ML20055J264
| ML20055J264 | |
| Person / Time | |
|---|---|
| Issue date: | 07/27/1990 |
| From: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Miller V NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| References | |
| REF-WM-3 NUDOCS 9008010265 | |
| Download: ML20055J264 (62) | |
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k UNITED STATES NUCLEAR REGULATORY COMMISSION W ASHING TON, D. C. 20666 t
JUL 2 7 E l
MEMORANDUM FOR:
Yandy L. Miller, Assistant Director for State Agreements Program State Programs, GPA j
FROM:
Richard L. Bangart Director Division of Low-Level Waste Management and Decommissioning, NMSS
SUBJECT:
RESPONSES TO QUESTIONS RAISED BY THE CALIFORNIA DEPARTMENT OF HEALTH SERVICES This is in response to your July 16, 1990 memorandum to me transmitting four low-leven waste items raised by the State of California Department of Health i
i Services.
The issues raised by California are associated with waste verification, uniform manifest reporting, financing of long term facility care, 6nd regulatory unwtainties.
It should be noted that the issues raised by California are very gettral and, therefore our responses to the issues are general.
If the Depat u ent of Health Services has additional technical issues that are specific to./ e application that their staff is currently reviewing, we will be glad to provide technical assistance on these issues.
VerificationofWaste-TheNRChasinspectionprocedures(attached)for waste inspections at licensed facilities. Also, the NRC staff is in the process of developing additional procedures for future LLW disposal facilities which will be licensed by NRC. These will cover all of the a)propriate licensee activities.
Current schedules cell for completion of tiese procedures in late 1991.
Verification techniques can range from drum sounding at the time of disposal to complex coring and analysis using a GeLi detector. NUREGs 1199 and 1200 also offer some limited guidance with regard to waste verification at the point of disposal.
Onsite computer systems currently used to stcre waste manifest information can assist in the verification process. For example, the software could verify the arithmetic on the manifest, check for spurious information, and perform routine cross-checks.
Uniform Manifest - The NRC staff has undertaken a rulemaking for mandatory electronic database management for LLW. Recently, Chairman Carr responded to the low-Level Radioactive Waste Forum and the Host State. Technical Co' Jinating Comunittee regarding their position that NRC should require un? urm manifest for low-level waste transport. Chairman Carr responded th6i the Conunission would consider such a requirement as part of t'1e database rulemaking currently scheduled for completion in early 1992.
We will keep California informed of NRC staff views about necessary information to be included in a uniform manifest. With this information
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California may be able to take the lead and require the developer to use
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an equivalent manifest prior to final rulemakings.
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JS/V.HILLEp/7/17 2
Financial Assurance for Long Term Care. Financial Assurance for l
i institutional controls is discussed in 10 CFR 61.63. The regulation calls i
for a binding arrangement, such as a lease, between the applicant and the disposal site owner that provides for sufficient funds to cover the cost i
of monitoring and any required maintenance during the institutional control period. NRC has not developed any further guidance related to 10 CFR 61.63 nor has NRC established generic guidance related to the amount of n.onty required for future costs.
Such monetary requirements woulo be site dtpendent.
It should also be reiterated that the 110 ou s not have regulations related to third party liability except in the case of f acilities covered by Price-Anderson Legislation. Low-Level. Waste disposal facilities are not covered by Price. Anderson.
Regulatory Uncertainties. As California pointed out in its letter to you.
1 the 11C staff is attempting to keep States informed regarding the status of its c'ealings with U.S. LFA on anos of rutual concern such as the Clean Ait Act end RCF.A Siting Standards. The NRC staff intends to continue in this practice of keeping the States informed on these issues through our interactions with State representatives at meetings of the Low. Level Waste Forum, Agreement States Workshops, the Technical Coordinating Committee, and other similar forums for information exchange.
If you have any questions about these responses, please contact Paul Lohaus at extension 20553.
