ML20035B233

Draft Completion Review Rept for Remedial Action at Lowman,Id U Mill Tailings Site

ML20035B233
Person / Time
Issue date:	03/31/1993
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
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ML20035B231	List: ML20035B230 ML20035B233
References
REF-WM-43 NUDOCS 9304010062
Download: ML20035B233 (40)

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{{#Wiki_filter::,- i DRAFT l COMPLETION REVIEW REPORT t i FOR THE REMEDIAL ACTION AT THE LOWMAN, IDAHO - URANIUM MILL. TAILINGS SITE i MARCH 1993 i i N 'I i DIVISION OF LOW-LEVEL WASTE MANAGEMENT AND DECOMISSIONING I U.S. NUCLEAR REGULATORY COMMISSION -9304010062 930308 PDR WASTE WPf-43 PDR

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r TABLE OF CONTENTS Section Pace INTRODUCTION I

1.0 BACKGROUND

I 1.1 UMTRCA I 1.2 CONCURRENCE PROCESS FOR THE SELECTION OF DOE'S REMEDIAL ACTIONS........................... I 1.3 CONCURRENCE PROCESS FOR THE PERFORMANCE OF DOE'S REMEDIAL ACTIONS........................... 2 1.4 LOWMAN SITE......................... 2 1.5 COMPLETION REVIEW REPORT (CRR) ORGANIZATION......... 4 2.0 ANALYSIS OF DOE REMEDIAL ACTION PERFORMANCE............ 4 2.1 PREVIOUS ACTIONS 4 2.2 REVIEW 0F REMEDIAL ACTION PERFORMANCE............ 5 2.2.1 Geotechnical Engineering Review............ 5 2.2.2 Surface Water Hydrology and Erosion Protection Review. 6 2.2.3 Radiation Protection Review.............. 7 2.2.4 Water Resources Protection 8 3.0

SUMMARY

10

4.0 REFERENCES

11 APPENDIX A - NRC SITE VISITS TO THE LOWHAN UMTRA PROJECT SITE A-1 APPENDIX B - VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES B-1 APPENDIX C - UMTRCA, THE EPA STANDARDS, AND THE PHASED UMTRA PROJECT C-1 APPENDIX D - OPEN ISSUES AND

GENERAL COMMENT

S FOR DOE RESOLUTION D-I i LO(dCRR.truh March, M93 1

.- p i t 4 l [ t1ST OF FIGURES l Fioure Pace s 1.1 Location of the Lowman Uranium Mill Site............................. 3 l l t i ? e I t l l I 1 1 i 1 LOW dCRR. nub March, 1993 ii

t l l LOWMAN, IDAHO DRAFT COMPLETION REVIEW REPORT i INTRODUCTION The Lcwman site is one of the 24 abandoned uranium mill tailings sites to be j remediated by the Department of Energy (DOE) under the Uranium Mill Tailings l Radiation Control Act of 1978 (UMTRCA). UMTRCA requires, pursuant to Section ^ 104(f)(1), that the Nuclear Regulatory Commission (NRC) concur with the DOE's - determination that the remedial action has been properly completed. This-Completion Review Report (CRR) documents the NRC staff's basis for its ( concurrence decision with respect to DOE's Certification Report for the completion of the Lowman site (D0E,1992a). 1.0 BACKGROUlm 1.1 UMTRCA Title I of UMTRCA provides for remedial action at abandoned. uranium mill 'l tailings sites and associated vicinity properties. The purpose of this legislation is to protect the public health and safety and the environment from radiological and non-radiological hazards ~ associated with the radioactive materials at these sites. UMTRCA directs DOE to select and' perform remedial actions at 24 i abandoned uranium mill tailings sites to ensure compliance with the ~ general environmental standards promulgated by the Environmental c Protection Agency (EPA) under Section 275(a) of the Atomic Energy Act of 1954, as amended by UMTRCA. UMTRCA also requires DOE to obtain NRC's concurrence with DOE's selection and performance of the remedial -l actions. Following completion of the. remedial actions, UMTRCA' l authorizes NRC to license the long-term custody, maintenance, and .j ] monitoring of the disposal sites to ensure continued protection of the i public health and safety and the environment. Appendix' C includes: a more detailed discussion of this legislation. 'l 1.2 CONCURRENCE PROCESS FOR THE SELECTION OF DOE'S REMEDIAL ACTIONS i To document its selection of the remedial. action to be implemented at a particular site, DOE develops and issues a Remedial Action Plan (RAP). The RAP describes the series of. activities and presents the design proposed by DOE to stabilize the residual radioactive materials at the-i disposal site and to provide for the long-term protection of the public and the environment. In addition,.00E issues a Remedial Action l Inspection Plan--(RAIP), which establishes the quality control program of testing and inspection that will be employed for the remedial-action. In accordance with UMTRCA Section 108(a)(1), the NRC staff reviews and-concurs with the RAP-and RAIP, and any subsequent modifications. By its review and concurrence in the remedial action selection, the NRC staff concludes that the planned remedial actions will comply with EPA's-applicable standards in 40 CFR 192, Subparts A, B, and C. LOW dCRR.mwh Marih,1993 1

s i 1.3 CONCURRENCE PROCESS FOR THE PERFORMANCE OF DOE'S REMEDIAL ACTIONS The remedial action work is performed by DOE contractors under Federal procurement regulations. During construction, DOE inspects and documents activities in accordance with the UMTRA Project Quality Assurance Plan, the RAIP, and the RAP. In addition, the NRC staff conducts independent reviews during construction. Upon the completion of the remedial action, DOE compiles construction records and prepares a Completion Report (CR) to document that remedial actions were performed in accordance with the RAP or RAP modifications, and the RAIP. Based on this information, DOE certifies that all provisions of the RAP have been satisfied and, therefore, that the remedial actions comply with the applicable EPA standards in 40 CFR 192. Based on its review of DOE's documentation, and on its site visits and observations, NRC makes a concurrence decision with regard to DOE's remedial action completion determination for the sites, and then i documents the basis for this concurrence decision in the CRR. By its review and concurrence in the remedial action performance,-the NRC staff concludes that the remedial action has been completed in accordance with the concurred-in design. NRC's concurrence with DOE's completion determination fulfills the Commission's responsibility under UMTRCA Section 104(f)(1) to concur with DOE's determination of completion of remedial action. 1.4 LOWMAN SITE The Lowman uranium mill tailings site is located in Boise County, Idaho, approximately one-half mile northeast of the city of Lowman (Figure 1.1). Prior to remedial action, the uranium mill tailings on the designated site and the windblown con})aminated materials totalled approximately 127,481 cubic yards (yd The remedial action performed by DOE consisted of the following major activities: 1. Consolidation of all contaminated materials-(uranium mill tailings, windblown / waterborne contaminants, settling pond contaminants, vicinity property material, and demolition debris from the mill building and ore storage areas) on top of the existing tailings piles of black sand located in the southern portion of the site. 2. Stabilization of contaminated material in an approximately 9 acre tailings disposal cell with side slopes of 20 percent and top slope of 10 percent. LOW dCRR smA March, 1993 2 i t

