ML20149F380
| ML20149F380 | |
| Person / Time | |
|---|---|
| Issue date: | 07/20/1994 |
| From: | Randy Hall NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Chernoff A ENERGY, DEPT. OF |
| References | |
| REF-WM-48 NUDOCS 9408100109 | |
| Download: ML20149F380 (74) | |
Text
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JUL 2 01993 Docket No. WM-48 U.S. Department of Energy Albuquerque Operations Office A11N: Albert R. Chernoff Project Manager P.O. Box 5400 Albuquerque, New Mexico 87115
Dear Mr. Chernoff:
We have completed our review of the Draft Completion Report for the Durango, Colorado, Remedial Action Project. Our review is documented in the enclosed Draft Ce:pletion Review Report.
Based on our review, we have identifico several open iss,aes which will need to be resolved in your Final Completion Report in order for us to concur in the completion of remedial action at the Durango, Co brado, site.
Ground-water Lleanup at the processing site will be addressed by DOE as part of a separate ground-water restoration program once the proposed EPA ground-water standards have M an finalized. This will require that DOE maintain control of the processing site in a manner consistent with DOE's April 9,1993, policy letter.
Although ground-water compliance strategy at the disposal site is acceptable, several issues related to the toe drain, and associated evaporation pond, remain q.cn.
It is our understanding that since the toe drain system is expected to be active for about 7 to 10 years, it will be discussed more completely in the Long-Term Surveillance Plan (LTSP).
Because of the longevity of the dewatering system, we agree that the LTSP is an appropriate place for this issue. The remaining open issues related to the toe drain include (1) the need for some form of quantitative decision to determine when the toe drain system will no longer be needed, and (2) the need to formulate a procedure for ultimate disposal of the evaporation pond sludges and pond liner.
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E ? 0 19M U.S. Department of Energy As you know, the NRC Uranium Recovery field Office will be permanently closing on August 1, 1994.
There fore, if you have any questions, please contact Mr. Joe Holonich in NRC Headquarters at flS (301) 415-6643.
Sincerely,
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Ramon E. Hall Director
Enclosures:
As stated i
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J. Pape, DOE D. Gillen, NRC R.Quillin, RCPD, C0 i
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DRAFT COMPLETION REVIEW REPORT f
FOR THE REMEDIAL ACTION AT THE DURANGO, COLORADO l
URANIUM MILL TAILINGS SITE t
JULY 1994 r
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URANIUM RECOVERY FIELD OFFICE REGION IV U.S. NUCLEAR REGULATORY COMMISSION I
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TABLE OF' CONTENTS Durango Completion Review Report Section Page
1.0 INTRODUCTION
I 1
2.0 BACKGROUND
2.1 UMTRCA 1
2.2 Concurrence Process for the Selection of DOE's Remedial Actions.
1 2.3 Concurrence Process for the Performance of DOE's Remedial 2
Actions........
2 2.4 The Durango Site 2.5 Completion Review Report (CRR) Organization.
4 3.0 ANALYSIS OF DOE'S REMEDIAL. AC110N PERIORMANCI.
4 4
3.1 Previous Actions 3.2 Review of Remedial Action Performance 5
3.2.1 Geotechnical Engineering Review 5
7 3.2.2 Surface Water Hydrology and Erosion Protection Review 3.2.3 Radiation Protection Review 8
3.2.4 Water Resources Drotection.
9 4.0
SUMMARY
10
5.0 REFERENCES
11 APPENDIX A - NRC Site Visits to the Durango, Colorado, Uranium Processing and Disposal Sites APPENDIX B - Detailed Comparison of Design Specifications with Completed Remedial Actions Performed at the Durango, Colorado, UMTRA Project Site APPENDIX C - VMTRCA, the EPA Standards, and the Phased UMTRA Project APPENDIX D - Open Issues and General Comments for DOE Resolution DUR DRAFT CRR July 1994 j
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L LIST OF' FIGURES l
Durango Completion Review Report i
Fiqure Page I
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DURANCO, COLORADO COMPLETION REVIEW REPORT 1.0 INIRODUC110N The Durango, Colorado, site is one of 24 abandoned uranium mill tailings sites to be remediated by the Department of Energy (DOE) under the Uranium Mill Tailings Radiation Control Act of 1978 (UMTRCA). Section 104(f)(1) of UMIRCA j
requires that the Nuclear Regulatory Commission (NRC) concur with DOE's determination that the remedial action has been properly completed.
This Completion Review Report (CRR) documents the NRC staff's basis for its concurrence decision.
2.0 BACKGROUND
2.1 UMIRCA
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Title I of UMIRCA requires remedial action at abandoned uranium mill tailing sites and associated vicinity properties. The purpose of this legislation is to protect the public health and safety and the environment from radiological and nonradiological hazards associated with radioactive materials at these sites.
UMTRCA directs DOE to select and perform remedial actinns at 24 abandoned uranium mill tailings sites to ensure compliance with the general environmental standards promulgated by the Environmental Protection Agency (EPA) under Section 275(a) of the Atomic Energy Act of 1954, as amended by UMIRCA.
UMIRCA also requires NRC's concurrence with DOE's selection and performance of the remedial actions.
Following completion of the remedial actions, UMIRCA authorizes the NRC to issue a license for 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.
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) and a Remedial Action inspection Plan (RAIP). The RAP describes the design and procedures 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. The RAIP identifies the means by which the remedial action activities will be controlled, verified, and documented.
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 proposed remedial action, the NRC staff concludes that the remedial action will comply with applicable EPA standards in 40 CFR 192, Subparts A, B, and C.
DUR DRAFT CRR July 1934 1
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2.3 Concurrence Process for the Performance of DOE's Remedial Actions
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i The remedial action work is performed by DOE contractors under Federal procurement regulations. During construction, DOE inspects and documents activities in accordance with the UMTRCA Project Quality Assurance Plan, the RAIP, and the RAP.
In addition, the NRC staff conducts independent inspections during construction.
l Upon completion of the remedial action, DOE compiles construction records i
and prepares a Completion Report to document that remedial actions have l
been performed in accordance with the RAP or RAP modifications and the l
RAIP.
Based on this information, DOE certifies that all provisions of the RAP have been satisfied and, therefore, tlrt the remedial actions comply with the applicable EPA standards in 40 CFR 192.
Based on its review of DOE's documentation and onsite visits and observations, the NRC concurs i
that remedial actions have been performed as proposed and approved.
The basis for this concurrence is documented in the CRR. NRC's concurrence with DOE's completion determination fulfills the Commission's responsibility under UMTRCA Section 104(f)(1).
t 2.4 The Duranco Site The Durango processing site is located just outside the city limits of Durango, in southwest Colorado. The site is bounded on the east by the Animas River and U.S. Highway 160/550, on the north by U.S. Highway 160 l
and Lightner Creek, on the south by County Road 211, and on the west by Smelter Mountain (Figure 1). The processing site consisted of the mill l
site, two tailings piles, and a raffinate pond area located about 0.5 mile south of the site.
The processing site contained approximately 2,500,000 cubic yards of contaminated materials including tailings, subsoils, windblown materials, vicinity properties materials and raffinate pond materials.
i The remedial action performed at Durango consisted of the removal and a
cleanup of all contaminated material at the processing site and relocation to a new disposal cell at the Bodo Canyon site, which is located about 2.5 road miles southwest of the processing site. The remedial action consisted of the following major activities:
1.
Preparation of the processing site by constructing wastewater retention basins, and decontamination pads for washing down contaminated equipment.
2.
Construction of drainage control features for diverting runoff from contaminated areas into retention basins, 3.
Construction of a bentonite amended test pad for radon cover material
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to verify the permeability of the radon cover.
DUR DRAFT CRR July 1994 2
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R FIGURE 1 - Location of the Durango Uranium Mill Site (00E, 1991a) l
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4.
Excavation of a disposal cell at the Bodo Canyon site and placement of a low permeability clay liner to minimize seepage from the relocated contaminated materials into the ground-water system.
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5.
Demolition of the old mill structures at the processing site and removal of all contaminated material to the Bodo Canyon Disposal Cell.
6.
Placement of a multi-layered soil and rock cover over the relocated contaminated material to reduce radon emissions to EPA standards, to i
minimize seepage of water, and to prevent erosion.
7.
Construction of diversion ditches to divert flood flows away from the Bodo Canyon Disposal Cell.
9.
Placement of rock protection in the diversion ditches to minimize erosion potential.
The NRC was not involved with the actual remedial action activities, which were performed by DOE contractors.
Ilowever, DOE obtained NRC concurrence with the site construction design and significant modifications thereof.
NRC also performed onsite construction reviews to monitor the progress of construction activities (See Appendix A).
2.5 C_ompit(ion Review J]eport (CRR)_ Organization The purpose of this CRR is to document the NRC staff review of DOE's Durango Draft Completion Report (DOE, 1991c).
Section 3 of this CRR presents the analysis of remedial action construction. That section is organized by technical discipline and addresses the geotechnical engineering, surf ace-water hydrology, and radiation protection aspects of the remedial action.
Appendix A provides a listing of NRC staff visits to, and observations of the Durango 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 Completion Report documentation. Appendix C presents a detailed description of the requirements of UMTRCA and the resulting phased process of the UMTRA Project, and Appendix D presents the open issues which have resulted from NRC's review and for which DOE has to provide responses.
3.0 ANALYSIS DE DOE'S REMEDIAL ACTION PERfDRMANCE 3.1 Previous Actions The NRC staff, based on its review of the RAP (DOE, 1991a; 1991b; 1990a; 1990b), RAP modifications (DOE,1991d; 1990d; 1989c; 1989d), and Project Interface-Documents (PlDs) concurred that the remedial action as designed, other than the deferred cleanup of ground water, would meet applicable EPA i
standards.
This concurrence was based on technical findings that there l
was reasonable assurance that the selection of the remedial action would DUR DRAFT cHR suy ne4 4
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meet the standards for long-term stability, radon attenuation, water i
resources protection, and cleanup of contaminated land and buildings.
Staff reviews included assessments in the areas of geotechnical t
engineering, surface-water hydrology, ground-water hydrology, geology, and health physics.
Conditional concurrence on the RAP was provided to DOE on August 26, 1986, (NRC,1986).
That concurrence provided for excavation and construction of the disposal cell (excluding radon barrier placement and cell closure) and l
for transfer and placement of contaminated tailings within the cell.
The
[
3 basis for that concurrence was documented in a Memorandum to Docket File i
WM-48 (NRC, 1987b).
Exceptions and open items included (1) final design of the radon cover, (2) ground-water cleanup strategy, (3) erosion protection, and (4) geotechnical issues.
l Subsequently, NRC concurred in the radon cover design for the disposal cell and all other open items identified in the November 16, 1986, FTER,
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except for the ground-water strategy (NRC, 1990a).
DOE proposed four RAP modifications (DOE,1991d; 1990d; 1989t; 1989d).
All of these were subsequently approved by NRC (NRC, 1991; 1990c; 1989a; 1989b). The NRC staff also reviewed and concurred with Revision 4A of DOE's Remedial Action Inspection Plan (NRC,1990b).
That concurrence was the NRC staff's agreement that the quality control program, i.e., the plan for testing and inspection, was acceptable for the Durango site.
3.2 Review of Remedial Action Performance The 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, RAP modifications, Project Interface Documents (PIDs) 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 construction reviews (see Appendix A), field observations, assessments of onsite data and records, i
and review of DOE site audit reports.
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The following sections present the results of the review of remedial action performance by individual technical discipline. Note that for the t
Durango remedial action completion review, the pertinent technical disciplines are (1) geotechnical engineering, (2) surface-water hydrology and erosion protection, and (3) radiation protection and ground-water hydrology.
a 3.2.1 Geotechnical Engineering Review Results The tC staff reviewed the Durango Draft Completion Report (DOE, i
1991) to determine whether the geotechnical engineering aspects of the remedial action had been completed in accordance with (1) the applicable technical specifications in the RAP (DOE,1991b), and (2)
DUR DRAFT CRR Jufy 1994 5
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P the RAIP Revision 4A (DOE, 1990c), and applicable Class 1 PIDs.
NRC did not review all of the testing and inspection records due to the voluminous amount of documentation. However, the staff did review records during onsite visits during construction.
In addition, the staff's review was based on statements made by DOE in the completion report that all requirements had been complied with, descriptions of l
construction operations, as-built drawings, summaries of laboratory i
and field testing data, and DOE Qua'ity Assurance Audits.
Based on its review of the geotechnical engineering aspects of the remedial action completion documentation, the NRC staff noted the following:
j 1
i 1.
DOE concluded that appropriate tests (gradation and classification) and inspections were performed to assure that the proper type of material was placed for each feature of construction.
The loose thickness of the lifts was continuously l
monitored to ensure compliance with the specifications for that i
I material.
Placement and compaction operations were routinely inspected and tested to assure that the moisture and density requirements were met and that the soil moisture was uniform throughout the compacted li f ts.
2.
DOE concluded that laboratory and field testing was adequately documented indicating that they were conducted in accordance with acceptable test procedures by trained and qualified personnel.
l 3.
The Draf t Completion Report shows that frequencies of materials testing and inspection comply with the frequencies specified in the RAIP.
j 6.
As-built drawings adequately document that the completed remedial action was consistent with the design concurred in by the NRC.
7.
DOE concluded that final slope, elevation, and placement of the disposal cell cover were adequately inspected to ensure that the final conditions were consistent with those stated in the RAP
[
and final design.
l Details of the staff's geotechnical engineering review, which provide the basis for concurring with DOE's conclusions, are included in the attached Appendix B.
Based on the above conclusions, and on the results of onsite inspections performed by the 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 and the l
RAIP.
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3.2.2 Surface Water Hydrology and Erosion Protection Review Results l
l The NRC staff reviewed the surface water hydrology and erosion i
protection aspects of remedial actions at Durango to ensure that they were constructed in accordance with the applicable technical construction specifications in the RAP (DOE, 1991b) and the RAIP (DOE,1990c). Areas of review included as-built 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 construction reviews (see Appendix A).
j The remedial action design featured soil / rock matrix erosion
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protection on the top of the Bodo Canyon Disposal Cell, and riprap on the side slopes and in the diversion ditches.