(SIGNED) FWCHARD L. BlWGART Richard L. Bangart, Director Division of Low. Level Waste Management and Decommissioning, NMSS Distribution: (90 144)
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l JShaffner JKennedyi LLWM t/f LLOB r/f LLOB t/f PDR YES X
l PDR NO Category:
Proprietary or CF Only ACNW YES X
NO
- See Previous Concurrence SUBJECT AB5TTtACT: RESPDNSITTO QUESTIONS RAISED BY THE CALIFORNIA DEPARTMENT OF HEALTH SERVICES l
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JS/V. MILLER /7/17 4 Financial Assurance for Long Term Care. Financial Assurance for institutional controls is discussed in 10 CFR 61.63.
The regulation calls for a binding arrangement, such as a lease, between the applicant and the disposal site owner that provides for sufficient funds to cover the cost of monitoring and required maintenance during the institutional control period. NRC has not developed any further guidance related to 10 CFR 61.63 nor has NRC established generic guidance related to the amount of money required for future costs. Such monetary requirements would be site dependent.
It should also be reiterated that the NRC does not have regulations related to third party liability except in the case of f acilities covered by Price. Anderson Legislation.
Low-Level Waste isposal facilities are not covered by Price. Anderson.
Regu tory Uncertainties - As California pointed out in its letter to you, the NR taff is attempting to keep States informed regarding the status of its de gs with U.S. EPA on areas of mutual concern such as the Clean Air Act and A Siting Standards.
The NRC staff intends to continue in this practice f keeping the States informed on these issues through our interactions with ate representatives at meetings of the Low. Level Waste forum, Agreement Sta s Workshops, the Technical Coordinating Committee, and other similar forum for information exchange.
l If you have any questions about these responses, please contact Paul Lohaus at extension 20553.
Richa L. Bangart, Director Division of Low-Lev Waste Management and Dec issioning, NMSS l
l Distribution: (90-144)
Central File #
NMSS r/f RBangart JGreeves JAustin JSur ier PLohaus JShaf fner JKennedy LLWM t/f LLOB f
LLOB t/f PDR YES X
PDR NO Category:
Proprietary or CF ly ACNW YES X
NO
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DATE:07/24/90
- 07/24/90 :07/24/90 :07/24/90 : 1/76/90
/ /90 0FFICIAL RECORD COPY JS/V. MILLER /7/17 3
J$/LMILLER/7/17
-2 the Low. Level Radioactive Waste Forum and the Host State Technical Coordinating Comittee regarding their position that NRC should require uniform manifest for low. level waste transport. Chairman Carr ressonded that the Commission would consider such a requirement as part of tie database rulemakins.
It is noteworthy that consideration of such a change will add r.t least six months.
We will keep California inforned of NRC staff views about necessary information to be included in a uniform manifest. Witn this information California may be able to take the lead and require the developer to use an equivalent manifest prior to final rulema kings.
nancial Assurance for Long Term Care. rinancial Assurance for in itutional controls is discussed in 10 CFR 61.63. The regulation calls for binding arrangement, such as a lease, between the applicant and the dispos 1 site owner that provides for sufficient funds to cover the cost of moni ring and required maintenance during the institutional control i
period.
RC has not developed any further guidance related to 10 CFR 61, not has NRC established generic guidance related to the amount of m ey required for future costs. Such monetary requirements would be sit dependent.
It should also be reiterated that the NRC does not have regu tions rehced to third party ',iability except in the case of facilities vered oy Price. Anderson Legislation. Low. Level Waste disposal facilit e*, are not covered by Price. Anderson.
Regulatory Uncerta nties. As California pointed out in its letter to you, the NRC staff is at nipting to keep States inforned regarding the status of its dealings with
.S. EPA on areas of mutual concern such as the Clean i
Air Act and RCRA Sitin Standards. The NRC staff intends to continue in this practice of keepin the States informed on these issues through our interactions with State presentatives at meetings of the Low. Level Waste l
Forum, Agreement States Wo kshops, the Technical Coordinating Committee, l
and other similar forums fo information exchange.
If you have any questions about the e responses, please contact Paul Lohaus at extension 20553.
