ML20137B680

Forwards Final Draft Proposed Manual Chapter 2620, Insp of Remedial Action at Inactive U Mill Tailing Sites, for Recommendations & Comments by 860115

ML20137B680
Person / Time
Issue date:	12/31/1985
From:	Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Bangart R, Danni Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
References
REF-WM-39 NUDOCS 8601160025
Download: ML20137B680 (10)

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.*86 JM -2 PCO2 MEMORANDUM FOR:

Richard L.- Bangart, Director Division of Radiation Safety and Safeguards, RIV R. Dale Smith, Director Uranium Recovery Field Office, RIV FROM:

James G. Partlow, Director Division of Inspection Programs, IE

SUBJECT:

PROPOSED MC 2620 -

INSPECTION PROCEDURES FOR UMTRCA SITES The final draft of the subject manual chapter and implementing procedures is enclosed for your recommendations and comment.

The proposed chapter has been reviewed by the Division of Waste Management, NMSS. The proposed procedures were prepared by them.

Please provide your comments and recommendations by l

January 15, 1986.

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Jamps G. Partlow, Director Div81sion of Inspection Programs, IE

Enclosure:

As stated

Contact:

D. Sly, IE i

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CHAPTER 2620 i

INSPECTIONS OF REMEDIAL ACTION AT INACTIVE URANIUM MILL TAILING SITES i

(TITLE I, URANIUM MILL TAILINGS RADIATION CONTROL ACT (LHTRCA))

i 2620-01 PURPOSE t

The purpose of this instruction is to provide guidance for planning and r.onducting inspections of the remedial action being carried out to stablize inactive uranium mill tailings sites.

The work is carried out under the t

I direction of DOE' under the autnority of the UMTRCA, Title I.

The Act requires the Nuclear. Regulatory Commission (NRC) to concur with the Depart-ment of Energy (00E) actions to stabilize the sites and afterward to issue t

a license for custody of the material and maintenance of the site to the federal agency that accepts custody of the remedial site.

f 2620-02 OBJECTIVE i

k This chapter establishes the inspection procedures to be used by inspectors monitoring the remedial action work carried out at inactive uranium mill i

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tailings sites by DOE contractors.

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2620-03 DEFINITIONS l

03.01 Remedial action means those work activities carried out to sta-bilize mill tailings and otherwise perform work to assure the tailings pile will conform to the Environmental Protection-Agency (EPA) standards for inactive sites.

03.02 Inspection includes all those actions necessary to monitor the j

activities during the remedial action at inactive tailings j

sites.

An " inspection" is generally referred to as an on-site i

construction review; as the majority of the remedial action is i

" earth moving" construction work.

The inspection does not~

include enforcement action, as NRC does not have the enforcement i

authority for this program under the Act.

2620-04 RESPONSIBILITIES AND AUTHORITIES-04.01 Division of Inspection Proc rams IE.

The Division develops and issues requirements, guic ance, and procedures for the NRC inspection program, and modifies the program as necessary based t

j on experience, performance and other factors.

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INSPECTIONS AT REMEDIAL ACTION AT INACTIVE l*

URANIUM MILL TAILING SITES (TITLE I, URANIUM P

2620-04 MILL TAILINGS RADIATION CONTROL ACT (UMTRCA))

f 04.02 Division of Waste Management, IMSS. - The Division develops and I

issues policy, guidance, and procedures for the uranium recovery licensing program; and directs the NRC program for' evaluation f

and concurrence with DOE remedial action plans for. cleanup of i

inactive uranium mill tailings sites and contaminated vicinity 4

. f properties unde LMTRCA.

h 04.03 Uranium Recovery Field Office (URF0), Region IV.

The Office

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carries out NRC's licensing functions for uranium recovery acti-

!g vities, under programmatic delegation from NMSS; carries out

e programmatic work for remedial action sites as designated and assigned by NMSS; and carries out the NRC inspection program for t

• i activities as assigned by Region IV, including inspection moni-i l toring for remedial actions covered by this procedure.

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2620-05 DISCUSSION g

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The foundation for planning and scheduling inspections during remedial action at inactive tailings sites is the remedial action plan (RAP), pre-pared by DOE and its contractors and issued with NRC concurrence.

This plan includes criteria for all phases of the proposed remedial action.

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I The RAP contains the basic elements of the remedial action but does not always contain specific criteria or procedures for carrying out the work.

The specific criteria and procedures not included in the RAP are developed 6

by the DOE contractor performing the remedial action at the site.

Those procedures are designed to control, verify, and document all remedial l

t action at the site and are referred to collectively as the remedial action i

j inspection plan (RAIP).

The RAP and RAIP are the primary commitments and j

standards used as a basis for the NRC inspections of the remedial action work.

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2620-06 BASIC REQUIREMENTS t

06.01 Most inspection requirements are covered by the procedures in this chapter.

It may be necessary, however, to develop case-i specific procedures to cover a particular site or special pro-cedures to cover highly technical aspects for a particular i

situation.