The erosion protection l
on the top and side slopes of the cell was designed to prevent long-term erosion and gullying of the cell cover. The erosion protection i
i in the diversion ditch was engineered to provide a low-maintenance, armored pathway for conveyance of flood flows around the disposal l
cell.
l The NRC staff reviewed each of these features and determined that their testing, placement, and configuration complied with specifications in the RAP and the RAIP.
The review was partially based on NRC staff observations and review of onsite records during l
the remedial actions, as well as assessment of the results presented in the DOE Draft Completion Report.
During its review of the surface-water hydrology and erosion protection aspects of the remedial action documentation, the NRC staff noted the following:
1.
DOE concluded that tests (gradation ar.d durability) and inspections were adequate to ensure that erosion protection materials were properly selected. However, NRC review of the gradation documentation indicated that DOE did not provide t
sufficient information to confirm that the riprap met the gradation specifications (see Appendix D).
Riprap layer i
thicknesses were verified periodically by DOE to ensure compliance with the specifications for the particular type of
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material.
2.
DOE concluded that laboratory and field testing was documented in accordance with specified test procedures.
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3.
DOE concluded that testing and inspection frequencies for materials used at the site for erosion protection complied with the frequencies specified in the RAIP.
Based on NRC staff observations and review of onsite records during the remedial actions, as well as assessment of the verification
(
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July 1994 7
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r results presented in the DOE Draft Completion Report, the NRC staff concludes that additional documentation is needed to verify that i
riprap gradation tests performed during the remedial action met the specifications (see Appendix D). The NRC staff concludes that the riprap is of adequate quality and has been acceptably placed.
3.2.3 Radiation Protection Review Results The NRC staff reviewed radiation protection aspects of remedial l
actions at Durango to ensure that cleanup of residual radioactive l
materials was performed in accordance with specifications in the RAP and RAP modifications, RAIP, and the final design. Areas of review l
included contaminated material excavation, verification of cleanup, laboratory and field testing, and quality assurance audits.
Speci fic discussion of the details of this review can be found in Appendix B.
The review was based on the NRC staff's assessment of the verification results presented in the DOE Draf t Completion Report.
In addition, the design and construction of the disposal cell cover were reviewed to ensure compliance with the RAP design for limiting radon releases, and thus with the EPA standards.
i During its review of the radiation protection aspects of the remedial t
action completion documentation, the NRC staff noted the following:
1.
The techniques which DOE states to have been used for verifying radiological cleanup at the processing site, complied with DOE's summary protocols and the Vicinity Property Management and l
Implementation Manual (VPMIN) procedures, with which NRC concurred in June 1987.
l 2.
Average Ra-226 concentrations at the processing site met the EPA cleanup standard in 40 CFR 192.
i 3.
Th-230 concentrations along with Ra-226 concentrations after 1000 years of decay met the cleanup standard (RAP Modification 4) except at one grid location.
At this location, l
DOE estimated the radon flux using the RADON computer code and I
concluded that the grid location has been remediated sufficiently.
The NRC staff does not agree that a radon flux estimate can be substituted for a cleanup standard. Therefore, l
DOE should consider removing the contaminated material or restrict access to the contaminated area (see Appendix D).
4.
Two regions adjacent to the Animas River were not remediated because of the risk of injury to workers and environmental harm.
Supplemental standards were applied at these two regions (RAP Modifications 1 and 3 (DOE,1989d; 1990d)) with NRC approval (NRC, 1989b; 1990c).
i 5.
Two steeply-sloping hillside areas on Smelter Mountain were not remediated because of the risk of injury to workers and DUR DRAFT CRR July 1994 8
l i
A environmental harm.
Supplemental standards were applied at these locations (RAP Modification 2 (DOE,1989c)) with NRC approval (NRC, 1989a).
Based on the above statements, the NRC staff concludes that additional documentation is needed to verify that cleanup at the processing site meets applicable standards.
3.2.4 Water Resources Protection The NRC staff reviewed the ground-water actions that have been performed at the processing site. Five monitoring wells have been installed and DOE has been monitoring ground-water quality in the wells since 1985. The DOE has decided that aquifer restoration at the processing site will be addressed under a separate DOE program.
Several actions have taken place at the disposal site which give a high level of confidence that the ground-water resources will not be adversely affected by relocation of residual radioactive materials.
Based on its review of the ground-water aspects of the remedial action completion documentation, the NRC staff noted the following:
l 1.
Design Specification 02090 provides a list of wells scheduled for abandonment and the procedures and materials to be used in sealing the wells. As-Built Drawings in the Completion Report do not show the locations of abandoned wells listed in the J
specification.
DOE should therefore provide an As-Built Drawing showing the locations of abandoned wells (see Appendix D).
2.
In consideration of background water quality, point of compliance wells were established at the downgradient edge of the disposal cell.
3.
To minimize the potential for contamination of ground water at the disposal cell, a 2-feet thick low-permeability material layer was placed at the bottom of the disposal cell.
Infiltration of rainfall into the contaminated material is minimized by a 2-feet thick clay and silt layer and a Claymax l
layer The hydraulic conductivity is estimated to be about _1 0 7
9 x 10 cm/sec for the clay and silt layer and about 1.0 x 10 cm/sec for the Claymax.
4.
During the process of relocating the residual radioactive material, seepage was observed along the eastern side of the disposal cell.
It was subsequently determined that the seepage was due to transient drainage of construction water.
In order l
to remove the water from the cell, a dewatering trench and drain system was constructed along the eastern toe of the cell.
In i
addition, an evaporation pond was constructed to store the collected water. DOE anticipates that the toe drain will be DUR DRAFT CRR Jut / 1994 9
needed for a period of about 7 to 10 years.
Because of this longevity, 00F needs to develop some form of quantitative i
decision to determine when the toe drain system will no longer be needed.
In addition, DOE needs to formulate a procedure for ultimate disposal of the evaporation pond sludges and pond liner (see Appendix D).
1 l
Based on the above conclusions and on the results of onsite reviews during construction, the staff concludes that by placing a low permeability layer in the bottom of the disposal cell prior to relocating the contaminated material, the potential for movement of contaminants into the ground water has been minimized. This potential has been further minimized by placement of a layer of clay and silt and a Claymax layer on top of the contaminated material that is even less permeable than the low permeability layer on the bottom of the cell.
This design imparts a high level of confidence that the ground-water resources at the disposal site will not be impacted due to the minimal amount of liquid that may move through the contaminated material.
Should the amount of liquiu moving through the cell be greater than expected, the ground-water monitoring program will detect changes in ground-water quality. Pending final i
EPA regulations regarding ground-water standards, corrective actions may be required; however, based on the draft ground-water regulations i
that currently exist, sufficient details associated with protection of the ground-water resources at both the processing site and the disposal sites have been implemented.
4.0
SUMMARY
The NRC staff reviewed geotechnical engineering, surface water hydrology and erosion protection, ground-water hydrology and radiation protection aspects of the remedial action performed at the uranium mill tailings site in Durango, Colorado. The purpose of this review was to determine whether DOL had performed remedial actions at the site in accordance with specifications in the l
RAP, modifications to the RAP, PIDs and other supporting project documents, and thus with the EPA standards in 40 CFR Part 192, Subparts A-C.
Based on its t
review of the Draft Completion Report and on observations during periodic site construction reviews, the NRC steff has identified several open issues. These open issues are discussed in Appendix D of this Completion Review Report.
Therefore, the NRC cannot concur that DOE has performed the remedial action at the Durango site in accordance with the above specifications, or that the Durango remedial action complies with the EPA standards in 40 CFR Part 192, Subparts A-C.
00E needs to adequately resolve the open issues identified in Appendix 0.
DOE has proposed deferral of selection and performance of a ground-water cleanup program at this time and plans to handle this as part of a j
separate UMTRA ground-water restoration program. The NRC staff considers DOE's deferral to be acceptable.
I DUR DRAFT CRR July 1994 10 i
5.0 REFERENCES
DOE,1992, Report of Final Audit, Remedial Action Construction, UMTRA Project, Durango, Colorado, U.S. Department of Energy, February 1992.
DOE,1991a, Remedial Action Plan and Site Design for Stabilization of the Inactive Uranium Mill Tailings Site at Durango, Colorado, Remedial Action Selection Report, Revised Final, Appendix B of the Cooperative Agreement No. DE-FC04-84All6257, U.S. Department of Energy, UMTRA-DOE /Al-050503.0000, December 1991.
DOE,1991b, Remedial Action Plan and Site Design for Stabilization of the Inactive liranium Mill Tailings Site at Durango, Colorado, Attachments 1, j
2, 3, 4, 5, and 6, Revised Final, Appendix B of the Cooperative Agreement No. DE-FC04-84All6257, U.S. Department of Energy, UMIRA-DOE /Al-'
050503.0000, December 1991.
DOF, 1991c, Draft Completion Report, Durango, Colorado, Volumes 1, 2, 3, 3A, 4, 5, 5A, 58, SC, SD, SE, and 6, September 1991.
DOE, 1991d, Matthews, M. L. letter, dated May 15, 1991, to Hall, R.
L., U.S.
Nuclear Regulatory Commission, submitting Modification No. 4 to the Remedial Action Plan.
DOE,1990a, Remedial Action Plan and Site Design for Stabilization of the Inactive Uranium Mill Tailings Site at Durango, Colorado, Attachments 1, i
2, 3, 4, 5, and 6, Preliminary Revised final, Appendix B of the Cooperative Agreement No. DE-FC04-84All6257, U.S. Department of Energy, UMTRA-DDE/AL-050503.0000, November 1990.
DOE, 1990b, Uranium Mill Tailings, Remedial Action Project (UMTRAP), Durango, i
Colorado, Calculations, Final Design for Construction, Volumes I, II, 111, IV, V, and VI, September 1990.
DOE, 1990c, Matthews, M. L. letter, dated September 16, 1990, to Hall, R.
E.,
U.S. Nuclear Regulatory Commission, submitting Revision 4A to the Remedial Action Inspection Plan.
00E, 1990d, Matthews, M. L. letter, dated June 19, 1990, to Hall, R. E., U.S.
Nuclear Regulatory Commission, submitting Modification No. 3 to the Remedial Action Plan.
DOE, 1989c, Matthews, M. L. letter, dated October 17, 1989, to Hall, R. E.,
U.S. Nuclear Regulatory Commission, submitting Modification No. 2 to the Remedial Action Plan.
DOE, 1989d, Matthews, M. L. letter, dated July 18, 1989, to Hall, R. E., U.S.
Nuclear Regulatory Commission, submitting Modification No. 1 to the Remedial Action Plan.
DUR DRAFT CRR July 1994 Il
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NRC,1991, Hall, R. E. letter, dated May' 31, 1991, to Matthews, M.L., U.S.
)
Department of Energy, providing concurrence on Modification No. 4 to the Final Remedial Action Plan.
j NRC, 1990a, Hall, R. E. letter, dated October 24, 1990, tn Matthews, M.L.,
U.S.
I Department of Energy, providing concurrence on all the open items identified in NRC's November 16, 1987,.echnical Evaluation Report.
NRC, 1990b, Hall, R. E. letter, dated October 16, 1990, to Matthews, M.L., U.S.
Department of Energy, providing concurrence on the Remedial Action inspection Plan, Revision 4A.
j NRC, 1990c, Yandell, L. A. letter, dated August 22, 1990, to Matthews, M.L.,
U.S. Department of Energy, providing concurrence on Medi fication No. 3 to the Final Remedial Action Plan.
NkC, 1989a, Hall, R. E. letter, dated December 15, 1989, to Matthews, M.L.,
U.S. Department of Energy, providing concurrence on Modification No. 2 to the Final Remedial Action Plan.
i NRC, 1989b, Hall, R. E. letter, dated September 19, 1989, to Matthews, M.L.,
U.S. Department of Energy, p; oviding concurrence on Modi fication No. I to the Final Remedial Action Plan.
NRC, 1987a, Hall, R. E. letter, dated November 27, 1987, to Arthur, W.
J., U.S.
Department of Energy, providing copy of the November 16, 1987 Memorandum For Docket File WM-48.
j l
NRC, 1987b, Memorandum for Docket File WM-48, Final Technical Evaluation Report for the Proposed Remedial Action at Durango, Colorado, November 16, 1987.
i NRC, 1987c, Smith, R. D. letter, dated March 18, 1987, to Anderson, J. R., U.S.
Department of Energy, providing signed signature pages on the Remedial Action Plan.
i NRC, 1986, Smith, R. D. letter, dated August 26, 1986, to lhemelis, J. G., U.S.
Department of Energy, providing conditional concurrence on the Remedial Action Plan.
i i
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DUR DRAFT CRR July 1994 12 i
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APPENDIX A:
NRC SITE VISITS TO lHE DURANGO, COLORADO URANIUM PROCESSING AND DISPOSAL SITES i
i f
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I
,t DUR DFWT CRR July 1994
)
1 APPEN'IX A D
NRC SITE VISITS TO THE DURANGO, COLORADO URANIUM PROCESSING AND DISPOSAL SITES l
DATE STAFF DISCIPLINE PURPOS[
10/2-3/84 G. Gnugnoli Project Management Public Meeting and tour of alternate sites 5/21/85 M. Fliegel Technical Management Observe proposed G. Gnugnoli Project Management disposal area and T. Johnson Surface Water Hydrology rock borrow area 9/8-9/86 E. Hawkins Management Observe construction T. Olsen Project Management activities and assess l
H. Rose Project Management QA/QC program 4/02/87 T. Johnson Surface Water Hydrology Observe stockpiled R. Gonzales Project Management riprap and visit alternate rock sources 5/19/88 T. Olsen Project Management Observe construction I
R. Gonzales Project Management activities and assess QA/QC program 4
8/22/89 E. Hawkins Management Observe construction R. Gonzales Project Management activities and assess D. Jacoby Project Management QA/QC program i
G. Konwinski Project Management j
10/12/89 R. Hall Management Attend DOE's Final j
Inspection at comple-tion of construction i
[
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DUR DFMFT CRR j
July 1994 A-1 r
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l APPENDIX B:
VERIFICATION OF REMEDIAL ACTION ACTIVITIES (DETAllED COMPARISON OF DESIGN SPECIFICATIONS WITH COMPLETED REMEDIAL ACTIONS)
[
i DURANGO, COLORADO, UMTRA PROJECT SITE DUR DRAFT CAR July 1994 i
I I
. ~ - - - - -
~ _... _ _, _. _ _ _ _. _.. _ _ _ _, _ _ _ _. _,
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I VERIFICAT10N OF REMEDIAL ACTION PLAN ACTIVITIES l
Site:
Durango Bodo Canyon Disposal Cell l
RAP Feature:
Subgrade Preparation (pg.1 of 3) 4 RAP Reauirement Verification a.
