**NRC INSPECTION MANUAL** NMSS/FCSS

INSPECTION PROCEDURE 88035

RADIOACTIVE WASTE MANAGEMENT

PROGRAM APPLICABILITY: 2600

88035‑01 INSPECTION OBJECTIVES

The objectives of this procedure are to determine whether:

01.01 The licensee or certificate holder has established and is
maintaining adequate and controlled procedures and quality assurance
(QA) programs to ensure compliance with the requirements of 10 CFR Part
20 and 10 CFR Part 61 applicable to low‑level radioactive waste form,
classification, stabilization, and shipment manifests/tracking.

01.02 The licensee or certificate holder stores and/or disposes of
low‑level radioactive waste (LLRW) safely and in accordance with
license/certificate[^1] conditions. This procedure applies to any
licensee or certificate holder who stores LLRW, regardless of when the
storage facility was established.

88035‑02 INSPECTION REQUIREMENTS

02.01 [Management Controls for Waste Classification, Shipping, and
Burial]{.underline}. Review the licensee or certificate holder\'s
written procedures for radioactive waste processing. Determine whether
the following aspects are adequately addressed:

a.  The organization and individual(s) assigned the responsibility for
    radioactive waste processing for low‑level land burial have been
    clearly designated in writing;

b.  There has been a clear delineation of the authorities and
    responsibilities of those individuals and organizational entities;

c.  Written management‑approved instructions have been established to
    carry out the various radioactive waste processing and packaging
    activities, including authorized changes thereto, and the
    promulgation/distribution of such instructions to the appropriate
    line/staff organization.

02.02 [Quality Assurance]{.underline}. Determine whether the licensee or
certificate holder has established and maintains an adequate quality
assurance (QA) program to determine compliance with the waste
classification and characterization requirements of 10 CFR 61.55 and
61.56. Determine whether the QA program includes the required audits and
management evaluation of such audits. Review the results of the most
recent audit and corrective actions \[Subsection III.A.3 of Appendix G
to 10 CFR Part 20\] if any, since the prior Inspection Procedure (IP)
88035 inspection.

02.03 [Waste Classification]{.underline}. Review the licensee or
certificate holder\'s documentation and records of activities that have
been established and are being maintained to determine whether all
low‑level radioactive wastes are properly classified according to 10 CFR
61.55. Determine whether such efforts reasonably determine whether a
realistic representation has been accomplished \[Subsection III.A.1 of
Appendix G to 10 CFR Part 20\].

Review the license requirements for authorized releases of radioactive
nuclides in liquid and solid products transferred to non-licensed
entities to assure they meet the license requirements.

02.04 [Waste Form and Characterization]{.underline}. Review the licensee
or certificate holder\'s documentation and records of activities which
have been established and are being maintained to determine whether all
LLRW meets the waste characteristics of 10 CFR 61.56. Determine whether
the methods and determinations of the licensee or certificate holder
provide reasonable assurance that the waste form requirements are met
\[Subsection III.A.1 of Appendix G to 10 CFR Part 20\].

02.05 [Waste Shipment Labeling]{.underline}. Review the licensee or
certificate holder\'s procedures and records to determine whether each
package of radioactive waste intended for shipment to a licensed land
disposal facility is labeled, as appropriate, to identify it as Class A,
B, or C waste in accordance with the classification criteria of 10 CFR
61.55 \[10 CFR 61.57 and Subsection III.A.2 of Appendix G to 10 CFR Part
20\].

02.06 [Tracking of Waste Shipments]{.underline}. Review the licensee or
certificate holder\'s procedures and records to determine whether a
system has been established to forward to recipients or deliver to waste
collectors, at the time of shipment, a copy of the waste manifest.
Determine whether acknowledgment of receipt of the manifest is obtained.
Determine whether the licensee or certificate holder has a procedure in
place to initiate an investigation in any instances wherein
acknowledgment of receipt of shipment has not been received within the
specified period. Determine whether procedures are in place to report
such investigations to the appropriate NRC Regional Office and file the
required written report \[Subsection III of Appendix G to 10 CFR Part
20\].

02.07 [Disposal Site License Conditions]{.underline}. Review the
licensee or certificate holder\'s procedures and records to determine
whether the applicable disposal site license conditions are being met.
Determine whether the licensee or certificate holder has on file a
current version of the disposal site license.

