ML20247K563
| ML20247K563 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/1989 |
| From: | Gillen D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Fliegel M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-72 NUDOCS 8909210196 | |
| Download: ML20247K563 (7) | |
Text
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DG/M.FLIEGEL/9/15
-1 SEP 181999 I
MEMORANDUM FOR: Myron Fliegel, Section Leader Operations Branch Division of Low-Level Waste Management and Decommissioning, NMSS FROM:
Daniel 11. Gillen Operations Branch Division of Low-Level Waste Management and Decommissioning, NMSS
SUBJECT:
REPORT OF CONSTRUCTION INSPECTION AT SP0OK, WYOMING SITE On September 6,1989, G. Gnugnoli, L. Camper and I conducted a routine announced inspection at the Spook UMTRAP site in Converse County, Wyoming.
I performed an inspection of construction activities and quality control records, and G. Gnugnoli and L. Camper toured radiological soil clean-up areas and discussed related issues with staff of the DOE and their contractors. No major problem areas were identified. Enclosed for your information is an inspection report summarizing NRC activities and observations.
ORIGINAL SIGNED BY Daniel M. Gillen Operations Branch Division of Low-Level Waste Management and Decommissioning, NMSS
Enclosure:
As stated cc: Mark Matthews, DOE /Alb.
Chris Watson, DOE /Alb.
Sally Mann, DOE /Hg.
Distribution:
Central File ~# WM-72 NMSS r/f
'RBangart, LLWM JGreeves, LLWM MBell, LLRB JSurmeier, LLTB PLohaus, LLOB DGillen, LLOB MFliegel, LLOB GGnugnoli, LLOB RMacDougall, LLOB LCamper, LLOB JJones, LLOB r/f PDR YES /X /
PDR NO
/ / Category: Proprietary /_/
or CF Only / /
ACNW YES /T7 N0/__/
SUBJECT AB5 TRACT:
REPORT OF INSPECTION OF SPOOK, WYOMING UMTRAP SITE OFC :LLOB
- LLOB
- LLOB
- LLWM
- LLWM
- hM55
- NMSS
' I NAME:DGill n/jj
/ /89 : / /89 :
/ /89 :
/ /89 : / /89 : / /89 DATE: 'l /8 /89 p g 92gi g spopig gjg 1
0FFICIAL RECORD COPY WM rDC jgjyp'JZ
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1 On-Site Construction Inspection Report Facility Name:
Spook Uranium Mill Tailings Remedial Action Project Converse County, Wyoming Inspection Conducted:
September 6, 1989 NRC Personnel:
Daniel Gillen Giorgio Gnugnoli Larry Camper Area Inspected:
D. Gillen conducted a routine, announced inspection including review of scope of construction activities, site conditions, and quality control records.
In conjunction with the inspection, G. Gnugnoli and L. Camper observed the Acid Pond vicinity property, the windblown areas, and other soil clean-up areas, and discussed related radiological clean-up issues with appropriate staff of DOE and their contractors.
Details:
1.
Persons Contacted:
Dana Williams, Site Manager, Morrison-Knudsen, Inc. (RAC)
Jack Roesch, QC Supervisor, MK Chris Watson, Site Manager, U.S. DOE Karen Agogino, Site Manager, Jacobs/Weston (TAC)
Von Black, Chem-Nuclear Dave Charlton, Chem Nuclear Jim Turner, Chem Nuclear Bud Preston, State of Wyoming, UMTRAP Ed Sadler, State of Wyoming, AML George Hoffman, State of Wyoming, AML Dale Shay, State of Wyoming, AML Present at exit interview 2.
Disposal Site The inspector observed general conditions of the disposal cell construction area. The only construction activity o) served during the inspection was the backfilling of a portion of the pit north of the disposal cell, an aspect of the project associated with the Abandoned Mine Lands (AML) program.
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2 Prior to the construction inspection, contaminated material had been placed to elevations exceeding the maximum elevation established in the RAP. Volume of contaminated material had exceeded the estimated quantity by approximately 50,000 cubic yards. A DOE audit noted this deviation, and DOE subsequently decided to modify the design such that the additional contaminated material is to be relocated along the east and west sides of the existing disposal cell. A PID on this design change has been submitted to NRC for review.
In the meantime, DOE has elected to proceed with this reconfiguration of the cell, and has completed about 50% of the additional work.
3.
