IR 05000361/1998010
| ML20239A343 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/02/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20239A341 | List: |
| References | |
| 50-361-98-10, 50-362-98-10, NUDOCS 9809090057 | |
| Download: ML20239A343 (15) | |
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ENCLOSURE
, U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket Nos.: 50-361
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50-362 License Nos.: NPF-10 NPF-15 Report No.: 50-361/98-10 50-362/98-10 Licensee: Southern California Edison C Facility: San Onofre Nuclear Generating Station, Units 2 and 3
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Location: 5000 S. Pacific Coast Hw San Clemente, California Dates: August 17-21,1998 Inspector: J. Blair Nicholas, Ph.D., Senior Radiation Specialist Plant Support Branch Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment: SupplementalInformation
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2-i EXECUTIVE SUMMARY 1
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San Onofre Nuclear Generating Station, Units 2 and 3 I NRC Inspection Report 50-361/98-10; 50-362/98-10 I
This announced, routine inspection reviewed the implementation of the solid radioactive waste 4 management and radioactive waste / materials transportation programs. Training and qualifications, quality assurance, facilities and equipment, procedural guidance, and annual reports were reviewe i Plant Suocort
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Overall, a very good solid radioactive waste management program was in place. The licensee's radioactive waste minimization program was effectively implemented. The !
volume and activity of dry active waste generated during the time period 1993 through l 1997 showed a declining trend with a volume reduction of approximately 47 percent and I an activity reduction of approximately 76 percent. Good facilities were maintained for the processing, storage, and management of solid radioactive materials and wastes and the performance of shipping activities. Solid radioactive waste was properly classified f and characterized for shipment and disposal. Housekeeping in the radwaste building, I south yard multi-purpose handling facility, and radioactive equipment and materials storage areas was very good. An excellent solid radioactive waste and materials ,
storage and inventory / accountability system was maintained (Section R1.1). l i
. A very good transportation program for radioactive waste and materials was maintaine I Shipping documentation was organized, easily retrievable, and packages were properly prepared for shipment. Proper emergency telephone numbers were included on shipping manifests. The licensee's fire department responded properly to the transportation accident emergency drill scenario (Section R1.2).
. The radioactive material control group staff was experienced and had an excellent working knowledge of the transportation regulations (Section R4).
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A strong solid radioactive waste management and transportation training program was maintained. The instructors assigned to provide initial and continuing solid radioactive l waste management and transportation training had a good technical background in l
these program areas. Lesson plans were well written, and plant management was j appropriately involved in the development and review of the training materials -
(Section RS).
. An effective quality assurance program was in place. The biennial audit, when combined with leadership observation program reports, provided management with a good assessment of the solid radioactive waste management and transportation programs. No negative trends were identified during the review of solid radioactive waste and transportation action reports. Appropriate evaluation of the contractor's performance was performed (Section R7).
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IV. Plant Suncort R1 Radiological Protection and Chemistry Controls L
R1.1_ Implementation of the Solid Radioactive Waste Proaram ,
, Insoection Scope (86750)
The inspector interviewed licensee personnel and reviewed the following: i
. Waste stream sampling results and waste characterization documentation .
. Scaling factors for required isotopes not measured directly -
. , Solid radioactive waste disposal data
. Waste minimization program ;
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.. Waste shipment manifests :
-. Waste storage and container accountability
. Annual radioactive effluent and solid radioactive waste reports b.- Observations and Findinas The inspector verified that waste stream samples were taken as required and analyzed
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to meet 10 CFR Part 61 requirements for waste classification and characterization. The
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licensee had identified various radioactive waste streams. The inspector determined '
. that these waste streams were representative of radioactive waste generated and were
> properly analyzed by a contractor laboratory. Additionally, the inspector verified that the results were used to update the software for selecting the proper containers for radioactive material shipments and for characterizing and classifying radioactive waste
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l Classification of radioactive waste was performed with a computer code commonly used
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~ in the nuclear industry. Scaling factors for difficult to measure nuclides in the waste i streams were determined and updated as needed in the radwaste computer code data j base. A review of selected examples of radioactive waste packaged for burial i determined that the waste was properly classified and characterize A review of the annual radioactive effluent release reports for 1996 and 1997 verified !
i that the reports contained the required solid radioactive waste data,
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Dry active waste was compacted in 55-gallon drums on site for volume reduction and
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subsequent burial. A summary of the volume and activity of solid radioactive waste s
including spent resins, spent filters, and dry active waste shipped for disposal during the past 5 years is tabulated belo .
