NRC INSPECTION MANUAL FCSS

INSPECTION PROCEDURE 88035

RADIOACTIVE WASTE PROCESSING, HANDLING, STORAGE, 

AND TRANSPORTATION
Issue Date: 02/07/14 1 88035

88035-01 INSPECTION OBJECTIVES

Determine whether the licensee’s performance is in accordance with the requirements of Title 

10 of the Code of Federal Regulations (10 CFR) Part 20 and 10 CFR Part 61 and in compliance 

with the license1application and commitments for the processing, handling, storage and 

transportation of radioactive waste.

88035-02 INSPECTION REQUIREMENTS AND GUIDANCE

02.01 Radioactive Waste Program.

a. Inspection Requirements. Determine if the radioactive waste program is being 

implemented in accordance with the licensee’s procedures, license application, and 

regulatory requirements.

b. Inspection Guidance. Review organizational and procedural changes, training, plant 

incident reports, corrective action database, events, and any licensee 

self-assessments, audits or independent reviews performed since the last 

Implementation Plan (IP) 88035 inspection. 

02.02 Organizational Structure.

a. Inspection Requirements. Verify that any changes to the organizational structure in the 

area of radioactive waste are in compliance with license requirements, if applicable.

b. Inspection Guidance. 

1. Interview licensee staff and management and review documentation to determine 

whether the organizational structure is consistent with the license requirements. 

Begin interviews with any managers who are new since the previous inspection.

2. Determine whether these managers meet the training and experience 

requirements for their positions as specified in the license.

3. Focus on whether the qualifications of assigned plant staff meet the requirements 

of the license or certificate, including years of relevant experience, educational 

background, and training required for the newly assigned responsibilities.

 

1

References to license or licensee should be understood to include facilities regulated under 

10 CFR 76 with a certificate.
Issue Date: 02/07/14 2 88035

4. Examine changes in the organizational structure which impact personnel’s’

qualifications, assigned responsibilities, and authority.

If no significant changes have occurred in the organization since the previous 

inspection, then limit time spent on this section.

02.03 Procedures.

a. Inspection Requirements. 

1. Verify that safety-significant changes to procedures in the area of radioactive 

waste are in compliance with license requirements.

2. Verify that safety-significant changes were made in accordance with the 

licensee’s procedure revision process, if required by the license.

b. Inspection Guidance. 

1. Review any safety-significant changes to procedures for the area being 

inspected since the last inspection. If there were safety-significant changes, 

review them to determine if they followed the procedure revision process 

regarding the following aspects:

(a) Only approved current procedures are used;

(b) Personnel affected by a procedure are adequately and timely informed of 

changes in the procedures; 

(c) Changes to procedures, other than editorial and typographical, conformed 

with the Integrated Safety Analysis and had an engineering basis; and/or

(d) Whether any previously approved field changes have been incorporated 

into the changed procedure within an established time period.

2. If there were any new procedures developed for the area being inspected, 

determine if the development of the new procedures followed the procedure 

development process.

02.04 Training.

a. Inspection Requirements. 

1. Review training in the area of radioactive waste and evaluate if training is in 

compliance with license requirements. 

2. Determine whether personnel designated by the licensee to certify radioactive 

material shipments (Subsection II of Appendix G to 10 CFR Part 20 and 49 CFR

172.204) are adequately trained and qualified.
Issue Date: 02/07/14 3 88035

b. Inspection Guidance. 

1. Review area specific training to ensure that the following topics are included, as 

appropriate:

(a) Items relied on for safety, process safety information elements (such as 

safety and health hazards, relevant material safety data sheets [MSDS], 

personal protective equipment, etc.);

(b) Safe work practices (such as confined space entry, lockout/tagout 

procedures, opening process equipment, hot work, control of entry into 

hazardous areas, etc.);

(c) Process technology (as required);

(d) Operating procedures for all phases of operation;

(e) Emergency procedures (such as Hazard Waste Operations and 

Emergency Response;

(f) Reporting unusual events or non-routine operations;

Note: On-the-job training should, as a minimum, include: equipment familiarization, 

completing log sheets, equipment startup/shutdown activities, limiting operating 

conditions, control of process variables, and applying operating procedures in the field.

2. No guidance is provided2.

02.05 Problem Identification and Resolution.

a. Inspection Requirements. 

1. Determine whether the licensee is identifying issues in the area of radioactive 

waste at an appropriate threshold and entering them into the corrective action 

program, if required by the license application.

2. Verify that the licensee is appropriately addressing and correcting safetysignificant condition reports.

 

2

Per IMC 0040, 07.02(c) Note.
Issue Date: 02/07/14 4 88035

b. Inspection Guidance. 

