ML19325D777

Draft IP 71124.08

ML19325D777
Person / Time
Issue date:	12/05/2019
From:	David Garmon-Candelaria NRC/NRR/DRA/ARCB
To:
Smith M
References
Download: ML19325D777 (11)

Text

NRC INSPECTION MANUAL ARCB INSPECTION PROCEDURE 71124 ATTACHMENT 08 RADIOACTIVE SOLID WASTE PROCESSING AND RADIOACTIVE MATERIAL HANDLING, STORAGE, AND TRANSPORTATION Effective Date: January XX, 2020 PROGRAM APPLICABILITY: IMC 2515 App A CORNERSTONES: Public Radiation Safety (80 percent)

Occupational Radiation Safety (20 percent)

INSPECTION BASES: See IMC 0308 Attachment 2 SAMPLE REQUIREMENTS:

Sample Requirements Minimum Baseline Sample Budgeted Range Completion Requirements Sample Type Section(s) Frequency Sample Size Samples Hours Radioactive Material 03.01 Biennial 1 per site 1-3 per site 34 +/- 4 per site Storage and Control Solid Radioactive 03.02 Biennial 1 per site 1-3 per site Waste System Walkdown Waste 03.03 Biennial 2 per site 2-3 per site Characterization and Classification Shipment 03.04 Biennial 1 per site 1 per site Preparation Shipping Records 03.05 Biennial 3 per site 3-5 per site 71124.08-01 INSPECTION OBJECTIVES 01.01 To verify the effectiveness of the licensees programs for processing, handling, storage, and transportation of radioactive material.

01.02 To conduct a routine review of problem identification and resolution activities per Inspection Procedure (IP) 71152, Problem Identification and Resolution.

Issue Date: 1 71124.08

71124.08-02 GENERAL GUIDANCE Whenever possible, inspectors should coordinate the inspection schedule with the licensee to coincide with risk-significant activities so that licensee performance can be directly observed.

Inspectors should review the solid radioactive waste system description in the Final Safety Analysis Report (FSAR), the Process Control Program (PCP), and the most recent Annual Radiological Effluent Release Report (ARERR) for information on the types and amounts of radioactive waste disposed.

Inspectors should review results of radiation protection program audits related to this area (e.g.,

licensees quality assurance (QA) audits, self-assessments, access authorization program reviews, Part 37 security program reviews or independent audits) since the last inspection. The reviews of these audits should be used to gain insights into overall licensee performance and focus the inspectors activities consistent with the principle of smart sampling.

Inspectors should review the radioactive waste and radioactive shipment records since the last inspection. These records should be used to gain insights into the radioactive material shipments made and the type of transport packages used.

For each sample, conduct a routine review of problem identification and resolution activities using Inspection Procedure (IP) 71152, Problem Identification and Resolution. Per IP 71152, it is expected that routine reviews of Problem Identification and Resolution (PI&R) activities should equate to approximately 10 to 15 percent of the resources estimated for the associated baseline cornerstone procedures, this is a general estimate only based on the overall effort expected to be expended in each strategic performance area. It is anticipated that the actual hours required to be expended may vary significantly from attachment to attachment, depending on the nature and complexity of the issues that arise at the particular facility. Overall, an effort should be made to remain within the 10 to 15 percent estimate on a strategic performance area basis. Inspection time spent assessing PI&R as part of the baseline procedure attachments should be charged to the corresponding baseline procedure.

71124.08-03 INSPECTION SAMPLES 03.01 Radioactive Material Storage and Control Sample Verify radioactive materials are controlled, labelled and secured against unauthorized removal.

Specific Guidance

a. Consider inspection of temporary radioactive material storage areas that are established to support plant outage activities as well as long-term storage facilities that can be inspected during non-outage periods.

b. Consider if the licensee is performing periodic container inspections sufficient to meet applicable requirements.

