Number range CHAPTER **NRC INSPECTION MANUAL** CHPB

INSPECTION PROCEDURE 84527

PART 52, SOLID WASTE MANAGEMENT SYSTEM

PROGRAM APPLICABILITY: 2504

84527-01 INSPECTION OBJECTIVE

01.01 To verify that the components and installation of the solid waste
management system (SWMS) are built and installed as designed.

01.02 To determine that the licensee has tested the SWMS and the results
of the tests verify that it operates as intended.

01.03 To verify that the licensee has management programs in place to
ensure proper operation and maintenance of the SWMS.

84527-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 [Regulatory Basis and Background]{.underline}. The SWMS handles
radioactive wastes produced during normal operation. The SWMS includes
design features that are necessary for collecting, handling, processing,
storing, and disposal of wastes, and may rely on mobile equipment and
subsystems connected to permanently installed plant systems and
structures. This procedure is used to determine the readiness of the
SWMS, and whether the effluents produced by the SWMS meet regulatory
requirements for disposal, as defined by the Process Control Program
(PCP).

The PCP and associated plant technical specifications (TS) identify all
regulatory requirements, follow NRC guidance, and contain all
appropriate operational elements of the SWMS. (The regulatory
requirements are associated with 10 CFR Parts 61.55 and 61.56 for waste
classification and characteristic, in 10 CFR Part 20.2006 on the
characterizations of waste in shipping manifests; 10 CFR Part 20.2007 as
it relates to other applicable Federal, State, and local regulations
governing the presence of any other toxic or hazardous materials; NRC
and DOT shipping regulations under 10 CFR Part 71 and 49 CFR Parts 171 -
180; and waste acceptance criteria of authorized disposal facilities or
waste processors.)

The PCP describes, given specific waste processing technologies and
methods, a set of process parameters which are used to process wastes.
The PCP should identify surveillance requirements consistent with the
plant\'s TS, administrative procedures, operational procedures, quality
assurance and quality control, radiological controls and monitoring,
information to be contained in annual radiological effluent release
report, reporting requirements to NRC, instructions on the use of the
NRC\'s uniform radioactive shipping waste manifest, and process for
initiating and documenting changes to the PCP and its supporting
procedures.

02.02 [Definition of Solid Waste Management System]{.underline}. In
accordance with the guidance of Regulatory Guide 1.143, the boundary of
the SWMS begins at the interface from plant systems provided for the
collection of process streams and radioactive wastes to the points of
controlled discharge to the environment as defined in the PCP and/or
Offsite Dose Calculation Manual (ODCM), at the point of recycling to
primary or

secondary water system storage tanks, or to within plant facilities used
for the storage of radioactive wastes and mixed wastes.

02.03 [Construction and Installation of the SWMS]{.underline}. Determine
that the Solid Waste Management System is built as designed and ready to
operate under normal and emergency conditions. Verify that the SWMS
components, sampling and monitoring points, piping, mobile subsystems,
and waste storage areas are adequately shielded for safe operations.

a\. Verify that the SWMS is constructed as designed. Review the system
piping and instrumentation diagrams (P&IDs), process and effluent
radiation monitoring and control instrumentation and sampling systems
for process streams. Also review the process flow diagrams showing the
methods of operation (including equipment design capacities),
interconnections between plant subsystems (e.g., ventilation, service
water, equipment drains, electrical, etc.), mobile processing equipment,
alternate processing methods, principal parameters assumed in the
operation of the SWMS. Evaluate the appropriate use of such information
in the development of the PCP.