02.08 [Management Controls and Surveys for Solid Waste
Storage]{.underline}. Review the license file and identify any special
authorizations and requirements for LLRW storage. Determine where LLRW
is being stored. Review how long the LLRW has been stored and examine
the licensee or certificate holder\'s accountability and security
procedures for the waste. Determine whether the licensee or certificate
holder is within the authorized possession limits. Review the licensee
or certificate holder\'s procedures for safe placement, inspection, and
repackaging of LLRW in storage. Determine whether or not the licensee or
certificate holder has conducted and properly documented: (1)
inspections of LLRW packages to assure they maintain integrity; (2)
radiation surveys of individual packages and the storage area, in
general; and (3) any required effluent sampling. Review the licensee or
certificate holder\'s records for waste placed in storage and determine
whether they are adequate to account for the LLRW stored.

02.09 [Radioactive Solid Waste]{.underline}. Determine compliance with
the following listed regulations and/or license requirements applicable
to the facility.

a.  10 CFR 20.1901, .1902, .1903, .1904, and .1905 \[caution signs,
    labels\]

b.  10 CFR 20.2001 \[general requirements for disposal\]

c.  10 CFR 20.2101, .2102, .2103, .2108, and .2110 \[records of
    disposal\]

d.  10 CFR 20.2004(a)(2) and (3) \[incineration\]

e.  License requirements for:

    1.  Use of specified containers and packages,

    2.  Identification of the quantity and radionuclide composition of
        waste in containers and packages,

    3.  Records of waste shipments and waste in storage, and

    4.  Reports of solid waste shipment and waste in storage.

f.  Examine several waste packages to determine whether the packages are
    adequate for the expected term of storage. Determine whether the
    type of packaging maintains the package integrity.

02.10 [Waste Burial]{.underline}. Determine compliance with the
following license/certificate and regulatory requirements applicable to
the facility:

a.  Use of specified containers and packages,

b.  Quantity and radionuclide composition of waste in containers and
    packages,

c.  Identification of containers and packages,

d.  Restoration of excavated areas, trenches, etc.,

e.  Markers for burial sites, e.g., trenches, holes, cairns, vaults,

f.  Records (of container contents, burial location, etc.), and

g.  10 CFR 20.2002, AMethod for obtaining approval of proposed disposal
    procedures,@ and 10 CFR 20.2108, ARecords of waste disposal.@

02.11 [Adequacy of Storage Area]{.underline}. Inspect the storage
area(s) to determine the adequacy of:

a.  Access control and security.

b.  Access to, and housekeeping around waste packages. Adequate lighting
    should be provided to permit identification of unsafe radiological
    and non-radiological conditions.

c.  Stable placement of waste or waste packages.

d.  Protection from environmental elements, fire and flooding, avoidance
    of temperature/humidity extremes, and ventilation considerations.

e.  Posting and labeling.

f.  Segregation from hazardous materials

g.  Waste minimization techniques

02.12 [Earthen (surface) Waste Retention Systems]{.underline}. If there
is a license/certificate requirement for earthen waste retention
systems, determine compliance with the license/certificate requirements.

88035‑03 INSPECTION GUIDANCE

Note: Guidance offered below is specific to Inspection Requirements in
Section 02 above.

[General Guidance]{.underline}.

As noted in Information Notice 90‑09, AExtended Interim Storage of
Low‑Level Radioactive Waste by Fuel Cycle and Materials Licensees,@ LLRW
storage areas or facilities are being added by licensee or certificate
holders as interim measures until their States or Regional Compacts
construct LLRW disposal facilities. Some licensee or certificate holders
already have LLRW storage facilities. Depending on the specific
situation of a State or Compact, LLRW may be in storage for anywhere
from several months to several years. In general, because the safety
hazard of LLRW storage facilitiesBespecially for dry LLRW storageBis
low, extensive inspection efforts are not warranted. The inspection
effort, therefore, should be geared toward assuring that licensee or
certificate holders who are storing LLRW for such periods are in
compliance with possession limits and license/certificate conditions,
and do not develop an \"out‑of‑sight, out‑of‑mind\" attitude. This will
best be done by examining the licensee or certificate holder\'s records
to determine whether the required surveys, inspections, and
accountability checks are being done and then following up with a
physical examination of the storage area and waste containers/packages.

