ML20212A078

Insp Procedure 87654, Uranium Mill Site Decommissioning Insp

ML20212A078
Person / Time
Issue date:	09/02/1997
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
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ML20212A051	List: ML20212A046 ML20212A064 ML20212A074 ML20212A078 ML20212A082
References
REF-WM-3 IP-87654, NUDOCS 9710230150
Download: ML20212A078 (9)

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NRC INSPECTION MANUAL NMSS/ URB INSPECTION PROCEDURE 87654 URANIUM MILL SITE DECONMISS10NING INSPECTION PROGRAF APPLICABILITY: 2801 87654-01 INSPECTION OBJECTIVES To determine if licensed decomissioning programs are being conducted in accordance with Nuclear Regulatory Commission requirements specified in individual licenses and the regulations. To provide assurance that uranium mill site decommissioning activities are being performed appropriately to demonstrate comal1ance with the decommissioning regulations and guidelines, and in accordance wit 1 the approved reclamation plan. This procedure supplements Inspection Procedure (IP) 88104 and provides details specific to decommissioning uranium mill sites. This arocedure is also applicable to 11e.(2) byproduct disposal sites licensed by tae NRC that are not associated with a uranium mill: however.

[ the inspector should confirm the regulatory requirements for the site as V] indicated in the site license.

87654-02 INSPECTION REQUIREMENTS A determination of compliance with NRC requirements will be based on direct observation of work activities, interviews with workers, demonstrations by workers performing tasks regulated by NRC, independent measuremuts of radiation conditions at the facility, and review of licensee records. The inspector should refer to Inspection Manual Chapters (IMCs) 2602, 2605, and 2801 for general policies and guidance.

The scope of the inspection of licensed activities will be commensurate with the scope and status of the licensee's decommissioning program and with previous inspection efforts. A primary decommissioning activity to be addresseo is soil cleanup and cleanup verification to demonstrate compliance with Criterion 6(6) of 10 CFR Part 40. Appendix A (most mill buildings are buried in the disposal I cell) . However, inspection of the implementation of other radiological decommissioning requirements in Criterion 6. such as measurement of radon flux and gamma levels from th: disposal cell cover, may be necessary and should be

- coordinated with the Headquarters health physicist. Ground-water compliance will be evaluated against Criteria 5B. SC, 50, SE, SG, and 13. Surface reclamation (includes disposal cell construction) compliance will be evaluated against

. Criteria 4 and 6, and is discussed in Inspection Procedure (IP) 88001.

Applicable portions of 10 CFR 40.42. such as the requirenents for timely decommissioning, may need to be addressed, therefore the NRC Project Manager O) i should be consulted when the site inspection plan is being developed.

Issue Date: 09/02/97 ,

87654 9710230150 971003 PDR WASTE WM-3 PDR.

This IP should be used as a checklist when developing a site-specific decomnissioning inspection plan. The decommissioning inspection plan should not duplicate the normal inspection for radiation protectDn and environmental mordtoring, but emphasize observation of key decommissioning activities being performed. If possible, implementation of this procedure should be initiated early in the decommissioning phase, to identify any program deficiencies and to gain confidence in the licensee's performance.

02.01 Preparation. The inspector should allow adequate time to pre)are for the inspection. Preparation will include reviewing documents. mating travel arrangements, coordinating with appropriate staff, notifying appropriate State .

agencies, and selecting necessary equipment, ln particular, the inspector shall identify whether any license amendments have been issued since the last inspection, or whether the licensee has informed NRC of any major program changes since the last inspection. The inspector shall also review any event files to determine if the licensee had any incidents or events since the last inspection.

02.02 Entrance Briefina. When the inspector arrives at the licensee's facility, he/she will inform an available tenior management representative of the purpose and scope of t h inspection.

02.03 General Overview

a. Oraanization. Interview cognizont licensee representatives about the current organization of the program. Examine the licensee's organization with respect to changes that have occurred in personnel, functions, responsibilities and authorities since the previous inspection. Identify the reporting relationship and management structure between the licensee's executive management and the Radiation Safety Officer (RS0).

b. Stone of Proaram. Interview cognizant personntl to determine the scope of licensed activities, site status, staff size, etc.

c. Manaaement Oversiaht. In the course of interviewing cognizant personnel, determine if management oversight is sufficient to provide the licensee staff with adequate resources ana authority to administer the licensed program.

1. RS0 - Determine whether the RSO has sufficient authority, and fulfills the appropriate duties commensurate with the size and scope '

of licensed activities.

