ML20206C264

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Forwards NRC Staff Technical Position on Testing & Insp Plans During Const of DOE Remedial Action at Inactive U Mill Tailing Sites
ML20206C264
Person / Time
Issue date: 03/11/1987
From: Martin D
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: James Anderson
ENERGY, DEPT. OF
Shared Package
ML20206C256 List:
References
REF-WM-68 NUDOCS 8811160195
Download: ML20206C264 (2)


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ATTACHMENT #6

[a ceco,Do UNITED STATES

!'i 7 NUCLEAR REGULATORY COMMISSION

{, $ WASHINATON D. C. 20$55 k *....

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MAR 11 W  :.g .,; , -- , . . g, . , , , , ,

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Janes R. Anderson, Project Manager  ?'.'.' " T "

Uran.um Mill Tailings Proje-t Office U. S. Departrent of Energy 2J nia?

P.O. Box 5400 Albuquerque, NH 87115 "s - --

Oear Mr. Anderson:

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Enclosed for your information is Revision 1 of the NRC Staff Technical l Position (STP) on Testing and Inspection Plans during Construction of DOE's Remedial Action at Inactive Mill Tailings Sites.

Se. tion 3.2.3, Compaction Evaluation Procedures, has been revised to reflect experience gained from the field testing programs (specifically nuclear gauge moisture / density testing) conducted at the Shipreck, New Mexico and Clive.

Utah UMTRAP sites. The revised STP will be used as a basis for NRC staff reviews of all future site-specific 00E Retr.edial Action Inspection Plans.

If you have any questions concerning this revision, please contact Dan Gillen of my staff at (FTS) 427-4160. .

Sincerely.

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Dan E. Martin, Section Leader Uraniam Recovery Projects Section Low-Level Waste and Uranium Recovery Projects Branch Division of Waste Management Office of Nuclear Material Safety and Safeguarcs

Enclosure:

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WN-39/DCG/85/$/23/0 1-STAFF TECHNICAL POSITION ON TESTING AND INSPECTION PLANS OURING CONSTRUCTION OF 00E'S REMEDIAL ACTION .:-

AT INACT!YE URAN!UM HILL TAILING SITES LOW LEVEL WASTE AND URAN!UM REC 0VERY PROJECTS BRANCH U.S. NUCLEAR REGULATORY CCPNISSICH

  • Revision 1 MARCH, 1987 TTl cy I

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- c-Revision 1 March 1987 STAFF TECHNICAL POSITION ON TESTING AND 'NSPECTION PLANS CURING

  • CONSTRUCTION Gr CCE'S 3EMEDI.,L ACTION AT "lACTI'/E URANIUM MILL TAILING SITE!
1. INTRODUCTION Title ! of the Uranium Mill Tallings Radiation Control Act of 1976, as amended (UMTRCA) requires Nuclear Regulatory Com:ssion (NRC) concurrence in DOE's ,

selection and cerfomance of remedial actions at inactive uranium mill tailings j sites. The NRC provides reviews, concurrances, aM licensing actions during the remedial process. Among the soecifis .Jchrim aspects of the remedial acticn perfomance is field control, inc 'dir; 3 sting and inspection.  :

This staff technical position describes the enyneering practices, testing, inspection, record keeping, nonconformance corrective action and "stop work order" controls considered satisfactory for the implementation of remedial action orograms. These criteria reflect the aporoaches and state-of-the-art methods that are considered to be adequate to rrotect public health and safety, and as such acceptable to the NRC staff. If alternate methods are proposed, they will be considered on a case-by-case t,asif.

2. MSCUSSION OCE is responsible for planning and cenducting remedial ac',fons for i stabiliaation of inactive uranium mill tailings in accercance with EPA l stano4rde. The cotions presently being considered and im l

for stabili:aticr. of the inactive tailings cchsist of (t)plemented by the CGE stabilization of tailings in place, (ii) it:b'lization en site, and (iii) relecation and stabilization of tallings at anote=r 16 cation. The ditatled design are construction procedure for each remedial acticn 9ecnds upon the site-specific l plan selected by the COE.

1he objective of NRC's review and cencurrence with DCE's remedial action plans is the '/erification of ccmpliance with the requirteents of the EPA standaros issued pursuart to the C11RCA. To meet this objective, the COE's remedial action plan and constructien must assure adecuacy of (i) geotechnical stability (ii) erosion protection (iii) raden attenuation, and (iv) d k

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protection against existing and future grcundwater contamination. Acceptance f testing and adequate inspection during constructi:n are essential to assure  !

ccmpliance with specification recuirements and to provide confidence that the l intended design criteria are implemented during construction.

