ML20148T235

Forwards Shell of Completion Review Rept Based Upon Recently Completed Final Completion Review Rept for Remedial Action at Shiprock U Mill Tailings Site at Shiprock,Nm & Summary of Standardized Format

ML20148T235
Person / Time
Issue date:	06/04/1991
From:	Surmeier J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Randy Hall NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20148T236	List: IA-97-204, Forwards Shell of Completion Review Rept Based Upon Recently Completed Final Completion Review Rept for Remedial Action at Shiprock U Mill Tailings Site at Shiprock,Nm & Summary of Standardized Format ML20148T235
References
FOIA-97-204 NUDOCS 9106100250
Download: ML20148T235 (21)

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• ' Ulff) 4 193f MEMORAftDUM FOR: Ramon E. Hall,' Director Uranium Recovery Field Office FR0it: John J. Surmeier, Chief Uranium Recovery Branch Division of Low. Level Waste flanagement and Deconmissioning, NHSS

SUBJECT:

STAfWARD FORMAT FOR COMPLET10ft REVIEW REPORT (CRR) t Enclosed is a shell of a CRR based upon the recently completed " Final Completion Review Report for the Remedial Action at the Shiprock Uranium Mill l Tailings format.

Site at Shiprock, New Mexico," and a summary of this st Lakeview and Tuba City CRRs (URF0 in-house casework) and all future CRRs. Use

{ of this format, with the boilerplate, should ensure a consistent, time-effective product for CRRs produced by both Uranium Recovery Field Office and

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lieadqurrters.

An IBM 5520 docurrent entitled, "Shell Completion Review Report," has been developed to further reduce secretarial time as well as ensure A briefconsistency.

discussion on

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This IBM document will be transmitted to URF0 this week.

using the Shell Completion Review Report document is presented in Enclosure 3.

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I The Shiprock CRR, dt.ted May 9,1991, should be of assistance in have If you providing any a perspective in those areat not covered in the shell CRR.or Allan Mullins (492-0578) questions please call either Dan Gillen (492 0517) of my staff. ORIG!NAL SIGNED By John J. Surmeier, Chief Uranium Recovery Branch Division of Low-level Waste Management and Decommissioning, tiMSS

Enclosures:

1. Standard format for flRC's Completion Review Report

2. IBM 5520 Shell Completion Review Report

3. Procedures for Usin:1 IBM 5520 Shell cc: R.L. Bangart, LLWD A.W. Beach, Region IV AMullins HMSS r/f LLUR r/f Uq Distribution: Central'FileO . Plohaus JGreeves DGillen JSurmeier' JAustin '

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STANDARD FORMAT FOR COMPLET10N REVIEW REPORT 4

The Completion Review Report (CRR) is divided into an introduction, four sections, and three appendices.

This format should be closely followed with only the changes noted.

Introduction- Change site name and references, otherwise, use as written.

Section 1.1- UMTRCA- Use as written.

Section 1.2- Concurrence Process for the Selection, etc.- Change site name and references, otherwise, use as written.

l Section 1.3- Concurrence Process for the Performance, etc.- Use as I written.

Site- Use the general format but alter as Section 1.4- The appropriate for the specific site.

Section 1.5- CRR Organization- Change site names, otherwise, use as written.

Section 2.0- Analysis of DOE Remedial Action Performance- Follow the preferred format and alter for specific site characteristics and assessments.

Section 3.0- Sumary- Change site name, and use as written if concurrence is given. Otherwise .(open issues exist) present a summary of the issues needing resolution.

Section 4.0- References- References listed should be those used in the rev'cw process and those cited in the document.

Appendix A- NRC Site Visits- All site visits and inspections should be listed following the format in the example.

Appendix B- Detailed comparison- This is very site specific.

All of the RAP features shown ma" not be applicable for every site and some RAP features may not be 1centified which would be needed in addition to those shown. The categories shown under each RAP feature should be addressed as Additional site-needed and appropriate for the site being discussed.

specific categories may be added as needed to complete the detailed comparison and verification of the remedial activities.

Use Appendix C- UMTRCA, the EPA standards and the Phased UMTRA Project-as written.