Configuration:
{
(1) Disposal Cell Bottom - Slopes toward As-Built Drawing No. DUR-DS-10-0334 the east at a gradient varying from (Draft Compl. Rpt., Vol. 2, App. D) j about 2% to about 7%.
(Drawing No.
indicates that the disposal cell bottom i
DUR-DS-10-0334).
was excavated as designed, j
(2) Disposal Cell Sides - Slopes vary As-Built Drawing No. DUR-DS-10-0334 i
from 6H:lv to 3H:lV.
(Drawing No.
(Draf t Compl. Rpt., Vol. 2, App. D) l DUR-DS-10-0334).
indicates that side slopes of disposal cell were excavated as designed.
(3) Drainage Ditches - Bottom slopes of As-Built Drawing No. DUR-DS-10-0335 ditches are 0.5?.
(Drawing No. DUR-(Draft Compl. Rpt., Vol. 2, App. D) i DS-10-0335).
indicates that slopes of the drainage Ditches were constructed as designed.
I i
b.
Materials: - Not applicable i
I c.
Placement:
(1)
Lift Thickness - Not applicable (2) Compaction / Moisture:
Disposal Cell - Top 6 inches of the DOE states that 90 passing in-place l
subgrade area receiving the low tests performed on the disposal cell Permeability Material layer shall be subgrade indicated an average density j
compacted to at least 901 of maximum of 97.6%. One test that failed was dry density as per ASlM D698.
reworked and retested.
(Draft Compl.
(Design Specifications 02200-3.3.A.5 Rpt., Vol. 3, App. E, Contaminated i
and 02200-3.5.C).
Material Subgrade, Pg. 2).
Drainage Ditches - Top 6 inches of DOE states that 21 passing in-place i
the subgrade shall be compacted to a tests performed on the drainage ditch minimum of 95% of maximum dry subgrade indicated an average density 1
density as per AS1M D698.
(Design of 98.9%.
There were no failing tests.
Specifications 02200-3.2.L.2.c.2 and (Draft Compt. Rpt., Vol. 3, App. E, 02200-3.6.B).
Contaminated Material Subgrade, Pg. 3).
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DUR DRAF T CHR July 1991 8-1 i
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1
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1 t
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVillES I
f Site: Durango Bodo Canyon Disposal Cell RAP Feature: Subgrade Preparation (pg. 2 of 3) j RAP Reauirement Veri fi cation f
d.
Test frequency:
i i
2 (1) InplaceFigidDensity-1 test DOE states that an area of 87,861 yd per 1500 yd of compacted in the disposal area was compacted and i
subgrade.
(Procedure 6.1.4 of a total of 90 passing tests were i
the RAIP, Rev. 4A).
performedforagaverageofonepassing test per 976 yd.
For the drainage i
ditches, an area of 28,614 yd" was compacted and a total of 21 passing testswereperformedforangverageof one passing test per 1363 yd.
l The specifications for test frequencies f
are not based on averages; however, DOE i
states that quantities between tests were estimated to never exceed the l
specified test frequencies. Density i
tests were proportionally taken during I
the remedial action.
(Draft Comp 1.
Rpt., Vol. 3, App. E, Contaminated 1
Material Subgrade, Pg. 2).
i (2) One-Point Proctor - 1 test per 5 DOE states that a total of 31 one-point i
field density tests.
(Procedure tests were taken.
Since there were 111
[
6.1.7 of the RAIP, Rev. 4Al.
passing density tests (90 in the i
disposal area and ?1 in the ditches),
this resulted in an average of 1 one-1 point test per 3.6 field density tests, d
(Draft Compl. Rpt., Vol. 3, App. E, Contaminated Material Subgrade, Pg. 4).
i i
l DUR DRAFT CRR Ju!y 1994 B-2 i
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell a
RAP Feature:
Subgrade Preparation (pg. I of 3)
RAP Requirement Verification j
d.
Test frequency (cont'd):
(3) Laboratory Compaction - Maximum dry DOE states that a total of 8 laboratory density tests will be performed at tests were performed. Since there were an approximate rate of 1 test for 111 passing field density tests, this every 10 nr 15 in-place field resulted in an average of I lab test density tests depending on the per 13.8 field density tests.
(Draft variability of materials.
Compl. Rpt., Vol. 3, App. E, (Procedure 6.1.6 of the RAIP, Rev Contaminated Material Subgrade, Pg.
l 4A).
4).
4 2
(4) Nuclear Density Gauge / Sand Cone DOE states that a total of 63 nuclear l
Correlation - Minimum of I sand density tests were performed with 17 cone test for each 10 nuclear gauge sand cone correlation tests.
This tests. Nuclear gauge shall not be resulted in an average of I sand cone l
used where the gauge may be affected test for each 3.7 nuclear gauge tests.
by radiation.
(Procedure 6.1.3 of (Draft Compl. Rpt., Vol. 3, App. E, i
j the RAIP, Rev 4A).
Contaminated Material Subgrade, Pg. 3).
i i
(5) Conventional Oven / Microwave Oven DOE states that for 16 microwave tests Moisture Correlation - Minimum of 1 performed, 6 oven dried comparisons oven dried moisture test for every were made for an average of 1 oven j
10 microwave or nuclear gauge dried moisture test for 2.7 microwave moisture tests performed.
tests.
For the 63 nuclear gauge l
i (Procedure 6.1.2 of the RAIP, Rev density tests,10 oven dried j
i 4A).
comparisons were made for an average of j
1 oven dried moisture test for 6.3 l
nuclear gauge density tests.
(Draft i
Compl. Rpt., Vol. 3, App. E, j
Contaminated Material Subgrade, Pg. 5).
1 l
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f
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DUR ORAFT CRR
]
July 29M B-3 i
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VERiflCA110N OF REMEDIAL ACTION plan AC11VITIES Site: Durango Bodo Canyon Disposal Cell l
RAP Feature:
Low Permeability Material layer (pg. 1 of 5)
RAP Reauirement Veri ficat ion a.
Configuration:
(1) Areal Extent - Entire basin of As-Built Drawing Nos. DUR-DS-10-0338, disposal cell shall be covered with DUR-DS-10-0339, and DUR-DS-10-0341 a low permeability material layer.
(Draf t Comp 1. Rpt., Vol. 2, App. D)
(Drawing Nos. DUR-DS-10-0338, DUR-indicate that the low permeability DS-10-0339, and DUR-DS-10-0341.
material layer was placed as designed.
(2) Thickness - 2 ft. (Drawing Nos. DUR-As-Built Drawing Nos. DUR-DS-10-0338,
~
05-10-0338, DUR-DS-10-0339, and DUR-DUR-DS-10-0339, and DUR-DS-10-0341 DS-10-0341.
(Draf t Compl. Rpt., Vol. 2, App. D) indicate that the thickness of the low permeability material layer is 2 ft.
r b.
Materials:
(1) Similar to Radon Barrier Material.
(Design Specifications 02200-2.1.C.3 I
1 and 2,1,C.2.a).
(a) Gradation - Min. 50k passing the 90. 200 sieve. Max.
DOE states that 88 gradation tests particle size 2 in.
(Design passed the gradation requirement.s.
1 Specification 02200-2.1.C.2.b (Draf t Compl. Rpt., Vol. 3, App. E. Low and Procedure 6.2.3 of the Permeability Material, Pg. 2).
l RAIP, Rev 4A).
(b) Classification - Material shall DOE states that 80 classification tests consist predominantly of passed the material classification soils classified as CL, ML, or requirements.
(Draft Compl. Rpt., Vol.
(Design 3, App. E, low Permeability Material, Specification 02200-2.1.C.2.b Pg. 2).
and Procedure 6.3.3 of the RAIP, Rev 4A).
DUR DRM T CRR July 1994 B-4
-r
- - =,.
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Codo Canyon Disposal Cell RAP Feature:
Low Permeability Material layer (pg. 2 of 5)
RAP Reauirement Verification c.
Placement:
(1) Li f t lhickness - Approximately equal DOE states that Low Permeability thicknesses and the maximum Material was placed on top of the compacted thickness of any one layer subgrade in four lif ts of approximately shall not exceed 6 in.
(Design 6 inches for a final depth of two feet.
Specification 02200-3.3.A.4).
During placement, lift thickness measurements were performed to ensure that compacted lif t thicknesses did not excecd 6 inches.
(Draft Compl. Rpt.,
Vol. 3, App. E, Low Permeability Material, Pg 1).
j (2) Compaction / Moisture - Compaction DOE states that 331 passing in-place shall be at least 90% of maximum dry tests met both the compaction and density. Moisture shall be moisture requirements. The averige maintained below minus 1% of optimum density was 98.4%.
41 tests that moisture as per ASTM D698.
(Design failed initially had to be reworked and
~
Speci fica tions 02200-3.5.D.1 and re ested.
(Draft Compl. Rpt., Vol. 3, 02200-3.3.A.6).
App. E, Low Permeability Material, Pg.
4).
The Low Permeability Layer was placed over a period of three construction seasons. During winter shutdown some areas were exposed to freeze thaw conditions.
To verify the compaction in these areas, 29 additional in-place density tests were performed.
Four areas had to be reworked and retested to meet both the compaction and moisture requirements.
(Draft Compl.
l Rpt., Vol. 3, App. E, Low Permeabili ty l
Material, Pg. 4).
l 6
l DUR DRAFT CRR July 1934 B-5
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VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell P,AP Feature:
Low Permeability Material Layer (pg. 3 of 5)
RAP Requirement Verification
]
d.
Test Frequency:
i 3
(1) In-PlageFieldDensity-Itestper DOE states that 113,529 yd were placed 500 yd of material placed. Minimug and a total of 331 passing in-place of 2 tests for each day that 150 yd tests were performed for an average of i
3 or more are placed and a minimum of one passing test per 343 yd.
(Draft 1 test f or each full shift of Compl. Rpt., Vol. 3 App. E, Low compaction operations.
(Procedure Permeability Material, Pg. 4).
6.1.4 of the RAIP, Rev 4A).
The records maintained by DOE show the in addition, the sand used for volume of low Permeability material determining the volume of the test placed and the number of in-place holes shall be calibrated twice a density tests that were taken.
Because j
day and for each bag of sand, the records show the material placed (Procedure 6.1.8 of the RAIP, Rev and not the material compacted, the 4A).
number of tests recorded do not correlate well with the material that was compacted. However, DOE states that Quality Control personnel pegformedtestsasneededforeach500 yd of compacted material.
(Draft Comp 1. Rpt., Vol. 3, App. E, Low Permeabili ty Material, Pg. 8).
DOE also states that a minimum of two I
in-place moisture density tests werg performed whenever more than 150 yd of material were placed and the sand used for sand cone density tests was calibrated twice a day and at the i
beginning of each new bag of sand.
(Draft Comp 1. Rpt., Vol. 3, App. E, Low Permeability Material, Pgs. 5 & 6).
I I
I f
I DUR DRAFT CHR j
July 1994 B-6 j
I t
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature:
Low Permeability Material Layer (Pg. 4 of 5)
RAP Reauirement Verification d.
Test Frequency (cont'd):
(2) Gradation /C}assification - 1 test DOE states that a total of 88 passing per 2000 yd of material placed. A Gradation tests and a total of 80 minimug of 1 test for each day that passing Classification testg were 150 yd or more are placed.
performed on the 113,529 yd that were (Procedure 6.2.1 of the RAIP, placed.
This amounts to an average of Rev 2).
one passing gradation test per 1290 yd", ang one classification test per (Note: Rev 3A of the RAIP increased 1419 yd.
(Draft Comp 1. Rpt., Vol. 3, 3
the frequency to 1 test per 1000 yd App. E, Low Permeability Material, of material placed.
However, this Pg. 2).
testing frequency increase was made after the Low Permeability layer had The specifications for test frequencies been placed).
are not based on averages; however, DOE states that quantities between tests were estimated to never exceed the specified test frequencies. Gradation and Classification tests were proportionally taken during the remedial action.
(Draft Compl. Rpt.,
Vol. 3, App. E, Low Permeability i
Material, Pg. 6).
In addit. ion, DOE states that a minimum of 1 test was pegformed each week that more than 150 yd of material were placed.
(Draf t Compl. Rpt., Vol. 3, App. E, Low Permeability Material, Pg. 5).
DUR DRAFT CRR July 1994 D-7
,._.~,w,....
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VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Durango Bodo Canyon Disposal Cell RAP Feature:
Low Permeability Material layer (Pg. 5 of 5)
RAP Requirement Verification d.
Test Frequency (cont'd):
(3) Laboratory Compaction - Maximum DOEstatesthatatotalof10laboratorf dry density tests will be tests were performed for the 113,529 yd performedatthergteof1 test thatwereplaced,{oranaverageofone for each 15,000 yd of material test per 11,353 yd.
(Draft Compl. Rpt.,
placed.
(Procedure 6.1.5 of the Vol. 3, App. E, Low Permeability Material, RAIP, Rev. 2).
Pg. 3).
(Note: Rev 3A of the RAIP The specifications for test frequencies are revised the testing frequency to not based on averages; however, DOE states 1 test for every 10 or 15 in-that quantities between tests were place field density tests estimated to never exceed the speci fied depending on the variability of testing frequency and tests were material s. However, this proportionally taken during the remedial revision was made after the Low action and were not taken all in one given Permeability layer had been time frame.
(Draft Compl. Rpt., Vol. 3, placed).
App. E, Low Permeability Material, Pg. 6).
i (4) One-Point Proctor - Testing DOE states that a total of 94 one-point frequency shall be established tests were taken.
Since there were a total by the site quality supervisor.
of 360 passing in-place field density tests A guide would oe 1 test per 5 (331 tests taken during placement and 29 field density tests.
In no case tests taken after winter shutdowns), this should there be more than 10 resulted in an average of 1 one-point test field density tests without a per 3.8 field density tests.
