ML20057D028
| ML20057D028 | |
| Person / Time | |
|---|---|
| Issue date: | 08/31/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20057D027 | List: |
| References | |
| REF-WM-64 NUDOCS 9310010009 | |
| Download: ML20057D028 (51) | |
Text
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l FINAL COV 3LET ON REVIEW RE307T for the lEMEDIAL ACTION at the LAKEVIEW, OREGON URANIUM MILL TAILINGS SITE August 1993 Uranium Recovery Field Office
- goo 3g g 930,01 Region IV
~
U.S. Nuclear Regulatory Commission
i a
TABLE OF CONTENTS Lakeview Completion Review Report Section Page
1.0 INTRODUCTION
1 L
2.0 BACKGROUND
I 2.1 UMTRCA I
2.2 Concurrence Process for the Selection of DOE's Remedial Actions.
I 2.3 Concurrence Process for the Performance of DOE's Remedial Actions............................
2 2.4 The Lakeview Site........................
2 2.5 Completion Review Report (CRR) Organization...........
6 3.0 ANALYSIS OF DOE'S REMEDIAL ACTION PERFORMANCE 7
3.1 Previous Actions 7
3.2 Review of Remedial Action Performance..............
7 3.2.1 Geotechnical Engineering Review Results 7
3.2.2 Surface Water Hydrology and Erosion Protection Review Results........................
9 3.2.3 Radiation Protection Review Results 10 3.2.4 Water Resources Protection................
11 4.0
SUMMARY
13 8
5.0 REFERENCES
14 APPENDIX A - NRC Site Visits to the Lakeview, Oregon, Uranium Processing and Disposal Sites l
APPENDIX B - Detailed Comparison of Design Specifications with Completed Remedial Actions Performed at the Lakeview, Oregon, UMTRA i
Project Site
- ~ ~
l APPENDIX C - UMTRCA, the EPA Standards, and the Phased UMTRA Proje.t FINAL CRR August 27, 1993 i
LIST OF FIGURES Lakeview Completion Review Report Fiqure Page I
1 La ke vi ew Si t e Loc a t i o n................................................
3 2
Lakeview Mill Tailings Processing Site................................
4 3
Final Conditions Disposal Site........................................
5 4
l I
.s -
FINAL CRR August 27, 1993 ii
1.0 INTRODUCTION
The Lakeview, Oregon, site is one of 24 abandoned uranium mill tailings sites to be remediated by the Department of Energy (DOE) under the Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA). Section 104(f)(1) of UMTRCA requires that the Nuclear Regulatory Commission (NRC) concur with DOE's determination that the remedial action has been properly completed. DOE's remedial action is documented in its Final Verification Report (DOE,1989c),
Final Audit Report (DOE, 1990), and Final Completion Report (DOE, 1991a). This Completion Review Report (CRR) documents the NRC staff's basis for its concurrence decision.
2.0 BACKGROUND
2.1 UMTRCA l
Title I of UMTRCA requires remedial action at abandoned uranium mill tailing sites and associated vicinity properties. The purpose of this legislation is to protect the public health and safety and the environment from radiological and nonradiological hazards associated with radioactive materials at these sites.
UMTRCA directs DOE to select and perform remedial actions at 24 abandoned uranium mill tailings sites to ensure compliance with the general environmental standards promulgated by the Environmental Protection Agency (EPA) under Section 275(a) of the Atomic Energy Act of 1954, as amended by UMTRCA. UMTRCA also requires NRC's concurrence with DOE's selection and I
performance of the remedial actions.
Following completion of the remedial actions, UMTRCA authorizes NRC to issue a license for long-term custody, maintenance, and monitoring of the disposal sites to ensure continued protection of the public health and safety and the environment.
2.2 Concurrence Process for the Selection of DOE's Remedial Actions To document its selection of the remedial action to be implemented at a particular site, DOE develops and issues a Remedial Action Plan (RAP) and a Remedial Action Inspection Plan (RAIP). The RAP describes the design and procedures proposed by DOE to stabilize the residual radioactive materials at the disposal site and to provide for the long-term protection of the public and the environment. The RAIP identifies the means by which the remedial action activities will be controlled, verified, and documented.
In accordance with UMTRCA, Section 108(a)(1), the NRC staff reviews and concurs with the RAP and any subsequent modifications.
By its review and concurrence in the proposed remedial action, the NRC staff concludes that the remedial action will comply with applicable EPA standards in 40 CFR 192, Subparts A, B, and C.
A conditional concurrence on the RAP was issued by the NRC staff in a letter to DOE datad June 9, 1986. The basis for that concurrence is 3,
j documented in a preliminary Technical Evaluation Report (pTER) issued on FINAL CRR August 27, 1993 1
i l
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1 February 7, 1986. Subsequently, a final Technical Evaluation Report (fTER) was issued on fiovember 19, 1990, to address modifications to the i
RAP that were submitted by DOE after the pTER was issued.
2.3 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 UMTRCA Project Quality Assurance Plan, the RAIP, and the RAP.
In addition, the NRC staff conducts independent inspections during construction.
Upon completion of the remedial action, DOE compiles construction records and prepares a completion report to document that remedial actions have been performed in accordance with the RAP or RAP modifications and the RAIP. Based on this information, DOE certifies tha all provisions of the RAP have been satisfied and, therefore, that the iemedial actions comply with the applicable EPA standards in 40 CFR 192.
Based on its review of DOE's completion report and on site visits and inspections, the NRC concurs that remedial actions have been performed as proposed and approved. The basis for this concurrence is documented in the CRR. NRC's concurrence with DOE's completion determination fulfills the Commission's responsibility under UMTRCA Section 104(f)(1).
j 2.4 The Lakeview Site The Lakeview site is located in south central Oregon approximately 16 miles north of the Oregon-California border (Figure 1). The mill, which was built in 1958, by the Lakeview Mining Company, operated until 1961. During this time, approximately 130,000 tons of ore were processed to produce 171 tons of uranium oxide for the Atomic Energy Commission.
The tailings processing site is located about 1 mile north of the Lakeview city limits in Lake County, Oregon. The site covers about 258 acres including 30 acres of tailings, 69 acres of evaporation ponds, and 25 acres of windblown tailings (Figure 2).
e-The remedial action performed at Lakeview consists of the removal and cleanup of all contaminated material at the processing site and relocation to a new disposal cell at the Collins Ranch site, which is located about 7 miles northwest of the processing site (Figure 3).
The remedial action performed by DOE at Lakeview consisted of the following major activities:
FINAL CRR August 27, 1993 2
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l' 1.
Preparation of the processing site by constructing a waste water retention basin, and a decontamination pad for washing down contaminated equipment and by locating trailers to house employee shower / change facilities and temporary field offices.
2.
Construction of diversion ditches at the processing site to direct storm water runoff away from the site.
3.
Excavation of a partially below-ground disposal cell at the Collins Ranch site.
4.
Placement of a geochemical / flow barrier on the bottom and sides of the excavated disposal cell to minimize seepage from the relocated tailings into the ground-water system.
5.
Removal and cleanup of all contaminated material at the processing site and relocation to the disposal cell at the Collins Ranch site.
6.
Placement of a soil layer over the relocated tailings to reduce radon emissions to EPA standards and to minimize seepage of water into the tailings.
7.
Placement of a rock layer on the outslopes and a rock-soil matrix on the pile top for erosion protection.
8.
Construction of a ditch to divert flows away from the relocated pile.
I 9.
Placement of rock protection in the diversion ditch to minimize erosion potential.
10.
Release of the processing site for unrestricted use by private and/or public entities.
The NRC was not involved with the actual remedial action activities, which were performed by DOE contractors. However, DOE obtained NRC concurrence with the site construction design and significant modifications thbreof.
NRC also performed site inspections to monitor the progress of construction activities (see Appendix A).
2.5 Completion Review Report (CRR) Organization The purpose of this CRR is to document the NRC staff review of DOE's l
Lakeview Final Completion Report.
Section 3 of this CRR presents the analysis of remedial action construction. That section is organized by technical discipline and addresses the geotechnical engineering, surface-water hydrology, and radiation protection aspects of the remedial action.
Appendix A provides a listing of NRC staff visits to and inspections of the Lakeview 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 FINAL CRR l
August 27, 1993 6
1 s
Completion Report documentation. Appendix C presents a detailed description of the requirements of UMTRCA and the resulting phased process of the UMTRA Project.
