ML20245E762
| ML20245E762 | |
| Person / Time | |
|---|---|
| Issue date: | 06/22/1989 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-68 NUDOCS 8906270429 | |
| Download: ML20245E762 (6) | |
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1 9(m 2 21989 Mr. Mark Matthews Acting Project Manager Uranium Mill Tailings Project Office Department of Energy Albuquerque Operations Office P.O. Box 5400 Albuquerque, New Mexico
Dear Mr.'Matthews:
By letter dated June 1,1989, DOE transmitted for NRC review and concurrence Revision C to the Green River, Utah Remedial Action Inspection Plan (RAIP).
Memorandum of Understanding (MOU)ponse time as agreed to in the NRC/D0E In accordance with the 21 day res
, the NRC staff has completed the RAIP review and detailed comments are attached.
In addition, sone of these consents were discussed with DOE, TAC and RAC personnel during the NRC inspection at the Green River site on June 13, 1989. The NRC will concur in the kAIP upon satisfactory resolution of our RAIP comments and our concurrence in the Remedial Action Plan (RAP).
If you hav'e any questions regarding these comments, please contact me or M. Fliegel of my staff at FTS 492-0555.
-(SIGNED) PAULH.LOHAUS Paul H. Lohaus, Branch Chief Operations Branch Division of Low Level Waste j
Management and Decons:issioning 1
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cc:
C. Watson, DOE /AL S. Mann,' DOE /HQ L. Anderson, Utah l
DISTRIBUTION:
% Central? File;WM-687 PLohaus,LLOB MFliegel,LLOB' MBell,LLWM JAustin',LLWM ~
'DG111en,LLOB SWastler,LLOB JGreeves,LLWM JJSurmeier,LLTB RDSmith,URF0 NMSS r/f PDR Yes /X /
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No
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/ Reason:
Proprietary /~ / or CF Only /~~/
ACNW Yes K/'
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SUBJECT ABSTRACT: RATPREVIfW; COMMENTS
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ATTACHMENT 1 l
COMMENTS OF THE REMEDIAL ACTION INSPECTION PLAN FOR THE GREEN RIVER UMTRA PROJECT Document Reviewed:
1 1.
UMTRA Project, Green River, Utah, Remedial Action Inspection Plan (RAIP),-
Testing and Inspection; Document No. MK-F-UMTRA-30, REY. C, Prepared by MKF for DOE, May 17, 1989, i
References:
l 1.
Memo of September 26, 1988, f rom H. Toker to h. Fliegel; transmitting staff review comments on Green River UMTRA Project RAIP, Rev. A.
2.
Letter of December 19, 1988, from W. J. Arthur, III of DOE to P. Lohaus of t!RC; submitting Rev. B version of Green River UMTRA project RAIP for NRC review and concurrence.
3.
Letter of January 27, 1989, from P. Lohaus of HRC to M. Matthews cf DOE; transmitting Rev. 2 version of NRC Staff Technical Position on Testing and Inspection Plans During Construction of DOE's Remedial Action at Inactive Uranium Mill Tailings Sites.
4.
Memo of April.6, 1989, from P. Lohaus to J. Greeves; NRC/ DOE Green River Meeting ct April 5, 1989, documenting NRC/ DOE Agreement.
Comments 1.
Statement of Policy As per paragraph 3, this RAIP is a means by which MK-Ferguson Company will assure that EPA requirements and NRC guidelines for Testing and Inspection Plans During Construction of DOE's Remedial Actions at Inactive Uranium Mill Sites (Reference 3) are satisfied. The last paragraph states that shoulo a conflict exist between this RAIP and the approved Design Specifications and/or Drawings, the specified requirements in the Design Documents shall take precedence. This statement should be revised to include another restriction that any deviation from the NRC guidelines (Reference 3) shall'be identified and such deviation shall be adequately justified. The NRC guidance on RAIPs (Reference 3) was revised recently after evaluating the past few years experience with UMTRA projects,.and DOE was consulted in the revision process before finalizing.