The intent of this standard format is to reduce the amount of time and effort spent in producing a CRR and to make them relatively consistent.

ENCLOSURE 1

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FINAL COMPLETION REVIEW REPORT FOR THE

REMEDIAL ACTION AT THE 1 [**NAME OF SITE **] URANIUM MILL TAILINGS SITE

! [** LOCATION OF SITE **]

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Division of Low-Level Waste Management and Decommissioning U.S. Nuclear Regulatory Commission iC' f

ENCLOSURE 2

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INTRODUCTION ...............................................................

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1.0 BACKGROUND

............................................................ I 1.1 UMTRCA ...........................................................

1.2 Concurrence Process for the Selection of DOE's Remedial Actions .. 2 1.3 Concurrence Process for the Performance of DOE's Remedial Actions. 2 1.4 The [**NAME OF SITE **] Site ......................................

1.5 Completion Review Report (CRR) Organization. . . . . . . . . . . . . . . . . . . . . . .[*

• 2.0 ANALYSIS OF 00E REMEDIAL ACTION PERFORMANCE ...........................[** **

2.1 Previous Actions .................................................

2.2 Review of Remedial Action Performance ............................ **

2.2.1 Geotechnisel Engineering Review Results ................... **

2.2.2 Surface Water Hydrology and Erosion Protection Review Results.................................................;**

2.2.3 Radiation Protection Review Results ......................,**

[** OTHER SUBSECTIONS AS REQUIRED, E.G., GROUN0 WATER **]...........[** j 3.0

4.0 REFERENCES

............................................................ l 1

APPENDIX A - NRC Site Visits to the [**NAME OF SITE **] UMTRA Project Site l APPENDIX B - Detailed Comparison of Design Specifications with Completed Remedial Actions Performed at the [**NAME OF SITE **] UMTRA Project Site APPENDIX C - UMTRCA, the EPA Standards, and the Phased UMTRA Project t

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[** CAP FLAME OF SITE **] COMPLETION REVIEW REPORT INTRODUCTION t site is one of the 24 abandoned uranium mill tailings The ["NAME OF SITE **]

i sites to be remediated by the Department of Energy (DOE) under the Uranium Mill

• Tailings Radiation Control Act of 1978 (UMTRCA). UMTRCA requires, pursuant to Section 104(f)(1), that the Nuclear Regulatory Commission (NRC) concur withThis the DOE's determination that the remedial action has been properly completed.

Completion Review Report (CRR) documents the NRC staff's basis for its concurrence decision with respect to DOE's Certification Report for the completion of the [**NAME OF SITE"] site [**(CITE OF DOE COMPLETION REPORTS)**].

l

1.0 BACKGROUND

1.1 UMTRCA

' Title I of UMTRCA provides for remedial action at abandoned uranium mill tailings sites and associated vicinity properties. The purpose of this

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a legislation is to prote'ct the public health and safety and the environment from

' radiological and non-radiological hazards associated with the radioactive materials at these sites.

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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 Environmental Protection Agency (EPA) under Section UMTRCA also 275(a) of the Atomic Energy Act of 1954, as amended by UMTRCA, 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 C includes a more detailed discussion of this legislation. 1 l

1.2 Concurrence Process for the Selection of DOE's Remedial Actions To document its selection of the remedial action to be implemented at a The RAP '

particular site, DOE develops and issues a Remedial Action Plan (RAP).

describes the series of activities and presents the design proposed by DOE to stabilize the residual radioactive materials at the disposal site and to provide for the long-term protection of the public and the environment. In accordance with UMTRCA Section 108(a)(1), the NRC staff reviews and concurs with the RAP,

- and any subsequent modifications. By its review and concurrence in the remedial action selection, the NRC staff concludes that the planned remedial actions will The comply with EPA's applicable standards in 40 CFR 192, Subparts A, B, and C.

basis for the NRC staff's concurrence in DOE's selection of remedial action at

' the [**NAME OF SITE **] site is ducumented in a Technical Evaluation Report (TER) issuedin[**0ATEOFTERANDCITATION**].