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Waste Burial spent Flesin spent Filters Dry Active Total l Year Number of Volume Activity Volume Activity Waste Volume Activity l shipments (ra3) (Cl) (m3) (Cl) Volume Activity (m3) (Cl) l (m3) (Cl) j 1993 6 0 0 .7 7 .74 7 .44 1994 6 1 .6 .7 3 .89 5 .19 1995 1 0 0 .1 1 .78 1 .88 1996 6 1 .0 0 0 3 .07 5 .0 1997 34* O 0 .4 71 .5 71 .90 I
- 29 shipments were of dry active waste generated dunng the steam generator chemical clearung Over the past 5 years, the inspector noted the volume of spent resin shipped for disposal had remained relatively constant; however, there was an increase in spent resin activity due to increased resin bed run times. Two spent resin shipments in 1997 accounted for approximately 1000 curies of the total spent resin activity. Between 1993 l and 1997, a decreasing trend of both volume and curies of spent filters shipped for disposal showed that the annual volume of spent filters was reduced by approximately 57 percent and the annual curies was reduced by approximately 63 percen From discussions with licensee personnel, review of Procedure SO123-XV-28,
" Radioactive Waste Minimization Program," Revision 0, and field observations, the i inspector determined that the licensee's dry active waste minimization program was effectively implemented. The licensee's data showed that the number of bags of dry active waste generated during outages since 1993 was reduced by approximately 75 percent. Between 1993 and 1996, both the volume and activity of dry active waste shipped for burial showed that the annual volume was reduced 47 percent, and the annual activity was reduced 76 percent. The increase in dry active waste generated in 1997 resulted from the large volume of dry active waste generated from the chemical cleaning of the steam generators. Relative to that increase of dry active waste generated from the steam generator chemical cleaning, the amount of dry active waste generated during 1997 remained approximately the same as the preceding 3 year The inspector determined that station management was properly involved in establishing the 1997 and 1998 dry active waste generation goals of 2,387 bags and 1,315 bags, respectively. The inspector noted that for 1997, the number of dry active waste bags generated was 1,555 bags (65 percent of the annual goal) and that for the first 6 months of 1998 the dry active waste generation was 648 bags (49 percent of the annual goal).
This performance trend indicated that it was likely that the licensee could meet its 1998 annual goal for generation of dry active wast The inspector toured and inspected areas in the radwaste building, multi-purpose handing facility, and south yard radioactive equipment and materials storage area where radioactive materials and radioactive waste were handled, processed, and stored. The radioactive waste processing areas were properly posted and controlled. Containers of radioactive materials and radioactive wastes were properly labeled in accordance with l
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5-the requirements of 10 CFR 20.1904 and were maintained in good physical conditio Housekeeping in the radioactive waste processing and storage areas was very goo The inspector performed an inventory and accountability inspection of selected ;
containers of radioactive materials and radioactive waste stored in the low-specific !