Issue Date: 2 71124.08

c. Select a representative sample of containers of stored radioactive materials, and observe for signs of swelling, leakage, and deformation. Consider if buildup of any gases produced by waste decomposition or chemical reactions results in container deformation or loss of container integrity.

d. For radioactive materials in controlled or unrestricted areas consider if they are secured against unauthorized removal or access; if they are controlled and maintained under constant surveillance; and if they are physically protected, as required.

e. Consider if the licensee has adequately evaluated radioactive material to determine if the material contains aggregated quantities of category 1 or category 2 material as defined by 10 CFR Part 37. Inspectors should focus on material that is located outside of the protected area (PA) or that has the potential to be moved outside the PA.

f. Review the annual access authorization program review and consider if unauthorized personnel were granted access to category 1 or category 2 material that is stored outside the PA.

g. Consider if the personnel who implement the 10 CFR Part 37 security program (e.g.,

security staff and health physics staff) are trained appropriately and receive refresher training.

h. Review the 10 CFR Part 37 annual security program review and consider the following:

1. For material stored outside the PA, failures of equipment used to detect the unauthorized removal of category 1 and category 2 material;

2. For material stored outside the PA, failures to maintain continuous surveillance of category 1 material during periods when physical barriers or intrusion detection systems were disabled (e.g., during periods of movement);

3. For radioactive waste that is stored outside of the PA and that contains category 1 or category 2 quantities of radioactive material, failures to correctly apply the exemption criteria of 10 CFR 37.11(c);

4. Failures to respond appropriately to any actual or attempted theft or diversion of category 1 or category 2 material;

5. Failures to notify the local law enforcement agency (LLEA) or the NRC of an actual theft or diversion of category 1 or category 2, or of LLEA to respond to notifications as coordinated with the site; and

6. Actual cases where category 1 or category 2 radioactive material was accessed by unauthorized individuals, stolen or diverted from its intended location.

i. Note: For issues that can potentially result in a licensees violation of Part 73 requirements consult regional security inspection staff to resolve how to disposition the issue.

Issue Date: 3 71124.08

j. Select sealed sources from the licensees inventory that present the greatest radiological risk. Consider if the sources are accounted for and have been verified to be intact (i.e., they are not leaking their radioactive content).

Licensees are required under 20.1501(a)(2) to conduct surveys that are reasonable under the circumstances to evaluate the magnitude and extent of radiation levels; evaluate quantities of radioactivity; and evaluate potential radiological hazards.

Some plants have technical specification (T.S.) requirements to inventory and leak test sources greater than a certain activity (e.g., > 100 microcurie beta/gamma, and 5 microcurie alpha activity). Other plants may have moved this requirement to a licensee-controlled document. In cases where the specific requirements, as stated in a plants license, are different than the applicable regulations, licensees are obligated to meet the specific requirements as stated in their license. Therefore, it is possible that a licensee would be obligated to leak test sources that are otherwise exempt from leak testing per NRC regulations because that licensees T.S. contains a provision that generically states that sources above a certain level require leak testing.

The focus of this specific inspection item is on sealed sources that present the greatest radiological risk in the event their leakage is not adequately monitored. Devices that only contain exempt concentrations (10 CFR 30.14) or exempt quantities (10 CFR 30.18); or certain devices that are exempt from NRC materials licensing requirements under 10 CFR 30.15, 10 CFR 30.19, 10 CFR 30.20 or 10 CFR 30.22; or devices that contain generally licensed by-product materials that are exempt from leak testing as described in 10 CFR 31.5(c)(2)(i) or (ii) do not require leak testing per NRC regulations and do not fall within the scope of this inspection item.

High activity irradiators/calibrators are required to be registered in the NRC Sealed Source and Device Registry (SSDR). The SSDR lists which sources can be used in a particular device, the frequency for leak tests, the ANSI Category (ANSI CAT I is a self-shielded irradiator whereas a CAT II would fall under 10 CFR Part 36, Licenses And Radiation Safety Requirements For Irradiators), conditions of normal use, and other information related to the use of the device.

