**NRC INSPECTION MANUAL** DQASIP

INSPECTION PROCEDURE 84524

GASEOUS WASTE SYSTEM

(PREOPERATIONAL AND SUPPLEMENTAL)

PROGRAM APPLICABILITY: 2513, 2515, and 2525

84524‑01 INSPECTION OBJECTIVE

To determine whether the gaseous waste system is as described in the
FSAR; whether the applicant has conducted preoperational tests of waste
systems to verify their operability; whether the applicant\'s effluent
and process monitoring program is adequate and conforms with the FSAR
description; whether procedures, instrumentation, and equipment to
sample and handle radioactive gases and particulates are adequate and
operational under accident conditions; and whether preoperational,
startup, and operational procedures have been written and approved.

84524‑02 INSPECTION REQUIREMENTS

02.01 [Construction and Installation]{.underline}. Verify that the
gaseous waste system is built and installed as described in the FSAR and
that gaseous waste system components have been adequately shielded.

02.02 [Sampling]{.underline}. Determine adequacy of sampling systems for
normal operations and of post‑accident sampling of containment air.

02.03 [Test Program]{.underline}. Determine whether the testing program
for the gaseous waste management system is adequate and observe the
performance of preoperational tests of the waste management systems.

02.04 [Test Completion]{.underline}. Verify that appropriate tests of
the waste gas, purge, and ventilation systems have been completed.

02.05 [Process and Effluent Monitors]{.underline}. Determine adequacy of
installation, calibration, and testing of process and effluent monitors
for gases and airborne particles.

02.06 [Programs, Plans, and Procedures]{.underline}. Determine adequacy
of the applicant\'s documented programs, plans, and procedures for
normal operations.

84524‑03 INSPECTION GUIDANCE

03.01 [Construction and Installation]{.underline}

> a\. Comparison of the systems as built and installed with the
> description in the FSAR may include:
>
> 1\. Type, quantity, and capacity of components and systems.
>
> 2\. Waste gas decay tanks, offgas system, stacks, ventilation system,
> standby gas treatment system (BWR), containment purge (PWR), etc.
>
> 3\. Inputs to the waste gas header (PWR).
>
> 4\. System relief valves‑‑setpoints and release pathways.
>
> b\. Any changes should be supported by an FSAR amendment or an
> evaluation demonstrating that the change does not alter the technical
> content of the FSAR.
>
> c\. Regulatory Guide 1.143 and ANSI/ANS 55.4‑1979 recommend that the
> design, construction, and operation of the gaseous radwaste processing
> system be such that radiation exposures to plant personnel be
> maintained ALARA.

03.02 [Sampling]{.underline}

> a\. Consideration of continuous sampling and monitoring may include
> isokinetic probes, prevention of moisture or condensation, and sample
> line deposi­tion.
>
> b\. Sample collection points should be easily accessible and properly
> shielded and should be properly ventilated.
>
> c\. Guidance on sampling airborne radioactive materials in nuclear
> facilities to obtain representative samples is given in ANSI
> N13.1‑1969 (R 1982). Provision for purging sample lines should be
> included in the system.
>
> d\. A list of typically required sampling locations is provided in
> Standard Review Plan Section 11.5. Review of the adequacy of sample
> collection systems for routine grab samples may include consideration
> of:
>
> 1\. Normal nonradioactive systems, buildings, (e.g., PWR turbine
> building ventilation), and instrument air systems.
>
> 2\. Normal ventilation systems ‑ upstream of filters.
>
> 3\. Purge of sample lines back to source or waste system in off‑gas
> system.
>
> e\. 1. Use the applicable guidance above in examining the licensee\'s
> post‑accident sampling system. See also NUREG‑0737, Items II.B.2 and
> II.B.3 and the licensee\'s Emergency Plan and Implementation
> Procedures.
>
> 2\. Consider other specifications applicable to the Post‑Accident
> Sampling System (NUREG‑0737, Item II.B.3, Clarification Item 11).
> There should be provisions for:
>
> \(a\) Purging sample lines.
>
> \(b\) Reducing plateout in sample lines.
>
> \(c\) Minimizing sample loss or distortion.
>
> \(d\) Preventing blockage of sample lines.
>
> \(e\) Appropriate disposal of samples.
>
> \(f\) Samples shall be representative of the containment atmosphere.
>
> \(g\) Sample lines should be as short as possible to minimize the
> volume of fluid taken from containment.
>
> \(h\) If inline monitoring is used, the licensee must provide backup
> sampling through grab samples.
>
> \(i\) Ventilation exhaust from sampling station should be filtered.
>
> 3\. Consider the adequacy of shielding of the sampling station, which
> is considered a vital area in case of an accident.
>
> 4\. Consider the adequacy of procedures for taking, handling, and
> transporting samples safely.
>
> 5\. Laboratory analyses are covered in IP 84525.