Guidance for inspectors as well as licensee or certificate holders has
been provided by Low-Level Waste Management Branch, Nuclear Material
Safety and Safeguards (NMSS) in the form of branch technical positions
(BTPs) on \"Waste Classification,\" dated May 1983 (see Federal
Register, Vol. 48, No. 110, June 7, 1983), and \"Waste Form,\" dated
January 1991 (see Federal Register, Vol. 56, No. 18, January 28, 1991).
In addition to the BTPs, NMSS has stated publicly (48 FR 40512, Vol. 48,
No. 175, September 8, 1983), that \"topical reports\" of licensee or
certificate holders that have been reviewed by NMSS may be useful in
demonstrating compliance with the requirements. Inspectors should be
aware of and be prepared to accept results referenced in such topical
reports as demonstration of compliance in specific inspection cases.

03.01 [Management Controls for Waste Classification, Shipping, and
Burial]{.underline}. Inspection effort should be directed at determining
whether written procedures have been established in a manner approved by
management and a discussion and field observation of the program
implementation with the licensee or certificate holder. The procedures
should be readily available to any persons having responsibility for
low‑level waste classification and preparation for transfer of such
wastes to land disposal facilities. The inspector should confirm that
the written procedures include provisions for all of the applicable
activities pertaining to Section 88035‑02 Inspection Requirements. The
inspector should observe (to the maximum extent possible) workers
performing specific tasks and discuss the

program with licensee or certificate holder personnel to determine that
waste operations are being conducted safely and in accordance with any
applicable approved written procedures.

03.02 [Quality Assurance]{.underline}. The written operating procedures
and QA procedures of the licensee or certificate holder collectively are
intended to accomplish compliance with the 10 CFR Part 20 and 10 CFR
Part 61 regulatory requirements. The nature and scope of the licensee or
certificate holder\'s QA program will vary depending on the nature and
complexity of the specific waste stream. Inspectors should observe
whether the program

and procedures are effective in causing the licensee or certificate
holder to perform the required waste form classification and
characterizations when changes to the waste stream occur.

03.03 [Waste Classification]{.underline}. The inspector should review
whether the method used by the licensee or certificate holder is
adequate to determine radionuclide concentrations in order to classify
his waste. The NMSS BTP on waste classification describes four
acceptable methods for classifying wastes. The inspector should use this
BTP as basic guidance in implementing this inspection requirement.

a.  For those licensee or certificate holders who use correlation
    factors for classifying wastes, correlation factors should be based
    on actual waste stream analysis.

b.  Generic fuel cycle facility scaling factors are acceptable if actual
    sample analysis data correlate with the generic database. More
    specific scaling factors should be determined for the facility if,
    for example, uranium or plutonium has been contaminated with
    technetium and other by-product isotopes due to prior processing.

c.  If generic scaling factors are not appropriate for an individual
    waste stream, scaling factors should be based on the specific waste
    stream data.

d.  It is acceptable to base correlation factors on a single set of
    analyses, repeated annually.

e.  If sample analyses have not been completed, calculation methods for
    scaling factors are acceptable while analyses are in progress.
    Samples should be offsite for analysis to be considered in progress.
    After receipt of the sample analyses, the licensee or certificate
    holder may continue using calculation methods, provided the results
    correlate with the actual sample analyses.

f.  NRC‑approved topical reports for waste classification are acceptable
    for demonstrating compliance with 10 CFR 61.55.

> The inspectors should review the license requirements for authorized
> release guidelines for byproduct materials transferred to
> unlicensed/uncertified persons. Chemical process byproducts in liquid
> and solid form such as ammonium hydroxide, hydrogen fluoride and
> calcium fluoride are frequently sold to unlicensed commercial
> customers. Depending on the facility and processes, uranium and
> plutonium release criteria will be specified in the license. These
> criteria and analysis supporting the releases should be reviewed for
> compliance with the license criteria.

03.04 [Waste Form and Characterization]{.underline}. The inspector
should determine the test methods and acceptability of such tests used
by the licensee or certificate holder to characterize this waste stream.
In cases where a \"high integrity container\" is used to stabilize the
waste, the type and acceptability of the specific container should be
verified. The inspector should use the NMSS BTP on waste form as his
basic guidance in implementing this inspection requirement. In addition:

a.  Classes B and C solidified waste programs should contain test data
    on compressive strength, leaching, irradiation stability,
    biodegradation, and thermal stability. Results of tests should be
    consistent with the BTP on waste form. Test data packages that do
    not address all of the above areas may be acceptable, provided that
    testing is under way to complete the data package. A schedule for
    completion of the testing should be available for NRC inspection.
    Solidification media currently being used (cement,
    vinyl‑ester‑styrene, asphalt) are acceptable waste forms for
    shipment and burial, provided that qualification testing is in
    progress and there are procedures and controls in use to determine
    the consistent production of waste capable of existing as a
    free‑standing monolith.

b.  The licensee or certificate holder\'s solidification process control
    program should incorporate the testing information from the
    solidification agent stability qualification.

c.  NRC‑approved topical reports on high integrity containers and
    solidification agents are acceptable for demonstrating compliance
    with 10 CFR 61.56(b).

d.  A Certificate of Compliance issued by a State for a high integrity
    container is acceptable for demonstrating compliance for waste
    shipped to that State.

