**NRC INSPECTION MANUAL** FSME/DWMEP

INSPECTION PROCEDURE 84850

RADIOACTIVE WASTE MANAGEMENT - INSPECTION OF WASTE

GENERATOR REQUIREMENTS OF 10 CFR PART 20 AND 10 CFR PART 61

PROGRAM APPLICABILITY: 2561, 2600 and 2800

84850-01 INSPECTION OBJECTIVE

To determine whether the licensee as a waste generator, in accordance
with 10 CFR Part 20, Appendix G, has established and is maintaining
adequate management-controlled procedures and quality assurance that
reasonably ensure compliance with the requirements of 10 CFR Part 20 and
10 CFR Part 61 applicable to low-level radioactive waste form,
classification, characterization, stabilization, and shipment
manifests/tracking.

84850-02 INSPECTION REQUIREMENTS

02.01 [Management Controls]{.underline}. Review the licensee\'s written
procedures and documents for radioactive waste processing and disposal,
specifically identifying the primary documentation thereof. Verify that
the following aspects are adequately addressed:

> a\. That the individual(s) and organizational entities that have been
> assigned the responsibility for radioactive waste processing for
> eventual land disposal per 10 CFR Part 61 have been clearly designated
> in writing;
>
> b\. That there has been a clear delineation of the authorities and
> responsibilities of those individuals and organizational entities;
>
> c\. That written management-approved instructions have been
> established to carry out the various radioactive waste processing,
> disposal, and packaging activities, including authorized changes
> thereto, and the promulgation/distribution of such instructions to the
> appropriate line/staff organization.
>
> d\. That there is an unambiguous procedure or process by which the
> licensee as a licensed processor or user of radioactive material
> becomes a "waste generator" in accordance with Appendix G of 10 CFR
> Part 20.

02.02 [Quality Assurance (QA)]{.underline}. Verify that the licensee has
established and maintains an adequate QA program to ensure compliance
with the waste classification and characterization requirements of 10
CFR 61.55 and 61.56. Verify 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 \[Subsection III.A.3 of
Appendix G to 10 CFR Part 20\].

For nuclear power plant licensees, 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\'s
corporate level QA program for \"Nuclear Safety Related\" items.

02.03 [Waste Manifests]{.underline}. Review the licensee\'s procedures
and records to verify that each shipment of radioactive waste, intended
for eventual land disposal per 10 CFR Part 61, to a broker or a licensed
land disposal facility is accompanied by a shipment manifest that
includes all the required information \[10 CFR 20.2006(b) and (c)\].

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

02.05 [Waste Form and Characterization]{.underline}. Review the
licensee\'s documentation and records of activities, which have been
established and are being maintained, to ensure that all low-level
radioactive waste meets the waste characteristics of 10 CFR 61.56.
Verify whether the methods and determinations of the licensee provide
[reasonable]{.underline} assurance that the waste form requirements are
met \[Subsection III.A.1 of Appendix G to 10 CFR Part 20\].

02.06 [Waste Shipment Labeling]{.underline}. Review the licensee\'s
procedures and records to verify that 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\].

02.07 [Tracking of Waste Shipments]{.underline}. Review the licensee\'s
procedures and records, to verify that 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. Verify that acknowledgment of
receipt of the manifest is obtained. Verify that the licensee has a
procedure in place to effect an investigation in any instances wherein
acknowledgment of receipt of shipment has not been received within the
specified period. Verify that procedures are in place to report such
investigations to the appropriate U.S. Nuclear Regulatory Commission
(NRC) Regional Office and file the required written report. \[Subsection
III of Appendix G to 10 CFR Part 20\].

02.08 [Disposal Site License Conditions]{.underline}. Review the
licensee\'s procedures and records to verify that the applicable
disposal site license conditions are being met. Verify that the licensee
has on file current versions of applicable disposal site licenses.

84850-03 INSPECTION GUIDANCE

Guidance for inspectors as well as licensees has been provided by Low
Level Waste Management Branch/Nuclear Material Safeguard and (NMSS) in
the form of branch technical positions (BTPs) on \"Waste
Classification,\" dated May 1983 (see [Federal Register]{.underline},
Vol. 48, No. 110, June 7, 1983), and \"Waste Form,\" dated January 1991
(see [Federal Register]{.underline}, Vol. 56, No. 18, January 28, 1991).
In addition to the BTPs, NMSS

(antecedent of FSME) has stated publicly (48 FR 40512, Vol. 48, No. 175,
September 8, 1983) that \"topical reports\" of licensees that have been
reviewed by NMSS may be useful in demonstrating compliance with the
requirements. Inspectors should be aware of and may accept results
referenced in such topical reports as demonstration of compliance in
specific inspection cases.