The need for such procedures should be identified

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as soon as possible so that they may be developed and available f

when needed.

I 06.02 The criteria for inspections for a particular site will be the RAP for the site and the associated RAIP. Guidance for carrying out the inspections shall be incorporated into the procedures

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appended to this chapter.

lI 06.03 The foundation for planning and scheduling inspections will.be

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the DOE schedule for the site and the contractor's "construc-tion" schedule for the remedial action work.

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Issue Date: f I

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INSPECTIONS AT REMEDIAL ACTION AT INACTIVE URANIUM MILL TAILING SITES (TITLE I, URANIUM j

MILL TAILINGS RADIATION CONTROL ACT (UMTRCA))

2620-06.04 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, pro-cesses, or milestones t.s 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 RAP.

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06.07 Results of each inspection shall be conveyed to management

,i representatives of the site contractor and the DOE at a closeout meeting immediately following the inspection.

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06.08 All NRC concerns arising from the inspection shall be clearly

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stated and resolved at the closeout meeting, if possible.

t Generally, all agreements made for resolution of the NRC inspec-t tion concerns shall be in written form and signed by the princi-pals.

06.09 A reasonable completion date shall be established for all unre-

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solved NRC concerns.

Priorities for completion dates will be i

established based on the health and safety significance of the concerns and considering the schedule for orderly completion t

of the remedial action.

l 06.10 The basic procedures for the inspection program are contained in the Appendix to this chapter.

h 06.11 The inspection program at each site should consist of at least f

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 foun-dation 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).

t In many cases, multiple activities can be observed given proper j

scheduling of these inspections.

t Issue Date:

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INSPECTIONS AT REMEDIAL ACTION AT INACTIVE i

URANIUM MILL TAILING SITES (TITLE I, URANIUM 2620-04 MILL TAILINGS RADIATION CONTROL ACT (UMTRCA))

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t Additional inspections may be perfomed as permitted by sched-t ules and budget, if specific site activities warrant them.

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INSPECTIONS AT REMEDIAL ACTION AT INACTIVE

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URANIUM MILL TAILING SITES (TITLE I, URANIUM

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MILL TAILINGS RADIATION CONTROL ACT (UMTRCA))

APPENDIX, 2620 t

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UMTRCA CONSTRUCTION INSPECTION PROCEDURES Ob.iectives The objectives of the on-site review of remedial action construction are'as

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follows:

To detemine by direct observation whether work and inspection per-formance are being accomplished in accordance with specifications and procedures;

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To determine whether the system for preparing and maintaining I

records is functioning properly;

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To determine whether records reflect work accomplishment consis-tent with specifications and procedures; and I

4 i l To determine whether the records and/or work activities indicate l

any generic problems, inadequacies or other weaknesses that could l

impact the acceptability of remedial action.

i j Preparation Applicable portions of the RAP, the final design, and NRC/ DOE comments and responses should be briefly reviewed to determine commitments relative

.l to construction and inspection requirements before performing the -on-site review.

The reviewer should then utilize these documents in a more

i detailed review of the construction specifications, drawings, and RAIP.

Work Observation By direct observation of earthwork in progress, the reviewer should ascer-tain whether applicable activities are being controlled and accomplished in accordance with the requirements of the documents reviewed above.

Key con-struction milestones (listed in Table 1) should be observed as directed in

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Section 06.11 of this chapter.

Specific inspection procedures applicable to these particular construction activities are as follows:

j 1.

Foundation and Subgrade Preparation a.

Check to ensure that the subgrade is cleared of all vegetation j

and topsoil, shows no deterioration due to frost action or_ ero-l sion, and exhibits no rutting from construction vehicles, b.

Check to ensure that the subgrade exhibits no areas of subsi-dence, extreme surface drying, or localized ponding (overly wet areas).

c.

Observe proof rolling operations or density testing; if density -

testing is performed, compare results of tests observed in the field with specifications.

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t INSPECTIONS AT REMEDIAL ACTION AT INACTIVE r

URANIUM MILL TAILING SITES (TITLE I, URANIUM 2620, APPENDIX MILL TAILINGS RADIATION CONTROL ACT (UMTRCA))

ij' if 2.

Placement of Capillary Break i-a.

Observe placement and compaction operations to ensure that pro-i-

cedural and equipment requirements are being followed.

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!I b.

Visually check the capillary break zone to ensure proper thick-ness and material type, and to ensure that segregation of mate-rials has not occurred.

c.

Observe gradation and/or moisture / density testing and compare results of tests observed with specifications.

3.

Placement of Seepage Barrier / Liner 4

a.

Observe placement and compaction operations to ensure that pro-cedural and equipment requirements are being followed.

b.

Visually check the liner zone to ensure proper thickness and t

material type.