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s 3. Coverage of the' embankment with one-and-a-half feet of compacted f earth as a radon / infiltration barrier overlain by a six-inch-thick i sand bedding layer and a one-foot-thick rock erosion protection } layer in order to ensure long-term stability, reduce radon emissions, and protect ground and surface water. The NRC was not involved with the actual remedial action activities, which were performed by the DOE contractors. However, DOE obtained NRC concurrence with the site construction design and a few significant modifications thereof as Project Interface Documents (PIDs). NRC also i performed on-site construction reviews to monitor the progress of the l construction activity (see Appendix A). I q 1.5 COMPLETION REVIEW REPORT ORGANIZATIOM l The purpose of this CRR is to document the NRC staff review of DOE's Lowman Completion Report (DOE, 1992a). Section 2 of this report presents the analysis of remedial action performance. This-section is organized by technical discipline and addresses _geotechnical i engineering, surface water hydrology,. groundwater hydrology, and radiation protection aspects of the remedial action. Appendix A i provides a listing of all NRC staff visits to,'and on-site construction reviews of, the Lowman site.. Appendix B provides a table that cross-checks the requirements of the RAP /RAIP, as concurred:in by the NRC staff, with DOE's Completion Report documentation. Appendix C presents a detailed description of the requirements of UMTRCA and the resulting l phased process of the UMTRA Project. Appendix D presents the open issues, as well as the general comments not directly related to the-RAP /RAIP requirements, which'have resulted from NRC's review and for which DOE needs to provide a response. ) 2.0 ANALYSIS OF DOE REMEDIAL ACTION PERFORMANCE 2.1 PREVIOUS ACTIONS 3 The NRC staff, based on its review of the RAP (DOE,1991b; 1991c; 1991d;. 1991e; 1991f) and the RAIP (DOE,1991a), concurred that the remedial j action, as designed, would meet the applicable EPA standards. This concurrence was based on technical findings that there is reasonable assurance that the selection of the remedial action would meet the. standards for long-term stability, radon attenuation,- water resources. I protection,- and cleanup of contaminated land and buildings. Staff reviews included assessments in the areas of geology, geotechnical.. i engineering,. surface water hydrology, ground-water hydrology, and health j physics. The NRC concurred on the final RAP, Revision 3, and the RAIP, 1: Revision _B (NRC, 1991b) on July 31, 1991. The basis for the NRC staff's concurrence in DOE's selection of remedial action at the Lowman site is documented in a Technical Evaluation Report (TER) issued in July, 1991 (NRC,1991b). LOW cCRR.andh Marih,1993 4 /

2.2 REVIEW OF REMEDIAL ACTION PERFORMANCE t The NRC staff's primary objective in reviewing DOE's certification of remedial action completion is to determine whether the remedial actions have been performed in a manner consistent with specifications provided 4 in the RAP and the RAIP, and if not, that deviations to these specifications do not significantly affect compliance with the EPA standard. In support of this action, the NRC staff participated in site reviews (See Appendix A), field observations, assessments of on-site data and records, and review of DOE Site Audit Reports. There were no RAP Modifications associated with the Lowman review process. However, j during remedial action, 5 Class I PIDs, i.e. those related to meeting the EPA standards, were reviewed and concurred in by the NRC staff. These PIDs are listed in Section I of Volume I of the CR and are reflected in the as-built conditions presented in the CR. The following sections present the results of the review of remedial l action performance by individual technical discipline. Note that for the Lowman remedial action completion review, the pertinent technical disciplines are:

1) geotechnical angineering, 2) surface water i

hydrology and erosion protection, radiation protection, and 4) groundwater hydrology. 5 2.2.1 Geotechnical Engineering Review ~ NRC staff reviewed the Lowman draft CR (DOE, 1992a) to determine + whether the geotechnical engineering aspects of the remedial action were completed in accordance.with: (1) the applicable construction specifications in the RAP and design (DOE 1991e, 1991f), and (2) the RAIP (DOE 1991a). Items reviewed include descriptions of construction operations, as-built drawings, laboratory and field testing data, and DOE Quality Assurance Audits. In addition, the review was based on staff observations and review of records during on-site construction reviews. l During its review, the NRC staff noted the following: 1. Appropriate tests (gradation) and inspections were performed to assure that the proper type of material was placed for each feature of the construction. The loose thickness of the lifts was verified periodically to ensure compliance with the specifications for that material. Placement and compaction operations were routinely inspected and tested to verify that the moisture and density requirements were met and that the soil moisture was uniform throughout the compacted lifts. 2. Documented results of laboratory and field testing indicate that they were conducted in accordance with acceptable procedures by trained and qualified personnel. I LOW cCRR.smA Mar k 1993 5 I

3. Verification that contaminated fill material and placement

riteria were tested at the minimum required frequency are not provided (See Appendix D, also).

4. As-built drawings indicate that the completed remedial action is consistent with the NRC-approved design. Details of the staff's geotechnical engineering review, which provide the basis for the above statements, are included in the attached Appendix B. In addition to item 3, above, the detailed review has identified open issues related to verification that maximum organic content levels were not exceeded. The open issues are summarized and listed in Appendix D. Therefore, the NRC staff i concludes that additional information needs to be provided to enable the staff to complete its assessment of the completion status of the Lowman UMTRA project in the area of geotechnical engineering. 2.2.2 Surface Water Hydrology and Erosion Protection Review NRC staff reviewed the surface water hydrology and erosion protection aspects of remedial actions at Lowman to ensure that they were constructed in accordance with the applicable construction specifications as stipulated in the RAP / design, and RAIP. Areas of review included as-built drawings, constructic.) operations, laboratory and field testing, and quality assurance audits. In addition, the review was based on NRC observations of the remedial actions, and reviews of records and testing during NRC on-site construction reviews (See Appendix A). The remedial action design featured riprap erosion protection in several specific areas, including the top and side slopes of the encapsulation cell and in the apron surrounding the cell. The erosion protection was designed to prevent long-term erosion and gullying of the cell cover. The NRC staff reviewed each of these features and determined that their testing, placement, and configuration complied with specifications in the RAP, and the RAIP. The review was partially based on NRC staff observations and review of on-site records during the remedial actions, as well as assessment of the results presented in the DOE Completion Report. During its review, the NRC staff noted the following: 1. Tests (gradation and durability) and inspections were performed by DOE to assure-that erosion protection materials for the cell were properly selected. The review of the documentation indicated that placement of materials was routinely inspected by DOE to assure that the rock size and gradation specifications were met. Likewise, the thickness LOW dCRR.anA Madh,1993 6 l