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In its review of the Remedial Action Inspection Plans (RA!P's), the NRC staff t must assure that acceptable criteria are used for the inspection and testing i perf rved during construction cf each reredial action. Tc facilitate this-  !

action, the staff has developed this position caper. It identifies rettedial [

action inspection plan features related to geotechnical engineering that may be i necessary to control, verify, and document the DOE's remedial action i activities. It does not cover the general cuality assurance requirements for  !

an acceptable inspection and testing plan.  !

i Since conoitions are likely to vary frem site to site and the various MP's may differ in scope and extent, only relevant portions of the staff position on i testing are inspection requirements need be applied at a given site.

3. STAFF POSITION
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l The establishment of the adequacy of construction is usually accomplished by i i

visual examination, measurements, and testing. The extent of inspectinn and (

testin0 should be sufficient to provide adecuate cuality control, to satisfy  !

requirements of plans and specifications, and to furnish the necessary  !

permdnent record. Also, it is essential that the personnel perfoming the  :

inspect' ion and testing have the required traf. ;ng ano experience to perform a professional job.

It is impracticable to test ccepletely all the work perfomed. An acceptable l procedure wJld be to select samples of the work or materials for testing which  !

are representative of some unit of work or material. Concitiens which produce  !

test results below the requirements should be rettedied. For each failing test, j representative samplir.g and testing should be acccmolished before the e.aterial i is accepted. If there is an uppreciable number of borderlire test results,  ;

imediate steps should be taken to ascertain the cause and to correct it. l Section 3.1 describes the hRC staff position on an acceptable testing ano inspection plan for various geotechnical aspects of the design. Acceptable g procedures ano frequency of testing and inspe: tion to implement this plan are j; given in Section 3.2 of the staff position.

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3.1 Testine and Inscection Plan ,

3.1.1 Foundation and Subarade Prior to placing the first layer of material on the founoation, a final insperf. ion of the subgrade should be made to assure that it haa ro sign of deterioration due to frost action, erosion due to rainwater, rutting, reas of subs dence, or dryir.g out of tr.e surface. The inspection snruld verify tnat the foundation surface has been moistened, but there is no standing water on the surface. In addition, the inspection shcult' > l s t- verify that the founoation surface of cohesive soils has been scarified or penetrated by tamping rollers to insure proper bonding of material. Any unacceptable surface material should be eitner removed or excavated and recompacted to design specifications.

3.1.2 Caoillary Break (non. cohesive)

Cao'!1ary break materials should be inspecteo and testeo to verify that the grweation requirements of the materials have been met. Testing of in-place ' !

cacillary break eaterials M uld be accemplished to assure that the in. place density of the material? , in confomance witn the spacified percentace of maximum relative densi' .

3.1.3 Geotextile Seearsters In seme Remedial Action Plans, a geotextile separator eay be specified for placerent between two different construction materials. Thia, separator shculd be inspected to verify that the specified f abric is being used and that the fabric has no tears and has sufficient overlap of material between aojoining pieces when emplaced.

3.1.4 Seeeace Bar-ier/ Liner (Cchesive) ,

Inspection and testing of seepage barrier / liner eaterials should inc.lude verification that gradation, classification, plast.icity index, and the moisture-density relationship confom with the specifications.

3.1.5 Tailines/ Contaminated Material Inspection a .d testing of tailings /centaminateo material shculd be accc.mplished to assure that the quantity and maximum size of foreign material placed in the encapsulation col! is in conformance with the toplicable specifications.

Ceepaction of tailings arcund the relatively large si:ed foreign material snould meet the specifieo requirerents. Inspection shculd also verify that organic materials are uniferr.ly 01stributed throughcut tha errolaced tailings.

Ccepaction testing sneuld be acccmplisted to assure that the in-place density and moisture centent of **e emolacea tailings are in ccepliance with actplicaole taecificaticns.

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5-3.1.6 Radon Barrier / Soil Covers .

haterials for the raden barrier / soil cover should be inspected and tested to ensure verification of gradstion, plasticity index, classification, and roisture-density relationship to conform with the scecifications. Testing of in-placa density should also (;e acccmplished to ensure cempliance with appropriate compaction specifications.

3.1.7 Filter Bed Inspection of filter bed materials emplacement shculd be acccmplished to assure that they are baing properly placed. Testing of emplaced materials should be accorolished to assure that the gradation is in confomance with applicable specifications. Inspection shculd assure that the gradation of filter materials are not altered by segregation at the time of emplacement or by physical breakdown of grains by ccmpaction equipment.

3.1.8 Riorap, ,

The placement +f the riprap materials shculd receive inspection to assure that proper placement techniques are employed o prevent degradation of the material due to improper handling, to assure that the distribution is uniform and that voids are kept as small as possible, and to assure proper gradation. The inspection should also verify that the si:e ano classification of riprap rock, the lif t thickness, and elevations cceply with applicable specifications and drawings. Inspection of riprap quality may be provided at the material source if required to assure c:mpliance to the specification requirements. The testing should include curability tests including tests such as specific gravity, soundness, abrasion, ano absoretion. Inspectic.n of riprap at '

placement should include visual inspection of size and shape of riprap materials to ensure that riprao is nonsegregated (free of pockets of small stone:, or of clusters of large stones), that tne gradation tolerance is met and that the riprap is cet emplaced in layers.

