ML20012D623
| ML20012D623 | |
| Person / Time | |
|---|---|
| Issue date: | 03/14/1990 |
| From: | Tokar M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Fliegel M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-68 NUDOCS 9003280144 | |
| Download: ML20012D623 (3) | |
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1 A:\\FLIEG.MEM MAR 141MO MEMORANDUM FOR:
Myron Fliegel, Section Leader Operations Branch Division of Low-Level Waste Management and Decommissioning, NMSS FROM:
Michael Tokar, Section Leader i
Technical Branch Division of Low-Level Waste Management and Decommissioning,.NMSS
SUBJECT:
REVIEW OF RAIP - Rev.
D, GREEN RIVER UMTRA PROJECT
REFERENCES:
1.
Letter dated February 9, 1990, from M.
Matthews of DOE to P.
Lohaus of NRC; transmitting Revision D version of Remedial i
Action Inspection Plan (RAIP) for Green River UMTRA Project.
I 2.
Letter dated October 5, 1989, from P. Lohaus 1
of NRC to M. Matthews of DOE; transmitting review comments on Rev.C version of the RAIP document _for the Green River UMTRA project.
3.
Letter dated February 9, 1990, from M.
Matthews of DOE to P. Lohaus of NRC; transmitting information requested by NRC -
copy of compaction analysis of contaminated materials placed in the Green River site Disposal Cell.
4.
Letter dated February 23, 1990, from M.
Matthews of DOE to P. Lohaus of NRC; transmitting information requested by NRC on Green River project RAP and RAIP documents.
5.
Letter of January 27, 1989, from P. Lohaus of NRC to M. Matthews of DOE; transmitting Rev. 2 version of NRC Staff Technical Position on-Testing and Inspection Plans During Construction of DOE's Remedial Actions at Inactive Uranium Mill Tailings Sites.
9003280144 900314 PDR WASTE FDC WM-68 hf.
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, We have. reviewed the Remedial Action Inspection Plan (RAIP),
Revision D, for the Green' River UMTRA project (Ref. 1) that was submitted in February 1990.
We had reviewed the Revision C 4
version of this RAIP document and had returned comments to DOE I
(Ref. 2) in October 1989.
The revised version, Revision D, is in response to staff comments on the Rev. C version, and the current review was part of a concurrent review of both the final RAP and the RAIP documents for this projuct.
Some of the information presented in the RAP was used in the review of the RAIP document (Refs. 3 and 4).
A-major concern with the RAIP Rev. C version was the frequency of j
density and moisture content tests performed as part of 1
construction inspection to verify compliance with the NRC concurred RAP design and specifications.
The frequency of testing presented in the RAIP, Rev. C document was less frequent than the testing required in the RAIP guidance document prepared by the NRC (Ref. 5) in consultation with the DOE.
The' construction of.the Green River project was initiated after a conditional concurrence by the NRC based on the draft final RAP and certain commitments made by the DOE.
But the conditional concurrence was subsequently withdrawn because preliminary field test data submitted by the DOE indicated that the placement moisttre content of contaminated materials was higher than the values committed-to by the DOE and would result in not meeting the commitment.
Because the construction and inspection testing was completed prior to the NRC review of the RAIP, the NRC,.while returning comments to DOE on the Rev C. version of the RAIP, suggested that DOE provide adequate justification to support their assertion that the testing performed as proposed in the Rev. C version of the RAIP is adequate to conclude with reasonable assurance that the material placed in the disposal cell is in compliance with the NRC-concurred RAP design and specifications.
The justification provided by the DOE includes the following:
1.
Gradation data for tailings and other contaminated materials placed in the disposal cell.
The data indicate i
that these materials are relatively homogeneous, as indicated by their gradation curves falling within an acceptably narrow band.
The DOE contends that the number of verification tests needed for a relatively uniform or homogeneous material should be less than that needed for a nonhomogeneous or nonuniform material.
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The DOE has analyzed the density and moisture content test data statistically and has demonstrated that the probability of the density at any random location within the cell being less than the specified density is 1.65 and 3.75 percent, for tailings and other contaminated materials respectively.
l The density test data indicate that the materials were placed in compliance with the design specifications.
In the case of placement moisture content, the results indicate that the placement moisture is slightly highar than the desired value.
The impact of this slightly higher moisture content, on satisfying the design requirements is addressed-in the Technical Evaluation Report (TER) for this project.
This higher than desired placement moisture content has no bearing on the adequacy of the number or frequency of tests performed to determine the moisture content.
Based on an evaluation of the data from the density and moisture content tests performed as per the proposed RAIP during construction and the supporting justification provided by the DOE, the staff concludes that the provisions of testing in the RAIP were adequate to verify compliance with the RAP design specifications.
The RAIP Rev. D has satisfactorily incorporated other staff comments on previous version of the RAIP for the Green River project.
Therefore, the staff concurs with the RAIP Rev.
D.
This Greon River project construction was initiated without a fully concurred RAP and RAIP.
This resulted in the project being completed using a RAIP that had not been concurred-in by the NRC.
The DOE had to provide subsequent justification to adequately support their assertion that the provisions in the RAIP, although different from NRC guidance, were adequate to accomplish the purpose of the RAIP and to ensure that public health and safety will be adequately protected.
This situation should be avoided in future UMTRA projects.
This review was performed by Banad Jagannath; please contact him should you have any questions.
Ori inal Signed BF Michael Tokar, Section Leader Technical Branch Division of Low-Level Waste Management and Decommissioning, NMSS N Censra5C lie 9 tnm'.68L Distribution:
F LLTB r/f NMSS r/f BJagannath MTokar RBoyle JSurmeier PLohaus JGreeves RBangart SWastler PDR Yes:gj>c-/
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