of each rock layer was verified periodically by DOE or its agents to ensure compliance with the specifications for the particular type of material. 2. Laboratory and field testing was documented by DOE in accordance with specified test procedures. 3. Testing and inspection frequencies for materials used at the site for erosion protection were documented by DOE as complying with the frequencies specified in the RAIP. Based on NRC staff observations and review of on-site records 4 during the remedial actions, as well as assessment of the verification results presented in the DOE Completion Report, the NRC staff concludes that the required durability and gradation tests were performed during the remedial action. The riprap is of adequate quality and has been acceptably piaced. The NRC staff concurs that remedial action has been adequately completed at Lowman with respect to erosion protection. 2.2.3 Radiation Protection Review The NRC staff reviewed radiation protection aspects of remedial actions at the Lowman site to ensure that cleanup of residual radioactive materials was performed in accordance with specifications in the RAP, RAIP, and the final design. Areas of review included contaminated material excavation, verification of cleanup, laboratory and field testing, and quality assurance audits. Specific details of this review can be found in Appendix B. The review was mainly based on NRC staff assessment of the verification results presented in the DOE Completion Report. In addition, NRC geotechnical engineering staff reviewed the design and construction of the disposal cell cover to ensure compliance with the RAP design for limiting radon releases to meet the EPA standards (See Section 2.2.1). During review of the radiation protection aspects of the remedial action completion documentation, the NRC staff noted the following: 1. The techniques, which DOE states to have used for verifying radiological cleanup at the processing site, complied with DOE's summary protocols. 2. The radiological records support compliance with EPA's cleanup standards in Subpart B of 40 CFR Part 192. 3. The CR (Volume 5B, Appendix B) presents new data to support changes in the input parameters for the PAECOM analysis of cover radon flux. DOE concludes that most of the embankment requires no radon barrier layer. Of 20 locations tested for LOW dCRR.twh March, 1993 7 i I

I as-built Ra-226 levels and modeled for radon flux, the thickest barrier required to meet the flux criteria is four cm. The low radon flux is primarily related to the unique sands at this site that have a low radon emanation fraction. NRC staff used more conservative input values and calculated that at least 10 cm (four inches) of barrier is required. Since 45.5 cm (18 inches) of barrier material was placed, even allowing for frost penetration up to 25 cm (10 inches) into the barrier layer, the radon attenuation barrier of the cover is more than adequate. 4. Areas of windblown contamination and creek bank (9.6 acres) were not remediated. Supplemental standards were applied with NRC approval because of ecological and engineering 3 considerations (RAP, PID 12-S-09). 5. The Remedial Action Selection (RAS) Report (pages 2, 6) states that the cell will cover 9 acres and approximately 18 acres will be restricted area. There is no map in Appendix D, As-Built Drawings, that indicates which 18 acres have restricted assess or how the restricted area will be maintained. No fence is indicated. DOE should indicate the location and current / future status of this 18-acre area (See Appendix D). 6. As stated in a November 5, 1991, letter to DOE, NRC's concurrence on PID 12-S-07 was on the condition that the Completion Report contain data supporting the estimate that the average radium content of the additional material placed in the ditch at the north end of the disposal cell was below 25 pCi/g. A copy of an Inter-Office Communication was attached to PID 12-S-07, Revision 1, that was transmitted to NRC on September 25,3 1991. That document stated that the additional 24,500 yd of contaminated material contained less than 20 pCi/g in the top 10 feet. DOE should present the data in the CR (See Appendix D). 6. The issues identified above, and requests for clarification of portions of the CR are noted for DOE response in Appendix D of this report. Based on the above statements, the NRC staff concludes that additional information needs to be provided to enable the staff to complete its assessment of the completion status of the Lowman UMTRA project in the area of radiation protection. 2.2.4 Water Resources Protection The NRC staff reviewed the construction elements and the ground-water and unsaturated moisture monitoring performed during the remedial actions that relate to ground-water resource protection. ~ LOW dCRR.snwh March, 1993 8

This review is based on NRC staff assessment of verified results presented in the DOE Completion Report. During its review, the NRC staff noted the following: 1. Document No. 3885-LOW-S-01-00268-02 contained in the CR (D0E, 1992a) provides subcontractor well abandonment specifications and a list of wells scheduled for abandonment. NRC was notified of the proposed abandonment of Wells 571 and 581 in PID No. 12-S-13. As-Built drawings do not show the locations of abandoned wells listed in the specification; or a listing and location of abandoned piezometers situated beneath the designated disposal cell. 2. Details of As-Built drawings show that the constructed cover consists of an 18-inch-thick radon barrier, covered by a 6-inch-thick sand layer, and 12-inches of small rock on the surface. This is in agreement with RAP requirements for Water Resource Protection. 3. Volume 5, Appendix B of the draft Completion Report provides the initial engineering calculations that were used to develop the water corfsumption estimate; however, the amount of water actually used in construction and dust control are not included for 'As-Built' verification. 4. The draft Completion Report does not contain any information on the collection of, or the results of, ground-water sampling during and immediately following remedial activities. These data, and an interpretative analysis of the results, should be included in the Completion Report to document the impact (or lack of impact) of remedial l activities on the ground-water quality. Details of the staff's ground-water performance review, which provide the basis for the above observations, are included in the attached Appendix B. In general, the NRC staff concludes that the ground-water protection aspects of the remedial action were completed in accordance with the design and procedures identified in the RAP, and the RAIP. However, three open issues remain to be resolved prior to concurrence in this area (See Appendix D, also): 1. DOE should update the As-Built drawings to include the locations of abandoned wells and piezometers. DOE should also provide the abandonment procedures for the piezometers, if those procedures varied from the well abandonment specification in the RAP. Additionally, several monitoring wells described in the RAP LOW KRR.mdh March, 1993 9 i

1 i 4 j are not shown on the As-Built Drawing LOW-PS-10-1209, and not listed as being abandoned. Well 641 and the on-site perennial spring (561) are designated monitoring points described in the RAP. DOE should revise Drawing LOW-PS l 1209 to show the location of all wells remaining after completion of remedial activities. 2. DOE should provide tabulations of the measured quantities of l water actually used for dust control and tailings material compaction. 3. DOE should provide the ground-water monitoring data collected during and immediately after the remedial activities. Additionally, an interpretive analysis of the monitoring results should be provided to document the impact that remedial activities may have had on the ground-water quality. 6 3.0

SUMMARY

The NRC staff reviewed geotechnical engineering, surface water hydrology, radiation protection, and groundwater aspects of the remedial action performed at the uranium mill tailings site in Lowman. The purpose of this review was to determine whether DOE had performed ~ remedial actions at the site in accordance with specifications in the RAP, and other supporting project documents, and thus with the EPA standards in 40 CFR Part 192, Subparts A-C. Based on our review of the Completion Report and on observations during periodic on-site construction reviews, the NRC staff has identified open issues, as well as, additional general comments in Appendix D. Therefore, the NRC cannot concur that DOE has performed remedial action at the Lowman site in accordance with the above specifications, or that the Lowman remedial action complies with the EPA standards in 40 CFR Part 192, Subparts A-C. DOE needs to adequately resolve the open issues identified in Appendix D. L h LOW dCRR.ndh March, 1993 10 l

