ML20059P019

Guidance on the Application of Quality Assurance for Characterizing a LOW-LEVEL Radioactive Waste Disposal Site. Final Report

ML20059P019
Person / Time
Issue date:	10/31/1990
From:	Hedges D, Pittiglio C, Starmer R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
References
NUREG-1383, NUDOCS 9010240396
Download: ML20059P019 (17)

Text

-

j i

NUREG-1383 l

i 1

Guidance on the Application of l Quality Assurance for Characterizing a Low-Level Radioactive Waste Disposal Site l

Final Report l

l U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards

('.1. l'ittiglio, Jr., It. J. Starmer. D liedges fy no,%

v N

4 2

78A 20828 ' 2 1383 R PDR l

\\

e i

4

• O AVAILABILITY NOTICE Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources:

1.

The NRC Public Document Room, 2120 L Street, NW, Lower Level, Washington, DC 20555 i

2.

The Superintendent of Documents, U.S. Govemment Printing Office, P.O. Box 37082, Washington, DC 20013 7082 3.

The National Technical Information Service, Springfield, VA 22161 Although the listing that follows represents the majority of documents cited in NRC publica-tions, it is not intended to be exhaustive.

Referenced documents available for inspection and copying for a fee from the NRC Public Document Room include NRC correspondence and internal NRC memoranda: NRC Office of Inspection and Enforcement bulletins, circulars, information notices, inspection and investi-gation notices: Licensee Event Reports: vendor reports and correspondence: Commission papers; and applicant and licensee documents and correspor.dence.

The following documents in the NUREG series are available for purchase from the GPO Sales Program: formal NRC staff and contractor reoorts, NRC-sponsored conference proceed-ings, and NRC booklets and brochures. Also available are Regulatory Guides, NRC regula-tions in the Code of Federal Regulations, and Nuclear Regulatory Commission issuances.

l Documents available from the National Technical Information Service include NUREG series reports and technical reports prepared by other federal agencies and reports prepared by the Atomic Energy Commission, forerunner agency to the Nuclear Regulatory Commission.

Documents available from public and special technical libraries include all open literature items, such as books, journal and periodical articles, and transactions. Federal Register notices, federal and state legislation, and congressional reports can usually be obtained from these libraries.

Documents such as theses, dissertations, foreign reports and translations, and non-NRC conference proceedings are available for purchase from the organization sponsoring the publication cited.

Single copies of NRC draft reports are available free, to the extent of supply, upon written request to the Office of Information f.asources Management, Distribution Section, U.S.

Nuclear Regulatory Commission, Washington, DC' 20555.

Copies of industry codes and standards used in a substantive manner in the NRC regulatory process are maintained at the NRC Library, 7920 Norfolk Avenue, Bethesda, Maryland, and are available there for reference use by the public. Codes and standards are usually copy-i riDhted and may be purchased from the originating organization or, if they are American National Standards, from the American National Standards institute,1430 Broadway, New York NY 10018.

i n

-m.

y

NUREG-1383 i

1 r

Guidance on the Application of Quality Assurance for P

Characterizing a Low-Level Radioactive Waste Disposal Site Final Report i

Manuscript Completed: October 1990 Date l'ublished: October 1990 C. l Pittiglio, Jr., R. J. Starmer, D liedges l

Division oflam Level Waste Management and Decommissioning Omce of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555 a

r ia y p

g

--gas,

-m--

-a

.>m.--

7y 7

4 m

e 4

n.

y_m-

,._-e

ABSTRACT This document provides the Nuclear Regulatory Com-rial controls and audits are the basis for developing a mission's staff guidance to an applicant on meeting the quality assurance (QA) program and for the guidance quality control (QC) requirements of Title 10 of the Code provided herein. QA guidance is specified for site charac-of federal Regulations. Part 61, Section 61.12 (10 CFR terization activities necessary to meet the performance 61.12), for a low level waste disposal facility. The QC re-objectives of 10 CFR Part 61 and to limit crposure to or quirements combined with the requirements for manage-the release of radioactivity.

i 9.

f i

f l

l 1

l iii NUREG-1383 i

l

r CONTENTS Page Abstract......................................................................................

iii I

I n t rod u ct ion...............................................................................

I 2 Regulatory Basis for Quality Assurance Program................................................

