Issue Date: 10/05/01
NRC Inspection Manual FCLB
The purpose of this instruction is to provide guidance for planning and conducting on-site construction reviews of the remedial action to stabilize inactive uranium mill tailings sites. The work is under the direction of the Department of Energy (DOE) under the authority of the Title I, Uranium Mill Tailings Radiation Control Act of 1978. The Act requires the Nuclear Regulatory Commission to concur with DOE selection and performance of actions to stabilize the sites and, following those actions, to license DOE or such other Federal agency that the President may designate for the long-term care of the completed sites.
This Chapter establishes the program to be used by NRC reviewers monitoring the remedial action work carried out at inactive uranium mill tailings sites by DOE and DOE contractors.
| 03.01 | Remedial action. Those work activities carried out to stabilize mill tailings, clean up the processing site, and otherwise perform work to assure the site and tailings pile will conform to the Environmental Protection Agency (EPA) standards for inactive sites. |
| 03.02 | On-Site Construction Review. Includes all the efforts necessary to monitor the remedial action at inactive tailings sites, including, but not limited to, examination or evaluation of a program or activity. The majority of the remedial action subject to an on-site construction review is "earth moving" work. The review will determine compliance with the Remedial Action Plan (RAP), but will not include enforcement action, as NRC does not have the enforcement authority for this program under the Act. |
| 04.01 | Program Management, Policy Development, and Analysis, Office of Nuclear Reactor Regulation. Develops and issues requirements, guidance, and procedures for the NRC inspection program, and modifies the program as necessary based on experience, performance, and other factors. |
| 04.02 | Division of Fuel Cycle Safety and Safeguards, Office of Nuclear Material Safety and Safeguards. The Division develops and issues policy, guidance, and procedures for the Uranium Recovery Program; directs and carries out the NRC program for evaluation and concurrence with DOE remedial action plans for cleanup of inactive uranium mill tailings sites and contaminated vicinity properties under Uranium Mill Tailings Remedial Action (UMTRCA); and performs on-site construction reviews of remedial actions covered by this procedure. |
| 05.01 | The foundation for planning and scheduling reviews during remedial action at inactive tailings sites is the RAP, prepared by DOE and its contractors and issued with NRC concurrence. This plan includes criteria for all phases of the proposed remedial action. | |
| The RAP contains the construction specifications and the basic elements of the remedial action but does not always contain specific criteria or procedures for carrying out the testing and quality control inspection during construction. The specific criteria and procedures not included in the RAP are developed by the DOE contractor performing the remedial action at the site. Those procedures are designed to control, verify, and document all remedial action at the site and are referred to collectively as the Remedial Action Inspection Plan (RAIP). The RAP and RAIP are the primary commitments and standards used as a basis for the NRC reviews of the remedial action work. | ||
| 05.02 | The basis and criteria for reviews for a particular site will be the RAP, the construction specifications provided in the RAP, and the associated RAIP. Guidance for conducting the reviews shall be incorporated into the procedures appended to this Chapter (Appendix A). | |
| 05.03 | The lead reviewer shall develop and prepare an On-Site Construction Review Plan (OCRP). See Appendix B for an example. The OCRP will be approved by the other review team members and the lead reviewer's immediate supervisor before the review. The extent and detail of the OCRP will vary with the type, length, and complexity of the review. Most review requirements are covered by the procedures stated in this Inspection Manual Chapter. | |
| 05.04 | The foundation for planning and scheduling reviews will be the DOE schedule for the site and the DOE contractor's construction schedule for the remedial action work. | |
| 05.05 | Because of the need for close coordination with the construction activities, routine reviews will normally be performed on an announced basis rather than unannounced, as is the present NRC policy for inspection of its licensees. The NRC shall provide notification to the DOE UMTRA Project Office at least five days in advance for any routine review to enable a DOE representative to be present. | |
| 05.06 | As appropriate, the review effort will be weighted toward direct observation of work activities. Written and photographic records will be reviewed as necessary. The review process shall include photographic recording of critical work phases, processes, or milestones, as necessary for the record. | |
| 05.07 | To the extent practicable, review of remedial action at a site should be performed by individuals who have not been directly involved in the review. It is recognized, however, due to staffing levels, that some of the review team members will be cognizant of the site-specific aspects of the RAP. | |
| 05.08 | Results of each review shall be conveyed to the DOE management representative(s) at a closeout meeting (exit interview) immediately following the review. Attendance at the closeout meeting by DOE contractors should be at the discretion of DOE. | |
| 05.09 | The closeout meeting (exit interview) participants will include the most senior DOE participant present. During the closeout meeting, the DOE representative should be made aware of the preliminary findings, including any apparent items of noncompliance with the RAP. In accordance with Manual Chapter 1007, the reviewers also will address safety concerns in the area of Occupational Safety and Health Administration (OSHA) responsibility. The reviewers will inform DOE representatives and notify the NRC Regional Office OSHA Liaison Officer, of non-radiological hazards brought to their attention by site personnel or observed during the review. OSHA decisions will not be made by NRC personnel. | |
| 05.10 | Resolution or schedules for commitments to resolve NRC concerns should be requested from DOE within 30 days of the review report date. | |
| 05.11 | The basic procedures for the review program are appended to this Chapter. | |
| 05.12 | In general, the review program at each site should be scheduled, such that the following construction milestones are observed, as appropriate: | |
| a. | During the early stages of remedial action, depending on site-specific design aspects, review of foundation preparation, placement of capillary break, liner, or tailings/contaminated material should be performed; | |
| b. | During construction of the radon barrier and frost protection soil cover; | |
| c. | During placement of erosion protection (rock cover); and | |
| d. | At or near the completion of remedial action (closeout review). | |
Multiple construction activities should be reviewed simultaneously when the schedule permits; however, at least one review during the construction year should be conducted, if construction activities are occurring. Additional reviews should be performed when warranted, if project-specific design/construction phases include critical work phases or features not identified above. Examples of project-specific design/construction activities may include, but not be limited to, aggregate production, bentonite amendments for radon covers, slurry wall construction, ground modification, and monitoring well activities. The NRC closeout review will be conducted independently of DOE's final inspection. However, the final NRC review and DOE inspection may be conducted concurrently. In accordance with procedures in the UMTRA Project Operations Manual, Section 9.2.10, DOE will notify the NRC staff of the schedule for closeout reviews.
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Appendices:
| Appendix A | Uranium Mill Tailings Remedial Action Project On-Site Construction Review Procedures |
| Appendix B | On-Site Construction Review Plan (Example) |
| Appendix C | On-Site Construction Review Report (Example) |
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