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4.0 REFERENCES

i U. S. Department of Energy, 1992a, " Draft Completion Report, Lowman, t Idaho," Volumes 1-6,. transmitted on January 8,1993. ....,1991a, "UMTRA Project - Lowman, Idaho, Remedial Action Inspection' Plan, Revision B," transmitted on June 24, 1991.. .i ....,1991b, " Final Remedial Action Plan and Site Design for Stabilization of the Inactive Uranium Mill Tailings at Lowman, Idaho," Remedial Action Selection Report. and Attachments 1 - 4. - i ....,1991c, " Final Reniedial Action Plan and Site Design for l Stabilization of the Inactive Uranium Mill Tailings at Lowman, i Idaho," Remedial Action Selection Report and Attachments 1 - 4, Revision 1. ]* ....,1991d, " Final Remedial Action Plan and Site Design for l Stabilization of the Inactive Uranium Mill Tailings at Lowman, i Idaho,". Remedial Action Selection Report and Attachments 1 - 4, Revision 2 (Modificat4n No. 1)- . j ....,1991e, " Final Remedial t.: tion Plan and Site Design for l Stabilizatio af the Inact,1ve Uranium Mill Tailings' at Lowman,- Idaho," Remial Action Selection Report and Attachments 1 - 4, Revision 3. l ...., 1991f, " Uranium Mill Tailings Remedial Action Project (UMTRAP), j Lowman, Idaho - Design Calculations," Volumes 1, II, and III. U.S. Nucleer Regulatory Commission,1992a, Surmeier, J.J. -letter, dated February 26, 1992, to Chernoff A. R., U.S. Department of Energy, j providing concurrence on RAIP Revision IB. ...., 1991a, Surmeier, J.J. letter, dated June 18, 1991, to Matthew, M., l U.S. Department of Enngy, providing concurrence on the final RAP, l Revision 2 (Modification No. 1). j ....,1991b, Surmeier, J.J. letter, dated July 31, 1991, to Matthew, M., U.S. Department 'of Energy, transmitting the final TER and. providing full concurrence on the final RAP, Revision 3, and the t RAIP, Revision B. l l LOW dCRR.nwh I meren. m s 11 i '3 v

e i P h APPENDIX A NRC SITE VISITS TO THE LOWMAN UMTRA PROJECT SITE t f I s i E I P 1 f LOW dCA2.mwh MarEh,1993 A-1 APPENDIX A t

l...- NRC SITE VISITS TO THE l _ LOWMAN UMTRA PROJECT SITE i DATE STAFF / DISCIPLINE PURPOSE j l 07/27/87 Lynn Deering Initial visit to observe general conditions of site John Starmer and surrounding area. j Kristin Westbrook, and Ted Johnson j 06/12/90 Dan Gillen To observe the processing / ) i, disposal site, and to l-Ted Johnson discuss NRC informal preliminary comments on S. Wastler, and Lowman draft RAP. l A. Fan i 06/18/91 Dan Gillen/Geotechnical On-site Construction Review. I -I Dan Rom /Geotechnical 09/18/91 T. L. Johnson / Surface Water On-site Construction Review. j Hydrology & Erosion Protection i D. Rom /Geotechnical-09/18/91 D.L. Jacoby (URFO) Site visit to observe I Subpart T NESHAP testing, E. F. Hawkins (URFO) and areas approved for. 1 application of supplemental standards. 10/29/91 T. L. Johnson / Surface Water On-site Construction Review.- Hydrology & Erosion Protection D. Gillen/Geotechnical (Close Out) S. Abt, CSU LOW E RR.anA March, 1993 A-2 APPENDIX A r

4 7 I I APPENDIX B i VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES (DETAILED COMPARISON OF DESIGN SPECIFICATIONS WITH COMPLETED REMEDIAL ACTIONS PERFORMED) LOWMAN UMTRA PROJECT SITE i i LOW dCRR.nwh 8 Larch, 1993 B-1 APPENDIX B

VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lowman, Idaho Reviewer: Daniel Rom RAP Feature: Tailings / Contaminated Geotechnical Engineering Issues Material RAP Requirements Verification l

1. Configuration:

1. Configuration: i A. Areal Extent; Drawing No. LOW-A. Verified in As-built Drawing No. PS-10-1209 LOW-PS-10-1209 B. Slopes; 4(H):1(V) maximum side B. Verified in As-built Drawing No. slopes; 10% slope above LOW-PS-10-1210 transition 2. Placement: 2. Placement: A. Lift Thickness - 10" loose A. " Loose lift thickness (Specification page 02200-17) measurements were performed which verified that the loose lift thickness of the contaminated fill material did not exceed 10 inches." [Vol. 3, Appendix E, Contaminated Fill Material (CFM) page 2]

8. Compaction - 95% (uppermost 2'),

B. " Average percent compacti<m 90% (remainder) of maximum obtained was 98.9%." (Vol. 3, density by ASTM D-698, moisture Appendix E, CFM page 4). 253 content 0 to 5 percentage points in-place field density tests, below optimum (Specification for an average of one test per page 02200-20). Non-testable 332 cubic yards placed, were material density confirmed by conducted. Non-testable fill performance specification (per compaction was verified by PID no. 12-S-03). routine daily Quality Control inspections. C. Organics in lower lifts; <5% by volume in any area (Specification page 02200-16) C. Not verified by DOE - Open Issue i $[I B-2 APPENDIX B i i

f I VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lowman, Idaho Reviewer: Daniel Rom RAP Feature: Tailings / Contaminated Geotechnical Engineering Issues { Material. 3 RAP Requirements Veri fication -

3. Test Frequency:

3. Test Frequency: 3 Moisture / density 1 per 1000 yd 253 tests (Specification page 02200-19) 84,110 yd* - 1 test /332 yd l 3 (Vol. 3, Appendix E, CFM, page 4). Whereas total frequency is { satisfactory, frequency distribution was not stated, and is an open issue. i i i l i J I t l t 4 1 i e i 1 l ? LOW dCRR.pth i march, 1993 B-3 APPE@IX B l f

k i ) i VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES l Site: Lowman, Idaho Reviewer: Daniel Rom RAP Feature: Radon Barrier Geotechnical Engineering' Issues RAP Requirements Verification 1. Configuration: 1. Configuration: i A. Areal Extent A. Verified in As-built Drawing No. Drawing No. LOW-PS-10-1209 LOW-PS-10-1209 B. Thickness B. Verified in As-built Drawing No. Drawing No. LOW-PS-10-1210 LOW-PS-10-1210 f f 2. Material: 2. Material: i A. Maximum 5% <#200 sieve, A. "There were 23 passing gradation Maximum 15% >#4 sieve as per ASTM tests on radon barrier material, D-422, (Specification page all of which met the specified-02200-8) requirements." [Vol. 3, Appendix E, Radon Barrier Material (RBM) page 1] B. Maximum 5% by volume B. Not verified by DOE.Open j l organic / deleterious substance Issue content (Specification page i 02200-8) t 3. Placement: 3. Placement: l A. Lift thickness 12" loose A. " Continuous monitoring was (Specification page 02200-15) performed 'during material placement l to ensure that the loose lift-thickness did not exceed 12-inches..." (Vol. 3, Appendix E, RBM page 2) B. Moisture / Density: 95% of B. "The average' percent compaction maximum by ASTM D-698, O to 3 obtained was 98.4%, which was percentage points above opt determined from a total of 73 (Specification page 02200-18) passing in-place field density tests." (Vol. 3, Appendix E, RBM page 3) i'i LOW dCRR.sedh k merin, m3 B-4 A m uoix s q i

