groundwater system and boundaries liydraulic condt.ctivitics ASTM CII 1111 Pump tests Geological criteria Grain size data
- See knotnote at end of table.
3 NUl(EG-1383
Table 1 (Continued)
Standard Parameter method' Pormallred guidance l'.sisting data Welllogging liydraulic potentials and Piezometeric determination ptssures Technical review Immediate site boundary Infiltration capacity ASThi Curve number estimation Saturation method lon exchange capacity hichlich method litnology and soils Geological criteria Material color ASTM Color chart method Material densities AS111 Cl3 Gamma gamma logging Material radioactivity llorehole gamma survey Gamma spectrallogging ASTM Dil Thermistor readings Material temperature Water temperature Standard deviation method Material variability parameter Range determination Detailed logging, sampling, and Material zone boundaries analysis Mineralogy and clay ASTM X ray diffraction mineralogy Petrography Monument and point NOAA Plane surveying positions Control surveys and grids Platinum / hydrogen electrode Oxidation-reduction potential Geological criteria Ilatch leach testing Partition coefficients Column test Geochemical criteria Penetration parameter ASTM Instantaneous profile Permeability function Radioisotopic ratios Pore water age Stable isotope test Conducthity test Groundwater chemistry
'See footnote at end of table.
4 NURIIG-1383
m Table 1 (Continued)
Standaril i
Parameter '
method
- I'ormalir.ed guidance Esl6 ting data Porositics and void ratio Cl!
Acoustic logging Nuclear logging Geological critcria e
f Weather records
. Precipitation Rain gauge obserwitions i.
Rebound Index CII Geotechnical critcria F
I Geologiend criteria Recharge and discharge areas llock classification AS'lhi Durability test Scismic velocity Core logging indices Itunofi Stream gauging Curve numScr estimation AS'thi Tracer studies Scepage velocity Surface survey Seismic velocity llorehole survey Shrinking swelling parameter AS'lhi Geological criteria Soil classification AS'thi Soil taxonomy Textural method Soil organics Sample ignition method Soil pil and acidity ASTM Titration Soll solubles 11PA APIIA Specific gravity AS'thi Cl3 Pump test Storativity Neutron logging Geological criteria Strati raphy E
Strength Cil Geological criteria Structure
. Suction pressure function AS'lhi
'Sec kotnote at end of tabic.
i-5 NUltl!G-1383 l-i i
m..
1 F
Table 1 (Continued)
Standard l'arameter method
- Formalized guidance Existing data n
Tensiometric determination -
Suction pressures -
Psychrometric determination Porous element test Surface water chemistry Surface water system and Geological criteria
- boundaries Transmissivity Pump test V.isual description ASTM Water content ASTM Agronomic Cata Water-holding parameters Suction pressute function Water zone boundaries llorchold logging 1
Water table measurements Water contents i
Weather records j
Wind speeds and direc ions Anemometer and vane measurements
' ASTM = American Society of Testing and Materials: CII = Corps of Engineers; APilA = American Public IIealth Association; EPA = Environ-f mentalProtection Agency;GS = GeologicalSurvey;DR = Burenu of Reclamation;DE = Department of Energy;and NOAA = NationalDecanic and Atmospheric Administration
{
l 4 DOCUMENTATION OF standard tests or commonly accepted tests or for tests LABORATORY OR FIELD TEST dml p d6 sp cificsite,thebasisforthemodification j
"'d ""**
"'d D" d *"**"**d PROCEDURES At the time oflicensing, the documented procedures and Testing procedures for characterizing an LLRW disposal records to verify that work was performed in accordance site generally are classified into two categories. The first with the procedures will be the means to demonstrate category would be described as standardized tests that that the tests were properly performed and the data col-have been developed by a standards-setting organization lected is valid. At a minimum the test procedurer should such as ASTM.The second category of tests are those that contain:
have not been codified by a standards-setting organization but are nationally recognized and considered state of the a description of the objectives art. Such tests are those recommended by Federal Gov-ernment organizations such as the Army Corps of Engi-neers, the Environmental Protection Agency, and the test equipment to be used a
United States Geological Sun ~ The applicant may adapt tests or other guidance to ute-specific conditions or prerequisites for performing the tests, including any to incorp3 rate newer, more accurate or sensitive tech.
specialconditionstobe user nyspecialequipment, niques. Regardless of the type of test conducted or or any special calibration wquired to conduct the whether the test is conducted in the field or laboratory, it tests is an absolute necessity that the procedures for conduct-
]
step-by-step instructions, including reference to any 1
ing the selected test be in writing and clearly define how the test is to be conducted. For tests modified from established standards for conducting the test NUREG-1383 6
f acceptance criteria or instructions to evaluate the date of certification and date of expiration of certifi-e-
e test results to ensure that either the field or labora-cation tory test has been properly conducted Properly conducted tests performed by qualified person-recording date nel will provide the basis for the applicant to defend the
+
validity of the information in a license application if chal-identification of person performing the test lenged during a licensing review or hearing.
as-found conditions
'Ihe training program also should include, as a minimum, the following information:
l corrective actions performed,if any
]
provisions about the technical objectives of the proj.
