Number range CHAPTER **NRC INSPECTION MANUAL** NMSS/DWM

INSPECTION PROCEDURE 84100

SPECIAL NUCLEAR MATERIAL INSPECTIONS AT NEAR SURFACE LOW-LEVEL WASTE
DISPOSAL FACILITIES IN AGREEMENT STATES

NOTE: This document was last reviewed on 10/05/01 (last revision was
05/29/92). Since NRC is not currently engaged in the activities
addressed in this document, no revision is deemed necessary at this
time. The document will be maintained in its original form until NRC
program changes warrant an update of the document coincident with NRC
requirements and policy for NRC use.

PROGRAM APPLICABILITY: MC 2401

This inspection procedure is applicable to the disposal of low-level
radioactive waste (LLW) containing special nuclear material (SNM) at
near-surface disposal facilities in Agreement States (AS\'s). The AS
licenses the disposal of byproduct and source material, and the Nuclear
Regulatory Commission (NRC) licenses only the disposal of SNM in
quantities greater than those exempted by 10 CFR Part 150. The
objectives of NRC in regulating SNM disposal are the maintenance of
criticality safety and the safeguarding of SNM from diversion. The AS
regulatory agency retains its responsibility for inspecting for all
other aspects of radiological safety concerned with the near-surface
disposal of LLW except for criticality safety and the safeguarding from
diversion of SNM.

The inspector will carefully document all violations observed whether or
not those violations are under enforcement by the AS: decisions by the
region concerning issuance of Notice of Violation or imposition of civil
penalty shall conform to Section 6.5.1 [State Enforcement
Action]{.underline} (Supplement V - Transportation) of the NRC
Enforcement Manual for all documented violations whether or not related
to transportation.

84100-01 INSPECTION OBJECTIVES

This procedure addresses licensee staff qualifications and training,
waste form and classification, site operations, radiation protection,
accountability, criticality prevention, and procedures for near-surface
disposal of SNM.

The objectives of this inspection procedure are to ensure that:

01.01 The licensee\'s activities are conducted safely, avoiding the
possibility of a criticality accident;

01.02 The licensee has staff that are properly trained and qualified to
comply with SNM criticality requirements and security provisions;

01.03 The licensee is providing accountability in accordance with
license conditions for the types and quantities of SNM being held for
disposal at the facility, and that records of previous disposals are
being maintained properly;

01.04 The licensee has appropriate physical security and emergency
planning in accordance with license conditions.

84100-02 INSPECTION REQUIREMENTS

02.01 [SNM Safety Verification]{.underline}. Verify, by means of
observations of operations, personnel interviews and records review,
including reports of recent AS inspections, the means by which the
licensee complies with license conditions directed at criticality
safety, accountability, waste form, and waste classification of SNM.
These include, but are not necessarily limited to:

a.  Licensee\'s means of verification that waste shipments entering the
    site comply with license requirements for maximum SNM content of
    packages and accumulations of packages.

b.  Licensee\'s procedures to ensure that SNM packages are off-loaded
    and handled in a manner to ensure compliance with criticality safety
    requirements of the license.

c.  Licensee\'s procedures to ensure that personnel, equipment and
    vehicles that have been used for SNM management have been
    radiologically surveyed and decontaminated properly before release
    from the facility.

d.  Licensee\'s means of ensuring that any stored waste packages
    containing SNM are stored in a configuration and location necessary
    to ensure criticality safety consistent with requirements of the
    license.

e.  Licensee\'s methods of emplacement for disposal and of disposal of
    SNM waste are consistent with license conditions for criticality
    safety.

f.  Licensee\'s means of safely handling SNM packages that have been
    damaged, tampered with, improperly packaged or are of improper waste
    form, and the means by which the licensee provides timely and
    effective notification of such events to NRC and the waste
    generator.

g.  Status and organization of licensee\'s records related to
    criticality safety and accountability, including records related to
    disposition of SNM packages, and accumulations of SNM in disposal
    units.

h.  Licensee\'s means of tracking shipments to identify lost SNM
    shipments, including notification to NRC and the shipper.

The inspector should ensure that SNM containers accepted by the licensee
meet the general packaging conditions of the license, along with the
requirements of 10 CFR 20.311 (Appendix F to 10 CFR 20.1001 - 20.2401,
as appropriate). The inspection should include, but need not be limited
to, the examinations described below.

Undisposed containers of SNM waste should be examined and compared to
their manifests, to ensure that wastes have been classified and labeled
properly, according to 10 CFR 61.55 and 10 CFR 61.57, and that the
shipper\'s classification has been verified by the licensee before
acceptance of the waste for disposal. A random sampling of records on
file should likewise confirm the licensee\'s continuing practice of
verifying waste classification and labeling before acceptance of
shipments for disposal. Containers should also be examined to determine
their conformance with waste-form requirements of regulations and
license conditions, and records should be examined to confirm the
licensee\'s practice of verifying waste-form requirements before
acceptance of a shipment for disposal. Containers containing SNM waste
should be intact and tightly covered. The inspector should randomly
check SNM containers awaiting disposal to ensure that they are intact
and that the container or accumulation of containers contain quantities
of SNM less than the authorization limits contained in the license
conditions. The inspector should also ensure that the placement of the
containers complies with license conditions and other requirements for
criticality safety.

