ML20138G914

Forwards Criteria for Preparation of Technical Evaluation Memo Re Final Remedial Action Plan (Rap).Suggests That Tl Johnson Provide Direct Input to Project.Tentative Review Schedule for Lakeview RAP Also Encl

ML20138G914
Person / Time
Issue date:	09/16/1985
From:	Higginbotham L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Knapp M, Rich Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
REF-WM-64 NUDOCS 8510280087
Download: ML20138G914 (9)

Text

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DISTRIBUTION:

SEP H Eg WM s/f WMLU r/f L.4/GG/85/09/03 NMSS r/f RE Browning MEMORANDUM FOR: R. Dale Smith, Director MJ Bell J0 Bunting i

Uranium Recovery Field Office, Region IV g[inbotham Malcolm R. Knapp, Chief G Gnugnoli Geotechnical Branch M Fliegel Division of Waste Management, hMSS hf UN 6 s

FROM: Leo 8. Higginbotham, Chief E RF0 Low-Level Waste and Uranium Recovery Projects Branch .,

Division of Waste Management, NMSS

SUBJECT:

INITIATION OF TECHNICAL EVALUATION MEMCRANDUM (TEM)

SUPPORTING NRC'S DECISION ON CONCURRENCE FOR THE LAKEVIEW, OREGON UMTRAP SITE REMEDIAL ACTION PLAN (RAP)

It has been our policy to produce TEMs supporting our decisions on the final RAPS for UMTRAP. This provides an established record containing the technical basis for our RAP decisions. Since DOE has recently provided responses to our comments on the draf t RAP and EA for Lakeview, it is appropriate to begin the documentation process which culminates in the creation of the TEM. Guidance is provided in Enclosure 1.

Since T.L. Johnson (WMGT) has been providing technical support directly to URF0 in the area of sur' ace-water hydrology, he should provide direct input into the creation of the TEM by URF0.

A tentative schedule is enclosed (Encic,sure 2) which outlines activities associated with the NRC review of the Lakeview RAP over the next few months.

Should you have a problem with either the TEM or the schedule, contact G. Gnugnoli at (FTS) 427-4788.

Original signdt by leo H, Higginbotham

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• 8510280087 PDR 850916 Low-level Waste and Uranium Recovery WASTE WM-64 PDR Projects Branch Division of Waste Management, NMSS

Enclosures:

V.M Rd fib'

1. Guidelines for Preparation YlMProlzt of the TEM *

2. Tentative Activities Scheduled FDR.I for Lakeview LPUL--_

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ENCLOSURE 1 Criteria for Preparation of a Technical Evaluation Memorandum (TEM)

The TEM is a memorandum documenting the technical review of a RAP for a l specific UMTRAP site. The areas to be covered include:

1. Erosion Protection - Evaluation of adequacy of the erosion protection designed for an UMTRAP disposal site with respect to the EPA standard.

2. Geotechnical Stability - Evaluation of geotechnical stability design aspects with respect to the EPA standard.

3. Geology / Seismology - This discipline may be factored into the geotechnical stability evaluation.

4. Water Resources - Evaluation of protection against existing and future ground-water contamination. This evaluation should be consistent with the 2

EPA recommendations in Subpart C of the inactive site standards. This includes a justifiable determination of the need for any aquifer restoration.

5. Radon Attentuation - Evaluation of the adequacy of the soil cover design with respect to the EPA radon control standard.

The TEMS should specify what was reviewed, what criteria were applied, what conclusions were reached and what recommendations were made by each reviewer on the basis of the technical analysis and conclusions.

The TEM should conclude with an overall acceptability determination indicating which technical areas evaluated were fully acceptable, and which areas were i not. Those technical areas not meeting acceptability must be identified by a clear, concise statement delineating what prevents acceptability.

Attached is a portion of the guidance relating to NRC review of UMTRA Remedial Action Plans. More specific explanations relating to generating a TEM are contained in this attachment.

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CRGANIZATION AND CONTENTS OF REMEDIAL ACTION PLAN

. CONCURRENCE REVIEW DOCUMENTATION In order for NRC to concur with a DOE selection of remedial action, as documented in a Remedial Action Plan (RAP), certain determinations must be made. It must be found as a result of PAP review that: *

, (i) there is reasonable assurance of coroliance with the EPt requirements for durability of stabilization and centrol of radon ir, 40 CFR 192.02; and

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(ii) the remedial action provides those measures for protection against j existing and future. ground water. contamination determined to be

' needed as a result of following EPA guidance for decision-making in

• this area provided in 40 CFR 192.20.