(Draft Compl.
cne-point proctor.
(Procedure Rpt., Vol. 3, App. E, low Permeability.
6.1.6 of the RAIP, Rev 2).
Material, Pg. 3).
l (Note: Rev 3A of the RAIP The specifications for test frequencies are revised the testing frequency to not based on averages; however, DOE states 1 test for each 5 in-place field that quantities between tests were density tests).
estimated to never exceed the specified test frequencies. One-point Proctor tests were proportionally taken during the remedial action.
(Draft Compl. Rpt.,
Vol. 3, App. E, Low Permeability Material, Pg. 6).
DUR DRAFT CRR July 1994 B-8 l
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Durango Bodo Canyon Disposal Cell RAP Feature: Tailings / Contaminated Material (pg.1 of 4)
RAP Requirement Verification a.
Configuration:
(1) Areal Extent - lailings and As-Built Drawing Nos. DUR-DS-10-0335, contaminated material to be placed DUR-DS-10-0336, and DUR-DS-10-0341 in disposal cell as indicated in indicate that tailings and contaminated Drawing Nos. DUR-DS-10-0335, DUR-DS-material were placed in disposal cell 10-0336 and DUR-DS-10-0341.
as was designed.
(2) Slopes - 1.5% to 2% top slope and As-Built Drawing No. DUR-DS-10-0337 SH:lV side slopes as indicated in indicates that slopes of disposal cell Drawing No. DUR-DS-10-0337.
were constructed as designed.
b.
Materials: - Not applicable c.
Placement:
(1) Contaminated materials from the Not verified by DOE - Open issue, See tailings piles (Type 2 Materials)
Appendix D.
shall be placed immediately above the low permeabi ity material layer in the disposal cell.
(Design Speci fications 02200-3.5.C.6 and 02200-1.4.E).
(2) Contaminated materials from Not veri fied by DOE - Open Issu.e, See windblown areas (Type 1 materials)
Appendix 0.
shall be placed directly over the relocated tailings (Type 2 Materials).
(Design Specifications 02200-3.5.C.6 and 02200-1.4.D).
DUR DRAFT CRR auw i9u B-!
g y -- +-
~.
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Durango Bodo Canyon Disposal Cell RAP Feature: Tailings / Contaminated Material (pg. 2 of 4)
RAP Requirement Veri fica t ion c.
Placement (cont'd):
(3) Placement of bulky demolition debris DOE states that placement of and large rocks shall be done with Contaminated Material was continuously care to minimize voids.
Such monitored to assure that debris was material shall not be placed within evenly distributed throughout the 10 feet of the Low permeability disposal cell.
Pieces of debris were layer.
(Design Specification 02200-cut or broken up to be no greater than 3.5.C.ll).
10 feet in any dimension or no greater 3
than 27 ft in volume. No demolition debris was placed within approximately 10 f t. of the Low Permeability Layer.
(Dra f t Compl. Rpt., Vol. 3 App. E, Contaminated Material Fill, Pgs. 1 &
2).
(4) Lift Thickness - Not greater than DOE states that loose lift thickness that required to achieve the measurements were performed which specified compaction. For material verified that loose lif t thicknesses containing particles having a did not exceed 12 inches. Where maximum diameter < 10 in. the loose material contained particles > 12 lift thickness shall not exceed 12 inches, the loose lifts were kept to a in.. For material > 10 in., the minimum constructible thickness in such loose lift shall be kept to the a manner as to avoid voids and provide minimum constructible thickness.
adequate compaction.
(Draft Compl.
(Design Specification 02200-Rpt., Vol. 3, App. E, Contaminated 3.5.C.8).
Material fill, Pg. 1)
(5) Compaction / Moisture - At least 90%
DOE states that 1720 passing in pirce of maximum dry density, as per ASIM tests performed on the Contaminated 0698. (Design Specification 02200-Fill Material met both the compaction 3.5.D.1).
On the side slopes, the and moisture requirements. The average top foot shall be compacted to a density was 95.5%.
58 tests that minimum of 95% of maximum dry failed initially had to be reworked and density, as per ASTM D698.
(Design retested.
(Draft Compl. Rpt., Vol. 3, Speci fication 02200-3.5.C.12).
App. E, Contaminated Material Fill, Pg.
Moisture content shall be maintained 2) to achieve the specified compaction (Design Specification 02200-3.5.D.2).
DUR DRAFT CRR July 1994 B-10
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES l
Site: Durango Bodo Canyon Disposal Cell RAP Feature: Tailings / Contaminated Material (pg. 3 of 4) l l
l RAP Requirement Verification d.
Test Frequency:
(1) InPlacgFieldDensity-1testper D0gstatesthattherewere 1,258,214 1000 yd of material placed. At yd of testable material and a total of legst 2 tests for each day that 150 1720 passing in-place tests were yd or more are placed.
There shall performed for ag average of one passing be a minimum of 1 test for each full test per 732 yd.
(Dra f t Compl. Rpt.,
shift of compaction operations.
Vol. 3, App. E, Contamicated Material (Procedures 6.1.4.b, 6.1.4.d and Fill, Pg. 2).
i i
6.1.4.e of the RAIP, Rev. 4A) l DOE also states thct a minimum of 2 in-place density tests were gerformed each I
day that more than 150 yd of material were placed.
(Draft Compl. Rpt.,
Vol. 3, App. E, Contaminated Material Fill, Pg. 6)
The specifications for test frequencies are not based on averages; however, DOE states that quantities between tests were estimated during the remedial I
action to never exceed the specified I
test frequencies.
Field density tests I
were proportionally taken throughout placement and compaction and were not taken all at one given time. (Draft Compl. Rpt., Vol. 3, App. E, j
Contaminated Material fill, Pg. 7).
l 1
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1 l
l l
l DUR DRAFT CRR i
JWIm g_y)
VERIFICA110N OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature: Tailings / Contaminated Material (pg. 4 of 4)
RAP Reauirement Verification
~~
d.
Test Frequency (cont'd):
(2) Laboratory Compaction - Maximum dry DOE states that a total of 160 density tests will be perforged at a laboratory igsts were performed for the rate of 1 test per 10,000 yd of 1,258,214 yd of testable material.
material placed.
(Procedure 6.1.5 This provide an average of one test of the RAIP, Rev. 2).
per 7,864 yd (Note: Rev 3A of the RAIP revised The specifications for test frequencies the test frequency to 1 test per 10 are not based on averages; however, DOE or 15 in-place field density tests.
states that quantities between tests However, this revision was made were estimated during remedial action after the Tailings / Contaminated to never exce.d the specified test Material had been placed in the frequencies.
1.aboratory tests were Disposal Cell).
proportionally taken throughout placement and compaction and were not taken all in one given time frame.
(Draft Compl. Rpt., Vol. 3, App. E, Contaminated Material Fill, Pg. 7).
(3) One-Point Proctor - Testing DOE states that a total of 398 one-frequency shall be established by point tests were taken.
Since there the site quality supervisor. A were 1720 passing in place field l
guide would be 1 test per 5 field density tests, this resulted in an density tests.
In no case should average of 1 one-point test per 4.3 there be more than 10 field density field density tests, tests without a one-point proctor.
(Procedure 6.1.6 of the RAIP, The specifications for test frequencies Rev 2).
are not based on averages; however, DOE states that the specified frequency was (Note: Rev 3A of the RAIP revised never exceeded and tests were the testing frequency to 1 test for proportionally taken during the each 5 in-place field density remedial action and were not taken all tests).
in one given time frame.
(Draft Compl.
Rpt., Vol. 3, App. E, Contaminated Material Fill, Pg. 3).
DUR DRAFT CRR My e B-12
VERitlCATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature:
Radon Barrier (pg. I of 10)
RAP Requirement Verification a.
Configuration:
(1) Areal Extent - Type C Radon Barrier As-Built Drawing Nos. DUR-DS-10-0338, Material to be placed directly over DUR-DS-10-0339, and DUR-DS-10-0341 the contaminated material. Type A indicate that the three Radon Barrier Radon Barrier Material to be placed Types were placed as designed.
over the Type C Radon Barrier Material on the top of the disposal cell. Type B Radon Barrier Material to be placed over the Type C Radon Barrier Material on the disposal cell side slopes.
(Drawing Nos.
DUR-DS-10-0338, DUR-DS-10-0339, and DUR-DS-10-0341).
(2) Thickness - Radon Barrier Material As-Built Drawing Nos. DUR-DS-10-0338, Types A and B shall be 1.5 ft. thick and DUR-DS-10-0339 indicate that the and Type C shall be 0.5 ft. thick.
thicknesses of Radon Barrier Types A (Drawing Nos. DUR-DS-10-0338, and and B are 1.5 ft. and Type C is 0.5 ft.
DUR-DS-10-0339).
thick.
b.
Materials:
(1) Gradation - Min. 50% passing the DOE states that all gradation tests No. 200 sieve. Max. size 2 in. as performed on Radon Barrier Material met per ASTM Cl36 and ASIM Dll40 the requirements.
(Design Specification 02200-2.1.C.2.b).
25 gradation tests were performed on Type A Radon Barrier Material.
(Draft Compl. Rpt., Vol. 3A, App. E, Type A Radon Barrier, Pg. 2).
34 tests were performed on Type B Material.
(Draft Compl. Rpt., Vol. 3A, App. E, Type B Rado". Barrier, Pg. 2).
28 tests were performed on Type C, Material.
(Draft Comp 1. Rpt., Vol. 3A, App. E, Type C Radon Barrier, Pg. 2).
DUR DRVT CRR July 1994 B-13
i VERIFICA110N OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature:
Radon Barrier (pg. 2 of 10)
RAP Reauirement Verification b.
Materials (cont'd):
l (2) Classification / Atterberg Limits -
DOE states that all classification Radon Barrier Material shall consist tests performed on Radon Barrier predominantly of soils classified Material Types A and 8 met the as CL, ML, or CH as per ASIM D2487.
classification requirements.
(Draft P1 > 10 as per ASTM D4318 (Design Compl. Rpt., Vol. 3A, App. E, Type A l
Specification 02200-2.1.C.2.b).
In Radon Barrier, Pg. 1; and Type B Radon addition, the Type A material shall Barrier, Pg. 1).
contain a minimum of 7% bentonite.
(Design Specification 02200-27 out of 28 classification tests 2.1.C 2.d).
performed on Type C Radon Barrier Material met the classification (Note: The P1 requirement was requirementc. However, two retests on deleted by PID 03-5-34).
the failing material passed the l
classification requirement allowing the material to be accepted.
(DraftCompl.
i Rpt., Vol. 3A, App. E, Type C Radon Barrier, Pg. 1).
In addition, there were 47 percent-bentonite verification tests, all of which indicated that the Type B material contained at least 7%
i bentonite.
(Draft Comp 1. Rpt.,
Vol. 3A, App. E, Type B Radon Barrier, Pg. 5).
(Note: There were no specific frequency requirements for performing
[
percent-bentonite verification tests).
[
i t
DUR DRAFT CW1 July 1994 B-l4
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES 4
Site: Durango Bodo Canyon Disposal Cell RAP Feature:
Radon Barrier (pg. 3 of 10) f RAP Reauirement Verification j
c.
Placement:
(1) Lift Thickness:
DOE states that material placement was continuously monitored to ensure the Type A - Max.12 in. loose lift.
following-(Design Specification 02200-l 3.5.C.8).
Loose lifts of Type A Material did not exceed 12 in.
(Draft Comp 1. Rpt., Vol.
Type B - Loose thickness of lift to 3A, App. E, Type A Radon Barrier, Pg.
achieve a max. 6 in. of compacted 3).
lift.
(Design Specification 02200-l 3.5.C.13).
The compacted lifts of Type B Material j
did not exceed 6 in.
(Draft Compl.
i Type C - Loose thickness of lift to Rpt., Vol. 3A, App. E, Type B Radon i
achieve one 5 in. lift of compacted Barrier, Pg. 4).
l material.
(Design Specification l
02200-3.5.C.8).
Type C Material was placed in one lift i
to acLieve the required 6 in layer.
(Draft Compl. Rpt., Vol. 3A, App. E, Type C Radon Barrier, Pg. 3).
j l
i I
f l
i t
I DUR DRAFT CRR July 1994 B-15
VERIFICATION OF REMEDIAL ACT10N PtAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature: Radon Barrier (pg. 4 of 10)
RAP Reauirement Verification Placement (cont'd):
(2) Compaction / Moisture:
DOE states that in areas where in-place tests failed, those areas were reworked i
Type A - At least 95% of maximum dry and retested.
The results af all density, with moisture content passing tests were as follows:
between optimum moisture and 4%
l above optimum as per ASTM D698.
Type A - 113 in-place tests indicated a (Design Specifications 02200-3.5.D.1 minimum compaction of 95% and an l
and 3.5.D.2).
average of 99.3%.
All moistures were above optimum and ranged from 0% to Type B - At least 100% of maximum
+4.04.
The average moisture content dry density, with moisture content was 1.6% above optimum.
(Draf t Compl.
between optimum moisture and 4%
Rpt., Vol. 3A, App. E, Type A Radon above optimum as per ASTM D698.
Barrier).
(Design Specifications 02200-3.5.D.1 and 3.5.D.2).
Type B - 117 in-place tests indicated a minimum compaction of 100% and an Type C - At least 95% of maximum dry average of 101.1%. All moistures were density on the top of the Disposal above optimum and ranged from 0% to Cell and 100% on the side slopes of
+4.0i.
The average moisture content the Disposal Cell. Moisture was 0.6% above optimum.
(Draft Compl.
condition, if required, to allow Rpt., Vol. 3A, App. E, Type B Radon material to be compacted as Barrier).
speci fied.
(Design Specifications 02200-3.5.D.1 and 3.5.C.15).
Type C - 31 tests performed on top of the Disposal Cell indicated a minimum compaction of 95% and an average of i
100.7%.
34 tests performed on the side slopes of cell indicated a minimum compaction of 100.2% and an average of i
103.1%.
(Draft Compl. Rpt., Vol. 3A, App. E, Type C Radon Barrier).
DUR DRAFT CRR July 1994 B-16
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature:
Radon Barrier (pg. 5 of 10)
RAP Requirement veri fi ca t i on d.