1 3 Identification of Parameters and Tests for Evaluating a Disposal Site...............................

2 4 Documentation of laboratory or Field Test Procedures...........................................

2 d

5 Qualifications and Training for Personnel Conducting Site Characterization Activitics.................

7 6 Storage of Site Characterization Data.........................................................

7 7 Records for Sit e Characterization Activities........................................... -..........

7 8 Il ibl iog ra p hy...............................................................................

9 Appendix A Summary of Public Comments on Draft Technical Position Statement....................

9 l

v NUREG-1383 a

i i

QA GUIDANCE FOR CHARACTERIZING A LLRW DISPOSAL SITE 1 INTRODUCTION of the QC program, audits, and managerial controls re-t quired by 10 CFR 61.12((j) is to ensure a planned, organ-ne United States Congress passed laws in 1980 and 1985 ized, and documented approach to meeting the perform-that require States to take specific actions to deal with the ance objectwes ar d techmcal requirements of 10 CFR low level radioactive waste generated by facilities operat-Part 61.ncsc requirements provide the bases for the de-ing within their boundaries. He 1980 law (Public Law velopment of a QA program and the guidance provided heretn.96-573, ne low Level Radioactive Waste Policy Act) specifies that each State will be responsible for disposing its own radioactive waste after January 1,1986; authorizes States to join together to form regional compacts; and De regulatory requirements for a QC program, audits, f.

authorizes those compacts to prohibit disposal of low-and managerial controls, apply to the preoperational t

level radioactive waste generated outside the regional phase, the operational phase, the site closure phase, and compact. ne 1985 amendment (Public Law 99-240, ne the post closure institutional control phase, nese re.

low level Radioactive Waste Policy Amendments Act) quirements cover all activities, structures, systems, or extended the date to January 1993. nis amendment im.

components whose failure could result in not meeting the poses intermediate milestones that the States are re-performance objectives of 10 CFR Part 61 or not limiting quired to meet 'o demonstrate progress and authorizes the exposure to or the release of radioactivity. A Q A pro-the States acceptta this waste for disposal to impose a gram includes a multidisciplinary system of management surcharge on the extdng waste disposal costs.

controls supported by quality verification and ove: view activities that demonstrate completeness and appropri-In an attempt to assist the States in meeting these mile, ateness of achieved quality and serves as a mechanism to stones, the Nuclear Regulatory Commission (NRC) has meet the requirements for audits and managerial con-developed and issued several documents providing guid.

trols.ne applicant should develop and implement an ef-ance on the development of a low level radioactive waste fective QA program before starting site characterization disposal facility. his document provides guidance to an activities and, as the licensee, should continue an effec-applicant on the quality assurance principles for charac.

tive Q A program until the license has been transferred or terizing a disposal site; it is not a regulatory requirement, terrninated. Site characterization is one of the initial and This document does not address all of the 18 criteria de.

most significant activities for determining the suitability fined in NUREG-1293, Quality Assurance Guidancefor of a site and demonstrating performance of an LLRW dis-Low-LevelRadioactive IVaste Disposalfacilityt however, it posal site; therefore, it is important that proper quality as-l provides some additional guidance on the criteria com.

surance procedures are developed and applied to all site mon to all site characterization activities, in addition, the characterization aethities.

NRC is in the process of developing quality assurance (QA) guidance in several other related areas and is con-tinuing to conduct workshops on the QA principles to be To ensure that the site meets regulatory requirements, an used by an applicant for license of a low level radioactive applicant should have management controls in place at waste disposal facility, including workshops for site char-the beginning of the investigation of the disposal site's acterization activitics, characteristics and before performing the analyses to es-tablish a base for its suitability, he applicant must bc 2 REGULATORY BASIS FOR prepared to demonstrate in the license application that QUALITY ASSURANCE the proposed LLRW disposal site, disposal s,ite design, lanMSP Salfadly Perati ns(ine udm8c9u1Pment,fa-PROGRAM cilities, and procedures), disposal site closure, and post-closure institutional control are adequr.te to demonstrate Title 10 of the Code of federal Regulations, Part 61 Sec-that the performance objectives and technical require-tion 61.12(j)(10 CFR 61.12(j)), requires that a license ap-ments of 10 CFR Part 61 will be met, ne applicant plication for a low level radioactive waste (LLRW) dis-should expect that the validity ofinformation contained in posal facility include a description of the quality control the license application will be challenged during licensing (OC) program to be applied to determining the natural review and hearing, and the applicant must be prepared characteristics of a disposal site. The regulation also re-to defend the validity of the data, the analyses, and the quires a QC program during design, construction, opera-conclusions reached. A well designed and effectively im-tion, and closure of the LLRW land disposal facility and plemented QA program provides the disciplined ap-the receipt, handling, and emplacement of waste. Audits proach, verification of results, and records to support the and manaperial controls must be included. De purpose positions taken in the license application.