1. Perform a screening review to select a representative sample of items entered 

into the corrective action program. Identify safety-significant or repetitive failures 

that fall within the scope of the inspection. In addition, be alert to conditions, 

such as repetitive equipment failures or human performance issues that might 

indicate a trend or warrant additional follow-up.

2. Use direct observation of operations, discussions with relevant plant staff, and a 

sample review of applicable documentation to: 

(a) Determine whether corrective actions commensurate with the significance 

of the issue have been identified and implemented by the licensee. 

Review a sample of issues to determine whether the licensee has 

appropriately classified the issue;

(b) Determine whether equipment, human performance, and program issues 

are being identified by the licensee at an appropriate threshold and are 

being entered into the problem identification and resolution program;

(c) Consider licensee identified issues (e.g., issues identified during audits or 

self-assessments) and issues identified through an employee concerns 

program, if applicable;

(d) Review a sample of safety-significant issues to determine whether the 

licensee has taken appropriate short- and long-term corrective actions;

02.06 Event Review.

a. Inspection Requirements. Determine whether the licensee has implemented a program 

of review that evaluates safety-significant events in the area of radioactive waste and 

meets the license requirements.

b. Inspection Guidance. Review the events occurring since the last inspection to 

determine compliance with the license including, as appropriate:

1. The prompt review and evaluation of non-routine events and unusual 

occurrences to determine their significance;

2. The reporting of events, both internally, and to the U.S. Nuclear Regulatory 

Commission (NRC) in a timely manner;

3. Evaluation of the extent of condition of findings; and 

4. Completion of corrective actions related to non-routine events and unusual 

occurrences.
Issue Date: 02/07/14 5 88035

02.07 Audits.

a. Inspection Requirements. Verify that the licensee has conducted audits or 

self-assessments in the area of radioactive waste and is in compliance with the license 

application.

b. Inspection Guidance. 

1. Determine if the licensee is required to conduct audits or self-assessments. 

Select internal or contracted audits performed since the previous inspection, and 

examine the records documenting the selected audits. Determine whether there 

was a written plan for the audit, the audit adequately reviewed the specified area, 

the appropriate corrective actions were taken whenever deficiencies were found, 

and whether there was a check of the effectiveness of the corrective action(s).

2. Determine by interviewing licensee representatives how the licensee ensures the 

effectiveness of audits, such as by use of contractor audits, use of a secondary 

(or follow-up) audit system on a periodic basis, conducted by a member of 

management or a senior technician not directly responsible for the system 

audited.

3. Determine if safety-significant audit findings are being tracked to completion in 

the corrective action program.

02.08 Processing Systems.

a. Inspection Requirements. Select one to three liquid or solid radioactive waste

processing systems; including settling ponds. Walk down accessible portions of 

systems to verify and assess that the as-built system configuration and operation agree 

with the descriptions in the license.

b. Inspection Guidance. 

1. Inspect radioactive waste processing equipment that is not operational and/or is 

abandoned in place.

Verify that the licensee has established administrative and/or physical controls 

(i.e., drainage and isolation of the system from other systems) to ensure that the 

equipment will not contribute to an unmonitored release path or affect operating 

systems or be a source of unnecessary personnel exposure. 

2. Verify that the licensee has reviewed the safety significance of systems and 

equipment abandoned in place in accordance with their engineering change 

process. 
Issue Date: 02/07/14 6 88035

Review the adequacy of any changes made to the radioactive waste processing 

systems since the last inspection. Verify that changes from what are described in 

the license were reviewed and documented in accordance with their engineering 

change process.

3. Review the impact, if any, on radiation doses to members of the public.

4. Verify that settling ponds, retention basins, and/or earthen retention systems are 

in accordance with requirements in the license application.

02.09 Quality Assurance.

a. Inspection Requirements. Determine whether the licensee has established and 

maintains an adequate quality assurance (QA) program to determine compliance with 

the waste classification and characterization requirements. 

b. Inspection Guidance.

1. Determine whether the QA program includes the required audits and 

management evaluation of such audits. 

2. 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 88035 inspection. 

3. 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 associated with the radioactive waste management program will vary 

depending on the nature and complexity of the specific waste streams 

encountered at a given fuel facility.

02.10 Waste Classification.

a. Inspection Requirements. Determine whether the licensee has established a program 

to identify and properly classify radioactive waste streams associated with plant 

operations in accordance with the requirements of 10 CFR 61.55 and the license.

b. Inspection Guidance. 

1. Review the licensee’s documentation and records of activities that have been 

established and are being maintained to determine whether 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).
Issue Date: 02/07/14 7 88035

2. Review the license requirements for authorized releases of radioactive nuclides 

in liquid and solid products transferred to non-NRC licensed entities to assure 

they meet the license and waste compact requirements. Waste compact 

requirements should be implemented in the disposal site license. Review 

whether the method used by the licensee is adequate to determine radionuclide 

concentrations in order to classify waste.