3.0 ANALYSIS OF DOE'S REMEDIAL ACTION PERFORMANCE 3.1 Previous Actions The NRC staff, based on its review of the RAP and RAP modifications, concurred that the remedial action as desigr.ed, other than the deferred cleanup of ground water, would meet 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 protection, and cleanup of contaminated land and buildings. Staff reviews included assessments in the areas of geotechnical engineering, surface-water hydrology, ground-water hydrology, and geology.
Conditional concurrence on the RAP was provided on June 9, 1986. Conditional concurrence on RAP modifications was subsequently provided on June 15, 1992. The NRC staff also reviewed and concurred with DOE's Remedial Action Inspection Plan (Rev. 3) on May 18,1989. This concurrence was the NRC staff's agreement that the quality control program, i.e.,
the plan for testing and inspection, was acceptable for the Lakeview site.
3.2 Review of Remedial Action Performance The NRC staff's primary objective in reviewing DOE's certificatio'n of g
remedial action completion is to determine whether the remedial actions have been performed in a manner consistent with specifications provided in the RAP, RAP modifications, 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 inspections (see Appendix A), field observations, assessments of onsite data and records, and review of DOE site audit reports. The following a
sections present the results of the review of remedial action performance by individual technical discipline. Note that for the Lakeview reme~ dial action completion review, the pertinent technical disciplines are (1) geotechnical engineering for review of earthwork activities, (2) surface-water hydrology for review of erosion protection aspects of the remedial action, and (3) radiation protection for review of site radiological cleanup activities. Ground-water resources protection is not addressed at this time, since DOE has elected to postpone any ground-water remedial action activities to a separate phase of the project.
3.2.1 Geotechnical Engineering Review Results The NRC staff reviewed the Lakeview Final Completion Report to determine whether the geotechnical engineering aspects of the remedial action had been completed in accordance with (1) the applicable technical specifications in the RAP and (2) the RAIP Revision 3 (DOE, 1989b).
The RAP was initially submitted in April FINAL CRR August 27, 1993 7
s 1986 (D0E, 1986). Subsequently, a final RAP (fRAP) was submitted in February 1989 (DOE, 1989a). This fRAP had technical specifications but no drawings. However, the specifications were not up to date as they were the same as in the 1986 RAP.
In October 1991 (DOE, 1991b),
another fRAP was submitted.
This fRAP also had specifications but no drawings. Again, the specifications were not up to date as there had been eight or nine Project Interface Documents (PIDs) that were not reflected in the specifications. To assure that current up-to-date plans and specifications were compared with the information in the Final Completion Report, the staff used the April 1986 RAP together with all addendums and PIDs. These included addendums 2 and 3 (MKF, 1886a, and 1986b, respectively), and PIDs numbered 13-S-01 to 13-S-30 (addendum I was not reviewed as it was never submitted to the NRC.
However it is understood that this addendum was not pertinent as it was related to a question regarding union labor). NRC did not review all of the testing and inspection records as they were not provided by DOE due to the voluminous amount of documentation. However, the staff did review records during onsite inspections conducted during construction.
In addition, the staff's review was based on statements made by DOE in the completion report that all requirements had been complied with, descriptions of construction operations, as-t built drawings, summaries of laboratory and field testing data, and DOE Quality Assurance Audits.
Based on its review of the geotechnical engineering aspects of the remedial action completion documentation, the NRC staff noted the following:
.1 i
l 1.
DOE concluded that appropriate tests (gradation and classification) and inspections were performed to assure that the proper type of material was placed for each feature of construction. The loose thickness of the lifts was continuously monitored to ensure compliance with the specifications for that material. Placement and compaction operations were routinely I
inspected and tested to assure that the moisture and density requirements were met and that the soil moisture was un Worm throughout the compacted lifts.
2.
DOE concluded that laboratory and field testing was adequately documented indicating that they were conducted in accordance with acceptable test procedures by trained and qualified personnel. Records showing acceptable calibration of measuring and testing equipment are included in the DOE Final Completion Report.
3.
The Final Completion Report shows that frequencies of materials i
testing and inspection comply with the frequencies specified in the RAIP.
FINAL CRR August 27, 1993 8
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/
)
I 4 4.
DOE concluded that Radon Barrier and Geotechnical Flow Barrier a
materials were tested prior to placement and the Ra-226 concentration less than the required 5 pCi/gm.
5.
DOE concluded that contaminated material from the processing site was placed in the disposal cell as was specified.
6.
As-built drawings adequately document that the completed remedial action was consistent with the NRC-approved design.
t 7.
00E concluded that final slope, elevation, and placement of the disposal cell cover were adequately inspected to ensure that the I
final conditions were consistent with those stated in the RAP and final design.
l Details of the staff's geotechnical engineering review, which provide the basis for concurring with DOE's conclusions, are included in the attached Appendix B.
Based on the above conclusions, and on the results of onsite inspections performed by the NRC staff during construction, the NRC staff concludes that the geotechnical engineering aspects of the construction were performed in ace dance with the design and specifications identified in the RAP and the RAIP.
3.2.2 Surface Water Hydrology and Erosion Protection Review Results The NRC staff rcviewed the surface water hydrology and erosio'n j
protection aspects of remedial actions at Lakeview to ensure that t
they were constructed in accordance with the applicable technical l
construction specifications in the RAP (DOE,1991b), and the RAIP (DOE,1989b). Areas of review included as-built drawings, construction 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 onsite inspections (see Appendix A).
f*
The remedial action design featured soil / rock matrix erosion protection on the top of the Collins Ranch disposal cell, and riprap on the side slopes and in the diversion ditch along the north side of the cell. The erosion protection on the top and side slopes of the cell was designed to prevent long-term erosion and gullying of the cell cover. The erosion protection in the diversion ditch was engineered to provide a low-maintenance, armored pathway for i
conveyance of flood flows around the disposal cell.
The NRC staff reviewed each of these features and determined that their testing, placement, and configuration complied with l
specifications in the RAP, RAP modifications, and the RAIP. The I
review was partially based on NRC staff observations and review of onsite records during the remedial actions, as well as assessment of the results presented in the DOE Final Completion Report.
l l
FINAL CRR August 27, 1993 9
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1 During its review of the surface-water hydrology and erosion protection aspects of the remedial action documentation, the NRC
]
staff noted the following:
l.
DOE concluded that tests (gradation and durability) and inspections were adequate to ensure that erosion protection materials were properly selected. The review of the documentation indicated that placement of materials was routinely inspected by DOE to ensure that the rock size (gradation) and durability specifications were met. Likewise, the thickness of each rock layer was verified periodically by DOE to ensure compliance with the specifications for the particular type of material.
2.
DOE concluded that laboratory and field testing was documented in accordance with specified test procedures.
3.
DOE concluded that testing and inspection frequencies for materials used at the site for erosion protection were complied with the frequencies specified in the RAIP.
i Based on NRC staff observations and review of onsite records during the remedial actions, as well as assessment of the verification i
results presented in the DOE Final Completion Report, the NRC staff concludes that the required durability and gradation tests were performed during the remedial action. The riprap is of adequate j
quality and has been acceptably placed. The NRC staff concurs that i
remedial action has been adequately completed at Lakeview with respect to erosion protection.
3.2.3 Radiation Protection Review Results The NRC staff reviewed radiation protection aspects of remedial actions at Lakeview to ensure that cleanup of residual radioactive
'j materials was performed in accordance with specifications in the RAP and RAP modifications, RAIP, and the final design. Areas of review included contaminated material excavation, verification of cleanup, laboratory and field testing, and quality assurance audits.
Speci fic discussion of the details of this review can be found in Feature 8 of Appendix B.
The review was based on the NRC staff's assessment of the verification results presented in the DOE Final Completion i
Report.
In addition, the design and construction of the disposal i
cell cover were reviewed to ensure compliance with the RAP design for limiting radon releases, and thus with the EPA standards (see Section 3.2.1).
During its review of the radiation protection aspects of the remedial action completion documentation, the NRC staff noted the following:
1.
Th-230 contamination was found at depths with the absence of Ra-226. To account for the gradual ingrowth of Ra-226 as a FINAL CRR August 27, 1993 10
\\.
result of Th-230 decay, it was necessary to estimate a cleanup value for the Th-230 to ensure that after 1000 years, the Ra-226 concentration would not exceed the EPA standard of 15 pCi/g.
l The Th-230 concentration selected by DOE was 35 pCi/g and the soils at depths exceeding 15 cm were cleaned up to this concentration. After removal of contaminated soils, one area was found to exceed the 15 pCi/g radium standard. However, since it was a single isolated occurrence and it exceeded the j
standard (plus background) by only 0.9 pCi/g, DOE found it acceptable.
