ML20140B973

Completion Review Rept for Remedial Action at Grand Junction,Co U Processing Site

ML20140B973
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Issue date:	03/31/1997
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
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REF-WM-54 NUDOCS 9704010554
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4 COMPLETION REVIEW REPORT i

i-FOR THE REMEDIAL ACTION 1

AT THE GRAND JUNCTION, COLORADO URANIUM PROCESSING SITE MARCH 1997

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DIVISION OF. WASTE MANAGEMENT U.S. NUCLEAR REGULATORY COMMISSION 9704010554 970328 PDR WASTE WM-54 PDR

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TABLE OF CONTENTS Title Page 1.0 Introduction.........................

1 2.0 Background........................... I 2.1 UMTRCA.......................... I j

2.3 Concurrence Process for the Performance........

2 of DOE's Remedial Actions 2.4 Grand Junction Processing Site............

2 2.5 Completion Review Report Organization.........

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3.0 Analysis of DOE Remedial Action Performance.........

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3.1 Previous Actions...................

4 3.2 Review of Remedial Action Performance.........

4 4.0 Summary...........................

7 5.0 References.........................

7 Appendix A............................ A-1 NRC Site Visits to the Grand Junction Processing Site Appendix B............................ B-1 UMTRCA, the EPA Standards, and the Phased UMTRA Project Appendix C............................ C-1 Verification of Remedial Action Plan Requirements

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GRAND JUNCTION, COLORADO, PROCESSING SITE COMPLETION REVIEW REPORT l

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1.0 INTRODUCTION

The Grand Junction processing site is one of the 24 abandoned uranium mill tailings sites to be remediated by the U.S. Department of Energy (D0E) under

'the Uranium Mill Tailings Radiation Control Act of 1978-(UMTRCA).

UMTRCA requires, pursuant to Section 104(f)(1), that the U.S. Nuclear Regulatory l

Commission concur ~with the DOE's determination that the remedial action has 1

been properly completed. This Completion Review Report (CRR) documents the NRC staff's basis for its concurrence decision with respect to DOE's Certification Summary for the completion of cleanup at the Grand Junction processing site.

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2.0 BACKGROUND

2.1 UMTRCA Title I of UMTRCA provides for remedial action at abandoned uranium mill l

tailings sites and associated vicinity properties.

The purpose of this legislation is to protect the public health and safety and the environment l

from radiological and non-radiological hazards associated with the process l

related materials at these sites.

UMTRCA directs DOE to select and perform remedial actions at 24 abandoned uranium mill tailings sites to ensure compliance with the general environmental standards promulgated by the U.S. 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 B includes a more detailed discussion of this legislation.

2.2 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).

The RAP describes the series of activities and presents the design proposed by DOE to provide for the long term protection of the public and the environment.

Usually this involves cleanup of the processing site, adjacent windblown areas, and vicinity properties, in addition to stabilization of the residual radioactive materials.

In addition, DOE issues a Remedial Action Inspection i

Plan (RAIP), which establishes the quality control program of testing and inspection that will be employed for-the remedial action.

In accordance with Grand Junction CRR 1

March 1997

I UMTRCA Section 108(a)(1), the NRC staff reviews and concurs with the RAP and the RAIP, and any subsequent modifications.

By its concurrence in the remedial action selection, the NRC staff concludes that the planned remedial i

actions will comply with EPA's applicable standards in 40 CFR 192, Subparts A, B, and C.

The basis for the concurrence in DOE's selection of remedial action is documented in a Technical Evaluation Report (TER).

2.3 CONCURRENCE PROCESS FOR THE PERFORMANCE OF DOE'S REMEDIAL ACTIONS The remedial action work is performed by DOE contractors under Federal procurement regulations.

During the remedial action, DOE inspects and documents activities in accordance with the Uranium Mill Tailings Remedial Action (UMTRA) Project Quality Assurance Plan, the RAIP, and the RAP.

In addition, the NRC staff conducts site visits or inspections of the site, as determined necessary.

Upon completion of the remedial action, DOE compiles cleanup and construction (in the case of a disposal site) records and prepares a completion report (CR) to document that remedial actions were performed in accordance with the RAP or RAP modifications, and the RAIP.

Based on this information, 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.

