IAEASAFETYREPORTSSERIES

Decision Making Process for Remediation Activities

SAFETY REPORT

INTERNATIONAL ATOMIC ENERGY AGENCY

Draft Safety Report DD 792February 2009

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STI/PUB/????

SAFETY REPORTS SERIES No. XX

DECISION MAKING PROCESS FOR REMEDIATION ACTIVITIES

INTERNATIONAL ATOMIC ENERGY AGENCY

VIENNA, 20XX

VIC Library Cataloguing in Publication Data

Decision Making Process for Remediation Activities International Atomic Energy Agency, ????.p. ; 24 cm. — (Safety report series, ISSN ?????????? ; no. ????????)STI/PUB/?????ISBN ???????????Includes bibliographical references.1. ????????????????? I. International Atomic Energy Agency. II. Series.

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FOREWORD

During the planning for remediation many options may have to be considered when

formulating the appropriate procedure. The optimization of the selected procedure requires

that a considerable range of factors be evaluated in making this final selection of appropriate

remediation activities. Many of the factors that need to be considered in planning remediation

activities are discussed in a wide range of applicable guidance documents published by the

Agency, This safety report not only integrates these factors in a single location but also

provides a methodology for decision making.

The factors to be considered include:

Human safety;

Regulatory framework ;

Stakeholder values;

Environmental impacts;

Costs;

Land Use;

Technology;

Best practice; and

Resources.

This Safety Report has been developed through a series of consultancies. The IAEA

wishes to express its gratitude to all who participated in its drafting and review. The technical

officers responsible for the preparation of this report were P.W.Waggitt and R. Edge of the

Division of Radiation, Transport and Waste Safety.

EDITORIAL NOTE

CONTENTS

1. 1. INTRODUCTION...............................................................................................11.1. Objective......................................................................................................................11.2. Scope............................................................................................................................1

2. RADIOACTIVE WASTE PRODUCING ACTIVITIES........................................2

3. DECISION MAKING PROCESS...........................................................................4

4. REMEDIATION OBJECTIVES...........................................................................114.1. Site characterization...................................................................................................124.2. Sustainability.............................................................................................................14

4.2.1. Environmental Issues.....................................................................................154.2.2. Social Issues...................................................................................................154.2.3. Economic Issues.............................................................................................164.2.4. Governance.....................................................................................................16

4.3. Stakeholders...............................................................................................................164.4. Land use.....................................................................................................................214.5. Legislation & regulations..........................................................................................224.6. External codes & guidelines......................................................................................224.7. Corporate policies......................................................................................................22

5. REMEDIATION CRITERIA................................................................................23

6. REMEDIATION OPTIONS..................................................................................256.1. Quality Control/Quality Assurance...........................................................................26

7. TECHNOLOGY SELECTION..............................................................................287.1. Financial Resources...................................................................................................307.2. Physical Resources....................................................................................................317.3. Socio-Economic Considerations................................................................................31

8. IMPLEMENTATION AND MONITORING.......................................................33

9. CASE STUDIES....................................................................................................34

10. CONTRIBUTORS TO DRAFTING AND REVIEW...........................................35

APPENDIX I. RISK ASSESSMENT TOOLS..................................................................36

APPENDIX II.-DECISION MAKING CASE STUDY: REMEDIATION OF LAND IMPACTED BY HISTORICAL URANIUM EXPLORATION, MINING & PROCESSING ACTIVITIES IN THE SOUTH ALLIGATOR VALLEY - KAKADU NATIONAL PARK – AUSTRALIA.................................................................................38

APPENDIX III DECISION MAKING CASE STUDY U.S. DEPARTMENT OF ENERGY URANIUM MILL TAILINGS REMEDIAL ACTION PROJECT.................63

1. INTRODUCTION

The remediation of facilities contaminated with radioactive residues as a consequence

of past practices, including those derived from naturally occurring radioactive materials

(NORM), is a major activity internationally. Some of these sites may still be associated with

current practices but many are the legacy of former activities that now require intervention

and remediation to make them safe. In some cases these locations may be considered as

orphans with no clear definition of the owner who is responsible for the safe remediation of

the site. In addition there are some locations where there are both current and legacy issues

present simultaneously.

1.1. OBJECTIVE

The objective of this Safety Report is to provide recommendations on the process of

decision making in the planning of remediation activities for sites. The recommendations of

this document applies equally to the planning of remediation for operating facilities and

legacy sites.

1.2. SCOPE

This document begins at the point where a decision to initiate remediation activities

has been made.

This Safety Report describes protocols, strategies, management procedures and

systems that may be used in the planning of remediation of facilities contaminated with

radioactive residues. The intention is to improve protection for the public and the environment

from any adverse impacts, now and into the future, which may arise as a consequence of

exposure to ionising radiation emanating from such radioactive residues.

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It must be remembered that, in addition to radiological contaminants, the residues may

contain other substances that are potentially hazardous to human and environmental health.

Whilst the detailed identification and assessment of such materials and the attendant risks is

outside the scope of this Safety Report the need to include such studies in the overall safety

assessment of the residues must not be overlooked during the planning for remediation.

2. RADIOACTIVE WASTE PRODUCING ACTIVITIES

While its basic structure may be applicable to other types of radioactive waste as well,

the decision making process outlined in this safety report is focussing on remedial activities

concerning bulk industrial waste containing naturally occurring radionuclides at activity

concentrations which require regulatory control. More specifically this report concentrates on

the remediation of waste material that contains the naturally occurring radionuclides uranium-

235, uranium-238, thorium-232 and their radioactive decay products1. Material which meets

this description is also known as NORM. The term NORM is an acronym for naturally

occurring radioactive material. The IAEA’s definition of NORM [1] reads:

Material containing no significant amounts of radionuclides other than naturally

occurring radionuclides. The exact definition of ‘significant amounts’ would be a

regulatory decision. Materials in which the activity concentrations of the naturally

occurring radionuclides have been changed by human made processes are

included.

From a radiological point of view a situation that necessitates remedial action may

arise when the activity concentrations in the waste are significantly higher than in normal

rocks or soil. This will be normally the case for material that is contaminated as a

consequence of an activity subject to regulatory control. For the assessment of other situations

graded activity concentration levels may be used as a guideline for justification and

optimization of possible remedial action activities. Based on the principles of the

International Basic Safety Standards [2] and considering the upper end of the worldwide

1 Waste containing other naturally occurring primordial radionuclides (e.g. rubidium-87, lanthan-138, samarium-147, luthetium-176) or tritium and carbon-14 which are perpetually generated the natural activation processes is not considered.

3

distribution of activity concentrations in soil as provided by UNSCEAR [3] the IAEA Safety

Guide Application of the concepts of exclusion, exemption and clearance proposes an activity

concentration of 1 Bq/g for naturally occurring radionuclides (except potassium-40 where it is

10Bq/g) below which human activities involving the material may usually be considered

exempt from regulatory control(see Table 1 in Ref. [4]). For human activities involving

material exceeding this activity concentration level up to ten times the regulatory body may or

may not decide on case by case basis to exercise regulatory control (see para. 5.12 in Ref.

[Error: Reference source not found]). At higher activity concentration levels it is likely that

some form of regulatory control does apply. A more detailed description of the application of

the graded approach to regulation can be found in Ref. [5], para. 2.3.

Waste containing naturally occurring radionuclides which most likely may require

regulatory consideration may be generated by the following industrial activities (see chapter 3

in Ref. [Error: Reference source not found] :

1. Uranium and thorium mining and processing

2. Extraction of rare earth elements;

3. Production and use of thorium and its compounds;

4. Production of niobium and ferro-niobium;

5. Mining of ores other than uranium ore;

6. Production of oil and gas;

7. Manufacture of titanium dioxide pigments;

8. The phosphate industry;

9. The zircon and zirconia industries;

10. Production of tin, copper, aluminium, zinc, lead, and iron and steel;

11. Combustion of coal;

4

12. Water treatment

For a detailed description of the industry sectors 2-12 mentioned in the above list see

chapter 3 in Ref. [Error: Reference source not found], for the uranium/thorium mining and

processing industries see Ref. [6].

5

3. DECISION MAKING PROCESS

Ideally, the primary objective of remediation, whether in an ongoing activity or in

dealing with consequences of past practices or accidents, is to mitigate radiation exposure

pathways for human receptors [?]. It should be noted that the potential for adverse impacts,

both social and environmental will often extend beyond those associated purely with

radiation. These objectives can often be met by either a combination of or a number of

alternative technical and management measures.

The ultimate goal of remediation is unrestricted release of a site or territory. However,

particular circumstances and considerations such as the remediation option selected,

budgetary constraints or the disturbance of valuable habitats, may require controls ranging

from limited/constrained land use to complete prohibition of access. Such restrictions can be

temporary, as may be expedient in the case of contamination with short-lived nuclides, or

long-term, as for uranium mill tailings impoundments.

To be effective a formalised decision making technique must fulfil the following basic

criteria:

be consistent with the rules of logic;

be transparent;

take account of the views of all stakeholders;

take account of all factors affecting the decision making process;

give balanced consideration to all possible options for action; and

provide unambiguous advice.

The overall remediation decision making process is illustrated in FIG. 1; it involves

the following main activities:

definition of remediation objectives;

definition of remediation criteria;

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identification of remediation options and resources and their optimization;

selection of technologies;

implementation of the remediation plan; and

monitoring/post-remediation management.

7

FIG. 1: Decision Making Process Flowchart.

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Site specific circumstances will dictate the degree of detail and complexity of the

activities undertaken in each step in the process. An iterative approach based on the potential

risks should be used in this process.

For all the options identified, a study should be undertaken to determine the most

appropriate option for the area and the highest net benefit. The study should initially provide

for sound justification and then provide optimization strategy which should consider the

following:

estimated doses to workers and the public due to exposure before, during and after

remediation;

overall safety issues during remediation;

various technologies available;

estimates of costs and other resources associated with implementing each option;

post-remediation monitoring and sampling requirements;

quantity and disposal options for the waste that will be generated; and

institutional controls required after implementation of the option, if applicable.

On the basis of this optimization study, a preferred option should be selected that also

takes into account non-quantitative considerations such as social and political aspects.