'l 2.
Nine existing buildings at the processing site were left standing and were released for unrestricted use by others.
l 40 CFR Part 192.12 requires that the annual average I,
concentration of radon decay products not exceed 0.02 WL and in any case 0.03 WL. With the exception of two buildings; the laboratory and the office, none of the buildings required any decontamination to meet the 0.02 WL standard. After limited cleanup, the laboratory also met the 0.02 WL criterion. The office after removal of a contaminated filter in the basement, had concentrations of 0.028, 0.027, 0.029, and 0.032 WL.
l Although one of these concentrations exceeded 0.03 WL, by a i
small amount, the average of the four concentrations was 1
0.29 WL.
Thus, the requirement of 40 CFR Part 192.12(B)(1) has been met.
3.
The techniques which DOE states to have been used for ve'rifying l:
radiological cleanup at the processing site, complied wifh DOE's summary protocols and the Vicinity Property Management and i
Implementation Manual (VPMIN) procedures, with which NRC concurred in June 1987.
3.2.4 Water Resources Protection The NRC staff reviewed the ground-water actions that have been performed at the processing site. A minimum number of monitqring wells have been installed to determine the effect of removing the residual radioactive materials from the site. These data are being compiled, but not analyzed. Further ground-water remedial actions, if any, are being considered by DOE, based upon the draft EPA 1
regulations.
Several actions have taken place at the disposal site which give a high level of confidence that the ground-water resources will not be adversely affected by relocation of residual radioactive materials.
Based on its review of the ground-water aspects of the remedial action completion documentation, the NRC staff noted the following:
FINAL CRR August 27, 1993 11
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1.
Ground water was characterized at the disposal cell from both flow and quality standpoints to determine an upgradient background water quality location.
2.
In consideration of background water quality, point of compliance wells were established at the downgradient edge of the disposal cell 3.
To minimize the potential for contamination of ground water at the disposal cell, a 2-ft thick low permeability geochemical flow barrier was placed at the bottom of the disposal cell 4.
During the process of relocating tailings, a naturally occurring hillside seep was discovered adjacent to the disposal cell.
In consideration of this feature, a rock-filled drain was constructed to intercept the seep and drain it to an updip location that will not impact the tailings.
5.
A soil cover with a lower permeability than that of the geochemical flow barrier was placed on top of the tailings in the disposal cell to minimize infiltration of rainfall runoff I
into the tailings.
6.
The soil cover on the top of the disposal cell is protected from erosion by a layer of rock (riprap) which is placed on a sand l
filter \\ drainage layer.
To minimize the potential for ponding of
.j water, the sand layer was designed to allow drainage of' water j
with minimum ponding.
I Based on the above conclusions and on the results of onsite inspections during construction, the staff concludes that by placing low permeability geochemical flow barrier in the bottom of the d
disposal cell prior to relocating the residual radioactive material, the potential for movement of contaminants into the ground water has 1
been minimized. This potential has been further minimized by placement of a soil cover on top of the residual radioactive :" '
materials that is even less permeable than the flow barrier on the bottom of the cell. This design imparts a high level of confidence that the ground-water resources at the disposal site will not be i
impacted due to the minimal amount of liquid that may move through the residual radioactive materials. Should the amount of liquid moving through the cell be greater than expected, the ground-water monitoring program will detect changes in ground-water quality.
l; Pending final EPA regulations regarding ground-water standards, corrective actions may be required; however, based on the draft ground-water regulations that currently exist, sufficient details j
associated with protection of the ground-water resources at both the processing site and the disposal sites have been implemented.
FINAL CRR l-August 27, 1993 12 it
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i 4.0
SUMMARY
The NRC staff reviewed geotechnical engineering, erosion protection, ground-water hydrology and radiation protection aspects of the remedial action performed at the uranium mill tailings site in Lakeview, Oregon. The purpose of this review was to determine whether DOE had performed remedial actions at the site in accordance with specifications in the RAP, addendums to the RAP,
)
PIDs and other supporting project documents, and thus with the EPA standards in i
40 CFR Part 192, Subparts A-C.
Based on its review of the Certification Report 1
l and on observations during periodic site inspections, the NRC staff concurs that DOE has performed the remedial action at the Lakeview site in accordance with the above specifications, and that this action complies with the EPA standards. With the exception of ground water clean up, remedial actions are complete for the Lakeview site. DOE has proposed deferral of selection and j
performance of a ground-water cleanup program at this time and plans to handle this as part of a separate UMTRA ground-water restoration program. The NRC staff considers D0F's deferral to be acceptable, and therefore, hereby concurs in completion of the Lakeview remedial action.
l l
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e-1 FINAL CRR August 27, 1993 33
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5.0 REFERENCES
DOE,1986, Remedial Action Plan and Site Design for Stabilization of the Inactive Uranium Mill Tailings Site at Lakeview, Oregon, U.S. Department of Energy, UMTRA-00E/AL-050510.0000, April 1986.
DOE,1989a, Remedial Action Plan and Site Design for Stabilization of the Inactive Uranium Mill Tailings Site at Lakeview, Oregon, Appendix B of the Cooperative Agreement No. DE-FC04-84AL20534, c.S. Department of Energy, l
UMTRA-D0E/AL-050510.0000, February 1989.
DOE,1989b, UMTRA Project, Lakeview, Oregon, Remedial Action Inspection Plan, U.S. Department of Energy, Document Number MKF-UMTRA-16, Revision 3, April 6,1989.
DOE,1989c, Lakeview, Oregon Site, Revised Final Verification Report, U.S. Department of Energy, November 29, 1989.
DOE,1990, Report of Final Audit, Remedial Action Construction, UMTRA l
Project, Lakeview, Oregon, U.S. Department of Energy, October 1990.
DOE,1991a, Lakeview, Oregon, Final Completion Report, Volumes 1, 2, 3, 4, l
5, 5A, 58, SC, 5D, SE, 5F, and 6, U.S. Department of Energy, December l
1991.
I DOE,1991b, Remedial Action Plan and Site Design for Stabilization of the l-Inactive Uranium Mill Tailings Site at Lakeview, Oregon, U.S. Department j
of Energy, UMTRA-D0E/AL-050510.0000, Rev.1, October 1991.
DOE,1992a, Letter from A. R. Chernoff, DOE, to R. E. Hall, NRC, transmitting revisions to the December 1991 Final Completion Report, June 9, 1991.
00E,1992b, Letter from A. R. Chernoff, DOE, to R. E. Hall, NRC transmitting revisions to the December 1991 Final Completion Report, July 17, 1992.
DOE,1992c, Remedial Action Plan and Site Design for Stabilization of the-Inactive Uranium Mill Tailings Site at Lakeview, Oregon, U.S. Department l
of Energy, UMTRA-DOE /AL-050510.0000, Rev.1, July 1992.
DOE, 1993a, Letter from A. R. Chernoff, DOE, to R. E. Hall, NRC, transmitting revisions to the December 1991 Final Completion Report, February 26, 1992.
00E,1993b, Lettr from A. R. Chernoff, DOE, to R. E. Hall, NRC, transmitting i
revisions to the December 1991 Final Completion Report, April 13, 1993.
FINAL CRR August 27, 1993 14 j
J V
a MKF, 1986a, Letter from J. G. Oldham, MK-Ferguson Company, to E. F. Hawkins, NRC, Lakeview Main Construction Subcontract, LKV-1, Final Design for Construction - Addendum No. 2, April 28,1986 MKF, 1986b, Letter from J. G. Oldham, MK-Ferguson Company, to E. F. Hawkins, NRC, Lakeview Main Construction Subcontract, LKV-1, Final Design for Construction - Addendum No. 3, April 30,1986 i
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FINAL CRR August 27, 1993 15
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APPENDIX A:
NRC SITE VISITS AND INSPECTIONS AT THE LAKEVIEW, OREGON, URANIUM PROCESSING AND DISPOSAL SITES i
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i FINAL CRR August 27, 1993 j
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i APPENDIX A NRC SITE VISITS AND INSPECTIONS AT THE LAKEVIEW, OREGON, URANIUM PROCESSING AND DISPOSAL SITES I
l DATE STAFF DISCIPLINE PURPOSE 10/2-3/84 G. Gnugnoli Project Management Public Meeting and tour of alternate sites 5/21/85 M. Fliegel Technical Management Observe proposed G. Gnugnoli Project Management disposal area and T. Johnson Project Management rock borrow area 9/8-9/86 E. Hawkins Management Observe construction T. Olsen Project Management activities and assess
}
H. Rose Project Management QA/QC program i
4/02/87 T. Johnson Project Management Observe stockpiled R. Gonzales Project Management riprap and visit alternate rock sources 5/19/88 T. Olsen Project Management Observe construction R. Gonzales Project Management activities and assess QA/QC program
~
8/22/89 E. Hawkins Management Observe construction
- j R. Gonzales Project Management activities and assess D. Jacoby Project Management QA/QC program G. Konwinski Project Management 10/12/89 R. Hall Management Attend DOE's Final l
Inspection at comple-l j
tion of construction i
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if FINAL CRR 1
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August 27, 1993 A-1 l
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APPENDIX B:
- )
i DETAILED COMPARISON OF DESIGN SPECIFICATIONS WITI: COMPLETED REMEDIAL ACTIONS PERFORMED AT LAKEVIEW, OREGON, UMTRA PROJECT SITE
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4 FINAL CRR August 27, 1993 t
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NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Lakeview Disposal Site RAP Feature:
1.
