ML20148F706
| ML20148F706 | |
| Person / Time | |
|---|---|
| Issue date: | 02/23/1988 |
| From: | Gillen D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20148F639 | List: |
| References | |
| REF-WM-39 NUDOCS 8803280262 | |
| Download: ML20148F706 (7) | |
Text
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0G/2/18,
FEB 2 31988 MEMORANDUM FOR:
Paul H. Lohaus, Chief Operations Branch FROM:
Daniel Gillen Uranium Recovery Section Operations Branch
SUBJECT:
SIMARY OF NRC/00E UMTRA PROGRAM MEETINGS Enclosed is a sumary of meetings held with DOE staff and their contractors on February 10 ano 11,1988, to discuss various aspects of the LNTRA Program. Major items of discussion included:
- 1) the NRC's review and concurrence process; 2) plans for implementation of EPA's recently proposed groundwater standards; and 3) DOE's QA/QC program.
ORIGINAL. SIGNED BY Daniel Gillon Uranium Recovery Section Operations Branch
Enclosure:
As stated DISTRIBUTION: 4 ^d'
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SUMMARY
OF NRC/ DOE MEETINGS URANIUM RECOVERY SECTION, LOW-LEVEL OPERATIONS BRANCH Oates:
February 10 and 11,1988 Place:
Room 6-B-11. One White Flint North
Purpose:
To discuss various aspects of the Uranium Mill Tailings Remedial Action Program (UMTRAP)
Attendees:
See attached attendees lists Discussion:
February 10 Following the opening introduction of attendees, John Arthur (DOE) described the status of UMTRAP activities.
Scheduled construction starts were discussed and information on the number of various type of documents planned for submittal to the NRC in 1988 was presented (seeattachment).
Debra Mann (DOE) led a discussion of the steps of the remedial action design / review / concurrence process. Various procedural aspects were clarified and verbally agreed upon as follows:
Acceptance reviews of submittals will be 5 days in length, followed by a teleconference call indicating 4
acceptance /non-acceptance. A non-acceptance will result from sinnificant gaps in information necessary for staff review, and wi'1 be formally documented following the teleconference call.
NRC staff may need to better define significant and develop some form of acceptance review checklist (s).
NRC recommended that submittals following NRC casusents include both a response to NRC comments and a clear indication of the effect of the consents / responses on the document reviewed. This l
will be done, and will include a "roadmap" for ease of review of document changes.
The goal of the submittal / review of the Pre Final RAP / Design will be development of the NRC's (draft) Technical Evaluation Report that clearly indicates remaining open issues, and transmittal of a "prepared to concur" letter.
This review, coupled with subsequent staff interactions, should be such that submittal of the FRAP/ Design with signature pages will require little review time.
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,3, NRC recommendeJ that if major design changes occur at any point in the design / review process, a revision of the previous submittal should be submitted rather than proceeding to the next step.
As an aid to NRC tracking and resource allocation. DOE will provide the monthly schedule data, sorted both by site and chronologically by "working start".
February 11 The morning session consisted of discussion relative to DOE's plans for implementation of EPA's recently proposed groundwater standards.
Mark Mathews (DOE) described their policy statement on the approach to the proposed groundwater standards, and Frank Titus presented possible technical approaches to further reduce infiltration in the remediated piles. The key points arising from these presentations tre as follows:
Copies of the February 9. 1988 letter from NRC to DOE were provided to DOE staff. The NRC staff position stated in the letter was discussed, and may be sunned as follows:
Based on our reading of Section 108(a)(3) of UMTRCA, remedial action plans must now be reviewed by NRC relative to EPA's proposed groundwater standards. NRC can no longer issue concurrences conditional on later demonstration of compliance with groundwater standards, unless it is demonstrated that the remedial action, including groundwater protection, can proceed independently of restoration of current groundwater contamination.
NRC staff coamitted to providing comments on DOE's policy statement in light our letter.
The NRC staff is working on an outline to describe the NRC view of what type of inferination is required by the standard. Once tMs is drafted, an NRC/ DOE dialogue will follow.
Copies of NRC staff cosuments on the EPA standard were provided to DOE, and we indicated that the Title II ACL Methodology paper would be provided for DOE's inforination upon its completion.
The afternoon session was devoted to presentations and discussion of the UMTRAP QA/QC Program. Based upon NRC staff observations of emplaced rock at the Canonsburg and Shiprock sites, concerns had been raised relative to the adequacy of rock placement at the two sites, as well as the adequacy of the overall DOE QA/QC program.
In response to these concerns, the DOE / TAC and RAC presented summaries of their existing QA/QC programs, and
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06/2/18 4-the results of assessments of the specific Canonsburg concern and the UMTRAP QA/QC programs in general. The key points arising from these presentations and related discussion are as follows:
DOE was unable to identify the exact circumstances leading to the existence of some less durable rock and some rock gaps in the riprapped diversion channels at Canonsburg. However, from a generic standpoint, DOE recognized deficiencies in the UMTRAP QA Program, including insufficient training of inspectors and insufficient site audits and inspections. DOE / TAC /RAC has reacted to this assessment by proposing certain enhancements to the QA/QC programs.
DOE / TAC /RAC submitted copies of the UMTRA Project QA Program and HK-Ferguson QA Program presentations, including the planned enhancements to the programs. NRC staff indicated that we would review and comment as necessary on these materials. Through a post-meeting telecon with DOE, it was agreed that this review would be initiated by DOE's submittal of proposed modified DOE / TAC /RAC QA Plans.
DOE presented a list of four QA related requests to NRC:
1)
Updated identification of responsible NRC QA contact:
P. Lohaus indicated that D. Gillen will be the NRC contact for QA.
2)
Direct, official and timely transmittal of concerns:
NRC staff noted this request and will strive for improved timeliness of transmittal of concerns.
3)
Regular meetings on site certification:
NRC staff will be willing to participate in meetings on site certification following each issuance of a Completion Review Report (CRR).
4)
NRC site visits during major phases of construction:
N The NRC staff practice has been to conduct a few visits per site during construction - changes to this practice may result from internal assessment of the NRC inspection program.
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