ML20248G239
| ML20248G239 | |
| Person / Time | |
|---|---|
| Issue date: | 10/05/1989 |
| From: | Lohaus P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Matthews M ENERGY, DEPT. OF |
| References | |
| REF-WM-68 NUDOCS 8910100145 | |
| Download: ML20248G239 (4) | |
Text
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Mr) Mark Matthews, Acting Projsct Manager M ' 61989 r
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lrranium Mill Tailings Project.0ffice U.:S. Department of Energy P.~ 0. Box 5400 Albuquerque, NM 87115
Dear Mr. Matthews:
We have reviewed Revision C of the Green River Remedial. Action. Inspection Plan (RAIP) and DOE responses to NRC comments. Rev. C of the RAIP was provided on-June 1, 1989; we reviewed this document and were unable to provide our concurrence. Comments were transmitted to you on June 22, 1989. Bised on our review of,the information and data subsequently provided by DOE on Jugust 15, 1989, we conclude that the procedures in the RAIP are not adequate t o assure that acceptable moisture / density testing has been performed. The RA13 procedures'do not adequately confirm that contaminated materials have been placed at the proper density / moisture levels, since the RAIP (Rev. C 4 has provisions only for limited verification testing, compared to Rev. B of the I
RAIP or to NRC generic guidance.- Therefore, lacking sufficient information to demonstrate that materials have been placed at the. proper density / moisture levels, we may not be able to concur that the remedial action has betn completed in conformance with the RAP.
For that reason, we are unabie to concur in Revision C of the RAIP.
To resolve this issue, DOE needs to provide adequate justification thit the material characteristics and testing employed and test results are sufficient to confirm that the contaminated material placement requirements are met and that there is reasonable assurance 'of site stability.and adequate pro;ection of public health and safety. This justification should be provided in t1e RAP.
To assist you in providing the justification needed, the information autlined in Enclosure 1 should be considered.
On October 11, 1989, we will be conducting an inspection at the Green River site. At that time, members of my staff will be available to discuss any questions you may have regarding details of the information and justification required to resolve this issue. We also expect to. perform a detailed review r
of the test data that was generated during the placement of contamina ted material.
If you have any questions, please do not hesitate to call Sincerely, hbkhN cc: Sally Mann, DOE Hg.
a Larry Anderson (State of Utah)
OB/LLWM/NMSS 1
Chris Watson, DOE: Alb.
Distribution: Central: File 1 WMf68f NMSS r/f RBangart, LLWM JGreeves, LLWM MBell, LLRB JSurmeier, LLTB PLohaus, LLOB MF11ege, LLOB TJohnson, LLOB DGillen, LLOB MTokar, I LTB
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- PDR YES /T7 LF co
.PDR NO L__/ Category: Proprietary / /
or CF Only / /
nw ACNW YES /X /
NO / /
- SEE PREVIOUS CONCURRENCE i
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REiew of Green River Remedial Action Inspection Plan i @ co 0FC :LLOB*
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ENCLOSURE 1 ADDITIONAL INFORMATION AND JUSTIFICATION NEEDED IN GREEN RIVER FINAL REMEDIAL ACTION PLAN i
ISSUE: Tests to verify the placement density and moisture content of the j
contaminated materials placed in the disposal cell were not required at a-1 i
frequency of one test per 1000 cubic yards of material placed, as recommended in NRC staff guidance and as generally performed at other UMTRA sites.
Rather, a performance specification was set and less frequent "non-record"
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verification tests were performed.
I RESOLUTION: DOE needs to provide a detailed justification that the field and laboratory testing performed, in conjunction with the performance specification, is adequate to provide reasonable assurance that the in-place contaminated materials meet the RAP design requirements for density and moisture.
In formulating this justification, DOE should consider, and provide ~
detailed information on, the following:
- The uniformity of the contaminated materials, as supported by gradation tests, resulting gradation p!!rameters, and Proctor compaction tests.
- The results and locations of all density and moisture tests that were performed, including results of the trial compaction, and an analysis of the data which provides the basis for confidence that the moisture / density requirements are met.
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.Mr.' Mark Matthews, Acting Project Manager Uranium Mill Tailings Project Offica
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- U. S. Department of Energy 1
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P.:0. Box 5400 Albuquerque, NM 87115
Dear Mr. Matthews:
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e We have' reviewed Revision C of the Green River Remedial Action Inspection Plan (RAIP) and DOE responses to NRC comments. Rev. C of the RAIP was provided on June 1, 1989; we reviewed this document and were unable to provide our concurrence. Comments were transmitted to you on June 22, 1989. Based on our i
review of the information and data subsequently provided by DOE on August 15, 1989, we conclude that the procedures in the RAIP are r.ot adequate to assure that acceptable moisture / density testing has been performed. The RAIP procedures do not adequately confirm that contaminated materials have been placed at the proper density / moisture levels, since the RAIP (Rev. C) has provisio only for limited verification testing, compared to Rev. B of the RAIP or t NRC generic guidance. Therefore, lacking sufficient information to demonstrat that materials have been placed at the proper density / moisture j
levels, we ay not be able to concur that the remedial hetion has been 1
completed in conformance with the RAP. For that reason, we are unable to concur in Rev ion C of the RAIP.
