ML20127C640

Final, Completion Review Rept for Remedial Action of Green River,Ut U Mill Tailings Site

ML20127C640
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Issue date:	07/31/1992
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
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ML20127C638	List: ML20127C635 ML20127C640
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REF-WM-68 NUDOCS 9209100006
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0, FINAL COMPLETION REV!EW REPORT for the REMEDIAL ACTION of the  :

GREEN RIVER, UTAH

. URANIUM MILL TAILINGS SITE July 1992 Division of Low-Level Waste Management and Decommissioning U. S. Nuclear Regulatory Commission i

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FINAL COMPLETION REVIEW REPORT for the Remedial Action

.at the Green River Uranium-Mill Tailings Site Green River. Utah U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards Division of low Level Waste Management and Decommissioning Ju'iy 1992 (re-issued)

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TABLE OF CONTENTS Sectton E_a.ge INTRODUCTION .. . .................... .... . 1

1.0 BACKGROUND

. . . . . . . . . . . . . . . . . . . . . . . , . . . . . I 1.1 VMTRCA . . . . . . . .................... 1 1.2 Concurrence Process for the Selection of DOE's Remedial Actions 1 1.3 Concurrence Process for the Performance of DOE's Remedial Actions 2 1.4 Green River Site . . . . . . . . . . . . . . . ... .... 2 1.5 Completion Review Report (CRR) Graanization . ....... 4 2.0 ANALYSIS OF DOE REMEDIAL ACTION PERFORMANCE ......... 4 2.1 Previous Actions . . . . . . . . . . . . . . . . . . . . . . . . .. 4 2.2 Review of Remedial Action Performance ............ 5 2.2.1 Geotechnical Engineering Review Results ..... .. 5 2.2.2 Surface Water Hydrology and Erosion Protection Review Results ..................... 6 2.2.3 Site Cleanup Review Results ............. 7 2.2.4 Water Resources Protection ........... .. 8 3.0

SUMMARY

. . . . ........ .............. .. 9

4.0 REFERENCES

........,,................. 9 APPENDIX A , . . . . . . . ................. ..... A-1 APPENDIX B ... .

........................... B-1 APPENDIX C ... .... ........... ....., ,..... C-1 l

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FINAL CRR July 15, 1992 (re-issued) i

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LIST-0F' FIGURES

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1 GREEN RIVER, UTAH COMPLETJON REVIEW REPORT INTRODUCTION The Green River site is one of the 24 abandoned uranium mill tailings sites to be remediated by the Department of Energy (DOE) under the Uranium Mill Tailings' Radiation Control Act 4978 (UMTRCA). UMTRCA requires, pursuant to Section 104(f)(1), that the Nuclear Regulatory Commission (NRC) concur with the DOE's determination that the remedial action has been properly completed.

This Completion Review Report (CRR) documents the NRC staff's basis for its

-concurrence decision with respect to DOE's Certification Report for the completion of the Green River site (DOE,1990).

1,0 BACKGROUND l.1 UMTFCA Title 1 of UMTRCA provides for remedial action at abandoned uranium mill tailings sites and associated vicinity properties. The purpose.of this legislation is. to protect the public health and safety and the environment from radiological and non-radiological hazards associated -

with the radioactive materials at these sites. ,

UMTRCA directs' DOE to select and perform remedial actions at 24 abandoned uranium mill tailings sites.to ensure compliance with tne 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 DOE to obtain NRC's concurrence with DOE's selection and performance of the remedial

-actions. Following completion of the remedial actions, UMTRCA authorizes NRC to license the long-term custody, maintenance, and monitoring of the disposal sites to ensure continued protection of the public health and safety and the environment. Appendix C includes a more detailed discussion of this legislation. -

1.2 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)

(DOE, 1989a; 1989b; 1988; 1987a; 1987b; 1987c). The RAP describes the series of activities and presents the design 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.

In accordance with UMTRCA Section 108(a)(1), the NRC staff reviews and cont s with the RAP, and any subsequent modifications. By its review and concurrence in the remedial action selection, the NRC staff concludes that the planned remedial actions will comply with EPA's applicable standards in 40 CFR 192, Subparts A, B, and C. The basis for the NRC. staff's concurrence in DOE's selection of remedial action at the Green River site is documented in a Technical Evaluation Report (TER) issued in March, 1990 (NRC, 1990b).

FINAL CRR July 15, 1992 (re-issued) 1 m

_.f-1.3 Concurrence Process for the Performance of DOE's Remedial Actioni The remedial-' action work is performed by DOE contractors under Federal per~urement regulations. During construction, DOE inspects and dc.uments activities in accordance with the UMTRA Project Quality Assurance Plan, the Remedial Action Inspection Plan (RAIP)' and the RAP. ,

In addition, the NRC staff conducts independent inspections during construction.

-Upon the completion aof the remedial action, DOE compiles construction records and prepares a completion report to. document that' remedial actions were performed in accordance with the RAP or RAP modifications, and:the RAIP. Based on this infonaation, DOE certifies that all provisions of the RAP have been satisfied and, therefore, that the remedial actions comply with the applicable EPA standards in 40 CFR 192.

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Basedion its review of D0E's documentation, and on its site visits and observations, NRC makes a concurrence decision with regard to DOE's remedial action completion determination for the sites, and then

documents the basis for this concurrence decision in the CRR. By its review and concurrence in the remedial action performance, the NRC staff concludes that the remedial action has been completed in accordance with the concurred-in design. NRC's concurrence with DOE's completion ,

determination fulfills the Commission's responsibility under UMTRCA

-Section 104(f)(1) to concur with DOE's determination of completion of remedial action.

1.4 Green River Site The Green River' uranium mill tailings site is located in Grand County, Utah, approximately one mile southwest of the city of Green River.

Prior to_ remedial action, the uranium mill tailings on the designated

- site and ;;the windblown contaminated materials totalled approximately 382,000 cubic yards-(cys) (See Figure 1.1)

The remedial action performed-by DOE consisted of the following major activities:

1. Movement of all contaminated materials (uranium mill tailings, windblown and' waterborne contaminants, and demolition debris -from

.the1 mill building addition, office building addition, and roaster

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building) to a disposal embankment on a terrace located above

-Brown's: Wash;-

2. Stabilization of contaminated material in the embankment constructed primarily below the existing ground surface; placement and compaction of tailings and windblown contaminated material on

-top of a six-foot thick buffer layer of select soil fill; and FINAL CRR July 15, 1992 (re-issued) 2

1 FIGURE 1.1 Pre Remedial Action Site Conditions

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3. Coverage of the embankment with-1) a three-foot-thick infiltration / radon barrier of compacted silty clay, amended witn a six percent by weight sodium bentonite; and 2) an erosion protection layer corsisting of bedding material, and Type A and Type B riprap. The cover has been designed to ensure long-term stability, reduce radon emissions and protect ground and surface water.

The NRC was not involved with the actual remedial action activities, which were performed by +he DOE contractors. However, DOE obtained NRC concurrence with the site construction design and significant modifications thereof. NRC also performed sit's inspections to monitor the progress of the construction activity (see Appendix A).

1.5 Completion Review Report (CRR) Oraanization ~

The purpose of this final CRR is to documint the NRC staff review of DOE's-Green River Completion Report. Section 2 of this report presents the analysis of remedial action construction. This section is organized by technical discipline and addresses geotechnical engineering, surface water hydrology, groundwater hydrology, and radiation protection aspects of the remedial action. Appendix A provides a listing of all NRC staff visits to and inspections of the Green River site. Appendix B provides a table that cross-checks the requirements of the RAP /RAIP as concurred in by the NRC staff with DOE's Completion Report document ition.