2. Audits - Verify that audits are performed as required. Verify that the results of the audit are reviewed and addressed.

3. Determine that individuals who perform and/or supervise licensed activities are qualified and perform an appropriate level of supervision, as required by the license or regulations,

d. Decommissionina Activities. The inspection should be scheduled so that decommissioning 6ctivities can be observed, unless it is to be the final decommissioning inspection (after the Final Survey Report submitted and reviewed). Licensee decommissioning staff should be interviewed and relevant records on decommissioning activities reviewed.

e. Site Orientation Tour. A brief site tour should be made. General observations should be noted on the condition of the facility and the licensed activities being performed.

87654 Issue Date: 09/02/97 I

02.04 Eauioment and Procedures. Review the equipment and procedures used for

,- decommissioning the site to determine if arm'opriate and approved equipment and methods were followed.

Q) 02.05 Final Survey. Verify the accuracy and reliability of the licensee's final survey data by reviewing the methods used and the final survey data.

02.06 Ouality Assurance /0uality Control. Verify the adequacy of the licensee's quality assurance and control program.

02.07 Data Reduction and Manaaement. Veri _fy the way field data is documented and processed.

02.08 Personnel Trainina. Verify that appropriate training and instructions were/are given. Through discussions with workers, verify that licensee personnel understand and implement the established decommissioning procedures.

02.09 Confirmatory Survey. The survey by the inspector should include gamme scans und alpha scans if applicable) and soil analysis using methods similar to those approved for use by the licensee. The inspector's survey data is used as an indication of whether or not the licensee properly implemented the approved procedures and complied with the decommissioning criteria.

02.10 Ground Water. Verify that the ground-water monitoring and/or corrective proccam is being conducted (1) in compliance with Appendix A of 10 CFR 40 and (2) as required by applicable license conditions. Verify that the aonds are being monitored for leakage into the ground water as required by applicable license conditions, fN s' ')

02.11 Exit Meetina. When the inspection is over, there should be an exit meeting with the most senior licensee representative present, to discuss the

! preliminary inspection findings.

02.12 Post-Insoection Actions. After the inspection, the inspector shall summarize the findings with his/her suoervisor. The inspector shall also contact Headquarters staff when any pertinent issues are raised during the inspection, when inspection findings impact on any licensing actions, or to give feedback on how the licensee has addressed recent licensing actions.

The inspection report should document what activities were observed, summarize the interviews with licensee personnel, and clearly indicate the evaluation of the licensee's decommissioning program.

87654-03 INSPECTION GUIDANCE 03.01 Precaration. Before the inspection, the inspector should be familiar with the guidance listed in the Appendix of this IP and a review of the following should be performed.

a. Ooeratina History. Review the history of each license to identify what types of work a:tivities were performed, the types of buildings that existed, and the geogra)hical location of each. Review the results of

. past operational radiological surveys that were used to demonstrate radiological control of the uranium mill.

, A

(' b. Waste Disoosal Practices and Radioactisity Releases.

disposal outside the tailings cell.

Verify waste Consider the potential for, or Issue Date: 09/02/97 -J- 87654

evidence of, contamination from spills, or other releases of radioactive material (such as haul routes) to compare with the soil cleanup boundary. .

I c. Environmental Monitorina Data. Verify operational soil sampling, airborne emissions, and ground-water monitoring data, specifically for evidence of radiological contamination. Verify effectiveness of effluent controls, particularly during drying and packaging operations, and when air was exhausted from the yellowcake stack. Determine area where ,

airborne contamination would likely be deposited.

d. Results of Previous Surveys. Verify the results of scoping. ,

characterization, and remedial action support (excavation control) surveys performed by the licensee. Review the results of previous surveys for justification of the classification of mill site areas (e.g..

mill site boundaries versus windblown areas). In particular, review data for the areas adjacent to the remediation of windblown contamination,

e. Remedial Actions. Review the specific procedures that were used to decontaminate the process facilities and/or land areas. Consider the potential for incomalete remediation based on these remedial action techniques. particu' arly the potential for the remedial actions to produce areas of localized contamination within verification grids that were not represented in the gamma scan average value. Determine if the licensee has identified the need to remediate radionuclides other than raditm-226 (Ra-226).(e.g. . beneath acidic raffinate ponds) where thorium-230 (Th-230) could migrate farther than Ra-226 or where uranium ore residue or yellowcake contamination could be located,

f. Guidelines Established. Review the guidelines that the licensee is using for indoor and outdoor areas and verify how the stated guidelines are being implemented:(e.g., use of surrogate measurements, presence of multiple contaminants, averaging conditions, and hot spots).

g. Records. Review the site's previous inspection history, license conditions and licensee's submittals concerning decommissioning, and the Technical Evaluation Reviews for the related amendments, to be aware of follow up inspection items, commitments made by the licensee, and assumptions or conclusions, made by licensing staff. related to decommissioning,

h. Backaround Refercnce Areas. Identify the value that NRC licensing staff approved as the site Ra-226 soil background. Determine if any recent information might require a review of the background value to determine that its use for soil cleanup is adequate to protect long-term health and safety (e.g., soil cleanup extended into background locations).