03.05 [Waste Shipment Labeling]{.underline}. Inspectors as well as the
licensee or certificate holder should be aware that Classes A, B, & C
wastes bear no relationship to Types A or B packaging for transport
purposes under 49 CFR Part 173 or 10 CFR Part 71. The labeling of waste
packages pursuant to this requirement is, therefore, in addition to any
other package markings and labels required by the transport regulations.

03.06 [Tracking of Waste Shipments]{.underline}. Inspectors should be
aware of the differences in the requirements of Appendix G to 10 CFR
Part 20 on waste manifest tracking for shipments by generators to waste
collectors, as opposed to shipments directly to land disposal
facilities. There are also some differences in the specific requirements
of a waste collector who processes the waste before shipping it to the
disposal facility, as opposed to a collector who simply stores the
material before transferring it to the land disposal facility.

03.07 [Disposal Site License Conditions]{.underline}. No further
guidance.

03.08 [Management Controls and Surveys for Solid Waste
Storage]{.underline}. Determine whether the procedures for placement,
inspection, and repackaging of LLRW are clear and available to all who
need to use them, and that they have been approved by management.
Confirm that inspections and surveys of stored LLRW have been performed
at the required frequency and properly documented, and that the licensee
or certificate holder has conducted and properly documented all required
effluent sampling. Review the results of inspections and surveys of LLRW
in storage focusing on licensee or certificate holder followup actions
to problems identified. Check the licensee or certificate holder\'s
records on LLRW storage, determine whether the records provide
accountability, and determine how long LLRW has been in storage. Confirm
that the licensee or certificate holder is within authorized possession
limits. Confirm that any required checks of fire protection systems have
been performed.

03.09 [Radioactive Solid Waste]{.underline}.

a.  Check posting of storage areas and labeling of a selected number of
    containers. Check to determine that the licensee or certificate
    holder=s packages are clearly and properly labeled in accordance
    with 10 CFR 20.1904 and 20.1905, and that LLRW is transferred or
    disposed in accordance with 10 CFR 20.2006.

b.  There may not be specific requirements included in the license, for
    02.10 b. and c., however, they are required for compliance with
    20.2001 and 20.2101, .2102, .2103, .2108, and .2110. Item 02.10 a.
    should be covered by licensee or certificate holder procedures.

c.  Examine a representative number of packages for signs of swelling,
    leakage, deformation, or deterioration (i.e., rusting or other
    corrosion which may lead to breach).

03.10 [Waste Burial]{.underline}. If the licensee or certificate holder
buries noncontaminated waste onsite, e.g., in a landfill, determine
whether a monitoring program exists which assures that the waste is
indeed \"nonradioactive.\" There may not be specific license
requirements which cover the items in 02.11, however, these essential
elements should be covered by licensee or certificate holder procedures.

If low level radioactive material is buried onsite, determine that it
meets the criteria contained in 10 CFR 20.2002, AMethod for obtaining
approval of proposed disposal procedures,@ and 10 CFR 20.2108, ARecords
of waste disposal.@ (Note: Prior to January 28, 1981, former regulatory
criteria contained in 10 CFR 20.304, Disposal by burial in soil,
permitted burial of small quantities of licensed/certificated materials
in soil without specific Commission authorization, but records of the
disposal were required to be maintained by former 10 CFR 20.401, Records
of disposal, until the Commission authorized their disposition.)

03.11 [Adequacy of Storage Area]{.underline}. Confirm that LLRW is
stored in a restricted area and is secured against unauthorized removal.
Check that waste containers are visible to allow routine inspection and
that they are readily accessible to licensee or certificate holder
personnel. Confirm that the placement or stacking of containers is
stable and that containers are not deformed under load, or likely to
fall. Determine that as low as reasonably achievable (ALARA)
considerations are used in the placement of the higher activity waste
containers in the storage area. Check that the storage area is posted in
accordance with 10 CFR Part 20 requirements.