activity waste storage area in the multi-purpose handling facility and in the fenced and locked radioactive equipment and materials storage area adjacent to the multi-purpose handling facility. The licensee kept well organized and accurate inventory records of radioactive materials and radioactive waste containers. The inspector verified thct selected radioactive materials storage containers and radioactive waste containers were :
stored as documented. No problems with the inventory and accountability of containers i were identifie ] Conclusions l Overall, a very good solid radioactive waste management program was in place. The j licensee's radioactive waste minimization program was effectively implemented. The volume and activity of dry active waste generated during the time period 1993 through ;
1997 showed a declining trend with a volume reduction of approximately 47 percent and l an activity reduction of approximately 76 percent. Good facilities were maintained for the processing, storage, and management of solid radioactive materials and wastes and the performance of shipping activities. Solid radioactive waste was properly classified ,
and characterized for shipment and disposal. Housekeeping in the radwaste building,
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south yard multi-purpose handling facility, and radioactive equipment and materials storage areas was very good. An excellent solid radioactive waste and materials storage and inventory / accountability system was maintaine R1.2 Transportation of Radioactive Materials and Radioactive Waste Inspection Scope (86750)
The inspector interviewed and observed licensee personnel and reviewed selected examples of the following:
. Radiation and contamination surveys of packages and vehicles l
. Shipping papers and shipment documentation
. Package marking and labeling
.- Vehicle placarding
. Emergency response information Observations and Findinas
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The inspector observed the preparation and shipment of two strong tight containers with miscellaneous internally contaminated measuring and test equipment characterized as a limited quantity shipment of radioactive material. The measuring and test equipment was properly surveyed, packaged, and marked for shipment to the shop services instrument division calibration facility. Radiation surveys of the transporting vehicle were properly performed and documented, and the shipping papers were properly completed. The inspector also observed the receipt of two strong tight shipping i
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-6-containers of measuring and test equipment from the shop services instrument division
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calibration facility. Receipt radiation surveys were properly performed, and health physics control was maintained of the two shipping containers until the measuring and test equipment was returned and properly stored in the radiological controlled are The inspector verified that the licensee maintained current copies on file of the consignees' radioactive materiallicenses. Current copies of both Department of Transportation and NRC regulations were maintained. Certificates of Compliance for routinely used shipping casks were verified. The licensee maintained an effective file syste A vendor supplied radwaste computer program was used to determine proper radioactive material transportation categories, shipping package labeling, and the generation of shipping papers. Revisions to the radwaste computer program were properly quality controlled and tested prior to installation and implementatio The inspector reviewed selected shipping records of radioactive waste and material shipments to determine compliance with DOT and NRC requirements. The inspector concluded that they contained the information required by 49 CFR Part 172, Subpart In addition to this informatiori, radioactive waste shipment documentation included manifests that conformed to the requirements of 10 CFR Part 20, Appendixes F and G; 49 CFR 173.433; and 49 CFR 173.435. Shipping documents included radioactivity measurements recorded in international system units, as well as, customary unit Reviewed radiation survey records documented that radiation and contamination levels of shipments were within regulatory limits. The inspector verified that proper emergency telephone numbers and emergency instructions were included with the shipping paper The inspector noted no problems with the shipping records reviewe The licensee utilized the station's fire department emergency center, which is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, to provide shipment emergency response information. In accordance with the radioactive materials and waste shipping procedures, the station's fire department emergency center was supplied with a copy of the radioactive waste / materials shipment manifest and emergency instructions prior to a shipment leaving the station's protected
- area. The inspector visited the fire department's emergency center and performed an accident emergency drillinvolving the above radioactive materials shipment. Fire department personnel responding to the accident emergency drill were knowledgeable of the shipment contents, obtained pertinent information concerning the postulated accident from the carrier reporting the shipment accident, and provided appropriate ,
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emergency radiological and safety information to the carrier at the simulated scene of the shipment accident. Fire department personnel also immediately notified the responsible health physics and radioactive materials control group personnel by use of the licensee's paging system. The health physics staff responded immediately to their page and were supplied with appropriate accident deals and emergency response {
information. The emergency response to the transportation accident drill was performed l in accordance with procedure. No problems were identifie l f: I
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-7-c. Conclusions A very good transportation program for radioactive waste and materials was maintaine Shipping documentation and packages were properly prepared for shipment. Proper emergency telephone numbers were included on shipping manifests. The licensee's fire department responded properly to the transportation accident emergency drill scenari R3 Radiological Protection and Chemistry Procedures and Documentation The inspector reviewed the procedures used to implement the solid radioactive waste management and transportation programs. Detailed procedures provided excellent guidance for the handling, processing, and shipping of radioactive waste and radioactive material R4 Staff Knowledge and Performance The inspector interviewed members of the radioactive material control group responsible for the implementation of the solid radioactive waste management program and performance of radioactive waste / materials shipping activities. The radioactive material control group staff was experienced and had an excellent working knowledge of the transportation regulation R5 Staff Training and Qualification a. !nsoection Scoce (86750)
The inspector reviewed the training and qualification requirements of personnel responsible for the preparation and packaging of radioactive waste and radioactive materials for shipment. .The following items were reviewed:
. Instructor qualifications
. Continuing training program
.. Training materials related to 10 CFR Part 71 and 49 CFR Parts 171-179
. Personnel training and qualification records b. Observations and Findinas The inspector reviewed the qualifications of the instructors assigned to provide initial and continuing solid radioactive waste management and transportation training to the staff involved in the packaging, storage, and transportation of radioactive waste and materials. The inspector determined that the trainir g instructors had attended appropriate vendor conducted training on the handling of hazardous material and the
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transportation regulations. The instructors had a good technical background in the
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i A good training program was conducted in accordance with commitments made in the licensee's response to NRC Bulletin 79-19," Packaging of Low-Level Radioactive Waste for Transport and Burial." A review of selected solid radioactive waste management and
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transportation lesson plans revealed that plant management was appropriately involved in the development and review of these plans. The inspector determined that the plans were organized, well written, and site and industry lessons learned were included in the !