Rich d L. Bangart, Director Division of Low.L el Waste Management and commissioning, NMSS Distribution: (90-144)
Central F le #
NMSS r/f RBangart JGreeves JAustin JSurmeier PLohaus
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JShaffner JKennedy LLWM t/f LLOB r/f LLOB t/f l
PDR YES X
PDR NO Category:
Proprietary r
CF Only
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ACNW YES 5
NO
- See Previous C ncurrence SUBJECT ABUTlACT: RE'5MNSITTO QUESTIONS RAISED BY T CALIFORNIA DEPARTMENT l
OF HEALTH SERVICES
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- 07/24/90 :07/24/90 :07/24/90 : / /90
/ /90 0FFICIAL RECORD COPY JS/Y. MILLER /7/17 1.
JE/V. HILLER /7/17 the Low-Level Radioactive Waste forum and tb Host State 'echnical Coordinating Casiittee regarding their position that NRC should require uniform snanifest for low-1cvel waste transport.
Cheirran Carr res Sonded that the Cornission would consider such a requircirent as part of tie database ru1meling.
It is noteworthy that consiet.ation of such a change will ac'd at least six months and possibly several years to the rulemaking process.
Financial Assurance for Long Term Care. Financial Assurance for nstitutional controls is discussed in 10 CFR 61.63. The regulation calls a binding arrangen,ent, such as a lease, between the applicant and the di posal site owner that provides for sufficient funds to cover the cost of CIboitoring and required maintenance during the institutional control period, NRC has not developed any further guidance related to 10 CFR 'E1.63 nor has NRC established generic guidence related to the arnount of noney required for future costs.
Such anonstary ru;uirements s
wouldbesitedependent.
It should be pointed out that 10 CFR 61.63 mey be amended - n a future ruitmaking.
It should also be reiterated that the NRC does not have regulations related to third party liability excest in the case of f 111 tics covcred by Price-Anderson Legislation.
Low evel Waste disposal (f cilities are beyond the scope of Price-Anderson.
Regulatory Uncert4nties - As California pointed out in its letter to you, the NRC staff is atten.pting to keep States informed regarding the status of its dealings with1.S. EFA cn areas of rautual concern suc1 as the Clean Air Act and RCRA Siting Standards.
The NRC staff intends to continue in th*s practice of keepingsthe States informed on these issues through our interactions with State representatives at sectir.gs of the Low-Level Waste Torura, Agreernent States Workshops, the Technical Coordinating Couaittee, and other similar forums forsinformation exchange.
It should be noted that regulatory uncertairities'will always be a significant factor associatcd with controversial hnd cortplex endeavors such as radioactive u ste saanagement.
The best one can hope to achieve is a understanding of the range of uncertainty in order \\to establish a reasonable assessroent of its isnpact on a particular program.\\
If you have any questions about these resporise, please contact Paul Lohaus at extension 20553.
Richard L. Bangart, Director Division of low-Level Waste,Hanagernent end N coninissicging, NHSS Distribution: (90 '44)
Central file i
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SUBJECT ABT MACT: REIN NSr5 T0 QUES 110NS RAISED BY THE CALIF 0f(NIA DEPARTHENT i
0F HEALTH SERVICES
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OFFICIIL RECORD COPY
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UNITED STATES
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NUCLEAR REGULATORY COMMIS$10N n
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NRC INSPECTION MANUAL PRP.
INSPECTION PROCEDURE 83750 0CCUPATIONAL n P050RE.
IPP!NG, TRANSPORTATION PROGR.91 APPLICA81LITY:
2515 and 2525 83750 01 INSPECTION OBJECTIVES To provide a balanced, minimum examination of the area of occupational radiation safety, particularly during extended outages when the occupational radiation protection program undergoes maximum stress.
To provide for early identification of potential problems in the area of occupational radiation safety.
To provide for early identification of potential public health and safety problems resulting from shipsonts of low-level radioactive wastes for disposal and transportation or l'conses rectoactive materials.
83750-02 INSPECTION REQUIREMENTS 02.01 Audits and Appraisals f
Revj= * *atart.ed saa>1e of the results of audit rformed by or for the licensee since
- he ~ 1.si iii. n siio M the adequacy of the i
licensee's commitments and corrective actions.
b.
Review the experience of the licensee in identifying and correcting deficiencies or weaknesses related to the control of radiation or radioactive material.
(Radiological Incident Reporting System).