In order for WMLU to make the necessary findings and issue the required NRC concurrence decision, supporting technical reviews and evaluations are performed within WMEG and WMGT. These supporting reviews are conducted, and the results are reported to WMLU. These reviews and their results then become i

I the supporting basis for the overall concurrence decision.

Occumer.tation of the supporting reviews conducted and the conclusions reached is required for the records. The purpose of this guidance is to provide the basic framework and ground rules for such documentation in order that the documentation process may be conducted efficiently and effectively. The basic procedure that has been settled on is to have reviews documented in the form of

" Technical Evaluation Memoranda (TEMs)", issued from the Chiefs of WMEG and WMGT to the Chief of WMLU, with a copy to the appropriate WM Project File.

Some basic objectives and characteristics of these memoranda are:

General: They should serve the same purpose as backup memoranda in support of licensing action. They should specify what was reviewed, what criteria were applied, what conclusions were reached, and what recommendations the reviewer makes on the basis of the technical conclusions reached.

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Coverate: As a group, the TEMs should provide a full and adequate basis for concurrence decisions. For example, all stabilizatice failure modes must be addressed, but not necessarily in the same TEM.

Seoarability: Ccverage requirements should be specified ano divided among tne required TEMs so that there is a clear definiticn of what each TEM is to cover, and they can be prepared and issued reasonably independently.

Issue Definition: Each TEM should conclude with either a statement of acceptability for the evaluation areas covered, or a clear and concise statement as to specifically what prevents full acceptability. Such "open items" should be well defined, and should be accompanied by further information and explanation that will be useful to DOE in understanding and resolving the problem.

Consistency: Once a particular scope, fcreat, and content are settled on for eacn TEM, others should be prepared in a similar manner. This will proccte consistency and efficiency of reviews by use of the same organizattun of review subjects and acceptarce criteria.

T nif' nt steps in the overall review process are listec in Table 3.1

, which in part illustrates hcw the TEMs would be used and when*

they woul e needed. The TEMs to be generated are listed in Table 4.1 which aisc details the review topics and failure mechanisms to'be addressed by each TEM. A suggested generic outline for TEMs is provided in Table 4.2 The TEMs are geared to support concurrence decisions. The essential product desired in each TEM is an unambiguous finding as to compliance with the EPA standards. 'It is intended that no conditional (cr other) concurrence be issued until all TEMs have been finalizec (or at least : heir conclusions). Once that has occurred, a concurrence would be issued, but made conditional on resolution of open items identified in the TENS.

In addition to open concurrence items TEM conclusions may include recommendations, suggestions or comments useful to transmit to DOE merely for their information and use. These should be clearly distinguished from deficiencies.which would block concurrence. There are three TEMs to cover compliance with the EPA radon and stability standards, and one to cover consistency with EPA groundwater guidance and adequacy of protection against ground-water contamination.

The groundwater TEM is different from the others because of the difference in the function it is to serve. For instance: (1) there are no firm ground-water i

protection requirements or criteria, only guidelines for judgements; and (E) the concept of " failure modes" is not very usefully applied.

We expect the ground water TEM to be generated as a result of concurrence reviews for all processing and disposal sites, and expect full concurrence to be blocked by any significant ground-water protection deficiencies. The primary mechanism for evaluation of the adequacy of proposed ground-water protection measures is to review DOE's proposals for consistency with EPA's guidance on. ground-water considerations (40 CFR 192.20). However, we do not intend,to deny concurrence merely due to inconsistencies with EPA's guidelines, provided that the final decision on protection measures is acceptable.

Procedures for quality assurance and control during remedial action will be documented by DOE on a site-specific basis in a Remedial Action Inspection Plan (RAIP), which is generated following the RAP concurrence process. As it is necessary to have acceptable quality assurance and control procedures to have reasonable assurar.ca of meeting the EPA standards, RAP concurrences will be conditional on review and concurrence of a site-specific RAIP. Review of RAIP documentswill be processed internally as supplements to RAPS, requiring appropriate revisions or supplements to TEMs.

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TABLE 3.1 NRC REMEDIAL ACTION PLAN REVIE4 PROCESS Step Action Teken ORAFT REMEDIAL ACTION PLAN REVIEW:

1. 00E submits preliminary or draft plan to NRC.

2. WMLU issues copies of WMEG and WMGT with Technical Assistance Recuest (TAR) forms.

3. WMEG and WMGT complete assigned reviews and provide preliminary cccclusions ard comments to WMLU.

4 WMLU prepares and transmits response to 00E.

FINAL PEMEDIAL ACTION PLAN REVIEW :

5. .

- COE submits final plan to NRC. ,

6. WMLU issues copies to WMEG and WiiGT with TARS.

7. WMEG and WMGT complete assigned reviews and provide Technical Evaluation Memos (TEMs) to WMLU* under Branch Chief signature.