Subgrade Preparation (pg. I of 3)
RAP Reauirement NRC Determination a.
Configuration:
(1) Disposal Cell Bottom - slope toward As-Built Drawing LKV-DS-10-1319 the east at a slope of 1% with an indicates that the disposal cell was elevation of 4880 ft at the west excavated as designed.
side of the disposal cell (Drawings LKV-DS-10-1316 and LKV-DS-10-1319 in Addendum No. 2, MK Ferguson Co.
3 letter dtd. 4/28/86).
(2) Disposal Cell Slopes - 3.5H:IV side As-Built Drawing LKV-DS-10-1319 slopes.
1% bottom slope (Drawings indicates that slopes of disposal cell LKV-DS-10-1316 and LKV-DS-10-1319 in were constructed as designed.
Addendum No. 2, MK Ferguson Co.
letter dtd. 4/28/86).
(3) Drainage Ditch - Bottom slope varies As-Built Drawings LKV-DS-10-1317 and as shown in Drawing LKV-DS-10-1317, LKV-DS-1321 indicate that slope of the in the April 1986 RAP; and Drawing Drainage Ditch was constructed as LKV-DS-10-1321 in Addendum No. 2, MK designed.
Ferguson Co. letter dtd. 4/28/86.
b.
Materials: - Not applicable c.
Placement:
(1)
Lift Thickness - Not applicable i
FINAL CRR August 27, 1993 B-1
L NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lakeview Disposal Site
. h RAP Feature:
I.
Subgrade Preparation (pg. 2 of 3)
RAP Reouirement NRC Determination c.
Placement (cont'd):
(2) Compaction / Moisture:
Disposal Cell - The top 6 inches of DOE states that 51 passing in place the subgrade area receiving the tests performed on the disposal cell Geochemical Flow Barrier shall be and diversion ditch subgrades indicated compacted to 95% of maximum dry densities of 95% or greater. There t
density as per ASTM D698 (Design were nine tests that failed and had to Speci fication 02200-3.5.C, PID No, be reworked and retested (Final Comp 1.
13-S-09).
Rpt., Vol. 3, App. E, Section 1).
Drainage Ditch - The top 6 inches of the subgrade of the drainage ditch shall be compacted to 95% of maximum dry density as per ASTM D698 (Design Speci fication 02200-3. 5. B).
d.
Test Frequency:
2 I
(1) InPlaceFigidDensity-1 test DOE states that an area of 11,809 yd per 1500 yd of compacted was compacted to at least 95% of subgrade (Procedure 6.1.4 of maximum density and a total of 51 the RAIP, Rev. 3).
passing tests were performed for an avgrage of one passing test per 232 yd. The specifications for test frequencies are not based en averages; however, DOE states that quantities between tests were estimated to never exceed the speciff ed testing frequency and tests were proportionally taken during the remedial action and were not taken all in one given time frame.
(Final Compl. Rpt., Vol. 3, App. E, Section 1).
FINAL CRR August 27, 1993 B-2
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l NRC STAFF REVIEW OF DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lakeview Disposal Site RAP Feature:
1.
Subgrade Preparation (pg. 3 of 3)
RAP Reauirement NRC Determination d.
Test Frequency (cont'd):
(2) One-Point Proctor - 1 test per 10 DOE states that a total of 10 one-point field density tests (Procedure 6.1.6 tests were taken. Since there were 51 of the RAIP, Rev. 3).
passing density tests, this resulted in l
an average of I one-point test per 5.1 field density tests. The specifications for test frequencies are not based on averages; however, DOE l
l states that the specified testing I
frequency was never exceeded and tests l
were proportionally taken during the l
remedial action and were act taken all I
in one given time frame.
(Final Comp 1.
Rpt., Vol. 3, App. E, Section 1).
[
l (3) Laboratory Compaction - There was no Thg subgrade covered an area of 11,809 specific laboratory testing yd. Assuming a subgrade thickness of l
requirement in either the RAP or in 0.5ft,thecompacgedsubgradevolume the RAIP. However, the laboratory was about 1,968 yd. DOE states that a i
g testing requirement for random fill, total of 4 laboratory tests were having no specified classification performed. Thisamoungstoanaverage and gradation requirement, wag 1 of one test per 492 yd (Information laboratory test per 10,000 yd of provided by DOE on April 13,1993).
material placed. (Procedure 6.1.5 of The specifications for test frequencies theRAIP,Rev.3). The subgrade are not based on averages; however, DOE laboratory results were compared to states that quantities between tests j
this requirement.
were estimated to never exceed the specified testing frequency and tests were proportionally taken d'uring the remedial action and were not taken all in one given time frame.
(Final Compl.
Rpt., Vol. 3, App. E, Section 1).
FINAL CRR August 27, 1993 B-3
s
-m NRC STAFF REVIEW OF DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Lakeview Disposal Site RAP Feature:
2.
Geochemical Flow Barrier (pg.1 of 4)
RAP Reouirement NRC Determination a.
Configuration:
l (1) Areal Extent - Bottom and side As-Built Drawing LKV-DS-10-1319 l
slopes of disposal cell to be lined indicates that the Geochemical Flow with a Geochemical Flow Barrier Barrier was placed as designed.
(Drawing LKV-DS-10-1319 in Addendum No. 2, MK Ferguson Co. letter dtd.
4/28/86).
(2) Thickness - 2 ft. (Pgs. 25 and 27 of As-Built Drawing LKV-DS-10-1319 the Feb. 1989 RAP and Drawing LKV-indicates that thickness of Geochemical DS-10-1319 in Addendum No. 2, MK Flow Barrier is 2 ft.
Ferguson Co. letter dtd. 4/28/86).
b.
Materials:
(1) Shall be similar to Radon Barrier Material (Design Specification 02200-2.1.C.3).
'Q (a) Gradation - Min. 50% passing DOE states that 27 gradation tests the No. 200 sieve. Max. size 2 passed the Radon Barrier Material in, as per ASTM C136 and ASTM gradation requirements (Final Compl.
D1140 (Design S ecification Rpt., Vol. 3, App. E, Section 2).
02200-2.1.C.2.b.
(b) Atterberg Limits - PI 2 10 as DOE states that of 27 samples tested, 4 oj per ASTM D4318 (Design had PIs of less t: tan 10. A Speci fication 02200-2.1.C.2.b).
nonconformance report was prepared and it was determined that the performance of the Geochemical Flow Barrier would not be significantly affected because the le s..cu where the failed tests were k m
.i. at least 185 ft apart in p:
F so, the Geochemical Flow Barri_... s constructed in 3 lifts so the potential for having overlying layers of low PI material is highly unlikely (Final Compl. Rpt., Vol. 3, App. E, Section 2).
i FINAL CRR August 27, 1993 B-4
N NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Lakeview Disposal Site RAP Feature:
2.
Geochemical Flow Barrier (pg. 2 of 4)
RAP Reauirement NRC Determination b.
Materials (cont'd):
(c) Classification - Material shall DOE states that 27 classification tests consist predominantly of passed the Radon Barrier Material soils classified as CL, MH, or classification requirements (Final ML as per ASTM D2487 (Design Compl. Rpt., Vol. 3, App. E, Speci fication 02200-2.1.C.2.b).
Section 2).
(d) Activity - Ra-226 concentration DOE states that samples were collected shall not exceed 5.0 pCi/gm and analyzed on-site to ensure that (Design Specification 02200-material was not contaminated (Final 2.1.C.2.a).
Compl. Rpt., Vol. 4, App. H, Section 2). rigure J-4 of Vol. 4, App.
J shows that all samples were less than 3.5 pCi/gm.
c.