b\. Compare the system as built and installed with the description in
the most recent FSAR and Design Certification Document (DCD). Evaluate
the type, quantity and capacity of components, and subsystems including
mobile and vendor supplied components and subsystems that may not be
described in the FSAR. Confirm that the design, fabrication,
procurement, construction, and installation of permanently installed or
mobile liquid waste management systems and components are built
according to the licensee\'s QA program, and the standards specified in
Regulatory Guides 1.21, 1.33, 1.143, and 4.15, and Standard Review Plan
Section 17.5 to the extent of control required by Appendix B to 10 CFR
Part 50. Additional standards and technical guidance can be found in
ANSI/ANS 55.1-1992, ANSI/ANS 55.6 - 1999, Standard Review Plan (SRP)
Section 11.4 (includes Branch Technical Positions 11-3 and 11.4 that
address design guides for SWMS and temporary waste storage facilities)
and SRP Section 11.5. Any changes to the SWMS should be supported by an
FSAR amendment or a 10 CFR Part 50.59 evaluation demonstrating that the
change does not violate 10 CFR 50.59.

c\. Determine that the licensee's SWMS has in place adequate design
solutions to meet the design criteria specified in Section B.I through V
in Attachment A of SRP 11.4. These criteria apply to the processing of
dry and wet wastes, assurance of complete waste stabilization,
solidification (if used), dewatering, waste storage, portable solid
waste systems, and other additional design features.

d\. Confirm the incorporation of special design features and operational
procedures to prevent, control, and collect releases of radioactive
materials due to overflows from tanks containing liquids, sludge, spent
resins, etc., and measures used to prevent the dropping of containers
from cranes and forklifts. Confirm that the correct corrosion resistant
materials were used for system piping and valves associated with
transfer lines to storage tanks and discharge piping buried in soils and
concrete. Include in this review any special design features for the
early detection of leaks and spills (e.g., leak detection sumps). Verify
the provisions and effectiveness of precautions taken to minimize spills
and leaks, (e.g., retention curbs, level gauges and alarms, catch
containment, self-sealing quick-disconnects) and measures to prevent
interconnections with non-radioactive systems, see IE Bulletin No.
80-10.

e\. Verify that the licensee's PCP correctly describes the methods used
for dewatering or stabilization (i.e., removal of free standing water).
That it correctly describes the types of stabilization agents used (if
any), the expected waste volume increase factors, and implementation of
a process control program to ensure a solid matrix and proper waste form
characteristics, and/or complete dewatering of wet wastes. Further NRC
guidance is given in three NRC Branch Technical positions (listed in
Section 04, References) on concentration averaging (1995), and final
(1983) and revised (1991) waste classifications and waste forms.

f\. Verify the types and characteristics of filtration systems,
ion-exchange resins, and adsorbent media to treat liquid and wet wastes,
including expected removal efficiencies and decontamination factors.

g\. Verify the description of methods used against the actual practice
for volume reduction of dry solid wastes, including sorting methods,
technologies (e.g., shredders, crushers, and compactors), system
components and their design parameters, and expected waste volume
reduction factors.

h\. For plants using offgas treatment systems relying on charcoal beds,
confirm that the licensee has operational procedures by which spent
charcoals will be regenerated for re-use, and facilities to store spent
charcoals prior to shipment for disposal or regeneration.

i\. Confirm the adequacy of radiation shielding around waste processing
equipment which is expected to exhibit elevated levels of external
radiation, the placement of such equipment in shielded cubicles, and the
use of temporary or permanent shielding mounted on or in the immediate
vicinity of mobile equipment. Use the guidance presented in Regulatory
Guides 8.8 and 8.10.

j\. Using the licensee's construction QA program, confirm that the
quality group classifications of installed piping and equipment are in
accordance with the guidelines of Regulatory Guide 1.143, such as
expected temperatures and pressures, and materials of construction of
permanently installed systems and mobile processing equipment.

k\. Verify design provisions incorporated in equipment and facility to
facilitate operation and maintenance in accordance with the guidelines
of Regulatory Guide 1.143 and as referenced in topical reports, and
previous experience with similar equipment and methods referenced in the
SAR or other supporting documents.