3.1.9 Too Soil If top soil is used over the riprao. the inscection shculd assure that the

, loose thickness of the top soil conforms with the specifications. The l inspection and testing should also verify that the icwer layers of top soil are l adequately compacted. The inspection should further verify that the upper layers of the top soll are seeded as per specifications.

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O e W 39/0CG/85/5/23/0 3.2 Testico and Insoection Procedure ,

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3.2.1 Materials Certification, Materials which are supplied for installation or which require certification shculd be verified by the project quality department as having met the spec'fied requirements. Appropriate tests should be run whenever there is a visible change in engineering characteristics of the e.aterial. The inspector l shculd sign or . initial the transmittal inoicating acceptance or describing the l reason (s) for non-acceptance. i 1

3.2.0 Inst-ument certification Instrw entation which is received should be inspected by the persen responsible for using and maintaining the instrument. Tbc instrument should be inspecteo for caeage, for correct operation, and for proper calibration records.

Ecuipeent which does not meet the applicable requirements should not be used. ,

The calibration records should be included in the instruments calibration systen. The system should identify the required frequency of calibration checks and methods of calibration for various instruments.

3.2.. C a eaction Evaluation procedure

! Inspections ard testing should assure that specified materials are emplaced and I ccmpacted as designated on drawings. The loose thickness of the lifts of material and elevaticns should be verified frequently to ensure compliance to

. the specification requirements for the particular type of materiai emplaced.

Inspectinn shoula also verify that the ccepaction equipment (or equivalent), as per soecifications, is being used for ccmcacting the material ano the number of roller passes meets the specificatica requirements.

In-place field density tests and sufficient laboratory moisture-density tests should be perfomed to further evaluate ccepaction. Hewever, the testing precedure sheuld not jeopardi:e the integrity of the emplaced materials. The field density and moisture testino should be in accordance with ASTN 0-698, ASTM 0-1557, ASTM 0-4253 and 0-4254, ASTM 0-1556 or ASTM 0-2922, as applicable.

'4 hen nuclear gauges are used (ASTN 0-2922), the instruments should be recalibrated before each density test by takino a stamrd ccunt at the test location. Additionally, when neutron absorbing elements Oxist in the soil, a correction factor should be determined fo* each material ty,9e enecuntered and the appropriate calibration adjustments should be made to the instrumert for

WM-39/DCG/85/5/23/0 that material type._. Any adjustments or recalibrations should be parformed accordirg to the procedures identified in the operating manual.

Moisture contents may also be determined by AASHTO T217 procedure, using the speedy coisture meter. khen speedy moisture meters are used to test contaminated material and radon barrier materiel, a correlation with the oven 4 drying method (ASTM 0-2216) steuld be developed for each test. Similarly, when testing other comoactec materiais, a correlation should be developed for every i tentn test, cr.more frequently if calibration of the moisture meter is necessary after every tenth test. Appropriate oven crying procedures shoulo be 4

used when (refer to ASTM oven drying)

D-2216 . soils containing significant amounts of hydrated water ,

The field test frequency should be a minimum of one test oer 1,000 cubic yards ^

of cont:minated material placed and one test per 500 cubic yards of other ccmpacted materials including seecage barrier and/or raden barrier eartn cov.tr. l There saould be a minimum of two tests taken for each day that an appreciable '

amount of fill is placed (in excess of 150 cubic yards). There should be a minimum of one test per lift and at least one test for every full shif t of i compaction operations. When testing contaminated materials using nuclear gauges, :ne sano cone test (ASTM D-1556) per every 5 nuclear gauge tests should ce perfon ed.

Prior to the start of field compaction operations, appropriate laberatory ccmpacticn curves should be obtaired for the range of emplaced materials.

j Curing -onstruction, one point Prcctor tests at a frequency of one test for every five field density tests on cohesive materials should be cerformed. .

Similar checks should be provided for verifying relative densities of 1 non-cchesive materials. Supplementary laboratory ccmpaction curves (based on  !

complete Proctor tests) should be obtained, accroxim.ately one for every 10 or j

i 15 field tests, depending on the variability'of raterials. ,

The field determinatien of moisture and density snould be comoared with the  :

appropriate ccmpaction curve to evaluate conformance with requirements. The  ;

Remedial Action Inspection Plan should incluce a criterion for evaluating the l inspected field censity and moisture data based on a continuous review of data.  !