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y~ 1.3 Concurrence Process f or the Performance of DOE's Remedial Actions The remedial action work is performed by 00E contractors under federal 1 procurement regulations. During construction, 00E inspects and documents activities in accordance with the UMTRA Project Quality Assurance Plan, the Remedial Action inspection Plan (RAIP), and the RAP. In addition, the NRC staff conducts independent inspections during construction.

Upon the completion of the remedial action, 00E compiles construction records and prepares a completion report to document that remedial actions were Based performed in accordance with the RAP or RAP modifications, and the RAIP.

on this information, 00E 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 the sites, and then By its review and documents the basis for this concurrence decision in the CRR.

concurrence in the remedial action performance, the NRC staff concludes that the remedial action has been completed in accordance with the concurred-in design.

NRC's concurrence with DOE's completion determination fulfills the Commission's responsibility under UMTRCA Section 104(f)(1) to concur with DOE's determination of completion of remedial action.

1.4 [" CAP NAME OF SITE"] [" SITE The ['NAME OF SITE **] uranium mill tailings site is located ... The sitetons of million consists of about acres, of which were covered by the -

uranium mill tailiiigs prior tTremedial action. The site ...

The remedial action performed by DOE consisted of the following major f activities:

1. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxx;

2. xxxxxxxxxxxx; and

x. ...

The NRC wat not involved with the actual remedial action activities, which were performed by the DOE contractors. However, 00E obtained NRC concurrence with NRC also the site construction design and significant modifications thereof.

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h'*. performed site inspections to monitor the progress of the construction activity l[

j{ (see Appendix A).

1 1.5 Completion Review Report (CRR) Oroanization The purpose of this CRR is to document the NRC staff review of DOE's [" FLAME OF SITE"] Certication Report.- Section 2 of this report presents the analysis of remedial action construction. This section is organized by technical discipline and addresses geotechnical' engineering, surface water hydrology, and radiation protection aspects of the r'emedial action. Appendix A provides a listing of all NRC staf f visits to and inspections of the ["NAME OF SITE **J site. Appendix B provides a table that cross-checks the requirements of the RAP /RAIP as concurred in by the NRC staff with DOE's Certification Report documentation. Appendix C presents a detailed description of the requirements of UMTRCA and the resulting phased process of the UMTRA Project.

2.0 ANALYSIS OF DOE REMEDIAL ACTION PERFORMANCE 2.1 Previous Actions The NRC staff, based on its review of the RAP and RAP modifications, concurred that the remedial action as designed would meet the applicable EPA standards.

This concurrence was based on technical findings that there is reasonable assurance that the selection of the remedial action would meet the standards for long-term stability, radon attenuation, water resources protection and cleanup of contaminated land and bu'ildings. Staff reviews included assessments in the areas of health physics and radiation protection, geotechnical engineering, surface water hydrology, ground-water hydrology, and geology. The NRC gave [**

CONDITIONAL "] concurrencd with the RAP on [" DATE ", CITATION **]. ...["

CONDITIONS "] [" RAP mods ") . . . NRC staff also reviewed and concurred with DOE's Remedial Action Inspection Plan (Rev ") on [** DATE "]. This concurrence was the NRC staff's agreement that the quality control program, i.e., the plan for testing and inspections, was acceptable for the [" NAME OF SITE **] site.

2.2 Review of Remedial Action Performance The NRC staff's primary objective in reviewing DOE's certification of remedial action completion is to det rmine whether the remedial actions have been performed in a manner consistent with specifications provided in the RAP, RAP modifications, and the RAIP, and if not, that deviations to these specifications ,

do not significantly affect compliance with the EPA standard. In support of this action, the NRC staff participated in site inspections (See Appendix A),

field observations, assessments of onsite data and records, and review of DOE Site Audit Reports. The following sections present the results of the review of remedial action performance by individual technical discipline. Note that for the ["NAME OF SITE"] remedial action completion review, the pertinent technical oisciplines are 1) ......, and x) .... [** IF APPLICABLE --

Groundwater resources protection is not addressed at this time, since 00E has elected to postpone any groundwater remedial action activities to a separate phase of the project. **

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2.2.1 Geotechnical Engineering Review Results During its review, the NRC staff noted the following:

1. xxxx xxxx xxxx.