03.02 Entrance Briefina. No specific guidance required.

03.03 General Overview. No specific guidance required.

03.04 Eauioment and Procedures. The inspector shall verify the gamma surveys done by the licensee by reviewing the following:

a. Instruments. Review the basis for the selection of instruments (e.g., ,

based on potential contaminants and their associated radiations, types of media (soil sludge, etc.) to be verified, and detection sensitivities).

Typically, sodium iodide (Nal) scintillation detectors are used for land area surveys.

Issue Date: 09/02/97 I 87654

b. Sensitivity. Review documentation pertaining -to instrumentation -(

-sensitivity, particularly. licensee statem?nts to = the - effect that instrumentation will-be sufficient to detect radiological contamination.

O T,he detection sensitivity should be below the appropriate guideline Q -

values. Also. verify the instrument scan sensitivity for exterior scan-surveys (NUREG-1575. Section 6.4). Check the scan sensitivity in terms-

of the gamma soil cleanup guideline.

c. Gamma-Radium Correlation. Confirm that the licensee checkec the correlation of Ra-226 concentration to gamma levels during verification.

l' ~ and that an acceptable correlation was obtained,

d. Methods. Verify the methods / procedures for exposure rate measurements and gamma scans, unless these were reviewed with the Reclamation Plan.-

If - possible. -observe if the measurements - and scans- are performed according to the procedures and good health physics practices. such that reliable data are produced,

e. Calibration. Verify the procedures for instrument calibration: (e.g..

use of appropriate radionuclide calibration sources, source geometry, and appropriate consideration of environmental conditions). Check the calibration date of survey meters,

f. Check-out. Review the operational check-out of survey instrumentation.

Verify frequency of operational checks (both to calibration source and background) and if instrument responn fell within predetermined acceptance criteria.

The inspector should verify the surface scans of buildings and equipment by reviewing the following:

a. Instruments. Review the basis for the selection of instruments: (e.g.,

based on potential contaminants and their associated radiations, surface types to be verified, and detection sensitivities). Typically. Geiger Muller, gas oroportional, or zinc sulfide detectors are used for building surface con; amination surveys. Verify. the energy dependence of .the measurement instrument and determine if the licensee has appropriate.y addressed this issue. Remember that beta detectors are more sensit'.ve to for "old" yellowcake than alpha detectors.

b. Sensitivity. Review documentation pertaining to instrumentation sensitivity, particularly- licensee statements to the effect that instrumentation will be sufficient to detect radiological contamination.

The detection sensitivity should be below the a>propriate guideline values. Verify the instrument scan sensitivity for )oth the interior and exterior scan surveys of building surfaces (NUREG-1575. Section 6.4),

c. Eauations. Review the licensee's minimum detectable contamination equation for direct measurements on building surfaces and the conversion of counts to activity (should use the 4n efficiency factor).

d Calibration. Verify the procedures for instrument calibration, e.g.,

appropriate radionuclide calibration sources. source geometry, and

. appropriate consideration of surface and environmental conditions.

O e. Melhpdi Verify the method for exposure rate measurements, unless it was part of the Reclamation Plan. Normally, measurements are done 1 meter (3 feet) from the floor and at least 1 meter (3 feet) from a corner.

Issue Date: 09/02/97 87654 w i

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f. Check-out. Review the operational check-out of survey instrunentation.

Verify frequency of operational checks (both to calibration source and .

background) and if instrument response fell within predetermined acceptance criteria. ,

03.05 Final Survey. The inspector should verify the level of survey coverage for structures and land areas, based on the area classification (e.g., mill site or windblown area: affected or unaffected). The inspector should review the .

licensee's procedures for performing surface activity measurements and scans on building surfaces, for performing soil sampling. and ground-surface scanning.