l\. Confirm the installation of features that would reduce volumes of
waste passed to the SWMS, that will reduce radioactivity levels in the
wastes, minimize contamination of the facility and environment,
facilitate eventual decommissioning, and minimize the generation of
radioactive waste in accordance with 10 CFR Part 20.1406.

m\. For multi-unit stations, confirm the proper installation of
equipment and components (as permanently installed systems or in
combination with mobile processing equipment) normally shared between
interconnected processing and treatment subsystems.

n\. Determine that the licensee's low-level waste storage areas have in
place adequate design solutions to meet the criteria specified in
Sections III through VI in Appendix 11.4-A of SRP Section 11.4. The
criteria apply to generally accepted guidance and practices, for
radioactive waste storage. Useful background information is given in
Inspection Procedure 84850, and Generic Letters No. 80-009, 81-038, and
81-039.

02.04 [Sampling and Monitoring]{.underline}. Determine the adequacy of
provisions for sampling waste before and after processing, and the
adequacy of installation, calibration and testing of process radiation
monitors. See IP 84524 for effluent radiation monitors.

a\. (Verify that process monitors including radiation, differential
pressure, flow rate, and level indicators, in the FSAR are installed in
accordance with design specifications.) SRP Section 11.5 contains a list
of monitors typically required. This SRP also contains guidance on good
design and recognized industry practices using ANSI/ANS 55.1 and 55.6,
and ANSI N42.18.

b\. Determine that the SWMS has sampling points for input and end
product wastes. Verify that sample collection points are easily
accessible, properly ventilated, and shielded for both normal operations
and accident conditions.

c\. Determine that the licensee has the ability to take representative
samples from receiving and storage tanks, including circulation of tank
contents and purging of sample lines.

d\. For radioactive monitoring instrumentation providing alarm and
automatic termination of process operation, confirm that sufficient pipe
run length exist between the detector and isolation valve to ensure
timely isolation of the process.

e\. Verify that liquid process radiation monitors include features to
facilitate decontamination, flushing, and purging of piping and valves,
etc. and their replacements during maintenance.

02.05 [Test Program for SWMS]{.underline}. Determine the adequacy of the
test program for the SWMS and observe the preoperational testing. Verify
that the licensee performed all appropriate tests and results meet
performance criteria.

a\. Review the licensee's test program for the SWMS, including flushing,
cleaning, wiring check, hydraulic pressure testing, and instrumentation
requirements. Determine that the program, using Regulatory Guides 1.143
and 1.68, is adequate for its intended purpose and includes test
requirements and prerequisites, inspection check points, test
parameters, acceptance and test criteria, test QA criteria, detailed
testing procedures, inspection check and sign-off points, and record
keeping of all test results.

b\. Verify that all instruments are calibrated and working properly
before the testing begins.

c\. Verify that all equipment is operable, including main and remote
instrumentation control panels indicating system operational parameters,
local and ambient radiation levels, radioactivity levels in process and
effluent streams, and audio-visual indicators.

d\. Verify that the licensee's testing process has a detailed program
for test review, evaluation, and approval. Determine that all acceptance
criteria are included in the testing program and are appropriate.

e\. Witness at least two tests of the SWMS. Verify that the tests are
performed according to the test program described in the FSAR and/or
equipment vendor specifications.

f\. Verify that the system flow and differential pressures are within
testing criteria. The testing criteria should test the ranges provided
by the capacity of waste storage and holding tanks, and system
processing flow rates.

g\. Determine by evaluating confirmatory analyses done by the licensee
that the sampling systems take representative samples and verify sample
line input and source, and the proper operation of sample line purging
and recirculation of tank contents. Verify the selection of the
appropriate system sampling line before sample collection, and during
collection of sample. Verify the adequacy of the method used in
determining the necessary recirculation times to confirm that tank
contents are thoroughly mixed before sampling so as to ensure
representative sampling of liquid wastes.