3.2.4 Gradation and Classification Testine  ;

i The placement of materials thould receive continuous inscection ano frecuer,: [

vertfication testing to assure that specification requirements with respect to j gradation and classificatien are maintained. The inscection should assure that -

the maximum particle size in the emolaced eaterial meets the specified r

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requirements. For all materials other than contaminated 7:aterials, at least ,

one gradation '

test should be run for each day of significant material placement (in excess of 150cubicyards). Random samples cotained frem material being placed should be s used for these tests. Inspection may also be provided at the material source  :

to assure compliance with the specification requirements. Documentation of the '

test results should be on appropriate laboratory test report sheets ana results of visual inspection should be documented in the daily inspection report. i 3.2.5 Atterbers 1.imits Tests t Inspections should assure tnat the proper material is placed as designated on the drawings. Verification testing should include deter 71 nation of plasticity  ;

index, which detcrmines the range of water content over wnich a cohesive soil behavet plastically. The tests should be run at least once for each day of  ;

significant cohesive cover or liner raterial placement (in excess of 150 cubic '

yards). The samples should be randomly selected. The test results should be .

documented in the laboratory test reports.

  • 3.2.6 Rock Durability Tests  !

For each gradation cf riprap, rock durability tests such as specific gravity, absorptien, sodium or magnesium sulfate sour. dress, and abrasion testing should ,

be performed prior to delivery of any material to t>e site. The testing  ;

prograr may vary frem site to site and is decer.1ent on the type of rcck  :

selected and the expected environmental stresses that it will be subject to. '

Ouring construction activities, additional test series should be perfermed for  ;

each type of riprap when approximately ene-thirc and two-thirds of the total i volume of each type of riprap have been delivered. For any type of riprap l where the volume is greater than 30,000 cubic yards, a test series should be  ;

perfonned for each additional 10.0C0 cubic yarcs of riorap celivered. A final t sample shculd be obtained for each riprap type following ccmpletion cf delivery [

of the material. I t

3.2.7 Distributien of Ornantes l Continuous visual observation during placement of or:anics in the encaosulation  !

cell should be accomplished to assure that the organic caterial is unifom and evenly distributed. Also, the inspection shculd assure that the maximum size of the emplaced organic raterial does not exceed the specifieG requirements.

Results of visual 'nspection shculd be docurented on the caily inspection report.

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WM-39/0CG/85/5/23/0 9-3.3 Non Conformances. Corrective Action and Stoo Werk Orders In the Remedial Action Inspection Plan, the COE should establish procedures to define, identify, and document non-conformances or deviations from plans, specifications, or precedures. A mechanism to develop, control, approve and implement the necessary corrective acticn should 61so be established.

Follow-up procedures to assure that proposed corrective actions have been implererted should be documented.

The Remedial Action Inspection Plan shculd also address provisions for a "Stop Work Order". The situations when a "Stop Work Order" may beceme necessary should be described. Procedures and level of authcrity for issuing a "Stop Work Order" should be established and a mechanism for resolving the corresponding nonconfomance(s) should be discussed.

3.4 Aecords Daily inspection reports should be written th n aodress the adequacy, progress, and details of construction activities, and decisions. The reports should  :

incluce the results of visual inspection, measurements and tests perfomed in the laboratory and in the field. The inspection and test status should be identifieo ey charts, as-builts, or by periedic status reports. The inspector should surmar4:e volume of emplaced materials and the numoer of field and laboratory tests perfor ed on each material on a weekly basis. The status of inspection ano testing should be monitored as apprcpriate to prevent inadvertently by-passinc an inspection peint. The inspection and test reports should become p6rt of the pereanent record of' the implementation of the remeutal action plan.

The recorch should include date, name of tester or inspector, items inspected or tested, type of inspection or test, identificatien of test method, results, acceptabihty and acceptance criteria, and name and initials of the reviewer.

The records should also identify the testing equipment or instrument used in perfeming the tests When dccumenting deviations, renconformances, and stop work order situations, the report should provide sufficient details so that acceptability of the necessary corrective action and finsi resolution can be independently reviewed.

ATTACHMENT #7 l

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ATTACHMENT #7

, .i UMTRA PROJECT Creen River, Utah REMEDIAL ACTION INSPECTION PIAN

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. ,z,3 (uf*A moamisow MK-FERGUSON COMPANY nuvosaw coun=y Doewnent Number: HKF-UNTRA-30 Revision Nwaber: A CREEN RIVER INDEX RAIP 1 Testing and Inspection ,

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0003 MIS. DOC

MK-FERGUSON COMPANY A teo44fSoM RNVoSEN CoWPANY

, STATEMENT OF POLICY This Remedial Action Inspection Plan identifies the means by which the remedial action activities at Green River, Utah are controlled, verified, and documented. This plan is developed within the scope of the Quality Assurance Program Plan and it complies with the applicable portions of 10CTR50 Appendix B and ANSI /ASME NQA-1.

i The procedures covering Organization, Qualification and Certification of Inspection and Test Personnel, Quality Assurance Records Control, Control of Measuring and Test Equipment, and Nonconformance and  :

Corrective Action shall be in accordance with the applicable sections of l the Quality Assurance Program Plan as follows: Organization - QAPP 1, i Qualification and Certification of Inspection and Test Personnel, Lea,d  ;

Auditors, and Auditors - QAPP 4, Control of Measuring and Test Equipment i

- QAPP 5, Quality Assurance Records Control - QAPP 6, and Nonconformance and Corrective Action - QAPP 8.

