ML20129C641
| ML20129C641 | |
| Person / Time | |
|---|---|
| Issue date: | 05/17/1985 |
| From: | Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Higginbotham L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-58 NUDOCS 8506050606 | |
| Download: ML20129C641 (5) | |
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/ WM file: WM-58 WMEG r/f MAY 171985 NMSS r/f REBrowning WM-58/DCG/85/5/8/0 MJBell JTGreeves MSNataraja DCGupta HJMiller MEMORANDUM FOR:
Leo B. Higginbotham, Chief J0 Bunting Low-level Waste and Uranium LBHigginbotham Recovery Projects Branch PDR Division of Waste Management FROM:
John T. Greeves, Chief Engineering Branch Division of Waste Management
SUBJECT:
REVIEW 0F SHIPROCK REMEDIAL ACTION INSPECTION PLANS (RAIP 1 THROUGH RAIP 6), REVISION 0 DATED APRIL 10, 1985 As per your Technical Assistance Request (TAR-85032) of May 1985, we have reviewed the subject Inspection Plans for the construction of Shiprock Remedial Action. These Remedial Action Inspection Plans identify the means by which the DOE intends to control, verify and document the remedial action activities at Ship ock, New Mexico.
The work performed for the requested technical assistance consists of review of the Inspection Plans for the items pertaining to geotechnical engineering construction activities of the proposed Remedial Action Plan at this site.
Since the Inspection Plans cover many tonics related to Quality Assurance, additional review of the document by appropriate NRC staff members may be desirable to assure compliance of the DOE document with the NRC quality assurance requirements.
The enclosure to this memorandum presents our comments on the DOE's Inspection Plans related to minimum test frequency requirements to assure adequate field density control of the compacted material and data recording procedures. We recommend that the DOE be asked to modify the Inspection Plans in view of our comments.
M Rygeview wasgegfgedgDr. Dinesh Gupta. He may be contacted at x74742.
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. Greeves, Chief Engineering Branch Division of Waste Management j
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GE0 TECHNICAL ENGINEERING REVIEW COPMENTS.0N "UMTRA PROJECT - SHIPROCK REMEDIAL ACTION PLAN"
- (RAIP-1 THROUGH RAIP-6, REVISION 0. DATED APRIL 10,1985) by Dr. Dinesh C. Gupta Engineering Branch, WM/NMSS General Comments Applicable-to RAIP-1 Through RAIP 6 1.
The " Statement.of Policy", attached to the Inspection Plans, states that
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the plans will be appended as necessary to-accomodate changed work conditions or changed criteria. However, a mechanism to develop, control, approve and document.these changes has not been discussed in the Inspection Plans. The DOE should establish the necessary procedures to-
. control change's and include them in the pertinent inspection plans or in the. Statement of Policy.
2..
The Inspection Plans do not address any provision for a'"Stop Work Order".
The. situations when a "Stop Work Order" may become necessary should be addressed in the RAIP's.
Procedures and level o'f authority _ for issuing a -
"Stop Work Order" should be described and a. mechanism for resolving the corresponding nonconformance(s,) should be discu' sed.
s 3.-
The forms attached to various RAIP's should be numbered and should be referenced in the text of the corresponding RAIP's as'to the purpose and likely use of the forms.
4. -.
In Section 5.0-(References), the RAIP's make reference to NSI/ASME NQA-l' 1979 document.
Since the 1979 edition of this standard has been revised, the RAIP's'should refer to the later (1983) edition of the document.
Comnents on Section 6.1.2 of RAIP No. 2 31._
The minimum test frequency requirement for field density control should be revised to read as follows:: "The test frequency shall be a minimum of one test per 1,000 cubic yards of contaminated material placed and one test I
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. per 500 cubic yards of other compacted materials." This requirement would be consistent with that proposed in NAVFAC DM 7.2, May 1982.
2.
In the requirements for field density control, add the requirement that "There shall be a minimum of one test for every full SHIFT of compaction operations." (as per NAVFAC DM 7.2).
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The DOE should provide sufficient basis to support the requirement that one test for each 1,500 square yards would be' adequate to provide reasonable control of field density of compacted subgrade material.
4.
The DOE should provide sufficient justification to support the provision in the RAIP No. 2 that the Site Quality Supervisor may decrease the test frequency to one test for.each 4,000 square yards of the foundation subgrade. This provision seems to be arbitrary and its use may result in inconsistent and undesirable field density control of the foundation
.subgrade material.
Comments on Section 6.1.3 of RAIP No. 2 1.