4 - h VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES t Site: Lowman, Idaho Reviewer: Daniel Rom RAP Feature: Radon Barrier Geotechnical Engineering Issues RAP Requirements Verification 4. Test Frequency: 4. Test frequency: 3 3 A. Moisture / Density 1 per 500 yd A.73 tests /1[,929yd = r (Specification page 02200-19) I test /246 yd (Vol 3, Appendix E, RBM page 3) 3 B. Gradation 1 per 1000 yd, with 3 minimum 1/ day of fill placement B.23 tests /1[,929yd = (Specification page 02200-19) I test /780 yd (Vol 3, Appendix E, RBM page 1). Frequency distribution of testing not given - l Open Issue i l LOW dCRR.nwh March, 1993 B-5 APPEc!X B j

l VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lowman, Idaho Reviewer: Daniel Rom RAP Feature: Bedding Layer Geotechnical Engineering Issues RAP Requirements Verification 1. Configuration: 1. Configuration: i A. Areal Extent A. Areal extent verified in As-Drawing No. LOW-PS-10-1209 built Drawing No. LOW-PS-10-1209 B: Thickness - 6"

8. Thickness verified in As-built Drawing No. LOW-PS-10-1210 DrawingNo.LQW-PS-10-1210 2.

Material: 2. Material: A. Gradation (Specification page A. " Average value of 4 tests was 02278-7) within specified limits." It is not stated whether any individual test results were out of specified limits - Open Issue. 3. Placement: 3. Placement: A. 6" lift compacted by 3 passes A. "Of the 86 depth checks of D-6 bulldozer (Specification performed, 83 passed and 3 failed. page 02278-8) The 3 failing areas were reworked and retested until each met the thickness requirement." Depth checks verified project compliance. 4. Test Frequency: 4. Test Frequency: 3 A. 4 gradation test per first A.4tegts/6694yd = 1 test per 30,000 yd, additional test each 1674 yd 3 10,000 yd (Specification page 02278-8) 5. Material Tests: 5-Material Tests: A. Abrasion (ASTM Cl31) <40%/500 A. Average 3.90% loss /500 cycles cycles (Range 2.80-5.80%) B. Soundness (ASTM C88) <10%/5 B. Average 0.47% loss /5 cycles cycles (Range 0.40-0.56%) C. Specific Gravity >2.60 C. Average 2.74 (Range 2.65-2.78) LOW dCRR.nwh March, 1993 8-6 APPE@!R S

-i i ( i VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES i Site: Lowman, Idaho Reviewer: T. L. Johnson RAP Feature: Rock Cover Surface Water Hydrology & Erosion i Protection Issues l RAP Requirement Verification i 1

1. Configuration:

1. Configuration:

i A. Areal Extent A. Verified in As-built drawings l (Appendix D) and by visual observation during site visit. i B. Thickness: 12 inches B. Acceptable based on review of DOE's depth. testing in 69 locations on a 50' x 100' grid. Reworking l was performed at two locations-i where the thickness was not j acceptable. l

2. Material:

2. Material:

A. Gradation - Section 02278 of -A. Gradation summary curves j Specifications provided in Appendix E indicate j that all the select rock met the i gradation requirement, after the requirement was modified (and approved by the NRC staff) during construction to permit the use of l slightly smaller rock in the lower t end of the gradation. B. Durability - Rock score must B. Average Score: 96.7 l equal 80, in accordance with NRC Range: 95 - 98 procedures included in the i specifications -ij i l-! i 5 i LOW dCRR.awh i March, 1993 8-7 APPENDIX B l ~ t ~ c 4

4 - I VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES i i Site: Lowman, Idaho Reviewer: T. L.~ Johnson ' i, RAP Feature: Rock Cover Surface Water Hydrology & Erosion { Protection Issues _l RAP Requirement Verification

3. Placement

3. Placement A. Uniform distribution, A. Daily inspections of the Type A minimization of voids Riprap were conducted by the Contractor during excavation,

[ production, stockpiling, transporting, and placement to assure the following: That proper techniques were j employed to prevent degradation of the material due to-improper i handling; that distribution was uniform; that voids were kept as j minimal as possible; and that i' proper gradation was' maintained." (Appendix E Riprap Type A, page 4) 6 j

4. Test Frequency

4. Test Frequency A. Gradation tests at 1/3-points A. 4 tests were conducted. They I

of production were at the required frequency. i B. Durability tests - same B. 4 tests were conducted. They

l frequency'as Gradation tests were at the' required frequency.

i a l I i i i LmJ dCRR.mA Mar k 1993 B-8 APPENDIX 8 .i e ii i

VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES i Site: Lowman, Idaho Reviewer: T. L. Johnson l RAP Feature: Apron Surface Water Hydrology & Erosion Protection Issues RAP Requirement Verification l 'i

1. Configuration:

1. Configuration:

A. Location A, B, & C. Verified in As-built I drawings (Appendix D) and by visual B. Cross Sections and Areal Extent observations during site visit. (Thickness Varies) Depth checks were not required C. Site grading for Type B or Scalped Type B { rock. Engineering surveys were conducted to verify that the i thicknesses shown in design i drawings had been achieved. l t I l i i I [ .l l 2 .I L W g:RR,m h March, 1ma B-9 APMWIK B l l

i p VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lowman, Idaho Reviewer: T. L. Johnson RAP Feature: Apron Surface Water Hydrology & Erosion Protection Issues RAP Requirement Verification

2. Material:

2. Material:

l A. Gradation - Section 02278 of A. Gradation summary curves Specifications provided in Appendix E indicate i that all the Type B and Scalped l Type B rock met gradation requirements. B. Durability - Rock score must B. Type B rock was produced from equal 80, in accordance with NRC three sources: i procedures included in the specifications Buckskin Canyon: Range 92 - 95 Average Score 94.2 i Cascade: Range 78 - 84 -i Average Score 81.0 j Spar Canyon: Range 95 - 98 Average Score 96.7 Scalped Type B was produced only from the Spar Canyon-source. The rock which scored less than 80 I from the Cascade source did not-constitute a significant percentage i of the total quantity of rock placed. When averaged with the rock of higher quality, the resulting average score exceeded the minimum requirement of 80. j l LOW CRR.pnA i March, 1993 B-10 APPEND 1X B

i VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lowman, Idaho Reviewer: T. L. Johnson RAP Feature: Apron Surface Water Hydrology & Erosion Protection Issues RAP Requirement Verification-