8. WMLU prepares and transmits response to DOE (normally a concurrer.ce conditioned on satisfactory resolution of open items).

REVIEW OF FOLLOWUP RESPONSES AfiD REVISIONS:

9. DOE responds to open items which are ccnditions of concurrence, er revises or supplements plans.

10. WMLU issues copies to WMEG and/or WMGT with TARS.

11. WMEG and/or WMGT complete assigned reviews and provide amendments or supplements to previous TEMs to WMLU.

12. WMLU prepares and transmits response to DOE.

13. Repeat Steps 9-12 as necessary to resolve residual open items or process 00E-initiated revisions to remedial action plans.

• TEMs may be begun earlier in the overall review process, or completed later i

' if necessary to balance workloads. The review conclusions (open items preventing acceptability) must be documented to. conclude this step, however.

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s-Table

4.1 TECHNICAL EVALUATION

MEMORANDA DOCUMENTING DOE RAP REVILWS ,

e Title / Major Responsible Primary Review Topic (s) failure Mechanisms of Concern NO. ' '

Adequacy at erosion protection design Incident precipitation runoff erosion.

1. Erosioq Protection. flood or streambank ernsion. Wind WMGT with respect to EPA stability standard. erosion. Rock durability (WMEG input). .

Genmorphologic process failure. ;l Geotechnical Stability, Adequacy of geotechical stability design Static stability. Dynamic stability 'l

2. (hMGT input). Differential settlement.  !!

WMEG aspects with respect to EPA stability Settlement. Liquefaction potential. I' standard.  :

Adequacy of radon attenuation design Insufficient thickness. Loss of design !l j 3. Radon Attenuation,  !

WNEG with respect to EPA radon control soll moisture content. Dessication standard. cracking. koot penetration, animal burrowing.

Adequacy of protection against existing Erroneous definition of contaminant plumes.

4. Water Resources, transport potential, human exposure potential.

and future groundwater contamination.*

WMGT Consister.cy with EPA recommendations Continued contaminant leaching. Insufficient i-on ground water considerations.** monitoring, mitigation.

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• The " Water Resources" TEM is to be generated for all sites. Identified deficiencies in this area will be p concurrence matters, even for sites NRC will not Ilcense.

a *cReview in this area is for the primary purpose of determining the adequacy of protection against contamination. Inconsistencies with EPA guidelines are tolerable provided that there is 6 L.

g reasonable assurance of the adequacy of the protection measures included in the remedial action.

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• 4 TABLE 4.2 RECOMMENDED OUTLINE FOR TECHNICAL EVALUATION MEH0RANDA

1. Erosion Prctection A. Hydrologic description

2. Geomorphic considerations C. Flood determinations D. Erosion protection E. Rock cover durability F. Upstream dan failures G. Construction considerations H. Conclusions

2. Geotechnical Stability A. Geologic /Geotechnical site characterization ,

B. Seiscotectonic site characterization C. Slope Stability D. Settlement E. Liquefaction F. Soil cover engineering properties G. . Construction cor.siderations' ,

H. Conclusions

3. Radon Attenuatior. j A. Tailings characterization properties B. Long-term cover moisture C. Other cover characterization properties

• D. Calculational methodology E. Conclusions .

4 Water Resources A. Hydrogeologic setting B. Groundwater quality C. Extent of groundwater contaminatiun D. Impacts of contamination

E, Protective action F. Conclusions l

o s ENCLOSURE 2 Tentative Lakeview Schedule i

Activity Date T.L. Johnson to provide to URF0 preliminary 9/09/85 comments on 00E 8/20/85 responses to NRC comments regarding erosion protection design.

URF0 completes evaluation of DOE 8/20/85 responses 9/25/85 and meets with DOE, NRC/WM staff, Oregon DOE staff in Albuquerque, NM.

DOE to provide final RAP to NRC for review and 10/04/85 concurrence.

Initial comments on RAP completed by URF0 and 10/18/85 T.L. Johnson (WMGT).

Meeting with DOE, NRC/WM staff, and URF0 in 10/23/85 Denver, C0 to discuss initial comments on final -

RAP.

URF0 review and recommendations on final RAP are 10/31/85 completed for URF0 Management review.

URF0 transmits formal review and recommendations 11/04/85 to WMLU.

NRC transmits concurrence decision to 00E. 11/12/85 URF0,withT.L. Johnson (WMGT) input, completes 12/06/85 initial draf t of TEM and provides draft to WMLU.

WMLU review of TEM completed and provided to URF0 12/20/85 for revision.

URF0 completes TEM and transmits it to WMLU. 1/22/86

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