Issue Date: 12/30/91 - 1 - 84101

NRC INSPECTION MANUAL LLDR

INSPECTION PROCEDURE 84101

RADIOACTIVE WASTE MANAGEMENT

PROGRAM APPLICABILITY: 2560

84101-01 INSPECTION OBJECTIVE

To determine the adequacy of the licensee's radioactive waste

management for the SAFSTOR or DECON option.

84101-02 INSPECTION REQUIREMENTS

02.01 Audits and Appraisals. Review the results of audits and

appraisals performed by or for the licensee since the last

inspection and the adequacy of the licensee's procedures, commitments, and corrective actions taken.

02.02 Changes. Review changes in equipment, facility,

procedures and operations for liquid, airborne and solid waste

systems. Determine whether changes are in accordance with 10 CFR

50.59 and license requirements.

02.03 Radioactive Liquid Effluents

a. Determine compliance with effluent requirements and efforts

to keep effluents ALARA.

b. Determine by observation whether the liquid waste systems

incorporate provisions to prevent and collect leakage,

overflows, and spillage in accordance with the licensee

approved safety analysis report.

02.04 Radioactive Airborne Effluents

a. Determine compliance with effluent requirements and efforts

to keep effluents ALARA.

b. Determine whether normal and special ventilation exhaust

system air cleaning units are maintained and operated as

required by the license procedures and Technical Specifications (TS).

02.05 Instrumentation and Systems
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a. Determine whether process and effluent monitors are maintained, and calibrated as required by the license procedures

and TS.
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02.06 Radioactive Solid Waste

a. Determine that the processing, control, and storage of solid

wastes is in accordance with the license procedures, safety

analysis TS, and applicable Federal and State regulations.

b. Determine that the procedures for proper classification and

characterization of wastes, for preparation of waste manifests, for marking packages with the class of waste, and for

investigation of lost shipments are in accordance with

regulatory requirements.

84101-03 INSPECTION GUIDANCE

03.01 Audits and Appraisals

a. Review reports of required audits since the last inspection.

Look particularly for those audits that probe for programmatic

weaknesses and assess the quality of the program. Focus upon

licensee followup actions for identified deficiencies. Are

corrective actions timely and technically acceptable?

Requirements for reviews and audits normally are contained in

the technical specifications for SAFSTOR. Audit teams should

include someone knowledgeable in liquid and airborne effluent

s, solid wastes effluents and their associated systems.

(Regulatory Guide 1.146 and ANSI/ASME N45.2.23-1978, Section

2.2)

03.02 Changes

a. Discuss significant changes in equipment, facility, procedures

and operations with cognizant management. (See IE Circular

No. 80-18.) Determine whether changes in dose calculation

methods in the Offsite Dose Calculation Manual (ODCM) have

been implemented.

Review all the changes in effluent control procedures and

equipment made since the last inspection and verify that:

1. they were made in accordance with the licensee's procedural control system and reviewed and approved by

management and supervision, and

2. they afford the same or a higher level of control of

effluents as the procedures reviewed during previous

inspections.

b. Determine whether the licensee is following their effluent and

solid waste control procedures.

03.03 Radioactive Liquid Effluents

a. Briefly review Semi-annual Radioactive Effluent Release

Reports for obvious mistakes, anomalous measurements,

omissions and trends.
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b. Review selected records (including release permits) to

determine compliance with effluent requirements. Verify dose

calculations using the licensee's ODCM for a major nuclide

(e.g., Cs-137 or Co-60) for one pathway for the last reporting

interval.

c. Review the licensee's experience in maintaining and using

liquid waste process systems.

d. Identify significant sources of radioactive liquids and solids

released within and from the facility.

e. Review the licensee's identification of significant sources

of release and unmonitored release paths.

f. Determine the volume of mixed waste being generated. Review

mixed waste treatment methods.

g. Briefly review selected records of required chemical and

radiochemical determinations for existing radioactive liquid

systems. Verify whether these determinations have been

performed as required and whether the results are within

limits. The TS may require special limitations for spent fuel

pools containing stored fuel.