3. Placement:

3. Placement:

I i A. Uniform distribution, A. Daily inspections of the Type B minimization of voids riprap were conducted by the' i Contractor during excavation, production, stockpiling, transporting, and placement to assure the following i That proper techniques were l employed to prevent degradation of the material due to improper handling; l i That distribution was uniform; That voids were kept as minimal as possible; .j And that proper gradation'was maintained. (Appendix E - Riprap Type B, page 7) l

4. Test Frequency:

4. Test Frequency:

A. Gradation tests at 1/3-points A. 4 tests were conducted for each of production of the rock sources (total of 12). They were performed at the required frequency. B. Durability tests - same B. 4 tests were conducted for'each frequency as Gradation tests rock source (total of 12), resulting in average test frequency of one durability test for each 565 i 3 yd of Type B riprap placed. These tests were performed at the i required frequency. j Oh) I B-1} APPENDIX B 4 f 1

VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lowman, Idaho Reviewer: Elaine Brummett RAP Feature: Radon Attenuation Radiation Protection Issues RAP Requirement Verification in CR RAS Report Section 6.4 Estimated radon flux at the cover Appendix B of Volume 5B presents a to meet EPA standard: calculation with parameter data and average radon release (over year RAECOM code analysis. Maximum or greater) of disp /s. osal site not barrier soil layer thickness to exceed 20 pCi/m required is four cm (1.6 inches). NRC staff analysis indicates that a 10 cm (3.9 inch) radon barrier layer in the cover shoy/s. ld restrict radon flux to 20 pCi/m The 45.5 cm (18 inch) barrier layer is more than adequate for radon attenuation. Appendix J, Table J.7, indicates 100 radon flux measurements done to comply with 40 CFR 61, Subpart T of the National Emission Standards for Hazardous Air Pollutants regulations. All measurements less 2 than 0.5 pCi/m /s. PID 12-S-07 proposed change to the Supporting data was not found. designofthecell}oaccomodate This is an open issue - see additional 13000 yd of Appendix D. contaminated material. NRC concurrence was conditional on providing data supporting the average radium content to be below 25 pCi/g. n)h0!$$Ef B-12 Arecuant a \\

o ^f VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES i Site: Lowman, Idaho Reviewer: Elaine Brummett-i RAP Feature: Site Cleanup Radiation Protection Issues t i RAP Requirements Verification in CR i

1. Soil Verification Procedures

1. Soil Verification Procedures RAS Report Section 6.5.4 Appendix J Determine average Ra-226 on 100 The site was divided into 10 x 10

-t square meter areas. Use quality meter grids and RAC-015 sampling assurance and control procedures. and analysis procedures were i followed. i

2. Soil Cleanup

2. Soil Cleanup RAS Report Section 6.5.3 Appendix J l

A. Ra-226 and Th-232: A. Ra-226 analysis of 766 samples Average within each grid to meet yielded an average of 1.9 pCi/g. EPA standard not to exceed The maximum value was 8.6 and no background by: sample exceeded the standards.

a. 5 pCi/g in top 15 cm Th-232 analysis of 764 samples

b. 15 pCi/g in subsequent 15 cm

. yielded an average of 1.3 pCi/g and i layers the maximum value was 4.2. j% B. Th-230: B. Th-230 analysis of 42 samples l Supplemental standard imposed to demonstrated the highest.value was l achieve the projected (1000 yr) 6.4 pCi/g. No sample exceeded the i Ra-226 or WL standard. projected Ra-226 standard. .j C. Total uranium: C. No measurement data is presented Supplemental standard of 10 pCi/g for total uranium. See Appendix D.- in the top 15 cm, then 30pti/g in 1 subsequent 15 cm layers.

3. Decontamination / Demolition

3. Decontamination / Demolition i

RAS Report Section 3.4.1 Appendix H Contaminated demolition debris to Contaminated building foundations, { be placed in the disposal cell. rubble, and debris were buried in the lower lifts of the cell. i l i s f LGJ CRR.fmm I Madh,1993 B-13 Ameir s

9 ~ VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lowman, Idaho RAP Feature: Water Resources Protec-tion Issues Reviewer: M. Layton RAP Requirements Verification

1. Ground-water characterization

1. Document No. 3885-LOW-S-01-00268-wells and piezometers situated 02 provides subcontractor well l

beneath the designated disposal abandonment specifications and a cell will be properly abandoned. list of wells scheduled for Wells located outside the abandonment. NRC was notified of disposal cell, which are not the proposed abandonment of Wells designated for future monitoring, 571 and 581 in PID No. 12-S-13. will also be abandoned. This was listed as an item in the As-Built drawings do not show the construction specifications. locations of abandoned wells listed in the specification; or a listing and location of abandoned piezometers situated beneath the designated disposal cell. Additionally, several monitoring wells described in the RAP are not shown on the As-Built Drawing LOW-PS-10-1209, and not listed as being abandoned. Well 641 and the on-site perennial spring (561) are designated monitoring points described in the RAP. See Appendix D. ~

2. The cover design of the disposal

2. Limiting infiltration is not cell will limit the infiltration considered a critical design to a rate approximately equal to, element for ground-water resource or less than, the unremediated protection, since no ground-water infiltration rate.

The cover contamination has resulted from design will consist of an 18-the tailings remaining uncovered inch-thick radon / infiltration for about 30 years. As-Built barrier constructed from on site Drawing LOW-PS-10-1210 shows the borrow, beneath a 6-inch-thick detail of the cover to consist of sand drainage layer, and a 12-an 18-inch thick radon barrier, inch gravel and rock layer on the covered by a 6-inch bedding surface for erosion protection. (sand) layer, with 12-inches of The radon barrier will have a small rock (Type A) on the designed saturated hydr,aulic surface. conductivity of I x 10' cm/s. i LOW dCRR.mwh March, ??93 8-14 APPENDIX B

9 VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lowman, Idaho RAP Feature: Water Resources Protec-tion Issues Reviewer: M. Layton RAP Requirements Yerification

3. The amount of water added to the

3. Volume 5, Appendix B of the draft disposal cell for, dust control Completion Report provides the and construction will be limited initial engineering calculations to approximately 2,000,000 that were used to develop the gallons. This will be done to water consumption estimate; limit the amount of water however, the amount of water contributing to transient actually used in construction and drainage.

dust control are not included for 'As-Built' verification. See Appendix D.