To resolve this sue, DOE needs to provide adequate justification that the materialcharacte}rsticsandtestingemployedandtestresultsaresufficient to confirm that the contaminated material placement requirements are met and that there is reason le assurance of site stability and adequate protection of publichealthandsaf(ety This justification should be provided in the RAP.
To assist you in providi the justification needed, the information outlined in Enclosure 1 should be nsidered.
On October 11, 1989, we wi be conducting an inspection at the Green River site. At that time, members o'f my staff will be available to discuss any s
questions you may have regardindsdetails of the information and justification required to resolve this issue. W'q also expect to perform a detailed review of the test data that was generatedNiuring the placement of contaminated material.
If you have any questions, please do not hesitate to call.
Sircerely, Pqui Lohaus, Chief OB'/4LWM/NMSS Distribution: Central File # WM-68 NMSS r/f RBangart, LLWM JGreeves, LLWM MBell, LLRB JSurmeier,,TB PLohaus, LLOB MFliege, LLOB TJohnson, LLOB DGillen, LLOB MTokar, LLTB BJagannath, LLTB JJones, LLOB r/f i
PDR N0
/ / Category: Proprietary / /
or CF Only / /.s
- SEEPREVIOUSCONCURRENCE\\
ACNW YES /Y~7 N0
/
SUBJECT AB5 TRACT:
e'Tiew of Green River Remedial Action Inspecfion Plan
- LLT c-LLOB
- LLWM
- HhSS 0FC :LLOB^*
- LLOB
- LLTB*.. --... s.. M ':
-.................g NAME:TJohb/'jj
- MFliegel :BJa ath :MTokar
- PLohaus :
n DATE:10/04/89
- / /89 :10/04/89
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/ /89 : / /89 : / /89
/TJ/D0E/GRN/10/02 1-
' ^Mr. Mark Matthews,- Acting Proj:ct Manager 6 ' EUranium Mill' Tailings Project Office p
U. S. Department of Energy P. 0.' Box 5400
, Albuquerque, NM 87115
Dear Mr. Matthews:
We have reviewed Revision C of the Green River Remedial Action Inspection Plan (RAIP)'and DOE responses to NRC comments. Rev. C of the RAIP was provided on June 1, 1989; we re iewed this document and were unable to provide our 4
concurrence.. Commer s were transmitted to you on June 22, 1989.
Based on our, review of the informa ion and data subsequently provided by DOE on August 15,-
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1989, we conclude-that he procedures in the RAIP are not adequate to assure that acceptable moisture ensity testing has been performed. The RAIP y
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procedures do not adequate confirm that contaminated materials have been 1
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' placed at the proper densit.mistura levels, since the RAIP (Rev.' C)' has provisions only for limited / rification testing, compared to Rev. B of the RAIP or to NRC generic guidanc. Therefore, lacking sufficient information to
'1 demonstrate that materials have been placed at the proper density / moisture levels, we may not be able to co cur that the remedial action has been completed in conformance with the RAP. For that reason, we are unable to concur in Revisinn C of the RAIP.
To' address this issue, DOE needs to ustify that the material characteristics and testing employed and test result are sufficient to confirm that the
-contaminated material placement requi ements are met and that there is reasonable assurance of site stability and adequate protection of public health and safety. This justification should e provided in the RAP. To assist you-in providing the justification needed, t e information outlined in Enclosure 1 should be considered.
On October 11, 1989, we will be conducting n inspection at the Green River site. At that time, members of my staff wi 1 be available to discuss any I
questions you may have regarding details of he information and justification required to resolve this issue. We also expe t to perform a detailed review of the test data that was generated during th placement of contaminated j
material.
If you have any questions, please do not hesitat to call.
Sinc rely, Paul ohaus, Chief I
OB/LL /NMSS j
Distribution: Central File # WM-68 NMSS r/f RBangart, LLWM JGreeves, LLWM MBell, LLRB JSurmeier, L TB PLohaus, LLOB MFliege, LLOB TJohnson, LLOB DGillen, LLOB MTokar, LLTB BJagannath, LLTB JJones LLOB r/f PDR NO
/- 7 Category: Proprietary /7 or CF Only
/
ACNW YES /X /
NO / /
SUBJECT AB5 TRACT:
RWiew o~f Green P.iver Remedial Action In pection Plan OFC :LLOB
- LL65
- LLTB
- LLTB
- LLOB MLLWM
- NMS5 hAkET n)jl kFiiehk n$t5 MTokar PLohau a
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- / /89 : 10/4 /89
/ /89 :
/ /89 : / /89 : / /89 DATE:[o/y/89
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