Where either fielrl or laboratory tests are to be witnessed, cet for personnel performing the tests
-l the procedure should identify ho!d points in the testing sequence to permit witnessing and documentation and the codes and standards that are to be used should include appropriate approval for the work to con-tinue beyond the hold point.
the current status of the procedures developed for unique tests A properly planned and implemented QA program will ensure that tests are planned and conducted as described and the quality assurance elements that are to be abore.
employed 5 QUALIFICATIONS AND Where the need for formal training programs are deter-TRAINING FOR PERSONNEL mined for tests, such training activities should be con-ducted as necessary to qualify personnel who perform CONDUCTING SITE these tests. On the-job participation should be included CIIARACTERIZATION tvith emphasis on first hand experience gained through ACTIVITIES actual performance of these tests.
To ensure that the tests for characterizing an L1RW dis.
6 STORAGE OF SITE posal site are properly conducted, it is necessary for the Cl{ARACTERIZATION DATA applicant to define the qualifications for the persons con-ducting these tests and to implement a training program The purpose of defining thc storage procedures for data i
to assure an adequat,e number of personnel are available
( neluding samples) collected during site characterization to perform the required tests-is to minimize the possibility of damage or lowering the quality of the data as a result of corrosion, contandaation, The minimum capabilities that qualify personnel to per-deterioration, or physical damage from the time the data form a test should be written. The document defining the are collected.This also will ensure that the data are avail.
)
qualifications of personnel performing the tests should able at the time of licensing. The applicant may elect to include, as a minimum, the following information:
develop classification levels for items to be stored on the basis of the environmental conditions under which the employer's name samples must be stored.
identification of person performing test Quality assurance procedures shouid provide for over-view of the data collection and storage process to ensure tests personnel are qualified to perform that planned steps for collection and storage are followed consistently.
bases for qualification, including Before storing field data, a written storage procedure records of education, experience, and training should be prepared and appropriate personnel should be trained in its use.The OA procedures should include as a results of qualification test, when appropriate minimum:
a description of the storage area results of periodic evaluations a system for marking and identifying the data tesults of physical examinations, when required e
l 7
NURI!G-1383
a method for verifying that the data stored is in ord"is a document that will either receive no more entries agreement with the documentation transmitting the or whose revision would normally consist of reissuance of data the document; it is signed and dated by the originator and, as applicable, by personnel authorized to approve the a method for maintaining control of the data document.
e identification of special conditions (e.g., tempera-llound notebooks should be the primary record document ture, humidity, and vapor-proof barriers) required for field survey work, providing a chronology of significant for storage cf the data events for the work. All references to the literature, pro-cedures, or other documents should be complete and a description of the housekeeping practices neces-traceable to each document and the specific section or sary to maintain the facility where data samples are pages identified. The following requirements also apply; stored Pages should be numbered consecutively and kept procedures or measures to prevent rodents and intact. (No page shall be left blank or removed from other small animals from entering indoor storage ar-the notebook.)
cas to minimize possible contamination and damage Each page should be signed and dated by the person to stored material making the entry.
periodic inspection procedures to ensure the storage areas are being maintained in accordance with pro-Records should be stored in a manner to preclude dete-cedures rioration of the records. 'lhe following requirements ap-ply:
7 RECORDS FOR SITE Pr M no shou d be made m. the stomge anange-CHARACTERIZATION ment to prevent damage from moisture, tempera-ACTIVITIES ture, fire, and pressure.
Records should be firmly attached in binders or
'!he purpose of maintaining QA records is to furnish evi-dence that site characterization activitics affecting quality placed in folders or envelopes for storage in steel file have been properly performed. QA records should be cabinets or on shelving in contt.iners.
considered completed documents that furnish evidence Provisions should be made for special processed rec-of the quality of the test or activity, Samples, such as geo-logic, hydrologic, and environmental, that are required to ords (e.g., radiographs, photographs, negatives, mi-be maintained are considered QA records.'Ihe applicant crofilm, and magnetic material) to prevent damage should assure identification, storage, maintenance, from excessive light, stacking, electromagnetic traceability, legibility, and retrievability of QA records, fields, temperature, and humidity.