Test f requency:
3 (1) In Place f ield Density and goisture DOE states that 36,534 yd of Type A Content - 1 test per 500 yd of Material were placed and a total of 113 material placed. A minimum of 2 passing tests were performed fgr an 3
tests for each day that 150 yd or average of one test per 323 yd.
more are placed (Procedure 6.1.4 of (Draft Comp 1. Rpt., Vol. 3A, App. E, the RAIP, Rev. 2).
Type A Radon Barrier, Pg. 3).
3 For lype B Material, 45,251 yd were plar.ed and 117 passing tests were performed for an ayerage of one test passing per 388 yd.
(Draft Compl.
Rpt., Vol. 3A, App. E, Type B Radon Barrier, Pg. 6).
3 For Type C Material, 26,627 yd were placed and 65 passing tests were performed for ag average of one passing test per 410 yd.
(Dra f t Compl. Rpt.,
Vol. 3A, App. E, Type C Radon Barrier, Pg. 5).
The specifications for test frequencies are not based on averages; however, DOE states that quantities between tests were estimated during remedial action to never exceed the specified test frequencies. Density and moisture tests were proportionally taken throughout placement and compaction and were not taken all in one given time frame.
(Draft Comp 1. Rpt., Vol. 3A, App. E, Type A Radon Barrier Pg. 8; Type B Radon Barrier Pg. 10; and Type C l
Radon Barrier Pgs. 7 & 8).
DUR DFMFT CR4 July 1934 B-17
l i
l i
VERIFICA110N OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Durango Bodo Canyon Disposal Cell RAP Feature:
Radon Barrier (pg. 6 of 10)
RAP Requirement Veri fi ca ti on d.
Test Frequency (cont'd):
3 (2) Gradation /C}assification - 1 test DOE states that a total of 36,534 yd per 2000 yd of material placed. A of Type A Material were placed and a minimug of 1 test for each day that total of 25 passing tests were 150 yd or more are placed.
performed fgr an average of one test Procedure 6.2.1 of the RAIP, per 1461 yd.
(Draft Compl. Rpt.,
Rev. 2).
Vol. 3A, App. E, Type A Radon Barrier, Pg. 2).
(Note: Rev 3A of the RAIP i m eased i
3 3
the frequency to 1 test per 1000 yd For Type B material, 45,251 yd were of material placed. However, this placed and 33 of 34 tests met the testing frequency increase was made specificatigns for an average of 1 test af ter the Rador. Barrier had been per 1331 yd.
(Note that the failed placed),
test did not meet the P1 requirement i
but the material was accepted anyway).
i The PI requirement was later deleted by j
PID no. 03-S-34).
(Draft Compl. Rpt.,
Vol. 3A, App. E, Type B Radon Barrier, j
Pgs. 2 & 3).
3 For Type C material, 26,627 yd were placed and 28 tests were perforged for j
an average of 1 test per 951 yd.
(Draft Compl. Rpt., Vol. 3A, App. E, Type C Radon Barrier, Pgs. 1 & 2).
l The specifications for test frequencies are not based on averages; however, DOE states that quantities between tests were estimated during remedial action to never exceed the specified test frequencies. Gradation anc classification tests were proportionally taken compaction and l
were not taken all in one given time i
frame.
(Draf t Compl. Rpt., Vol. 3A, App. E, Type A Radon Barrier Pg. 8; Type B Radon Barrier Pg. 10; and Type C i'
Radon Barrier Pgs. 7 & 8).
i i
DUR DRAFl CRR July 1994 B-]8
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell l
RAP Feature: Radon Bar,-ier (pg. 7 of 10)
I RAP Requirement Verification d.
Test Frequency (cont'd):
(3) Laboratory Compaction - Maximum dry DOE states that the same type of I
density (Proctor) tests will be material was required for construction l
performed at a rate of 1 test per of both Type A and Type C Radon 3
15,000 yd of material placed Bagriers. Therefore, for the 63,#J62 (Procedure 6.1.5 of the RAIP, Rev.
yd of materigl placed (36,534 yd Type 2).
A + 26,627 yd Type C), a total of 13 Proctor tests were performd fog an j
average of one test per 4859 yd.
(Draft Compl. Rpt., Vol. 3A, App. E,
-l Type A Radon Barrier, Pgs. 4 & 5; Type i
C Radon Barrier, Pg. 3).
For Type B material, a total of 12 Proctor tgsts were performed for the 45,251 yd that were placed, for an average of one test per 3771 yd.
(Draft Compl. Rpt., Vol. 3A, App. L, Type B Radon Barrier, Pg. 6).
The specifications for test frequencies are not based on averages; however, DOE states that quantities between tests 1
were estimated to never exceed the specified testing frequency, and tests j
were proportionally taken during the remedial action and were not taken all in one given time frame. (Draft Comp 1.
Rpt., Vol. 3A, App. E, Type A Radon Barrier, Pg. 8; Type B Radon Barrier, Pg. 10; Type C Radon Barrier, Pgs. 7 &
8).
l l
DUR DRAFT CAR July 1994 B-19
l VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Durango Bodo Canyon Disposal Cell RAP Feature:
Radon Barrier (pg. 8 of 10)
RAP Requirement Veri fication Test Frequency (cont'd):
(4) One-Point Proctor - 1 test per DOE states that for Type A Material, a i
10 in-place field density tests total of 13 one-point tests were performed.
(Procedure 6.1.6 of the RAIP, Since 113 in-place tests were taken, this i
Rev. 2).
resulted in an average of 1 one-point per j
8.7 in place tests.
(Draft Comp 1. Rpt.,
i Vol. 3A, App. E, Type A Radon Barrier, Pg.
t 5).
i For Type B material, a total of 15 one-i point tests were performed and 117 in-place tests were taken. This resulted in an i
average of I one-point per 7.8 in-place tests.
(Draft Compl. Rpt., Vol. 3A, App.
E, Type B Radon Barrier, Pg. 7).
For Type C material, a total of 11 one-point tests were performed and 65 in place tests were taken. This resulted in an average of 1 one-point per 5.9 in-place tests.
(Draft Compl. Rpt., Vol. 3A, App.
E Type C Radon Barrier, Pg. 5).
The specifications for test frequencies are not based on averages; however, DOE states that quantities between tests were estimated to never exceed the specified i
to, ting frequency, and tests were proportionally taken during the remedial action and were not taken all in one given time frame. (Draft Comp 1. Rpt., Vol. 3A, App. E. Type A Radon Barrier, Pg. 8; Type B Radon Barrier, Pg. 10; Type C Radon Barrier, Pgs. 7 & 8).
i l
I DU3 ORAFT CRR July 19N B-20
i VERIFICATION Of REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature:
Radon Barrier (pg. 9 of 10)
RAP Reauirement Verification l
Test frequency (cont'd):
(5) Nuclear Density Gauge / Sand DOE states that for Type A Material, a Cone Correlation - Minimum of total of 100 nuclear density tests were 1 sand cone test for each 10 performed with 22 sand cone correlation i
nuclear gauge tests. Nuclear tests. This resulted in an average of 1 i
gauge shall not be used where sand cone test for each 4.5 nuclear gauge the gauge may be affected by tests.
(Draf t Compl. Rpt., Vol. 3A, App.
radiation.
(Procedure 6.1.3 of E, Type A Radon Barrier, Pg. 7).
i the RAIP, Rev 4A).
For Type B material, a total of 83 nuclear density tests were performed with 18 sand cone correlation tests. This resulted in an average of I sand cone test for each 4.6 nuclear gauge tests.
(Draft Compl. Rpt.,
Vol. 3A, App. E, Type B Radon Barrier, Pg.
6).
For Type C material, the nuclear density gauge was not used. Therefore, correlation tests were not required.
(Draft Compl.
Rpt., Vol. 3A, App. E, Type C Radon Barrier, Pg. 4).
6 DUR DRN7 CRR July N B-21
l l
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature: Radon Barrier (pg. 10 of 10)
RAP Requirement Verification Test Frequency (cont'd):
(6) Conventional Oven / Microwave DOE states that for 22 microwave tasts Oven Moisture Correlation -
performed on Type A Material, 4 oven dried Minimum of 1 oven dried moisture comparisons were made for an average of 1 test for every 10 microwave or oven dried moisture test for 5.5 microwave nuclear gauge moisture tests tests.
(Draf t Compl. Rpt., Vol. 3A, App.
performed.
(Procedure 6.1.2 of E, Type A Radon Barrier, Pg. 7).
the RAIP, Rev 4A).
for Type B material, 175 microwave dried tests were performed and 36 oven dried comparisons were made for an average of I oven dried moisture test for 4.9 microwave i
tests.
(Draft Compl. Rpt., Vol. 3A, App.
I E, Type B Radon Barrier, Pg. 9).
for Type C material,159 microwave dried tests were performed and 29 oven dried comparisons were made for an average of I oven dried moisture test for 5.5 microwave tests.
(Draft Compl. Rpt., Vol. 3A, App.
E, Type B Radon Barrier, Pgs. 6 & 7).
l l
DUR DRNT CAR July 1994 B-22
.. - = _ _.
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:.Durango Bodo Canyon Disposal Cell RAP Feature:
Bentonite Matting (pg.1 of 1) i RAP Reauirement Veri ficat ion a.
Configuration:
(1) Areal Extent - Bentonite matting As-Built Drawing No. DUR-DS-10-0338 to be placed directly over ile indicates that the Bentonite Matting was Type A Radon Barrier Material on placed as designed.
the top of the disposal cell.
(Design Specification 02773-1.2 and Drawing No. DUR-DS-10-0338).
b.
Materials:
(1) Bentonite matting shall be Not verified b_y DOE - Open Issue. See "Claymax l.C" as manufactured by Appendix D.
Clem Environmental Corporation or approved equal (Design Specification 02773-2.1.A).
c:
Placement:
(1) Bentonite matting shall be DOE states that all seams were inspected pulled tight with the for proper overlap. Continuous inspections polypropylene side facing up.
were performed to verify that installation i
Seams shall be overlapped a procedures were in compliance with the minimum of 6 inches.
(Procedure specified requirements.
(Draft Compl.
6.5.5 of the RAIP, Rev 4A).
Rpt., Vol. 3A, App. E, Bentonite Matting, Pg. 2).
- d. Test Frequency: - Not applicab!e DUR DRAFT ORR July 1994 B-23
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature: Drain Layer (pg. 1 of 2)
RAP Reauirement Verification a.
Configuration:
(1) Areal Extent - The Drain Layer As-Buil t Drawing Nos. DUR-DS-10-0338, DUR-shall be placed directly over DS-10-0339, and DUR-DS-10-0341 indicate the Type B Radon Barrier that the Drain Layer was placed as Material on the side slopes of designed.
the disposal cell.
(Drawing Nos. DUR-DS-10-0338, DUR-DS 0339 and DUR-DS-0341).
(2) Thickness - Nominal 0.5 ft. with DOE states that the material was placed in a tolerance of 0.1 in..
a 0.5 ft. thick layer with a tolerance of (Design Speci fication 02278-0.1 ft.
(Draft Compl. Rpt., Vol. 3A, 3.1.G and 3.2.A.1).
App. E, Drain Layer, Pg. 2).
b.
Materials:
(1) Gradation - (Design Plotted data show that the average value of Specification 02278-2.1.F).
4 tests was within the specified gradation limits.
(Draft Compl. Rpt., Vol. 3A, App. E, Drain Layer).
DOE does not state whether any individual test results were out of the specified limits - Open Issue. See Appendix D.
(2) Durability - (Design Specifications 02278-2.1.F and 02278-2.1.D.1).
Specific Gravity 2 2.5 00E states that 4 tests were performed.
(ASTM C127)
The average spet.ific gravity was 2.64 with a low value of 2.62.
The average weight Na SO Soundness < 10% weight ioss for the Na SO tests was 1.7% with a 2 4 2 4 loss after 5 cycles.
high value of 1.9%.
(Draft Compl. Rpt.,
(ASTM C88)
Vol. 3A, App. E, Drain Iayer, Pg. 1).
1 DUR DRAFT CRR July 1994 B-24 j
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature: Drain Layer (pg. 2 of 2)
RAP Reauirement Verification c.
Placement - Not Applicable d.
Test frequency:
(1) Durability - 1 test at start of DOEstatesthat4durabili}ytestswere production,1 test for the first performed on the 15,635 yd of drain 1/3 and second 1/3 quantities material for an gverage of I durability produced, and a fourth test near test per 3909 yd.
(Draf t Compl. Rpt.,
completion of production Vol. 3A, App. E, Drain Layer, Pg. 1).
activities.
DOEstatesthat4gradatiogtestswere 3
(2) Gradation - 1 test per 10,000 yd performed on the 15,635 yd of drain l
produced. (Design Specification material fog an average of I gradation test 02278-2.1.F).
per 3909 yd.
(Draft Compt. Rpt., Vol. 3A, App. E, Drain Layer, Pg. 2).
The specifications for test frequencies are not cased on averages; however, DOE states that quantities between tests were estimated during remedial action to never exceed the specified test frequencies.
Durability and gradation tests were proportionally taken throughout production, placement and/or compaction and were not taken all in one given time frame.
(Draft Compl. Rpt., Vol. 3A, App. E, Drain Layer, Pg. 4).
i i
DUR DRN7 CAR July 1994 B-25
~
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES site: Durango Bodo Canyon Disposal Cell RAP Feature: Drain and filter Layer (pg.1 of 2)
RAP Requirement Veri fi ca t i on a.
Configuration:
(1) Areal Extent - The Drain and As-Built Drawing No. DUR-DS-10-0338 Filter Layer shall be placed indicates that the Drain and Filter Layer directly oser the Bentonite was placed as designed.
Matting on top of the disposal cell.
(Drawing No. DUR-DS 0338).
(2) Thickness - The material shall DOE states that the Drain and filter Layer be within 1 0.1 f t. of the was constructed to 0.1 ft. of the design design elevation.
(Design elevation.
(Dra f t Comp 1. Rpt., Vol. 3A, Specification 02278-3.2.A.1).
App. E, Drain and filter, Pg. 3).
b.
Materials:
(1) Gradation - (Design Plotted data show that the average value of Speci fication 02278-2.1.G).
4 tests was within the specified gradation limits.