Appendix C presents a detailed description of the requirements of UMTRCA and.the resulting phased process of the UMTRA Project.

2.0 ANALYSIS OF DOE REMEDIAL ACTION PERFORMANCE 2.1 Previous Actions The NRC staff, based on its review of the RAP and RAP modifications, concurred that the remedial action as designed would meet the applicable -

EPA standards. This concurrence was based on technical findings that there is reasonable assurance that the selection of the remedial action gwould 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 health

_ physics and radiation protection, geotechnical engineering, surface water hydrology, ground-water hydrology, and geology. The NRC gave a conditional concurrence with the RAP on March 22, 1990 (NRC, 1990b) and concurrence with RAP Modificaticn No. 2 (DOE, 1991b) on August 7, 1991

-(see Section 1.2.4). The NRC staff. also reviewed and concurred with DOE's. Remedial Action Inspection Plan (Rev D) on March 20, 1990 (NRC, 1990a). This concurrence was-the NRC staff's agreement that the quality control program, i.e., the plan for testing and inspections, was acceptable for the Green River site. The NRC, however, did not concur with RAP modification No.1 (D0E,1991a), which proposed the removal of the neutron protes.

FINAL CRR July 15, 1992 (re-issued) 4 l

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2.2- Review of Remedial Action Performance The NRC staff's primary ' objective in reviewing DOE's certification of remedial action completion is to determine whether the remedial actions have been performed in a manner consistent with specifications provided in the RAP, rap modifications, and the RAIP, and if not, that deviations te 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 easito' data and record:, and review of DOE Site Audit Reports. The following sections present the results of the review of remedial action parformance-by individual technical discipline. Note that for the Gree, River remedial action completion review, the pertinent technical disciplines are 1) geotechnical engineering, 2) surface water nydrology and erosion protection, 3) radiation protection, and 4) groundwater hydrology. Groundwater cleanup is not addressed at this time, since DOE has elected to postpone any groundwater remedial action activities to a separate-phase of the project.

22.1 Geotechnical Engineering Review Results NRC staff reviewed the Green River draft Completion Report (CR) to determine whether the geotechnical engineering aspects of the remedial action were completed in accordance with (1) the applicable construction specifications in the RAP and design (DOE 1989a, 1987c),-(2) all the appropriate RAP modifications (00E 1989b, 1988),-and (3) the RAIP (MK-Ferguson 1990). Items reviewed include descriptions of constru'ction operations, as-built drawings, laboratory and field testing data, and 00E Quality Assurance Audits. In addition, the review was based on staff observations and review of records during onsite inspections.

During its review, the NRC staff noted the following:

1. Appropriate tests (gradation) and inspections were performed to assure that the proper type of material was placed for each feature of the construction. The loose thickness of the-lifts was verified by DOE periodically to ensure compliance with the specifications for that material.

Placement and compaction operations were routinely inspected and tested'to verify that the moisture and density requirements were met and that the soil moisture was uniform throughout the compacted lifts.

2. Documented- results of laboratory and field testing indicate that they were conducted in accordance with acceptable procedures by trained and qualified personnel.

j. 3. The CR shows that the frequencies of material testing and l

inspection comply with the frequencies specified in the RAIP l

FINAL CRR July 15, 1992 (re-issued) 5 i

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4. As-built drawings indicate that the completed remedial action is consistent with the NRC-approved design. -

E Details of the staff's geotechnical engineering review, t.hich provide the basis for the above statements, are included in the attached Appendix B. The NRC staff concurs that the remedial action at the Green River UMTRA project has been adequately completed with respect to geotechnical engineering.

2.2.2 Surface Water Hydrology and Erosion Protection Review Results NRC staff reviewed the rface water hydrology and erosion protection aspects of remedial actions at Green River to ensure -

that they were constructed in accordance with the applicable -

construction specifications as stipulated in the RAP / design, RAP modifications, and RAIP. 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 observctions of the remedial actions and reviews of records and testing during NRC onsite inspections (See Appendix A).

The remedial action design featured riprap erosion protection in several cpecific areas, including the top and side slopes of the encapsulation cell and in the apron surrounding the cell . The erosion protection was designed to prevent long-term erosion and gullying of the cell cover.

The NRC staff reviewed each of these features and determined that their testing, placement, and configuration complied with specifications in the RAP, RAP modifications, and the RAIP. The review was partially based on NRC staff observations and review of onsite records during the remedial actions, as well as assessment of the recults presented in the DOE Completion Report.

During its review, the NRC staff noted the following:

1. Tests (cradation and durability) and inspections were performed by DOE to assure that erosion protection materials for the cell were properly selected. The review of the documentation indicated that placement of materials was routinely inspected by DOE to assure-that the rock size and ,

gradation specifications were met. Likewise, the thickness of each rock layer was verified periodically by DOE or its agen' to ensure compliance with the specifications for the ,

particular type of material.

2. Laboratory and field testing was documented by DOE in accordance with specified test procedures.

3. Testing and inspection frequencies for materials used at the flNAL CRR July 15, 1992 (re-issued) 6 l

site for erosion protection were documented by DOE as complying with the frequencies specified in the RAIP.

Based on NRC staff observations and review of onsite records during the remedial actions, as well as assessment of the verification results presented in the DOE Completion Report, the NRC staff concludes that the required durability and gradation tests were performed during the remedial action. The riprap is of adequate quality and has been acceptably placed. The NRC staff concurs that remedial action has been adnquately completed at Green River with respect to erosion protection.

2.2.3 Site Cleanup Review Results G" The NRC staff reviewed the radiation protection aspects of remedial actions at Green River to ensure that cleanup of residual radioactive materials was performed in accordance with specifications in the RAP and RAP modifications, RAIP, and the

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final design. Areas of review included contaminated material '

excavation, verification of cleanup, laboratory and field testing, and quality assurance audits. In addition, NRC geotechnical engineering staff reviewed the design and construction of the disposal cell cover to ensure compliance with the RAP design for limiting radon releases, and thus with the EPA standards (See Section 2.2.1). Specific discussion of the details of this review can be found in Appendix B. The review was based on NRC staff assessment of the results presented in the DOE Completion Report.

During its review of the processing site cleanup aspects of the remedial action completion documentation, the NRC staf f noted the following:

1. The techniques, which DOE states to have used for verifying radiologici cleanup at the processing site, complied with DOE's summary protocols.

2. The radiological survey records support compliance with EPA's cleanup standards in Subpart B of 40 CFR Part 192.

This includes the soil Ra-226 concentration and the interior gamma and radon progeny levels for habitable buildings on the site.

3. The surface alpha contaminations of the three remaining buildings, as documented in Appendix J of the CR, were reduced to the cleanup levels designated in the PAP.

Based on the above observations, the NRC staff concludes that the remedial action at the Green River UMTRA project processing site cleanup meets applicable standards.

FINAL CRR July 15, 1992 (re-issued) 7 i

2.2.4 Water Resources Protection The NRC staff reviewed the construction elements and the ground-water and unsaturated moisture monitoring performed during the remedial action, that relate to ground-water resource protection.

This review is based on NRC staff assessment of verified results preser.ted in the DOE Completion Report. '

During its review, the NRC staff noted the following:

1. Ground-water characterization wells located within the boundaries of the disposal cell and wells located outside of the disposal cell (which were not designated for continued monitoring) have been abandoned and grouted.

i. A buffer layer (six feet in thickness) has been installed at the base of the disposal cell to retard contaminant movement toward the ground water.