Rules should be established governing access to and Records that furnish evidence of site characterization ac-tivitics affecting quality include, but are not limited to, control of records.
operating logs: results of reviews, inspections, tests, and Methods should be established forfiling supplemen-audits; monitoring of work performance; and material analyses.The records alw should include closely related tal information and disposing of superseded records.
data such as qualification of personnel, procedures, and equipment.
8 BIBLIOGRAPHY Inspection and test records should, at a minimum, identify U.S. Department of Energy, DOE /L1,W-670, Site Char-the inspector or data recorder, the type of observation, acterization llandbook, Washington, DC, June 1988.
the results, the acceptability, and the corrective action taken, with any deficiencies noted. In addition, these rec-U.S. Government Printing Office, Code of Federallhula-ords should include all related QA activitics. 'Ihese activi-tions, Title 10," Energy," Chapter 1, U.S. Nuclear Regu-ties include review of nonconformance reports, corrective latory Commission, Parts 0 to 199, Washington, DC, re-i action reports, audit and surveillance reports, inspection vised annually.
reports, plans, procedures, and other documents such as telecons, specifications, technical data, books, maps, pho-U.S. Nuclear Regulatory Commission, NUREG-1199, tographs, data sheets, and magnetic media and other ma-Revision 1. Standard Format and Content of a License Ap-terials that provide data and document quality, regardless plicationfor a Low-Level Radioactive Waste Disposal Facil-of the physical form or characteristic. A " completed rec-ity, Washington, DC, January 1988.
I
7:
.23
.. c I:
-, NUREG-0902, Site Suitability, Selection and Char.
-, NUREGICR-2700, Parameters for Characterizing C
acterization, April 1982.
Sites for Disposal of Low-Lewi Radioactin Waste, May 1982.
-,NUREG-1200,Rcrision1,StandardReviewPlanfor the Review of a License Application for a Low-LewiRadio-
-,NUREGICR-3038,TestsforEval:tatingSitesfotDis-actin Waste DisposalFacility, January 1988.
posal of Low-Lewi Radioactin Waste, December 1982.
American National Standards InstitutcIAmerican Society NUREG-1293, Quality Assurance Guidance for
, of Mcchanical Engineers, ANSIIASME NOA-1-1986, Low-Lewi Radioactin Waste Disposal Facility, January Quality Assurance l>ogram Requirementsfor Nuclear Facili.
1989,-
ties, New York.
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- 1. NEPORT NUMBE R EY4 ilor.
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BIBLIOGRAPHIC DATA SHEET
<s,sa,truererue w.,nnen; NUREG-1383
- 7. YlTLE AND SUSTITLE
. Guidance on the Application of Quality Assurance for Characterizing a Low-Level Radioactive Waste Disposal Site
[j "'" "** $',"'
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Draft for Comment November 1989 j
- b. AUTHOH(S)
- 6. TYPE OF REPORT i
Technical i
- 1. VE RIUD COV E n E D tincousase ostn>
C. L. Pittiglio, Jr., R. J. Starmer, D. Hedges ggRM;ggR,c,3NIZ AT lON ~ N AME AN D ADDR E SS (It NRC. prove 0,ven, pitsre or Repean. U.S kucorer R suktory Commesseon. ena means edders
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- s. e Division of Low-level Waste Management and Decommissioning Office of Nuclear Material Safety and Safeguards i
U.S. Nuclear Regulatory Commission Washington, DC 20555 l
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- 9. SPONSORING ORGANIZATlON ~ N AME AND ADDRLSS ttt kRC, type "somr es sorm*:H eentractor. provoar NRC Oownoon. Ottoce or Reeson. V S kuswer nw. tory Comenuon.
and meshnt editress,i e
See item 8. above.
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i
- 10. $UPPLEMENT ARY NOTES l
- 11. ABSTRACT (200 worm ar kus This document provides guidance to an applicant on meeting the Quality Control (QC) requirements of 10 CFR Part 61.12 for a Low-Level Waste (LLW) disposal f acility.
.The QC requirements are the basis for develop ng a Quality Assurance (QA) program i
and for the guidance provided herein. The document specifically established QA-guidance for site characterization activities necessary to meet the performance objectives of 10 CFR Part 61 and to limit exposure to or release of radioactivity.
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