(Draft Compl. Rpt., Vol. 3A, App. E, Drain and Filter).
DOE does not state whether any individual test results were o.ut of the specified limits - Open issue, See Appendix D.
(2) Durability - (Design Specifications 02278-2.1.G and 02278-2.1.D.1).
Specific Gravity > 2.5 DOE states that 4 durability tests were (ASTM C127).
performed.
The average specific gravity was 2.65 with a low value of 2.65.
The was 6.0% with a high value of 6.02k. tests average weight loss for the Na,5 Na2SO Soundness < 10% weight 4
(Draft loss after 6 cycles (ASTM C88).
Compl. Rpt., Vol. 3A, App. E, Drain and Filter, Pg. 1).
DUR DFVET CRR July 1994 8-26
~.
. _. ~ _.
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell
{
RAP Feature: Drain and Filter layer (pg. 2 of 2)
RAP Requirement Veri fication c.
Placement:
(1) Material shall be placed in one DOE states that the material was loaded in l
lif t, spread and bladed to a belly dumps and transported to the site thickness of 6 in..
(Design where it was placed in a 0.5 ft thick l
Specification 02278-3.1.H).
layer.
4 d.
Test frequency:
(1) Durability - 1 test at start of DOEstatesthat4durabiljtytestswere production,1 test for the first performed on the 9,374 yd of material from l/3 and second 1 /3 quantities the Wheeler Pit and 4 tests on material p'oduced, and a fourth test near fromtheSagdcoPit.
Thisaverageg1 test completion of production per 2344 yd and 1 test per 867 yd for the activities.
Wheeler and Sandco Pits respectively.
t (Draft Comp 1. Rpt., Vol. 3A, App. E, Drain i
and Filter, Pgs. 1 & 2).
l DOEstatesthat4gradatiogtestswere I
3 (2) Gradation - 1 test per 10,000 yd performed on the 12,841 yd of drain produced. (Design Specification material fog an average of I gradation test 02278-2.1.F).
per 3210 yd.
(Dra f t Compl. Rpt., Vol. 3A, App. E, Drain and Filter, Pg. 2).
The specifications for test frequencies are not based on averages; however, DOE states that quantities between tests were estimated during remedial action to never exceed the specified test frequencies.
Durability and gradation tests were proportionally taken throughout production, placement and/or compaction and were not taken all in one given time frame.
(Draft Compl. Rpt., Vol. 3A, App. E, Drain and Filter, Pg. 4).
i There is a discrepancy between the volume 04 material tested for durability (IL718 yd ) and the volume of material tested for gradation (12.841 yd').
DOE should provide an explanation - Open Issue. See Appendix 0-dun DRArT CRR July 1994 B-27
i VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature:
Bio-Intrusion Layer (pg.1 of 2)
RAP Reauirement Veri fi ca tion a.
Configuration:
(1) Areal Extent - The Bio-Intrusion As-Built Drawing No. DUR-DS-10-0338 i
Layer shall consist of Type A indicates that the Bio-intrusion Layer was riprap and Bedding Material and placed as designed.
DOE states that the shall be placed directly over Bio-Intrusion Layer was placed directly the Drain and Filter Layer on above the Drain and Filter layer.
(Draft t
top of the disposal cell.
Compl. Rpt., Vol. 3A, App. E, Bio-(Drawing No. DUR-DS-10-0338).
Intrusion, Pg. 1).
[
I (2) Thickness - The material shall DOE states that the Bio-Intrusion Layer was l
be within 1 0.1 ft. of the constructed to 2 0.1 ft. of the design design elevation.
(Design elevation.
(Draft Compl. Rpt., Vol. 3A, Specification 02278-3.2.A.6).
App. E, Bio-intrusion, Pg. 2).
b.
Materials:
(1) Gradation - (Design For results of gradation testing refer to f
Speci fications 02278-2.1.E, the Type A riprap layer summary and the 2.1.C.4 and 2.1.D.2).
Bedding Layer summary.
(Draft Comp 1. Rpt.,
i Vol. 3A, App. E, Bio-Intrusion, Pg.1).
l (2) Durability -
For results of durability testing refer to the Type A riprap layer hummary and the For Type A riprap - (Design Bedding Layer summary.
(Draft Comp 1. Rpt.,
Specifications 02278-2.1.C.3).
Vol. 3A, App. E, Bio-Intrusion, Pg. 1).
For Bedding Material - (Design Specifications 02278-2.1.D.1).
)
l 1
DUR DRAFT CRR July 1994 B-28
)
l 1
VERIFICATION OF REMEDIAL AC110N PtAN ACTIVlilES l
t Site: Durango Bodo Canyon Disposal Cell RAP Feature:
Bio-Intrusion Layer (pg. 2 of 2)
RAP Requirement Verification j
c.
Placement-(1) lhe Bio-intrusion Layer shall DOE states that Type A riprap was loaded consist of a 1.5 ft. thick layer and transported to the site where it was of lype A riprap with the top of placed in a 1.5 ft thick layer with the the layer " choked" with bedding surface choked with bedding material such material. Choking material that a smooth surface resulted.
(Draft shall be spread evenly such that Compl. Rpt., Vol. 3A, App. E, Bio-all bio-intrusion material is Intrusion, Pg. 1).
covered and shall be rolled with l
a smooth drum rolled and bladed i
to provide a smooth surface.
(Design Specification 02278-2.1.E).
(2) Quality Control - Prevent DOE states that daily inspections were degradation of material, uniform conducted to assure that proper techniques distribution, and minimization were used to prevent degradation of the of voids.
(Procedure 6.5.7 of material, to assure that distribution was the RAIP, Rev 4A).
uniform and that voids were kept as minimal as possible.
(Draft Compl. Rpt., Vol. 3A, l
App. E, Bio-Intrusion Pg. 4).
j l
d.
Test Frequency:
(1) A minimum of 4 durability and For results of durability and gradation gradation tests. The first test testing refer to the Type A riprap layer i
shall be performed at the summary and the Bedding Layer summary in i
beginning of placement of this Appendix.
Comp 1. Rpt., Vol. 3A, material. Wheretgetotal App. E, Bio-Intrusion, Pg.1).
volume < 30,000 yd, tests will be performed when approximately j
1/3 and 2/3 of the total volume has been produced /placed. A l
final test shall be performed 1
near completion of production.
[
Wegethetotalvolume>30.000 yd, tests will be performed at a minimum frequency of one test, 3
per 10,000 additional yd.
(Procedure 6.4.3 of the RAIP, Rev 4A).
t DUR DRIET CRR Juy1994 6-29 1
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES
(
i Site: Durango Bodo Canyon Disposal Cell RAP Feature: Frost Protection Layer (pg. I of 2) l l
RAP Requirement Veri fi ca t ion a.
Configuration:
l (1) Areal Extent - The material As-Built Drawing Nos. DUR-DS-10-0338, DUR-l shall be placed over the first DS-10-0339, and DUR-DS-10-0341 indicate l
Bedding layer on the side slopes that the Frost Protection Layer was placed of the disposal cell.
(Drawing as designed.
I Nos. DUR-DS-10-0338, DUR-DS l 0339, and DUR-DS-10-0341.
(2) Thickness - 1.5 ft.
(Drawing As-Built Drawing Nos. DUR-DS-10-0338 and l
Nos. DUR-DS-10-0338, and DUR-DS-DUR-DS-10-0339 indicate that a 1.5 ft.
10-0339 Layer was placed as designed.
b.
Materials:
(1) The Frost Protection Layer shall DOE states that the material used was shot-consist of General Fill rock and soils excavated during permanent material.
(Design Specification ditch construction.
(Draft Compl. Rpt.,
02200-2.1.C.4, and 2.1.C.1).
Vol. 3A, App. E, Frost Protection, Pg. 1).
This material meets the definition of General Fill in Design Specification 02200-2.1.C.1).
(2) Frost Protection Layer material DOE states that placement of the material (uncontaminated fill) shall not was continuously monitored to ensure that contain more than 5% organic it did not contain more than 5% organic material by volume of other material or other deleterious substances.
deleterious substances.
(Design (Draf t Compl. Rpt., Vol. 3A, App. E, Frost Specification 02200-2.1.C.l.b).
Protection Layer, Pg. 1).
c.
Placement:
(1) Lift Thickness - For material DOE states that in most cases, the layer containing particles with a max.
was constructed in one lift because of the diameter < 10 in., the loose large particle size. An inspector lift shall not exceed 12 in..
continuously monitored construction for material containing activities to assure that lifts were held particles > 10 in., the loose to the minimum constructible thickness.
lift shall be kept to the (Draf t Comp 1. Rpt., Vol. 3A, App. E, Frost maximum constructible thickness.
Protection, Pgs.1 & 2).
(Design Speci fication 02200-3.5.D.1).
DUR DRAFT CnR July 1994 B-30
r VERIFICATION OF REMEDIAt ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature: Frost Protection Layer (pg. 2 of 2)
RAP Requirement Verification j
C.
Placement (cont'):
(2) Compaction - At least 90% of DOE states that all the material used in maximum dry density. For the Frost Protection Layer had more than i
materials containing more than 30% retained on the 3/4-in. sieve.
30% retained on the 3/4-in.
Therefore, compaction was achieved by l
sieve, compaction shall be complete coverage of 2 passes of a achieved by complete coverage of Caterpillar 825 compactor.
(Draft Compl.
at least 2 passes. (Design Rpt., Vol. 3A, App. E, Frost Protection, Speci fication 02200-3.5.D.1).
Pg. 2).
lest frequency:
(1) In-PlaceFjeldDensity-Itest Because all the material used in the Frost per 500 yd of material placed.
Protection Layer had more than 30% retained A min of 2 tests for each day on the 3/4 inch sieve, the density of this 3
that 150 yd or more are placed material could not be tested using in-place and a min. of 1 test for each field methods. Therefore, the In-place i
full shif t of compaction testing frequency was not applicable to the operations.
(Procedure 6.1.4 of Frost Protection Layer.
the RAIP, Rev 4A).
l (2) Laboratory Compaction - Maximum Since the in-place testing was not dry density tests will be applicable (see above), there was no need performed at a rate of 1 test to perform laboratory compaction tests.
j for every 10 or 15 in place i
field density tests depending on
{
the variability of materials.
(Procedure 6.1.6 of the RAIP, Rev 4A).
(3) One-Point Proctor - 1 test per 5 One-point proctor tests were not required field density tests (Procedure because there was no need to perform l
6.1.7 of the RAIP, Rev. 4A).
laboratory compaction tests.
}
4 I
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i DUR DRAFT CHR i
July 1934 B-31
1 VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature: Rooting Medium /f rost Protection Layer (pg.1 of 3)
RAP Requirement Veri fication a.
Configuration:
(1) Areal Extent - The material As-Built Drawing No. DUR-DS-10-0338 shall be placed directly over indicates that the Rooting Medium / Frost the Bio-Intrusion Layer on the Protection Layer was placed as designed.
top of the disposal cell.
(Design Specification 02937-3.1.A and Drawing No. DUR-DS 0338).
(2) Thickness - 2.5 ft.
(Design As-Built Drawing No. DUR-DS-10-0338 Specification 02937-3.1.A and indicates that a 2.5 ft. Rooting Drawing No. DUR-DS-10-0338).
Medium / Frost Protection Layer was placed as designed.
b.
Materials:
(1) The Rooting idedium/ Frost DOE states that the material used was Protection Layer shall consist obtained during excavation of the disposal of Uncontaminated Fill material.
cell.
(Draft Compl. Rpt., Vol. 3A, App. E, (Design Specification 02200-Rooting Medium / Frost Protection Material, 2.1.C.5 and 2.1.C.1).
Pg. 1). This material meets the definition of General Fill in Design Specification 02200-2.1.C.1).
(2) Frost Protection Layer material Not verified by DOE - Open issue. See (Uncontaminated Fill) shall not Appendix D.
contain more than 5% organic material by volume of other i
deleterious substances.
(Design Speci fica tion 02200-2.1.C.I.b).
l c:
Placement (1) Lift Thickness - Material to be DOE states that the Rooting Medium / Frost spread in 8-in. minimum lifts.
Protection Layer was constructed in minimum (Design Specification 02937-8-in. li f ts.
(Draft Compl. Rpt., Vol. 3A, 3.1.A)
App. E, Rooting Mcdium/ Frost Protection Material, Pg. 1).
DUR DRAFT CRR JWy W4 B-32
VERIFICA110N OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature:
Rooting Medium / Frost Protection Layer (pg. 2 of 3)
RAP Re_quirement Verification b.
Placement (cont'd):
(2) Compaction - The lower lif ts DOE states that compaction of the lower shall be compacted by at least 2 lifts was achieved by 2 passes of a passes of a CAT 825 sheepsfoot Caterpillar 825 compactor and the top lift compactor or equivalent.
The was compacted to a minimum of 80% of top lift shall be placed to a maximum dry density.
(Draft Compl. Rpt.,
minimum of 80s of maximum dry Vol. 3A, App. E, Rooting Medium / Frost density per ASTM D698. Every Protection Material Pg. 2).
effort should be made to avoid undue overcompaction.
(Design Specifications 02200-3.5.D.1 and 02937-3.1.A).
d.
Test frequency:
3 (1) In-PlacefjeldDensity-1 test DOE states that 14,852 yd were placed and per 500 yd of material placed.
a total of 32 passing in-place tests were A min. of 2 tests for each day performed for ag average of one passing 3
that 150 yd or more are placed test per 464 yd.
(Draft Comp 1. Rpt.,
and a min. of 1 test for each Vol. 3A, App. E, Rooting Medium / Frost full shift of compactio:,
Protection Material, Pg. 2).
operations.
(Proceture 6.1.4 of the RAlP, Rev 4A).
In addition, DOE also states that a minimum of two in-the sand used for determining place moisture density tegts were performed the volume of the test holes whenever more than 150 yd of material were shall be calibrated twice a day placed and the sand used for sand cone and for each bag of sand.
density tests was calibrated twice a day (Procedure 6.1.8 of the RAIP, and at the beginning of each new bag of Rev 4A).
sand.
(Draft Comp 1. Rpt., Vol. 3A, App. E.
Rooting Medium / Frost Protection Material, Pg. 3).
(2) Laboratory Compaction - Maximum DOE states that : total of 3 laboratory dry density tests will be tests were performed.