h\. Verify that the system's automatic isolation features fail in the
closed position, including provisions used for the diversion of process
and effluent streams. Confirm that operational procedures for
determining the appropriate alarm set-points for all installed radiation
monitors are feasible.

i\. Review the process used in evaluating all test results against test
acceptance criteria and NRC requirements in confirming the operability
of the SWMS. Review all pre-operational testing records and determine
that the SWMS can adequately solidify, handle and store waste in a safe
and reliable manner. Test records should verify the tolerances for
proper waste/solidification agent mixes and feed rate limits.

j\. Verify that there is a capability to sample and monitor the waste
transfer system to disposal, or to shipping containers, especially those
used for resin and filter sludge. Results of the sampling/monitoring are
utilized to determine scaling factors to meet criteria in 10 CFR 61.

02.06 [Program Management]{.underline}. Determine that the licensee has
the necessary management program to effectively operate the SWMS, make
changes to the solid waste management program, validate and verify
quality objectives, and document the process.

a\. The PCP and associated plant TS are reviewed to determine whether
they identify all regulatory requirements, follow NRC guidance, and
contain all appropriate operational elements. The PCP should describe,
given specific waste processing technologies and methods, a set of
process parameters which are used to process wastes. The PCP should
identify surveillance requirements consistent with the plant\'s TS,
administrative procedures, operational procedures, quality assurance and
quality control, radiological controls and monitoring, information to be
contained in annual radiological effluent release report, reporting
requirements to NRC, instructions on the use of the NRC\'s uniform
radioactive shipping waste manifest, and process for initiating and
documenting changes to the PCP and its supporting procedures.

b\. Confirm that the PCP and operational procedures describe, given
specific waste processing technologies and methods, a set of process
parameters which are used to process wastes. Among others, the
parameters include pH, water content, oil content, presence of hazardous
materials, content of chelating agents, and ratio of solidification
agent to chemical additives by types of wastes. The types of wastes may
include filter sludge, spent-resins, boric acid solutions, process
concentrates, filter media, etc. The PCP should describe the bases in
developing waste mixture formulas, sampling, analysis, tests,
radionuclide scaling factors, encapsulation and concentration averaging,
controls on radiolytic hydrogen gas generation, and methods to
demonstrate that the processing of actual or simulated waste samples can
be successfully accomplished and ensure compliance with NRC
requirements.

c\. Review the PCP to determine if the Quality Assurance/Control
measures recommended in Regulatory Guides 4.15, 4.8 1.33 and 1.21,
NUREG-1301 or NUREG-1302, and NUREG-0133 are being followed.

d\. Verify that the licensee is following appropriate quality control
measures specified in the PCP, the licensee's QA program, and SOPs for
permanently installed systems and mobile waste processing systems.

e\. Verify that all SWMS operators and technicians have been trained on
the PCP and the details of specific operating procedures and technical
specifications.

f\. Confirm that the licensee has a mechanism to document and
incorporate changes to the PCP.

g\. Confirm that the licensee has a plan or program for routine and
preventative maintenance to ensure equipment availability under accident
conditions and to maintain release and worker exposure as low as
reasonably achievable using Regulatory Guides 8.8 and 8.10.

h\. If the licensee is expected to ship waste to processors for
treatment and disposal on its behalf, confirm that the PCP identifies
procedures in managing such transfers and in accounting for waste
volumes and radioactivity levels in its material inventory program.