03.03 [Test Program]{.underline}

> a\. The applicant should have a detailed test program for the radwaste
> system including:
>
> 1\. Detailed test procedures.
>
> 2\. Test prerequisites (inspections, checks, etc., and a sign‑off).
>
> 3\. Flushing, cleaning, wiring checks, leak tightness tests.
>
> 4\. Requirement for initial calibration of instrumentation before
> system testing.
>
> b\. The applicant should have a program covering review, evaluation,
> and approval of test results including:
>
> 1\. Review by a qualified individual.
>
> 2\. Evaluation and acceptance criteria.
>
> c\. Witness one or more tests if convenient. (Do not make extra
> inspection trips for this purpose.) Determine whether the tests are
> being performed in accordance with test program requirements.

03.04 [Test Completion]{.underline}

> a\. Operational performance tests of ventilation and purge systems
> should include:
>
> 1\. Verification of design air flows and differential pressures.
>
> 2\. Tests of efficiency and retention for HEPA filters and charcoal
> adsorbers (Regulatory Guides 1.52 and 1.140).
>
> b\. Operational performance tests of waste gas systems (Regulatory
> Guide 1.68) should demonstrate the functional capability and design
> flow rates of systems and components and should include:
>
> 1\. BWR off‑gas system: recombiners, holdup times, charcoal adsorbers,
> loop seals.
>
> 2\. PWR waste‑gas system: vent header, waste gas surge and decay tank
> relief valves.
>
> c\. Tests to demonstrate the capability to obtain representative
> samples should include:
>
> 1\. Verification of sample line input.
>
> 2\. Operability of purge and recycle of sample lines.
>
> 3\. Consideration of the guidance in ANSI N13.1.
>
> d\. Tests of the isolation features for ventilation and waste gas
> systems should include verification that auto‑isolation fails in the
> closed position.

03.05 [Process and Effluent Monitors]{.underline}

> a\. Requirements for calibration are normally included in the
> technical specifications. Guidance on calibrations is provided in
> Regulatory Guides 1.21 and 4.15. For the high range noble gas effluent
> monitor, see NUREG‑0737, Item II.F.1, Attachment 1 and the August 16,
> 1982 letter from D. G. Eisenhut.
>
> b\. The installation of selected gaseous process and all effluent
> monitors (radiation, flow rate, differential pressure, alarm) that are
> included in the FSAR should be verified. A list of monitors typically
> required is included in Standard Review Plan Section 11.5. See also
> NUREG‑0737, Item II.F.1, Attachment 2.
>
> c\. Monitoring instruments and their locations should provide for
> representa­tive monitoring with adequate detection capability,
> sensitivity, and range. (See technical specifications, ANSI N13.1, and
> Regulatory Guide 1.97 for accident monitors and samples).
>
> d\. Calibration of monitors should include consideration of collection
> efficiencies for sampling media (e.g., charcoal cartridges).
>
> e\. Functional tests should be performed on all monitoring systems
> including tests of alarms, setpoints, and auto‑isolation.
>
> f\. All potential radioactive release paths should be monitored and/or
> sampled (IE Bulletin No. 80‑10).
>
> g\. Installation, calibration and functional testing of appropriate
> hydrogen and oxygen analyzers should be verified. These analyzers
> include the BWR off‑gas system hydrogen analyzer and the PWR waste‑gas
> system oxygen analyzer. Technical specifications address concentration
> limits and calibration requirements.