03.04 Radioactive Airborne Effluents

a. Briefly review the Semiannual Radioactive Effluent Release

Reports for obvious mistakes, anomalous measurements,

omissions, and trends.

b. Review selected records (including release permits) to

determine compliance with effluent requirements. Verify dose

calculations using the licensee's ODCM for two major nuclides

in two pathways for the last reporting interval. Plants that

have been shut down for a long time may only have particulates

released in their effluents.

c. Review the licensee's experience in maintaining and using

gaseous and particulate process systems.

d. Identify the significant sources of radioactivity released

within and from the facility.

e. Look for unmonitored release paths.

f. Review records of tests of required air cleaning systems.

Identify recurrent test and maintenance problems and licensee's corrective actions, both long and short-term.

03.05 Instrumentation

a. Requirements for calibrations are normally contained in the

TS. Guidance on calibrations is contained in Regulatory

Guides 1.21 and 4.15.
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b. Where possible, compare monitor readings with laboratory

measurements to ensure that monitors respond acceptably.

c. Observe remote and local process and effluent monitor readouts

to determine operability. Identify recurrent maintenance

problems.

d. Process and effluent monitor alarm and control setpoints

should be described in written procedures. The basis for each

setpoint should be understood by affected operators and

technicians.

e. Review procedures for routine calibration and surveillance

tests for all instrumentation.

03.06 Radioactive Solid Wastes Processing, Storage and Disposal

a. Requirements for a process control program usually are

contained in the TS.

IE Inspection Procedure 65051 covers the adequacy of construction of facilities for temporary onsite storage of low-level

waste.

b. Inspect selected processing and disposal records to determine

whether quantity and radionuclide composition are being

measured or estimated as required.

c. Briefly review solid radwaste processing and storage reports

for obvious mistakes, anomalous measurements, omissions, and

trends.

d. Review the licensee's experience in maintaining and using

waste solidification systems.

e. Inspect the operation of solid waste processing activities.

Consider whether process or other engineering controls are

being used to the extent practicable to limit airborne

concentrations.

f. If mobile waste solidification systems are used, determine by

discussion and review of records whether the systems are

tested before use, whether adequate communications exist with

facility waste operators, and whether precautions have been

taken to isolate and control inadvertent discharges because

of leaks or malfunctions. Determine whether the integrity of

the existing plant/mobile radwaste interface is tested

periodically (e.g., system hydrostatic testing and visual

checks for leakage). Determine how leakage is contained if

it occurs. NRC Information Notice No. 90-31 provides

information on the identification of problems with cement

solidification, and reporting of waste mishaps.

g. Prior to shipping low-level wastes for disposal, the licensee

must have procedures properly approved by management for:

1. Classifying wastes pursuant to 10 CFR 61.55.
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2. Assuring that wastes meet the characteristics of 10 CFR

61.56.

3. Preparation of shipment manifests pursuant to 10 CFR

20.2006(b).

4. Assuring that each shipment manifest includes a certification pursuant to 10 CFR 20.006(c).

5. Control and tracking transferred radioactive waste

pursuant to 10 CFR 20.0006(d).

h. Review procedures for segregation and packaging greater-than

Class-C waste.

i. Review procedures for segregation and packaging mixed waste

as defined by RCRA.

j. Review procedures for preventing creation of mixed waste.

k. Determine whether the licensee has established a quality

assurance program to assure compliance with 10 CFR 61.55 and

61.56. Such a program must include management evaluation of

audits pursuant to 10 CFR 20.2006(d).

84101-04 REFERENCES

10 CFR Parts 20 and 61

Facility Technical Specifications

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 1.140, "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 1.146, "Qualification of Quality Assurance Program

Audit Personnel for Nuclear Power Plants."

Regulatory Guide 4.15, "Quality Assurance for Radiological

Monitoring Programs (Normal Operation) - Effluent Streams and the

Environment."

NUREG-1301, "Offsite Dose Calculation Manual Guidance, Standard

Radiological Effluent Controls for PWRs."