02.02 Chances Review major changes since the last inspection in organization, personnel, f acilities, equipment, programs, and procedures that may affect occupational radiation protection.
Issue Date: 09/30/88
)
02.03 Plannina and Preparation Determine whether planning and preparation for the outage are adequate.
Determine whether management support for, and cooperation with, radiation protection planning for the outage are adequate.
02.04 Trainina and Qualifications of New personnel a.
Review the applicable education, experience, qualifications and training of selected members of the licensee's (and its contractor's) radiation protection organization (s).
b.
Review applicable radiation protection worker
- shcation, qua)ification, and. training of selected-members of other organizations (including contractor employees).
02.05 External Exposure Control a.
Determine whether personal dosimetry for external exposure meets requiremente.
b.
Determine whether management and administrative controls of external radiation exposure meet requirements and are designed to maintain exposures ALARA.
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c.
Detemine whether records, reports, and notifications of external exposures meet regulatory requirements.
32.06 Internal Exposure Control a.
Determine whether assessment of individual intakes of radioactive materials meets requirements, b.
Determine whether process or other engineering controls are used to
/
the extent practicable to limit concentrations of airborne radioac-l tive materials, c.
Determine whether administrative controls of internal radiation exposure meet requirements and maintain exposures ALARA.
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'hath&T u64 of respia atory protection equipment meets requimeents.
e.
Determine whether records, reports, and notifications of internal exposures meet requirements.
02.07 Control of Radioactive Materials and Contamination. Surveys, and Monitorina Determine whether survey and monitoring activities are performed as a.
required.
i Issue Date: 09/30/88 83750 i
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l b.
Detemine whether control of radioactive materials and contamination meets requirements.
t 02.08 Maintainino Occupational Exposure ALA.RA I
s.
Radiation Source and Field Control Determine the extent to which the licensee is utilizing r.roven industry developed methods of controlling out-of-core radiation l
sources and fields.
I b.
Workers Awareness and Involvement Detemine whether workers are aware of, and involved in, the ALARA program.
c.
ALARA Goals and Ob.iectives i
Detemine whether the licensee is establishing and tracking ALARA goals and objectives, j
d.
ALARA Results Review measures of the effectiveness of the ALARA program and i
detemine whether the progree is effective, t
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2.09 ShiDDin0 of low-level Wastes for Discosal. and Transoortation I
a.
Determine whether shipments made by the licensee are in compliance I
with the licensee's quality assurance progree requirements and NRC and 00T regulations.
b.
Determine whether there have been any transportation incidents involving the licensee's shipments, and whether such incidents were reported, when required.
For redweste shipments to a commercial disposal facility, detemine whether there have been any violations.
cited by the state regulatory authority which inspects shipments received at the licensed low-level weste facility.
Determine the licensee's action in response to such notices of violation, c.
Review management evaluations of audits conducted as part of the
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qua11ty control program to ensure compliance with 10 CFR 61.55 and 10 CFR 61.66 [in accoroance with 10 CFR 20.311(dM3).
Detemine whether management response was timely and appropriate.
83750-03 INSPECTION GUIDANCE 1
83750 Issue Date: 09/30/88 s
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03.01 Audits and Appraisals t
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a.
Review a selected sample of reports of required audits since the last i
inspection.
Look particularly for those audits that probe for I
programmatic weaknesses and assess the quality of the program.
Include one or more audits of transportation or shipment of low-level radioactive waste.
Focus upon licensee followup actions for identified deficiencies.
Are corrective actions timely and j
technically acceptable 7 4
Requirements for reviews and audits nomally are contained in the technical specifications.
Audit teams should include someone with experience or training commensurate with the scope, complexity, or special nature of the activities audited.
and ANSI /ASME N45.2.23-1978, Section 2.2) b.
Review reports of other audits, appraisals, assessments, evaluations (including INP0 evaluations), etc., that may provide information on program quality.
Include review of radiological events / incidents in the licensee's system for reporting and followup on these items.
c.
Review a sample of incident reports (radiological occurrence reports)
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to determine if programmatic problems exist and if licensee identified deficiencies are properly addressed, i
03.02 Channes t
4.
By observation and discussion with cognizant supervisory and management personnel, determine whether the changes have adversely 1
affected the licensee's program for control of radiation exposures.