Based on its review of DOE's documentation, and on its site visits and observations, NRC makes a concurrence decision with regard to DOE's remedial action completion determination for each site, and then documents the basis for this concurrence decision in the CRPs.

By its concurrence in the remedial action performance, the NRC staff concludes that the remedial action has been completed in accordance with the NRC approved plan. NRC's concurrence with DOE's completion determination fulfills the Commission's responsibility under UMTRCA Section 104(f)(1).

Because contaminated materials from the Grand Junction processing site were relocated for stabilization at a separate site (Cheney site), DOE's CR, and therefore this CRR, deal only with the remedial actions for cleanup of the processing site (Climax site). DOE will provide, under separate cover for NRC's concurrence, a CR for the Cheney disposal site.

2.4 GRAND JUNCTION PROCESSING SITE The 105 acre Grand Junction uranium mill tailings processing site is located in Mesa County, Colorado, on the south-southeast side of Grand Junction at the city limits.

The processing site is located in the floodplain of the Colorado River, on the north side of the river, approximately 0.75 miles upstream from where the Gunnison River joins the Colorado.

The Climax Uranium Company opened its mill in Grand Junction in 1951.

The mill was designed and built for the production of uranium, with capability for by-product vanadium production.

Processing capability of the mill was 330 tons or ore per day at its opening, increasing to 500 tons per day in 1955.

The mill used an acid-leaching and solvent extraction process to recover uranium from sand.

Slimes were salt roasted and water-leached to remove vanadium, and then acid-leached by solvent-extraction to extract uranium and any remaining vanadium.

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During the mill's operation period, approximately 4.6 million tons of tailings were produced.

From 1951 to 1966, approximately 500,000 cubic yards of tailings were released by the mill owners to private individuals and contractors for use around Grand Junction as fill material.

The properties where tailings were used for construction are now known as " vicinity.

properties" and are part of the Grand Junction cleanup effort.

In 1960 the Climax Uranium Company was incorporated into American Metals Climax, Inc., which operated the mill until early 1970.

From late 1970 to early 1971, the mill was dismantled and tailings at the site were stabilized j

in place. Contaminated materials removed from vicinity properties around Grand Junction were placed in the evaporation ponds located at the Climax

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site.

The Climax site is owned by the state of Colorado. The city of Grand Junction plans to turn the remediated site into a park.

Prior to remediation, the tailings site consisted of structures and facilities located on the northwest side of the site, the tailings pile area, and pond i

areas where the vicinity property materials were located.

Radium-226 concentrations in the tailings measured fron near background to approximately 7600 pCi/g. Average on-site radon concentration was approximately 30 pCi/L.

Remedial action included demolition and/or decontamination of site buildings, excavation and removal of tailings and contaminated vicinity property material, and site restoration, such as grading, seeding, and wetland installation. A total of 4,425,244 cubic yards of contaminated material was relocated to the Cheney disposal site and the site cleanup was verified according to EPA standards. The site was recontoured with 639,969 cubic yards of uncontaminated fill and most of the site was covered with topsoil and reseeded. Twenty acres were restered as wetlands.

Reclamation activities were conducted by DOE and its contractors. DOE obtained NRC concurrence in the cleanup activities.

NRC staff also performed periodic on-site reviews to monitor the progress of the remedial action activities (See Appendix A).

1 2.5 COMPLETION REVIEW REPORT ORGANIZATION The purpose of this CRR is to document the NRC staff review of DOE's Grand Junction processing (Climax) site CR.

Because contaminated materials from the Climax site were relocated for disposal at the Cheney site, DOE's CR deals only with the cleanup activities at the Climax site. Therefore, this CRR also deals only with NRC's review of the completion of cleanup at the Climax processing site. DOE's CR of the construction of the Cheney disposal cell will be submitted as a separate document and NRC will complete a separate CRR for that review. Appendix A provides a listing of NRC staff visits to the Grand Junction processing site. Appendix B provides a detailed description of the requirements of UMTRCA and the resulting phased process of the UMTRA project.

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l 3.b ANALYSIS OF DOE REMEDIAL ACTION PERFORMANCE l

t 3.1 PREVIOUS ACTIONS NRC staff, based on its review of the RAP (D0E,1991a - f), and the RAIP (DOE, l

1991) concurred that the remedial action, as proposed in the RAP, would meet the applicable EPA standards.