Placement:
(1) Lift Thickness - Not greater than DOE states that placement was that required to achieve the continuously monitored to ensure that required compaction and in no case loose lifts did not exceed 12 in.
Section 2)pl. Rpt., Vol. 3, App. E, (Final Com more than 12 in. (Design Specification 02200-3.4.B.8, PID Nos. 13-S-02 and 13-S-09).
(2) Compaction / Moisture - At least 958s DOE states that there were 20 failing of maximum dry density, at or less in place density tests within than optimum moisture as per ASTM 12 different areas that had to be D698 (Design Specifications 02200-reworked in order to obtain the 3.4.C.1 and 3.4.C.2, Addendum No. 3, required density. After r600rking MK Ferguson Co. letter dtd.
those areas, 130 tests met both the 4/30/86).
moisture and density requirements (Final Compl. Rpt., Vol. 3 App. E, Section 2).
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FINAL CRR August 27, 1993 B-5 i
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t NRC STAFF REVIEW OF DOE'S VERIFICATION OF' REMEDIAL ACTION PLAN ACTIVITIES Site: Lakeview Disposal Site RAP Feature:
2.
Geochemical Flow Barrier (pg. 3 of 4) l RAP Reauirement NRC Determination d.
Test Frequency:
3 (1) In Plage Field Density - I test per DOE states that 47,236 yd were placed l
500 yd of material placed. A and a total of 130 passing in place minimug of 2 tests for each day that tests were performed for an average of 3
150 yd or more are placed one passing test per 363 yd. The (Procedure 6.1.4 of the RAIP, specifications for test frequencies are Rev. 3).
not based on averages; however, DOE l
states that quantities between tests were estimated to never exceed the.
specified testing frequency and tests i
were proportionally taken during the-remedial action and were not taken all in one given time frame.
In addition, l
DOE states that a minimum of 2 in place tests were gerformed each day that more j
than 150 yd of material were placed (Final Compl. Rpt., Vol. 3, App. E, Section 2).
j (2) Gradation /C}assification - I test DOE states that a total of,27 passing 3
1 per 2000 yd of material placed. A tests were performed for the 47,236 yd minimum of 1 test per week when an that were placed, for an average of one i
3 appreciable amount of material is passing test per 1750 yd. The i
placed (Procedure 6.2.1 of the RAIP, specifications for test frequencies are Rev.3).
not based on averages; however, DOE states that quantities between tests were estimated to never exceed the 1
specified testing frequency and tests I
were proportionally taken a,uring the
)
remedial action and were not taken all 1
in one given time frame.
In addition, DOE states that a minimum of 1 test was pepformedeachweekthatmorethan150 yd of material were placed (Final i
Compl. Rpt., Vol. 3, App. E, Section 2).
FINAL CRR August 27, 1993 B-6 I
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NRC STAFF REVIEW OF DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lakeview Disposal Site RAP Feature:
2.
Geochemical Flow Barrier (pg. 4 of 4)
RAP Reauirement NRC Determination d.
Test Frequency (cont'd):
(3) One-Point Proctor - I test per 10 DOE states that a total of 22 one-point field density tests (Procedure 6.1.6 tests were taken. Since there were 130 of the RAIP, Rev. 3).
passing density tests, this resulted in an average of I one-point test per 5.9 field density tests. The specifications for test frequencies are not based on averages; however, DOE states that the specified testing frequency was never exceeded and tests were proportionally taken during the remedial action and were not taken all in one given time frame.
(Final Compl.
Rpt., Vol. 3, App. E, Section 2).
(4) Laboratorf Compaction - I test per DOE states that a total of 16 lab.
3 15,000 yd of material placed tests were performed for the 47,236 yd (Procedure 6.1.5 of the RAIP, that were placed for an average of one 3
Rev. 3).
test per 2952 yd. The specifications for test frequencies are not based on averages; however, DOE states that quantities between tests were estimated to never exceed the specified testing frequency and tests were proportionally taken during the remedial action and were not taken all in one given time frame.
(Final Compl. Rpt., Vol. 3, App. E, Section 2).
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l FINAL CRR August 27, 1993 B-7 l
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NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES 1
1 Site:
Lakeview Disposal Site j
RAP Feature:
3.
Tailings / Contaminated Material (pg. I of 4) l RAP Reouirement NRC Determination
{
a.
Configuration:
l l
(1) Areal Extent - Tailings and As-Built Drawing LKV-DS-10-1319 i
i contaminated material to be placed indicates that tailings and in disposal cell as indicated in contaminated material were placed in Drawing LKV-DS-10-1316 and LKV-DS-disposal cell was as designed.
i-10-1319 in Addendum No. 2, MK j
Ferguson Co. letter dtd. 4/28/86.
(2) Slopes - 3% top slope and 5H:1V side As-Built Drawing LKV-DS-10-1319 slopes. Drawing LKV-DS-10-1313 in indicates that slopes of disposal cell Addendum No. 2, MK Ferguson Co.
were constructed as designed.
3 letter dtd. 4/28/86.
l b.
Materials: - Not applicable l
c.
Placement:
l (1) Contaminated materials from the DOE states that windblown contami-l evaporation pond and windblown areas nants, evaporation pond materials, and (Type 1 materials) shall be placed vicinity property materials were mixed in the upper portions of the together and placed on top of the main disposal cell (Design Specifications tailings pile materials. _(Information 02200-1.4.C, and 02200-3.4.B.5).
provided on April 13, 1993 for revising the Final Compi. Rpt., Vol. 4, App. J).
4 (2) Contaminated materials from the As stated above, tailings pile 1
tailings pile (Type 2 materials) materials were placed belorwindblown, shall be placed in the lower evaporation pond, and vicinity property j
i portions of the disposal cell materials.
(Design Specifications 022000-1.4.0, and02200-3.4.B.5).
(3) Contaminated materials from vicinity DOE states that vicinity property properties shall be placed in the materials were placed in the disposal Encapsulation Cell. (Design cell.
(Information provided on April Specification 02200-3.4.B.6).
13, 1993 for revising the Final Comp 1.
Rpt., Vol. 4, App. J).
FINAL CRR August 27, 1993 B-8 i
i 1
NRC STAFF REVIEW OF DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lakeview Disposal Site RAP Feature:
3.
Tailings / Contaminated Material (pg. 2 of 4)
RAP Reauirement NRC Determination c.
Placement (cont'd):
(4) Wood Chips from processing site DOE states that the percent by volume shall be distributed in the disposal of wood chips placed in the disposal cell so as to not exceed 5% by cell did not exceed 5% by volume as volume. (Design Specification 02200-monitored by load counts. (Final Comp 1.
3.2.C).
Rpt., Vol. '. App. E, i.a 3).
(5) Lift Thickness - Not greater than DOE states that material placement was that required to achieve the continuously monitored to ensure that required compaction and in no case loose lifts did not exceed 12 in.
more than 12 in. (Design (Final Compl. Rpt., Vol. 3, App. E, Speci fication 02200-3.4.B.8, PID Section 3).
Nos.13-S-02 and 13-S-09).
(6) Compaction / Moisture - At least 90%
DOE states that there were 62 failing of maximum dry density, as per ASTM in place density tests within 52 D698. Soil to be moisture different areas that had to be reworked
)
conditioned as required to achieve in order to obtain the required the required compaction (Design density. After reworking those areas,
- I Speci fications 02200-3.4.C.1 and 912 tests met the density rbquirement 3.4.C.2).
(Final Compl. Rpt.,
Vol. 3, App. E Section 3).
1 1
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FINAL CRR August 27, 1993 B-9
L I
NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lakeview Disposal Site RAP Feature:
3.
Tailings / Contaminated Material (pg. 3 of 4)
RAP Reouirement NRC Determination d.
Test Frequency:
j (1) In Placg Field Density - 1 test per DOE states that 768,612 yd were placed 3
1000 yd of material placed. A and a total of 912 passing in place minimug of 2 tests for each day that tests were performed for an average of l
3 150 yd or more are placed (Procedure one passing test per 843 yd. The 6.1.4 of the RAIP, specifications for test frequencies are Rev. 3) not based on averages; however, DOE also states that quantities between tests were estimated during remedial action to never exceed the specified testing frequency, and tests were proportionally taken during the remedial action and were not taken all in one given time frame.
In addition, DOE states that a minimum of 2 in place testsweregerformedeachdaythatmore than 150 yd of material were placed (Final Compl. Rpt., Vol. 3, App. E, Section 3).