Determine whether changes are in accordance with 10 CFR 50.59.
Se sensitive to changes that result in a lessening of the ability of the radiation protection manager to have direct recourse to the onsite i
plant / station manager in order to resolve questions related to the conduct of the radiation protection program.
Additionally, be sensitive to any organizational change in the RPM position relative to its reporting chain and level in the organization.
Document any such changes in the inspection report.
b.
By direct observation and discussion, detemine whether workers are aware of, and understand, the changes.
03.03 Plannine and Preparation Review representative records and discuss outage planning with licensee representatives, and observe activities to verify necessary planning and preparations and management support for radiation protection planning.
Examples of areas that may be examined include:
a.
Increased health physics staff, including plant's method of ensuring supervisory control over contract technicians.
Issue Date:
09/30/88 83750 4
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Special training, including use of mockup training.
c.
Increased
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materials, etc.
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d.
ALARA considerations, including work package review by health physics i
personnel, dose reduction methods, and radweste reduction.
e.
Adequacy of licensee controls and monitoring of contractor work standards, equipment, and practices.
f.
Early involvener.t of health physics group and knowledge of work to be perfomed.
This involvement should include an examination of the
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adequacy of plant review of special (non routine, seldom used) procedures and infrequent evolutions that have the potential for l
creating radiological hazards.
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g.
Provisions for engineering controls, such as auxiliary ventilation systems to minimize the need to use retpiratory protection equipment (Regulatory Guide 4.8, Section C.2.d).
i h.
Examination of indicators of management support, or lack of support, for radiation protection planning such as:
l 1.
Approvals of budgeted items needed for radiation protection during the outage.
2.
Inclusion of radiation protection staff in outage planning meetings.
3.
Approval of needed visits by radiation protection personnel to other sites to observe outage activities.
1.
For plants planning their first outage, detemination of the extent to which the outage experience of other similar plants is being used in the planning process.
J.
For plants that have experienced outages, detemination of the extent to which experience from, and lessons learned during, previous outages are being. incorporated to improve performance.
03.04 TesiMng,,anf,,qualgicatiensofNewPersonnel a.
Select individuals who have joined the radiation protection staff since the last inspection and contractor personnel hired for the l
outage.
See Inspection Procedure 83723 for guidance regarding NRC policy on the INP0 training and accreditation program.
Supplemental guidance on this topic is provided in a Dec. 12, 1986 memorandum from James G.
Partlow to Deputy Regional Administrators on the subject, l
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83750 Issue Date: 09/30/88
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" Inspection Policy Training and Qualifications."
By direct observation and discussion' with workers determine if they have the minimus knowledge (10 CFR 19.12) required to work with radioactive i
material.
By direct observation and discussion with health physics i
technicians providing job coverage, determine if they have knowledge
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of the job activities and radiological conditions to provide adequate coverage.
l b.
Emphasis should be on training provided to the increased work force required for the outage.
Consider training concerning hot particles. Discuss with plant management and the RPM.-
t 03.05 External Exposure Control i
By direct observation, discussion, and review of records, determine s.
whether personal dosimetry is used effectively and in accordance with i'
i requirements for monitoring external exposure.
The review of records should include (since the last NRC inspection 4
of this area) the results of whole body and skin dose measurements t
and review of selected investigations by the licensee of instances where an individual exceeded an administrative dose limit.
The other i
aspects of the program (dosimeter placement, RWPs, planning, etc.)
should be evaluated by observation of actual work. in progress and discussion with workers with special attention placed on high dose rate jobs or jobs in radiation fields with high dose rate gradients.
Aspects of personal dosimetry that may be examined include:
1.
Compliance with 10 CFR 20.202(c) requiring that personnel dosimeters that are used in accordance with 10 CFR 20,202(a) be processed by a processor accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) for the appropriate types of radiation.
Voluntary and redundant dosimeters, as well as direct and indirect reading pocket ionization chambers and those dosimeters used to measure the dose to hands and forares, feet and ankles, are excepted from this requirement.