Routine maintenance can be performed by licensee personnel, but non-routine maintenance must be performed by the device manufacturer (or distributor) or a person specifically authorized by NRC or an Agreement State.

k. Determine if any transactions since the last inspection involving nationally tracked sources were reported in accordance with 10 CFR 20.2207.

03.02 Solid Radioactive Waste System Walk-Down Sample Walkdown accessible portions of a solid radioactive waste system and verify that the selected system is correctly configured and able to perform its intended function.

Specific Guidance

a. Consider radioactive waste processing equipment that is abandoned in place and evaluate licensee controls to ensure that the equipment will not contribute to an unmonitored release path and is isolated from operating systems.

Issue Date: 4 71124.08

b. Consider radioactive waste processing equipment that is not operational and has not been abandoned in place and evaluate licensee actions to repair and return the equipment to service. Consider if the licensee is meeting T.S. requirements on the use of radioactive waste processing equipment to ensure that appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a period of 31 days would exceed 2% of the guidelines for the annual dose or dose commitment, conforming to 10 CFR Part 50, Appendix I.

c. Review any changes made to the radioactive waste processing system. Consider if changes from what is described in the FSAR were reviewed and documented as required, and, if applicable, that the licensee has reviewed the safety significance of equipment abandoned in place. If the licensee uses a vendor to perform onsite waste handling or processing, consider if any changes in the system configuration were made in accordance with vendor manuals, diagrams and procedures.

d. Consider if the waste stream mixing, sampling procedures, and methodology for waste concentration averaging are consistent with the PCP and the BTP on concentration averaging and encapsulation, and the BTP on waste classification.

e. For those systems that provide tank recirculation, consider if the tank recirculation procedure provides sufficient mixing. Generally, a minimum of three volumes of mixing is provided. See ASTM D3370-10, Standard Practices for Sampling Water from Closed Conduits section 11.4 for tank recirculation information and section 12.2 for sample line flushing.

f. The licensees PCP should correctly describe the current methods and procedures for dewatering and waste stabilization. Consider if the licensee is using the process for the removal of freestanding liquid, particularly prior to shipment. If the licensee uses an on-site vendor to perform dewatering or waste stabilization, inspect the methods and procedures to assure compliance with vendor manuals, diagrams and procedures.

03.03 Waste Characterization and Classification Sample Verify the licensee characterizes and classifies radioactive waste.

Specific Guidance

a. Consider if the licensee correctly uses radiochemical analyses results to support radioactive waste characterization and if the licensees use of scaling factors and calculations to account for hard to detect radionuclides is technically sound.

b. Waste generators shipping material intended for ultimate disposal (even through a waste processor) are required to document information on the Uniform Low-Level Radioactive Waste Manifest (NRC Forms 540 and 541) in accordance with 10 CFR 20.2006, which will require some characterization of the shipment. However, the waste classification section on NRC Form 541 is only required if the waste is consigned to a disposal facility. Instructions on filling out these forms (and what is/isnt required based on destination) can be found in 10 CFR Part 20, Appendix G and NUREG/BR-0204.

c. Consider if changes to plant operational parameters (changes in reactor coolant Issue Date: 5 71124.08

chemistry (e.g., fuel integrity or corrosion film morphology)) are accounted for (1) to maintain the validity of the waste stream composition data with respect to the sample analysis update, and (2) to verify that waste shipments continue to meet the requirements of 10 CFR 20.2006 and 10 CFR Part 20, Appendix G.

Note: The frequency of sample analysis update may be increased or decreased based on consideration of the waste stream. Scaling factors may be used for H-3, C-14, Tc-99 and I-129 - see RIS 2015-02, Reporting of H-3, C-14, Tc-99 and I-129 on the Uniform Waste Manifest. Licensee staff may monitor reactor coolant radiochemistry as a method of determining if the waste stream composition has changed.

d. Consider if the licensee maintains an adequate QA program to ensure compliance with the waste classification and characterization requirements of 10 CFR 20.2006 and 10 CFR Part 20, Appendix G.

03.04 Shipment Preparation Sample Observe that a shipment containing radioactive material is prepared according to requirements.