(2) One-Point Proctor - l' test per 10 DOE states that a total of'i82 one-I field density tests (Procedure 6.1.6 point tests were taken. Since there of the RAIP, Rev. 3).
were 912 passing density tests, this resulted in an average of I one-point test per 5.0 field density tests. The specifications for test frequencies are not based on averages; however, DOE I
states.that the specified fre,quency was never exceeded and tests w(re proportionally taken during the remedial action and were not taken all l
in one given time frame (Final Compl.
Rpt., Vol. 3, App. E Section 3).
+
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i FINAL CRR August 27, 1993 B-10 i
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l l-NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lakeview Disposal Site RAP Feature:
3.
Tailings / Contaminated Material (pg. 4 of 4)
RAP Reouirement NRC Determination d.
Test Frequency (cont'd):
(3) Laboratorg Compaction - 1 test per DOE states that a total of 100 lab.
10,000 yd of material placed tegts were performed for the 768,612 (Procedure 6.1.5 of the RAIP, Rev.
yd that were placed,3for an average of 3).
one test per 7,686 yd. The specifications for test frequencies are i}
not based on averages; however, DOE l
i_
states that quantities between tests I
were estimated to never exceed the specified testing frequency, and tests were proportionally taken during the remedial action and were not taken all in one given time frame.
(Final Compl.
Rpt., Vol. 3, App. E, Section 3).
=
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FINAL CRR August 27, 1993 B-11
7 l
i NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES 1
Site: Lakeview Disposal Site RAP Feature:
4.
Radon Barrier (pg.1 of 4)
RAP Reouirement NRC Determination a.
Configuration:
(1) Areal Extent - Radon Barrier to be As-Built Drawing LKV-DS-10-1319 placed over all contaminated indicates that Radon Barrier was placed i
material (Drawing LKV-DS-10-1319 in as designed.
Addendum No. 2, MK Ferguson Co.
letter dtd. 4/28/86).
(2) Thickness = 1.5 ft. (Pg. 25 of the As-Built Drawing LKV-DS-10-1319 Feb. 1989 RAP and Drawing LKV-DS indicates that thickness of Radon 1319 in Addendum No. 2, MK Ferguson Barrier is 1.5 ft.
Co.letterdtd.4/28/86).
b.
Materials:
(1) Gradation - Min. 50% passing the DOE states that 28 gradation tests No. 200 sieve. Max. size 2 in as passed the Radon Barrier gradation per ASTM C136 and ASTM D1140 requirements (Final Comp 1. Rpt.,
(Design Specification 02200-Vol. 3, App. E, Section 4).
2.1. C. 2. b).
(2) Atterberg Limits - PI ~210 as per DOE states that of samples t'ested, 3 ASTM D4318 (Design Specification had PIs less than 10. Soils that 02200-2.1.C.2.b).
failed to meet the PI requirement were rejected and removed.
(Final Compl.
Rpt., Vol. 3, App. E, Section 4 and DOE letter dated July 17,1992).
(3) Classification - Radon Barrier Information provided by DOE indicates Material shall consist that of the samples tested 28 met the predominantly of soils classified classification requirements. Soils as CL, MH, or ML as per ASTM D2487 that failed were removed and rejected (Design Specification 02200-(Final Compl. Rpt., Vol. 3, App. E, 2.1.C. 2. b).
Section 4 and DOE letter dated July 17, 1992).
l FINAL CRR August 27, 1993 B-12
i N
NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Lakeview Disposal Site RAP Feature:
4.
Radon Barrier (pg. 2 of 4)
RAP Reauirement NRC Determination b.
Materials (cont'd):
(4) Activity - Ra-226 concentration in DOE states that samples were collected Radon Barrier Material shall not and analyzed on-site to ensure that exceed 5.0 pCi/gm (Design material was not contaminated (Final Speci fication 02200-2.1.C.2.a).
Compl. Rpt., Vol. 4, App. H, Section 2). Figure J-4 of Vol. 4, App.
J shows that all samples were less than 4
3.5 pCi/gm.
3 c.
Placement:
(1) Lift Thickness - Not greater than DOE states that material placement was that required to achieve the continuously monitored to ensure that required compaction and in no case loose lifts did not exceed 12 inches.
more than 12 in. (Design (Final Compl. Rpt., Vol. 3, App. E.
Specification 02200-3.4.B.8, PID Section 4).
Nos.13-S-02 and 13-S-09).
(2) Compaction / Moisture - At least 100%
DOE states that there were 118 failing of maximum dry density, at or in place density tests within 34 j
greater than optimum moisture as per different areas that had to be reworked ASTM D698 (Design Specifications in order to obtain the required 02200-3.4.C.1and3.4.C.2).
density. After reworking those areas, 75 tests met both the moisture and density requirements.
(Final Comp 1.
Rpt., Vol. 3, App. E, Section 4).
^>-
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FINAL CRR
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August 27, 1993 B-13
)
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1 i
2 NRC STAFF REVIEW OF DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lakeview Disposal Site RAP Feature:
4.
Radon Barrier (pg. 3 of 4)
RAP Recuirement NRC Determination d.
Test Frequency:
3
)
(1) InPlageFieldDensity-Itestper DOE states that 33,388 yd were placed 500 yd of material placed. A and a total of 75 passing in place minimugof2testsforeachdaythat tests were performed for an average of 3
150 yd or more are placed (Procedure one passing test per 445 yd. The 6.1.4 of the RAIP, Rev. 3).
specifications for test frequencies are not based on averages; however, DOE i i states that quantities between tests were estimated to never exceed the j
specified testing frequency, and tests were proportionally taken during the remedial action and were not taken all in one given time frame.
In addition, DOE states that a minimum of 2 in place a
tests were performed each day that more than 150 yd of material were placed i
(Final Compl. Rpt., Vol. 3, App. E, Section4).
(2) Gradation /C}assification - I test DOE indicates that a total of 28 per 2000 yd of material placed. A passingtgstswereperformedforthe minimum of one test per week when an 33,388 yd that were placedi fog an appreciable amount of material is average of one test per 1192 yd. The placed.
(Procedure 6.2.1 of the specifications for. test frequencies are i
RAIP,Rev.3).
not based on averages; however, DOE states that quantities between tests l
were estimated to never exceed the
'j were proportionally taken dGr,nd tests specified testing frequency a ing the remedial action and were not taken all in one given time frame.
In addition, DOE states that a minimum of 1 test was pepformed each week that more than 150 S
yd of material were placed (Final 1
Compl. Rpt., Vol. 3, App. E, Section4).
1 -:
FINAL CRR August 27, 1993 B-14 i
i
,y.,,.e-r v-
- - - - - = -
w-
-'-----*m=*9
-:"?
w st -- P V--
./
,k 5
j ii I
NRC STAFF REVIEW OF DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES
{
l Site: Lakeview Disposal Site RAP Feature:
4.
Radon Barrier (pg. 4 of 4)
RAP Reauirement NRC Determination d.
Test Frequency (cont'd):
(3) One-Point Proctor - I test per 10 DOE states that a total of 59 one point field density tests (Procedure 6.1.6 tests were taken. Since 75 density l
of the RAIP, Rev. 3).
tests were performed, this resulted in 3
an average of I one-point test per 1.3 field. density tests. The l
specifications for test frequencies are
- j not based on averages; however, DOE l
- 'i states that the specified testing frequency was never exceeded and tests were proportionally taken during the remedial action and were not taken all in one given time frame (Final Comp 1.
)
Rpt., Vol. 3, App. E, Section 4).
(4) LaboratoryCompaction-Itestper DOE states that a total of 32 lab..
3 j
15,000 yd of material placed tests were performed for the 33,388 yd i
(Procedure 6.1.5 of the RAIP, Rev.
that were placed,3for an average of one 3).
test per 1,043 yd. The specifications ijl for test frequencies are not based on
)
lI averages; however, DOE states that j
quantities between tests were estimated to never exceed the specified testing
)
frequency, and tests were proportionally taken during the remedial action and were not taken all in one given time frame.
(Final Comp 1.
!l Rpt., Vol. 3, App. E, Section 4).
d J
FINAL CRR 2 :
August 27, 1993 B-15' i
s NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES l
Site: Lakeview Disposal Site RAP Feature:
5.
Bedding Layers (pg.1 of 2)
RAP Reauirement NRC Determination a.
Configuration:
(1) Areal Extent - B-1 Bedding to be As-Built Drawings LKV-DS-10-1319 and placed under riprap on the pile side LKV-DS-10--1321 indicates that the B-1 slopes and diversion ditches.
B-2 and B-2 Bedding was placed as designed.