This concurrence was based on technical l

findings that there is reasonable assurance that the selection of the remedial action for the Grand Junction Processing Site would meet the standards for radon attenuation, and cleanup of contaminated land and buildings.

The NRC notified DOE that it had completed its review of the final RAP and the RAIP on July 18, 1994, and signed the original. signature pages signifying the NRC's concurrence in the remedial action on December 6,1994. The basis for the NRC staff's concurrence in DOE's selection of remedial action at the Grand Junction site is documented in a Technical Evaluation Report (TER) issued in July 1994 (NRC, 1994).

3.2 REVIEW 0F REMEDIAL ACTION PERFORMANCE 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, any RAP modifications or Project Interface Documents, and the RAIP, and if not, that deviations to these specifications still result in compliance with the EPA standards.

In support of this action, the NRC staff participated in site reviews (See Appendix A), field observations, assessments of on-site data and records, and review of DOE Site Audit Reports.

The results of the staff's review of the remedial action are contained in this section of the CRR.

For the Grand Junction Processing site remedial action completion review, the pertinent technical discipline is radiation protection.

Radiation Cleanup Review The NRC staff reviewed radiation protection aspects of remedial actions at the Grand Junction processing site to ensure that cleanup of residual radioactive materials was performed in accordance with specifications in the RAP, RAIP, and the final design.

Areas of review included contaminated material excavation, verification of cleanup, laboratory and field testing, and quality assurance audits. The review was mainly based on NRC staff assessment of the verification results presented in the DOE CR for the Grand Junction Processing Site.

The criteria for site cleanup were established in the RAP and concurred in by NRC staff as providing assurance that the processing site and disposal cell would meet the EPA requirements of 40 CFR Part 192. The criterion for soil radium (Ra-226) requires cleanup at the processing site and on adjacent lands to levels complying with the applicable EPA standards (40 CFR 192.12) such Grand Junction CRR 4

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1 that the average Ra-226 levels above background in each 100 m area (grid) do 2

not exceed either 5 pCi/g in the top 15 cm of soil, or 15 pCi/g in any underlying 15-cm layer. A supplemental cleanup standard for thorium (Th-230) was proposed in the RAP in the event an area contained significant Th-230 levels at a depth below the excavation depth for Ra-226, as required by l

40 CFR 192.21(h).

The supplemental standard was based on meeting either the 1000-year Ra-226 level, or the interior radon progeny limit (assumes a house would be built over the deposit) within 1000 years.

For cleanup of building surface contamination, DOE directed [ letter from DOE UMTRA Project Office to DOE contractor, MX-Ferguson Company (MX-F), January 22,1992] the use of the release criteria for uranium and associated decay products as stated in NRC Regulatory Guide 1.86.

The revised radiological assessment for buildings left at the site (CR Appendix J) indicates that dose and contamination limits from DOE Order 5400.5 were applied. The release limits in both documents are:

5,000 total (fixed plus removable) averaged over not more than 1 meter,15,000 maximum total and 1,000 removable, dpm/100 2

cm for alpha or beta-gamma, and beta-gamma should not exceed an average and maximum of 0.2 and 1.0 mrad /hr, respectively, at I cm.

During review of the radiation protection aspects of the remedial action completion docunentation for the processing site, the NRC staff noted the following:

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

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The radiological survey records support compliance with EPA's soil cleanup standards in Subpart B of 40 CFR Part 192, based on field data (5059 samples).

Five quality assurance (laboratory) sample results, all from Grid F, indicate that the Ra-226 standard of 17 pCi/g (15 + background of 2 pCi/g) was exceeded.

Because the highest value for these samples was 20 pCi/g, and the area will be used as a park, NRC staff considers this acceptable.

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Two buildings (brick warehouse and quonset hut) that are located on private property, but are considered to be part of the designated site, were cleaned by DOE and remain at the site. However, elevated fixed surface readings (alpha and beta-gamma) remain on the exterior of both buildings. DOE and the State of Colorado agreed that no further decontamination work on the warehouse was necessary (DOE letter to MK-F, January 4, 1994). The State of Colorado (letter of February 13, 1997, from J. Deckler, State of Colorado, to J. Pape, DOE) reviewed the projected radon dose from the buildings and concluded that the Grand Junction site cleanup was complete. NRC staff also finds the building cleanup to be acceptable.