Records Review The inspector reviewed the following quality control records to ensure compliance with current versions of the cor.struction specifications, Remedial Action Inspection Plan (RAIP), and Remedial Action Plan (RAP):
(1) microwave / oven correlations and frequencies of correlations for contaminated materials, low-permeability layer, high-permeability layer, and granular fill; (2) frequencies and results of moisture and density testing of contaminated material, low-permeability layer, high-permeability layer, and granular fill; (3) frequencies and results of classification and gradation testing of low-permeability layer and granular fill; (4) frequencies of 4-point and 1-point Proctor tests; and (5) Quality Control Photograph Album.
Review indicated that a sufficient number of moisture / density tests, even/ microwave correlations, gradation tests, classification tests, and Proctor tests have been performed for appropriate QC of earthwork materials in accordance with the RAIP. Furthermore, all testing indicated results which met specifications. One potential minor problem area was noted during the review of records. There exists a discrepancy between the RAIP and the construction specifications regarding the requirements for number of moisture / density tests per day on which more than 150 cubic yards of fill are placed. The specifications required at least 1 test per day while the RAIP requires at least 2 tests per day.
In addition, it was noted that NRC had not been provided the most recent version of the construction specifications.
4.
Soil Clean-up Issues NRC and DOE staff and DOE contractor staff (Chem-Nuclear, Jacobs Engineering) discussed the reliance upon visual observation for determining UMTRA soil clean-up responsibility. After touring those specific locations where DOE intends to use visual observation to define t
clean-up responsibilities for DOE, as opposed to AML, it was apparent to l
NRC staff that there were clear physical characteristics distinguishing natural unprocessed ore and ore spoil materials from residual radioactive materials (color, granular consistency, etc.). NRC staff provided an informal mark-up of the RAC HP procedure RAC-021, which addressed visual
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observation criteria specifically for the Spook site.
In addition, NRC staff provided copies of an NRC internal memorandum identifying various portions of the Spook site, windblown area, and nearby acid pond according to what the NRC staff thought to be the supplemental standard clean-up criteria. DOE indicated that they would review this internal memorandum and that they would compare its content to the DOE understanding of appropriate clean-up criteria. NRC staff indicated that visual observation could be used in the Spook clean-up, provided that the NRC concerns with RAC-021 were adequately addressed. DOE staff requested that NRC submit formal written comments on RAC-021; NRC staff agreed. NRC staff also observed the analytical counting techniques and equipment (spectral analyzer) used to determine the radioactivity and specific radionuclides composition of soil samples.
5.
Exit Interview The inspector and other NRC staff met with representatives of the DOE, the State of Wyoming, the TAC, and the RAC at the conclusion of the inspection. The staff summarized the sccpe and findings of the inspection, as well as results of the discussions and observations related to the radiological clean-up aspects of the remedial action as follows (signed observations attached):
Issues from previous site visits o
N/A Observations In general, test records are complete and thorough, and display o
acceptable test results and frequencies for all earthwork materials. QC personnel (Jack Roesch) exhibits excellent knowledge of the construction activities and specifications for those activities.
o The RAIP and the specifications being used in the field contain an inconsistency regarding3the requirement for moisture / density testing per day of +150 yd of material placed (1/ day-Spec, 2/ day-RAIP).
In addition, the latest specs submitted to NRC is now outdated (Rev.B vs. Rev.1). DOE should assure that the RAIP and specifications are consistent and that NRC receives the updated versions of the specifications.
Other Items o
NRC staff received copies of PID No. 15-S-02 and PID No. 15-S-03. NRC plans to review these in conjunction with the ongoing final RAP review and issue a final TER which addresses both reviews.
4 o
NRC staff discussed concerns with the RAC-021 Health Physics Procedures on Visual Identification of Naturally Occurring Uranium Deposits for Spook, Wyoming. DOE contractor staff agreed to initiate clarifications of the. criteria in RAC-021 to be used to distinguish UMTRA clean-up material versus natural or AML clean-up materials. The revised RAC-021 procedures will be used for identifying any further material to be cleaned up in the windblown area, the mill yard area, an ore body area directly west of the Loma Pit, and the Acid Pond VP area.
PID No.15-S-03 referring to an alluvial deposit containing Radium-226, located north of the millsite, also will rely on criteria in RAC-021 to identify material to be cleaned up versus naturally occurring uranium deposits. NRC will transmit specific comments on RAC-021 to DOE.
M.)
Daniel Gillen Giorgio Gnugnoli l
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