ML20204D987
| ML20204D987 | |
| Person / Time | |
|---|---|
| Issue date: | 09/28/1988 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Arthur W ENERGY, DEPT. OF |
| References | |
| REF-WM-68 NUDOCS 8810210264 | |
| Download: ML20204D987 (6) | |
Text
e SW/GRN/RAIP/ COMMENTS 3 8 SEP 1988 W. John Arthur, Project Manager Uranium Mill Tailings Project Of fice Department of Energy Albuquerque Operations Office P.O. Box 5400 Albuquerque, NM 87115
Dear Mr. Arthur:
On September 6, 1988,)the NRC received the Green River, Utah, Remedial Action InspectionPlan(RAIP for review and concurrence. The NRC staff has completed, its review of the RAIP and identified the enclosed comments and recommended revisions. Upon receipt of adequate responses to the enclosed coments the NRC will continae its review towards concurrence with the RAIP.
If you have any coments or questions concerning the above discussion, please contact M. Fliegel, of my staff at FTS 492-0555.
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/m Paul H. Lohaus, Chief Operations Branch Division of Low-level Waste Management and Decomissioning
Enclosure:
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GEOTECHNICAL ENGINEERING REVIEW OF L
PEMEDIAL ACTION INSPLCTION PLAN FOR UMTRA PRNECT CREEN RIVER, UTAH l
Document Reviewed:
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UMTRA Project, Green River, Utah, Remedial Action Inspection Plan (RAIP)..
Testing and Inspection; Document No. NKF-UtiTRA-30 Rev. A, Prepared by MKF for 00E, September 01,1988.
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Reference:
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Staff Technical Position on Testing and Inspection Plans during Construction of DOE's Remedial Action at Inactive Uranium Mill Tailings Sites Low-Level Waste and Uranium Recovery Projects Branch, U.S. Nuclear ReguIatory Consnission, Rev.1, March 1987.
Geutechnical Engineering Comments,on Testing and Inspection aspects of RAl_P:
1.
Section 6.1.2, Field Density Control l
t The RAIP states that when a speedy moisture meter is used in the determination of noisture content, a correlation sample will be oven dried a minimum of every tenth moisture test.
However the NRC Staff Technical Position requires i
that when speedy moisture meters are used to test contaminated material and I
radon barrier material, a correlation with the oven drying method (ASTM i
0-2216) should be developed for each test. Similarly, when testing other compacted materials, a correlation should be developed for every tenth test, or i
more frequently if calibration of the moisture meter is necessary after every tenth test.
If a nuclear density gauge is used, the correlation tests for both moisture (oven drying) and density (sand cone method) should era at a rate of l
one for every five tests. The RAIP should be revised to comply with the f
guidance ir the NRC Staff Position on Testing (Reference 1) or an acceptable justification with adequate backup information should be provided for the
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alternatives proposed in the RAIP l
2.
Section 6.1.4.e, Field Density Control The PAIP does not require the in-place density and moisture testing %Quencies to be a function of the compaction operation shift and/or material placement t
lifts.
The testing frequencies in the RAIP should be amended to include c cininun requirement of one test per full shift of operation and/or one i
test per each lift on material placement. The RA!P should be revised to
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I ccmply with the guidance in the NRC Staff Position on Testing (Reference 1) or l
an acceptable justification with adequate backup information should be provided for the alternatives proposed in the RAIP.
3.
Section 6.1.7, Field Density Control e
The RAIP states that the site quality supervisor shall establish the frequency l
of performing one point proctor tests to evaluate the maximum dry density.
Suggested guidance in the RAIP is one test for every ten field density) tests, l
In order to comply with the NRC Staff Position on Testing (Reference 1 the requirement in the RA!P for performing one point proctor test should be amended I
to require one test for every five field density tests or an acceptable justification with adequate backu) information should be provided for the i
alternatives suggested in the RAl).
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LLTB-SITING COMMEhTS ON ThE GREEN RIVER RAIP REVISIONS TO DEMONSTRATE' COMPLIANCE WITH 40 CFR 192 1.
Section 6.0. In-situ Hydraulic Conductivity Testing Section 6 omits procedures for treasuring the in-situ hydraulic conductivity of t.5: radon barrier.
The Remedial Action Plan (RAP) identifies a saturated hydraulic conductivity less than or equal to 1E-7 cm/s as a design criterion for the radon barrier.
Performance of the disposal unit relies directly on the hydraulic conductivity of the raden barrier to limit infiltration into the tailings, thereby protecting groundwater downgradient from the unit.
Therefore, field testing is necessary to verify that the saturated hy<iraulic ccnductivity of the radon barrier is less than or equal to IE-7 cm/s.
Is-situ hydraulic conductivity of the radon barrier can be measured using a redified Double Ring Infiltrometer (ASTM D 3385 75), Modified Air-Entry Pertwameter, or other techniques. COE should revise the RAIP to (1) require a sufficient nutter of measurements of in-situ hydraulic conductivity of the radon barrier to verify compliance with the IE 7 cm/s design hydraulic conductivity criterion established in the RAP, or (2) provide an alternative basis to verify that the saturated hydraulic conductivity of the radon barrier will be less thar. or equal to IE-7 cm/s.
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2.
Section 6.4.5.4. Radon Barrier Thickness l
1 Section 6.4.5.4 of the RAIP indicates that analysis of Th-230 and Ra-226 concentrations in emplaced tailings will be used to determine the final thickness of the radon barrier.
The statement ir. plies that 00E could reduce the thickness of the radon barrier to less than the thickness required in the RAP. Although such reductions ray be appropriate with respect to radon 4'.tenuation, they could significantly reduce the effectiveness of the barrier in limiting infiltration into the tailings. Therefore, the RAIP should be
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revised to state that the radon barrier thickness may be adjusted based on the Ra-226 and Th-230 concentrations in the emplaced tailings, provided that barrier thickness exceeds the minimum thickness criterion adopted in the RAP, SUGGESTED REVISIONS 1.
Statement of Policy The third paragraph of the policy statement states that NK-Ferguser. Cornpany will assure satisfaction of EPA and NRC requirenents.
The NRC has not established any requirements for the UMTRA Project. NRC's review and concurrence with DOE's proposed remedial actions are intended to assure compliance with EPA's requirements.
Therefore, DOE should delete the reference to NRC requirerents in its 3tatement of Policy.
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2.
Section 6.4.3, Size Limits for Organics Section 6.4.3 of the RA!P requires that inspections assure that the maxiri.n size of emplaced organic material does not exceed the specified requirements, licwever, the RAIP does not state or reference these requirenents.
The RA!P should be revised to state or reference limits on the maximum size or amount of emplaced organic materials.
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g SW/GRN/RAIP/ COMMENTS
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f 0Gillen, LLOB SWastler, LLOB HFliegel, LLOB PLohaus, LLOB JSurmeier, LLTR MBell, LLRB JGreeves,LLhH HKnapp, LLWH D5mith, URF0 LAnderson, Utah e
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