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c.

Observe gradation, plasticity index, and/or moisture / density testing and compare results of tests observed with specifica-

=p tions.

4.

Placement of Contaminated Materials i

a.

Observe placement and compaction operations to ensure that pro-cedural and equipment requirements. are being followed.

This 4

includes checking the loose-lift thickness (during placement)

' j against the specifications.

b.

Visually check the quantity, maximum size, and distribution of i

foreign material, and the distribution of organics against the allowable criteria of the specifications.

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c.

c.

Observe moisture / density testing and compare results of tests observed with specifications.

5.

Placement of Soil Cover (Radon Cover) i a.

Observe placement and compaction operations to ensure that l

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 j

density have been established by test fill, verification of I

number of equipment passes.

b.

Visually check cover layer (s) to ensure proper material type for l

j each layer.

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INSPECTIONS AT REMEDIAL ACTION AT INACTIVE i

URANIUM MILL TAILING SITES (TITLE I, URANIUM MILL TAILINGS RADIATION CONTROL ACT (UMTRCA))

APPENDIX. 2620 i

b c.

Observe gradation, plasticity index, and/or moisture / density testing and compare results of tests observed with specifica-i tions.

j 6.

Placement of Filter Layer (s) and Rock Cover (Riprap) f a.

Observe placement and compaction operations to ensure that pro-cedural and equipment requirements are being followed.

For the rock cover and other riprap layers, this includes checking that i

placement techniques are conducted in a manner that prevents material degradation, assures uniform distribution and minimizes voids.

I b.

Visually check the filter zones and riprap layers to ensure pro-j per thickness and material type for each zone.

c.

Visually check riprap for size (maximum, average).

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Observe gradation testing of filter and rock layers and compare I

results of tests observed with specifications.

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Other Potential Observations hi a.

Check operations at borrow areas; verify that any procedures for g

moisture control and properly conducted; and visually check that a

material type (s) are consistent with specifications.

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b.

Check layout of diversion ditches.

Check for conformance to

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design configuration and riprap requirements.

4 c.

Check overlap and integrity of geotextile separators, if they are used.

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If an approved vegetative cover is used in place of rock cover, check to ensure uniform seeding, use of specified seed type, l

seed density, etc.

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Check overall site grading to assure that cut and fill proce-

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i dures, which would not be susceptible to future surface erasion.

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The reviewer may not be able to directly observe all facets of the activi-l ties identified above.

However, direct observation of at least some of the j

important activities should be made.

Observation of some field testing should be made at all site inspections.

In some cases, it will be neces-i?

sary to observe a completed activity rather than work in progress.

The intent is to determine whether the activities and/or the end product meet j

l the requirements of the remedial action plan.

Additionally, during wo_rk observation, informal interviews with RAP inspec-i tion personnel should be randomly conducted to determine how well employees know their work activity.

The reviewer should ascertain whether a suffi-f cient number of adequately qualified inspection personnel are at the-site, i

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INSPECTIONS AT REMEDIAL ACTION AT INACTIVE URANIUM MILL TAILING SITES (TITLE I, URANIUM 2620, APPENDIX MILL TAILINGS RADIATION CONTROL ACT (UMTRCA))

commensurate with the work in progress, and whether they are adequately performing their assigned ' duties through the established organizational structure.

Record Review w

1 The reviewer should review selected documentation maintained on site to ascertain the following:

a.

Records confirm that required material characteristics and other specification requirements were met.

2 b.

Records confirm that specified materials were installed in accor-dance with specifications.

l c.

Records indicate that adequate corrective action is being taken fol-g lowing'non-concurrence / deviation occurrences.

d.

Records confirm that the required inspections and testing were per-g formed adequately and at required frequencies.

e.

Records established that QC personnel are adequately qualified for

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their assigned duties and responsibilities.

Findings i

All aspects of the construction observed in accordance with the above recommended review activities should be documented in the construction i

review report.

Findings should address each aspect as being satisfactory, being unresolved and requiring resolution, or being in conflict with RAP, construction specification, or RAIP requirements and requiring correction.

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t INSPECTIONS AT REMEDIAL ACTION AT INACTIVE

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URANIUM MILL TAILING SITES (TITLE I, URANIUM i,

MILL TAILINGS RADIATION CONTROL ACT (UMTRCA))

TABLE I, 2620 1

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KEY CONSTRUCfl0N MILESTONES f

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Foundation and Subgrade Preparation

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2.

Placement of Capillary Break I

3.

Placement of Seepage Barrier / Liner t

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4.

Placement of Contamineted Materials 5.

Placement of Soil Cover (Radon Barrier) 6.

Placement of Filter Layer (s) and Rock Cover t

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3 May or may not apply to a particular site depending on site-specific design.

I Will apply to all material action sites.

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Will apply to nearly all sites (vegetative cover may be proposed for 1 or 2 sites).

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