02.07 [Low-level Waste Disposal]{.underline}. Verify that licensee has
established procedures for proper classification and characterization of
solid waste, preparation of manifests, packaging, and waste tracking and
inventory to ensure compliance with NRC requirements.

a\. Verify that NRC requirements for classifying waste and waste
characteristics under 10 CFR Part 61.55 and 10 CFR Part 61.56 are
incorporated into approved procedures. If the process is covered by an
approved topical report, verify that the process is reflected in the PCP
or implementing procedure. Any changes should be supported by a PCP
amendment or a 10 CFR Part 50.59 evaluation demonstrating that the
change does not introduce an unreviewed safety question and does not
alter the technical and regulatory commitments.

b\. Verify that the licensee has approved procedures for preparing waste
manifests, labeling of waste packages and tracking waste pursuant to 10
CFR Part 20.2006 and NUREG/BR-0204; and Part 20.2108 on records keeping.

c\. Verify that NRC regulations under 10 CFR 71, DOT regulations, under
49 CFR 171 - 180 and the waste acceptance criteria of the authorized
disposal facilities or waste processors are incorporated into approved
procedures.

d\. Confirm that all operators and technicians with responsibilities for
preparing wastes for shipment and disposal are trained on the PCP and
its implementing procedures.

e\. Review the waste disposal program and verify that the Quality
Assurance/Quality Control measures recommended in 10 CFR Parts 61.55 and
61.56 are implemented in the PCP and SOPs.

84527-03 RESOURCE ESTIMATES

For budgeting purposes, approximately 120 hours of direct inspection
effort will be required to implement this procedure. An inspection of
the SWMS will require: a lead inspector, one subject matter expert in
SWMS operation, one health physicist, and one expert in low-level waste
shipment manifesting, tracking, and disposal.

The hours expended during an inspection should be adjusted to reflect
the specific requirements of that plant; specific design features and
operational programs.

84527-04 REFERENCES

10 CFR Part 20.1406, \"Minimization of Contamination.\"

10 CFR Part 20.2006, \"Transfer for Disposal and Manifests.\"

10 CFR Part 20.2007, \"Compliance with Environmental and Health
Protection Regulations.\"

10 CFR Part 20.2108, \"Records of Waste Disposal.\"

10 CFR Part 50.59, \"Changes, Tests, and Experiments.\"

10 CFR Part 61, \"Licensed Requirements for Land Disposal of Radioactive
Waste.\"

10 CFR Part 71, \"Packaging and Transportation of Radioactive
Material.\"

49 CFR Parts 171 - 180, \"Subpart C - Hazardous Materials Regulations.\"

ANSI/ANS 55.1 - 1992 (R2000), "Solid Radioactive Waste Processing System
for Light-Water-Cooled Reactor Plants." Reaffirmed 2000.

ANSI/ANS 55.6 - 1993 (R1999), "Liquid Radioactive Waste Processing
Systems for Light Water Reactor Plants." Reaffirmed 1999.

ANSI N42.18-2004 1980 (Reaffirmation of ANSI N42.18-1980) (Redesignation
of ANSI N13.10-1974 ), \"Specification and Performance of Onsite
Instrumentation for Continuously Monitoring Radioactivity in
Effluents.\"

NUREG/BR-0204, \"Instructions for Completing NRC\'s Uniform Low-Level
Radioactive Waste Manifest.\"

NUREG-0800, Standard Review Plan, Section 11.4, "Solid Waste Management
System."

NUREG-0800, Standard Review Plan, Section 11.5, "Process and Effluent
Radiological Monitoring Instrumentation and Sampling Systems.

NUREG-0133, \"Preparation of Radiological Effluent Technical
Specifications for Nuclear Power Plants.\"

NUREG-1301, \"Offsite Dose Calculation Manual Guidance: Standard
Radiological Effluent Controls for Pressurized Water Reactors.\" (With
Generic Letter 89-01, Supplement 1).

NUREG-1302, \"Offsite Dose Calculation Manual Guidance: Standard
Radiological Effluent Controls for Boiling Water Reactors.\" (With
Generic Letter 89-01, Supplement 1).

Regulatory Guide 1.21, \"Measuring, Evaluating, 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
(Operation)".

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

Regulatory Guide 1.143, \"Design Guidance for Radioactive Waste
Management Systems, Structures and Components Installed 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.\"

Regulatory Guide 4.8, "Environmental Technical Specifications for
Nuclear Power Plants."