1 NUREG-1383

3 1DENTIFICATION OF health and safety of the public is ensured. An evaluation PARAMETERS AND TESTS FOR f the methodology used for the site characterization process is one of the pnncipal mechanisms used to make EVALUATING A DISPOSAL SITE that finding. Herefore, it is paramount that the appli-cant's planning process reflect the intent to collect and As part of defining the quality assurance procedures for a analyze data for that purpose. The license application can license application, it is first necessary to identify the most only be approved when the performance objectives and significant parameters for characterizing a site. This will technical requirements of 10 CFR Part 61 are met and provide an insight into the magnitude of work required for when the application irrefutably demonstrates that the site characterization. Table I lists the tests and proce-health and safety of the public are protected.

dures necessary to evaluate or document approximately 70 important site parameters for licensing an LLWR dis-ne most common (and most costly) error applicants posal site.

make is to not carefully plan the investigations needed to characterize the site with a goal of assuring that the 11-

)

A detailed discussion of each of these parameters is pro-cense application will be technically complete, procedur.

\\

vided in NUREG/CR-2700, Parametersfor Characterizing ally defensible, and supported by fully traccable docu-Sitesfot Disposal oflow leve/ Radioactirc lVaste. htost of mentation of the quality of the technical work. A the tests and procedures given in Table 1 are accepted wc!! planned and implemented QA program will ensure standard methods-such as those endorsed by the Ameri-that organizational responsibilitics are assigned, person-can Society for Testing and hiatcrials (ASTM)-that are nel are adequately trained, and plans and procedures are used nationwide and are listed in the column designated written before site characterization activitics are started.

" standard method." Other tests, designated as " formal-ized guidance," provide documented direction for con-In planning the tests to be conducted during site charac-ducting activitics related to site characterization. In addi-terization, the applicant must assure that the resulting tion to the standard methods and formalized guidance, an data will provide the information required to conduct a li-additional categotf of methods involves the use of existing censing assessment. He licensing assessment includes data sources or resognized correlations used in place of the initial step in site characterization of establishing the new testing or doc tmentation. It may be necessary to present level of understanding about the site followed by develop unique procedures for site specific testing and identification of the issues related to meeting perform-measuring. NUREG.CR-3038, Testsfor Evaluating Sitc3 ance objectives and technical requirements of 10 CFR for DisposalofLow Lc.r/ Radioactive IVaste, provides a de-Part 61, and finally, collecting data required by regulation scription of most of tac tests identified in Table 1. He and needed to support a complete and technically defen-U.S. Department of Energy Site Characterization Hand-sible license application. The QA program should be an book, DOE /LLW-67l', also provides information on integral part of the test program to ensure adequate plan-parameters and testi for characterizing an LLRW ning, equipment selection and use, training of personnel, disposal site-sample handling and storage, and records of testing.

Because of much diversity in materials,and conditions be-4 DOCUMENTATION OF tween many sites across the country, it ts tmpossible to list all the parameters required to characterize a site. Table 1 IsABORATORY OR FIELD TEST provides only a partial listing of parameters that charac-PROCEDURES terize an LLRW disposal site. NUREG-0902, Site Suit-ability, Sclection and Characteri:ation, provides detailed Testing procedures for characterizing an LLRW disposal guidance on all parameters required to characterize a dis',

site generally are classified into two eategories. He first posal site, including ecology, social economics, land use category would be described as standardized tests that and cultural resources, as well as those parameters listed have been developed by a standards-setting organization m Table 1.

such as ASTht.The second categoryof tests are those that have not been codified by a standards setting organization Section 5 provides guidance on qualifications and training but are nationally recognized and considered state of the for personnel conducting site characterization activitics.

