ML20136H699
| ML20136H699 | |
| Person / Time | |
|---|---|
| Issue date: | 12/10/1985 |
| From: | Guillen D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Sly D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| REF-WM-39 NUDOCS 8601100459 | |
| Download: ML20136H699 (11) | |
Text
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WM39'dMC/35/12/09 DEC 101985 Distribution:
WMLU r/f JM39r/f hMSS s/f DM Gillen Note for:
Doug Sly LB Higginbotham I&E DE Martin From:
Dan Gillen WMLU
Subject:
Inspection Procedures for UMTRAP Sites Enclosed for your use is WMLU input pertinent to I&E's development of guidance for inspections of remedial action at inactive mill tailings sites. The enclosure includes a revision of your initial draft, plus our proposed " procedures" appendix.
Please let me know if you have any comments on this input, and keep me posted on further I&E action to finalize this guidance.
9 S
Dan Gillen WMLU
Enclosure:
ylft Record Fde Y.'t.1 Fred df As stated
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NAME :DM Gille PDR DATE :85/12/10 1
INSPECTIONS OF REMEDIAL ACTION AT INACTIVE URANIUM MILL TAILINGS SITES (Title I, Uranium Mill Tailings Radiation Control Act (UMTRCA))
2620-01 PURPOSE The purpose of this instruction is to provide guidance for planning and conducting inspections of the remedial action being carried out to stabilize inactive uranium mill tailings sites. The work is carried out under the direction of DOE under the authority of the UMTRCA Title I.
The Act requires NRC to concur with DOE actions to stabilize the sites, and afterward to issue a license for custody of the material and maintenance of the site, to the Federal agency that accepts custody of the remediated site.
i 2620-02 OBJECTIVE This chapter establishes the inspection procedures to be used by inspectors monitoring the remedial action work garried out at inactive uranium mill tailings sites by DOE contractors.
2620-03 DEFINITIONS 03.01 Remedial action means those work activities carried out to stabilize mill tailings and otherwise perform work to assume the tailings pile will conform to EPA standards for inactive sites.
03.02 Inspection includes all those actions necessary to monitor the activities during the remedial action at inactive tailings sites.
An " inspection" is generally referred to as an on-site construction review, as the majority of the remedial action is " earth moving" construction work. The inspection does not include enforcement action, as NRC does not have enforcement authority for this program under the Act.
2620-4 RESPONSIBILITIES AND AUTHORITIES 04.01 Division of Inspection Programs, IE The division develops and issues requirements, guidance and procedures for the NRC inspection program, and modifies the program as necessary based on experience, performance and other factors.
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l 2-04.02 Division of Waste Management, NMSS The division develops and issues policy, guidance and procedures for the uranium recovery licensing program, and directs the NRC program for evaluation and concurrence with DOE remedial action plans for cleanup of inactive uranium mill tailings sites and contaminated vicinity properties under UMTRCA.
04.03 Uranium Recovery Field Office (URF0), Region IV The Office carries out NRC's licensing functions for uranium recovery
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activities, under programmatic delegation from NMSS; carries out 4
programatic work for remedial action sites as designated and assigned by NMSS; and carries out the NRC inspection program for activities as assigned by Region IV, including inspection monitoring l
for remedial actions covered by this procedure.
2620-05 DISCUSSION The foundation for planning and scheduling inspections during remedial action
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at inactive tai'ings sites is the remedial ac ion plan (RAP), prepared by DOE i
and its contractors and issued with NRC concurrence. This plan includes criteria for all phases of the proposed remedial action.
l The Remedial Action Plan contains the basic elements of the remedial action but l
does not always contain specific criteria or procedures for carrying out the work. The specific criteria and procedures not included in the RAP are j
developed by the DOE contractor performing the remedial action at the site, j
These procedures are designed to control, verify, and document all remedial 1
i action at the site and are referred to collectively as the remedial action I
i inspection plan (RAIP). The RAP and RAIP are-the primary comitments and standards used as a basis for NRC inspections of the remedial action work.
2620-06 BASIC REQUIREMENTS 06.01 Most inspection requirements are covered by the procedures in this chapter.