In Appendix J to the CR, DOE's radiological assessment indicates that the annual dose limit is 100 mrem for the public.

However, both DOE and NRC regulations and guidance recognize this as a limit for all residual sources considering all pathways. Although the buildings were cleaned to l

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.' meet the 100 mrem /yr Hmit specified in DOE order 5400.5, the soil around the buildings was lot clearad to background levels of Ra-226 and Th-230.

However, DOE utilized conservative parameters in the dose modeling and the results indicate that only the skin dose limit would be exceeded and only at the quonset hut, assuming someone is located next to the area of maximum contamination continuously for one year.

Three of the 565 measurements on the warehouse exceed the NRC maximum 2

contaminati;n release limit (15,000 dpm/100 cm ), but the highest surface activity ca the warehouse is on the north wall, 26 feet from the ground.

DOE dose modeling indicates that someone standing one foot from 10,740 2

dpm/100 cm continuously for a year, or a demolition worker on site two days would receive doses of 16.2.and 1.3 mrem / year, respectively.

The exterior walls (ends) of the quonset hut had 10 of 40 total alpha measurements above the maximum release limit, with the 7 highest (25,455 2

to 38,909 dpm/100 cm ) on the south foundation.

The north and south foundations of the quonset hut also had beta-gamma readings up to 77,300 2

dpm/100 cm. DOE dose modeling indicates that someone standing one foot away from the highest reading for one year, or a demolition worker on site for two days would receive doses of 41.7 and 6.1 mrem, respectively.

To verify DOE's conclusions regarding the buildings, NRC staff and DOE used the RESRAD-Build code for interior contamination.

The NRC staff, in its assessment, modified parameter values to simulate outdoor conditions.

Staff assumed an exposure time of 250 hr/yr at the location of the hig, hest readings on the quonset hut with an exposure volume of 11.3 m (400 ft ),

and increased the values based on alpha readings to reflect equilibrium with the beta-gamma based concentrations.

The resulting dose was 24 mrem /yr, primarily from inhaled particulates.

Staff also modelled a scenario where the most contaminated bricks from the warehouse were assumed to make up an internal wall of a building. The resulting dose was 7.4 mrem /yr.

Based on these results with reasonably conservative exposure scenarios, staff is confident that no one will receive a significant dose due to the remaining contamination on the exterior of these buildings.

However, NRC staff is concerned about the potential for contamination to be released should the buildings be demolished or the bricks be reused.

Therefore, staff expects information relative to the quonset hut and warehouse to be placed in DOE's database to be made available to the State of Colorado at the termination of the UMTRA Program, to facilitate tracking and control of the contamination associated with the two buildings should the property be sold or the buildings be demolished.

DOE has agreed that this will be done.

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Supplemental standards were applied for the cleanup of thorium (Th-230).

Th-230 was measured for 509 grids.

The highest Th-230 value measured was 33 pCi/g, which is acceptable under the UMTRA Project Generic Thorium Policy, as long as reasonable efforts were made to reduce the level.

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Approximately 20 acres along the southwest edge of the site (river bank) were remediated and wetlands vegetation was restored.

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The' bulk determination of radionuclides (cobbles-fines procedure) was proposed in the RAP for us' on part of the site, but the procedure was not l

e used.

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SUMMARY

Based on the above observations and on the results of on-site reviews conducted by staff during site cleanup, the NRC staff has determined that DOE j

has performed remedial actions at the Grand Junction Processing Site in j

accordance with specifications in the RAP, addenda to the RAP, other supporting documents, and the EPA standards in 40 CFR Part 192, Subparts A-C.

With the exception of the groundwater cleanup, remedial actions are complete for the processing site.

DOE has proposed deferral of selection and performance of a groundwater cleanup program at this time, and plans to handle these matters as part of a separate UMTRA groundwater restoration program.

The NRC staff considers DOE's deferral to be acceptable, and therefore, hereby concurs in completion of the Grand Junction Processing Site remedial action.