continuing training material. The training department's lesson plans and vendor j supplied course materials provided a comprehensive training progra A review of the training schedule revealed that training was provided in accordance with ,
the requirements of 49 CFR Part 17 !
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controls group staff assigned the responsibility to implement the solid radioactive waste processing and transportation activities were properly trained and qualifie c. Conclusions i
A strong solid radioactive waste management and transportation training program was l maintained. The instructors assigned to provide initial and continuing solid radioactive !
waste management and transportation training had a good technical background in these program areas. Lesson plans were well written, and plant management was appropriately involved in the development and review of the training material R6 Radiological Protection and Chemistry Organization and Administration The health physics department's organization and staffing of the radioactive material control group for the implementation of the solid radioactive waste management and transportation programs were reviewed. During the past year, there were several personnel changes in the supervisory positions within the radioactive materials control groupi These personnel changes were the result of promotional opportunities within the radioactive materials control group. Because of the knowledge and experience of the personnel involved, the staff changes in the radioactive materials control group 4 supervisory positions did not reduce the effectiveness of the solid radioactive waste !
management and transportation programs. The inspector determined that an effective !
organization and experienced staff were maintained to properly implement the solid j radioactive waste management and transportation program '
R7 Quality Assurance in Radiation Protection and chemistry Activities i insoection Scope (86750)
The inspector interviewed licensee personnel and reviewed the following: .
. Auditor qualifications l
. Quality assurance audits and checklists i Leadership observation program reports . Vendor audits
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b. Observations and Findinas The inspector reviewed the qualifications of the leao auditor responsible for the oversight of the solid radioactive waste management and transportation programs and determined that this individual was properly trained to assess the programs. The inspector noted that the auditor attended the appropriate vendor conducted solid radioactive waste and transportation training course Quality Assurance Audit Report SCES-807-98," Packaging and Transportation of Radioactive Material," was performed since the previous NRC inspection of this area in April 1997. This biennial audit was thorough, compliance and performance based, and included the appropriate areas to properly assess the solid radioactive waste management and transportation programs. The audit verified compliance with applicable federal regulations, Technical Specifications, established station procedures, and the effectiveness of corrective actions. Checklists used for the audit provided assurance that program areas were prope ly reviewed. One administrative issue was identified during the audit. This issue was properly documented and tracked in the station's problem review reporting syste Thirty-one nuclear oversight division leadership observation program reports pertaining to the solid radioactive waste management and transportation programs were written since April 1997. The inspector determined that the quality assurance observation program reports properly assessed the areas reviewed. These obsen/ation program reports were thorough and provided management with a good assessment of the solid radioactive waste management and transportation program areas reviewed. The inspector determined that when the audited areas were combined with the observation program reports, they provided management with a very good assessment of the solid radioactive waste management and transportation program The inspector reviewed selected solid radioactive waste and transportation action j reports written since April 1997 and noted that the licensee identified issues at the proper threshold. In general, response timeliness was appropriate and corrective actions appeared to be effective to correct identified issues. The inspector noted no negative trends during the revie Contractors were used to provide radwaste disposal services and radiochemistry analyses of radwaste samples for 10 CFR Part 61 waste classification and characterization requirements. Nuclear procurement issues committee audits of the contractors were used to evaluate the performance of their respective radwaste activities. No problems were identified during the review of the vendor audit Conclusions An effective quality assurance program was in place. The biennial audit, when combined with leadership observation program reports, provided management with a good assessment of the solid radioactive waste management and transportation l programs. No negative trends were identified during the review of solid radioactive l waste and transportation action reports. Appropriate evaluation of the contractor's I performance was performed.