03.06 [Programs, Plans, and Procedures]{.underline}

> a\. Relevant procedures are listed in Appendix A of Regulatory Guide
> 1.33; these procedures are usually required by the technical
> specifications.
>
> b\. Procedures for gaseous releases to the environment should include
> release rates, alarm and trip setpoints, laboratory analysis results,
> compliance with technical specification limits, total activity
> released, total volume released, valve lineups, and appropriate review
> and approvals. Alarm and trip action setpoints for each release point
> should be determined in accordance with the ODCM.
>
> c\. Procedures for sampling and analysis should specify types of
> samples to be collected, the analysis to be performed on each sample,
> and the appropriate sampling and analysis schedules.
>
> d\. There should be procedures for routine calibration and
> surveillance tests of all instrumentation.
>
> e\. The applicant should have a plan/program or routine maintenance
> (including preventive maintenance) to ensure availability of equipment
> under accident conditions and to maintain releases ALARA.
>
> f\. The applicant should have a program for evaluating system
> performance including:
>
> 1\. Efficiency evaluation.
>
> 2\. Identification of need for corrective action.
>
> 3\. Verification of system operation as designed.
>
> g\. Procedures should address system use under abnormal (accident)
> conditions.
>
> h\. Procedures should be clear on division of responsibilities and
> lines of communications among different organizational units (e.g.,
> radwaste operations/management and radiation protection) involved in
> radwaste operations.

84524‑04 REFERENCES

Standard Review Plan Section 11. 3, \"Gaseous Waste Management
Systems,\" and Section 11.5, \"Process and Effluent Radiological
Monitoring Instrumentation and Sampling Systems,\" NUREG‑0800.

Regulatory Guide 1.21, \"Measuring and Reporting Radioactivity in Solid
Wastes and Releases of Radioactive Materials in Liquid and Gaseous
Effluents from Light‑Water‑Cooled Nuclear Power Plants.\"

Regulatory Guide 1.33, \"Quality Assurance Program Requirements
(Operations).\"

Regulatory Guide 1.52, \"Design, Testing, and Maintenance Criteria for
Post‑Accident Engineered Safety Feature Atmosphere Cleanup System Air
Filtration and Adsorption Units of Light‑Water‑Cooled Nuclear Power
Plants.\"

Regulatory Guide 1.68, \"Initial Test Programs for Water‑Cooled Nuclear
Power Plants.\"

Regulatory Guide 1.97, \"Instrumentation for Light‑Water‑Cooled Nuclear
Power Plants to Assess Plant Conditions During and Following an
Accident.\"

Regulatory Guide 1.140, \"Design, Testing, and Maintenance Criteria for
Normal Ventilation Exhaust System Air Filtration and Adsorption Units of
Light‑Water‑Cooled Nuclear Power Plants.\"

Regulatory Guide 1.143, \"Design Guidance for Radioactive Waste
Management Systems, Structures, and Components in Light‑Water‑Cooled
Nuclear Reactor Power Plants.\"

Regulatory Guide 4.15, \"Quality Assurance for Radiological Monitoring
Programs (Normal Operations) ‑ Effluent Streams and the Environment.\"

NUREG‑0472, \"Radiological Effluent Technical Specifications for PWRs,\"
February 1980.

NUREG‑0473, \"Radiological Effluent Technical Specifications for BWRs,\"
July 1979.

NUREG‑0737, \"Clarification of TMI Action Plan Requirements,\" November
1980, and Supplement 1 (1982).

ANSI N13.1‑1969 (R 1982), \"Guide to Sampling Airborne Radioactive
Materials in Nuclear Facilities.\"

ANSI N42.18‑1980 (Reaffirmation and Redesignation of ANSI N13.10‑1974),
\"Specification and Performance of Onsite Instrumentation for
Continuously Monitoring Radioactivity in Effluents.\"

ANSI/ANS‑N55.4‑1979, \"Gaseous Radioactive Waste Processing Systems for
Light‑Water Reactor Plants.\"

ANSI/ASME N509‑1980, \"Nuclear Power Plant Air‑Cleaning Units and
Components\" (revision of ANSI/ASME N509‑1976).

ANSI/ASME N510‑1980, \"Testing of Nuclear Air‑Cleaning Systems\"
(revision of ANSI/ASME N510‑1975).

IE Bulletin No. 80‑10, \"Contamination of Non‑Radioactive System and
Potential for Unmonitored, Uncontrolled Release to Environment.\"

IE Information Notice No. 82‑43, \"Deficiencies in LWR Air
Filtration/Ventilation Systems,\" November 16, 1982.

IE Information Notice No. 82‑49, \"Correction for Sample Conditions for
Air and Gas Monitoring,\" December 16, 1982.

\"Proposed Guidance for Calibration and Surveillance Requirements for
Equipment Provided to Meet Item II.F.1, Attachments 1, 2, and 3,
NUREG‑0737,\" memorandum from D. G. Eisenhut, NRR, to Regional
Administrators, August 16, 1982, with enclosures.

END