ML20138H088
| ML20138H088 | |
| Person / Time | |
|---|---|
| Issue date: | 09/18/1985 |
| From: | Higginbotham L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Themelis J ENERGY, DEPT. OF |
| Shared Package | |
| ML20138H094 | List: |
| References | |
| REF-WM-41 NUDOCS 8510280227 | |
| Download: ML20138H088 (5) | |
Text
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Mr. John G. Themelis UMTRA Project Office DE Martin j;
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Albuquerque, New Mexico 87115 S Sm kowski k
Dear Mr. Themelis:
l During a meeting in our offices on August 20, 1985, Dave Ball delivered a draft i
Remedial Action Inspection Plan (RAIP) prepared by the State of Utah for the i
Salt Lake City project.
In accordance with conclusions of the meeting, we i
have reviewed the RAIP and are providing the enclosed comments for your transmittal to the State. We are also enclosing as reference the NRC Staff Technical Position on testing and inspection that provides the basis for this review.
l Should you have any questions regarding this review, please contact me or Dan j
Gillen (FTS 427-4160) of my staff.
i i
Sincerely, I
Original signal by lee B. W i
Leo B. Higginbotham, Chief Low-Level Waste and Uranium Recovery Projects Branch Division of Waste Management i
Office of Nuclear Material and Safefy j
and Safeguards l.
Enclosures:
As stated 8510280227 850918 PDR WASTE i
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- WMLL
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_____:_q.f...._:____________:____________:________..__:_
0FC :WMLU:rb NAME :DM Gillen rtin
- LB Fiijginbotham l...__:____________:..._____...:....._______:.__________.:____________:____________:___________
DATE :85/09/tv
- 85/09//8
- 85/09/
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s 8 1985 ENCLOSURE 1 l
. Review of Draft Remedial Action Inspection Plan Clive UMTRA Site j
by Engineering Branch, WM l
CHAPTER 2 - TESTING AND INSPECTION Section 6.1, Field Density Control, Page 2 1.
Section 6.1.1 - Since the Troxler Nuclear Densometer is beinn used in radiation areas, it will require frequent calibration. The RAIP should specify the frequency (as per Section 6.7.4 of Chapter 5) for which sand cone tests will be used to confirm the results of the Troxler Nuclear Densometer rather than stating "when deemed necessary".
2.
Section 6.1.2. - The RAIP should additionally specify that a minimum of 2 density tests be performed per day when appreciable material is placed (in
' excess of 150 cubic yards) and that a minimum of one test be performed per lift and per every full shift of compaction operations.
3.
Section 6.1.3 - The RAIP states that a Proctor test will be run for every 20,000 cubic yards of contaminated material placed and for a minimum of every 20,000 cubic yards of radon barrier material placed. However, the Staff Technical Position [Ref.1] recomends that " supplementary laboratory compaction curves (based on complete Proctor tests) should be obtained, approximately one for every 10 or 15 field tests, depending on the variability of materials." This corresponds to a minimum of one complete test per 10,000-15,000 cubic yards of contaminated material placed and one complete test per 5,000-7,500 cubic yards of radon barrier material placed based on the STP recomendation for field density test frequencies. The STP also recomends that one-point Proctor tests should be performed more frequently, and that whenever different material types are encountered, a complete Proctor test should be perfomed for each material type.
It is recomended that the frequencies of Proctor tests be increased such that they are consistent with the Staff Technical Position.
In addition, the RAIP should specify whether one-point Proctor tests or complete Proctor tests will be perfonned.
Section 6.2, Gradation Testing, Pages 2-3 Section 6.2.1 - This specification should also state that at least one 1.
gradation test be performed for each day of significant material placement l
t
U SEP Q6 1345
. (in excess of 150 cubic yards) for all materials other than contaminated material (as per STP).
2.
Section 6.2.3 - The RAIP states that " Gradation tests will be done on material-that is taken from material that is 'in place' on the Clive site."
If the material does not meet gradation specifications, then this "in place" material would need to be removed or reblended so that material that meets the specifications can be placed. Gradation tests on the soil and rock cover materials should be performed during placement rather than after the material has been placed to avoid the potential for removal of material.
Section 6.3, Soil Classification, Page 3 1.
The classification testing requirements should be based on a frequency criterion rather than "whenever called for by the engineer or the inspector."
Section 6.4, Other Testing, Page 3-4 1.
Section 6.4.1 and 6.4.2 - These sections should further state that at least one series of Atterberg Limits tests should be performed for each day of significant radon barrier material placed (in excess of 150 cubic yards).
2.
Section 6.4.3 - Specific Gravity and Absorption tests on rock erosion barrier material will be run "once a month and whenever they are deemed necessary." The requirement for these tests should be specified by the volume of material placed rather than on a time basis. The recommended frequency of testing should be consistent with that as specified for the soundness and abrasion tests, i
3.
Section 6.4.4 and 6.4.6 - These sections indicate test frequencies of one test for every 120,000 square feet of rock erosion barrier material placed. The RAIP should also specify that a minimum of three tests equally spaced throughout rock placement should be performed for each type of riprap.
Furthermore, the RAIP indicates that the material to be tested will come from material that is already "in place".
For the same reason as identified in comment 2, Chapter 2, Section 6.2, the tests should be performed on the material before placement rather than after the material has been placed.
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sEP_Of_B85 Section 6.5, Inspection, Pages 4-5 1.
Section 6.5.1 - The RAIP states that " Inspection shall be performed to assure that all excavation is done according to the approved plans and specifications."
If " excavation" as used in this section also applies to the Vitro site, then a statement should be made requiring verification by l
the H.P. supervisor that all contaminated materials have been excavated.
2.
Section 6.5.2 - Reference to the 1-foot maximum lift depth should be clarified to indicate whether this is the loose or compacted lift thickness.
3.
Section 6.5.3 - It is recommended that the first sentence of this section be modified to read as follows:
" Inspection of the radon barrier material will be performed to assure that the material is placed in accordance with 4
the specifications."
Section 7.0, Records, Pages 5-6 i
l 1.
Section 7.1 - This section states that " Inspectors will be on-site whenever there is progress being made on the project."
It is recommended that the word " progress" be better defined.
Section 7.1 - This section.should include a statement which requires that l
2.
the status of inspection and testing be identified by charts, as-builts, I
or periodic status reports.
1 CHAPTER 5 - CONTROL OF MEASURING AND TEST EQUIPMENT t
Section 6.0, Procedure, Pages 1-4 i
1.
Section 6.3.2.4 - The results of the calibration should also include the required accuracy for the instrument that is being calibrated.
2.
Section 6.7.4 - This section states that "At least 10 sand cone tests will be performed when tailings are initially placed."
It is not clear what
" initially placed" is intended to mean (i.e. the first day of placement, the first lift of material, etc.).
It is reconnended that this statement be clarified.
l
'V SEP 0g 1995
. CHAPTER 6 - NONCONFORMANCE AND CORRECTIVE ACTION Section 6.3, Corrective Action, Page 3 Section 6.3.4 - The RAIP states that if "the nonconformance is of a serious nature it may be necessary to inform the DOE UMTRA Project Office. This contact may result in approval and/or suggestions from the DOE." Clarification of this statement is necessary so that it is clear what the DOE would be approving.
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