As a tool for the selection of appropriate and sustainable remediation measures at

reasonable costs, risk based cost-benefit analyses are used. There are various techniques to

conduct cost-benefit analyses.

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All decisions and activities must be checked for conformance with remediation objectives

Undertaking a formal risk analysis is a fundamental component of the decision making

process for remediation of facilities and sites. There are a number of formal risk assessment

tools that can assist decision makers to evaluate the risks and benefits of the range of

remediation options being considered.

Risk is the probability of an adverse effect occurring as the result of an activity or an

event.

A risk assessment considers the combination of:

the likelihood of an event occurring;

the consequence of that event; and

the management measures required to reduce the residual risk (likelihood, severity

and/or consequence) to an acceptable level.

The probability addresses the likelihood of the event occurring, while the adverse

effect is the undesired effect or outcome causing concern (e.g., reduced reproduction in fish,

or toxic effects to the liver or nervous system). The primary objective of risk management is

to provide sufficient information to allow decision makers the ability to do the following:

achieve acceptable levels of risk, where benefits flowing from a particular action or

decision outweigh the potential loss or damage; and,

avoid unacceptable levels of risks, where the likelihood and magnitude of the potential

loss or damage outweighs the expected benefits, or where the magnitude of the potential

loss or damage, regardless of likelihood, is such that it cannot be reversed or mitigated

(Macfarlane 2002).

Risk assessment can be used to determine the existing level of risk to the social,

environmental and economic aspects of a project. Risk assessment can also be used to

evaluate the relative risk reduction achieved by various risk management options and the

residual risk after management options are applied. Risk assessment is site or project specific.

10

Screening level risk assessment can identify areas of critical uncertainty through the

use of sensitivity analysis (i.e., the assumptions, variables and parameters that "drive" the risk

estimate are identified). Additional data collection may then be required to fill in identified

critical data gaps, in particular for issues that may carry higher risk.

There are three possible outcomes of the screening level risk assessment:

all potential risks are ruled out;

some potential risks are identified, but risk management decisions are made on the

basis of the screening level risk assessment and no further risk assessment is required;

or

some potential risks are identified, but risk management decisions are too uncertain

and further risk assessment is required.

A screening level risk assessment may show that remediation plans will reduce all

potential risks to levels deemed acceptable, if not then there will be a need to proceed to

detailed risk assessment for the identified unacceptable residual risks.

Formal risk assessment processes usually require the following actions:

Identify and involve stakeholders;

Establish the context;

Analyse the hazard;

Analyse the risk;

Evaluate the risk and determine acceptability;

Decide to accept or mitigate the risk;

Monitor controls and outcomes; and

Develop Contingency Plans.

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Risk assessment and management is an iterative process consisting of a series of well-

defined steps, taken in sequence, to support decision-making by contributing to an insight into

the risks and their impacts.

Many jurisdictions will have formalised risk assessment tools available through their

local standards organizations and these may be suitable tools to use for the risk assessment

process. An example of a risk assessment tool available from a national standards

organization is Standards Australia AS/NZS 4360:2004. This standard provides a generic

framework for establishing the context, identification, analysis, treatment and monitoring of

risk. As an alternative there are also many other risk analysis tools available, examples of

which include; the Failure Modes and Effects Analysis (FMEA) (Robertson and Shaw, 2003

[7]), Multiple Accounts Analysis (MAA) [Robertson and Shaw, 2003], Sandia Environmental

Decision Support System (SEDSS) (Sandia 2001, [8]), HIVIEW™ [hiview, 2001] and Expert

Choice™ [EC Inc., 2001] . More details regarding these tools can be found in Appendix 1.

Formal tools are not an end in themselves. The methods and degrees of complexity of

formalised decision making processes must be proportional to the issue being considered.

The outcomes from risk analyses should then be subject to sensitivity analyses in

order to test their robustness in the face of variable inputs. In conjunction with risk analyses,

sensitivity analyses are also powerful instruments to guide the decision making process and

can help to evaluate the impact numerical values of variables have on the outcome of such a

process. Sensitivity analyses will help to distinguish between the importance of crucial

variables.

Sensitivity analysis is used to examine how robust an alternative is to changes in the

information or assumptions used in the original analysis. Sometimes the original information

or data set may be limited or not precise in nature. Additionally, the misuse or selection of

parts of a data set can lead to the manipulation of the final solution. The application of

sensitivity analysis can help to show in a more transparent nature, how varying certain

parameters can affect the outcome of a decision making process.

A variant of this are critical path analyses, which serve to identify those criteria that

have to be met in order that the overall process can proceed. The result is a ranking or

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weighting structure identifying the relative importance of decisions. Applying Monte-Carlo

simulation techniques to the input variables can also give valuable information on the possible

outcomes of complex decision making processes and/or the performance of the environmental

remediation project under investigation.

The use of risk assessment and sensitivity analyses are fundamental components of the

application of best practice principles to the decision making process for the development and

implementation of remediation projects.

Principle 10 of the Rio 1992 UNCED Declaration affirms "environmental issues are

best handled with the participation of all concerned citizens, at the relevant level". This is

where formal decision aiding tools can be useful, to organize and evaluate information

regarding uncertainties and conflicts inherent in the decision making process, and to

communicate the options to decision makers and the interested public.

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4. REMEDIATION OBJECTIVES

Remediation objectives are the overall guiding principals that every activity must be

checked against. Without clearly defined overarching remediation objectives none of the

subsequent stages of the remediation process can be developed with accuracy or certainty.

Only once the required outcomes (such as future land use) are known can remediation criteria

and remediation technologies be developed or selected to meet these objectives. Decisions

regarding the form of post-remediation control mechanisms, i.e.; institutional control, should

be made at this time and incorporated into the remediation objectives. Figure 1 illustrates the

various inputs into the process of developing remediation objectives, they are;

Characterization;

Sustainability;

Stakeholder expectations;

Final (post-remediation) land use for the site;

Stakeholder expectations;

Legislation and regulations;

Codes of practice and guidelines; and

Corporate policies.

In order to develop appropriate remediation objectives for a remediation program the

decision making process should incorporate input from all of these sources. There may also

be conflicting requirements or expectations from each of these sources, for example, where

stakeholder expectations for a post remediation land-use cannot be fulfilled due to legislative

restrictions arising from residual contamination levels.

Without clearly defined overarching remediation objectives decisions regarding the

subsequent stages of the remediation process cannot be made with confidence. It is only once

the required outcome is defined that development of the strategies and selection of the

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technologies necessary to meet these outcomes can commence. The following critical

components are essential for defining the remediation objectives and facilitate the remediation

decision making process.

Setting clear agreed objectives for remediation strategies is the critical task to ensuring

acceptable and enduring outcomes are achieved during the remediation process. Failure of

remediation programs can often be traced back to the failure to undertake a rigorous program

to develop and define clear and appropriate remediation objectives at the outset.

Remediation objectives will reflect the overall values that the operator, stakeholders,

regulators and general community place on the physical and social environment in which the

operation is located and as such they will typically have a location or regional specific basis.

4.1. SITE CHARACTERIZATION

Accurate and comprehensive characterization data will make it possible to reliably

demonstrate that the environmental and social impacts of a site are understood and that the

proposed remediation works will provide the required outcomes.

Site characterization is needed to provide sufficient data to allow for good engineering

design of environmental remediation activities and cost-effective/reasonable use of resources.

It typically involves an assessment of historical data (baseline) of the area followed by the

collection of additional information if required. Historical data may be collected from

operational records or governmental files and from interviews with present and former

employees. In the case of more modern operations baseline physical and social data would

have been collected as a component of the environmental approval process. The results of the

historical data assessment will help to delineate the scope of the problem and will identify the

type, quality and quantity of additional information necessary to make a definitive decision on

the extent of the remediation required.

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For physical characterization data the following items may be required:

Nature and spatial distribution of possible radiological and non-radiological

contamination such as heavy metals, arsenic, acid generating minerals and toxic

organics;

chemical and physical characteristics of the contaminants;

related past activities that occurred on the site;

geological and hydrogeological characteristics, type of soils;

location of buildings, buried material, physical barriers;

likelihood of migration of contaminants;

transport of radioactive constituents in groundwater and hydraulically connected

surface water;

site ownership;

cadastre survey;

geography;

meteorology/climate; and

flora and fauna.

An important part of the site characterization is the documentation and assessment of

human activities on or near the area to identify individuals who may potentially be exposed to

radiation or chemical contamination through different pathways. In addition, characterization

of any waste stream may be necessary if transport and disposal options for waste are

considered.

Examples of data collected during socio-economic characterization include, but are

not limited to those outlined below, it must be noted that the data sets required will be site

specific as is the timeframe over which they are collected. .

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Socio-economic characterization;

Current and historic land uses;

Archaeological and heritage surveys;

Identification of all stakeholders;

Identification of beneficial uses of land and water; and

Documentation of regulatory regime for project operation

Data from site characterization is also needed to feed into mathematical models used

to estimate/predict/describe the likely results of different remediation alternatives. Therefore,

the potentially more expensive the remediation, the more characterization it is worth

performing in order to allow the optimization of the remediation options.

4.2. SUSTAINABILITY

Sustainability is also a significant factor in decision making and must be considered as

another filter when making decisions regarding remediation objectives. The Brundtland

Report states that "humanity has the ability to make development sustainable-to ensure that it

meets the needs of the present without compromising the ability of future generations to meet

their own needs.”

Sustainability in the context of this document balances four main aspects:

environment;

social issues;

economics; and

governance.

A sustainable decision is one that balances the environmental, social and economic

requirements within a regime of good governance. Concentration on only one aspect is certain 17

to conflict with the others. However, the balance of the emphasis on each particular aspect

will vary with the specific remediation program and the physical and social environment it is

being undertaken within. Good corporate and regulatory governance will have in place the

structures to permit the appropriate balance to be achieved.

4.2.1. Environmental Issues

The environmental aspects of sustainability must:

promote responsible stewardship of natural resources and the environment, including

remediation of past damage;

minimize waste and environmental damage throughout the whole supply chain;

exercise prudence where impacts are unknown or uncertain; and,

operate within ecological limits and protect critical natural capital.