Bedding under the riprap on the pile top (Drawings LKV-DS-10-1319 and j
LKV-DS-10-1319 in Addendum No. 2, MK Ferguson Co. letter dtd. 4/28/86).
(2) Thickness - nominal 6 in. with a As-Built Drawings LKV-DS-10-1319 and tolerance 5.4 in. to 7.5 in. for the LKV-DS-10-1321 indicate that bedding B-1 Bedding and 6.0 in. to 8.1 in.
thicknesses were placed as designed.
for the B-2 Bedding (Design Specifications 02278-3.2.A.1 and 3.2.A.2, PID No. 13-S-26),
b.
Materials:
(1) Gradation -
Gradation summary curves indicate that 3
8-1 Bedding pile side slopes and both the B-1 Bedding and the B-2 ditches.
Bedding met the gradation requirements.
B-2 Bedding pile top.
(Final Compl. Rpt., Vol. 3, App. E, (Design Specification 02278-Sections 5 and 6).
2.1.B.5.b, PID Nos. 13-S-12-Rev. 2, and 13-S-25-Rev. 1).
(2) Durability - Using the scoring DOE states that based on lab. test criteria of NUREG/CR-4620, a minimum results, the minimum score for the B-I score of 65% was required. Min.
bedding was 89% (Final Compi Rpt.,
values for individual lab.
Vol. 3, App. E, Section 5). The durability tests were not required.
minimum score for the B-2 Bedding was (Design Specification 02278-2.1.B.4, 69% (Final Compl. Rpt., Vol. 3, PID Nos. 13-S-12-Rev. 2 and App. E, Section 6).
13-S-25-Rev.1).
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1 FINAL CRR August 27, 1993 B-16
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NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES 1
Site: Lakeview Disposal Site RAP Feature:
5.
Bedding layers (pg. 2 of 2)
RAP Reauirement NRC Determination c.
Placement:
(1) Compaction - Nominal 6 in. lifts to DOE states that quality control l
be compacted by 4 passes of a 2 to 3 personnel continually monitored ton vibratory roller (Design placement of bedding to ensure that i
Speci fications 02278-3.1.B and layer thicknesses were adequate and to 3.1.C).
verify the number of passes of the 2-2 ton vibratory roller that was used.
l l
(Final Compl. Rpt., Vol. 3, App. E, Sections 5 and 6).
t l
(2) Quality Control - Uniform DOE states that daily inspections of l
distribution, minimization of voids the bedding layers were conducted to (Procedure 6.3.5 of the RAIP, assure that proper techniques were used i
Rev. 3).
to prevent degradation of the material, to assure that distribution was uniform and to minimize voids. (Final Comp 1.
Rpt., Vol. 3, App. E, Sections 5 and 6).
d.
Test Frequency.
(1) A minimum of 4 gradation and DOE states that 4 Tests each were durability tests required for each performed for both the B-1 and B-2 bedding type. One test at the Bedding.3 Thetotalvojumeplacedwas beginning of placement activities, 6,600 yd and 6,400 yd for the B-1 and one test for the first one-third and B-2 bedding, respectively. As these 3
second one-third quantities placed, volumes were both less than 30,000 yd,
4 and a final test near the completion 4 tests are an acceptable n,ymber.
i of placement activities.
If the (Final Compl.
Rpt., Vol.
3, App. E, volume of each tyge of bedding Sections 5 and 6).
exceeds 30,000 yd, an additional 1
3 test is required for each 10,000 yd or fraction thereof (Procedure 6.2.2 oftheRAIP,Rev.3).
FINAL CRR i
August 27, 1993 B-17 1
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NRC STAFF REVIEW OF DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Lakeview Disposal Site RAP Feature:
6.
Erosion Protection (pg. I of 2)
RAP Reauirement NRC Determination a.
Configuration:
(1) Areal Extent - Rock (riprap) to be As-Built Drawings LKV-DS-10-1319 and placed as shown in Drawings LKV-DS-LKV-DS-10-1321 indicate that riprap was 10-1319 and LKV-DS-10-1321 (Addendum placed as designed.
No. 2, MK Ferguson Co. letter dtd.
1 4/28/86).
(2) Thickness -
As-Built Drawings LKV-DS-10-1319 and Type A = 12 in, with a tolerance of LKV-DS-10-1321 indicate that riprap 10.8 in. to 15 in.
thicknesses were placed as designed.
j Type B = 12 in, with a tolerance of t
10.8 in. to 15 in.
Type C = 18 in, with a tolerance of 16.2 in. to 22.5 in.
Type D = 36 in. with a tolerance of 32.4 in. to 45 in.
(Design Specifications 02200-2.1.B.5, PID No. 13-S-25 Rev.1, and 02200-3.2.A.1, and 3.2.A.2).
1 b.
Materials:
(1) Gradation -
Gradation tests and summary curves Type A pile top.
indicate that all riprap met the
,1 Type B - pile side slopes.
gradation requirements.
(Final i
Type C - drainage ditches, key Compl. Rpt., Vol. 3, App. E,
.i trenches and aprons.
Sections 7, 8, 9, and 10).
i Type 0 - ditch outlet.
(Design Specification 2.1.B.5.a. PID Nos. 13-5-12-Rev. 2, and 13-S Rev. 1).
t (2) Durability - Using the scoring DOE states that based on lab. test criteria of NUREG/CR-4620, results, the minimum scores were:
minimum scores of 50 for type A Type A - 90 and 75% for types B, C, and D were Type B - 77 required (Design Specification Type C - 91 2.1.B.4, PID Nos. 13-S-12-Rev. 2, Type D - 93 and 13-S-25-Rev. 1).
(Final Compl. Rpt., Vol. 3, App. E, Sections 7,8,9,and10).
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- p FINAL CRR August 27, 1993 B-18
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NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES t
Site:
Lakeview Disposal Site l
RAP Feature:
6.
Erosion Protection- (pg. 2 of 2)
RAP Reauirement NRC Determination i
c.
Placement l
(1) Quality Control - Uniform DOE states that placement of the riprap distribution, minimization of was continuously monitored to ensure voids (Procedure 6.3.5 of the that layer thicknesses were adequate.
RAIP,Rev.3).
In addition, daily inspections of the i
riprap layers were conducted to assure i
i!
that proper techniques were used to
,j' prevent degradation of the material, to assure that distribution was uniform and to minimize voids.
(Final Compl.-
Rpt., Vol. 3, App. E Sections 7, 8, 9, j
and 10).
i d.
Test Frequency:
l (1) A minimum of 4 gradation and DOE states that 4 tests each were l
durability tests were required for performed for the Type A, B, C, and D each riprap type. One test at the riprap. Jhetotalvo]umesplacepwere beginning of placement activities, 12,664 yd, 3,529 yd, and 11,843yg,ortheTypeA,B;C,andD l
one test for the first one-third and 6,480 yd f second one-third quantities placed, riprap, respectively. As thase and a final test near the completion volumeswgrealllessthan of placement activities.
If the 30,000 yd, four tests per riprap volume of each tyge of riprap type is an acceptable number.
exceeds 30,000 yd, an additional (Final Compl. Rpt., Vol. 3, 3
test is required for each 10,000 yd App. E, Sections 7, 8, 9, and 10).
l or fraction thereof (Procedure 6.2.2 of the RAIP Rev. 3).
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!i FINAL CRR August 27, 1993 8-19 i
NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Lakeview Disposal Site RAP Feature:
7.
Channels, Ditches, and Site Grading (pg 1 of 1)
RAP Reouirement NRC Determination a.
Configuration:
(1) locations, Cross-Sections and Site As-Built Drawings LKV-DS-10-1313, Grading as shown in RAP Drawings LKV-DS-10-1317, LKV-DS-10-1319, and LKV-DS-10-1313, LKV-DS-1317, and LKV-DS-10-1321 indicate that the site LKV-DS-10-1319.
was configured as designed.
9 (2) Material, Placement, and Test Material, Placement, and Test Frequency S
Frequency (See Feature 6 " Erosion (See Feature 6, " Erosion Protection,"
Protection," in this Appendix).
in this Appendix).
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FINAL CRR August 27, 1993 B-20
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NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lakeview Proceseing Site RAP Feature:
8.
Sitt 'eanup (radiological) (pg.1 of 4)
RAP Reauirement NRC Determination a.
Cleanup Verification Procedures:
(1) As indicated in Appendix C of the DOE states that the processing site was April 1986 RAP, and in RAC HP divided into 10 ft. grids and sampled Procedures - 015 " Verification per the procedures in RAC-015 (Final Procedures - Soil Sampling and Compl. Rpt., Vol. 4, App. J).