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I i-10-R8 Miscellaneous Radiation Protection and Chemistry issues i R (Closed) Inspection Follow-up Item 50-361:362/9710-01: Personnel Selection Process l to Ensure that Personnelinvolved in Transportation Activities Received 49 CFR Part l 172, Subpart H, Training l This inspection follow-up item dealt with the selection and documentation of hazardous
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material training of craft personnel assigned to support the radioactive material control group during packaging, handling, and transportation activities of radioactive materials and wastes. Specifically, the item was concerned with lack of a documented review i process to verify that craft personnel had received appropriate hazardous material training in accordance with 49 CFR Part 172, Subpart H, prior to performing ancillary i support tasks involving the handling, processing, and shipping of radioactive materials ,
and wastes. The inspector reviewed and verified that the licensee had properly i addressed the inspection follow-up item's personnel training concerns and had completed appropriate corrective actions. The licensee revised their response to NRC Bulletin 79-19, "4 ckaging of Low-Level Radioactive waste for Transport and Burial,"
and clarified wt = were considered HAZMAT employees and what level of hazardous material training was required for personnel performing ancillary support duties during shipping activities. The licensee revised appropriate training and health physics procedures to specifically address the training requirements for all personnel involved in performing shipping activities. The licensee had also developed a hazardous material training course specifically designed for training craft personnel involved with the handling, processing, and shipping of radioactive materials and radioactive wastes. In addition, the licensee had developed a mechanism using specific radiation exposure permits (REPS) for solid radioactive waste / materials processing, handling, and shipping activities and interfacing these REPS with the integrated health physics system data base to verify that personnel signing in on the radwaste REPS had successfully completed the appropriate hazardous material training prior to being authorized to i perform work controlled by a REP requiring HAZMAT employee training. The inspector reviewed the licensee's revised response to NRC Bulletin 79-19 and found that it satisfactorily defined who was specifically designated as a HAZMAT employee and, therefore, was required to receive hazardous material training. The inspector attended a hazardous material employee training session for craft personnel and determined that-the course material and training presentation satisfactorily met the training requiremen The inspector verified that the implementation of two specific REPS for solid radioactive waste and materials processing, handling, and shipping activities were successfully interfaced with the integrated health physics system data base so as to ensure that only those employees who had completed the necessary hazardous material training were allowed to sign on the REP. The inspector also verified that the appropriate health physics engineers associated with the radioactive materials group shipping activities had received the required training on hazardous material and shipping regulations. The l inspector concluded that the licensee's completed corrective actions satisfactorily addressed the inspector's concerns and provided appropriate hazardous materials training to support personnel assisting with shipping activities that directly affected transportation safet .