When possible, the inspector should observe implementation of the procedures to ,

determine if the procedure is followed and performed in a manner reflecting good health physics practices. In particular, review the following:

a. Measurements. Determine whether the type, location, and number of measurements and/or samples per area are sufficient to provide a good representation of the radiological contamination. NUREG/CR-5849 should be consulted for general guidance.

b. Boundaries. Ensure that the boundaries of the windblown areas have been appropriately determined (review gamma data and perform spot-check gamma scans), and that any potential subsurface radioactive material deposits have been addressed,

c. Follow-uo. Determine the use of investigation levels for measurements results and if the licensee performed appropriate follow-up actions. For example, soil samples should be collected if the Nal scintillation detector readings exceed a specified investigation level,

d. Samole and Analytical Procedures. Verify the licensee's sample collection and preparation techniques and equipment: (e.g., mixing ,

drying, geometries used for gamma spectrometry on soil samp*les, ingrowth period for Ra-226 progeny, etc.). Review the licensee s analytical ,

procedures for radiological analyses, particularly the analysis of soil samples by gamma spectrometry. If a contract laboratory was used, those procedures should be available for review, including sample chain-of-custody procedures.

e. Meters. Review the protocol the licensee uses to interpret the gamma spectrometry results, particularly the radionuclide peaks used to identify various contaminants. Check for dri ft checks, energy calibration, control charts, duplicate sample counts, split samples with outside laboratory, etc. Determine whether the survey meters and gamma spectrometer are maintained and operated in accordance with the manufacturer's recommendations and good health physics practices,

f. Egplaced Data. Review survey results for those areas where additional investigations have been conducted. If initial survey data have been replaced or supplemented as a result of the investigation, ensure that the replacement data are annotated in the final report. The annotation is intended to alert the reviewer that the initial data have been -

replaced.

g. Survey data. Select a portion of completed survey data and review data .

for compliance with procedures and final survey plan. Review the documentation for scan surveys to determine how the licensee identified and investigated any elevated readings during the scan survey. Review survey results for specific processing areas that have been remediated.

87654 Issue Date: 09/02/97 l m- _ - - - - - - - - _ - -

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including bu'ried raffinate lines, eva) oration ponds. etc. Determine-if

• .results demonstrate ' compliance wi;h guidelines -and :whether any -

modifications to the general survey approach were necessary.

5 03,06 Ouality Assurance /Ouality Control-

a. Laboratory.- Review the-licensee *s on-site laboratory and/or licensee's contracted off-site . laboratory quality assurance / quality control L procedures, including duplicates, blanks, and matrix sp1kes. Determine the frequency of anaiysis for each of the quality control- (0C) checks.

• Determine: whether the laboratory participates in cross check of aerformance: evaluation programs, such as those offered. by the Environmental Monitoring Laboratory and the U.S. Environmental Protection Agency,

b. Final Data. Review the final survey report data and discuss with the Headquarters health )hysicists, to ensure that the items listed below are adequately addressec either in the report or in the licensee's records:

1. QC sampling and direct measurements along with associated acceptance criteria and corrective actions.

2. Verification of survey measuremer.t data (i.e., data quality assessment 4 to determine adequacy of the collected data, for the intended use). Examples of- data quality assessment include verification that the collected data- are applicable to the statistical model used-to reduce the data, and other data quality indicators, including completeness, comparability, representativeness, precision, and accuracy.

3. Testing of. computer calculations by manual calculation.

03.07 Data Reduction and Manaaement

a. -Proaram Review. Perform a program review to determine if the licensee

-has set up a data reduction process with criteria stated in procedures, and-if the licensee's computer software has data reduction features in-the analysis, counting, and data reporting,

b. Soot Check. Select a completed survey data package, the data reduction procedure, and verify implementation by performing the data reduction proces: under the direction of the licensee.

1. Trace-- the path of data from their' generation in the field or laboratory, to their final- use.

-2. Review any checklist forms used for preventing loss of data during data reduction.

3. Ensure that data reduction analysis information are reflected in the

1. final survey results.

03.08 Personnel Trainina. Review the qualifications and training for survey

.- technicians and other project personnel.- If possible. question technicians about their' knowledge of procedures and the frequency or detail of their training.

03.09 Confirmatory Survey, Verify the need for a confirmatory survey based on the criteria in IMC 2801. A confirmatory survey by the inspector and/or NRC Issue Date: 09/02/97 87654

contractor should only be necessary if there is significant doubt regarding the licensee's final survey results. The extent of the survey (e.g.. gamma survey and soil analysis) should be determined with input from the Headquarters health physicist who reviewed the Final Survey Report. Confirmatory analysis of archived soil samples may be included.