5.0 REFERENCES

00E,1991, Remedial Action Plan and Final Design for Stabilization of the Inactive Uranium Mill Tailings at Grand Junction, Colorado: U.S.

Department of Energy, Final, UMTRA-00E/AL 050505.0000, September 1991.

MK-Ferguson Company,1991, Remedial Action Inspection Plan, Grand Junction, Colorado: July 1991.

j NRC,1994, Final Technical Evaluation Report for the Proposed Remedial Action at the Grand Junction Uranium Mill Tailings Site, Grand Junction, j

Colorado: U.S. Nuclear Regulatory Commission, July 1994.

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l APPENDIX A i

NRC SITE VISITS TO THE GRAND JUNCTION PROCESSING SITE l

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F APPENDIX A NRC SITE VISITS TO THE GRAND JUNCTION PROCESSING SITE QAIE NAME/ TITLE PURPOSE 2/9/83 G. Pangburn/ Project Manager Site review 3/25/83 E. Hawkins/ Project Manager Discuss approach for R. Pennifill and remedial action H. Pettengill/Geotechnical Engineer 8/3/88-S. Wastler/ Project Manager Observe progress of i

J. Grimm / Geologist cleanup L. Deering/ Hydrologist 10/24/90 M. Thaggard, Hydrologist Site review 6/13/95 C. Abrams/ Project Manager Site review D. Gillen/ Assistant Branch Chief J. Holonich/ Branch Chief 1

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i APPENDIX B 1

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UNTRCA, THE EPA STANDARDS, AND THE PHASED UMTRA PROJECT i

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

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The Standards

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UMTRCA charged the EPA with the responsibility for promulgating remedial action standards for inactive uranium mill sites.

The purpose of these standards is to protect the public health and safety and the environment from 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:

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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 [40 CFR 192.02(a)].

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Provide reasonable assurance that the disposal site design shall prevent radon-222 from residual radioactive material to the atmosphere from exceeding an average release rate of 20 picocuries per square meter per second, or from increasing the annual average concentration of radon-222 in air, at or above any location outside the disposal site, by more than one-half picocurie per liter [40 CFR 192.02(b)].

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The remedial action shall be conducted so as to provide reasonable assurance that, as a result of residual radioactive materials from any designated processing site, the concentrations of radium-226 in land 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 15 centimeter thick layers of soil more than 15 centimeters below the surface [40 CFR 192.12(a)].

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The objective of remedial action involving buildings shall be, and reasonable effort shall be made to achieve, an annual average (or equivalent) radon decay product concentration (including background) not to exceed 0.02 WL and the level of gamma radiation shall not exceed the background level by more than 20 microroentgens per hour [40 CFR 192.12(b)].

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The portion of the EPA standards dealing with groundwater requirements, 40 CFR 192.20(a)(2)-(3) were remanded by the Tenth Circuit Court of Appeals on September 3, 1985. Based on this court decision, EPA was directed to promulgate new groundwater standards.

EPA proposed these standards in the 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.

DOE 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 groundwater protection standards may be unnecessarily complicated and expensive and may not yield commensurate benefits in terms of human and environmental protection.

Therefore, the Commission believes that sites where remedial action has been essentially completed prior to EPA's promulgation of final groundwater standards will not be impacted by the final groundwater standards.

Although additional effort may be appropriate to assess and clean up contaminated groundwater at these sites, the existing designs of the disposal sites should be considered sufficient to provide long-term protection against future groundwater contamination.

NRC does not view UMTRCA 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 (Desian) 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 RAP 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 will review the RAP and then concur that the RAP will meet the EPA standards.

The Performance (Construction) Phase In this phase the actual remedial action (which includes decontamination, decommissioning, and reclamation) at the site is done in accordance with the i

f RAP. 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 remedial action activities at the site, NRC concurs in DOE's determination that the activities at the site have been completed in accordance with the approved plan.

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'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 custody to provide for long-term Federal control.

Disposal sites on Indian land will remain in the beneficial ownership of the Indian tribe.

NRC concurrence in the DOE determination that remedial action at a processing site has been accomplished in accordance with the approved plan may be accomplished in two steps where residual radiohetive material is not being i

moved from the processing site to a different disposal site.