Therefore, any deviation from this guidance, particularly in terms of materials to be tested, types of tests, test methods, and frequency of tests should be identified and adequately justified.
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2.
Section 6.1.2 Field Density Control The statement, " In any event, any test results which would be outside of the I
Design Specification tolerances shall be retested, where )ossible ", needs an explanation about how DOE intends to address situations w1ere they decide not to retest a measurement that is outside design specification tolerances.
Besides, there are statements in the design specifications (see Section 3.5.D.7 page 02200-24 RAP Vol III, Design Specifications, January 1989) that require
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fill materials placed outside the specifications ranges to be reworked to meet the specifications or removed and replaced with acceptable matorials to meet the specifications.
The intent of the phrase "where possibit" needs further explanation.
In addition Section 6.1.2 distinguishes between " test results" and " record test results," which implies that DOE does not consider some of the density and moisture content results as official records of the remedial action. Such a distinction appears inappropriate because DOE uses the test results either
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to verify compliance with design specifications for the remedial action or to j
assess the accuracy and reliability of other results used to verify l
compliance. Therefore, the RAIP should be revised to consider all test results as official records of the remedial action.
3.
Section 6.1.4 Field Density Control i
There is no mention of any in-place field density tests on tailings and other contaminated materials. The omission seems to be intentional, as this item was included in Rev. A and Rev. B (References 1 and 2 respectively) versions of this RAIP document. This item was included in all the previous RAIPs for other UMTRA project sites. The NRC guidance on RAIPs (Reference 3), which was concurred in by the DOE, also requires this item. The field density test requirements should j
be revised to include (1) testing of the tailings and other contaminated materials at a frequency of one test per 1,000 cubic yards and (2) a minimum of one test per each lift of material placed.
4.
Section 6.1.4.1 Field Density Control The frequency of in-place moisture content tests is one per 2,000 cyd of contaminated materials placed. As per the NRC guidance on RAIPs (Reference 3),
I the frequency of in-place moisture content tests should be same as that far in-place density tests, which should be one test per 1,000 cyd of contaminated materials placed.
The current provision of one moisture content test per 2,000 cyd of contaminated materials placed should be changed to one test per 1,000 cyd of contaminated materials placed.
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Section 6.1.5.2 The statement that all contaminated materials shall be placed at a moisture
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content of less than 3' percent below 'the opt _imum moisture content' does not'
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reflect both the intent of the design and the placement moisture content-i limitations agreed-to by.the DOE (Reference 4). The intent of the design is to place the contaminated materials at moisture contents that are as-close as possible to their steady-state. moisture condition. The DOE has cosmitted to place the tailings materials at an average volumetric moisture content less than or equal-to 5 percent and the windblown anc vicinity property materials.
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-less than or equal to-10.6 percent. Please note that the.above moisture i
contents are volumetric, and'the RAIP should highlight the difference between this ard the' moisture content by weight that is normally used by~geotechnical engineers. This section of the RAIP'should be revised to reflect the above-moisture content requirements.
6.
Section 6.1.7 The RAIP requires one one-point Proctor test at a frequency of one for ear.h five field density tests for radon barrier material and one for each ten field density tests on all other materials. The NRC guidance document (Reference 3) requires one-point proctor test at a frequency of one for every five field density tests for all materials, and this should be followed in the RAIP.
7.
Section 6.3.1 Erosion Protection Materials Testing This section of the RAIP indicates that different durability tests will 4
be conducted on Type A and Type B riprap. Additionally, a different number of tests will be conducted on each type.
h is not clear.why cifferent types and number of tests will be conducted. Since the riprap will be produced from the same source, the selection of such tests seems unwarranted and unnecessarily complicated. We recommend that the same tests be conducted on both Type A and Type B riprap sources; the four tests proposed for the Type A.
i riprap are acceptable. Alternately, additional justification should be provided for the selection of different tests for the Type B rock.