02.02 [Procedures and Training]{.underline}. Verify that
management-approved procedures conforming to license conditions are
available to all personnel handling SNM and that the procedures
containing criticality safety and security requirements are available
for operations. Discuss procedural requirements with selected operations
personnel to ascertain their familiarity with the procedure. Determine
that the operating procedures have been prepared or revised and reviewed
by the licensee management, and that the licensee has an approved method
for establishing, revising, and reviewing operating procedures that
incorporate criticality safety limits and security requirements.

Also verify that the procedures cover both normal operations and
accidents or other potential abnormal conditions. Examine records to
verify that the operators have been trained and periodically retrained
in the procedures in accordance with license conditions for the conduct
of training. Observe operations to ascertain that procedures are being
followed. If operations are not underway at the time of inspection,
select operations personnel to walk through some operations activities.

02.03 [Audits]{.underline}. Review any audits done by the licensee on
its operations of the facility since the prior inspection. Discuss with
the licensee any abnormal occurrences that may have had an impact on
criticality safety. Verify that corrective actions were taken and that
they were effective in those areas of interest at the facility. Discuss
with the licensee any breach of procedures found during audits of
operations. Failure to follow SNM-oriented procedures may include, but
not be limited to improper handling and placement for disposal, or
improper storage before disposal. Verify that corrective actions are
indicated in the audit reports and that open items from previous audits
have been attended to. Examine procedures to determine if any changes
were made as a result of deficiencies found, and if the lessons learned
have been incorporated in the training program.

02.04 [Physical Security]{.underline}. The inspector should determine if
the physical security of SNM at the site complies with the license
conditions, is subjected to periodic review, and that revisions are
promptly communicated to NRC Headquarters and to the region in
accordance with license conditions.

84100-03 INSPECTION GUIDANCE

03.01 [SNM Safety Verification]{.underline}. Criticality safety is not
likely to be a major safety issue at LLW facilities, given the
quantities and concentrations of SNM that a licensee will receive, in
accordance with the license limitations. However, the licensee must be
capable of confirming criticality safety within constraints of the SNM
license and of confirming that license constraints are being met by
waste generators. To the extent practicable, implementation of
procedures pertinent to SNM should be physically examined or observed.

03.02 [Procedures and Training]{.underline}. Operating procedures should
be written so that the operators can easily understand them. The
procedures should provide clear directions for the various process steps
and must include criticality safety considerations, as appropriate, for
the processes. In addition, the procedures should clearly indicate to
operators how to recover from accidents or other abnormalities.
Management should ensure proper employee training in accordance with
license conditions in the use of approved procedures. The inspector
should pay particular attention to the qualifications and training of
newly hired licensee personnel and should interview these personnel to
ascertain the adequacy of their knowledge and understanding of safety
and operating procedures. The inspector should also verify that when
licensee personnel trained in SNM procedures are absent, only licensee
employees comparably trained in SNM procedures are substituted in the
place of the absent employees.

03.03 [Physical Security]{.underline}. The review of security plans and
procedures should be limited to actions related to the SNM on site and
should be concerned with any degradation of the required physical
security. The adequacy of site security should be subjected to periodic
review, preferably on an annual basis, and revisions made to security
procedures should be promptly communicated to NRC Headquarters and to
the Region in accordance with license conditions.

84100-04 REFERENCES

04.01 [Regulations]{.underline}

10 CFR Part 19

10 CFR Part 20

10 CFR Part 61

10 CFR Part 70

10 CFR Part 71

10 CFR Part 73

10 CFR Part 150

04.02 [Other References]{.underline}

Federal Register, Vol. 56, No. 18, January 28, 1991, p. 3123, Notice of
Availability, \"Technical Position on Waste Form (Revision 1).

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

Federal Register, 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.\"

\"Final Waste Classification and Waste Form Technical Position Papers,\"
mailed to all NRC licensees on May 11, 1983, by NMSS, Low-Level Waste
Licensing Branch.

Approach for NRC Licensing of Special Nuclear Material Waste Disposal at
Agreement State Licensed Low-Level Waste Disposal Facilities, Malcolm R.
Knapp, Director, Office of Nuclear Material Safety and Safeguards.
Proposed August 8, 1988; approved September 30, 1988.

NRC Enforcement Manual, 6.5 Supplement V - [Transportation]{.underline},
6.5.1 [State Enforcement Action]{.underline}.

END