. This Remedial Action Inspection Plan and the Quality Assurance Program I t

Plan describe the means by which the KK Ferguson company will assure i that the Environmental Protection Agency and Nuclear Regulatory Commission requirements are satisfied.

It is the intent that this plan be applied to all permanent installations and work. Temporary facilities, installations, or work is to be tested and inspected as stated by the specifications. Where '

testing and inspection is not stated in the specifications for temporary  ;

work, the work is to be tested and inspected to the degree necessary to ensure it's integrity for the anticipated period of usage, i.e. access roads, temporary ditches, etc. ,

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MK FERGUSON COMPANY '" " ^

A monnison zuvonan couramy om REMEDIAL ACTION INSPECTION PLAN UMTRA Project D*tamd Coatest Prime Contract No.DE AC04 83AL18796 PHIL D. CATE PROCEDURE TITLE: TESTING AND INSPECTION 1.0 Purpose 1.1 To describe the methods by which the construction activities will be tested and inspected to verify compliance with the specification requirements.

2.0 Scope 2.1 This procedure defines the testing and inspection of remedial action constructio.$ activities at Green River, Utah. Types of tests, test frequ ncles and acceptability, and documentation and rept.rting requirements are contained in this procedure. Procedures for performing the individual tests 6 shall be in accordance with the applicable . ASTM Standards,~

the referenced methods, and th'e design specifications.

3.0 Definitions None 4.0 Attachments None 5.0 References ,

5.1 10CTR50 APP. B, Criteria 5, 10, 11, 14 5.2 ANSI /ASME NQA 1 1979 with addends A 81 through C 82 5.3 Contract DE AC04 83AL18796 5.4 ASTM 5.5 AASitTO 5.6 H.S. & E. Procedures / Plans 5.7 DOE 5700.6B 9/23/86 Page 1 of 14 0003 MIS. DOC m 57 oste m J

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5.8 DOE AL5700.6B 4/24/84 5.9 UMTRA Quality Assurance Plan 5.10 MK Ferguson Quality Assurance Program Plan 5.11 Green River Design Specifications 5.12 American Petroleum Institute 5.13 International Society For Rock Mechanics 6.0 Procedures 6.1 Field Density control 6,1.1 Soil density and moisture testing shall be in accotdance with ASTM D 698 ASTM D 1556, ASTM D-2167, ASTM D 2216, or ASTM D 2922, as applicable. AddYtionally, moisture '

control may be in accordance with AASHTO .

T217, using the speedy moisture meter.

6.1.2 When the speedy moisture meter or nuclear density gauge is used in the determination of the moisture content, a correlation sample will be oven dried a minimum of every tenth moisture test. If the difference in results is greater than one percent, all test results obtainad since the previous correlation test shall be reevaluated, where possible. In any event, test results which are outside of the specification tolerances will be retested.

6.1.3 Vhen the nuclear density gauge is used for density determinations, a minimum of one sand cone density correlation test shall be performed a minimum of every five densities performed using the nuclear method. If there is a difference in results obtained, which exceeds 2 percent, the sand ec.ne test results shall be used. All test results which were recorded using the nuclear gauge since the last correlation shall be reevaluated. Test results which may be indicated as failures as a result of H AIP NO. A L V. N O.

REMEDIAL ACTION INSPECTION PLAN ,,,,,,,

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this reevaluation, shall be retested in the area represented by the indicated f.nilure. The nuclear density gauge will only be used on material with a nominal particle size of 3/4 inch maximum. The nuclear density gauge shall not be used in material which is radioactively contaminated. ,

6.1.4 In place field density and moisture tests for compacted materials, where density requirements are specified by the design specifications, shall be tested at the following minimum frequency:

a. One test per 1,000 cubi: yards of contaminated materials p1 seed,
b. One test per 1,000 cubit. yards of select fill materials placed,
c. One test per 500 cubic yteds of radon barrier materials placed. .
d. One test per 3,000 cubic yards of coraon filJ materials placed, except for the retention basin dike, which will be one test per 1,000 cubic yards placed.
e. At least two tests for each day of material placement in excess of 150 cubic yards for each material.

A test may be performed at any time the inspector or site manager determines the need to verify the compaction effort. To the extent possible, as allowed by placement methods and operations, there shall be a minimum of one test each lift. The test elevation shall be documented for each test.