03.10 Ground Water. Verify that ground-water cuality data were cilected at the "

correct locations and frequency, as requirec by the license (NRC-approved ,

radiological environmental monitoring program), were analyzed for the right constituents, and were verified to make a determination against established detection or com)liance standards, as appropriate. Confirm that if ground-water .

quality data incicated detection or compliance standards (including compliance standards set by Alternative Concentration Limits) were exceeded, that the licensee appropriately notified NRC and took appropriate sampling and, if necessar , corrective actions. Visually verify that compliance wells are correctl located with respect to the most recent NRC-approved locations. If applicab e, verify that ground-water corrective action programs were conducted in a timely manner. Also, verify that wells and boreholes that must be sealed under the approved reclamation plan, were correctly sealed and abandoned.

Visually verify that: (1) there are no failures or breaks in impoundment embankments, (2) that there are no obvious tears in impoundment liners, and (3) that there are no springs and seeps around impoundment embankments. If applicable. visually verify that the impoundment leak-detection and impoundment water-level monitoring systems are in place and operational. Verify that the licensee is conducting the appropriate level of visual inspections of impoundment integrity. If applicable, verify that the impoundment leak detection system is being monitored at an appropriate frequency and for the correct indicator parameters. Verify that appropriate monitoring. cleanup, corrective actions, and regulatory notifications were taken when impoundment fluids were found in the impoundment ground-water leak-detection system.

03.11 Exit Meetina. When the inspection is over, there should be an exit meeting with the most senior licensee representative present at the facility (see IP 30703 for details). If a senior management representative is unavailable for the exit meeting, the inspector may hold a preliminary exit meeting with appropriate staff on site.

03.12 Post Insoection Actions. The insnector will review his or her inspection findings with his or her supervisor and discuss violations, items of concern, and unresolved items in sufficient depth for management to make appropriate decisions regarding enforcement actions, referral to other State and Federal agencies, and decisions on the scheduling of future inspections of the licensee's facility.

The inspector should also discuss inspection findings with the appropriate Headquarters staff to inform the staff about how the licensee has addressed (or failed to address) special license amendments or recent licensing actions.

Licensing information requested by the licensee should also be discussed with the Headquarters staff.

Inspectors should be aware that NRC has entered into several memoranda of .

understanding, with other Federal age.cies. that outline agreements on items such as exchange of information and evidence in criminal proceedings. The inspector should ensure that the exchange of information relevant to inspection activities .

is made in accordance with the appropriate memorandum of understanding.

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87654 Issue Date: 09/02/97

87654 05- ' REFERENCES

~ The'following NRC IMCs and related IPs should be used for guidance. in part, for I O the dec6missioning inspection * '

.:IMCil230 " Quality Assurance Program for Radiological Confirmatory d

a Measurements" e IMC 2602 ' "Decomissioning Inspection Program for Fuel Cycle Facilities and i Materials Licensees"

. IMC 2605 "Decomissioning Procedures for Fuel Cycle and Materials Licensees" 4

• IMC 2801 " Uranium Mill and 11e.(2) Byproduct Material Disposal Site and Facility Inspection Program" (revised August 1997]

e.IP 30703- " Management Entrance / Exit Interview"

. IP 88001 " Construction Review"

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• IP 88104 "Decomissioning Inspection Procedure for Fuel Cycle Facilities" Applicable portions of the following NRC documents should be used for guidance:

• Draft BTP " Site Characterization for Decomissioning" November 1994, NRC, NMSS/DWM-

"A Nonaarametric Statistical Methodology for the Design and O e'NUREG-1505 Analysis of Final-Status Decomissioning Surveys" Draft.

-August 1995 (only Section 4)

. NUREG-1506 "Heasurement Methods for Radiological-Surveys in Support of New Decomissioning Criteria" Draft.- August 1995 (Sections 2 to 4)

• NUREG-1507' " Minimum Detectable Concentrations with Typical Radiation Survey

-Instruments for Various Contaminants land field Conditions" Draft. August 1995 e NUREG-1575L " Multi-Agency Radiation Survey and Site Investigation Manual

-(MARSSIM)" Draft. December 1996 (particularly Sections 5.5 and 6.0)

NUREG/CR-5849 - " Manual for Conducting Radiological Surveys in Support of License Termination"- Draft 1992

. NUREG/BR-0241 "NMSS Handbook for Decomissioning Fuel Cycle and Materials Licensees" March 1997 END O

-Issue Date: 09/02/97 87654