Specific Guidance

a. Observe plant workers conducting radioactive material shipment preparation. When observations are not available document the inability to complete this sample in accordance with IMC 0306.

b. Consider the adequacy of shipment preparation (e.g., shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency response information, disposal manifests, shipping papers provided to the driver, and licensee verification of shipment and recipient readiness), as applicable.

c. Consider how the licensee meets requirements for highway route control quantities (HRCQs) of materials in transport, if applicable.

03.05 Shipping Records Sample Verify the adequacy of a non-excepted package shipment through record review.

Specific Guidance

a. Consider if the licensee selected the correct package for shipment.

b. Consider reviewing non-excepted package shipment (LSA I, II, III; SCO I, II; Type A or Type B) records. As a minimum, consider if the shipping documents indicate the proper shipper name; emergency response information and a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and United Nations (UN) identification number. Also consider if the shipment marking, labeling, and placarding is consistent with the information in the shipping documentation.

c. Inspectors should focus on the most important parameters such as waste volume, Issue Date: 6 71124.08

waste weight, allowable void space and radiological survey information, and isotopic analysis (including hard-to-detects).

d. For packages characterized using specific activity calculations, the inspectors should focus on the representativeness of the sample used (e.g., was the waste mixed adequately prior to obtaining a sample); see ASTM D3370-10. For packages characterized by dose-to-curie methodology, the inspectors should focus on the adequacy of the radiological survey information used (e.g., were measurements taken at the appropriate distance and was a current survey date used).

e. Consider if site personnel involved in the preparation and shipment of radioactive material are trained and qualified in accordance with licensee procedures and applicable regulations.

f. Consider how the licensee meets requirements for HRCQs of materials in transport, if applicable.

g. For Type B shipments, consider if the requirements of the transport package Certificate of Compliance (CoC) have been met; that the user is a registered package user and has an NRC approved QA program; and that the licensee followed procedures for cask loading and closure procedures consistent with the vendors current approved procedures.

h. For non-Type B shipments (Type A, Industrial Package, General Design packages),

consider if the shipment is made in accordance with the package quality documents.

i. Consider if the licensees procedures for package loading and closure procedures are followed and are consistent with the vendors current approved procedures.

j. For shipments of category 1 or category 2 material, consider if the licensee met the requirements for recipients license verification.

k. For shipments of category 1 or category 2 material, review documentation describing preplanning and coordination activities as follows.

1. For shipments of category 1 material, consider if adequate movement control centers are established; if communications are adequate; if the driver is provided with an accompanying individual (if applicable); and if the driver is provided with written normal and contingency procedures.

2. For shipments of category 2 material, consider if the shipment is in constant control and surveillance of the licensee (or carrier); if the licensee (or carrier) has the capability to immediately establish communications; and, for situations when a licensee uses a carrier, if the carrier requires an authorized signature prior to release of the material for delivery.

l. Consider if the licensee satisfied the advanced notification requirements applicable to category 1 material shipments.

Issue Date: 7 71124.08

71124.08-04 REFERENCES 10 CFR Part 71, Packaging and Transportation of Radioactive Material, 49 CFR Part 172, Hazardous Materials Table, Special Provisions, Hazardous Materials Communication, Emergency Response Information, Training Requirements, and Security Plans, Subpart H, Training RG 1.21, Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste RG 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments RG 1.181, Content of the Updated Final Safety Analysis Report in Accordance with 10 CFR 50.71(e)

RG 4.15, Quality Assurance for Radiological Monitoring Programs (Inception through Normal Operations to License Termination)