6.1.5 Each layer of embankment and backfill shall be compacted to the minimum percentage of maximum dry density as deceruined by ASTM D 698, in accordance with the percentaget prescribed by the design l specifications, i

l 6.1.5.1 During compaction, the moisture content of fill material shall be maintained to achieve the minimum specified density, and moisture shall be uniformly distributed throughout each lift.

Ralph 01 CRN A IY 0

  • A REMEDIAL ACTION INSPECTION PLAN un q g g 0003 MIS. DOC "**" 8d#"

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1 6.1.5.2 During compaction, contaminated materials shall be maintained at moisture contents between 10 and 14 percent.

6.1.5.3 During compaction of radon barrier materials, the moisture content shall be maintained within zero to plus three percent of the optimum moisture content.

Radon Barrier materials shall be moisture conditioned a minimum of two hours prior to compaction. Moisture shall be added as

.'ecessary to maintain a moisture content fo- two hours prior to compaction equal to or greater than optimum moisture content.

Moist'are shall not be mixed or otherwise worket into radon barrier materials after placement of materials over the contaminated materials.

6.1.5.4 Optimum moisture content shall be determined in accordance with ASTM D 698.

6.1.6 Maximum density determinations shall be performed prior to the start of embankment or backfill placement when possible. The inspector or technician shall be alert for changes in material such as, color, size distribution, etc. When different material types are encountered a complete maximum density determination test shall be performed.

For material which is a random type, having no specified gradation requirements, there shall be a minimum average of o a maximum density test for each 10,000 cubic yards of material placed. For material which has a specified gradation requirement, the frequency may be decreased to a minimum average of one maximum density test for each 15,000 cubic yards of material placed. Maximum density determinations will be accomplished in accordance with ASTM D.698.

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. MK FERGUSON COMPANY

(. Geetstede sewetee Ce#PMr1 6.1.7 In order to assurs that the correct maximum dry density is being used to determine the relative compaction, a one point proctor test shall be performed. The material shall be as close to optimum moisture as possible and shall be compacted in accordance with the requirements of ASTM D 698.

The frequency for performing this check point shall -

be established by the site quality supervisor, dependent upon the nature of the material. A guide would be one check for every five field density tests performed. In no case should there be more than ten field density tests performed without a one point proctor check.

6.1.8 Vhen the level of work activity is such that sand cone density tests are being performed throughout the day, the sand used for determining the volume of the test hole shall be calibrated twice a day and for each new bag of sand.  ;

6.1.9 Density test resultV shall be recorded and logge'd on the applicable forms. ,

6.2 Cradation Testine 6.2.1 Cradation testing of Select Fill Type A, select bedding, gravel fill, riprap, and radon barrier materials shall be performed in accordance with the applicable ASTMs (c.117, C 136, D 422) or other approved testing methods.

6.2.2 Cradation testing of Select Fill Type A and gravel fill material shall be performed a minimum of once for each 2,000 cubic yards of each material placed, Additionally, material shall be tested

  • l for gradation a minimum of once per day during placement in excess of 150 cubic yards.

6.2.3 Gradation testing of radon barrier material shall be l performed a minimum of once for each 1,000 cubic l yards of material placed. Additionally, one I

gradation test shall be performed each day during placement. Gradation tests shall be performed before bentonite is sixed with radon barrier  :

materials. J

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l R AtP NO.1 CRN AIY'N0* A l REMEDIAL. ACTION INSPECTION PLAN ract No. 5 of 14 0003 MIS. DOC ""#"#5"'"

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e O.N C.,OMPANY NOTE: Select Fill Type B shall be visually inspected to ensure the exclusion of shale bedrock.

6.3 Erosion Protection Materints Testing 6.3.1 Select bedding material and each type of riprap material shall be tested by a commercial testing laboratory during production in accordance with the following:

Riorno Tyr e A and Select Bedding Specific Gravity (SSD) ASTM C 127 Absorption ASTM C.127 Soundness ASTM C 88 Abrasion ASTM C 131 Rieran Tyre B Schmidt Rebound Hardness ISRM Method Splitting Tensile Strength ISRM Method Test results shall be submitted to the Design Engineering Firm (M.K Engineers) for analysis and subsequent acceptance or rejection of the material represented by the test results, based on engineering calculations.

6.3.2 Select bedding material and each type of riprap shall be tested for gradation in accordance with ASTMs C 117 and C 136, and other approved testing methods. Test results shall be in accordance with the design specification requirements.

6.3.3 Select bedding material and each type of riprap shall be tested, as delineated in sections 6.3.1 and 6.3.2 above, a minimum of four times. The materials shall be tested initially prior to the delivery of any of the materials to the site.