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Section 6.4.3.1 Embankment Fill and Backfill This section prescribes the procedures and the equipment to be used in compacting the contaminated materials. Normally the density to be achieved by compaction is specified and not the method of compaction without any. provision i
to verify the in-place or compacted density. The trial compaction proposed and carried out by the DOE was to develop the compaction. procedures that would enable compacting at such dry or low moisture conditions and to demonstrate that the density assumed ir, the design, 90 percent Proctor density, could be
-achieved.
It was not intended to eliminate the density requirement from the design specifications or from ne RAIP. The placement density requirement for all contaminated materials should be included in the specifications and RAIP.
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9.
Section 6.4.5 Contaminated Materials - Trial Compaction This section states that after the trial compaction of the contaminated materials is completed, further testing for in-place moisture and density-during the construction will be at a frequency of one test per each 6,000 cyd of j
contaminated. materials placed.
It is stated that these test results and records-
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are.for information only-and are not subject to acceptance or rejection.
As stated previously in comment 2, all test results should be considered as j
official records of the remedial action. 'In addition given the:importance of, maintaining moisture contents as low as reasonably _ achievable,-the records
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should be used for acceptance or rejection.
Neither the proposed frequency of-
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testing (one test per 6,000 cyd of materials placed) nor the assertion-that the results would not )e considered for acceptance or rejection of compacted materials are in compliance with the NRC guidance on RAIPs (Reference 3). As stated in above Comments No. 3 and 4, all the contaminated materials'placed in the disposal cell should be tested for both in-place moisture and density at a frequency of one test per 1,000 cyd of materials placed, and the results should q
be useo to evaluate compliance with the design assumptions and design spectiications.
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- 10. Section 6.4.6 This section provides the maximum volumetric moisture content for which the tailings, windblown and other vicinity property materials can be placed in the disposal cell. However, the RAIP indicates that exceptions to these values are permitted because of field conditions. Also, the RAIP states that
" Records required by this section are considered as providing information only, and are not subject to acceptance or rejection. " This is contrary to NRC guidance on RAIPs, procedures followed in previously approved RAIPs, and completed UMTRA projects. Moisture and density testinD requirements for placing contaminated materials should be as per NRC guidance (Reference ~3) and as suggested in above Comments No. 3, 4, 5, and 9.
- 11. Section 6.4.10 RAIP Section 6.4.10 provides for application of protective erosion control I
measures on ex >osed surfaces during shutdown periods. The RAIP, however, does-not describe t1e composition and characteristics of the protective measures or l
reference appropriate specifications. Use of surfactants or other chemical additives applied on the surface of the tailings may be effective in temporarily mitigating erosion. However, their addition may also adversely affect the performance of the disposal unit by adding constituents to the f.
contaminated material that may be hazardous constituents themselves or may release complex hazardous constituents and increase their mobility. The RAIP should be revised to describe the types of interim protective measures that may be applied at the site or reference appropriate specifications for such a)plications.
In addition, the RAIP or a supporting document should demonstrate that such measures do not adversely affect the performance of the disposal unit in terms of groundwater protection if chemical additives, surfactants, or
. binding agents are applied as prottctive measures.
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. General Comment l
Agreement no.'4 of the April 6, 1989 NRC/ DOE agreement letter (Reference 4) states that DOE will place and maintain contaminated materials at specific l
steady state moisture contents. Density verification of compacted contaminated i
materials in the disposal cell are normally part of the RAIP and the NRC/ DOE 1
agreen,ent letter does not waive'this requirement.
If the DOE's interpretation i
of the agreement is not to have any verification of as-compacted density (as' reflected in this RAIP), then it is not acceptable to NRC. All the contaminated materials to be placed in the disposal cell should be compacted to a minimum dry l
density of 90 percent Proctor density (density assumed in the design to i
establish stability of the disposal cell) and to less than or equal to the
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volumetric moisture contents mentioned in Agreement 4 of Reference 4.
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