No NVLAP tests are included for the dose at the nominal depth of
- the lenses of the eye, i.e., 300 mg/cm8 The licensee should either have procedures in placo to ensure that eyes are shteidert with material having a density thickness of about 700 mg/cm8 or have a method for determining the dose delivered to the lenses of the eyes through a tissue equivalent absorber having a density thickness of 300 mg/cm8 (See instruction for NRC Form 5 i
l Item 5.)
It is expected that power reactor licensees holding an operating license will be accredited in test Categories
- 1. through VII, inclusive, and in Category VIII if personnel dosimeters are used Issue Date: 09/30/88 83750 w.-.
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to measure neutron dose equivalent.
(See ANSI N13.11 for a description of these test categories.)
If a Itcensee is not accredited in all of these categories, the categories omitteiJ 4
and the reasons for omitting them, should be noted in the inspection report.
j 2.
Dosimeter selection and placement:
Adequacy of criteria for i
utilization and placement of whole body and extremity dosimeters, including use in non uniform radiation fields.
See IE Informa-l tion Notice Nos. 83 59, 81-26 Part 3, and Supplement No.1, 83 59, and INP0 82 0010EN 04 Reasonable "multibedging" cri-
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l teria are provided in a paper by C. G. Hudson (Radiation Protec-tion Menacement 1 (#2), 43-49, (1944)), a paper by W. E. Ferrell j
et al. [ Radiation Protection Menenement 4 (#5), 31 36 (1987)).
i 3.
Improper wearing or use of dosimeters.
i i
4.
Exposure records and reports.
5.
Use of pocket dosimeters and comparison of their measurements with TLD or film badge results; procedures for investigating overexposures and lost /offscale dosimeters.
2 6.
Special processing of dosimetry devices.
7.
Quality assurance of personal dosimetry measurements, f
8.
Photon, beta, and neutron exposures, l
9.
Extremity exposures.
1
- 10. Timely dissemination of current dose status.
11.
Review of workers' dose status by managers, b.
By direct observation, discussion, and review of records and procedures, determine whether management and administrative controls are adequate.
1.
Practices and P'rocedures l
Aspects of management and administrative controls that may be e nsidered ine1 A -
(a) P1'anning work to maintain exposures ALARA and within I
limits.
l (b) Use of current survey and personal dosimeter data for dose 1
control.
(c) Use of control / action levels.
1 83750 Issue Date: 09/30/88
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I (d) Radiation work permit (RWP) program.
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(e) Controlling access to high exposure areas.
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i (f) Radiation work practices including considerations of high i
radiation areas and awareness of potential hazards (e.g.,
l in diving operations and other non routine and infrequent l
operations).
(g) Management involvement with and oversight of ongoing l
radiation protection activiti6s including first line
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j supervisory oversight and control of contractor activities.
(h) Management reviews of exposure data trends and discrepancies.
2 2.
Postina and Labeline i
.i While touring the plant, determine by direct observation and l
radiation esasurements of representative areas, whether posting and labeling requirements are met.
If convenient, this may be done by accom daily survey, panying a health physics technician on a routine c.
1.
Review exposure suunary reports to determine compliance with
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regulation.
l 2.
Review exposure summary records to verify compliance with l
1 10 CFR 20.101(b) limits.
Select a sampling of individuals who have current exposures in excess of 10 CFR 20.101(a). limits and verify that Forms NRC 4 were completed prior to exceeding the 10 CFR 20.101(a) limits.
Review exposure records to verify that the licensee is complying with provisions of 10 CFR 20.102 (transient worker rule).
4 3.
Determine if minors have been permitted to work in restricted areas, and. if so, review records to determine compliance with 10 CFR 20.104(a).
4.
Review selected Forms NRC-5 to determine compliance with the regulations, t
5.
Detemine if overexposures of individuals to external radiation have been appropriately reported to NRC (10 CFR 20.403 and 20.405) and to the exposed individual (10 CFR 19.13(d)].
Issue Date: 09/30/88 83750 1
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1 03.06 Internal ExDosure Control
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a.
1.
Review the licensee's analyseh and corrective act'.ons for intakes greater than 40 MPC-hr.
Consider the licer%e's comparisons of whole body or organ burden data obtained from bioassays with i
estimates based on air-sampling data.