4. Compliance monitoring will be

4. The draft Completion Report does performed in existing Wells 575, not contain any information on 580, 641 and spring 561. Two the collection of, or the results additional P0C wells will be of, ground-water sampling during installed at a future date.

and immediately following Compliance monitoring wells will remedial activities. See Appendix be sampled twice during the D. construction period, quarterly during the first two years following the completion of remedial action. The wells will be monitored for antimony, barium, chromium, lead, molybdenum, net gross alpha, nitrate, radium-226 & -228, and uranium. MSN B-15 APPENDIX B

i i i i i i l APPENDIX C + UMTRCA, THE EPA STANDARDS, AND THE PHASED UMTRA PROJECT P b i ww can.mwh MarEh,1993 C~1 ^ *E"D3"

• 4 lr i

i UMTRCA. THE EPA STANDARDS. AND THE PHASED UMTRA PROJECT Title I of UMTRCA defines the statutory authority and roles of the DOE, the NRC, and the EPA with regard to the remedial action program for inactive uranium mill tailings sites. The Standards UMTRCA charged the EPA with the responsibility for promulgating remedial action standards for inactive uranium mill sites. The purpose of these standards is to protect the public health and safety and the environment from radiological and non-radiological hazards associated with radioactive t materials at the sites. UMTRCA required that EPA promulgate these standards by no later than October 1,1982. After October 1,1982, if the EPA had not promulgated standards in final form, DOE was to comply with the standards proposed by EPA under Title I of UMTRCA until such time as the EPA had promulgated its standards in final form. The final EPA standards were promulgated with an effective date of March 7, 1983 (48 FR 602; January 5, 1983); See 40 CFR Part 192 - Standards for Remedial Actions at Inactive Uranium Processing Sites, Subparts A, B, and C. These regulations may be summarized as follows: 1. The disposal site shall be designed to control the tailings and other residual radioactive materials for up to 1000 years, to the extent reasonably achievable, and, in any case, for at least 200 years [40 CFR 192.02(a)]. 2. Provide reasonable assurance that the disposal site design shall prevent radon-222 from residual radioactive material to the atmosphere from exceeding an average release rate of 20 picocuries per square meter per second or from increasing the annual average concentration of radon-222 in air at or above any location outside the disposal site by more than one-half picocurie per liter [40 CFR 192.02(b)]. 3. The remedial action shall be conducted so as to provide reasonable assurance that, as a result of residual radioactive materials from any designated processing site, the concentrations of radium-226 in land averaged over any area of 100 square meters shall not exceed the background level by more than 5 picocuries/ gram averaged over the first 15 centimeters of soil below the surface and 15 picocuries/ grim averaged over any 15 centimeters more than 15 i centimeters below the surface [40 CFR 192.12(a)]. The portion of the EPA standards dealing with ground water requirements, 40 CFR 192.20(a)(2)-(3) were remanded by the Tenth Circuit Court of Appeals on September 3, 1985. Based on this court decision, EPA was directed to promulgate new groundwater standards. EPA proposed these standards in the form of revisions to Subparts A-C of 40 CFR Part 192 in September 1987, and now is in the process of completing action to promulgate the final groundwater tow ocu. e March, 1993 C-2 Aertuarx c i

4 standards. As mandated by Section 108(a)(3) of UMTRCA, however, the remedial action at the inactive uranium processing sites, is to comply with EPA's proposed standards until such time as the final standards are promulgated. DOE continues to perform remedial action at the inactive processing sites in accordance with NRC's concurrence with the remedial action approach based on the proposed EPA groundwater standards (52 FR 36000; September 24,1987). Delaying implementation of the remedial action program would be inconsistent with Congress' intent of timely completion of the program. Modifications of disposal sites after completion of the remedial action to comply with EPA's final ground water protection standards may be unnecessarily complicated and expensive and may not yield commensurate benefits in terms of human and environmental protection. Therefore, the Commission believes that sites where remedial action has been essentially completed prior to EPA's promulgation of final ground water standards will not be impacted by the final ground water standards. Although additional effort may be appropriate to assess and clean up contaminated ground water at these sites, the existing designs of the disposal sites should be considered sufficient to provide long-term protection against future ground water contamination. NRC does not view UMTRCA as requiring the reopening of those sites that have been substantially completed when NRC concurred with the selection of remedial action in accordance with applicable EPA standards, proposed or otherwise in place at the time such NRC concurrence was given. DOE Selection (Desion) Phase For each site, UMTRCA requires that DOE select a plan of remedial action that will satisfy the EPA standards and other applicable laws and regulations, and with which the NRC will concur. For each site, this phase includes preparation by DOE of an Environmental Assessment or an Environmental Impact Statement, and a Remedial Action Plan (RAP). The Remedial Action Plan is structured to provide a comprehensive understanding of the remedial actions proposed at that site and contains specific design and construction requirements. To complete the first phase, NRC and the appropriate State or Indian tribe review the RAP and then concur that the RAP will meet the EPA standards. The Performance (Construction) Phase In this phase the actual remedial action (which includes decontamination, decomissioning, and reclamation) at the site is done in accordance with the Remedial Action Plan. The NRC and the State / Indian tribe, as applicable, must ccncur in any changes to the concurred-in plan that arise during construction. At the completion of remedial action activities at the site, NRC concurs in DOE's determination that the activities at the site have been completed in accordance with the approved plan. Prior to licensing (the next phase), title to the disposed tailings and contaminated materials must be transferred to the United States and the land upon which they are disposed of must be in Federal custody to provide for long-term Federal control. Disposal sites on Indian land will remain in the beneficial ownership of the Indian tribe. Low ocan."* u ren. 1993 C-3 ""C

1 i NRC concurrence in the DOE determination that remedial action at a processing 1 site has been accomplished in accordance with the approved plan may be i accomplished in two steps where residual radioactive material is not being moved from the processing site to a different disposal site. The Uranium Mill Tailings Remedial Action Amendments Act of 1988 allows for a two step approach for Title I disposal sites. The Amendments Act will allow DOE to do all remedial actions, other than ground water restoration, for the first step of t closure and licensing. The second step, which can go on for many years, will deal with existing ground water restoration. When ground water restoration is completed, the Long-Term Surveillance Plan requirtd under the licensing phase will be appropriately amended. For sites that are being moved, licensing will occur in one step. There is no ground water restoration at the disposal site and the processing site will not be licensed after completion of remedial action. i The licensino Phase Title I of UMTRCA further requires that, upon completion of the remedial action program by DOE, the permanent disposal sites be cared for by the DOE or l other Federal agency designated by the President, under a license issued by the Commission. DOE will receive a general license under 10 CFR Part 40.27 following (1) NRC concurrence in the DOE determination that the disposal site has been properly reclaimed and (2) the formal receipt by NRC of an acceptable Long-Term Surveillance Plan (LTSP). NRC concurrence with DOE's performance of l the remedial action indicates that DOE'has demonstrated that the remedial action complies with the provisions of the EPA standards in 40 CFR part 192, Subparts A, B, and C. This NRC concurrence may be completed in two steps as discussed above. There is no termination date for the general license. Public involvement has been and will continue to be provided through DOE's i overall remedial action program for Title I sites. The local public will have an opportunity to comment on the remedial action or closure plans proposed and implemented by DOE and to raise concerns regarding final stabilization and the degree of protection achieved. NRC fully endorses State / Indian tribe and public input in all stages of the program, especially in the planning stages of remedial action when such input can be most effective in identifying and resolving issues affecting long-term care. At the time the LTSP is submitted, the NRC will consider the need for a public meeting in response to requests and public concerns. Therefore, NRC encourages State / Indian tribe and public participation early in the remedial action and closure process and will provide additional opportunities, as needed, later in the process. The Surveillance and Monitorino Phase in this phase DOE and NRC periodically inspect the disposal site to ensure its integrity. The Long-Term Surveillance Plan (LTSP) will require the DOE to make repairs, if needed. 4 One of the requirements in the EPA standards is that control of the tailings should be designed to be effective for up to 1000 years without active maintenance. Although the design of the stabilized pile is such that reliance LN dCRR.smh ~ Mar h, 1993 C-4 A M CIR C j l