art. Such tests are those recommended by Federal Gov-It is important to emphasize that characterization activi-crnment organizations such as the Army Corps of Engi.

tics-such as mapping, logging, sampling, testing, inter-neers, the Environmental Protection Agency, and the j

pretation, and analysis-be conducted by technically United States Geological Survey. He applicant may qualified personnel.

adapt tests or other guidance to site-specific conditions or to incorporate newer, more accurate or sensitive tech-The regulatory review of a license application against the niques. Regardless of the type of test conducted or requirements of 10 CFR Part 61 will determine that the whether the test is conducted in the field or laboratory, it NUREG-1383 2

U

r i

t Table 1 Testing and other information to characterise LLRW sites j

Standard Parameter method

• Formallmed guidance Existing data i

Air pressure ASTM Barometric observations Weather records

. Thermometric observations Air temperature Weather records Geologicalcriteria Anisotropy Permeabilities

)

Apparent velocity Tracer studies Atterberglimits ASTM CE l

Burial unit boundaries Plane surveying I

Collapse susceptibility CE Geological criteria Grain size data -

Compaction relation ASTM Consolidation relative CE 3

Dispersion Breakthrough curves Electrical resistivity Total salinity of soll Surface resistivity survey Borehole reistivity survey Specific conductance Prodibility CE

)

Agronomical criteria

]

Evapctranspiration Saporimetric or lysimetric observations Weather records -

Extended site boundary Technical review Tracer studies Flow direction Well data i

Frost heaving Ocological criteria.

Grain size data Gaseous constituents APHA ASTM j

Geomorphology Geological criteria Grain-size distribution CE i

ASTM Groundwater chemistry APHA EPA

.I ASTM 3

GS 1

Gas chromatography for organic I

materials 6See footnote at end of table.

I 3

NUREG-1383

'l 1

l j

Table 1 (Continaed)

Standard 1

~ Paranneler seethod*

Fannall ed gaidance Existing data Geological criteria Groundwater system and boundaries Hydraulic conductivities ASTM CE BR Pump tests Geological criteria Grain size data Welllogging Hydraulic potentials and Piezometric determination pressures Technical review Immediate site boundary Infiltration capacity ASTM Curve number estimation Saturation method Ion exchange capacity Mehlich method Geological criteria Uthology and soils Matcrial color ASTM Color chart method Material densities ASTM CE Gamma gamma logging Material radioactivity Borehole gamma survey Gamma spectrallogging ASTM DE Thermistor readings Material temperature Water temperature Standard deviation method l

Material variability parameter Range determination Detailed logging, sampling, and Material zone boundaries analysis Mineralogy and clay ASTM X ray diffraction mineralogy Petrography Monument and point NOAA 1

Planc surveying positions Control surveys and grids Platinum / hydrogen electrode Oxidation reduction potential t

Geological criteria _

Partition coefficients Batch leach testing Column test Geochemical criteria

'See footnote al end of tabic.

NUREG-1383 4

, c.-

..[

i -

Table 1 (Condneed)

Standard rasawler mothed*

FonanHaed seidance Existlag dets Penetration parameter ASD4 l

Instantaneous profile Permeability function l

Radioisotopic ratios Pore water age Stable isotope test Conductivity test.

}

Groundwater chemistry Porosities and void stio CE j

Acoustic logging '

f Nuclearlogging t

Geological criteria Weather records i

Precipitation Rain gauge observations Reboundladex CE Geotechnkal critena Geo!ogical criteria j

Recharge and discharge areas i

Rock classification AFIM Durability test Seismicvelocity Core logging indices Stream gauging '

Runoff Curve number estimation ASTM j

Seepage velocity Tracer studies i

Seismic velocity Surface survey

]

Borehole survey Shrinking swelling parameter AFIM Geological criteria Soll classification ASTM Soil taxonomy Textural method Sampleignition method Soil organics Soil pH and acidity AS'IM 11tration Soil solubles EPA APHA Specific gmvity AS'IM CE Storativity Pump test Neutronlogging Geological criteria Stratigraphy 1

Strength CE see km noie ni end or inbw, i

5

. NUREG-1383 i

l

Table 1 (Contissed)