Since there were 32 performed at a rate of 1 test passing field density tests, this resulted for every 10 or 15 in place in an average of I lab test per 10.7 field field density tests depending on density tests.
(Draft Compl. Rpt.,,
the variability of materiais.
Vol. 3A, App. E, Rooting Medibm/ Frost (Procedure 6.1.6 of the RAIP, Protection Material, Pg. 2).
Rev 4A).
DUR DRAFT CRR July 1994 B-33
I VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature: Rooting Medium / Frost Protection Layer (pg. 3 of 3)
RAP Reauirement Veri fication d.
Test frequency (cont'd):
(3) One-Point Proctor - 1 test per 5 DOE states that a total of 7 one-point field density tests (Procedure tests were taken.
Since 32 density tests 6.1.7 of the RAIP, Rev. 4A).
were performed, this resulted in an average of 1 one-point test per 4.6 field density tests.
(Draft Compl. Rpt., Vol. 3A, App. E, Rooting Medium / frost Protection Material, Pg. 2).
The specifications for test frequencies are not based on averages; however, DOE states that the specified testing frequency was never exceeded and tests were proportionally taken during the remedial action and were not taken all in one given time frame.
(Draft Compl. Rpt., Vol. 3A, App. E, Rooting Medium / Frost Protection Material, Pg. 3 & 4).
DUR DRtIT CnR July 1994 B-34
VERIFICATION OF REMEDIAL ACTION PLAN ACTlVITIES Site: Durango Bodo Canyon Disposal Cell
)
RAP Feature:
Bedding Layer (pg.1 of 2) 1 RAP Reauirement Verification a.
Configuration:
(1) Areal Extent - Bedding Material to As-Built Drawing Nos. DUR-DS-10-0338, be placed above and below the Frost DUR-DS-10-0339, DUR-DS-10-0340, and Protection Layer on the disposal DUR-DS-10-0341 indicate that the cell side slopes.
In addition, Bedding was placed as designed.
bedding along with other materials was required for constructing the Bio-Intrusion Layer and the Rock / Soil Matrix Layer on the top of the disposal cell.
(Draft Comp 1.
Rpt., Vol. 3A, App. E, Bedding Material, and Drawing Nos. DUR-DS-10-0338, DUR-DS-10-0339, DUR-DS '
0340, and DUR-DS-10-0341.
(2) Thickness - The material shall be As-Built Drawing Nos. DUR-DS-10-0338, placed in a 0.5 ft thick layer DUR-DS-10-0339 and DUR-DS-10-0340 except in the grade break transition indicate that the Bedding thicknesses between the disposal cell top and were placed as designed.
side slopes where a 1.0 ft layer is required. (Design Specification 02278-3.2.A.2 and Drawing Nos. DUR-DS-10-0338, DUR-DS-10-0339 and DUR-D5-10-0340.
b.
Materials:
(1) Gradation - (Design Specification Plotted data show that the average 02278-2.1.D.2).
value of 9 gradation tests was within the specified gradation limits.
(Draft U.S. Standard Compl. Rpt., Vol. 3A, App. E, Bedding i
Sieve Size Percent Passing Material).
DOE does not state whether (Sauare Opening)
By Weight any individual test results were out of the specified limits - Open Issue. See 2-inch 100 Appendix D.
3/4-inch 75-100 1/4-inch 55-80 j
No. 10 40-60 No. 40 25-45 No. 200 0-25 DUR DRAFT CRR July 1994 B-35
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site:
Durango Bodo Canyon Disposal Cell l
RAP Feature:
Bedding Layers (pg. 2 of 2) i RAP Reauirement Verification j
b.
Materials (cont'd):
(2) Durability - (Design Specification DOE states that based on 16 durability j
02278-2.1.D.1).
tests, the average Specific Gravity was i
2.55 with a low value of 2.63.
The Specific Gravity > 2.5 (ASTM C127).
Na SO tests indicated an average value 2 4 of 3.9% with a high value of 7.4%.
j Na2SO Soundness < 101 weight loss (Draft Compi. Rpt., Vol. 3A, App. E, 4
after 5 cycles (ASTM C88).
Bedding Material, Pg. 1).
c.
Placement:
(1) Bedding shall be compacted by full DOE states that a Caterpillar D6 dozer coverage of a track-type tractor with a ground pressure 2 8 psi was used with a ground pressure of 8 pounds to compact the Bedding Material.
per square foot (psi).
(Design (Draft Compl. Rpt., Vol. 3A, App. E, Specification 02278-3.1.C).
Bedding Material, Pg. 4).
(2) Bedding placed beneath riprap shall Not verified by DOE - Open Issue. See have visible free water prior to Appendix D.
compaction. (Design Specification 02278-3.1.0).
d.
Test Frequency:
3 (1) A minimum of 4 durability and DOE states that 54,562 yd of Bedding gradation tests.
The first test Material were placed and a total of 16 shall be performed at the beginning durability tests were performed for an 3
of placement of material Where the average of one test per 3410 yd 3
total volume < 30,000 yd, tests will placed.
be performed when approximately 1/3 and 2/3 of the total volume has been 9passinggradationtestsyere produced /placed. A final test shall performed on the 54,562 yd for an 3
be performed near completion of average of one test per 6062 yd production.3 Where the total volume placed.
> 30,000 yd, tests will be performed ataminimumfrequencyo{onetest per 10,000 additional yd.
(Procedure 6.4.3 of the RAIP, Rev 4A).
DUR DRAFT CRR July 1934 B-36
VERIFICATION OF REMEDIAL AC110N PLAN ACTIVITIES Site:
Durango Bodo Lanyon Disposal Cell RAP Feature:
Rock / Soil Matrix (pg. I of 2)
RAP 60uirement Veri fica t ion a.
Configuration:
(1) Areal Extent - Rock / Soil Matrix As-Buil t Drawing Nos. DUR-DS-10-0337, and shall consist of a mixture of DUR-DS-10-0338 indicate that the Rock / Soil Type A riprap, Bedding Material Matrix was placed as designed.
and Top Soil and shall be placed over the entire Rooting Nedium/ Frost Protection t.ayer on top of the Disposal Cell.
(Design Specification 02937-3.1.B and Drawing Nos. DUR-DS-10-0337 and DUR-DS-10--0338).
(2) Thickness - The material shall DOE states that the Rock / Soil Matrix Layer be placed in a 0.5 ft thick was placed to a minimum thickness of 0.5 layer within a tolerance of +0.2 f t. with a tolerance of +0.2 ft. of the ft. (Design Speci ficat ion 02278-design thickness.
(Draft Comp 1. Rpt.,
3.1.8 and Drawing Nos. DUR-DS-Vol. 3A, App. E, Rock / Soil Matrix, Pg. 3).
10-0337, and DUR-DS-10-0338).
b.
Materials:
(1) Gradation -
DOE states that the required mixing ratios were converted to the following Type A riprap, Bedding, and lop percentages:
Soil shall be mixed in the following ratios:
Riprap -- 11.8% to 19.4%.
Bedding -- 14.9% to 23.8%.
Riprap --- 0.8 to 1.2 parts.
Top Soil - 59.7% to 71.4%.
Bedding -- 1.0 to 1.6 parts.
Top Soil - 4.0 to 4.5 parts.
DOE did not document that these percentages (Design Specification 02937-resulted in a mixture that met the 2.3).
r_equirements of Design Specification 02937-2.3. - Open Issue. See Appendix D.
DUR DRAr1 CRR July 19u B-37
VERIFICATION OF REMEDIAL ACTIOli PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP Feature:
Rock / Soil Matrix (pg. 2 of 2)
RAP Reauirement Verification i
Materials (cont'd):
(2) Durability -
For results of durability testing refer to the Type A riprap layer summary and the for Type A riprap - (Design Bedding layer summary in this Appendix.
Specifications 02278-2.1.C.3).
(Draft Compl. Rpt., Vol. 3A, App. E, Rock / Soil Matrix, Pg. 1).
For Bedding Material - (Design Speci fica t i ons 02278-2.1.D.1).
b.
Placement:
(1) Quality Control - Daily DOE states that tests and inspections were inspections of the blending performed on a routine basis at the system and blending plant blending plant during production.
(Draft i
control operations.
(Procedure Compl. Rpt., Vol. 3A, App. E, Rock / Soil l
6.5.6.1 of the RAIP, Rev 4A).
Matrix, Pg. 2).
i d.
Test frequency:
3 (1) Veri fication of the blending DOE states that 11,064 yd of Rock / Soil ratios of riprap, bedding and Matrix Material were placed and a total of top soil shall be conducted by 13 passing ratio verification tests were testing 1 sample obtained from perforged for an average of one test per thg conveyor belt for each 3000 851 yd placed. A minimum of one test was yd blended.
(Procedure 6.5.6 of performed at the start of each day of i
the RAIP, Rev 4A).
production, (Draf t Comp 1. Rpt., Vol. 3A, App. E, Rock / Soil Matrix, Pg. 2).
I l
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DUR DRTT CAR July 1994 B-38 m
~- ~
VERIFICA110N OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Bodo Canyon Disposal Cell RAP feature: Erosion Protection (pg. 1 of 4)
Rl(P Requirement verification a.
Configuration:
(1) Areal Extent - Rock (riprap) to be As-Built Drawing Nos. DUR-DS-10-0337, placed as shown in (Drawing Nos.
DUR-DS-10-0338, DUR-DS-10-0339, DUR-DS-DUR-DS-10-0337, DUR-DS-10-0338, DUR-10-0340, and DUR-DS-10-0341 indicate DS-10-0339, DUR-DS-10-0340, and DUR-that riprap was placed as designed.
DS-10-0341).
(2) Thickness -
DOE states that 8 thickness Type A = 0.50 ft. with a tolerance measurements of Type A riprap, showed of 0.45 f t. Lo 0.63 f t. when placed an average of 0.53 ft., a max. of 0.58 over bedding and 1.5 ft. with a f t., and a min. of 0.49 f t.
tolerance of 1 of the design elevation when used as Bio-Intrusion of 110 measurements on Type B riprap, Layer.
19 tests failed to meet the min. of 0.9 ft.
After reworking, all 19 areas Type B and Type B-1 1.0 ft. with a showed a thickness of at least 0.9 ft.
tolerance of 0.9 f t. to 1.25 f t.
6 of the measurements exceeded the max.
of 1.25 ft with the largest being 1.50 Type C = About 6 ft. to 15 ft. (Used ft. Of 7 measurements performed on in ditch outlets).
Type B-1 riprap, I test exceeded the max. of 1.25 ft with a measurement of (Design Specifications 02278-3.2.A.3 1.34 ft.
The B and B-1 areas that and 3.2.A.4 and Drawing Nos. DUR-DS-exceeded 1.25 ft. were not reworked 10-0337, DUR-DS-10-0338, DUR-DS because there were no visible ridges, 0339, DUR-DS-10-0340, and DUR-DS swales or depressions.
0341).
b.
Materials:
(1) Gradation - (Design Specifications Plotted data show that the average 02278-2.1.C.4) values of 5 gradation tests performed on Type A riprap, 11 on Type B,.4 on Type B-1 and 4 on Type C, were within the specified gradation limits.
(Draft Comp 1. Rpt., Vol. 3A, App. E, Riprap Types A, B, B-1, and C).
IX)E does not state whether an_y individual test results were out of the jspecified limits - Open Issue. See Appendix 0.
DUR DRAFT CRR July 1994 B-39
?
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVillES Site: Durango Bodo Canyon Disposal Cell l
RAP Feature: Erosion Protection (pg. 2 of 4) j RAP Reauirement Verification b.
Materials (cont'd):
f (2) Durability - (Design Specifications DOE states that lab. tests results were 02278-2.1.C.3).
as follows:
i Specific Gravity 2 2.55 (ASTM C127).
Speci fic Gravity:
Type A -
Low = 2.67; Ave.= 2.68.
Type B -
Low = 2.64; Ave.= 2.69.
Type B Low = 2.70; Ave.= 2.71.
Type C -
Low = 2.62; Ave.= 2.64.
t Absorption s 1.0% weight gain (ASTM Absorption:
C127).
Type A -
High = 0.88%;
Ave.= 0.50%.
Type B -
High = 0.94%;
Ave.= 0.48%.
Type B liigh = 0.30ft; Ave.= 0.27%.
Type C -
High = 0.86%;
Ave.= 0.56%.
Na2SO Soundness s 5% weight loss Na2SO Soundness:
4 4
af ter 5 cycles (ASTM 088).
Type A -
High = 3.50%;
Ave.= 1.83%.
Type B -
High = 2.80%;
Ave.= 1.36%.
Type B High = 4.40%;
Ave.= 2.70%.
l Type C -
High = 3.60%;
Ave.= 2.94%.
L.A. Abrasion s 10.5 % weight loss L.A. Abrasion.
after 100 revolutions.
Type A -
iligh = 8.00%;
Ave.= 5.73%.
Type B -
liigh = 8.30%;
Ave.= 6.40%.
[
Type B High = 5.60i; Ave.= 4.70%.
Type C -
liigh = 9.30%;
Ave.= 7.80%.
Petrographic Examination - Minimum Petrographic Examinations of the rock of 1 test per rock source from the approved Wheeler Pit were performed as required.
(Draft Compl. Rpt., Vol. 3A, App. E, Riprap Types A, B, B-1, and C).
DUR DRAFT CRR July 1994 B-40
.=.
i VERIFICATION OF REMEDIAL ACTION PLAN ACllVITIES f
Site: Durango Bodo Canyon Disposal Cell I
RAP Feature:
Erosion Protection (pg. 3 of 4) i RAP Reauirement Verification
(
c.
Placement:
(1) Quality Control - Uniform DOE states that daily inspections were j
distribution, minimization of conducted during excavation, voids.
(Procedure 6.3.7 of the production, and stockpiling to assure l
RAIP, Rev. 4A). Material shall that the riprap was dense, sound, be dense, sound, resistant to resistant to abrasion and free from
(
abrasion, and shall be free cracks. Additionally, inspections were from cracks, seams, and other conducted during loading, transporting, defects as shown in the and placing to assure that proper petrographic examination.
techniques were employed to prevent (Design Specification 02278-degradation of the material, to assure 2.1.C.1).
that distribution was uniform, to minimize voids and to assure that proper gradation was maintained.