4.2.2. Social Issues

The social aspects of sustainability must:

ensure a fair distribution of the costs and benefits of development for all those alive

today;

respect and reinforce the fundamental rights of human beings, including civil and

political liberties, cultural autonomy, social and economic freedoms, and personal

security;

seek to sustain improvements over time, by ensuring that depletion of natural

resources will not deprive future generations, through replacement with other forms

of capital; and,

optimize utilization of human resources by developing competencies, training and

knowledge exchanges.

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4.2.3. Economic Issues

The economic aspects of sustainability must:

maximize human well-being;

ensure efficient use of all resources, natural and otherwise, by maximizing returns;

seek to identify and internalize environmental and social costs; and,

maintain and enhance the conditions for viable enterprise.

4.2.4. Governance

The governance aspects of sustainability must:

ensure transparency by providing all stakeholders with access to relevant and accurate

information;

ensure accountability for decisions and actions, which are based on comprehensive

and reliable analysis;

ensure appropriate resources (financial, physical, regulatory, etc.) exists to maintain

the end state of the site after remediation,

encourage co-operation in order to build trust and shared goals and values; and,

ensure that decisions are made at the appropriate level, as close as possible to and with

the people and communities most directly affected.

4.3. STAKEHOLDERS

A critical component in remediation planning is the inclusion of stakeholders in the

decision making process. Without stakeholder involvement there is a significant risk that the

remediation program, or components of it, may be rejected by the stakeholders, with a

consequent economic loss to the operator as well as generating ill feelings between the parties

that may develop to an adversarial relationship. Stakeholders need to be identified and fully

19

integrated into the remediation planning process as early as possible in the decision making

phase.

Stakeholders are those individuals or organizations which may have an interest in or

be affected by the operation at any stage whether directly or indirectly. Examples of groups or

individuals that may be considered stakeholders include, but are not restricted to:

Project operator;

Shareholders;

Owners of the land impacted by the operation;

Surrounding landowners and local communities;

Local communities economically dependent on the operation or the land impacted;

Local government;

Regulators;

Employees;

Unions;

Non-Government Organizations (NGO's);

Contractors; and

Suppliers.

20

FIG. 2: Consultation group…….

21

This list illustrates that the stakeholder group is likely to consist of an extensive group

of individuals, businesses and organizations with vastly different skill sets, technical abilities

and most importantly expectations. Identifying stakeholders and then successfully engaging

them in a participatory manner is a fundamental building block in the development of a

successful remediation program. Each remediation project will have its own unique group of

stakeholders. Bringing these together in order to participate in the decision making process

and achieving an outcome that meets most of their expectations is an enormous task that will

require specialized skills and resource commitments on the part of the remediation planners. It

is also a time-consuming process that needs to be given as much time as possible, if

satisfactory outcomes are to be achieved, hence commencing it as early as possible in the

remediation planning phase is highly desirable.

Stakeholder consultation assists in identifying issues of significance and focuses the

social component of the decision making process. This consultation is an essential tool in

gaining support for the selected remediation strategy and technologies through demonstrating

transparent information exchange and the commitment by the proponent and regulators to

address the stakeholders' concerns.

Public and stakeholder consultation processes should commence and be managed in

parallel with the characterization programs and conceptual strategy design stage. This process

is critical to determine issues central to the remediation program and will assist in the

acceptance of a strategy. Recognition and response to stakeholder concerns and expectations

can minimize the potential for conflict and be of mutual benefit to the communities and the

operators

Key points to consider in bringing about constructive stakeholder participation in the

decision making process includes:

Identification of stakeholder groups – must be identified through community

surveys;

Selection of participants - participants are representative of the identified stakeholder

groups and speak with their authority;

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Timing - engagement of stakeholders and their involvement in the process begins as

early as possible;

Establishing objectives for participation in the decision making process early will

assist in ensuring that the activities of those participating are focussed on results;

Commitment to stakeholder involvement - if the stakeholders sense that the

decision makers are not actively listening and acting on their input their involvement

will likely breakdown and may increase mistrust;

External constraints - on the remediation program should be clearly communicated

to stakeholders, examples of these may include financial resources and regulatory

obligations;

Effective communication - clear, honest, and effective communication is a necessity

for a constructive stakeholder program;

Participation - different stakeholders will have differing levels of skills and

resources, to ensure fairness and appropriate representation it may be necessary to

consider allocating additional resources (including information and training) to some

groups or individuals in order that they can participate on an equal footing with other

stakeholders; and

Flexibility - the participation process must remain flexible as it proceeds in order to

allow for input from stakeholders as the process advances.

The above points demonstrate that effective participation needs to be a dynamic two-

way process - simply dictating to the public or informing the public of decisions cannot be

considered stakeholder participation.

In a successful decision making programme, stakeholders will play a significant role

in identifying issues and selecting options (strategies and technologies), this will in turn

generate broad based support and ownership of strategies ultimately selected.

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Where there has been inadequate engagement or consultation with stakeholders in the

decision making process, or where there has been a failure to identify all legitimate

stakeholders, the following can result:

delays or cancellation of the implementation phase;

lack of public support in the implementation phase;

loss of public trust, which may lead to difficulty in implementing future initiatives;

media criticism;

legal action; and

social conflict and violence.

FIG. 3: Malii- Suu no.2.

Effective stakeholder participation in the decision making process can be assisted by

implementing communications and education programs. This will ensure that the participants

have sufficient understanding of the issues with which to base informed decisions.

Once the overall remediation objectives have been defined and the site fully

characterized the decision making process can move on to developing appropriate site-

24

specific remediation criteria and methods of measuring (monitoring) that these are being met

and the remediation strategies are performing as planned.

4.4. LAND USE

Remediation strategies ought not to cause an ongoing liability or risk to accrue to

landowners and/or stakeholders. Careful planning is needed to ensure that remediation

strategies, to the maximum extent practicable, are maintenance free and minimize

requirements for ongoing management or intervention, and where appropriate incorporate

traditional human activities.

4.5. LEGISLATION & REGULATIONS

The selected remediation objectives must as a minimum be compliant with current

legislation and regulations, and should anticipate changes in legislation and community

expectations over the life of the project.

4.6. EXTERNAL CODES & GUIDELINES

Remediation design and implementation should take into consideration national

and international codes and guidelines promulgated by professional organizations.

4.7. CORPORATE POLICIES

The selected remediation objectives must as a minimum be compliant with all Codes

of Practice that the operator is signatory to and comply with any internal corporate policies

and procedures.

25

5. REMEDIATION CRITERIA

Once the remediation objectives have been decided, a set of remediation criteria has to

be developed to target remediation activities, to assess performance as the work proceeds, and

to verify that the remediation objectives have been achieved at its conclusion. The criteria

may include but not be limited to

radiological/radiation protection criteria (maximum dose rate, residual concentration

levels);

regulatory compliance criteria;

emission criteria (concentration limits, action levels);

geomechanical criteria (slope stability, seismic criteria);

geotechnical criteria (thickness of cover layers, soil compaction rate, erosion

protection);

geochemical criteria (precipitation/solution reactions);

Groundwater criteria (geohydrology, hydrochemical and hydraulic criteria (flow rates,

hydraulic capacity of pipes, drain etc);

technical performance criteria (infiltration/exhalation rates, erosion rates);

social criteria (local employment, local purchasing, visual criteria );

cost criteria (unit costs, overall investment/construction costs); and

scheduling criteria (project start/end, critical path).

Where applicable, specific remediation criteria can be set by either using a

deterministic or a risk based approach. In the first case fixed standards/parameters are being

applied whereas in the second case criteria are being based on a quantitative

26

evaluation/calculation of the risks of site specific impacts on health and environment. The

approach taken depends on the prescribed member states regulations.

27

6. REMEDIATION OPTIONS

The main objectives of residue management and remedial activities should be to

protect the environment and the public by preventing dispersal of radionuclides, either

through water or as gaseous or dust emissions [9]. Shielding against direct irradiation may

also be required. Owing to their physical properties as loose materials and because they are

apparently 'free', many mining and milling residues may be attractive local sources of building

material. Unauthorized reuse of such residues has been observed in both developing and

developed countries. Thus, effective passive institutional control to prevent or discourage

access to and use of the NORM containing materials may be an important objective of

remediation measures.

The decision on the intended remedial action has to consider three basic options:

1. Leave the site undisturbed.

2. Contain or restrict the mobility of the radioactive contaminants.

3. Remove the radioactive contaminants from the site.

The first option relies on natural processes to prevent significant exposure or

spreading of contaminants (in the groundwater). Natural remediation is the 'zero intervention'

option. It needs monitoring for determining the evolution of the site so that an alternative

option can be initiated if required. Before recommending a large-scale application of any

rehabilitation technique, it is essential to forecast the radiological situation in the absence of

intervention

The second option aims to immobilize the contaminants inside the area where they

already exist, reducing the potential for further migration or entry onto active pathways for

exposure.

The third option involves extraction, concentration and safe disposal of the

contaminants at a dedicated disposal facility.

28

Options two and three require engineered facilities to contain contaminants and reduce

exposures, either on-site or at the chosen disposal facility. Like option (1) they need long term

monitoring, and in addition periodic performance assessment and maintenance.

Within each option category there may be more than one feasible technical solution to

the problem at hand.

The factors influencing the decision making process at this point are:

Investment costs for constructing containment or disposal facilities;

Long-term cost for operating, maintaining and monitoring ;

Long-term stability of engineered facilities;

Regulatory acceptance; and

Community acceptance.

To decide on the optimum solution all five factors have to be assessed undertaking a

comparative risk and benefit analysis, with the natural remediation option as the reference

base case to evaluate the other options against. After consultation with the interested parties,

qualitative non-quantifiable concerns need to be combined with the results of the cost/benefit

analysis to determine a true optimum solution.

6.1. Quality Control/Quality Assurance

Once the desired remediation option has been selected and agreed to by stakeholders

the planning process then moves to the detailed design and implementation phase. A very

important and often overlooked component of the implementation phase is quality

control/quality assurance. It doesn't matter how well designed the strategy is; if it is not

constructed as designed there is a high likelihood that it will suffer premature failure or sub-

design performance with consequent potential safety impacts amongst others.

Formal quality control (QC) procedures and quality assurance (QA) measures are

essential management tools in any public or private expenditure project. QA/QC measures

29

should be all encompassing to extend beyond just the implementation phase and include post

implementation performance monitoring and compliance monitoring programmes as integral

components.