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3. Compacted windblown tallings ('contan.: nates') were placed .

above the buf fer layer, but b=1:w her tailings.

4. Four neutron access holes were installed for monitoring moisture c ntent within the tailings and buffer layer at different depths. No measurements were provided in the Completion Report. Subsequent measurement schedules should be provided in the Long-Term Surveillance Plan.

5. Arsenic, lead, and methylene chloride were added to the hazardous constituents list for ground-water monitoring, duriag the RAP review and concurrence process.

Subsequently, DOE submitted a RAP modification request to delete methylene chloride from the list. The NRC staff has agreed with the request to delete methylene chloride from ~

the constituents list; however, toluene has been detected in the tailings fluid and identified in ground-water monitoring results. DOE provided an adequate rai 2unale for not including the toluene as a hazardous constituent,

6. Quarterly monitoring results from wells 171, 172, 173, 174 175, 176, 177, 178, 179, 180, and 813 wer; provided in -

Appendix K of the CR and were used to finalize the concentration limits for the post closure ground-water monitoring.

i Details of the staff's ground-vater performance review, which crovide the basis for the above observations, are included in the attached Appendix B. The NRC staff concludes that the ground-water protection aspects of the remedial action were adequately completed in accordance with the design and procedures identified in the RAP, RAP modifications, and RAIP.

'INAL CRR

.uly 15, 1992 (re-issued) S

3.0

SUMMARY

The hRC staff reviewed geotechnical engineering, surface water hydrology, radiation protection, and hydrologic aspects of the remedial action performed at the uranium mill tailings site in Green River. The purpose of this review was to determine whether DOE had perforr.ed remedial actions at the site in accordance with specifications in the PAP, RAP modifications, and other supporting aroject documents, and thus with the EPA standards in 40 CFR Part 192, Subpar is A-C. Based on our review of the final Completion Repcrt and on

observations during pericaic site inspections, the llRC staff concurs that the Department of Energy (DDE) has performed remedial action at the Green River site in accordance with the approved plans and specifications and that t.s action complies with the Environmental Protection Agency's s' Mards in 40 CFR 4

Part 192, Subparts A-C. With the exception of selection and ,arformance of a groundwater cleanup program, remedial actions are complete for the Green River site. DOE har proposed deferral of this aspect of the remedial action at this

' time, and plans to handle this as part of a separate groundwater restoration program. The NRC staff considers DOE's deferral to be acceptable.

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4.0 REFERENCES

s

' MK-Ferguson,1990, "UMTRA Project - Green River, Utah, Remedial Action Inspection Plan, Revision D," February 9, 1990.  !

U. S. Department of Energy,1991a, " RAP Modification 1, Remedial Action Plan and Site Conceptual Design for Stabilization of the inactive Uranium Mill Tallings Site at Green River, Utah, January 16, 1991.

...., 1991b, " RAP Modification No. 2, Remedial Action Plan and Site Conceptual Design -for Stabilization of the inactive Uranium Mill Tailings Site at Green River, Utah, June 18, 1991.

...., 199C, " Draft Completion Report. Green River, Utah," Vol. 1-V. ,

-....,1989a, " Remedial Action Plan and Site Conceptual Design for Stabilization of the Inactive Uranium Mill Tailings site at Green River, Utah, December, 1985,

....,1989b, " Uranium Mill Tailings Remedial Action Project (UMTRAP),

Green River, Utah - Addendum 2," J auary, 1989.

...., 1988, " Uranium Mill Tailings Remedial Action Project (UMTRAP). I Green River, Utah - Addendum 1," fe!'ruary,1988.

...., 1987a, " Uranium Mill Tailings Remedial Action Project (UMTRCA),

Green River, Utah f Information for Bidders, December,1987.

....,1987b, " Green River Draf t Remedial Action Plan and Site Conceptual Design; geology, seismicity, and geomorphology," supplements FINAL. CRR

- July 15, 1992 (re-issued)- 9 L ,

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• C submitted as enclosures to Anderson, J.R., DOE to Martin, D.E.,

March 13, 1987.

... , 1987c, " Uranium Mill Tailings Remedial Action Project (UMTRCA).

Green River, Utah - Desigr Calculations, November,1987.

U.S. Nuclear Regulatory Commission, 1990a, Lohaus, P.H. letter to Matthew,- M., U.S. Department of Energy, providing concurrence on the RAIP, March 20, 1990.

...., 1990b, Lohaus, P.H. letter to Matthew, M., U.S. Department of Energy, transmitting the final TER and providing conditional concurrence on the RAP March 22, 1990.

...., 1991a, Surmeier, J.J. letter to Matthew, M., U.S. Department of inergy, providing concurrence on RAP Modification No. 2.,

August 7, 1991. -

...., 1991b, Surmeier, J.J. letter to Matthew, fi. , U.S. Department of  ?

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Energy, providing non-concurrence on RAP Modification No. 1, L February 7, 1991.

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FINAL CRR July 15, 1992 (re-issued) .10

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NRC SITE VISITS TO THE l GREEN RIVER UMTRA PROJECT SITE t

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Appendix A  !

NRC Site Visits to the Green River UMTRA Project Site l

. QAI[ STAFF / DISCIPLINE EMRPQS[ ,

10/1/86 J. Grimm /geclogy. Part of multiple site M. Haisfield/ project management tour; observation of

• T. Johnson / surf hydrology-erosion site characteristics i S. Smykowski/geotechnical M.-Young / groundwater .

S. Bilhorr/ project management '

-4/28/87 J. Grimm / geology Resolution of geological  :

issues (dRAP review) ,

- 6/8/87 M. Young / groundwater Resolution of  !

J. Starmer/ management hydrological issues '

K. Westbrook/ geology 8/2/88 S. Wastler/ project management Part of multisle site J. Grimm / geology tour; observation of L. Deering/ hydrology site characteristics

~ 6/12/89

- D. Cillen/geotechnical engineer Routine construction  ;

T. Johnson / surf hyurology-erosion inspection / visit M. Weber / hydrology borrow areas

- fi. Fliegel/ management 10/11/89 T. Johnson / surf hydrology-erosion Construction visit  :

G. Konwinski/ hydrology

, , 5/1/90 D.-Gillen/geotechnical engineer Final site' inspection A. Fan / hydrology T. Johnson / surf hydrology-erosion

-J. Gilray/ quality assurance r;

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APPENDIX B:

DETAILED COMPARIS0fl 0F DESIGf1 SPECIFICATIONS .;

WITH COMPLETED REMEDIAL ACTIONS PERFORMED AT GREEN RIVER OMTRA PROJECT SITE FINAL-CRR J' July;15. 1992 (re-issued) 3-i '

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• t NRC STAFF REVJEW OF DOE's.YERIFICATION OF REME01h_L ACT10_N_ PLAN ACllyJllLS <

Site: Green River, Utah Reviewer: Banad Jagannath/ Dan Rom  !

RAP FEATURE: 1. Type A Select fill, Tailings / Contaminated Material '

A. CONFIGURAllQff RAP Reauirement *

(1) location  ;

The disposal cell is approximately 500 feet south of Brown's Wash, f and 70 feet above the Brown's Wash flood plain. (final RAP Executive Summary)

(2) Design Feature '

- Excavation for the disposal cell down to el. 4098 ft., about 17 ft. into bedrock.