(Draft Compl. Rpt., Vol. 3A, App. E, Riprap Types A, B, B-1, & C,).
l (2) Dimensional Analysis - The shape of DOE states that the percentages of i
at least 75% of the material, by material having a minimum dimension not weight, shall be such that the less than one third of the maximum minimum dimension is not less than dimension were 77.4%, 89.2's, 91.9% and one third of the maximum dimension.
94.9% for Riprap Types A, B, B-1 and C (Design Specification 02278-respectively.
(Draft Compl. Rpt.,
2.1.C.2).
Vol. 3A, App. E Riprap Types A, B, B-1, & C,).
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i DUR DRAFT CRR July 1994 B-41
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIE_S Site: Durango Bodo Canyon Disposal Cell RAP Feature: Erosion Protection (pg. 4 of 4)
RAP Reauirement Verification d.
Test frequency:
(1) A minimum of 4 durability and DOE states that 7 durability and 5 gradation tests. The first test gradation tests were performed on 3
shall be performed at the beginning 39,643 yd of Type A riprap for an of placement of material Where the avgrage of I durability test per 566) 3 total volume < 30,000 yd, tests will yd and 1 gradation test per 7929 yd.
be performed when approximately 1/3 (Draft Compl. Rpt., Vol. 3A, App. E, i
and 2/3 of the total volume has been Riprap Type A, Pgs. 1 & 3).
i produced /placed. A final test shall be performed near completion of for Type B riprap, 9 durability and 11 production.3 Where the total volume gradation tests were performed on 3
ataminimumfrequencyo{onetest durabilitytestper6144yg{and1
> 30,000 yd, tests will be performed 55,294 yd for an average o
}
per 10,000 additional yd.
gradation test per 5027 yd.
(Draft (Procedure 6.4.3 of the RAIP, Rev Compl. Rpt., Vol. 3A, App. E, Riprap 4A).
Type B, Pgs. 1 & 2).
4 durability and gradation tests each were performed for Types B-1 and C riprap.3 Thetotalvglumesplacedwere 3171 yd and 4660 yd for Types B-1 and C respectively.
(Draft Compl. Rpt.,
Vol. 3A, App. E, Riprap Types B-1 & C).
3 As these volumes were < 30,000 yd, 4 tests per riprap type is an acceptable number.
DUR DRAFT CRR July 19N B-42
VERIFICA110N OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Processing Site and Bodo Canyon Disposal Cell RAP Feature: Water Resources Protection Issues (pg. I of 1)
RAP Reauirement Verification (1) 17 test wells at the Processing Site As-Built Drawings do not show the and 11 test wells at the Disposal locations of the wells nor do they Cell shall be sealed in accordance indicate that the wells were sealed as with procedures described in Design required.
Specification 02090.
DOE should revise the As-Built Drawings to show the locations of the wells that were sealed and provide assurance that the wells were scaled according to the procedures disc _ussed in Design Speci fication 02090. - Open issue. See Appendix D.
(2) A dewatering trench and drain system As-Built Drawing Nos. DUR-DS-10-0342, shall be constructed along the DUR-DS-10-0343, and DUR-DS-10-0344 eastern toe af the Disposal Cell.
indicate that the dewatering system was (Design Specification 02142 and constructed as designed.
PID's 03-S-22 and 03-S-22 Rev.1).
DUH DRAFT CRR July 1934 B-43
VERIFICATION OF REMEDIAL ACTION PLAN ACTIVITIES Site: Durango Processing Site RAP Feature:
Site Cleanup (pg.1 of 1)
RAP Requirement Veri fication a.
Cleanup Verification Procedures:
(1) Determine average Ra-226 on DOE states that the processing site was approximately 100 square meter divided into 30 x 30 ft. grids and areas.
(Section 6.5.3 of the sampled per the procedures in RAC-015 Remedial Action Selection (RAS)
(Draft Compl. Rpt., Vol. 4, App. J).
Report, HP Procedure, RAC 015, Verification Procedures - Soil Sampling and Analysis.)
b.
Test Results:
(1) Ra-226 - Average concentration The EPA standards for Ra-226 (including within each grid to meet the EPA background) are 6.6 pCi/gm for depths standard in 40 CFR 192 which is not
<l5 cm. and 16.6 pCi/gm for depths to exceed background by:
>l5 cm.
DOE states that of 4081
- 5 pci/gm in the top 15 cm.
samples taken and analyzed, all met the
- 15 pCi/gm in subsequent 15 cm EPA standard. For depths <l5 cm the layers.
max. concentration was 6.5 pCi/gm and for depths > 15 cm, the max.
(Note: Background Ra-226 concentration was 16.3 pCi/gm.
The concentration at Durango is 1.6 average concentration of all samples pCi/gm.)
was 2.65 pCi/gm.
(Draft Compl. Rpt.,
Vol. 4, App. J).
(2) Th-230 concentrations along with Ra-DOE states that of 856 samples taken 226 concentrations, af ter 1000 years and analyzed, all were found to meet of decay shall not exceed the EPA the EPA standards except grid location Ra-226 standard in 40 CFR 192 which H-38-20.
At this location, the 1000-yr is:
Ra-226 concentration was estimated at
- 5 pci/gm in the top 15 cm.
18.6 pCi/gm. DOE then estimated the
- 15 pCi/gm in subsequent 15 cm radon flux using the RADON computer layers.
code and concluded that grid location H-38-20 has been remediated sufficiently.
(Draft Comp 1. Rpt.,
Vol. 4, App. J).
The NRC staff does not agree that a radon flux estimate can be substituted for a cleanup standard.
Therefore. DOE should consider removing the contaminated material or restricting the contaminated area.
DUR DRAFT CRR July 1994 B-44
_ _. - ~ _ _.. _ _. -. - _. - -
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P APPENDIX C:
VMTRCA, THE EPA STANDARDS, AND THE PliASED UMTRA PROJECT 1
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F 1
L I
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6 l
DUR DRAFT CRR July 1994 l
a
+m~-
w-.,
~. -.,..,. - --,, - - -
5
l
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APPENDlX C:
UMTRCA. THE EPA STANDARDS. AND THE PHASED UMTRA PROJECT Title I of the Uranium Mill Tailings Control Act of 1978 (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 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.
Af ter 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:
1.
The disposal site shall be designed to control 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
[40CFR192.02(a)].
2.
Provide reasonable assurance that the disposal site design shall prevent radon-222 from residual radioactive material to the atmosphere from exceeding 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)].
3.
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 i
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/gnm averaged over any 15 centimeters more than 15 centimeters below the surface
[40CFR192.12(a)].
The portion of the EPA standards dealing with ground water 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 DUR DRAFT CRR
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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.
x 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 i
disposal sites after completion of the remedial action to comply with EPA's final ground water 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 ground water standards will not be impacted by the final ground water standards. Although additional effort may be appropriate to assess and clean up contaminated ground water at these sites, the existing designs of the disposal sites should be considered sufficient to provide long-term protection against future ground water 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 Remedial Action Plan 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 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 Remedial Action Plan. 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. Prior to licensing (the next phase), title to the disposed tailings and contaminated materials must be transferred to the DUR DRMT CRR July IW4 C-2
United States and the land upon which tiiey 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 j
accomplished in two steps where residual radioactive material is not being 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 ground water restoration, for the first step of closure and licensing.
The second step, which can go on for many trs, will deal with existing ground water restoration. When ground water re uration is I
completed, the Long-Term Surveillance Plan required under the lic asing phase will be appropriately amended.
For sites that are being moved, licensing will occur in one step.
There is no ground water restoration at the disposal site and the processing site will not be licensed after completion of remedial action.
The_Licensin_g Phas_e t
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 f
has been properly reclaimed and (2) the formal receipt by NRC of an acceptable Long-Term Surveillance Plan (LTSP).
NRC concurrence with DOE's performance of i
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.
j 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, especially in the planning stages i
of remedial action when such input can be most effective in identifying and
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resolving issues affecting long-term care. At the time the LISP is submitted, the NRC will consider the need for a public meeting in response to requests and public concerns.
Therefore, NRC encourages State / Indian tribe and public participation early in the remedial action and closure process and will l
provide additional opportunities, as needed, later in the process.
the Surveillance and Monitorina Phase 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 repairs, if needed.
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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. Although the design of the stabilized pile is such that reliance on active maintenance should be minimized or eliminated, the NRC license will
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require emergency repairs as necessary.
In the event that significant repairs are necessary, a determination will be made on a site specific basis regarding the need for additional National Environmental Policy Act (NEPA) actions, and l
health and safety considerations from 10 CFR Parts 19, 20, and 21.
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i APPENDIX D:
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t OPEN ITEMS AND
GENERAL COMMENT
S FOR RESOLUTION BY DOE i
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APPEN0lX D OPEN ITEMS 1.
Records in Volume 3 of the Draft Completion Report show that the Low Permeability Layer was placed in the Disposal Cell during the period 7/7/87 to 10/15/90, and the Contaminated Materials were placed in the cell during the period 8/1/87 to 6/14/90.
Since the Low Permeability Layer is supposed to underlie the Contaminated Material, please explain why placement of the Low Permeability Layer continued after the Contaminated Materials were in place.
2.
Design Specifications 02200-1.4.D, and 02200-3.5.C.6 required that contaminated materials from windblown areas (Type 1 materials) be placed in the disposal cell above Type 2 Materials.
This requirement was not addressed in the Draft Completion Report.
3.
Design Specifications 022000-1.4.E, and 02200-3.5.C.6 require that contaminated materials from the tailings pile (Type 2 materials) be placed in the disposal cell immediately above the Low Permeability Material layer disposal cel!. This requirement was not addressed in the Draft Completion Report.
4.
Design Specification 02773-2.1.A requires that Bentonite matting shall be "Claymax LC" as manufactured by Clem Environmental Corporation or approved equal. The Draft Completion does not address this requirement.
5.
Design Specification 02278-2.1.F provides the gradation limits for the Drain Layer.
In the Draft Completion Report, Volume 3A, Appendix E, Drain Layer, DOE presented plotted data that show that the average of four gradation tests was within the gradation limits. DOE should verify that all four individual tests met the gradation specifications.
6.
Design Specification 02278-2.1.G provides the gradation limits for the Drain and Filter layer.
In the Draft Completion Report, Volume 3A, Appendix E, Drain and Filter, DOE presented plotted data that show that the average of four gradation tests was within the gradation limits.
DOE should verify that all four individual tests met the gradation specifications.
7.
There appears to be a discrepaacy in the volume of Drain and Filter material that was tested for gradation and durability. On pages 1&2 of Volume 3A,AppendixE,DrainandgilterLayer,DOEstatesthatgrgdation tests were performed on 12,841 yd of Material but only 11,718 yd were tested for durability. DOE should explain or correct this discrepancy 8.
Design Specification 02200-2.1.C.l.b requires that uncontaminated fill shall not contain more than 5% organic material by volume of other deleterious substances.
Uncontaminated material was used for the Rooting Medium /Frest Protection layer. However, the Draft Completion DUR DRAFT CAR July 1994 D-1
Report, Volume 3A, Appendix E, RooLing Medium / Frost Protection, does not indicate that this specification was met. DOE should verify that the Rooting Mcam/ Frost Protection Layer met this specification 9.
Design Specification 02278-3.1.0 requires that Bedding Material placed beneath riprap shall have visible free water prior to compaction. DOE should verify that Bedding beneath riprap met this specification 10.
Design Specification 02278-2.1.G provides the gradation limits for the Bedding layer.
In the Draft Completion Report, Volume 3A, Appendix E, Bedding Material, DOE presented plotted data that show that the average of 9 gradation tests was within the gradation limits.
DOE should verify that all 9 individual tests met the gradation specifications.
11.
Design Specification 02937-2.3 requires that the Rock / Soil Matrix consist of Type A Riprap, Bedding Material, and Top Soil In the following ratios:
Type A Riprap - 0.8 to 1.2 parts Bedding 1.0 to 1.5 parts Top Soil ------ 4.0 to 4.5 parts In the Draft Completion Report, Volume 3A, Appendix E, Rock / Soil Matrix, DOE states that these ratios were converted to percentages and the percentages were then used to blend the materials.
The percentages used by DOE to blend the three materials were as follows:
Type A Riprap - 11.8% to 19.4%
Bedding 14.9% to 23.8%
Top Soil 59.7% to 71.4%
In PID 03-S-36, DOE approximated the loose densities as 105 pcf for Type A riprap,130 pcf for Bedding and 90 pcf for Top Soil.
Since approximately equal parts of Type A riprap and Bedding Material were to be blended together, it appears logical that the percentages of Bedding should be less that those of the Type A riprap since the bedding has a higher density.
However, this is not the case as the Bedding percentages (14.9% to 23.8%) are larger that the Type A riprap percentages (11.8% to 19.4%). DOE should discuss and verify that the percentages used to blend the Rock / Soil Matrix actually resulted in a mixture that met the requirements of Design Specification 02937-2.3 12.
Soil cleanup verification procedures at the processing indicated that grid location H-38-20 did not meet the EPA standards. At this location, the 1000-yr Ra-226 concentration was estimated at 18.6 pCi/gm.
DOE then estimated the radon flux using the RADON computer code and concluded that grid location H-38-20 had been remediated sufficiently (Draft Compl. Rpt., Vol. 4, App. J). The NRC staff does not agree that a radon flux estimate can be substituted for a cleanup standard. Therefore, DOE should consider removing the contaminated material or restricting the contaminated area.
DUR DfwT CRR July 1994 0-2 L
13.
Design Specification 02090 descri6es the materials and procedures to be-used to seal abandoned wells at both the Processing Site and at the Disposal Cell. However, the Draft Completion Report does not indicate that this specification was met. DOE should therefore revise the As-Built Drawings to show the locations of the wells that were sealed and provide assurance that the wells were sealed according to the procedures discussed in Design Specification 02090.
GENERAL COMMENT
S 1.
In Volume 3 of Appendix E the Tab titled, " CONTAMINATED MATERIAL SUBGRADE" should be titled " DISPOSAL CELL SUBGRADE," to make it consistent with the Index.
1 DUR DRAFT CRR July 1994 D-3 L_
l U.S. Department of Energy TR 2 01994 Case Closed:
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