30

7. TECHNOLOGY SELECTION

Once the best suited remediation option has been decided a remediation technology

has to be selected, which besides taking into account the site characteristics and the agreed

remediation objectives has as major factors to consider the:

Availability of financial resources

Availability and possible application of technical equipment

Socio-economic aspects

The impact these three factors will have on the selection of a remediation technology

will be project specific. In one situation it may be preferable to stretch out remediation work

for the sake of prolonging employment (scenario A in Figure 4) and in others this limitation

may not apply. In another remediation project the availability of financial and human

resources may strongly influence the decision (scenario B in Figure 4). Lastly, in specific

circumstances the availability of technical equipment may have a bearing on the choice of the

appropriate technology (Scenario C in Figure 4).

FIG. 4. Emphasis of financial, social and technical factors on technology selection.31

Examples of the range of technologies that can be utilized is provided in Figure 5.

To balance the different influencing factors the selection of a technology therefore

usually becomes an iterative process which is illustrated in FIG. 5figure 5.

FIG. 5. Technology selection flowchart.

32

7.1. Financial Resources

The operator of a waste management facility has the obligation to provide sufficient

funding for remediation. This obligation is recognized in the Joint Convention of the Safety of

Spent Fuel Management and on the Safety of Radioactive Waste Management [9], which

states in Article 22 (ii): "Each Contracting Party shall take the appropriate steps to ensure that

adequate financial resources are available to support the safety of facilities for spent fuel and

radioactive waste management during their operating lifetime and for decommissioning”.

Resources available for remediation are usually limited both in terms of the total funds

available and with respect to the time over which they can be spent. The amount of funds

available at any one time (cash flow) might well limit the choice of remediation option. For

example, an option involving a high investment over a short period of time; as opposed to an

option involving moderate expenditure of a longer period (figure 6), both options incurring

the same total project cost.

FIG. 6. Cash flow options and resource availability.

The second option may be more in line with the availability of cash and physical

resources, but in addition to the project costs may incur additional costs from spreading out

the task. These will typically include interest on loans, rental fees and higher depreciation for

equipment, and maintenance costs for the necessary infrastructure. This indicates that a full

economic cost assessment and accounting is an essential element of the decision making

process. Anticipated proceeds from the disposal of land, infrastructure or any other assets 33

should not be used to offset the provision made for the cost of closure. These are separate

issues and should be treated as such.

7.2. Physical Resources

As demonstrated in FIG. 5figure 5, the choice of the appropriate technology may also

be influenced by the availability of resources which in this case encompasses the availability

of human resources, material and equipmen .

7.3. SOCIO-ECONOMIC CONSIDERATIONS

The choice of remediation technologies may be tailored to the economic needs of a

region or the respective resources available. For example, the net economic benefit for a

region might be improved by choosing a less sophisticated technique, but involving more

local labour and other local resources. Or, in former industrial areas, drawing out a project

over a longer time-scale, thus keeping local staff employed for a longer period of time might

be more economical rather than earlier completion, followed by paying unemployment

benefits. Working out such trade-offs requires the cooperation of all stakeholders involved.

In conclusion, as illustrated in FIG. 7figure 7, the selection of the appropriate

remediation technology ideally will maximise the benefit for the lowest possible cost, whilst

still achieving the agreed remediation objectives.

FIG. 7. Scope for decision.

34

FIG. 8.

35

8. IMPLEMENTATION AND MONITORING

During implementation the remediation work has to be monitored and surveyed to

make sure that the remediation criteria are being met. Failure to meet the criteria can have two

reasons: either the work is not executed according to specification or fundamental design

flaws become apparent during implementation. In the first case measures have to be take ton

improve the existing technology. In the second case a decision may have to be taken to

change the technology itself.

Monitoring to show/demonstrate the effectiveness of the remediation measures and to

arrive at a decision whether the remediation objectives have been met or whether corrective

action has to be taken will vary in comprehensiveness and duration.

After completion, monitoring of the remediated site will be maintained to ensure that

the results continue to be in compliance with regulatory requirements. For that purpose a

monitoring and surveillance plan is required which is subject to periodical review and may

need approval by the regulatory body. Generally the monitoring and surveillance process will

carry on for a considerable length of time before this decision can be made. Time frames of

several decades are common. Therefore the proponent has set up appropriate organizational

structures and has to be prepared to provide adequate funding.

9. CASE STUDIESTwo case studies from Australia and the USA are provided in Appendix 2 and 3.

36

10. CONTRIBUTORS TO DRAFTING AND REVIEW

Becker, J. Consultant, Germany

Fawcett, M.N.R Consultant, Australia

Reisenweaver, D. International Atomic Energy Agency

Waggitt, P. International Atomic Energy Agency

Edge, R. International Atomic Energy Agency

Tillman, J.B. International Atomic Energy Agency

Guy, M.S.C. International Atomic Energy Agency

37

APPENDIX I. RISK ASSESSMENT TOOLS

There are a number of formal risk assessment tools available to assist in the decision

making process, this appendix provides some details on some of the packages available.

MAA is a tool for evaluating different options or alternatives for a project, or specific

components of a project by weighing the relative benefits and costs (or losses) of a variety of

unrelated factors. It is particularly useful when there are a large number of multi-disciplinary

or variable factors and stakeholders involved.

The MAA method of selecting the best alternative involves three basic steps:

Identify the impacts (benefits and costs) to be included in the evaluation;

Quantify the impacts (benefits and costs); and

Assess the combined or accumulated impacts for each alternative, and compare these

with other alternatives to develop a preference list (ranking, scaling and weighting) of

the alternatives.

More details on MAA can be found at this link:

http://www.robertsongeoconsultants.com/rgc_enviromine/Issues/cls_MAA.asp\

Software packages, like SEDSS, or HIVIEW™, allow the user to change physical

values or amend weighting factors in real time, which is especially useful for presentational

purposes. Such software can offer, for instance, the following features:

Value tree visually created and edited. Up to 15 options, 50 criteria per branch,

with unlimited branch layers;

Each node graphically displays the weighted scores for each criteria; bottom

up or top down calculation of weights. Option normalization of weights within

mode;

Map to show the efficiency frontier;

38

Sensitivity analysis to test robustness; and

Construction of options by importance of the weighted criteria.

More details on SEDSS can be found here:

http://www.sandia.gov/Subsurface/factshts/ert/sedss.pdf

More details on HIVIEW™ can be found here:

http://www.catalyze.co.uk/?id=230

The software package Expert Choice™ [x] on the other hand can offer the user the

following features:

Uses the analytical hierarchy process;

Guides you through the process of entering pair-wise assessments of your

alternatives and criteria;

Includes a rating method to rank large numbers of alternatives; and

Results are displayed graphically or in a detailed summary.

More details on Expert Choice™ can be found here:

http://www.expertchoice.com/products-services/expert-choice-115

39

APPENDIX II.-DECISION MAKING CASE STUDY: REMEDIATION OF LAND IMPACTED BY HISTORICAL URANIUM EXPLORATION, MINING & PROCESSING ACTIVITIES IN THE SOUTH ALLIGATOR VALLEY - KAKADU NATIONAL PARK – AUSTRALIA

II.1 INTRODUCTION

This Case Study follows the development and implementation of a remediation plan

for land impacted by historical uranium exploration, mining and processing operations. The

land affected is owned by traditional Aboriginal owners and is leased back to the Australian

Federal Government for incorporation in the World Heritage listed Kakadu National Park.

The Case Study is structured to reflect and address the headings as set out in decision making

flowchart provided in Figure 1 of this document. However, as it is a government funded and

managed project some of the inputs to the process of setting remediation objectives are not as

applicable as they would be to privately funded projects; for example the input from

Corporate Policies is not applicable in this case

II.2. BACKGROUND

Aboriginal people have lived in the area covered by Kakadu National Park continuously

for at least 50,000 years2. Kakadu National Park is nationally (Australian Register of National

Estate) and internationally (World Heritage List3) recognised for its cultural and natural

values and is classified as a category II area under the World Conservation Union (IUCN)

classification scheme of protected areas. The area is of high significance for both its natural

and cultural values.

Mineral exploration activities were conducted in the upper South Alligator River

Valley between 1954 and 1965. From 1955 to 1964 thirteen uranium mines were operated in

the area. Total production from these mines was about 875t U3O8, much of the ore was

processed in the area. There were also several residential areas for miners, and a network of

roads, tracks and airstrips. When mining became uneconomic, the area was simply

abandoned, there being no legal requirements for remediation at that time.

2Kakadu Board of Management and Parks Australia (1998) Kakadu National Park Plan of Management. Jabiru.3World Conservation Monitoring Centre (1998) Descriptions of Natural World Heritage Properties, Kakadu National Park. httpllwww.wcmc.org.uk/protected-areas/data/wh/kakdu.html last (updated 14 December 1998).

40

Between 1990 and 1992 as part of a federally funded hazard reduction programme,

adits, shafts and pits were blocked off or fenced and much of the radiologically contaminated

material and equipment was buried in shallow trenches at four sites in the area.

Since 1996 the upper South Alligator River valley has been owned by the Gunlom

Aboriginal Land Trust (GLT), which has leased it to the Director of National Parks as part of

Kakadu National Park.

Sites needing remediation were categorized based on their level of radiological

contamination. Part A sites have no significant radiological contamination while Part B sites

have significant radiological contamination.

Project planning for remediation of these sites began in 1999, with significant field

investigations commenced in 2000, in 2006 the Australian Federal Government allocated

$7.33m to carry out the remediation works.

41

FIG. II.1.

42

II.3. DEFINING THE REMEDIATION OBJECTIVES

The process of defining remediation objectives began in 1999, when an initial

stakeholders meeting was held to set the scope of the project. Within the scope of this project

the principal inputs into developing the remediation objectives were:

Final land use

Legislation & regulations

Site characterization

External codes & guidelines

Stakeholder expectations

II.4. FINAL LAND USE

After extensive consultations with stakeholders a range of final land uses for the sites

requiring remediation were developed. This range of land uses reflects the diverse nature of

the sites and their locations within both the physical and cultural landscapes.