- 6 ft. thick buffer layer (Type A Select Fill) between the bedrock '

foundation and contaminated materials.

- Embankment:

Slope SH:lV  !

Embankment Top el. 4165.0 ft. L i

Determination 1

(1) 'The Completion Report (CR) states the actual distance to be 600'

.aet.

(2) As-built' drawing GRN-PS-10-0517 indicates the bottom of excavation ,

to be el. 4098 ft.

As-built drawing GRN-PS-10-0517 indicates the thickness of the buffer layer above the foundation bedrock to be 6 feet.

As-built drawing GRN-PS-10-0517 indicates the side slope were 5H:lV, as per design,=and that-the embankment top was at el. 4180.97, which is higher than the design elevation:in the RAP. Since the as-built slope geometry did not match the design, DOE was requested to verify-L that.the as-built slopes were stable. In response to NRC's question, DOE stated that the elevation change was to accommodate additional contaminated material-(381,761 cyd instead of 200,000 cyd-estimated in d6 sign). DOE performed additional-stability calculations which verified that stability considerations would be met:with the'as-built geometry, which addressed NRC's concerns '

satisfactorily. <

. FINAL CRR

' July 15, 1992~(re-issued) B-2 ,

6

j tRG_STAFE..R_EVIEW or DOE'S VERiflCAT1.0N Of REME01AL ACTION PLAN ACTIVlljl5 l i

Site: Green River, Utah Reviewer: Banad Jagannath/ Dan Rom  ;

RAP FEATURE: 1. Type A Select fill. Tailings / Contaminated Material  !

i B. Pl ACEigl '

RAP Rehirement (1) Material

- Type A Select fill Material: Soil from foundation excavation but  !

should not contain more than 5 % of combined particles larger than '

one-inch and excavated bedrock particles. (Spec. page 02200-8 & 27; RAIP Section 6.2.2, one gradation test per 2000 cyd)

- Contuminated Materials: No requirements except it should be -!

contaminated material  !

--(2); Lift Thickness

- 12" loose-(Sper.. pg 02200-20).

~0)- Compaction ,

Density and Moisture control

- Typo A Select Fill: 95 % of maximum dry density determined by ASTM D698. Test; compaction density.to be verified by at least one -

test per every 1,000cyd of material.placed (Spec. page 02200- 26).

Placement moisture content.of zero to four percent below the optimum '

moisture content determined in ASTM D698 test. (Spec. 02200-23. 26

- &-28;-RAIP Section 6.1.4,6.1.5)

- Tailings Contaminated Materials: 90 % of maximum dry density tetermined by ASTM D698 Test. Trial compaction on first four lifts

~

and first-1~,000 cyd of material to establish the compaction procedures including the number.of passes and equip ent to be used for both windblown / vicinity property material and tailings material that would result in complying.with the specified density

-requirements. Production compaction to comply with the-established procedure. Also, density to be verified'by 12sts at a frequency of ,

w one test per 6,000 cyd of compacted material. Placerient moisture content 1shJuld be drier than 3 % below optimum moisture content idetermined by ASTM D698 test-and the average volumetric moisture .

content should be less than' 5 % by volume for tailings and-10.5 % by volume for windblown.and vicinity property materials. (Spec pg. +

02200- 22<.23, 27;- RAIP Rev. O Section 6.l.4, 6.1.5.-6.4.5).

FINAL CRR:

July-15,1992.(re-issued)' B-3 i

v +,,a <,--w. , w,-- .-e,,..-- ,-.,;.,, , . , < , , , , , - - . , , ,-n. , -.-

URC STAFF RE11EW OF DOE'S VE91FICAT10N OF REMEDIAL ACTION PLAN ACTIVITl[1 Site: Green River, Utah Reviewer: Banad Jagannath/ Dan Rom RAP FEATURE: 1. Type A Select Fill Tailings / Contaminated Material Determinatio.n (1) Material

- CR states' that gradation of Type A Fill Material was tested by 39 tests, anc all tests passed the gradation specification. The testing frequency was one test per 1,342 cyd of material against a Spec /RAIP requirement of one test per 2,000 cyd-of material. _

Although tests were not_ performed at exact intervals, efforts were made to assure that representative +ests were taken throughout the course _of placement.

-- No gradation recuirement for contaminated material.

(2) Lift-Thickness

.CR states that loose thickness of each lift was 12 inches or less

-(CR, Vol II, Appendix E, Type A Select Fill, page 1; Contaminated Materials, .page 3)

(3)' Compaction Type A Select Fill

- Average percent-compaction obtained was 98.5% of maximum dry density determined by ASTM 0698. -This was verified by 83 field density tests for-a total-of 52,339 cyd of-material, resulting in a test frequency lof I _ test for every 631 cyd of material placed.

Spec /RAIP requires one test for every 1,000 cyd of materials placed.

Efforts were made to test at regular intervals; however, it is not implied that tests were.run every 631 cyd.

/ - Nine_ maximum Proctor density determinations'(ASTM 0698) were made resulting in a . test frequency of 1 test per 5,815 cyd of material

-placed.

RAIP: requires one such test for every 15,000 cyd of i material placed. Tests were performed when material characteristics were believed to have changed from previous values.

- Seventeen one-point Proctor density tests were made for a total of

'52,339 cyd of material <(83 field density tests)-, resulting-in a test-

' frequency _of'one test for every 4.9 field density determinations.

- RAIP requires one such test for every five field density -

determinations.

FINAL CRR July 15,- 1992 (re-issued) B-4 1

H

HRC STAFF REVIEW OF DOE'S VERIFICATION OF REMEDIAL ACTION PLAN A.[TIVITl[S Site: Green River, Utah' Revtewer: Banad Jagannath/ Dan Rom kP7EiUkE$ii[pekSe5eI[tliiikaliin[s/Co[taminated5ateria5

- Fourteen density determinations by sand cone test method and 66 density determinations by nuclear density n.ethod resulted in correlttion test frequency of one sand cone test for every 4.7 nuclear density tests. RAIP requires one sand cone correlation test for every ten nuclear-density tests.

- Eighty-three moisture content tests were performed during placement of 52,339 cyd of material, which resulted in one test for every 631 cyd of material placed. RAIP requires one test for every

,000 cyd of material. placed. The average placement moisture content was 1.5% less than the optimum moisture content. RAIP

-required the placement moisture content to be zero to four percent less than the optimum moisture content.

I I

- Thirty-three moisture content determinations were by microwave j mhod, and there were 6 oven dried moisture content correlation 1 tests resulting-_in one correlation test for every 5.5 microwave i method determinations.- RAIP requires:one correlation test for every '

10 microwave method determinations.  !

(CR, Vol. II, Appendix E, Type A Select Fill Material, pages 1, 2 & 3)

Tailinas/ Contaminated Materials

- Average-percent compaction obtained was 95.2% of maximum dry density determined.by ASTM D698 test. Thir was verified by 79 field 3 density tests for a total of 339,377 cyd of contaminated materials, '

resulting in a test frequency of 1 test per 4,295 cyd of material placed. RAIP requires one test for every 6,000 cyd of material placed.

- Thirty-five one-point Proctor density tests:were made to verify the appropriateness'of 79 field density tests, resulting in a test frequency of one-point Proctor test for every 2.3 field density

tests. RAIP requires one-point Proctor' test for every 5 field density determinationa Forty-four maximum Proctor density (ASTM D698) determinat>N s were ,

_made for placing 339,337 -cyd of contaminated material, resulting in a frequency of one test per 7,713 cyd of material placed. RAIP

. requires one test for every 10,000 cyd of material placed.