It may be necessary, however,' to develop case-specific procedures to cover a particular site or special procedures to cover highly technical aspects.for a particular situation. The need for such procedures should be identified as soon as possible so that they may be developed and available when needed.
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. 06.02 The criteria for inspections for a particular site will be the Remedial Action Plan for the site and the associated Remedial Action Inspection Plan. Guidance for carrying out the inspections shall be incorporated into the procedures appended to this chapter.
06.03 The foundation for planning and scheduling inspections will be the DOE schedule for the site and the contractor's " construction" schedule for the remedial action work.
06.04 Because of the need for close coordination with the construction activities, inspections may be performed mainly on an announced basis, rather than unannounced as is the present NRC policy for inspection of its licensees.
06.05 As appropriate, the inspection effort will be weighted toward direct observation of work activities rather than extensive reviews of records and paperwork. The inspection process shall include photographic recording of critical work phases, processes, or milestones as necessary for the inspection record.
06.06 Inspection of remedial action at a site should be performed, whenever possible, by individuals that are cognizant of the site specific aspects of the Remedial Action Plan.
06.07 Results of each inspection shall be conveyed to management representatives of the site contractor and the DOE at a closeout meeting immediately following the inspection.
06.08 All NRC concerns arising from the inspection shall be clearly stated and resolved at the closeout meeting, if possible. Generally, all agreements made for resolution of NRC inspection concerns shall be in written form and signed by the principals.
06.09 A reasonable completion date shall be established for all unresolved NRC concerns. Priorities for completion dates will be established based on the health and safety significance of the concerns and considering the schedule for orderly completion of the remedial action.
06.10 The basic procedures for the inspection program are contained in the Appendix to this chapter.
06.11 The inspection program at each site should consist of at least three site visits during performance of the remedial action. These three inspections should be scheduled with respect to the construction milestones addressed in the Appendix as follows:
1.
During early stages of remedial action; depending on site-specific design aspects, this inspection may observe foundation preparation, or placement of capillary break, liner, or tailings / contaminated materials.
2.
During placement of the soil cover.
3.
During placement of erosion protection (rock cover)
In many cases, multiple activities can be observed given proper scheduling of these inspections.
Additional inspections may be performed as permitted by schedules and budget, if specific site activities warrant them.
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. APPENDIX: VMTRA CONSTRUCTION INSPECTION PROCEDURES I.
Objectives The objectives of the on-site review of remedial action construction are as follows:
o To determine by direct observation whether work and inspection performance are being accomplished in accordance with specifications and procedures; o
To determine whether the system for preparing and maintaining records is functioning properly; o
To determine whether records reflect work accomplishment consistent with specifications and procedures; and o
To determine whether the records and/or work activities indicate any generic problems, inadequacies or other weaknesses that could impact the acceptability of remedial action.
II. Preparation Applicable portions of the RAP, the final design, and NRC/ DOE comments and responses should be briefly reviewed to determine commitments relative to construction and inspection requirements before performing the on-site review. The reviewer should then utilize these documents in a more detailed review of the construction specifications, drawings, and RAIP.
III. Work Observation By direct observation of earthwork in progress, the reviewer should ascertain whether applicable activities are being controlled and accomplished in accordance with the requirements of the documents reviewed above.
Key construction milestones (listed in Table 1) should be observed as directed in Section 06.11 of this chapter.
Specific inspection procedures applicable to these particular construction activities are as follows:
A.
Foundation and Subgrace Preparation 1.
Check to ensure that the subgrade is cleared of all vegetation and topsoil, shows no sign of deterioration due to frost action or erosion, and exhibits no rutting from construction vehicles.
- TABLE 1 Key Construction Milestones
- 1.
Foundation and Subgrade Preparation
- 2.
Placement of Capillary Break
- 3.
Placement of Seepage Barrier / Liner
- 4. Placement of Contaminated Materials 1
- 5. Placement of Soil Cover (Radon Barrier)
- 6. Placement of Filter Layer (s) and Rock Cover May or may not apply to a particular site depending on site-specific design Will apply to all remedial action sites.
Will apply to nearly all sites (vegetative cover may be proposed for 1 or 2 sites) i
. 2.