2. XXXX XXXX XXXX.

X. XXXX XXXX.

t j Detailsofthestaff'sg$0technicalengineeringreview,whichprovidethebasis Based on

' for the above conclusions, are included in the attached Appendix 8.

the above conclusions, and on the results of on-site inspections performed by NRC staff during construction, the NRC staff concludes that the geotechnical engineering aspects of the construction were performed in accordance with the design and specifications identified in the RAP, RAP modifications, and RAIP.

I d.2 Surf ace Water Hydrology and Erosion Protection Review Results l{

NRC staff reviewed the surface water hydrology and erosion protection aspects of j remedial actions at ["NAME OF SITE **] to ensure that they were constructed in accordance with the applicable construction specifications as stipulated in the RAP / design, RAP modifications, and RAlF. Areas of review included as-built 2

drawings, construction operations, laboratory and field testing, and quality assurance audits. In addition, the review was based on NRC observations of the

[ remedial actions and reviews of records and testing during NRC onsite inspections (See Appendix A).

.... During its review, the NRC staff noted the following:

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t Based on NRC staff observations and review of o' n site records during the remedial actions, as well as assessment of the verification results presented in the DOE

' Completion Report, the NRC staff concludes that the required durability and

' gradation tests were performed during the remedial action. The riprap is of

> adequate quali+y and has been acceptably placed. The NRC staff concurs that remedial action has been adequately completed at ["NAME OF SITE"] with respect to erosion protection.

2.2.3 Radiation Protection Review Results The NRC staff reviewed radiation protection aspects of remedial actions at

["NAME OF SITE **] to ensure that cleanup of residual radioactive materials was performed in accordance with specifications in the RAP and RAP modifications, RAIP, and the final design. Areas of review included contaminated material excavation, verificatiop of cleanup, laboratory and field testing, and quality assurance audits. Specific discussion of the details of this review can be found in Appendix B. ThereviewwasbasedonNRCstaffassessmentofthe In addition, NRC verification results presented in the DOE Completion Report.

geotechnical engineerin'g staff reviewed the design and construction of the disposal cell cover to ensure compliance with the RAP design for limiting radon releases, and thus with the EPA standards (See Section 2.2.1).

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c The criteria for site cleanup were established in the RAP and concurred in by the NRC staf f [** CITATION **]. The general criterion was to cican up windblown

@f and waterborne contamination on adjacent lands to levels complying with the p

.g applicable EPA standards (40,CFR Part 192.12). ...

During its review of the radiation protection aspects of the remedial action f completion documentation, the NRC staff noted that'the techniques, which DOE l states to have used for verifying radiological cleanup at the processing site.

h complied with DOE's summary protocols and the Vicinity Property Management and v Implementation Manual (VPMIM) procedures, with which NRC concurred in June 1987.

~ In addition, DOE's radiological survey records support compliance with EPA's cleanup standards in Subpart B of 40 CFR Part 192.

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3.0 SUMitARY The NRC staff reviewed geotechnical engineering, surface water hydrology, and

/ radiation protection aspects of the remedial action performed at the uranium i

mill tailings site in [**NAME OF SITE **). The purpose of this review was to determine whether DOE had performed remedial actions at the site in accordance with specifications in the RAP. RAP modifications, and other supporting project documents, and thus with the EPA standards in 40 CFR Part 192, Subparts A-C.