This section of RAIP No. 2, as written, is for the most part applicable to the determination of relative compaction of cohesive materials. The use of the one' point proctor test is not generally applicable to non-cohesive soils.s Since the remedial action also requires compaction of non-cohesive
. materials and ASTM D-2049 is referenced'in Section 6.1.1, the Inspection Plan should include methods for verifying use of correct maximum dry densities of all materials proposed to be used at this site.
2.
The section should add the following requirement, " Supplementary compaction curves (complete) on field density test samples shall.be obtained, approximately one for every 10 or 20 field tests, depending on the variability of materials". Suggested addition of this requirement is consistent with NAVFAC DM 7.2, May 1982.
Comment on Section 6.1.5 of RAIP No. 2 The Inspection Plan should include a criterion for the acceptability of the inspected field density and moisture data (see Section 7.2.5 of the RAIP). The fMlowing criterion may be used for guidance:
For moisture control, if approximately two-thirds of all field values fall in the' range of + 1 percent of the specified moisture content, close moisture control would be evidenced. Similarily, if approximately two thirds of all field densities fall in the range of + 3 percent about the percent maximum
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.4 density required suitable compaction would be evident.
However, if two thirds of all-moisture content values fall in the range of + 3 percent about the specified moisture content or if two thirds of all tee field densities fall in the range of 5 percent below the specified maximum density, insufficient compaction control would.be evident."
Comment on;Section 6.2.1 of RAIP No. 2 Add the following requirement to this Section.
"At least one gradation and
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classification test shall be run each day of seepage barrier / liner material placement to verify _ that the specification limits are maintained." These tests are important to provide the necessary control on materials and are fairly simple to perform.
Cannent on Section 6.2.2 of RAIP No. 2 Modify'the requirement for " weekly" run of gradation and classification test to
- require " daily". tests. The second sentence of the Section should read, "At least one gradation and classification test shall be.run each day of radon barrier material placement to verify that the specification limits are maintained". ' These tests -are important to provide the necessary control on materials and are fairly simple to. perform.
Comment on Section 6.2.3 of RAIP Due to the possibleLvariability in the alluvial deposits to be used as rock sources, the requirements for rock durability testing should be modified.to include more frequent testing of the various riprap sizes to be provided. The third paragraph of this section should-read, "For each gradation of riprap, specific gravity, soundness, and abrasion testing shall be performed prior to r
beginning delivery of the material to the site. During construction activities, additional test series shall be performed for each type of riprap when approximately one third and two thirds of the total volume of each type of riprap have been delivered. For any type of riprap where the volume is. greater than 30,000 cubic yards, a test series shall be performed for-each additional 10,000 cubic yards of riprap delivered. A final sample shall be obtained for each riprap type following completion of delivery of the material."
In addition, a paragraph similar to that in' the Canonsburg RAIP should be added as follows:
The placement-of the riprap materials shall receive continuous inspection to assure that proper placing techniques are employed to prevent degradation of the material due to improper handling and to assure that the distribution is uniform and that voids are kept as minimal as possible
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f and~to assure proper gradation. The inspection shall'also verify'the lift-thickness and elevations.. Inspection may be provided at the material ~
source if required to assure compliance to the specification requirements.
Comments on Section 6.4.2 of RAIP No. 2
.In;the fourth line of the Section, change the word "per.iodically" to
" frequently". Also, the following inspection requirement should be added to
-this Section. " Inspection shall verify that the compaction equipment (or equivalent), as per specifications, is being used for compacting the material and the number of roller passes meets the specification requirements."
Comment on-Section 6.4.3 of RAIP No. 2 Add:the word." frequent" at the end of first line of this Section.
Comment on Section 7.2.3 of RAIP No. 2 The records'.should include the name of the person checking the calculations.
' Comment o'n Page 9 of RAIP.No. 2
.The form on " Maximum Density Determination" does not seem to include provisions for determination ~of maximum ~ density of.non-cohesive soils (relative density).
Since the remedial action requires compaction ~of a range of materials,-
appropriate form should be used for maximum density determination of.all the materials. proposed to be used at this site.
Comment on Section 6.1.1.1 of RAIP No.' 6 The Section should preferably read as follows:
"Failing density, moisture content, gradation or classification tests are considered to be nonconformances if they are not corrected prior to the-placement of additional materials which would make the area or item inaccessable for a rework."
Comment on Section 6.1.1.4 of RAIP No. 6 This Section should read as follows:
" Instruments found to be out of calibration, even thouch deemed to have beeni processed in accordance with approved procedures, woulc require a nonconformance procedure." This would be in accordance with the definition of "Nonconformance" (Section 3.3 of RAIP No. 6), since the deficiency in
-calibration of instruments is likely~to render the construction quality or activity unacceptable or indeterminate.