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Thereafter, the tests shall be performed at a minimum frequency of one test for each 10,000 cubic yards or fraction thereof produced. For materials where the total volume is less than 30,000 cubic yards, the test frequency chall be performed for each type material when approximately one third and two thirds of the total volume of material has been produced.

A final test shall be performed following completion of production for each type material.

6.4 Inspections Daily visual inspections shall be performed to verify that quality related activities are performed in accordance with the requirements of the Design Specifications, Remedial Action Inspection Plan, and the Quality Assurance Program Plan. Daily visual inspections performed by qualified and certified inspection persennel shall be accomplished

  • during execution of the various work activities to assure compliance to the above listed criteria, and as follows:

6.4.1 Excavation Inspections shall be performed to ensure that the correct line and grades are reached, as required.

Where contaminated material is excavated, the inspector shall verify with the H.P. Supervisor that the ro.itaminated material has been removed, as required.

6.4.2 Foundation and Suberade Prior to placing the first layer of material on the foundation, a final inspection of the subgrade shall be made to assure that it has no sign of deterioration due to frost action, erosion due to rainwater, rutting, areas of subsidence, or drying out of the surface. The inspection shall verify that the foundation surface has been moistened, but there is no standing vater on the surface. In addition, the inspection shall also verify that the foundation surface of cohesive soils has been RAlf NO,1 GRN l *

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f scarified or penetrated to insure proper bonding of overlying material. Any unacceptable surface material shall be either removed or excavated and recompacted to design specification requirements.

The subgrade for the tailings embankment shall not be compacted prior to tailings placement. Loose material shall be removed to the extent possible af ter excavating into bedrock for the tailings embankaant.

The subgrade for the retention basin dike shall be plowed, harrowed, and mixed to a depth of 6 inches.  ;

The subgrade shall be compacted to the minimum '

density as required by the design specifications.

6.4.3 Embankment Fill and Backfill Inspections shall assure that the proper material is placed as designated on the drawings. The loose thickness of the 11Tes of material shall be verified frequently to ensure compliance to the specification requirements for the particular type of material.

The inspections shall assure that the applicable moisture requirements are maintained and that the moisture is uniform throughout each lift. ,

Visual observation shall assure that placement of organics in the encapsulation cell is uniform and evenly distributed. Also, the inspection shall  ;

assure that the maximum site of the emplaced organic material does not exceed the specified requirements.

Results of visual inspection shall be documented on the daily inspection report.

6./ 4 Radon Barrier The placement of the radon barrier shall receive frequent inspection to verify lift thickness, elevations, moisture content, and as required, the number of roller passes. The moisture content will be determined as frequently as is required to assure the proper moisture content is maintained during the compaction effort.

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6.4.5 Radon Barrier Thickness Determination In order to determine the radon emanation rate of the tallings material for the purpose of determining the thickness requirement of the radon barrier material, the following procedure shall be verified by MX F Quality Control Personnel:

6.4.5.1 A grid shall be established by M.K Engineers of the encapsulation area and 20 areas shall be chosen which will  !

provide representative samples of tailings material.

6.4.5.2 When the elevation of the compacted tailings material is within 20 feet of the anticipated final elevation at each grid location, a sample shall be obtained for Ra.226 and Th.230 analysis. The analysis shall be performed in accordance with existing CNSI procedures.

  • 6.4.5.3 At e.ch sample location, additional samples shall be obtained for each additional 2 feet in elevation of tailings placed. The samples shall be composited over the 2 foot depth.

6.4.5.4 The results of the analysis shall be used to determine the radon emanation rate, which will deternine the final radon barrier cover thickness.

6.4.6 Erosion Protection ,

The excavation, production, stockpiling, transportation, placement, and compaction of the erosion protection materials she'l receive adequate l inspection to assure (1) proper 16chniques are l employed to prevent degradation of the material due  ;

to improper handling, (2) distribution is uniform,  ;

! (3) voids are kept as ainimal as possible, and (4)

{ proper gradation is maintained. The inspection l shall also verify the lift thickness and elevations.

Inspection will be provided at the material source '

as required to assure compliance to the  ;

specification requirements.

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Riprap material shall be visually inspected to assure the material is sound stone, resistant to abrasion, and free from cracks, seams, weathering rinds, and other defects as shown in the petrographic examination. Material with more than 10 percent sandstone by volume shall be rejected.

6.4.7 Health Physics The H.P. activities'shall be inspected a minimum of once weekly to assure compliance with the applicable H.P. procedures as specified by the KK F Quality Assurance Program Plan.

6.4.8 Receivine-6.4.8.1 Instrumentation which is received shall be inspected by the person responsible for using and maintaining the instrument. The instrument shall' be inspected for damage, correct ,

operations, and proper calibration records.

The inclusion of the calibration records into the calibration system shall be evidence of satisfactory inspection results.

Equipment which does not meet the applicable requirements shall be returned to the vendor.