Based on its review of the Certification Report and on observations during periodic site inspections, the NRC staff concurs that 00E has performed remedial action at the ["NAME OF SITE **] site in accordance with the above specifications and that this action complies with EPA's standards in 40 CFR Part 192, Subparts A-C. With the excep[ " IF tion of ...., --remedial actions are complete APPLICABLE DOE has proposed for the ["NAME OF SITE **] site.

deferral of selection and performance of a groundwater cleanup program at this time, and plans to handle this as part of a separate UMTRA groundwater restorationprogram.**] The NRC staff considers DOE's deferral to be acceptable, and therefore, hereby concurs in completion of the [**NAME OF SITE **] remedial action [**lF APPLICABLE -- (other than groundwater restoration).**]

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4.0 REFERENCES

[" EXAMPLE OF FORMAT **]  ;

l DOC (U.S. Department of Energy), 198Sa, " Remedial Action Plan and Site Conceptual Design for Stabilization of the inactive Uranium Mill Tailings ,

Site at Shiprock, New Mexico," June 1985. l l

00E, 198Sb, " RAP Modification No. 1, Remedial Action Plan and Site l Conceptual Design for Stabilization of the inactive Uranium Mill Tallings l Site at Shiprock, New Mexico," October 1985.

DOE, 1986a, " RAP Modification No. 2, Remedial Action Plan and Site 1

' Conceptual Design for Stabilization of the inactive Uranium Mill Tailings i

Site at Shiprock, New Mexico," February 1986, .

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l - DOE, 1988, Arthur, J.W. letter to Lohaus, P.H., U.S. Nuclear Regulatory l

Comission, transmitting " Evaluation of As-Constructed Riprap for Shiprock, New Mexico Site," December 5, 1988.

MK-Ferguson, 1986, "UMTRA Project - Shiprock, New Mexico, Remedial Action Inspection Plan," August 8, 1986.

' NRC (U.S. Nuclear Regulatory Comission),1985, Higginbotham, L.B. letter to

' Themelis, J.G., U.S. Department of Energy, providing conditional concurrence on the HAP, June 6, 1985.

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l HRC SITE VISITS TO THE l

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NRC Site Visits to the

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. DATE STAFF / DISCIPLINE PURPOSE

.f 0. Gillen/geotechnical eng Pre-construction disposal ef 6/26/84 T. Johnson / surf hydrology-erosion site and borrow site visit ys R. Pennifill/proj management

.ifl F. Ross/ groundwater hydrology Site visit to resolve gw k' 10/16/84 characterization issues

M. Weber / groundwater hydrology M. Knapp/ management J. Valdes/ geology Part of a multiple site S/9/85 tour; observation of K. Westbrook/ geology M. Larson/ groundwater hydrology initial construction D. Gillen/geotechnical eng-pm activities T. Johnson / surf hydrology-erosion B. Jagannath/geotechnical eng S. Smykowski/geotechnical eng M. Haisfield/proj management

i. P. Justus/ management

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i (" CAP NAME OF SITE **] UMTRA PROJECT SITE l

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% VERFICATION OF REMEDIAL ACTION PLAN ACTIVITIES l4-h Site: [**Name of Site")

RAP Feature: ["Name of Feature (p.x of N"]

Reviewer (s): [**Name(s)**]

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$ Determination r,/ . RAP Requirement b

a. Configuration (1) Floor of pit will be leveled The bottom of the pit was and proof rolled and all visually verified to be free tailings material or soft of uranium mill tailings -

spots removed (RAIP 6.2.1). (Comp. Rept. Vol. 1, III.0, Foundation elevation will be Soil Measurement Methods 5020' (RAP Vol.!!, Desi Sect.,p.1).

DrawingSPK-PS-10-0107)gn .

b. Material (1) Gradation-particle size'not Verified during gradation tests greater than lift thickness (Comp. Rept. Vol.3, App.E, f

(RAP Vol.!!, 022000-2.1 E.3). Foundation Fill Sect., p.2).

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c. Placement )

Continuous monitoring was performed (1) Lift thickness-not to exceed 12" 6 (RAP Vol.II, 022000-2.1 E.3). to ensure that lift thickness did

>h, not exceed 12" (Comp. Rept. Vol.3, App.E Foundation Fill Sect., p.2).

(2) Compaction-floor of pit will be Average compaction achieved was l

s. 95% (Comp. Rept. Vol.3, Ap .E. 1

$ proof rolled-minimum of 90% of Foundation Fill Sect., p.1 .

& maximum as er ASTM D698 (RAP k Vol.1, p.55 .

kr (3) Organic distribution-no visible NOT ADDRESSED IN DOE's COMPLETION b organic matter within tailings REPORT. See Section 2.2.1 of 5 embankment footprint (RAP Vol.II, CRR.