43

TABLE II.1 - AGREED LAND USE CATEGORIES FOR THE SITES

Category Descriptor Definition

Category 1 Regular use - relatively easy access

Traditional Aboriginal owners and invitees camping (dry-season only), fishing, hunting

Category 2 Intermittent use - easy access Traditional Aboriginal owners and invitees fishing, hunting (dry-season only), no camping. Possible day use for tourists also.

Category 3 Thoroughfare - easy access Sites of which themselves are unlikely to be destinations, but which are close to public access tracks or which may be used as thoroughfares.

Category 4 Rare use - moderately difficult to access

No reason to visit site.

Category 5 Cultural use - restricted access

Culturally sensitive sites, no tourists, no camping, occasional ceremonial use by traditional Aboriginal owners and site custodians.

II.5. LEGISLATION & REGULATIONS

The Director of National Parks as the lessee of the land has a legal obligation to

remediate the land under the conditions of the lease.

Clause 9(z) of the lease agreement between the Director of National Parks and the

Gunlom Aboriginal Land Trust (“the Lessor”) requires that; “in full consultation with the

Lessor, to complete ... a plan of environmental rehabilitation, in respect of the site known

as Guratba (Coronation Hill) and other mine sites and associated workings in the Leased

Area, so as to limit and where possible reverse the impact on the environment of any

mining activities previously carried out thereon.”

Other legislation that impacts on remediation planning for the sites include:

Environment Protection and Biodiversity Conservation Act (EPBC)1999

Australian Radiation Protection and Nuclear Safety Act 1998

44

II.6. SITE CHARACTERIZATION

Various chemical, radiological, physical and biological assessments were undertaken

by specialist consultants and the Supervising Scientist Division (SSD). Initial surveys

provided a general characterization of the sites, with limited sampling. More in depth

investigations were undertaken where required. There were two detailed field investigation

programmes undertaken in 2000 and 2007 as well as a large number (> 20) of site specific

field trips.

Radiological investigations and soil and water quality sampling and analyses were

also undertaken at each of the sites. A vegetation survey of the sites was also undertaken.

Fourteen endemic species were recorded, but none of the recorded plant species are listed

under the EPBC Act 1999, or the NT Threatened Species List (NRETA4)

II.7. EXTERNAL CODES & GUIDELINES

The Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) has

confirmed that, as an intervention, relevant codes of practice such as “Regulatory Guidance

for Radioactive Waste Management Facilities” are not mandatory for this project, but can be

considered as guidelines. The principles set out in such codes have been incorporated to the

extent practicable into the above technical criteria. The only mandatory code is Radiation

Protection Series 1, ‘Recommendations for Limiting Exposure to Ionizing Radiation’

(ARPANSA, 2002).

II.8. STAKEHOLDER EXPECTATIONS

In the context of this project stakeholder expectations were the primary driving factors

in developing the remediation objectives and subsequently the remediation plans.

The main stakeholders in this process were:

traditional Aboriginal owners

4Northern Territory Government - Department of Natural Resources, Environment and the Arts http://www.nt.gov.au/nreta/wildlife/animals/threatened/specieslist.html

45

the Director of National Parks

the Northern Land Council

the Northern Territory Government

In the early stages of the planning process, in 1997, the senior traditional Aboriginal

owner at the time made it clear that a number of cultural issues would have to be taken into

account in developing the remediation plan. In particular he asked that the special cultural

significance of the whole area be acknowledged when decisions were being made on how

work was to proceed.

Formal consultations towards the development of a remediation plan commenced with

a meeting in May 1999. This meeting approved the establishment of a consultative committee

to develop the remediation plan. The consultative committee was initially comprised of

traditional Aboriginal owners and representatives from the attending organizations.

September 1999 marked the initial field trip that was the first of a series of

consultations, field inspections, workshops and formal meetings involving consultative

committee members and other traditional Aboriginal owners. Traditional Owners formally

approved the draft Part A plan in December 2001 and during 2002 the draft was refined with

the addition of cultural background material by the Northern land Council and additional

material relating to proposed works for the Sleisbeck site. The draft Part B plan was

completed in 2008. Consultative meetings have occurred regularly since September 1999 with

the most recent one, at the time of writing, occurring in late 2008. Typically the consultative

meetings have taken place in the field in order to allow discussions to be held on each of the

individual sites when necessary.

II.9. SUSTAINABILITY

During the development of the remediation objectives for this project sustainability

was not considered as an individual issue in itself. However, within the objective

development process the four main aspects of sustainability as defined in this document;

environmental issues, social issues, economic issues and governance, were all

comprehensively addressed.

46

II.10. REMEDIATION OBJECTIVES

The Overall Objective of the Part A and Part B remediation works is:

“To rehabilitate the sites to a condition which is safe, stable and minimizes long term

cultural and environmental impacts and limits on subsequent land uses, and future

liability to stakeholders.

To ensure that following rehabilitation the sites will not require management

substantially different to the management regime applied to other areas in the vicinity

and within Kakadu National Park.”

This Overall Objective was developed through the inputs from Sections 2.1 to 2.6 above.

Following on from the Overall Objective a number of specific remediation objectives

were developed, they are set out in the table below.

TABLE II.2. - SPECIFIC REMEDIATION OBJECTIVES

Compliance Complies with current legislative requirements as a minimum and anticipates future trends in legislation and community expectations where practicable.

Parks Policy Preparation and implementation of closure plans will meet the requirements of Kakadu National Park Board of Management, Parks Australia and the Park Plan of Management.

Cultural Values Recognition of cultural values is paramount.

Heritage While the importance of mining history is recognised, preservation of heritage value will only occur where cultural, public safety and environmental values will not be compromised.

Safety Establishment of reasonable levels of post remediation public safety.

II.11. DEFINING REMEDIATION CRITERIA

A series of remediation guidelines were then developed to address these remediation

47

objectives. These guidelines were applied on a site specific basis to develop the preferred

remediation options for each site.

A summary of the guidelines used in developing the remediation plans are provided

below.

TABLE II.3. - REMEDIATION GUIDELINES

Safety Plug drill holes, backfill and/or cover shafts and adits, and install appropriate fencing and signage as required.

Stakeholder Involvement

Stakeholders will be involved in all stages of the implementation.

Cultural Values Traditional Aboriginal owners’ informed consent will be required before any aspects of the Plan are implemented.

Visual Amenity Consideration will be given to visual amenity during the design phase.

Revegetation Trending towards native woodland

Residual Contamination - soils

Meets criteria listed in Table II.2. and allows reestablishment of native vegetation.

Water Quality Meets criteria listed in Table II.3.

Radiation Meets criteria listed in Table II.4.

Other Hazardous Materials

Asbestos - will be removed and contained in a manner that complies with Northern Territory Work Health Authority Guidelines where practicable.

Rubbish Clean Up Material will either be removed to a designated landfill or contained on site in a safe manner.

Physical and numerical remediation criteria were used for determining beneficial land

use, water and soil quality and radiological conditions, these were bases on appropriate

guidelines.

48

II.12. RADIATION

Sites covered by the Part B remediation plan contain waste classified as “Category C”

wastes under ARPANSA Code (O’Brien, 20055):

“Category C waste is defined as solid waste containing alpha-, beta- or gamma

emitting radionuclides with activity concentrations similar to those for Category B. However,

this waste typically will comprise bulk materials, such as those arising from downstream

processing of radioactive minerals, significantly contaminated soils, or large individual items

of contaminated plant or equipment for which conditioning would prove to be impractical.”

ARPANSA is the project’s Regulator and has issued the Director of National Parks

with a ‘Facility License’ under the Australian Radiation Protection and Nuclear Safety Act

1998. It is a requirement that ARPANSA approve all the works proposed in the Part B

remediation plan.

TABLE II.4. - RADIOLOGICAL GUIDELINES

Guideline

Gamma dose 1 m above ground level

7.5 µSv/hr

Soil activity concentration 35 Bq/g

Annual radiation dose Less than 10 mSv to an average member of the critical group

II.13. RADIATION REMEDIATION CRITERIA

The criterion to exempt radioactive material from notification or registration as

outlined in Schedule 4 of the National Directory for Radiation Protection, is an activity

concentration 10 Bq/g (ARPANSA, 2004). This value is used in the Part B remediation plan

5O’Brien, R.S., Melbourne, A.J., Cooper, M.B. (2005) Scientific basis for the near surface disposal of bulk radioactive wastes. ARPANSA Technical Report Series 141

49

as acceptable as a remediation cut-off for activity concentrations. The dose rate used as a

remediation decision point for works proposed in the Part B remediation plan is 1.25 µSv/h ±

20%. This decision point was arrived at after Consultative Committee meetings and

consultations with experts in radiological contamination and mine rehabilitation, and was

based on field measurements of gamma radiation from tailings and surrounding soils in the

area of the former Rockhole Uranium Processing Plant.

As the activities proposed in the Part B plan are classified as an intervention, the key

aim of the intervention will be to substantially improve the existing situation on the basis of

criteria approved by ARPANSA

ARPANSA has confirmed that, as an intervention, relevant codes of practice such as

“Regulatory Guidance for Radioactive Waste Management Facilities” are not mandatory for

this project, but can be considered as guidelines. The principles set out in such codes have

been incorporated to the extent practicable into the above technical criteria. The only

mandatory code is Radiation Protection Series 1, ‘Recommendations for Limiting Exposure to

Ionizing Radiation’ (ARPANSA, 2002).

II.14. EXAMPLE OF THE APPLICATION OF THE PLANNING PROCESS TO A

SPECIFIC SITE (SLEISBECK)

For the purposes of this case study the planning process as applied to Sleisbeck site is

provided in detail. It is provided in the format used in this document to demonstrate how each

of the relevant Specific Remediation Objectives were addressed.

Sleisbeck is located approximately 42 km to the east of Guratba. Sleisbeck open cut is

located within the sacred site area registered by the Aboriginal Areas Protection Authority

(AAPA. An Authority Certificate was required from AAPA for all works within and around

the registered sacred site boundary.

Sleisbeck open cut is approximately 3 km west of the Sleisbeck camp site. Mine

workings consist of:

an open cut approximately 120 m in length by 30 m wide (at its widest point), which

is excavated into the side of a small hill in the midst of a floodplain.

50

Three areas of low truck dumps (typically less than 1.5 m high), covering an area of

approximately 1ha; which are located to the west of the open cut. Mature trees have

been noted growing throughout the truck dumps.