RG 4.22, Decommissioning Planning during Operations RG 7.7, Administrative Guide for Verifying Compliance with Packaging Requirements for Shipping and Receiving of Radioactive Material RG 7.10, Establishing Quality Assurance Programs for Packaging Used In Transport Of Radioactive Material, Revision 3 RG 8.8, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be as Low as Is Reasonably Achievable NRC Bulletin 1979-19, Packaging of Low-Level Radioactive Waste for Transport and Burial, dated August 10, 1979, NRC Regulatory Issue Summary 2008-32, Interim Low Level Radioactive Waste Storage at Reactor Sites NRC Regulatory Issue Summary 2015-02, Reporting Of H-3, C-14, Tc-99, and I-129 On the Uniform Waste Manifest NRC Information Notice 1986-20, Low-Level Radioactive Waste Scaling Factors, 10 CFR Part 61, March 28, 1986 NRC Information Notice 1990-50, Minimization of Methane Gas in Plant Systems and Radwaste Shipping Containers, August 8, 1990 NUREG-1556, Consolidated Guidance About Materials Licenses, Volume 18, Program-Specific Guidance About Service Provider Licenses, August 2017 NUREG-1608, Categorizing and Transporting Low Specific Activity Materials and Surface Contaminated Objects Issue Date: 8 71124.08

NUREG/BR-0204, Instructions for Completing NRC's Uniform Low-Level Radioactive Waste Manifest NUREG-1660, U.S.-Specific Schedules for Transport of Specified Types of Radioactive Material Consignments NUREG-2155, Implementation Guidance for 10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material NRC, Revised Staff Technical Position on Waste Form (SP-91-13), dated January 30, 1991, (ML033630746)

NRC, Concentration Averaging and Encapsulation Branch Technical Position, Vol. 1 February 2015, (ML12254B065)

NRC, Concentration Averaging and Encapsulation Branch Technical Position, Vol. 2, Response to Stakeholder Comments and Technical Basis, February 2015, (ML12326A611)

NRC, Changes to the Radioactive Material Packaging and Transportation Regulations, (ML16004A174)

NEI 96-07, Rev.1, Guidelines for 10 CFR 50.59 Evaluations, (ML003686043)

NEI 98-03, Rev.1, Guidelines for Updating Final Safety Analysis Reports, (ML003779028)

NEI 07-10A, Generic FSAR Template Guidance for Process Control Program (PCP),

(ML091460627)

END Issue Date: 9 71124.08

Attachment 1 - Revision History for IP 71124 Attachment 08 Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training Required and Closed Feedback Number Issue Date and Completion Form Accession Change Notice Date Number (Pre-Decisional, Non-Public Information)

N/A 12/02/09 Conducted four year search for commitments YES ML092810433 CN 09-030 and found none. 09/09/2009 This new procedure is being issued as a result of the 2009 ROP IP Realignment. It supersedes inspection requirements in IP 71121 and IP 71122.

N/A ML15345A075 Major revisions to the IP 71124 Attachment N/A ML1534508101/26/16 08 were made in response to the 2013 ROP CN 16-003 Enhancement Project.

The revisions clarified the existing inspection requirements and enhanced the inspection guidance section. The revision also changed how samples are counted.

Issue Date: Att 1-1 71124.08

Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training Required and Closed Number Issue Date and Completion Feedback Form Change Notice Date Accession Number (Pre-Decisional, Non-Public Information)

N/A ML17286A292 Major editorial revision of IP 71124.08 to Verbal discussion of ML17300A477 12/21/17 accommodate the launch of the new RRPS changes during CN 17-031 system. 2017 HP Counterpart Added guidance to 03.05 concerning meeting, 09/06/2017 evaluation of shipping records.

Section 02 was audited and modified to move guidance to Section 03 and concisely state actions necessary to complete each requirement PI&R was transitioned from an independent sample to a requirement that would be completed as part of each sample.

Guidance section updated to reflect resource estimates for routine review of PI&R activities per IP 71152 Section 04.01.

N/A Major editorial revisions of IP 71124.08 to Verbal discussion of conform with IMC 0040 formatting guidance. changes during 2019 HP Addition of specific guidance to provide Counterpart oversight of Part 37-related performance in Meeting, 09/04/2019 sections 03.01 and 03.05 Dedicated Part 37 Moved inspection guidance for sealed training during sources from IP 71124.01 to IP 71124.08 as calendar year 2020.

reflected in section 03.01.j.

Issue Date: Att 1-2 71124.08