6.4.8.2 Materials supplied for permanent installation or which by the specifications require certifications, will be verified by the quality department as having met the specified requirements. The inspector shall sign or initial the transmittal in the appropriate space indicating acceptance or describing the reason (s) for nonacceptance.

REMEDIAL ACTION INSPECTION PLAN RAIP h0 1 GRN l AIV'N0* A

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< o 6.4.9 Seasonal Shutdowns During the periods of time when work is interrupted for seasonal shutdowns, the exposed surfaces of the tailing material vill be stabilized in a manner to prevent offsite spread of contamination. Prior to the application of protective erosion control measures, exposed surfaces shall be sloped to drain, and compactoil with a tracked vehicle up and down the slope to eliminate ruts and ridges. Manufacturers recomraendations for the l methods of handling, mixing, application, and/or installation of erosion control materials shall be verified.

During this period, surveillances shall be performed and documented routinely to assure that the integrity of the method of l

1 stabilization is maintained.

I Prior to commencing work following a seasonal ,

shutdown, a radiological survey shall be l performed on all areas which may have been

! subject to contamination as a result of the l method of stabilization.

Also prior to commencing work following a sear.onal shutdown, the compaction of previously accepted exposed peruanont areas will be reverified. Density tests shall be performed I in areas that are obviously, or appear to be questionable, (i.e. soft, excessive moisture) in maintaining the minimum specified density.

In addition, randomly selected areas, representative of the in place exposed material, shall be reverified as meeting the specified minimum density requirements. Areas that fail to meet the minimum specified density requirements shall be reworked to meet specified density and moisture requirements or removed and replaced with acceptable fill l compacted to meet specified density and j moisture requirements.

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6.4.10 Bentonite Bentonite shall be untreated sodium bentonite, and shall meet the requirements of Specification 13A of the American Petroleum Institute.

6.4.10.1 Mixing of bentonite shall not be accomplished in place. If bentonite is mixed on the ground, loose material to be mixed with bentonite shall be placed on a 1. foot thick layer of specified radon barrier material rolled to a firm condition to avoid contamination by unacceptable materials.

6.4.10.2 Radon barrier material shall be thoroughly mixed with the specified equipment with three percent, by weight, of the specified sodium

  • bentonite, ,

6.4.10.3 Mixing of bentonite and soil shall be in a dry condition. Water shall be added only after dry mixing of bentonite and soil are complete.

Material with an initial moisture content above optimum as determined by ASTM D698 shall be scarified to accelerate drying before bentonite is added. Water shall not be applied by trucks operating on the mixing surface to avoid rutting and potholing of the surface.

Application of water shall be by spraying from off the mixing surface.

6.4.10.4 If mixed on the ground, bentonite shall be distributed over unrutted material to avoid pockets of concentrated bentonite. Bentonite applied with a spreader shall be spread with a fertilizer type spreader capable of controlling the rate of application and shall be RAlf NQ,1 GRN l RIV'NU A REMEDIAL ACTION INSPECTION PLAN  %,

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o applied in two passes at right angles to each other. The problem of dust and loss of bentonite in the atmosphere shall be minimized by placing bentonite over a disked surface and by controlling the speed of the mixer. The amount of mixing shall depend on the type of mixer used, the soil type, initial soil sciature and the grade of bentonite.

If mixed on the ground, the material shall be mixed uniformly by over. lapping with transverse mixing.

6.4.11 Eculement The following functions shall be accomplished by utilizing equipment meeting the specific criteria prescribed by the design specifications:

A. Excavation of all materials encountered

  • B. Compaction of Gravel Fill materials C. Mixing Bentonite and Radon Barrier materials D. Compaction of Contaminated materials E. Compaction of Radon Barrier materials F. Erosion protection during seasonal shutdowns C. Compaction of Bedding Material 7.0 Records 7.1 Test and inspection records shall be reported and filed in a timely manner, consistent wit.h the status of work performed.

Inspection and test status shall be identified by charts, blueprints, as.builts, or periodic status reports. The inspection and test status shall be available at all times to prevent inadvertent by passing of an inspection or test.

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7.2 Test and inspection records shall contain as a minimum the following:

7.2.1 Items tested or inspected.

7.2.2 Date of test or inspection. ,

j- 7.2.3 Tester, inspector or data recorder.

7.2.4 Type of test or inspection.

7.2.5 Results and acceptability, including the test or inspection acceptance criteria.

7.2.6 Instrument number used in performing the test or inspection.

7.2.7 Action taken in connection with any deviations noted.

7.2.8 Per:on evaluating test results, if different than, person named in paragraph 7.2.3.

7.3 Test and inspection records shall be filed and maintained in accordance with "0 APP 6. Quality Assurance Records Controli.

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  • A REMEDIAL ACTION INSPECTION PLAN ,,c , y o, 14 of 14 0003 MIS. DOC