A number of costeans which were cut into the floodplain to the south and west of the

open cut

Sleisbeck Camp is located approximately 3 km east of Sleisbeck airstrip, and is on the

banks of the Katherine River

II.15. LAND USE

Long term land use for the Sleisbeck Pit and adjoining areas following rehabilitation will be

Category 5 for cultural reasons (Table II.1). Human activity will be allowed on the site only

on specific ceremonial occasions, with no hunting or camping at the site. Note, this restriction

does not apply to the Camp Site. No tourists are to be allowed on the site or on Sleisbeck

access road.

Long term land use for the Camp Site following rehabilitation will be Category 1 (Table II.1),

traditional Aboriginal owners intend to use it as a base for future dry season activities in the

area, hunting and fishing are likely to occur in the area immediately surrounding the site.

51

FIG. II.3.

II.16. REHABILITATION STRATEGY

The overall rehabilitation strategy for the open pit and the truck dumps included

backfilling the pit with material from the truck dumps. The pit would then be covered with a

minimum of one metre of compacted clean fill. The radiological “hot spot” in the back wall of

the pit will also be covered with clean fill. The capped and other disturbed areas will then be

revegetated.

Identification of a suitable source for inert rock material to cap the Sleisbeck Open Cut

was identified as a significant issue of concern given the location of Sleisbeck within a sacred

site complex. Field investigations into a suitable source of material were the subject of a

52

number of site visits and inspections made with traditional Aboriginal owners.

An initial potential site was rejected on the basis that it lay within a sacred site

complex. A suitable site was located away from any sacred sites that would also minimiZe the

need to create new tracks. However, it was ultimately decided to source inert capping material

and erosion resistant material from costean spoil heaps and disused built up track respectively.

This decision had positive benefits from a visual amenity point of view as it involved

removing many of the unsightly spoil heaps that were pushed up when the costeans were

being excavated. There will also be some economic benefits due to the very short haul

distance.

II.17. SAFETY

Potential safety issues associated with the high wall of the pit were addressed as a

consequence of backfilling the pit, and placing inert material over the radiation “hot spot” in

the pit wall.

II.18. CULTURAL VALUES

Traditional Owners placed a number of conditions on undertaking works on this site,

they are:

The Sleisbeck Pit site can only to be accessed by men, women (traditional Aboriginal

owners or otherwise) must not enter the site.

Any works on the site must only be undertaken with the supervision of traditional

Aboriginal owners.

Explosives are not to be used on the site.

Materials import and export to be kept to a minimum.

Earthmoving equipment used on site is to be kept to a minimum and the smallest

practicable sized equipment is to be used.

Disturbances around the pit should be kept to the minimum required to satisfy over-

53

riding statutory requirements.

Any use of site as a camp for contractors to be approved by Traditional Owners with

conditions to be determined (i.e. ensure contractors remain in camp area due to

proximity of sacred sites).

II.19. REVEGETATION

Disturbed areas (under truck dumps, haul roads, capped pit surface) will be

revegetated once all earthworks have been completed.

II.20. RADIATION

Some elevated radiation readings were recorded at three locations in the truck dumps,

as well as an elevated reading on the back (high) wall of the pit. Once all of the truck dump

material has been placed in the pit, it will then be covered with a layer of inert material to a

minimum thickness of 1.0 metre.

II.21. OTHER HAZARDOUS MATERIALS

Two small dumps of asbestos-cement sheeting (< 1m3 each) were found near the camp

site. All of this material will be collected and disposed of in accordance with the National

Code of Practice for the Safe Removal of Asbestos 2nd Edition [NOHSC:2002 (2005)].

II.22. RUBBISH CLEAN-UP

Remove old residential buildings from the site, concrete slabs under buildings are to

remain on site. All non-contaminated rubbish to be buried on site.

II.23. TECHNOLOGIES SELECTION

In developing the remediation plan and selecting the appropriate technologies for its

implementation, social and cultural, as well scientific and engineering factors were

considered. These included (but were not limited to):

the significance of the sites and the surrounding environment to traditional Aboriginal

owners, including consideration given to sacred sites which may impose cultural

54

constraints on works which can be undertaken,

the desire of traditional Aboriginal owners that only small earthmoving equipment be

used and that drilling and blasting would not be allowed,

the significance of the sites and the surrounding environment to park authorities,

the degree of disturbance and past activity at each site.

the ease of access to the sites, both for visitors and traditional Aboriginal owners (site

usage) and for any machinery required for site works as part of a remediation plan,

the success of any previous remediation works,

the current and anticipated future use of the sites,

the level of contamination (chemical or radiological), physical safety issues, and

environmental degradation of the sites,

relevant regulatory criteria pertaining to soil, water and radiological contamination,

the presence of any vulnerable, threatened or endangered species at each site, and

other ecological constraints on future works,

the presence of ground water at the sites and potential for contamination,

the cost and benefits of any proposed work,

the potential impacts of implementation of the remediation plan, i.e. the physical

works necessary to clear vegetation and reinstate access in order to undertake remedial

works,

After consideration of the above factors in regards to the Part B radiologically

contaminated sites the conclusion was reached that to comply with the remediation objectives

and criteria it would be necessary to reclaim the contaminated material from each of the

affected sites. This then lead into consideration of how this material should be managed,

options initially considered ranged from collecting the material and hauling it for disposal at

55

unspecified locations beyond the boundaries of the park, to construction of a dedicated

containment facility within the South Alligator Valley.

Regional options for a possible containment site outside the South Alligator Valley

were rejected early on in the process as traditional Aboriginal owners expressed a strong view

that the material should stay within the South Alligator Valley and not be transported to

someone else’s country for containment.

Other factors that influenced the choice of the preferred remediation option were the

desire not to have to import construction materials into the area unless absolutely necessary,

both for logistical and environmental reasons. This led to a preference for containment

designs to be based on using local clays and other construction materials.

The desire to minimize impacts from access track and haulroad construction lead to

specifying that all haulage be done using 6-wheel drive articulated dump trucks due to their

ability to operate efficiently on poorly formed surfaces.

II.24. IMPLEMENTATION

For the purposes of this case study the implementation of the remediation plan for

Sleisbeck site are provided in detail.

II.25. SLEISBECK ACCESS TRACK

Upgrading works were restricted to:

Grading of the track surface where required

Construction of a new crossing of the South Alligator River.

Minor upgrading of the track reduced the travel time between Guratba and Sleisbeck

in a four wheel drive vehicle from approximately two hours to just under one hour.

II.26. SLEISBECK PIT

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The first task undertaken was to pump out the pit in preparation for backfilling. The

remediation strategy then called for the reclaiming of five areas of waste rock (truck heaps)

and placement of that material in the open pit. Prior to commencing reclaiming the truck

heaps it was necessary to clear the areas of the majority of the vegetation covering them in

order to minimize the bulk of organic material likely to be incorporated in the reclaimed truck

dump material, and to preserve the trees for spreading back over the stripped areas at the end

of the job to assist in revegetation establishment.

Reclaiming the waste rock from the truck dumps was completed over a period of

approximately seven days. Waste rock was placed in the pit in nominal one metre thick layers

and watered and track-rolled before the next layer was placed.

Based on gamma readings across truck heap #3 a decision was made to leave one

section of it undisturbed as all gamma readings across that area were at background level.

Field investigations had defined three areas of increased radiological activity within

truck dumps. Table II.5 below presents the readings taken at these sites before and after the

material was reclaimed.

TABLE II.5.

SIte Coordinates * - Zone 53L Reading - beforeµSv/h

Reading - afterµSv/hEasting Northing

Site 1 0264959 8475606 10.0 0.10

Site 2 0265092 8475584 14.0 0.60

Site 3 0264994 8475688 7.0 0.25

* WGS 84 datum

Inert cover material for placement over the truck heap material was sourced from spoil

piles remaining from where costeans were excavated on the flood plains immediately to the

east of Sleisbeck pit. This material was ideal to provide the majority of the cover layer and

was spread across the backfilled pit surface in a single layer to a nominal depth of 700 mm,

without compaction.

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Fill that had been used to construct a now disused track to the north-east of the pit

provided the material for the upper 300 mm layer. This material was selected to act as a rock

armouring layer over the pit given its higher content of more competent erosion resistant

material.

Once all the waste rock had been recovered from the truck heaps the footprint of each

area was ripped to a depth of approximately 300 mm in order to break up compaction and

provide a moisture retaining seedbed. Once the shallow ripping had been completed, the

stockpiled cleared vegetation was spread back across the ripped areas.

Revegetation of the site was undertaken in December 2007.

II.27. MONITORING

Monitoring has commenced on the sites where earthworks were completed during

2007. At the completion of these earthworks a screening survey for radiation was undertaken

by eriss staff at the Sleisbeck waste dumps site. Ongoing monitoring is currently limited to

observations of vegetation establishment and for formation of erosion features.

Upon completion of the Part B works in late 2009 (new containment construction) a

comprehensive automated monitoring system will be installed and regular visits will be made

to the sites to download data and to undertake other monitoring activities.

II.28. NEW CONTAINMENT

All of the radiologically contaminated materials collected during implementation of

the Part B remediation plan will be placed in a new containment facility to be constructed at

the site of the disused El Sherana airstrip. This section provides an illustration of the decision

making process involved in selecting the location of this new containment facility.

II.29. SITE SELCETION PROCESS

The process for selecting a site suitable for constructing a containment facility began

in 2003 with a desk top study to find potential areas suitable for further investigation.

The pre-selection process included an assessment of:

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regional options for a possible containment site within and outside the South Alligator

Valley (early in discussions with traditional Aboriginal owners they expressed a strong

view that the material should stay within the South Alligator Valley and not be

transported to someone else’s country for containment),

regional factors (climate, seismic/tectonic/volcanic activity and regional land use).

areas of high conservation value and high tourist presence (e.g. Gunlom Falls),

areas of cultural significance to traditional Aboriginal owners, such as known sacred

sites (e.g. Guratba),

social factors such as low population density, low potential for future development e.g

mining, agriculture or outdoor recreation use and long term control/ownership),

general local factors (geology, hydrogeology, flooding, geotechnical stability,

topography and access).

In addition the following technical criteria for site selection (endorsed by ARPANSA)

were applied.