The Uranium Mill Tailings Remedial Action Amendments Act of 1988 allows for a two-step approach for Title I disposal sites. The Amendments Act will allow DOE to do all remedial actions, other than groundwater restoration, for the first step of closure and licensing. The second step, which can go on for many years, will j

deal with existing groundwater restoration. When groundwater restoration is completed, the Long-Term Surveille.ce Plan required under the licensing phase will be appropriately amended.

For sites that are being moved, licensing will occur in one step.

There is no groundwater restoration at the disposal site and the processing site will not be licensed after completion of remedial action.

The Licensina Phase Title I of UMTRCA further requires that, upon completion of the remedial action program by DOE, the permanent disposal sites be cared for by the DOE or other Federal agency designated by the President, under a license issued by the Commission. DOE will receive a general license under 10 CFR Part 40.27 following (1) NRC concurrence in the DOE determination that the disposal site has teen properly reclaimed, and (2) the formal receipt by NRC of an i

acceptaole Long-Term Surveillance Plan (LTSP). NRC concurrence with DOE's performance of the remedial action indicates that DOE has demonstrated that the remedial action complies with the provisions of the EPA standards in 40 CFR part 192, Subparts A, B, and C.

This NRC concurrence may be completed in two steps as discussed 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 have an opportunity to comment on the remedial action or closure plans proposed and implemented by DOE and to raise concerns regarding final stabilization and the degree of protection achieved. NRC fully endorses State / Indian tribe and public input in all stages of the program. At the time the LTSP is submitted, the NRC will consider the need for a public meeting in response to requests and public concerns.

The Surveillance and Monitorino Phase In this phase, DOE and NRC periodically inspect the disposal site to ensu e its integrity.

The LTSP will require the DOE to make repairs, if needed.

One of the requirements in the EPA standards is that control of the tailings should be designed to be effective for up to 1000 years without active maintenance. Althou( the design of the stabilized pile is such that reliance Grand Junction CRR B-3 March 1997

l' on active maintenance should be minimized or eliminated, the NRC license will

-require emergency repairs as necessary.- In the event that significant repairs l

are necessary, a determination will_be made on a site specific basis regarding the need for additional National. Environmental Policy Act actions, and health and safety considerations based on 10 CFR Parts 19, 20, and 21.

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i APPENDIX C l.

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VERIFICATION OF REMEDIAL ACTION PLAN REQUIRENENTS I-c l

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Grand Junction, Colorado Reviewer: Elaine Brummett RAP Feature: Site Cleanup Radiation Protection Issues RAP Requirements Verification in CR i

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Decontamination / Demolition 1.

Decontamination / Demolition Tech. Specification Appendix H Contaminated demolition debris Two buildings were decon-to be placed in the disposal taminated and two were cell. Two buildings to remain.

demolished.

Contaminated building foundations, rubble, and debris were buried in the lower lifts of the disposal cell.

2.

Soil Cleanup 2.

Soil Cleanup RAS Report Section 6.5.3 Appendix J A.

Ra-226:

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Ra-226 analysis of 5,059 Average within each grid to meet samples yielded an average of EPA standard, will not exceed 2.4 pCi/g. The maximum value was background by:

16.5 pCi/g and no sample analyzed by OCS exceeded the a.

5 pCi/g in top 15 cm standards.

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15 pCi/g in subsequent Five QA lab samples exceeded 15 cm layers 17 pCi/g (15 + bkg), highest was 20 pCi/g.

j B..Th-230 analysis of 509 B.

Th-230:

samples yielded an average of i

Supplemental stanord imposed to 2.6 pCi/g, highest value was achieve the projected 1000-yr 33 pCi/g. No sample exceeded Ra-226, or WL standard.

the projected 1000-year Ra-226 standard.

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Soil Verification Procedures 3.

Soil Verification Procedures RAS Report Section 6.5.3 Appendix J Determine average soil Ra-226 The site was divided into 10 x for 100 square meter areas using 10 meter grids and RAC-015 rev.

9-plug composite samples.

7 and 8 sampling and analysis May use cobbles bulk procedures were followed.

l determination, 9-point gamma, or For QA, 4 % of samples were sent i

RTRAK in some areas. Use to an independent lab.

quality assurance (QA) and control procedures.

Grand Junction CRR C-1 March 1997 i

i