FINAL CRR-July 15, 1992 (re-issued) B-5

~ . _. , ,, . - . , . . , , . - _ . ~ . , , _ . - . . . _ _ - - - _ _ _ . - . . . . _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

._. m _ _ _ _ _ . _ . _ . _ . _ _ _ _ - _.

NRC STAFF REVIEW Of DOE'S VERlFICALLO.!LOF REMEDIAL ACTION PLAN ACTIVITIES Site: Green River, Utah Reviewer: Banad Jagannath/ Dan Rom RAP FEATURE: 1. Type A Select Fill Tailings / Contaminated Material

- The contaminated materials were placed at an average moisture content of less than 3 % below the optimum moisture content.

- There werc 254 moisture content determinations in conne; tion with .

placing a total of 339,377 cyd of material, resulting in a test frequency of 1 per 1,336 cyd of material placed. The RAIP requires one. test for every 2,000 cyd of natorial placed.

1

- The volumetric moisture content was 10.6 % against a requirement 1 of 10.5 %-for windblown / vicinity property materials. For tailings, .l the measured volumetric moi:ture content was 7.1 % against a volumetric moisture content requirement of 5 %. This non_ compliance

- was evaluated in the final RAP review stages and the TER concludes that the slightly higher placement moisture has no adverse impact on the groundwater protection performance of the disposal cell.

- There were a tctal of 386 moisture content determinations using l' microwave method and these were correlated with 75 oven dried moisture content determinations, resulting in one oven dried ,

m91sture content test for 5.1 microwave test. RAIP requires one l oven' dried test for every 10 microwave test me' hod of moisture '

content determination.

i l ,

I i-L I' 1 i

FINAL CRR July 15, 1992 (re-issued) BC

. - . - . ~ . - - .- - - . - . . - - . - . . - . . - . - . - . - - .

P NRC STAFF REVIEW 0F 00.E'S VERIFICATI0tLQF REMLQ13L ACTION PLAN ACTIVITIES  :

Site: Green River, Utah Reviewer: Banad Jagannath/ Dan Rom  !

RAP FEATURE: 2.. Radon ~ Barrier s A. CONFIGURATION RAP Reaul.rement

- Areal extent'as per Drawing GRN-PS-10-0517, RAP Modification, PID No.

10-S 03, Rev. 3

- Thickness 2 feet Dslermination

. As-built drawino GRN-PS-10-0517 indicates the areal extent and thickness-of tht radon barrier to be as per the RAP design. '

B. PLACEMENT FLAP Reauirement - .

(1) Haterial

- Silty Clay from borrow source identified in the RAP.

. Gradation requirement is a maximum of.10% weight retained on' No. 4 sieve. In addition, the material .for.first lift-of the radon barrier required to-have- a minimum of 70% passing No. 200 sieve and the material for subsequent lifts a minimum of 50% passing No. 200 sieve. The rador.

barrier material should be amended with 6% by weight Bentonite (Envirogel-200).

(RAP' Spec. page 02-200-9)

-(2) Lift Thickness-

- 9 in, compacted thickness or 12 in, loose thickness.

(3)' Compaction

.- 100 percentLof maximum density determined as por ASTM D698 test.

-- PlacementLmoisture content should be zero to 3 % above the optimum

-moisture content determined by ASTM D698 test.

, -FINAL'CRR- _.

July'15, 1992 (re-issued)- B-7 l

-i

)

. - , ,-....,..,_..-.~...._,_.,-,...._m--,, -

NRC STAFF REVIEW 0F DOE'S YERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Green River, Utah Reviewer: Banad Jagannath/ Dan Rom RAP FEATURE: 2. Radon Barrier

- Between lif ts, the moisture content of preceding in-place layers should not be drier than a maximum of one percent below the optimum moisture content.  :

(4) Saturated Hydraulic Conductivity ,

- 1he saturated hydraulic conductivity should not he higher than 2 x ,

10 to the minus 8 cm/sec. To be demonstrated by laboratory tests on field compacted block samples taken from radon barrier layer.

The frequency of tests should be a minimum of ene per 2,000 cyd of radon barrier material.

Determination.

.(1) Material-

- A total of 60 gradation tests were conducted for 27,911 cyd of radon carrier borrow material. This resulted in a test frequency '

of one test per 465 cyd. RAIP requires one test for every 500 cyd of borrow material. -The Bentonite amendment was closely mrsitored to comply with the specifications, as per statements in toe CR.

(2) Lift Thickness

-The lift thickness during placement was cicsely monitored to

-comply with-the specifications, as per-statement'in the CR. ,

l (3) : Compaction:

L - One-hundred-eleven in-place-field density tests were performed to 1

verify placement density of 27,911 cyd of material. This results in one test per 251 cyd of material placed. RAIP and specification Erequires one test per 500 cyd of material placed. The average p - degree = of contaction was -101.6%'of maximum densityLdetermined in L ASTM D698 tes'. .

l le

~ FINAL CRR -

July 15,11992-(re-issued) B-8 l

1 L- ,  ;# a _ ..__ _ . - __ _ .- _ _ - . - -

l

I

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, NRE STAFF REVIEW OF DOE'S VERIFICATION OF REMED]AL ACTION PLAN ACllVITIES Site: Green River, Utah Reviewer: Banad Jagannath/ Dan Rom RAP FEATURE: 2. Radon Barrier

- Thirty one one-point Proctor tests were performed to verify the maximum density value used in the above mentioned 111 field density determinations. -This resulted in one one-point Proctor test for 3.7 field density tests. RAIP requires or.e one-point Proctor density test for ever/ 5 field density tests.

- Fourteen maximum dry density determinations (ASTM D698) were _

performed for a total of 27,911 cyd of material compacted. This resulted in a test frequency of one test per 1,994 cyd of material.

RAIP requires one Proctor test for every 15,000 cyd of material compacted.

The average placement moieturc content was 1.6 % higher than the optimum moisture content.

- One-hundred-sixty-one moisture content dcterminations were made to ensure that the preceding layer of the radon barrier layer had not dried beyond the specification limits prior to placing the next layer of the radon barrier.

~

- There were a total of 423 moisture content determinations using microwave test method and these were correlated by performing 89 oven dried moisture content determinations resulting in or.e

orrelation test for 4.8 microwave method tests. RAIP requires one

, correlation test for every 10 microwave method tests.

(4) Saturated Hydraulic Conductivity i=

-- 14 bloc'< samples were taken from as-compacted radon barrier layer to determine saturated hydraulic conductivity by laboratory tests.

The block sample locations 'were distributed so' that the results may be considered to be representative of the as-built field conditions.

All the 14 tests indicated saturated nydraulic conductivity of 2 x 10.to the minus 8 cm/sec or less and complied with the specifications and-design: requirements. The frequency of test was one per 1,994 cyd of radon' barrier material compacted. Spec /RAIP required one test for every 2,000 cyd of radan barrier material.

FINAL CRR t

July 15, 1992 (re-issued) B-9

~ - . - . - - - _ . - . - - . - - . . - . _ . . _ _ - _ _ . . . - . - . . -

E NRC' STAFF REVIEW OF DOE'S VERJFICAf!ON OF REMEDIAL ACTION PLAN ACT!V! TIES 15ite:' Green River, Utah Reviewer: 84nad Jagannath/ Dan Rom RAP IIATURE: 3; Stdding layer A. CONFIGUPATION EhE_8gauirement

- Areal extent as per Drawing GRN-PS-10-0517, above the radon barrier

- Thickness 6 inches Dalerminatiqn

- As-built drawing GRN-PS-10-0517 shows the areal extent. The thickness of the' be.* Jing layer is 6 inches. There were 60 depth or thickness

' checks whIch showed the as-placed thickness to be within 0.1 ft. of the

-design-thickness of_0.5 ft.