Regulatory Guide 8.8, \"Information Relevant to Ensuring that
Occupational Radiation Exposures at Nuclear Power Stations Will Be as
Low as Is Reasonably Achievable.\"

Regulatory Guide 8.10, \"Operating Philosophy for Maintaining
Occupational Radiation Exposures as Low as Is Reasonably Achievable.\"

Branch Technical Position ETSB 11-3, \"Design Guidance for Solid
Radioactive Waste Management Systems Installed in Light-Water-Cooled
Nuclear Power Reactor Plants,\" Attachment A to SRP Section 11.4.

Standard Review Plan Section 11.4, Appendix 11.4-A, \"Design Guidance
for Temporary Storage of Low Level Radioactive Waste,\" Attachment B to
SRP Section 11.4.

NRC Generic Letter 80-009, \"Low Level Radioactive Waste Disposal.\"

NRC Generic Letter 81-038, \"Storage of Low Level Radioactive Waste at
Power Reactor Sites.\"

NRC Generic Letter 81-039, \"NRC Volume Reduction Policy.\"

NRC Inspection Procedure 84850, \"Radioactive Waste Management -
Inspection of Waste Generator Requirements of 10 CFR Part 20 and 10 CFR
Part 61,\" June 6, 2002.

NRC, \"Issuance of Final Branch Technical Position on Concentration
Averaging and Encapsulation,\" January 17, 1995.

NRC, \"Final Waste Classification and Waste Form Technical Position
Papers,\" May 11, 1983.

NRC, \"Revised Staff Technical Position on Waste Form (SP-91-13),\"
January 30, 1991.

IE Bulletin No. 80-10, \"Contamination of Nonradioactive System and
Resulting Potential for Unmonitored, Uncontrolled Release of
Radioactivity to Environment,\" May 6, 1980.

84527-05 PROCEDURE COMPLETION

This Procedure is complete when sufficient data to allow analysis under
the ROP has been amassed and the geographical Region has accepted the
results so that inspection and monitoring under the ROP can be
initiated.

END

Attachment 1: Revision History for IP 84527

Attachment 1

Revision History Sheet for

IP 84527

Solid Waste Management System

+--------+-------+------------+----------+-------------+---------------+
| Comm   | Issue | D          | Training | Training    | Comment       |
| itment |       | escription | Needed   | Completion  | Resolution    |
|        | Date  | of Change  |          | Date        |               |
| Tr     |       |            |          |             | Accession     |
| acking |       |            |          |             | Number        |
|        |       |            |          |             |               |
| Number |       |            |          |             |               |
+--------+-------+------------+----------+-------------+---------------+
| NA     | 07/   | Initial    | None     | Not         | ML072851246   |
|        | 01/08 | issue to   |          | Applicable  |               |
|        |       | support    |          |             |               |
|        | CN    | i          |          |             |               |
|        | 0     | nspections |          |             |               |
|        | 8-019 | of         |          |             |               |
|        |       | o          |          |             |               |
|        |       | perational |          |             |               |
|        |       | programs   |          |             |               |
|        |       | described  |          |             |               |
|        |       | in IMC     |          |             |               |
|        |       | 2504,      |          |             |               |
|        |       | NON-ITACC  |          |             |               |
|        |       | IN         |          |             |               |
|        |       | SPECTIONS. |          |             |               |
|        |       |            |          |             |               |
|        |       | Completed  |          |             |               |
|        |       | review of  |          |             |               |
|        |       | CNs for    |          |             |               |
|        |       | previous 4 |          |             |               |
|        |       | years and  |          |             |               |
|        |       | no         |          |             |               |
|        |       | c          |          |             |               |
|        |       | ommitments |          |             |               |
|        |       | were       |          |             |               |
|        |       | found.     |          |             |               |
+--------+-------+------------+----------+-------------+---------------+
|        |       |            |          |             |               |
+--------+-------+------------+----------+-------------+---------------+