03.01 [Specific Guidance]{.underline}

> a\. [Inspection Requirement 02.01, Management Controls]{.underline}.
> Inspection effort should be directed at verifying that written
> procedures have been established in a manner approved by management.
> 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 or waste
> processors. The inspector should confirm that the written procedures
> include provisions for all of the applicable activities pertaining to
> Section 84850-02 requirements.
>
> b\. [Inspection Requirement 02.02, Quality Assurance
> (QA)]{.underline}. The written operating procedures and QA procedures
> of the licensee 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\'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 to perform the required waste form classification
> and characterizations when [changes]{.underline} to the waste stream
> occur. Inspectors should also observe the records to verify they are
> legible, accurate, and complete throughout the specified retention
> period.
>
> c\. [Inspection Requirement 02.03, Waste Manifests]{.underline}.
> Inspectors should be aware that it is permissible for the licensee to
> use the same shipping paper documents that are required to meet U.S.
> Department of Transportation shipping paper and U.S. Environmental
> Protection Agency hazardous waste requirements, as the
> [waste-manifest]{.underline}, provided that the combined documentation
> contains all of the information required by Appendix G to 10 CFR Part
> 20. Inspectors should ascertain that licensee is aware that additional
> waste manifest information may also be required by the operator of the
> land disposal facility.
>
> d\. [Inspection Requirement 02.04, Waste Classification]{.underline}.
> The inspector should review whether the [method]{.underline} used by
> the licensee is adequate to determine radionuclide concentrations, in
> order to classify the waste. The BTP on waste classification describes
> four acceptable methods for classifying wastes. The inspector should
> use this BTP as the basic guidance in implementing this inspection
> requirement.
>
> 1\. For those licensees who use correlation factors for classifying
> wastes, correlation factors should be based on actual waste stream
> analysis.
>
> 2\. Generic pressurized water reactor, boiling-water reactor or
> facility scaling factors are acceptable if actual sample analysis data
> correlate with the generic data base.
>
> 3\. If generic scaling factors are not appropriate for an individual
> waste stream, scaling factors should be based on the specific waste
> stream data.
>
> 4\. It is acceptable to base correlation factors on a single set of
> analyses, repeated annually.
>
> 5\. If sample analyses have not been completed, calculational methods
> for scaling factors are acceptable while analyses are in progress.
> Samples should be off site for analysis to be considered in progress.
> After receipt of the sample analyses, calculational methods may
> continue to be used provided the results correlate with the actual
> sample analyses.
>
> 6\. NRC-approved topical reports for waste classification are
> acceptable for demonstrating compliance with 10 CFR 61.55.
>
> e\. [Inspection Requirement 02.05, Waste Form and
> Characterization]{.underline}. The inspector should determine the test
> methods and acceptability of such tests used by the licensee to
> characterize his 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 BTP on waste form as the basic guidance in implementing this
> inspection requirement. In addition:
>
> 1\. 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 must be consistent with
> disposal site license conditions.
>
> 2\. The licensee\'s solidification process control program should
> incorporate the testing information from the solidification agent
> stability qualification.
>
> 3\. NRC-approved topical reports on high integrity containers and
> solidification agents are acceptable for demonstrating compliance with
> 10 CFR 61.56(b).
>
> 4\. A Certificate of Compliance issued by an Agreement State for a
> high integrity container is acceptable for demonstrating compliance
> for waste shipped to a licensed disposal facility in that State.
>
> f\. [Inspection Requirement 02.06, Waste Shipment
> Labeling]{.underline}. Inspectors as well as the licensee should be
> aware that Classes A, B, & C [wastes]{.underline} bear no relationship
> to Types A or B [packaging]{.underline} 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.

g.  [Inspection Requirement 02.07, 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]{.underline}, as opposed to shipments directly to land
    disposal facilities. There are also some differences in the specific
    requirements of a waste collector who [processes]{.underline} the
    waste before shipping it to the disposal facility, as contrasted
    with a collector who simply [stores]{.underline} the material before
    transferring it to the land disposal facility.

84850-04 REFERENCES

04.01 [Regulations]{.underline}

10 CFR Part 61

10 CFR 20.1001 - 20.2402

10 CFR Part 20 Appendix G

04.02 [Other References]{.underline}

[Federal Register]{.underline}, Vol. 48, No. 110, June 7, 1983, NRC
Notice, \"Low-level Waste Licensing Branch Technical Position Papers on
Radioactive Waste Classification and Waste Form; Availability.\"

[Federal Register]{.underline}, Vol. 56, No. 18, January 28, 1991, NRC
Notice, \"Staff Technical Position on Radioactive Waste Form;
Availability.\"

\"Technical Position on Radioactive Waste Classification,\" mailed to
all NRC licensees on May 11, 1983, by NMSS, Low-level Waste Management
Branch.

\"Waste Form Technical Position Paper, Revision 1,\" mailed to all NRC
licensees on January 24, 1991, by NMSS, Low-level Waste Management
Branch.

[Federal Register]{.underline}, Vol. 48, No. 175, Sept. 8, 1983; NRC
Notice \"Topical Reports in Support of the Implementation of Waste
Classification and Waste Form Requirements.\"

END

Attachment 1

Revision History for 84850

+--------+--------+--------------------+------+----------+--------------+
| Comm   | Issue  | Description of     | Trai | Training | Comment      |
| itment | Date   | Change             | ning | Co       | Resolution   |
| Tr     |        |                    | Ne   | mpletion | Accession    |
| acking |        |                    | eded | Date     | Number       |
| Number |        |                    |      |          |              |
+--------+--------+--------------------+------+----------+--------------+
| N/A    | 12     | Completed 4 year   | none | N/A      | ML081990455  |
|        | /22/08 | historical search  |      |          |              |
|        |        | and found no       |      |          |              |
|        | CN     | commitments.       |      |          |              |
|        | 08-037 |                    |      |          |              |
|        |        | The revision       |      |          |              |
|        |        | changed document   |      |          |              |
|        |        | ownership to FSME, |      |          |              |
|        |        | added a new        |      |          |              |
|        |        | management         |      |          |              |
|        |        | control, included  |      |          |              |
|        |        | minor              |      |          |              |
|        |        | modifications to   |      |          |              |
|        |        | allow flexibility  |      |          |              |
|        |        | in meeting         |      |          |              |
|        |        | disposal site      |      |          |              |
|        |        | requirements, and  |      |          |              |
|        |        | added a reference  |      |          |              |
|        |        | to 10 CFR Part 20  |      |          |              |
|        |        | Appendix G.        |      |          |              |
+--------+--------+--------------------+------+----------+--------------+