B. ELhCLULUI f RAP Reauirement (1) Haterial

- Gradation (spec. page 02278-10)

- Percent of clay lumps and friable part;cles 3%

- Rock _ quality score of 50 percent or greater (Spec. page 02278-8) '

(2) Compaction .

- Uniform distributica, minimization of voids. Placement procedure and equipment to' be used is specified.

Determination

-(l) Material

- four gradation tests (frequency as per Section 6.3.3 of RAIP).

performed. - Average. gradation of- the four tests comply with the

-specifications.

- Material met the 3%-limit on-clej lumps tad friaole particles. ,

_ Average-content of percent clay -and friable particles was 0.85%

~

p l FINAL CRR l: ' July;15, 1992 (re-issued) B-10 ,

L o

~_ , . _ . . - -._ ..-- ~.- --- - - _ - - - - . - - - -

, . . . . -. _ .. . _..._.. _ . _ _._._._ . - ___._...._....__..m..___._.~_._.-_. - .

1 s , l i

NRC STAFF R[ylEW 0F DOE'S VERIFI[A, TION Of REMEDIAL ACTION PLAttACTIVITIES -I Site: Green River, Utah Reviewer: Banad Jagannath/ Dan Rom  !

_______..___________.._______________.s__ _____._______.. _________________ r

,. _ RAP FEATURE: 3. Bedding layer ,

- hock quality durability sco 2 was 62. l The, scope of testing was in compliance with tne provisior,s in the specifications- and _ project RAIP.

(CR;'Vol. II, Appendix E. Bedding Haterial, pages 1-4)

(2) Compaction

- CR states that the inspection and testing during construction resultad in the bedding material placed as per specifications.

7

, FINAL-CRR July ' l ^,, 1992.. ( re-i ssued) B-11

(

'- i e+ 3 -96 g er

]- V y s- p '*$We- P-T v9f'e'9'*'%% '

T FT -'* MW #-*EW'MY^- '" '"'-N-#" * ---

HRC STAFF E ylEW 0F_D0E'S VERiflCAT104 0F REMEDIAL ACTION PLAN ACTIVITILS Site: Green River, Utah Reviewer: Banad Jagannath/ Dan Rom RAP FEATURE: 4. Gravel fill

5. Type B Select Fill Gravel fill and Select Fill were sufficiently far removed from the disposal cell area that all parties agreed a formal write-up in the CR would not be required. This issue was discussed in a conference call on December 18, 1991.

In lieu of the formal write-up, DOE provided Gravel fill gradations test loc &tions and 2 greed to make available General fill records on request. .

was noted that the General Till consisted substantially of "non-testable" material i 30% retained on th? 3/4 inch sieve), and relatively few n:oisture! jeneity tests wer i t aken, a now section would not be added, l

flNAL CRR July 15, 1992 (re-issued) B-12 ,

I!RC STAFF REVlfW 0F DOE'S VERl(( CATION OF REMEQlAl A _TJON PLAN ACTIVITIES Site: Green River, Utah Reviewer: T.L. Johnson RAP FEATURE: 6. Rock Cover A. (QNFIGURATIDH RAP Reauirementi (1) Areal Extent (2) Thickness: 12 inches __

Determinatiqq (1) Verified in As-built drawings and by visual observation during site visit.

(2) Acceptable based on review of DOE testing in 39 locat' 7s on a 100' x 100' grid. Reworking was performed where not accept;cle.

iL liAl[Rlal BAP Requirement (1) Gradation - Section 02278 of Specification-(2) Durability - Rock score must equal 80, in accordance with flRC s procedures included in the specifications Determinatiom _

(1) Gradation summary curves provided in Appendix E indicate that all the select rock met the gradation requirement.

(2) Average S: ore: 85; range 78 - 90 C. EL&EEMENT P

Rap Reauirement (1) Uniform distribution, minimization of voids Petermination (1) " Daily inspections of the Tyne A Riprap were conducted during excavation, production, stockpiling, transporting, and placement to FlhAL CRR

• July 15, 1992 (re-issued) B-13 1

l

.,J* . i NRC STAFF REVIEW 0F DOE'S VERIFICATION CF REMEDIAL ACTION PLAN ACTIVITIES Site: Green River, Utah Reviewer: T.L. Johnson RAP FEATURE: 6. Rock Cover assure the following: That p oper techniques were employed to prevent degradation of the material due to improper handling; that d stribution a was uniform; that voids were kept as minimal as possible; and that proper

-gradation was maintained."'(Appendix E - Riprap Type A, page 3)

D. TEST FRE00ENCY i

RAP Reauirement '

(1) Gradation tests at 1/3-points of production (2) Durability tests same frequency.as Gradation tests Determination (1) 4-tests were conducted. They were at the required frequency.

(2)' 4' tests were conducted. They were at the required freauency.

I l

l' L

(.

. FINAL CRR' $

._ July .1S,1992 (re-issued)- . B-14 l

i

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m . _

l FRC STAFF REVIEW 0F' DOE'S VERIFICATION OF REMEDIAL AC110N PL AN ACTIVITIES Site: Green River, Utah. Reviewer: T.L. Johnson RAP FEATURE: 7. Apron A. CONFIGURATION EAP_Reauirements (1) location i 1

(2) Cross Sections l i

-(3) Site grading Determination i

. Verified in As-built dra&:'ogs and by visual observations during-site visit.

B. MATERIAL, PLACEMENT, AND TEST FREQUENCY t

RAP Reatirement~

(See Rock Cover, feature 4)

Determination.

DOE states that required tests were performed at.the required frequency, There were no failing tests. Rock quality met requirements (See Rock Cover, Feature 4, also) a FINAL.CRR July-15, 1992 (re-issued).

B-15 0

t y 4 4 a. -+,--,mm.=d are-. v ow - - re-e,e* + -vm+ . - * -- -*-+=we,me<-m> *c-++-w, *t-w-w-. w--.-n - "--tv-t-*rr--

[o *

• l NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACTION PL AN ACTIVITIQi '!

Site: Green Rivsr, Utah- Reviewer: E. Brummett {

' RAP FEATURE: 8. Site Cleanup A. CLEANVP VERIFICATION PROCEDUR" .

RAP Recairements

- RAP Section C.3.4 and RAC HP Procedures, 015 (Grid Sampling System)

Qglermination

- Appendix J documents that the entire site was divided into 10 foot i grids and sampled per RAC-015 sampling and analysis procedures i

B. TEST RESULTS RAP Reauirements 4

'All areas of the site to be cleaned up to meet the EPA radium-in-soil i standards, not to exceed background by:

1. '5 pCi/g Ra-226 top 15 cm.

2.

15areas pCi/g of Ra-226 100 m [)or a'y sLbsurface 15 cm. layer (averaged over Determination.

- 4326 soil samples were measured- for Ra-226. All meet the EPA standards

'(average 2.4 pCi/g; maximum 14.9 pCi/g; minimum 1.3 pCifg).