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VERFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: [**Name of Site"] Reviewer (s): [**Name(s)**]

fg', ) RAP Feature: [**NameofFeature(p.XofN**]

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, UMTRCA, THE EPA STANDARDS, AND THE PHASED UMTRA PROJECT a

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• APPENDIX C ir 4i UMTRCA, THE EPA STANDARDS, AND THE PHASED UMTRA PROJECT

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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 for inactive

- uranium mill tailings sites.

The Standards UMTRCA charged the EPA with the responsibility for promulgating remedfal action

- standards for inactive uranium mill sites. The purpose of these standards is

f 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. Af ter October 1,1982, if the EPA had not promulgated 1

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 Ura'nium Processing Sites, Subparts A, B, and C. These regulations may be summ'arized as follows:

The disposal site shall be designed to control the tailings and other f

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i residual radioactive materials for up to 1000 years, to the extent reasonably achievable, and, in any case, for at least 200 years

[40CFR192.02(a)].

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2. Provide reasonable assurance that the disposal site design shall l J prevent radon-222 from residual radioactive material to the i 4

atmosphere from exceeding 20 picocuries per scuare meter per second or from increasing the annual average concentration of radien-222 in air at or above any location outside the disposal site by more than i one-halfpicocurieperliter[40CFR192.02(b)].

t

! 3. The remedial action shall be conducted so as to provide reasonable

! assurance thats. 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 neters shall not exceed the background level by more than 5 picoeuries/ gram averaged over the first 15 centimeters of soil below the surface and 15 picacuries/ gram

,I averaged over any 15 centimeters more than 15 centimeters below the surface [40CFR192.12(a)].

1 The portion of the EPA standards dealing with ground water requirements, ls on 1 40 CFR 192.20(a)(2)-(3) were remanded by the Tenth Circuit Court of Appea

.{ September 3, 1985. Based on this court decision. EPA was directed to y 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 j in the process of completing action to promulgate the final groundwater

^i standards.

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' 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 promu %&ted. 00E 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 3 groundwater standards (52 FR 36000; September 24,1987). Delaying t implementation of the remedial action program would be inconsistent with Congress' intent of timely completion of the program. Modifications of disposal sites after cobpletion of the remedial action to comply with EPA's final ground water protbetion standards may be unnecessarily complicated and

{ , expensive and may not yield comensurate benefits in terms of human and environmental protection. Therefore, the Commission believes that sites where 4

remedial action has beeh essentially completed' prior to EPA's promulgation of

~

i final ground water standards will not be impacted by the final ground water standards. Although ad'ditional effort may be tppropriate to assess and clean i up contaminated ground water at these sites, the existing designs of the

1 I disposal sites should b'e considered sufficient to provide long-term protection against future ground water contamination. NRC does not view UMTRCA as l

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• 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 enncurrence was given.

} DOE Selection (Design) Phase l

' 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 y by DOE of an Environmental Assessment or an Environmental Impact Statement, and a Remedial Action Plan (RAP). The Remedial Action Plan is structured to l

provide a comprehensive understanding of the remedial actions proposed at that site and contains specific desig7 and construction requirements. To complete the first phase, NRC and the appropriate State or Indian tribe review the RAP and then concur that the RAP will meet the EPA standards.

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! The performance (Construction) phase I

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In this phase the actual remedial action (which includes decontamination, decommissioning, and eclamation) at the site is done in accordance with the

! L Remedial Action Plan. The NRC and the State / Indian tribe, as applicable, must I concur in any changes to the concurred-in plan that arise during construction.