Standard Parameter saethod' Formalised guidance Existlag data Structure Geological criteria Suction pressure function ASTM Suction pressures Tensiometric determination Psychrometric determination Porous element test Surface water chemistry Surface water system and Geological criteria boundaries Transmissivity Pump test Visual description ASTM Water content ASTM Water holding parameters Agronomic data Suction pressure function Water zone boundaries Borehole logging Water table measurements Water contents Wind speeds and directions Weather records Anemometer and vane measurements

'AS'IM = American Society of Testing and Materials; CE = Corps of Ensineen: APHA = American Public Health Association; EPA = Environ-mentalProtection Agency;OS = GeologicalSurvey;BR = Bureauof Reclamation;DE = Department of Energy;and NOAA = NationalOceanic and Atmospheric Admmistration is an absolute necessity that the procedures for conduct-step-byhed standards for conducting the teststep ins ing the selected test be in writing and clearly define how estabhs the test is to be conducted. For tests modified from acceptance criteria or instructions to evaluate the standard tests or commonly accepted tests or for tests e

developed for a specific site, the basis for the modification test results to ensure that either the field or labora-j and its use should be documented, tory test has been properly conducted recording date-e At the time oflicensing, the documented procedures and records to verify that work was performed in accordance identification of person performing the test l

e with the procedures will be the means to demonstrate as foun'd conditions a

that the tests were properly performed and the data col-lected are valid. At a minimum the test procedures should corrective actions performed,if any contain:

Where either field or laboratory tests are to be witnessed, a descript,on of the objectives the procedure should identify hnid points in the testing i

+

i sequence to permit wittsessing and documentation and test equipment to be used should include appropriat,e approval for the work to con-

+

tinue beyond the hold pomt.

prerequisites for performing the tests, including any o

special conditions to be used, any special equipment, A properly planned and implemented QA program will or any special calibration required to conduct the ensure that tests are planned and conducted as described tests above.

NUREG-1383 6

j l

]

5 QUALIFICATIONS AND with emphasis on first hand experience gained through

. TRAINING FOR PERSONNEL actual performance of these tests.

CONDUCTING SITE 6 STORAGE OF SI'TE CHARACTERIZATION CHARACTERIZATION DATA ACTIVITIES ne purpose of defining the storage procedures for data To ensure that the tests for characterizing an 11RW dis.

(including samples) collected during site characterization posal site are properly conducted, it is necessary for the is to minimize the possibility of damage or lowering the cpplicant to define the qualifications for the persons con-quality of the data as a result of corrosion, contamination, ducting these tests and to implement a training program deterioration, or physical damage from the time the data to assure an adequate number of personnel are available are collected.nis also will ensure that the data are avail.

to perform the required tests.

able at the time of licensing. ne applicant may elect to develop classification levels for items to be stored on the ne minimum capabilities that qualify personnel to per-basis of the environmental conditions under which the form a test should be specified in writing. ne document samples must be stored.

defining the qualifications of personnel performing the tests should include, as a minimum, the following infor.

Quality assurance procedures should provide for over.

mation:

view of the data collection and storage process to ensure that planned steps for collection and storage are followed employer's name consistently.

identification of person performing test Before storing field data, a written storage procedure tests personnel are qualified to perform should be prepared and appropriate personnel should be e

tramed in its use.The Q A procedures should include as a bases for qualification, including minimum:

records of education, experience, and training a description of the storage area results of qualification test, when appropriate a system for marking and identifying the data a method for verifying that the data stored is in results of periodic evaluations

+

ement with the documentation transmitting the results of physical examinations, when required d

date of certification and date of expiration of certifi-e a method for maintaining control of the data cation identification of special conditions (e.g., tempera-Properly conducted tests performed by qualified person-ture, humidity, and vapor proof barriers) required nel will provide the basis for the applicant to defend the for storage of the data validity of the information in a license application if chal.

a description of the housekeeping practices neces.

lenged during a licensing review or hearmg.

sary to maintain the facility where data samples are The training program also should include, as a minimum, procedures or measures to prevent rodents and the following information:

other small animals from entering indoor storage ar-provisions about the technical objectives of the proj.

cas to minimize possible contamination and damage cet for personnel performing the tests of stored material periodic inspection procedures to ensure the storage the codes and standards that are to be used areas are being maintained in accordance with pro-the current status of the procedures developed for cedures umque tests 7 RECORDS FOR SITE te ality assurance elements that are to be em-CHARACTERIZATION 1

ACTIVITIES Where the need for formal training programs are deter-mined for tests, such training activities should be con.