Th-230-was measured in some verification samples. Calculations indicate 1 that the Th-230 decay will not cause the Ra-226 to exceed.the EPA standards in 1000 years (Appendix J),

C. DECONTAMINATION OR'DEM0LITION l

-RAP Renuirements (l! Six existing buildings at the site to be-decontaminated er ,

demolished as necessary in accordance with the EPA standands for habitable / occupied buildings, not to exceed:

- Annual average radon decay product concentration of 0.0L WL, incloding background.

l-l- FINAL CRR

July 15e 1992 (re-issued) B-16 L

L l<

._ _ . _ .. _ . _ _.. _ _ _ _ . _ 7 . _ . _ _

s .

NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REME01Al ACTION PLAN ACTIVITIES

. Site: Green River, Utah Reviewer: E. Brummett RAP FEATURE: 8. Site Cleanup I

{

- Gamma radiation levels of 20 micro R/hr above background. i (2) Surface alpha shall not exceed limits that will ensure that  !

potential cirborne radionuclide concentrations will not exceed 10 '

CFR 20. Aop. B standards and that physical contact with surfaces -

will not result in a measurable radiation exposure. (UMTRA Project .

. Environmental, Health, and Safety Plan per RAP Section C.1) '

Qqtermination.

(1) The roaster building and the additions to the office and mill buildings were demolished and the debris placed in the disposal cell. Three other buildings were decontaminated, as necessary, and

-left for future use. Residual contamination was reduced to levels that were as low as possible using reasonable efforts. ,

1

- Measured radon decay products in the three remaining '

' buildings approximate background levels.

- All interior gamma readings were less than 5 micro R/hr above background.

-(2) All surface alpha levels met the criteria of:

removable 1000 dpm/100 sq.cm. i

- fixed .

5000 dpm/100 sq. cm.

- total (maximum)- 15000 dpm/100 sq. cm.

(NRC Reg. Guide 8.30) a l

L l-FINAL:CRR.

July 15, 1992 (re-issued)- B-17

. m- _-_ _ . _ ._. ._ u.. _ _ _ _ -. _ _ . _ _ _ _ ___ . _ _ -

s

• NRC STAFF REVIEW 0F DOE'S VERIFICATION OF REMEDIAL ACIJON PLAN ACTIVITIES

- Site: Green River, Utah Reviewer: M. Layton RAP FEATURE:-9. Hydrology  !

X IN5TAllATION ATID TESTITIDRUCEDVR.5 RAP Reauirement (1) _ Ground-water characterization wells situated beneath the designated disposal cell will be-properly abandoned. Wells located outside of i the disposal cell, which were not designated for continued monitoring, will also be abandoned. This requirement was not  ;

specifically listed in the RAP, but was presented as an item in the 4 list of construction drawings contained 'n the RAP. I (2) The bottom six feet of the disposal cell will be filled with a compacted, selected c, an fill (buffer layer) to retard the movement ,

of contaminants to ground-water from overlying contaminated 1

-materials. l (3) Compacted win'dblown tailings (mixed with clean soil) will be placed I cibove the buffer layer.

l

~ (4)' Four neutron-access holes for neutron logging will be used to monitor moisture within the tailings, vicinity property material, l other contaminated material, and buffer materials at different depth.

(5) Arsenic,_ lead, and methylene chloride are added to the hazardous constitucats list for ground-water monitoring at the disposal cell.

(6) DOE committed to continuing the background __ ground-water quality

' measurements in the six-POC wells, four new upgradient-wells, and ,

m exiting well'813 on a- quarterly schedule for two years following s

completion'of tne_ disposal cell. The purpose of _ this sampling is to

' establish the statistical maximum concentrations for:the hazardous

. constituents identified at the site. ,

Determination (1) Document No. 5057-GRN-5-01-00291-02 provides subcontractor well abandonment procedures. As-Built' Drawing GRN-PS-10-0518 " Monitor Well . Abandonment and -Boring Location Plan" shows locations and surveyed coordinates of ' abandoned wells, _ including those in vicinity of disposal cell _ and outside of the disposal cell.

- (2) Dodument No.- 5057-GRN-S-01-002494-07 " Earthwork Specification Type

' A' Fill"; Calculation No. 10-591-01-00 " Tailings Of fpile, Buf fer ,

FINAL =CRR

- July.15, 1992 (re-issued).

B-18 E

1

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NRC ST,AFF REVIEW OF DOE'S VERIFICATION OF REMEDIAL ACTION PIAN ACTIVITIES Site: Green River, Utah Reviewer: M. Layton RAP FEATURE: 9. Hydrology materials: In-Place Parameter Characterization"; As-Built Drawing GRN-PS-10-0517 " Tailings Embankment and Final Site Grading Sections and Details" Frovide details of material specifications and location

-and thickness of buffer layer.

(3) Photos 9-17A through 10-2A show placement of ' contaminates' above buffer layer (Type 'A' fill) and below tailings.

(4) As-Btilt Orawing GRN-PS-10-0516 " Tailings Embankment and Final Site Grading Plan" provides locations and coordinates for four neutron

-access holes within the constructed disposal cell. No measurements '

from neutron holes are presented in the DOE Completion Report, but are to be reported during the long-term surveillance. l (5) RAP modification was requested 'y DOE on June 18, 1991 to delete  !

methylene-chloride from the hazardous constituents list, based on 4

-ground. water monitoring results. NRC agreed with the request to delete. methylene chlorlde on August 7,1991; however, toluene has been detected in samples of tailings pore fluid and identified in some of the ground-water monitoring results. NRC has requested clarification as to why toluene has not been added to the hazardous constituents list. 00E responded by letter dated November 21, 1991, which provided additional information and clarified the reasons that toluens was not included as a hazardous constituents for ground-water monitoring. NRC agreed that toluene should not have been -

included as a hazardous constituent, based on the clarifications ir  ;

the November 21r 1991 letter.

(6) Appendix K of the CR provides tho monitoring results for upgradient wells.177, 178, 179, and 180; in addition to POC wells 171, 813, 172, 173, 174, 175, and 176. The Appendix also provides the

-statistical results used to establish the final concentrations limits. The NRC staff noticed that several data gaps existed in the analytical. results for these wells:

Well 175 did not have any results for the. sampling episode of 1/13/91; '

Net gross alpha results were not reported for wells 177, 178,

-179, and 180 for sampling episode of 8/23/90; and Combined radium-226 and -228 were not reported for-wells 177, 178, 179 and 180 for the sampling episode of 1/13/91.

LFIN L CRR l July-15, 1992'(re-issued) B-19

NRC STAFF REVIEW nF 07E'S VERIFICATION OF RrMEDIAL ACTION PLAN ACTIVITIES Site: Green River, Utah Reviewer: M. Layton RAP FEATURE: 9. Hydrology No explanation was provided for these data; however, these gaps should not adversely af fect the statistical determinations of

, background conditions at the site, and the NRC staff does not consider these gaps as significant.

r 4

FINAL CRR July 15, 1992 (re-issued) B-20

. . ~ . _ _ . ._. _.-~ _ _ .-__-._ _ - _. ... _ _ . . _ -

+

i APPENDIX C:

UMTRCA, THE EPA STANDARDS, AND THE PHASED UMTRA PROJECT L

E 1

FINAL CRR

-July '15 _1992 (re-issued) C-1

. :u, _ _ _ . . . - . _ , _ , _ . - . _ _ - _ _ _-__- __ ~ _ _ _ _ _ __ __. . _

o .