NUREG-1302, "Offsite Dose Calculation Manual Guidance, Standard

Radiological Effluent Controls for BWRs."
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NUREG-0133, "Preparation of Radiological Effluent Technical

Specifications for Nuclear Power Plants," 1978.

NUREG-0472, "Radiological Effluent Technical Specifications for

PWRs," February 1980.

NUREG-0473, "Radiological Effluent Technical Specifications for

BWRs," July 1979.

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/ASME N5.2.23-1978, "Qualification of Quality Assurance Program

Audit Personnel for Nuclear Power Plants."

ANSI/ANS-55.1-1979, "Solid Radioactive Waste Processing System for

Light-Water-Cooled Reactor Plants."

ANSI/ANS N55.4-1979. "Gaseous Radioactive Waste Processing Systems

for Light-Water Reactor Plants."

ANSI/ANS-N55.6-1979, "Liquid Radioactive Waste Processing System for

Light-Water-Cooled 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."

EPRI NP-2734, "Solid Radwaste Radionuclide Measurements," November

1982.

EPRI NP-2900, "Low-Level Radwaste Solidification," March 1983

IE Inspection Procedure 65051, "Low-Level Radioactive Waste Storage

Facilities," January 1, 1983.

IE Inspection Procedure 84850, "Radioactive Waste Management -

Inspection of Waste Generator Requirements of 10 CFR 20 and CFR 61."

IE Bulletin No. 80-10, "Contamination of Nonradioactive System and

Resulting Potential for Unmonitored, Uncontrolled Release of

Radioactivity to Environment," May 6, 1980.

IE Circular No. 77-10, "Vacuum Conditions Resulting in Damage to

Liquid Process Tanks," July 15, 1977.

IE Circular No. 77-14, "Separation of Contaminated Water Systems

from Uncontaminated Plant Systems," November 22, 1977.

IE Circular No. 79-21, "Prevention of Unplanned Releases of

Radioactivity," October 17, 1979.
84101 - 8 - Issue Date: 12/30/91

IE Circular No. 80-14, "Radioactive Contamination of Plant

Demineralized Waste System and Resultant Internal Contamination of

Personnel," June 24, 1980.

IE Circular No. 80-18, "10 CFR 50.59 Safety Evaluations for Changes

to Radioactive Waste Treatment Systems," August 22, 1980.

IE Circular No. 81-09, "Containment Effluent Water That Bypasses

Radioactivity Monitor," July 10, 1981.

IE Information Notice No. 79-07, "Rupture of Radwaste Tanks," March

26, 1979.

IE Information Notice No. 79-09, "Spill of Radioactively Contaminated Resin," March 30, 1979.

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.

IE Information Notice No. 83-52, "Radioactive Waste Gas System

Events," August 9, 1983.

IE Information Notice No. 84-15, "Reporting of Radiological

Releases."

IE Information Notice No. 84-72, "Clarification of Conditions for

Waste Shipments Subject to Hydrogen Gas Generation."

IE Information Notice No. 84-94, "Reconcentration of Radionuclides

Involving Discharges Into Sanitary Sewage System."

IE Information Notice No. 85-092, "Surveys of Wastes Before Disposal

From Nuclear Reactor Facilities."

IE Information Notice No. 86-090, "Requests to Dispose of Very Low

Level Radwaste per 10 CFR 20.302."

IE Information Notice No. 87-003, "Segregation of Hazardous and Low

Level Radwastes."

IE Information Notice No. 87-007, "QC of Onsite Dewatering/Solidificati

on Operations by Outside Contractors."

NRC Information Notice No. 90-31, "Update on Waste Form and High

Integrity Container Topical Report Review Status, Identification of

Problems with Cement Solidification and Reporting of Waste Mishaps,"

May 4, 1990.

Generic Letter No. 81-38 to all holders and applicants for operating

licenses and construction permits, "Storage of Low-Level Wastes at

Power Reactor Sites," and Enclosure, "Radiological Safety Guidance

for Onsite Contingency Storage Capacity," November 10, 1981.
Issue Date: 12/30/91 - 9 - 84101

END