The purpose of maintaining QA records is to furnish evi-ducted as necessary to qualify personnel who perform dence that site chameterization activities affecting quality these tests. On the-job participation should be included, have been properly performed. OA records should bc 7

NUREG-1383

t Records should be firmly attached in binders or considered completed documents that furnh.h evidence of the quality of the test or activity. Sarnples, such as geo.

placed in folders or envelopes for storage in stcel file Icgic, hydrologic, and environmental, that are required to cabincts or in containers on shelving.

be maintained are considered QA records.*Ihe applicant should assure identification, storage, maintenance.

Provisions should be made for special processed rec-traceability, legibility, and retrievability of QA reportis.

ords (e.g., radiographs, photographs, negatives, rm-crofilm, and magnetic material) to prevent damage Records that furnish evidence of site characterization ac, from excessive light, stacking, electromagnetic tivities affecting quality include, but are not limited to, fields, temperature, and humidity.

operating logs; results of reviews, inspections, tests, and Rules should be established governing access to and audits; monitoring of work performanec; and material control of records.

analyscs. ~lhe records also should include closely related Methods should be established for filing supplemen-data such as qualification of personnel, procedures, and cquipment.

tal information and disposing of superseded records.

[

Inspection and test records should, at a minimum, identify 8 BIBLIOGRAPHY the inspector or data recorder, the type of observation, the results, the acceptability, and the corrective action U.S. Department of Encrgy, DGE/11W-67r Site Chcr-taken, with any deficiencies noted. In addition, these rec-acterization Handbook. Was.hington, DC, Junc 1988, ords should include all rclated QA actrvitics.*lhese activi-tics include review of nonconformance reports. corrective U.S. Government Printing Office, Code o/FederalRegula-g action reports, audit and surveillance reports, inspection tions. Title 10,

• Energy," Chapter 1. U.S. Nuclear llegu.

reports, plans, procedurcs, and other documents such as latory Commission, Parts 0 to 199, Washington, DC, re-telecons, specifications, technical data, books. maps, pho-vised annually.

tographs, data shects, and magnetic media ned otact ma-terials that provide data and document quahty, reprdless U.S. Nuclear Regulatory Commission, NUREG-1199, of the physical forrn er *.haracteristic. A " completed rec.

Revision 1, Standard Format and Content ofa License Ap.

ord"is a document that s ill either receive no more entrics plicationfor a Low LevelRadioactive IVaste Disposal Facil-or whose revision would rormally consist of reissuance of ity, Washington, DC, January 1988.

the document; it is signed md dated by the originator and, as applicable, by personnel authorized to approve the

-, NUREG-0902, Site Suitability, Selection and Char-document.

acterization. April 1982.

(

llound notebooks should be th0 primary record document for field survey work, pr oviding a chronology of sigmficant

-,NUREG-1200, Revision 1.StandardReviewPlanfor the Review of a License A plicationfor a low LctrlRadio-I events for the work. All references to the literature, pro.

cedures, or other documents should be complete and active traste Disposal facility, January 1988.

traccable to each document and the specific section or pages identified. The following requirements also apply:

-, NUREG-1293, QuaSty Assurance Guidance for Low Lewi Radioacuve IVaste Desposal Facility, January Pages should be numbered consecutively and kept 1989-i intact. (No page shall be left blank or removed from the notcbook.)

-, NUREG/CR-2700, Parameters for Characterizing

?

Sites for Disposal of Low-Lewi Radioactin Waste, May i

Each pagc should be sign (d and dated by the person 1982.

makmg the entry.

Records should be stored in a manner to preclude dete.

-,NUREG/CR-3038,TesteforEvaluatingSitesfotDis-t rioration of the records. 'Ihc following requirements posal oflow-Lewl Radioactin IVaste. December 1982, apply:

American National Standards Institutc/American Society Provisions should be made in the storage arrange-of Mechanical Engineers, ANSI /ASMB NOA-1-1986, i

ment to prevent damagc from moisture, tempcra-Quality Assurance Program Requirementsfor Nuclear Facili-ture, fire, and pressure.

ties. New York.