Confirm that the containers are protected from reasonably expected
environmental conditions, including fire and flooding, and that the
storage location is not subject to extremes of temperature or humidity
(i.e., near a boiler room, laundry area, etc.). Check ventilation of the
storage area to determine if it is sufficient to prevent build‑up of any
gases produced by waste decomposition.

03.12 [Earthen (Surface) Waste Retention Systems]{.underline}.
Requirements should be stipulated in the license; the licensee or
certificate holder may refer to programs or controls contained in the
license application.

88035‑04 RESOURCE ESTIMATE

An inspection performed using this inspection procedure is estimated to
require 12 hours of inspector resources. This estimate is only for the
direct inspection effort and does not include preparation for and
documentation of the inspection. The estimate may vary depending on the
complexity of the waste streams and the amount of solid radioactive
wastes stored onsite.

88035‑05 REFERENCES

10 CFR Part 20, AStandards for Protection Against Radiation@

10 CFR Part 61, ALicensing Requirements for Land Disposal of Radioactive
Waste@

10 CFR part 71, APackaging and Transportation of Radioactive Material@

49 CFR Part 173, AShippers General Requirements for Shipments and
Packagings@

Federal Register, Vol. 48, No. 110, June 7, 1983, NRC Notice, ALow-level
Waste Licensing Branch Technical Position Papers on Radioactive Waste
Classification and Waste Form@

Federal Register, Vol. 56, No. 18, January 28, 1991, NRC Notice, AStaff
Technical Position on Radioactive Waste Form@

ATechnical Position on Radioactive Waste Classification,@ mailed to all
NRC licensees on May 11, 1983, by NMSS, Low‑Level Waste Management
Branch

AWaste Form Technical Position Paper,@ Revision 1, mailed to all NRC
licensees on January 24, 1991, by NMSS, Low‑Level Waste Management
Branch

Federal Register, Vol. 48, No. 175, Sept. 8, 1983; NRC Notice, ATopical
Reports in Support of the Implementation of Waste Classification and
Waste Form Requirements@

NRC Information Notice No. 89-13, AAlternative Waste Management
Procedures in Case of Denial of Access to Low-Level Waste Disposal
Sites,@ February 8, 1989

NRC Information Notice No. 90‑09, AExtended Interim Storage of Low‑Level
Radioactive Waste by Fuel Cycle and Materials Licensees,@ February 5,
1990

NRC Information Notice No. 93-50, AExtended Storage of Sealed Sources,@
July 8, 1993

END

ATTACHMENT 1

Revision History for IP 88035

+--------+-------+-----------------------+-----+-------+--------------+
| Comm   | Issue | Description of Change | Tr  | Tra   | Comment      |
| itment | Date  |                       | ain | ining | Resolution   |
| Tr     |       |                       | ing | Compl | Accession    |
| acking |       |                       | Nee | etion | Number       |
| Number |       |                       | ded | Date  |              |
+--------+-------+-----------------------+-----+-------+--------------+
| N/A    | 09/   | This document has     | N   | N/A   | ML061940414  |
|        | 25/06 | been revised to: (1)  | one |       |              |
|        |       | emphasize the         |     |       |              |
|        | CN    | risk-informed,        |     |       |              |
|        | 0     | performance-based     |     |       |              |
|        | 6-025 | approach to           |     |       |              |
|        |       | inspection, (2)       |     |       |              |
|        |       | impose changes to the |     |       |              |
|        |       | core inspection       |     |       |              |
|        |       | program based on      |     |       |              |
|        |       | operating experience, |     |       |              |
|        |       | and (3) remove        |     |       |              |
|        |       | completed or obsolete |     |       |              |
|        |       | MCs and incorporate   |     |       |              |
|        |       | other fuel cycle MCs  |     |       |              |
|        |       | into a central        |     |       |              |
|        |       | location.             |     |       |              |
+--------+-------+-----------------------+-----+-------+--------------+
|        |       |                       |     |       |              |
+--------+-------+-----------------------+-----+-------+--------------+
|        |       |                       |     |       |              |
+--------+-------+-----------------------+-----+-------+--------------+

[^1]: When license is mentioned, it refers to license or certificate.

    QA activities related to implementation of 10 CFR Part 61, 10 CFR
    20.2006, and Appendix G to 10 CFR Part 20 are not required to be
    included under the licensee or certificate holder\'s corporate level
    QA program for \"Nuclear Safety Related\" items.