1

[ At the completion of remedial action activities at the site, NRC concurs in 4 DOE's determination that the activities at the site have been completed in I

i accordance with the approved plan. Prior to licensing (the next phase), title to the disposed tailings and contaminated materials must be transferred to the f( 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 .

f G land will remain in the beneficial ownership of the Indian tribe. l M

4, HRC concurrence in the DOE determination that remedial action at a processing

?

site has been accomplished in accordance with the approved plan may be accompitshed in two steps where residual radioactive material is not being i[. moved from the processing site to a different disposal site. The Uranium Mill y Tailings Remedial Action Amendments Act of 1988 allows for a two step approach 1

for Title I disposal sites. The Amendments Act will allow DOE to do all C-2 yl I

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f 7 remedial actions, other than ground water restoration, for the first step of 7y closure and licensing. The second step, which can go on for many years, will M.  ;

deal with existing ground water restoration. When ground water restoetian it completed, the Long-Term Surveillance Plan required under the licensing phase will be appropriately amended. For sites that are being moved, licensing will

[4 6 occur in one step. There is no ground water restoration at the disposal site 6(R and the processing site will not be licensed af ter completion of remedial action.

y[ l The Li:ensing Phase i

% Title 1 of UMTRCA further requires that, upon completion of the remedial action

. L. program by DOE, the permanent disposal sites be cared for byissued the DOE

[ a license by or theother y Federal agency designated by the President, under'fider 10 CFR Part 40.27

. .- Comission. DOE will receive a general license u Y following (1) NRC concurrence in the DOE determination that the disposal site b has been properly reclaimed and (2) the formal receipt by NRC of an acceptable

~ Long-TermSurveillancePlan(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 f.

i discussed above. There is no termination date for the general license.

a.

5, 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 comention the remedial action or closure plans proposed and

b. '

implemented by DOE and to1 raise concerns regarding final stabilization and the degree of protection achieved. HRC fully endorses State / Indian tribe and L public input in all stages of the program, especially in the planning stages of T, j remedial action when suchlinput can be most effective in identifying and i  ; resolving issues affecting long-term care. At the time the LTSP is submitted, M  : the NRC will consider the need for a public meeting in response to requests and p' public concerns. Therefore, NRC encourages State / Indian tribe and public g participation early in the remedial action and closure process and will provide y!4 additional opportunities, as needed, later in the process.

t. .

The Surveillance and Monitoring Phase

[

x In this phase DOE and NRC periodically inspect the disposal site to ensure its

% integrity. The Long-Term surveillance Plan (LTSP) will require the DOE to make d

gp repairs, if needed.

N! One of the requirements in the EPA standards is that control of the tailings

'l"I should be designed to be effective for up to 1000 years without active maintenance. Although the design of the stabilized pile is such that reliance e yI on active maintenance should be minimized or eliminated, the NRC license will k i In the event that significant repairs require emergency repairs as necessary.

NJ a are necessary, a determination will be made on a site specific basis regarding j the need for additional National Environmental Policy Act (NEPA) actions, and t

health and safety considerations from 10 CFR Parts 19, 20, and 21.

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.l IBM 5520 PROCEDURES FOR USING y.

THE SHElt. COMPLETION REVIEW REPORT (CRR) b The IBM 5520 document entitled, "Shell Completion Review Report," is available for use in preparing CRR's. It is a " read only" document that can be

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{; duplicated (i.e, request " DUP") for creating the site specific CRR.

i All site specific names, references, etc. have been identified with a designator "[**" followed by another. designator ""J".

(: The IBM

" Global / Search / Replace" menu can be used to change such generic designators c.s

?. I ["NAME OF SITE **] or [** CAP NAME OF SITE **] to the specific site nam l location throughout the document. where 'words or phrases will need to be used to locate all occurrences of "[**"

' ;, l i be changed.

I The body of the CRR and each Appendix has been designated with "page format

This will permit the

< changes" (i.e., request "PFC") in the IBM 5520 system.

- secretary to insert new material into the duplicated 5520 document and still be able to keep page numbers in sequential order. Figures or other inserts may be added (or deleted) for page numbering purposes by inserting The use of "(or deleting) required page blank :

pages as illustrated on page 3 of the shell CRR.  !

endings" (i.e., request ALT + 3) for such blank pages will assist in the pagination of the document.

- It is suggested that,the secretary use the "IPN" request (i.e., interactive pagination) prior to printing the completed document in order to ensure that the pages are properly formatted.

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ENCLOSURE 3 5 i h

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