Check to ensure that the subgrade exhibits no areas of subsidence, extreme surface drying, or localized ponding (overly wet areas).
3.
Observe proof rolling operations or density testing; If density testing is performed, compare results of tests. observed in the field with specifications.
B.
Placement of Capillary Break 1.
Observe placement and compaction operations to ensure that procedural and equipment requirements are being followed.
2.
Visually check the capillary break zone to ensure proper thickness and material type, and to ensure that segregation of materials has not occurred.
3.
Observe gradation and/or moisture / density testing and compare results of tests observed with specifications.
C.
Placement of Seepage Barrier / Liner 1.
Observe placement and compaction operations to ensure that procedural and equipment requirements are being followed.
2.
Visually check the liner zone to ensure proper thickness and material type.
3.
Observe gradation, plasticity index, and/or moisture / density testing and compare results of tests observed with specifications.
D.
Placement of Contaminated Materials 1.
Observe placement and compaction operations to ensure that procedural and equipment requirements are being followed; This includes checking the loose-lift thickness (during placement) against the specifications.
. 2.
Visually check the quantity, maximum size, and distribution of foreign material, and the distribution of organics against the allowable criteria of the specifications.
3.
Observe moisture / density testing and compare results of tests observed with specifications.
E.
Placement of Soil Cover (Radon Cover) 1.
Observe placement and compaction operations to ensure that procedural and equipment requirements are being followed; This includes checking required loose-lift thickness and proper blending of any additives, and if method specifications for density have been established by test fill, verification of number of equipment passes.
2.
Visually check cover layer (s) to ensure proper material type for each layer.
3.
Observe gradation, plasticity index, and/or moisture / density testing and compare results of tests observed with specifications.
F.
Placement of Filter layer (s) and Rock Cover (Riprap) 1.
Observe placement and compaction operations to ensure that procedural and equipment requirements are being followed; For the rock cover and other riprap layers, this includes checking that placement techniques are conducted in a manner that prevents material degradation, assures uniform distribution and minimizes voids.
2.
Visually check the filter zones and riprap layers to ensure proper thickness and material type for each zone.
3.
Visually check riprap for size (maximum, average).
4.
Observe gradation testing of filter and rock layers and compare results of tests observed with specifications.
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Other Potential Observations 1.
Check operations at borrow areas; verify that any procedures for moisture control are properly conducted, and visually check that material type (s) are consistent with specifications.
2.
Check laycut of diversion ditches; Check for conformance to design configuration and riprap requirements.
3.
Check overlap and integrity of geotextile separators, if they are used.
4.
If an approved vegetative cover is used in place of rock cover, check to ensure uniform seeding, use of specified seed type, seed density, etc.
5.
Check overall site grading to assure that cut and fill procedures have produced uniform and even surfaces, which would not be susceptible to future surface erosion.
The reviewer may not be able to directly observe all facets of the activities identified above. However, direct observation of at least some of the important activities should be made; Observation of some field testing should be made at all site inspections.
In some cases it will be necessary to observe a completed activity rather than work in progress.
The intent is to determine whether the activities and/or the end product meet the requirements of the remedial action plan.
Additionally, during work observation, informal interviews with RAC inspection personnel should be randomly conducted to determine how well employees know their work activity. The reviewer should ascertain whether c sufficient number of adequately qualified inspection personnel are at the site, commensurate with the work in progress, and whether they are adequately performing their assigned duties through the established organizational structure.
r IV. Record Review The reviewer should review selected documentation maintained on site to ascertain the following:
1.
Records confirm that required material characteristics and other specification requirements were met.
2.
Records confirm that specified materials were installed in accordance with specifications.
3.
Records indicate that adequate corrective action is being taken following non-concurrence / deviation occurrences.
4.
Records confirm that the required inspections and testing were performed adequately and at required frequencies.
5.
Records establish that QC personnel are adequately qualified for their assigned duties and responsibilities.
V.
Findings All aspects of the construction observed in accordance with the above recommended review activities should be documented in the construction review report.
Findings should address each aspect as being satisfactory, being unresolved and required resolution, or being in conflict with RAP, construction specification, or RAIP requirements and requiring correction.
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