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-11-V. Manaaement Meetinos X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at an exit meeting on August 21,1998. The licensee acknowledged the findings presented. No proprietary information was identifie l
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ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee C. Ahola, Supervisor, Shipping / Receiving, Radioactive Material Control Group C. Anderson, Manager, Emergency Planning, Site Emergency Preparedness i J. Barrow, Supervisor, Operational Support, Health Physics E. Bennett, Auditor, Nuclear Oversight R. Borden, Supervisor, Nuclear Oversight P. Elliott, Supervisor, Radioactive Material Control Group, Health Physis R. English, Supervisor, Packaging / Accountability, Radioactive Material Control Group {
M. Farmer, General Foreman, Radioactive Material Control Group l G. Gibson, Manager, Compliance E. Goldin, Supervisor Health Physics and Engineering, Nuclear Regulatory Affairs M. Hunter, Coordinating Technical Specialist, Nuclear Oversight R. Krieger, Vice President, Nuclear Generation J. Madigan, Manager, Health Physics ,
S. Mahler, Engineer, Nuclear Regulatory Affairs D. Nunn, Vice President, Engineering and Technical Services
- B. Pennington, Supervisor, Fire Department, Site Emergency Preparedness A. Scherer, Manager, Nuclear Regulatory Affairs -
K. Slagle, Manager, Nuclear Oversight C. Stinson, Supervisor, Nuclear Training NRC J. Sloan, Senior Resident inspector J. Kramer, Resident inspector-INSPECTION PROCEDURES USED IP 86750 Solid Radioactive Waste Management and Transportation of Radioactive Materials ITEMS OPENED. CLOSED. AND DISCUSSED Closed 361/9710-01; IFl Personnel Selection Process to Ensure that Personnel involved in
~ 362/9710-01 Transportation Activities Received Appropriate 49 CFR Part 172, j Subpart H, Training i
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l 2-LIST OF DOCUMENTS REVIEWED ORGANIZATION CHARTS Health Physics Division - July 1998 TRAINING DOCUMENTATION Vendor Training Course WMG RC-100, "Radwaste Packaging, Transport, and Disposal Regulations," Revision 7, presented April 28,1998 SO123-XXI-1.1 " Health Physics Personnel Training Program Description," Revision 6 Lesson Plan RWR-396, "1996 Radioactive Material Control Personnel Continuing Training" Lesson Plan RWR-497, "1997 Radioactive Material Control Personnel Continuing Training" Lesson Plan PKG-171," Trash Compactor Operation" Lesson Plan PKG-175," Radioactive Waste Packaging / Accountability" Lesson Plan PKG-186," Packaging of Low Specific Activity" Lesson Plan SHP-024. " Packaging Radioactive Waste" Lesson Plan SHP-025, " Regulations for Packaging Radioactive Waste for Disposal" Lesson Plan SHP-053," DOT Shipping Regulations for Radioactive Materia!"
Lesson Plan SHP-137,"NRC Shipping Regulations for Radioactive Material" Lesson Plan SHP-144," Procedures for Solid Waste Curie Determination" Lesson Plan SHP-145," Loading Vans for Shipping" Lesson Plan SHP-207," Waste Stream Analysis"
, Radioactive Material Controls Group personnel training records Licensee's revised response to NRC Inspection and Enforcement Bulletin 79-19
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3-OUALITY ASSURANCE DOCUMENTS Quality Assurance Master Audit Schedule for 1998 Topical Quality Assurance Manual (TOAM), Revision 4, December 20,1996 SO123-Xil-1 " Scheduling of Audits," Revision 4, October 3,1997 SO123-Xil-18.15 " Nuclear Oversight Surveillance and Observation Program," Revision 2 March 31,1998 Audit Quality Assurance Audit Report SCES-807-98, " Packaging and Transportation of Radioactive Material from San Onofre Nuclear Generating Station," March 31 through April 30,1998 Leadershio Observation Proaram Reports Observation Program Reports of selected laundry, radioactive materials, and radioactive waste shipments performed during the period May 1997 and June 1998 Vendor Audits NUPIC Joint Quality Assurance Vendor Audit of Molten Metal Technology of Tennessee, conducted November 4-7,1997 NUPIC Joint Quality Assurance Vendor Audit of Thermo Nutech, conducted December 9-12,1996 PROCEDURES SO123-Vll- " Solid Radioactive Waste Sampling for Classification and Typification,"
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SO123-Vil-8. " Solid Radioactive Waste Packaging for Class A Unstable Waste," !
Revision 7 l SO123 Vil-8. "Use of Enviralloy High integrity Container (HIC) For Solid Waste Disposal," Revision 5 )
l SO123-Vil- " Shipment of Radioactive Material," Revision 15 I SO123-Vll-8. " Shipment of Radioactive Waste for Land Disposal at Barnwell, South Carolina," Revision 7 SO123-Vil-8.2.10 " Receipt of Radioactive Material," Revision 7 SO123-Vil-8.2.12 " Shipment of Radioactive Waste for Land Disposal at the Envirocare Facility at Clive, Utah," Revision 0 SO123-Vil-10 " Health Physics Computer Systems Quality Control Program," Revision 2 j
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SO123-XV-28 Radioactive Waste Minimization Program," Revision 0 MISCELLANEOUS DOCUMENTS Annual Radioactive Effluent Release Reports for 1996 and 1997 (Solid Radwaste portions only).
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