.'o e on active maintenance should be minimized or eliminated, the NRC license will. require emergency repairs as necessary. Ir the event that significant repairs are necessary, a determination will be made on a site specific basis regarding the need for additional National Environmental Policy Act (NEPA) actions, 'and health and safety considerations from 10 CFR Parts 19, 20, and 21. O m LO(dCRR.nwh March, 1993 C-5 APPEleIX C

O r \\,, ~

• 4 g

i APPENDIX D OPEN ISSUES AND

GENERAL COMMENT

S FOR DOE RESOLUTION P t L i l i i Lubi dCRR.rwh March, 1993 0-} APPENDIK D ) l

J*, f OPEN ISSUES GE0 TECHNICAL ENGINEERING 1. a) The RAP requirement that the organics in lower lifts of the contaminated material be <5% by volume in any area. (Specification page 02200-16), was not discussed in the CR. DOE should address how field activities controlled this aspect or otherwise provide verification for this item. b) The maximum 5% by volume organic / deleterious substance content for radon barrier material (Specification page 02200-8) was not discussed. As above, DOE should address'how field activities controlled this aspect or otherwise provide verification for this item. 2. Frequency distribution of testing for contaminated fill and radon barrier soils was not provided. DOE should address or provide verification for this item. 3. For the bedding layer material it was stated that an " Average value of 4 tests was within specified limits." It is not stated whether any individual test results were out of specified limits. DOE should verify that no individual tests were outside of acceptable limits. RADIATION PROTECTION / SITE CLEANUP 4. The RAS Report (pages 2, 6) states that the cell will cover 9 acres and approximately 18 acres will be restricted area. There is no map in Appendix D, As-Built Drawings, that indicates which 18 acres have restricted assess or how the restricted area will be maintained. No fence is indicated. DOE should indicate the location and current / future status of this 18-acre area. 5. As stated in a November 5, 1991, letter to DOE, NRC's concurrence on PID 12-S-07 was on the condition that the Completion Report contain data supporting the estimate that the average radium content of the additional material placed in the ditch at the north end of the disposal cell was below 25 pCi/g. A copy of an Inter-Office Comunication was attached to PID12-S-07, Revision 1,thatwastransmittedtoNRConSgptember25, 1991. That document stated that the additional 24,500 yd of contaminated material contained less than 20 pCi/g in the top 10 feet. i DOE should present the data in the CR. WATER RESOURCES PROTECTION / GROUNDWATER HYDROLOGY 6. As-Built drawings do not show the locations of abandoned wells listed in the specification; or a listing and location of abandoned piezometers situated beneath the designated disposal cell. DOE should update the As-Built drawings to include the locations of abandoned wells and piezometers. DOE should also provide the abandonment procedures for the DCN 0-2 APPENDIX D

4 d. J-a piezometers, if those procedures varied from the well abandonment specification in the RAP. Additionally, several monitoring wells described in the RAP are not shown on the As-Built Drawing LOW-PS-10-1209, and not listed as being abandoned. Well 641 and the on-site perennial spring (561) are designated monitoring points described in the RAP. DOE should revise Drawing LOW-PS-10-1209 to show the location of all wells remaining after completion of remedial activities. 7. DOE should provide tabulations of the measured quantities of water actually used for dust control and tailings material compaction. 8. DOE should provide the ground-water monitoring data collected during and immediately after the remedial activities. Additionally, an interpretive analysis of the monitoring results should be provided to document the impact that remedial activities may have had on the ground-water quality. i LOW WRR.awh March, 1993 0-3 APPICIX D

nP -3.

GENERAL COMMENT

S RADIATION PROTECTION / SITE CLEANUP 1. Appendix D as-built drawing LOW-PS-10-1208 s'hould be revised as follows: a. The drawing indicates four " hot spots" in areas where supplemental-standards were applied to leave low-level Ra-226. Note three on the drawing states that these spots are five feet in diameter and over the 5 pC1/g Ra-226 standard, More specific information-such as volume and average Ra-226 level, or a reference' to data on these spots should be provided on the drawing. b. The RAS Report indicates on page 71 that three " hot spots" along the access road, in the southwest corner of the property, were removed. The three " hot spots" on Figure 6.2 of the RAS Report correspond in i location to three of the " hot spots" on the drawing. DOE should i determine if the three " hot spots" should be removed from the drawing. If the drawing is correct and therefore, the supplemental standard application is incorrect or incomplete, this becomes an open issue. c. The drawing should indicate that the areas marked 0.0 feet for depth i of excavation are the suppleniental standards areas where Ra-226 contamination is to remain. i 2. Appendix K of the CR contains PID 12-S-09 which is the supplemental 'i standard application for 0.5 acres along Clear Creek. - NRC staff recommends that Appendix K be eliminated from the CR as presentation of entire PIDs in the CR is inappropriate. Summary information-related to 'l the PID should be added to Appendix H or Appendix J (page four), which i already contain discussion of supplemental standard areas. 3. Appendix J (page 1) indicates that the supplemental standards areas' are on-site. However, as-built drawings LOW-PS-10-1203 and 1209 indicate that ' i most of the supplemental standard areas are outside of the designated site boundary and the north windblown area is outside the property line. DOE-should explain the statement in Appendix J and indicate the' potential use of the supplemental standard areas. 4. Given that a supplemental standard for uranium was described in the PAP, Appendix J should mention why uranium measurements are not included. 5. Volume 58, Appendix B, Calculation 12-625-01-03 Addendum Appendix C (DOE, 1992a), is titled Field Radon Emanation Results. The data from 20 locations at various elevations, is presented as pCi/g. Radon emanation is the fraction of radon released into the pore space of the soil and would have no units. According to page AA-8, the data in Appendix C represents Ra-226 levels. DOE should correct the title page to this Appendix C. $MI D-4 Amerx o _}}