Analysis."
4' I
b.
Test Results:
(1) All areas of the site to be cleaned DOE s that of 6630 samples taken
'c and ana.s d, all were found to meet up to meet the EPA standards in e
40 CFR 192.32 which are:
the EPA standards. For depths < 15 cm
- 5 pci/gm Ra-226 top 15 cm.
the max. concentration was 4.5 pCi/gm.
- 15 pCi/gm Ra-226 for any For depths > 15 cm, all concentra-subsurface 15 cm layer.
tions, except for one, were <
(These values are above 15 pCi/gm. The one exception had a i
concentration of 15.3 pCi/gm. However, background avep) aged over areas of 100 m since background was determined to be I
about 1.0 pCi/gm, this is acceptable.
O-The average concentration o'f all
~j samples was 1.76 pCi/gm (Final Compl.
Rpt., Vol. 4, App. J).
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i FINAL CRR August 27, 1993 B-21
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NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Lakeview Processing Site RAP Feature:
8.
Site Cleanup (radiological) (pg. 2 of 4)
RAP Recuirement NRC Determination b.
Test Results (cont'd):
(2) Th-230 contamination in sub-surface DOE states that 6206 samples were taken areas of the processing site, absent and analyzed and projections were made of Ra-226, required consideration of to estimate the Ra-226 concentrations the decay of Th-230 to Ra-226. To after 1000-years, due to thorium ensure that after a 1000-year period ingrowth. Only one sample indicated a
.g t
the concentration of Ra-226 does not concentration greater than the EPA exceed the EPA standard of standard (plus background) of 15 pCi/gm, a maximum Th-230 16.4 pCi/gm. This was 17.3 pCi/gm.
concentration of 35 pCi/gm was Since the RAP states that verification selected. An onsite alpha counting measurements will be within *30'. at the system was developed to quickly 95% confidence level, the 17.3 pCi/gm detect Th-230. Ra-226 value was considered to be acceptable.
concentrations, after a 1000-year (Final Comp 1. Rpt.,
period, were then estimated by Vol. 4, App. J).
summing the present Ra-226 results after a 1000-year decay and the ingrown Ra-226 after a 1000-year period (RAC HP Procedures 015).
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FINAL CRR August 27, 1993 B-22
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NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Lakeview Processing Site RAP Feature:
8.
Site Cleanup (radiological) (pg. 3 of 4) t RAP Reouirement NRC Determination c.
Building Cleanup:
l (1) All buildings at the processing site are to be decontaminated as necessary in accordance with the i
following EPA standards for occupied / habitable buildings j
(Appendix C of the April 1986 RAP).
(a) Using reasonable efforts, the All nine buildings in use at the average annual concentration of processing site were left standing for radon decay products, due to future use (Appendix C of the October lll residual radioactive materials, 1991 RAP). DOE states that radon shall not exceed.0.02 WL and in daughter concentrations (RDC) averaged any case 0.03 WL (including 0.01 WL or less, in all buildings l
background).
except in the basement of the office where RDC averaged 0.03 WL. Extensive i
surveys consisting of gamma and borehole surveys outside the office and gamma and core hole surveys inside the office were performed. As a result of these surveys, contamination was removed from a lawn area next to the building. No other evidence of uranium mill tailings was found around or i
underneath the office building.
Therefore, DOE concluded that since the office has a direct conduit to the ground surface through a craw 1 space, the elevated working levels'could be from background levels of Ra-226 1
present in the crawl space and not from residual radioactive material.
(Information provided on July 17, 1992 for revising App. J of Vol. 4 of the Final Comp 1. Rpt.)
(b) The level of gamma radiation shall DOE states that survey results not exceed background by more indicated that gamma radiation exposure than 20 microR/h.
rates did not exceed 20 microR/h (Final Compl. Rpt., Vol. 4, App. J).
i i
f FINAL CRR i
August 27, 1993 B-23 1
1
I N.
I NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES
'l Site: Lakeview Processing Site RAP Feature:
8.
Site Cleanup (radiological) (pg. 4 of 4)
RAP Recuirement NRC Determination c.
Building Cleanup (cont'd):
(2) In addition to the above EPA DOE states that there were no removable standards, removable surface alpha alphameasurempntsabove contaminationsgallnotexceed 100 dpm/100 cm, and the highest figed 1000 dpm/100 cm, and total fixed alpha contamination was 1200 dpm/cm contamination sgall not exceed (Appendix C of the October 1991 RAP).
5000 dpm/100 cm (Appendix C of the March 1986 RAP).
e-FINAL CRR August 27, 1993 B-24
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NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES I
Site: Lakeview Processing Site 1
RAP Feature:
9.
Site Cleanup (non-radiological) (pg.1 of 1) i RAP Reauirement NRC Determination a.
Arsenic Cleanup:
(1) The arsenic concentration within DOE states that the processing site was 2 ft. of the final surface shall be divided into 30 by 150 ft. grids.
less than 200 ppm. At final Grids containing elevated concentra-excavation depth the concentration tions of arsenic were excavated and shall be less than 400 ppm (Revised sampling was performed according to the Final Verification Report, DOE, acceptance criteria.
1242 samples were 1989c).
taken and analyzed. For depths of less than 2 ft., the arsenic concentrations ranged from 0.5 ppm to 199 ppm.
For depths greater than 2 ft., the concentrations varied from 203 ppm to 394 ppm (Final Comp 1. Rpt.,
Vol.4, App.J).
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FINAL CRR August 27, 1993 B-25 I
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APPENDIX C:
UMTRCA, THE EPA STANDARDS, AND THE PHASED UMTRA PROJECT a
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August 27, 1993
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l APPENDIX C:
.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 i
to protect the public health and safety and the environment from radiological W.
and non-radiological hazards associated with radioactive materials at the sites. UMTRCA required that EPA promulgate these standards by no later than 5
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, l
1983 (48 FR 602; January 5,1983); See 40 CFR Part 192 - Standards for Remedial Acticns 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 c
k 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)].
i 2.
Provide reasonable assurance that the disposal site design shall prevent radon-222 from residual radioactive material to the l
atmosphere from exceeding 20 picocuries per square meter per second j
jh or from increasing the annual average concentration of radon-222 in air at or above any location outside the disposal site by smre than one-half picocurie per liter [40 CFR 192.02(b)].
3.
The remedial action shall be conducted so as to provide reasonable 1
assurance that, as a result of residual radioactive materials from I
i any designated processing site, the concentrations of radium-226 in i
land averaged over any area of 100 square meters shall not. exceed the background level by more than 5 picocuries/ gram averaged over a
the first 15 centimeters of soil below the surface and 15 picocuries/ gram averaged over any 15 centimeters more than 15
)
centimeters below the surface [40 CFR 192.12(a)].
s 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 I
FINAL CRR August 27, 1993 C-1 Ll
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N 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 1
standards.
As mandated by Section 108(a)(3) of UMTRCA, however, the remedial action at the d
inactive uranium processing sites, is to comply with EPA's proposed standards j
until such time as the final standards are promulgated. DOE continues to perform remedial action at tiie 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 C
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 i
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 i
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 HRC concurrence was given.
DOE Selection (Desion) Phase t
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 I
by DOE of an Environmental Assessment or an Environmental Impact Statement, and a Remedial Action Plan (RAP). The Remedial Action Plan is structured to 1
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, decommissioning, and reclamation) at the site is done in accordance with the i
Remedial Action Plan. The NRC and the State / Indian tribe, as applicable, must concur 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 i
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 j
to the disposed tailings and contaminated materials must be transferred to the i
United States and the land upon which they are disposed of must be in Federal 6,
FINAL CRR August 27, 1993 C-2 o'
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I custody to provide for long-term Federal control. Disposal sites on Indian land will remain in the beneficial ownership of the Indian tribe.
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NRC concurrence in the DOE determination that remedial action at a processing site has been accomplished in accordance with the approved plan may be j
accomplished in two steps where residual radioactive material is not being moved from the processing site to a different disposal site. The Uranium Mill 1
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 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 required 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 3
and the processing site will not be licensed after completion of remedial action.
The Licensina 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 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 i
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 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 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:an~d 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 Monitoring Phase In this phase DDE and NRC periodically inspect the disposal site to ensure its integrity. The Long-Term Surveillance Plan (LTSP) will require the DOE to make l
repairs, if needed.
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August 27, 1993 C-3
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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 on active maintenance should be minimized or eliminated, the NRC license will require emergency repairs as necessary.
In 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.
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I FINAL CRR August 27, 1993 C-4
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