3. Review the license requirements for authorized release guidelines for byproduct 

materials transferred to unlicensed 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 the analysis supporting the 

releases should be reviewed for compliance with the criteria specified in the 

license. 

4. Ensure that new waste streams and changes to existing waste streams have

been properly classified and characterized. Review licensee procedures to 

determine if they address these changes. 

5. Licensees may utilize the services of a contract analytical laboratory to analyze 

samples to determine waste stream classification. Under these circumstances 

verify that the licensee has established mechanisms to periodically evaluate the 

performance of the contractor analytical laboratory. These measures may 

include independent audits performed by the licensee or other qualified 

companies. Additionally purchase requisitions for contract services should be 

reviewed to ensure that appropriate performance standards and criteria have 

been included in the scope of the contract. This could include critical attributes 

such as the lower limit of detection or minimum detection level required to be 

achieved. Review the licensee’s process for placing a company that supplies 

analytical services on their approved vendors list.

02.11 Waste Characterization.

a. Inspection Requirements. Determine if the licensee has established and implemented 

adequate methods to ensure the proper evaluation of radioactive characterization.

b. Inspection Guidance. Review the licensee's documentation and records of activities 

which have been established and are being maintained to determine whether low level 

radioactive waste (LLRW) meets the waste characteristics of 10 CFR 61.56. 

(Subsection III.A.1 of Appendix G to 10 CFR Part 20).

02.12 Waste Shipment Labeling.

a. Inspection Requirements. Determine whether each package of radioactive waste 

intended for shipment to a licensed land disposal facility is labeled, as appropriate.
Issue Date: 02/07/14 8 88035

b. Inspection Guidance. Review the licensee's procedures and records to determine 

whether each package of radioactive waste intended for shipment 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). 

Inspectors should be aware that Classes A, B, and 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 10 CFR 61.57 is, therefore, in addition 

to any other package markings and labels required by the transport regulations in 49 

CFR Part 173 or 10 CFR Part 71. Inspectors should note that the vast majority of 

radioactive waste shipments made by fuel facilities consist of Class A waste.

02.13 Tracking of Waste Shipments.

a. Inspection Requirements. Determine if the licensee has established a program for 

tracking the shipment and receipt of radioactive waste shipments.

b. Inspection Guidance. 

1. Review the licensee'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. 

2. Determine whether acknowledgment of receipt of the manifest is obtained. 

3. Determine whether the licensee 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. 

4. 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).

Inspectors should be aware of the differences in the waste manifest tracking 

requirements of Appendix G to 10 CFR Part 20 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.
Issue Date: 02/07/14 9 88035

02.14 Disposal Site License Conditions.

a. Inspection Requirements. Determine if the licensee has established measures to 

ensure compliance with disposal site license conditions for those burial facilities that the 

licensee utilizes.

b. Inspection Guidance. 

1. Review the licensee’s procedures and records to determine whether the 

applicable disposal site license conditions are being met. 

2. Determine whether the licensee has on file a current version of the disposal site 

license.

02.15 Radioactive Solid Waste.

a. Inspection Requirements. Determine if the licensee has established measures to 

ensure the proper labeling and handling of solid radioactive waste storage containers 

while in interim storage prior to shipment and/or disposal offsite.

b. Inspection Guidance. 

1. Check posting of storage areas and labeling of a selected number of containers. 

Check to determine that 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. 

There may not be specific requirements included in the license relating to the 

onsite storage of solid radioactive waste; however, the licensee’s program should 

address the requirements of 10 CFR 20.2001 and 20.2101, .2102, .2103, .2108, 

and .2110. 

2. 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).

3. Review the results of inspections and surveys of LLRW in storage focusing on 

licensee follow-up actions to problems identified. 

4. Review licensee records relating to LLRW storage, determine whether the 

records provide accountability, and determine how long LLRW has been in 

storage. 

5. Confirm that the licensee is within authorized possession limits. 

6. Confirm that any required checks of fire protection systems have been 

performed.
Issue Date: 02/07/14 10 88035

7. Confirm that accumulations of stored radionuclides of concern are less than 

Category 2 quantities or, if exceeded, appropriate increased controls have been 

implemented.

02.16 Adequacy of Storage Area.

a. Inspection Requirements. Inspect the storage area(s) to determine the adequacy of:

1. Access control and security;

2. Access to, and housekeeping around waste packages. Adequate lighting should

be provided to permit identification of unsafe radiological and non-radiological 

conditions;

3. Stable placement of waste or waste packages;

4. Protection from environmental elements, fire and flooding, avoidance of

temperature/humidity extremes, and ventilation considerations;

5. Posting and labeling;

6. Segregation from hazardous materials; and

7. Waste minimization techniques;

b. Inspection Guidance. 

