ML20033F865
| ML20033F865 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/1988 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Gillespie F Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20033F829 | List: |
| References | |
| REF-WM-3 NUDOCS 9004030287 | |
| Download: ML20033F865 (3) | |
Text
L
.b MEMO TO F. GILLESPIE/IP 1
' MEMORANDUM FOR: Frank P. Gillespie, Director Program Management, Policy Developrent and Analysis Staff, NRR FROM:
Richard L. Bangart, Acting Director Division of Low-Level Waste Management and Decoamissioning, HMSS
SUBJECT:
COMMENTS ON DRAFT INSPECTION PROCEDURE (IP) 83750, "0CCUPATIONAL EXPOSURE, SHIPPING, AND TRANSPORTATION" In response to your memo of June 8,1988, requesting Division of Low-Level Waste Management and Decommissioning connents on the above subject inspection procedure (IP), we have enclosed our specific comments.
i In order to provide the proper vaphasis, we reconnend that the inspection reouirements and guidance contained in IPs 83750 and 84750 for low-level waste and transportation be combined into a new core inspection procedure and given a j
separate number. The new core inspection procedure should contain two separate sections: one for transportation and the other for low-level waste.
We have discussed the above approach with Al Grella (SGTR) and SGTR does not have any objections.
I will be pleased to meet with you on this issue, if you so desire. Our staff contact is Roy Person (X20575).
ORIMAL SIGNED BY l
I Richard L. Bangart, Director Division of Low. Level Waste Management and Decommissioning, HMSS
Enclosure:
As stated cc: Fred Hebdon, ILRB Al Grella, SGTR DISTRIBUTION:
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l DATE: 6/23/88
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OFFICIAL RECORD COPY
MEH0 TO F. GILLESPIE/IP MEMORANDUM FOR:
Frank P. Gillespia, Director l
Program Management, Policy Development p
and Analysis Staff, NRR FROM:
Richard L. Bangart, Acting Director Division of Low-Level Waste Management l
and Deconmissioning, NMSS
SUBJECT:
COMMENTS ON DRAFT INSPECTION PROCEDURE (IP) 83750, "0CCUPATIONAL EXPOSURE, SHIPPING, AND TRANSPORTATION" In response to your memo of June 8,1988, requesting Division of Low. Level Waste Management and Decommissioning consnents on the above subject inspection procedure (IP),wehaveenclosedourspecificcomments.
In order to provide the proper vaphasis, we recommend that the inspection requirements and guidance contained in IPs 83750 and 84750 for low-level waste and transportation be combined into a new ore inspection procedure and given a separate number.
The new core inspection procedure should contain two separate sections: one for transportation and the other for low-level waste.
WehavediscussedtheaboveapproachwithAlGrella(SGTR)andSGTRdoesnot have any objections.
I will be pleased to meet with you on this issue, if you so desire. Our staff contact is Roy Person (X20575).
ORIGINAL SIGNED BY Richard L. Bangart, Director Division of Low. Level Waste Management and Decommissioning, HMSS l
Enclosure:
As stated cc:
Fred Hebdon, ILRB Al Gre11a, SGTR DISTRIBUTION:
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central File HMSS rf LLOB rf LPerson, LLOB SBahaour LLOB
.>L t r.-LLOB JSurmeier, LLTB MBell, LLRB JGreeves. LLWM RRangart, LLWM TCJohnson, LLRB THuffert, IMNS 9004030287 900326
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i SUGGESTED CHANGES TO CORE INSPECTION PROCEDURE l
FOR OCCUPATIONAL EXPOSURE, SHIPPING, AND TRANSPORTATION l
(IP83750) l 1.
The title of the document should be changed to " Core Inspection Proceoure for Occupational Exposure, Transportation ano Low-Level Wastes."
2.
83729-01, Inspection Objectives; par. 3.
Change this sentence to read "To provide early identification of potential public health and safety problems resulting from processing, packaping and shipping low-level radioactive wastes and transportaticn of iconsed radioactive materials."
3.
83729-02, Inspection Requirements; sec. 02.09. Change the title to
" Transportation Activities" and incorporate SGTR's recommendations.
j 4.
83729-02, Inspection Requirements; sec. 02.10.
Create this new section with the title " Low-Level Waste Activities." and include the following elements; a)
If the licensee has disposed of LLW, determine whether the licensee has established and is implementing procedures for proper classification and characterization of wastes, for preparation of waste manifests, marking of packages with the class of wasta, and investigation of lost shipments.
Detemine whether the licensee has established and is implementin CFR 61.55. g a program to classify wastes in accordance with 10 Determine whether the licensee has established and is implementing a program to meet the waste form requirements of 10 CFR 61.56.
Review the licensee's Process Control Program for waste solidification and dewatering to ensure these programs are being implemented in accordance with technical specifications and written procedures.
Determine whether the licensee has established and is implementing a program to prepare wasta shipments and manifests in accordance with 10 CFR 20.311.
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.
5 Review reports of required audits since the last inspection.
l Are the corrective actions timely and technically appropriate?
b)
Determine the adequacy of processing, control, and storage of solid wastes.
Review the licensee's program from waste storage to ensure that storage activities are properly performed in accordance with written procedures.
Review the licensee's experience in maintaining and using waste solidification systems. Note problems encountered in using these systems, c)
Review changes in equipment and procedures and detemine whether changes are in accordance with 10 CFR 50.59.
Discuss significant changes in equipment and procedures with cognizant management.
(See IE Circular No. 80-18) 5.
In addition, add the following documents to the bibliography:
IE Information Notice Np. 86-20. " Low-Level Radioactive Waste Scaling Factor, 10 CFR 61," March 28, 1986.
IE Information Notice No. 87-07, " Quality Control of Onsite Dewatering /Solification Operations By Outside Centractors," February 3, 1987.
NRC Informatien hotice No. 88-88, " Chemical Reactions with Radioactive waste Solidification Agents," March 14, 1988.
NRC Technical Position on Waste Form and Waste Classification for 10 CFR 61, hay 1983.
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