1. The site for the containment should be free from flooding (above the 1:100 year

floodline), have good surface drainage features, and generally be stable with respect to

its geomorphology.

2. If possible, the water table in the area should be at a sufficient depth below the

planned containment to ensure that groundwater is unlikely to rise to within 5 m of the

waste.

3. The containment should be located away from any known or anticipated seismic,

tectonic or volcanic activity that could compromise the integrity of the containment

structures.

4. The groundwater in the vicinity of the site, which may be affected by the presence of a

containment facility, should neither currently, or be planned to be used, for human

consumption, pastoral or agricultural purposes.

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5. The site should have suitable geochemical and geotechnical properties to inhibit

migration of radionuclides and to facilitate containment operations.

6. The containment should not be situated in areas with ground slopes nominally greater

than 10% (1 vertical in 10 horizontal).

7. If possible, the site shall be selected such that soils surrounding the containment have

an in situ maximum hydraulic conductivity of 1x10-7 m/s, and that this condition

should extend to a level no less than 5 m below the base of the containment.

8. The containment facility shall be constructed such that low permeability barriers have

a design life of not less than 300 years, and a structural life of not less than 1,000

years.

9. The site shall have reasonable access for safe transport of materials, waste and

equipment during construction and operation.

From the pre-selection screening process two potential containment sites were

identified, the first on the disused El Sherana airstrip and the other near the former South

Alligator Village (SAV) site.

The next stage of the site selection process was to install water monitoring bores at

both of the sites. This was done during the 2004 dry-season. A new bore installation

programme was undertaken in 2006 at the preferred site with bores being drilled at intervals

adjacent to El Sherana airstrip. At the same time an automatic weather station was installed

nearby.

60

61

FIG. II.4.

62

The decision to concentrate on the airstrip as the preferred location was based on the

following factors:

The SAV site was relatively small.

There were concerns that given the proximity of the SAV site to the flood zone that it

may not meet the height above groundwater criteria.

The majority of contaminated material was closer to the airstrip site.

There would be lees mixing of haul truck with tourist traffic on the public access

sections of the road - reduced risk of accidents.

Using the airstrip site would interfere less with Park operations and tourists during the

construction phase.

The airstrip site was already disturbed from airstrip construction and subsequent

repeated use as a borrow pit.

In 2007 a consultant engineering company was engaged to design a containment

facility at the airstrip site, as well as to quantify the materials in each of the existing

containments and the Rockhole Uranium Plant Processing Plant Tailings Residues. All field

works required for this consultancy were completed during 2007 and a draft report was

received in June 2008.

The key outcomes of the report were:

Excavation and removal of all material at each of the Part B Sites to the proposed

containment is recommended. Four of the five sites (Battery Bund, Weighbridge, South

Alligator Village and Rockhole Uranium Plant Processing Plant Tailings Residues)

exceeded the decision thresholds, and El Sherana Camp Containment poses risks for other

reasons.

The total remediation volume for all material characterized is estimated to be

approximately 17,000 m3 when volumes for each of the containments were recalculated

to include additional quantities arising from dilution during excavation.

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A conceptual containment was outlined for the western end of the disused El Sherana

Airstrip to contain this material.

The proposed containment site complies with all nine of the criteria endorsed by

ARPANSA.

The proposed containment design includes a contingency for higher groundwater levels

than have been recorded, includes a compacted or man-made liner, and compacted cover

including a substantial growth medium. The final landform surface is designed to blend

with the environment and is fully water shedding.

The proposed design was required to consider the cover requirements for Category C

wastes within the ARPANSA code. However, as the proposed works are an intervention6,

therefore the cover requirements for Category C wastes should only be considered as advisory

guidelines and are not mandatory requirements.

II.30. CONTAINMENT DESIGN

At this stage two conceptual design alternatives have been developed for the

containment facility. The difference in the two conceptual design alternatives for the proposed

containment facility is the encapsulating layer around the radiologically contaminated

materials.

The first alternative includes the use of native clay, compacted in several lifts, while

the second alternative is a composite of native clay and geosynthetics. Possible geosynthetic

products are a HDPE geomembrane or a geosynthetic clay liner (GCL); although these

6 ARPANSA defines an intervention as follows:

“When sources of exposure and exposure pathways are already present, due to natural phenomena or to earlier practices that preceded regulatory control or to accidents, the only type of action available to control exposure is intervention. Before intervention is initiated, it should be justified; that is, it should be shown that it is likely to do more good than harm. Once justified, the form, scale and duration of the intervention should be optimized to obtain the maximum net benefit. Intervention levels are likely to vary from case to case, depending on the results of optimization. This does not imply an inconsistency of approach, rather it reflects the variability of the social and economic factors taken into account in the optimization process.”

NOHSC and ARPANSA. Recommendations for Limiting Exposure to Ionizing Radiation (1995) (Guidance Note [NOHSC:3022(1995)]) and National Standard for Limiting Occupational Exposure to Ionizing Radiation [NOHSC:1013(1995)], Radiation Protection Series Publication No. 1, Republished March 2002

64

products are less expensive and are reported to have a much lower ksat compared compacted

clay, their longevity and chemical compatibility with leachate waters are issues that will be

considered during Stage 2, which is scheduled to be completed in early 2009.

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APPENDIX III DECISION MAKING CASE STUDYU.S. DEPARTMENT OF ENERGY URANIUM MILL TAILINGS REMEDIAL

ACTION PROJECT

III.1. INTRODUCTION

The U.S. Department of Energy (DOE) established the Uranium Mill Tailings

Remedial Action (UMTRA) Project in the early 1980’s as a result of U.S. Congressional

legislation in 1978. The legislation directed the DOE to remediate 22 abandoned uranium

mill sites in 10 states (mostly in the western U.S.) including 5 sites involving Native

American lands.

Table 1 list the quantities of contaminated materials at the various sites. [Russ please

provide.]

Figure 1 shows the locations of the abandoned mill sites.

Upon completion of the UMTRA Project surface remediation activities in 1998, the

DOE had remediated 22 sites and over 5300 “vicinity properties” which were locations where

tailings materials were used in appropriately for construction purposes. Eighteen disposal

facilities were constructed (some sites were co-located). The UMTRA surface remediation

program cost approximately $1.5 billion.

The UMTRA ground water remediation activities are still on going at many sites and

will continue for many years.

III.2. PROJECT FRAMEWORK

Three key components were the foundation for the framework of the establishment

and implementation of the UMTRA Project. These include the enabling legislation, the

development and implementation of the U.S. Environmental Protection Agency (EPA)

regulatory standards for the Project, and the U.S. Nuclear Regulatory Commission (NRC)

rules and regulations for the Project.

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FIG. 1. UMTRA Project Site Locations.

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III.1.1. Enabling legislation

The Uranium Mill Tailings Radiation Control Act (UMTRCA) of 1978 (Public Law 95-604), as amended, (the Act) gave the DOE the responsibility to remediate the contamination associated with 22 abandoned uranium mill sites. The Act gave the EPA the responsibility to establish regulatory standards for the clean up, remediation, and disposal of contamination associated with the abandoned sites. The Act also gave the NRC the responsibility to approve of the remedial activities and then to subsequently license the disposal facilities.

Significant items of note in the Act are that it:

Required “long-term” solutions to the remediation of contamination. The Act

specifically stated the congressional desire to have long lasting solutions for

remediating the tailings and related contamination.

Required cooperative agreements with affected states and/or Native American tribes.

In the case of states, the Act required a 90/10 % cost sharing. The states were required

to fund 10% of the cost of remediation. Native American tribes were not required to

provide cost sharing.

Required an active public participation program. This was to encourage community

involvement in some decision making. This generally involved trying to

accommodate the local community’s preferences regarding remedial actions.

Community involvement often included discussions regarding the various options for

remediation.

III.2.2. EPA Standards

The EPA established various environmental requirements for the remediation of the

uranium mill tailings (40 Code of Federal Regulations (CFR) 192). These included:

Containment/disposal engineered units are to last from 200 to 1000 years

Gamma and Radon-222 emanation were limited.

Radium-226 emanation in soils was limited.

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Radiological and non-radiological contamination above appropriate standards were to

be remediated.

Remediation of ground water was included in the standards.

III.2.3. NRC Enforcement

The NRC was required to approve remedial activities through a variety of mechanisms

including concurrence on the site specific proposed remediation and concurrence on the site

specific remediation completion reports. The sites, once remediated, were licensed by the

NRC. In most cases, DOE was required to obtain and retain ownership of the disposal sites.

In cases where disposal facilities were located on Native American lands, only the tailings

materials were licensed. This is because the land that the disposal facilities were located on

belongs to the Native American tribes and therefore, the land was not required to be

transferred to DOE ownership.

A condition for NRC licensing of the UMTRA sites was for a Long-Term

Surveillance Plan to be produced for each site. These plans then formed the basis to

implement long term care of the individual sites.

III.3. DESIGN STANDARDS AND OTHER REGULATIONS

III.3.1 Design Standards

The EPA standards for the UMTRA Project were for the most part, descriptive, rather

than prescriptive. For example, the requirement that the disposal sites were to last 200 to

1000 years didn’t specify how to achieve the requisite longevity. The longevity requirement

resulted in numerous discussions and negotiations between the DOE and the NRC. This

resulted in a series of general design standards in order to meet the EPA requirements. For

example, the longevity design requirements were interpreted to mean that the engineered

disposal facilities were required to withstand maximum credible earthquakes, probable

maximum floods, and probable maximum precipitation events in order to abide by the EPA

longevity requirement. Also of note was the need for the cover components to minimize

infiltration through the stabilized mill tailsings and related contamination. Minimizing

69

infiltration through the cover materials was a key component in meeting the EPA ground

water requirements for disposal.

The DOE produced a Technical Approach Document which detailed guidance on such

topics as:

Geologic stability

Geotechnical issues

Radon barrier considerations

Surface water hydrology

Disposal design approaches

Cover design

Non radiological contaminants

Disposal of contaminated buildings and structures

The Technical Approach Document also included what became known as the

“checklist cover.” The checklist was utilized in part to assist in streamlining the design

process, to ensure that the appropriate components were included in the site specific designs,

and to ease and potentially shorten the NRC review and approval of the various remediation

documents.

There were two primary components related to groundwater which were 1) the

disposal unit compliance and 2) site specific groundwater remediation.