1. Confirm that LLRW is stored in a restricted area and is secured against 

unauthorized removal. 

2. Check that waste containers are visible to allow routine inspection and that they 

are readily accessible to licensee personnel. 

3. Confirm that the placement or stacking of containers is stable and that containers 

are not deformed under load, or likely to fall. 

4. Determine that as low as reasonably achievable considerations are used in the 

placement of the higher activity waste containers in the storage area. 

5. Check that the storage area is posted in accordance with 10 CFR Part 20 

requirements.

6. Confirm that 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.). 
Issue Date: 02/07/14 11 88035

7. Check ventilation of the storage area to determine if it is sufficient to prevent 

build-up of any gases produced by waste decomposition.

88035-03 RESOURCE ESTIMATE

The resource estimate to perform this inspection procedure is estimated to be 32 hours every 

two years. 

88035-04 REFERENCES

10 CFR Part 20, Standards for Protection Against Radiation.

10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste.

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

49 CFR parts 107, 171 through 180, and 390 through 397.

Inspection Procedure 84850, ‘Radioactive Waste Management - Inspection of Waste Generator 

Requirements of 10 CFR Part 20 and 10 CFR Part 61,’ December 22, 2008

Inspection Procedure 84900, ‘Low Level Radioactive Waste Storage,’ December 22, 2008

‘Technical Position on Radioactive Waste Classification,’ mailed to all NRC licensees on 

May 11, 1983, by NMSS, Low-Level Waste Management Branch, ML033630755.

Federal Register, Vol. 48, No. 175, Sept. 8, 1983; NRC Notice, ‘Topical Reports in Support of 

the Implementation of Waste Classification and Waste Form Requirements.’ 

‘Waste Form Technical Position Paper,’ Revision 1, mailed to all NRC licensees on 

January 24, 1991, by NMSS, Low-Level Waste Management Branch, ML033630746.

NRC Regulatory Guide 3.13, ‘Design, Construction, and Inspection of Embankment Retention 

Systems at FuelCycle Facilities,’ July 31, 2010, ML101470167.

NRC Information Notice No. 86-20, ‘Low-Level Radioactive Waste Scaling Factors, 10 CFR Part 

61,’ March 28, 1986.

NRC Information Notice No. 89-13, ‘Alternative Waste Management Procedures in Case of 

Denial of Access to Low-Level Waste Disposal Sites,’ February 8, 1989.

NRC Information Notice No. 90-09, ‘Extended Interim Storage of Low-Level Radioactive Waste 

by Fuel Cycle and Materials Licensees,’ February 5, 1990.
Issue Date: 02/07/14 12 88035

NRC Information Notice No. 93-50, ‘Extended Storage of Sealed Sources,’ July 8, 1993.

NRC Regulatory Issue Summary 08-012, ‘Considerations for Extended Interim Storage of 

Low-Level Radioactive Waste by Fuel Cycle and Materials Licensees,’ May 9, 2008

NRC Regulatory Issue Summary, 11-009, ‘Available Resources Associated With Extended 

Storage Of Low-Level Radioactive Waste,’ August 16, 2011

NUREG-1608, Categorizing and Transporting Low Specific Activity Materials and Surface 

Contaminated Objects.

NUREG-1660, U.S.-Specific Schedules of Requirements for Transport of Specified 

Types of Radioactive Material Consignments.

88035-05 PROCEDURE COMPLETION

Implementation of each applicable inspection requirement will constitute completion of this 

procedure. Individual inspection samples and breadth of review will be determined by the 

inspector based on requirement compliance, risk- significance of activity, and extent of the 

activity or records available.

END

Attachment:

 Revision History Sheet for IP 88035
Issue Date: 02/07/14 Att1-1 88035

Attachment 1 - Revision History Sheet for IP 88035

Commitment 

Tracking 

Number

Accession 

Number

Issue Date

Change 

Notice

Description of Change Description of 

Training 

Required and 

Completion 

Date

Comment and 

Feedback 

Resolution 

Accession 

Number

N/A 09/25/06

CN 06-025

This document has been revised to: (1) 

emphasize the risk-informed, 

performance-based 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. 

None ML061940414

N/A ML13233A179

02/07/14

CN 14-005

The IP was significantly revised to provide 

for a more in-depth inspection. The 

revised IP focuses more on systems, while 

the current IP focuses primarily on 

radioactive waste storage. The 

inspections examine the overall program 

in more detail as aspects from MO and OT 

have been added to the IP. The 

inspection has been revised on a biennial 

frequency and with an estimated 32 hours 

of direct inspection. The previous IP 

edition annually required 12 or 16 hours of 

direct inspection. 

None ML13347A944