NUREG-1383 8

l

..~

i l

APPENDIX A

SUMMARY

OF PUBLIC COMMENTS ON DRAFT TECHNICAL POSITION STATEMENT (FEDERAL REGISTER, VOL. 54, NO.- 237, DECEMBER 12,1989, t

54 FR 51033) i t

i i

l l

I

?

r i

Appendix A 9

NUREG-1383 i

^

m e-ww'-.-w--*wM swf "m'N m.

m

Commenter M40r Comment NRC's Response

' John Greenberg ne document should emphasize that NRC agrees, and the document has been Brattleboro, VT the purpose of the site characterization revised to better emphasize the purpose process is to ensure the protection of of site characterization.

the health and safety of the public in l

developing a low level waste disposal facility.

U.S. Department of De commenter discussed the Department The purpose of NUREG-1383 is to i

theInterior Officeof of Interior's policy regarding testing at provide guidance on the application of Envi:enmental Affairs, sites of low level and toxic waste disposal.

quality assurance principles to site Washington, DC characterization. His quality assurance j

document is not the appropriate document to communicate the policies of other agencies.

Roland Cote Inconsistencies exist between this NUREG - The NRC agrees that there is some Kennewick, WA and related NUREGs although the com-inconsistency between NUREG-1383, menter strongly supports these documents.

NUREG-1293, and Chapter 9 of J

NUREG-1199 and NUREG-1200. The NRC is currently reviewing and evaluating all these documents for consistency and for consistency with 10 CFR Part 61, I

i i

Appendix A 11 NUREG-1383 i

1

m.._.

tent some 35 U,8.10UCLE AR Lt&ULf TORY C0emsetteoes

1. REPoR1 Numet h

."ni b e.

.'* IE1"".".**"h*,,7 ""'

l am 8= '

BISUOORAPH6C DATA SHEET ts we,wew

w.,

.titLa Amo sustista NUREG-1383 l

Guidance on the Application of Quality Assurance for 3.

out,t,o,1,U,t,,,,to Characterizing a Low-Level Radioactive Waste Disposal Site j

.o i.

na October 1990 l

i Final Report

.. nw oR omaat =UMet a

s. AUTHOR ($)

4. tVPt oF MtPoRT Clayton L. Pittiglio, Jr.

Technical i

R. John Starmer r.Ptnioo Covinto,,

Dale Hedges yegaggmzuio= - =Aut A=o moontss ty-c.,,

,% us w e:

aP

.,=,w Division of Low-Level Waste Management and Decommissioning r

Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555 t,sPoggoAnization -==i A=o Aponess in-c.

w.

.c-o,

%,a

,r See item 8. above.

1

10. SUPPLEME NT ARY NOTES i t. Aast n ACT tm.we., i

.i This document provides guidance to an applicant on meeting the Quality Control (QC) requirements of 10 CFR Part 61.12 for a Low-level Waste (LLW) disposal facility.

The QC requirements combined with the requirements for managerial controls and audits are the basis for developing a Quality Assurance (QA) program and for the guidance provided herein. The document specifically established QA guidance for site characterization activities necessary to meet the performance objectives of 10 CFR Part 61 and to limit exposure to or release of. radioactivity.

i

12. KE y wORoVDESCRIPioRS ttee.we wan=ne m.

e -

...re.w see n.wi.s is. AvanasiuTv sTaTuurwT l

Unlimited quality assurance ie.uc a rveu = ica -

quality control tr w low-level waste Unclassified or

,wu Unclassified I

ns. NUMSER of PAQt$

18. PRICE 1

Nfic P08 48 3M 0406 m

g.

(

I i

l i

I I

i l.

l i

i

+

i l

l I

i I.

1

+

l l

t 1

h l1 I

I t

I l

t

l -

J t

t i

.i N

THIS DOCUMENT WAS, PRINTED USING RECYCLED PAPER.

c-J

'i i 1

1 E5I"7,*h'y, E N

NUCLEAR C i T RY MMIESION

- WASHINGTON, D.C. 20666 OFFICIAL SU$1NE88..

PENALTY FOR PRIVATE USE,6300

.l 120555139531 1 1AN

.N}y" hot $kPUBLICATIONSSVCS TPS POR-NUREG OC 2 0W h[khfNGTON s

la N

lli 11

)I P.

.ll i

a

.l I