The compliance portion required determining background water quality. Background

water quality played a major role in the determining the ability to achieve EPA ground water

standards for the individual disposal facilities. The disposal facilities were required to meet

specified groundwater quality standards at a point of compliance. This point of compliance

was usually defined as the downgradient edge of the disposal unit. Groundwater monitoring

at the point of compliance was required to meet specified water quality criteria. This is the

70

reason why the ability of the cover system to limit or impede precipitation infiltration played

an important factor in disposal cell design.

The determination of water quality standards at a point of compliance was based on

various factors including existing background water quality. For example, some UMTRA

sites were located in areas of known uranium ore bodies. Therefore, in those locations,

background groundwater quality had naturally occurring high concentrations of various

chemical constituents. As a result, at those sites, groundwater compliance was not based on

drinking water standards.

The groundwater cleanup standards were also based on existing background water

quality. There were several potential approaches for achieving the EPA standards.

Groundwater quality was required to meet background concentrations; maximum

concentration limits (for drinking water); alternative concentration limits, which could be

proposed based on site specific conditions; or supplemental standards which could be

proposed if the groundwater was not a current or future source of usable water. Supplemental

standards were utilized in a few instances where the disposal cells were located in uranium

ore bodies.

III.3.2 Other Regulations

The U.S National Environmental Policy Act (NEPA) of 1969 requires evaluation of

environmental impacts resulting from various U.S. federal government actions. Because of

the NEPA requirements, the UMTRA Project was required to conduct a wide variety of

environmental evaluations prior to remedial actions. These investigation included biota

studies for such things as threatened and endangered species and cultural resources

investigations.

Additionally, there were requirements to comply with various local, state, federal, and

tribal regulations. These included local land use planning, state and federal clear air and clean

water act requirements and state monitoring well permits. Also, various worker health and

safety requirements were implemented for field and construction activities.

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III.4. SITE EVALUATIONS AND ALTERNATIVE SITE SELECTIONS

Numerous criteria were utilized to evaluate the suitability of the individual sites for

disposal of the contaminated materials. The former milling sites were evaluated for final

disposition of the materials utilizing three options, 1) stabilization in place, 2) stabilization on

site, 3) or relocation.

III.4.1. Site Evaluations

Individual site evaluations and characterization activities included such topics as:

Identification of contaminant types and quantities

Geotechnical

Surface and ground water hydrology

Borrow sources

Environmental evaluations, such as wetlands and protected species

Risk assessments

III. 4.2. Alternative site selection process

As stated previously, some of the UMTRA mill tailings needed to be relocated. This

often had to do with the instability of the location, such as the potential for flooding; other

environmental issues; and in some cases proximity to local population.

Figure 2 illustrates the site selection process the was developed for the UMTRA

Project.

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FIG. 2. Alternative Site Selection Process.

Various factors were evaluated for the potential relocation of the contaminated

materials. The alternative site evaluation process included consideration of the proximity or

potentials of the following attributes:

Geological faults

Liquefaction potential

Landslides

Erosive soils

Slopes and escarpments

Water bodies

Wetlands and floodplains

Aquifers

Mineral resources73

Designation of Search Region

Preliminary Screening of Designated Search Region

Identification and Evaluationof Candidate Sites

Technical Site Evaluation(Post-Drilling)

Site Selection

Cultural resources

Transportation corridors

State and national parks

Wildlife habitats/refuges

These factors were evaluated using a quantitative and qualitative process that ranked

the various attributes of potential relocation sites. In all cases, additional data collection was

conducted in order to aid in the evaluations. This included such things as ground water well

drilling to determine subsurface conditions and collecting geotechnical soil samples.

III.5. REMEDIAL ACTION PLANS AND ENVIRONMENTAL DOCUMENTATION

The Remedial Action Plans (RAPs) and the environmental documentation formed the

basis of complying with the various regulatory requirements to begin remediating the former

mill sites.

III.5.1. Remedial Action Plans

A checklist for the RAPs was developed to ensure that all relevant requirements and

other factors were considered in the design and planning for remediation. This also included

compliance with the ground water standards.

The checklist considered the following:

Background ground water quality

Presence and movement of contaminant plumes in ground water and discharge to

surface water

Predictions of effects of remedial action on ground water

Impacts on beneficial use of ground water

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Control alternatives for ground water (aquifer restoration, institutional controls)

Radiological site characterization

Radon barrier design

Surface water hydrology

Erosion protection

Geotechnical

Non radiological contaminants

As mentioned previously, a checklist cover design was developed. Figure 3 illustrates

a typical cover design. Some cover elements were able to be eliminated in some site specific

circumstances. For example, with locations that did not have substantial freeze/thaw issues, a

frost protection layer would not be utilized. A component elimination criteria was developed

to aid in the decision making process.

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FIG. 3. Checklist cover.

III.5.2. Environmental Documentation

Environmental documentation in the form of either Environmental Assessments (EAs)

or Environmental Impact Statements (EISs) were produced for each site. These NEPA

documents included evaluations of the environmental impacts of the various activities

associated with the proposed remediation. Most of the UMTRA sites only required EAs.

However, due to the extensive impact of some of the individual remediations, a handful of

sites required EISs. The formal EIS process also included public meetings and public

comment on the draft documents.

III.6. FINAL DESIGN DOCUMENTS AND APPROVAL FOR REMEDIATION

Final design documents with specifications were submitted to NRC for approval to

construct the disposal facilities. Upon resolution of comments between the DOE and the

NRC on the final design, the site specific construction was approved by the NRC. In some

cases, construction was conditionally approved in order to begin site preparation.

III.7. CONSTRUCTION

Construction was conducted using the specifications in the approved final design

documents. Due to the volume of contamination, remediation activities often took more than

one construction season. Winter shut downs and spring start ups were factored into the

construction planning process.

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FIG. 4. The completed Gunnison, Colorado UMTRA site circa 2009.

III.8. NRC ACCEPTANCE AND LICENSING

Once construction was completed, site specific completion reports were submitted to

the NRC for verification and approval. Long term care plans were also submitted that

detailed the various activities related to long term care. This included such details as the

locations and numbers of survey markers and site monuments and the type of fencing

required.

Once completion and long term care documentation were completed and approved, the

individual sites were licensed by the NRC under a general NRC license.

In instances where disposal facilities were stabilized on site or on location, preexisting

groundwater contamination may have existed. In these instances, NRC approved and licensed

the surface remediation only. Once groundwater remediation is (or was) completed, the NRC

would (or will) approve the final remediation.

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III.9. SURVEILLANCE, MONITORING AND LONG-TERM CARE

The DOE developed a guidance document for evaluating and planning the needs for

long term care.

Disposal facilities are required to be inspected annually and evaluated to determine the

effectiveness of the engineered unit to perform as designed. Evaluation factors included the

need or requirement to remove invasive plants, the need to contend with animal burrows,

evaluating the effectiveness of institutional controls including signs and fences, and

thoroughly documenting annual inspections. An important element of long term care is

determining what constitutes failure of the disposal cell. For example, minor erosion issues at

disposal facilities would not be considered failure of the engineered unit. However, major

breaches in the cover would most likely be considered failure of the unit. To date, no cover

“failures” have been reported.

FIG. 5. Tuba City, AZ UMTRA site sign.

78

FIG. 6. Falls City, Texas granite monument.

III.10. THE UMTRA GROUNDWATER PROGRAM

The early focus of the UMTRA Project was the surface stabilization of the mill

tailings and associated contamination, in part because the UMTRCA specified a time limit on

surface remediation. Due to the nature of the ground water contamination, the ground water

remediation portion of the UMTRA Project was not given a time limitation.

Residual contamination cleanup was (is) conducted using either active or passive

approaches. Active techniques involve “pump and treat” methods.

Passive techniques involved utilizing natural subsurface attenuation processes. In

these cases, sites were (are) monitored to ensure that contaminants of concern were (are)

decreasing in concentration. A major component of this approach is to ensure that appropriate

institutional controls are implemented to preclude the inappropriate use of contaminated

groundwater.

The DOE developed site specific site observational work plans that discussed the

approach to groundwater remediation and compliance. These plans were submitted to the

NRC for concurrence.

ReferencesTADEPA standards

79

Public LawNRC regs

1 [?] INTERNATIONAL ATOMIC ENERGY AGENCY, Radioactive waste

management glossary, 2003 ed., Pub1155_web.pdf, Vienna (2003).

2 [?] INTERNATIONAL ATOMIC ENERGY AGENCY, Food and Agriculture

Organization of the United Nations, International Atomic Energy Agency,

International Labour Organisation, OECD Nuclear Energy Agency, Pan American

Health Organization, World Health Organization: International Basic Safety Standards

for Protection against Ionizing Radiation and for the Safety of Radiation Sources,

Safety Series No. 115, Vienna (1996).

3 [?] UNITED NATIONS, Sources and Effects of Ionizing Radiation (Report to the

General Assembly), Scientific Committee on the Effects of Atomic Radiation

(UNSCEAR), UN, New York (2000).

4 [?] INTERNATIONAL ATOMIC ENERGY AGENCY, Application of the

concepts of exclusion, exemption and clearance, Safety Guide No. RS-G-1.7., Vienna

(2004).

5 [?] INTERNATIONAL ATOMIC ENERGY AGENCY, Assessing the need for

radiation protection measures in work involving minerals and raw materials, Safety

Reports Series No. 49., Vienna (2006).

6 [?] INTERNATIONAL ATOMIC ENERGY AGENCY, Management of

radioactive waste from the mining and milling of ores, Safety Standards Series No.

WS-G-1.2., Vienna (2002).

7 [?] MACG A., ROBERTSON. P. ENG. & SHANNON SHAW, Risk management

for major geotechnical structures on mines, (2003)

www.robertsongeoconsultants.com/papers/cami03risk.pdf

8 [?] SANDIA ENVIRONMENTAL DECISION SUPPORT SYSTEM (SEDSS)

www.sandia.gov/Subsurface/factshts/ert/sedss.pdf

80

REFERENCES9 [?] INTERNATIONAL ATOMIC ENERGY AGENCY, Joint Convention on the

Safety of Spent Fuel Management and on the Safety of Radioactive Waste

Management, INFCIRC/546, Vienna (1996).

81