APPENDIX C UMTRCA. THE EPA STANDARDS. AND THE PHASED UMTRA PROJECT Title I of UMTRCA defines the statutory authority and roles of the DOE, the I NRC, and the EPA with regard to the remedial action program for inactive uranium mill tailings sites. #

Ihp Standards UMTRCA charged the EPA with the responsibility for promulgating reradial action standards for inactive uranium mill sites. The purpose of 1; ese standards 'is_ to protect the public health and safety and the environment fron radiological-and non-radiological hazards associated with radioactive materials at the sites. UMTRCA required that EPA promulgate these standards ,

by no later than October-1, 1982. After-October 1, 1982, if the EPA had not promulgated standards .in final form, DOE was to comply with the standards proposed by EPA under Title I of UMTRCA until such time as the EPA had promulgated its standards in final form.

The: final EPA standards were promulgated with an effective date of March 7, 1983. (48 FR 602; _ January -5,1983); See -40 CFR Part 192 - Standards for Remedial Actions at inactive Uranium Processing Sites, Subparts A, B, and C.

These regulations may be summarized-as follows:

1. .The disposal site shall be designed to control the tailings and other residual radioactive materials for- up to 1000 years, to the extent reasonably achievable, and, in any case, for at least 200

- years-[40CFR-192.02(a)]. ,

2. Provide reasonable assurance that the disposal site design shall prevent radon-222 from residual radioactive material to the atmosphere.from exceeding 20 picocuries per square meter per-second or from-increasing the annual average concentration of radon-222 in

, air at or above any Llocation outside the disposal site by more than one-half picocurie per liter (40 CFR 192.02(b)].

. 3. The remedial- action shall-be. conducted so as to provide reasonable as'surance that,- as. a result of reridual radioactive materials from any-designated processing site, the concentrations of radium-226 in 11and averaged over any area' of 100 square meters shall not exceed the background level by more than 5 picocuries/ gram averaged over the first 15 centimeters of soil below the surface and 15 .;

picocuries/ gram averaged over any'15 centimeters more than 15

. centimeters;below the curface (40 CFR 192.12(a)].

The. portion-of the EPA standards dealing with ground water _ requirements, 40 CFR 192.20(a)(E)-(3). were remanded by the Tenth Circuit Court .of Appeals on September 3, 1985. Based on this court decision, EPA was directed to-

promulgate neu groundwater standards. EPA proposed these standards in the -

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i form of revisions to Subparts A-C of 40 CFR Part 192 in September, 1987, and now is in the process of completing action to promulgate the final groundwater standards.  !

As mandated by Section 108(a)(3) of UMTRCA, however, the remedial action at the inactive uranium processing sites, is to comply with EPA's proposed standards until such time as the final standards are promulgated. 00E continues to perform remedial action at the inactive processing sites in accordance with NRC's concurrence with the remedial action approach based on the proposed EPA groundwater standards (52 FR 36000; September 24. 1987).

. Delaying implementation of the remedial action program would be inconsistent with Congress' intent of timely completion of the program. Modifications of

. disposal sites after completion of the remedial action to comply with EPA's final. ground water protection standards may be unnecessarily complicated and expensive and may not yield commensurate benefits in terms of human ano environmental protection. Therefore, the Commission believes that ' sites where remedial . action has been essentially completed prior to EPA's promulgation of final ground water stand 1rds will not be impacted by the final ground water standards.- Although additional effort may be appropriate to assess and clean up contaminated ground water at these sites, the existing designs of the disposal sites should be considered sufficient to provide long-term protection against future ground water contamination. NRC does not view VMTRCA as requiring the reopening of those sites that have been substantially completed when NRC concurred with the selection of remedial action in accordance with applicable EPA standards, proposed or otherwise in place at the time such NRC concurrence was_given.

DOE Selection (Desiani Phase For each site', UMTRCA requires that DOE select a plan of remedial action that will satisfy the EPA standards and other applicable laws and regulations, and with which the NRC will concur. For each site, this phase includes preparation by DOE of an Environmental Assessment or an Environmental Impact Statement, and a Remedial- Action Plan (RAP). The Remedial Action Plan is structured: to provide a comprehensive understanding of the remedial actions proposed at that site and contains specific design and construction requirements. 'To complete the first phase, NRC and the appropriate State or Indian tribe review the RAP and then concur that the RAP will meet the EPA standards.

The'PerformancL (Construction) Phase In this phase the actual remedial action (whi_ch includes decontamination, decommissioning, and reclamation) at the site is done in accordance with the 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 remedialiaction activities at the site, NRC concurs in DOE's determination that the activities at the si .e have been completed in accordance with-the approved plan. _ Prior to licensing (the next phase), title to the disposed tailings and contaminated materials must be transferred to the United States and the land.upon which they are disposed of must be in Federal -

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c.usto? to piovide f or long-te> a Federal control. Disposal sites on Indian land will remain in the ber ficial ownership of the Indian tribe.

(! N Qg c hRC concurrence in the DOE determination that remedial action at a processing site has been accomplished in accordar.ce witF 6

e approved plan to be t accomplished in two steps where residual ra. sa.tive material is not being "

im mv M from the proco:.;ing site to a differeit isposal site. The Uranium Mill j -

ngs Gemedial A; tion Amendments Act of :388 allows for a two step approach

. b I disposal sites. The Amendernts f.ct will allow DOE to do all e

tions, other than ground water restoraticn, for the first step of ilicensing. The second step, which can go on for many years, will

1. w .+ uisting ground water restoration. When ground water restoration is

' Q* c x *' the tong krm Surveillance Plan required under the licensing phat

• i " appropriately arended. For sites that are being moved, licen,;ng will v w - or.c step. There ;s no ground water restoration at the disposal site ,

f' an: er ocessing sice will not be licensed after completion of remedial an Nn.

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ye Licen -

ohase 17 u "h Title 1 of JRCA further requires that, upon completion of the re ..

action program by DOE, the permanent disposal sites be cared for bs one DOE or other Federal agency designated by the Prer.ident, undw a license issued by

.the Commission. DOE will receive a generai license u. % # CFR Part 40.27 following (1) NRC concurrence in the DOE dctern.:nat :m t Nt_ the disposal site has been p- trly reclaimed and (2) the formal receig by '.RC of an acceptable

!ong-Term St. 1111anca Plan (LTSP) . NLC concurrence v '.h DOE's performance of a the remedial ac' iafsates that DOE has demonstrated that tv. remedial a'. tion amplies .n i the provisions of the EPA standards in 40 CFR part 192,

, Subps t A, B, ano C. This NRC concurrence may be completed in two steps as discu. ed 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 nave ~

, as cpportunity to comment on the remedial action or closure plans prnposed and implemented by DOE and to raise concerns regarding final stabilization and the degree of protectica achieved. NRC fully endorses State / Indian tribe and ,

" public input in all stages of the program, especially in the pl?nning 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 siomitted, q' the Nkt will consider the need for a public meeting in response to rc iuests gj 2

and public concerns. Therefore, NRC encourages State / Indian tribe anu public 4- participation early in the remedial action and closure process and will provicie additional opporttoities, as i.eeded, later in the process.

Ibg Surveillanq1 and Monitorino Phase In this phase DOE and NRC periodically inspect the disposal site to ensure its -

integtity. The Long-Term Surveillance Plan (LTSP) will require the DOE to make repairs, if needed.

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, c< s One of the requirements in the EPA standards is that control of the tailings should be designed to be tffective for up to 1000 years without active maintenance. Although the design of the stabilized pilt 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 Nationa Environmental Policy Act (NEPA) actions, and health and safety considerations from 10 CFR Parts 19, 20, and 21.

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