2.
During tours of the facility, observe work in progress to I
determine wnether air sampling is representative of air in zones occupied by workers.
(See AN5! N13.1 Section 4.2.1.1 and Section 6.)
i r
3.
During tours of the facility, observe work to determine if the i
licensee has implemented proper equipment, use of procedures, and t
appropriate locations of equipment to determine the adequacy of j
provisions for bloessays of workers.
L i
4.
During whole body counting as part of site access processing, review whole body counting equipment operation and discuss counting and calibration methods with equipment operators.
5.
For selected individuals whose whole body counts exceed the licensee's action level for investigation, review the results and corrective actions from such investigations.
b.
See 10 CFR 20.103(b)(1) and Regulatory Guide 8.8 Section C.2.d. -
Review and discuss the licensee's evaluations of suspected exposures c.
or exposures exceeding the 40 MPC-hour control values.
Consider the use of proper equipment, use of proper protection factors, appropri-ateness of preventive esasures following exposure greater than 40 MPC hours, and proper use of 2 and 10 MPC hour exclusions, d.
Guidance on use of respiratory protection equipment is given in Regulatory Guide 8.15 and NUREG-0041.
e.
1.
Review records of the results of evaluations and actions taken when en individual has been exposed to concentrations of radioactive material greater than 40 MPC-hours.
2.
Review recoros of the results of bioassays, including whole-body cwnting.
3.
Detemine if minors have been permitted to work in restricted areas, and if so, review records to determine compliance with the regulations.
l 83750 Issue Date: 09/30/88
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03.07 Contral of Radioactive Materials and Contamination. Surveys.
and Monitorino i
a.
During tours of the facility and during discussion with workers.
l evaluate aspects of surveys and monitoring.
These may include:
l i
1.
Adequacy of surveys necessary to post ano control high radiation and radiation areas.
Verify that area-radiation monitors required by Technical Specifications have been maintained operable.
Confim that access to high radiation j
areas (> 1000 mR/hr) has been controlled.
l 2.
Adequacy of supply, maintenance, and calibration and perfor-l mance checks of. survey and monitoring instruments, i
I 3.
Proper use of portal monitors and friskers, including consider-t ation of hot particle contamination.
4.
Adequacy of surveys necessary to assess personnel exposure due to skin contamination, particularly for hot particle contam-ination.
5.
Adequacy of survey practices, including technician awareness of liettations of the survey instruments.
6.
Timely dissemination of survey data and infomation on plant conditions for use in work planning and dose control.
7.
Records of surveys and review of survey results by health physics r
supervision / management.
b.
Aspects of radioactive materials and contamination controls that may be examined include:
1.
Evaluation of personal contamination.
2.
Proper contamination control work techniques and prompt correc-tion and cleanup of contamination.
3.
Efforts to reduce the volume of contaminated trash including steot to minimize introduction of uncontaminated material inLu contaminated areas.
l 4.
Surveys, monitoring, and releases of potentially contaminated material to unrestricted areas.
Circular 8107. IE Information Notices 80-22, 83 05, 85-92, and 86-90.
i Issue Date:
09/30/88 83750
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4 j
03.08 Maintainina occupational Exposures _ALARA i
4.
Methods for reducing out-of core radiation sources / fields offer the i
greatest potential for continued reductions in occupational radiation exposure at nuclear power plants.
Techniques alread implemented are described in the Electric Power Research Institute (gPRI) report EPRI NP 45055R.
Energing techniques are outlined in an article by H. Ocken and C. J. Wood of EPRI in the Nuclear Plant Journal, March April 1988, pp 43 46.
The following techniques have been found to be highly cost-effective in reducing occupational. radiation exposure (see EPRI NP 4505 $R).
Sofore power raisina:
For BWRs, replace cobalt alloys in control b' ades and control oxygen during hot functional tests; for PWRs, control chemistry in hot functional testing.
i Durine operation:
For BWRs, einimize feedwater iron input, taprove reactor water quality, and use zinc injection; for PWRs, control pH and add peroxide at shutdowns.
Refuoline:
Use low cobalt materials in replacement fuel and coba' t-free pins and rollers in BWR control blades; use Zircaloy grids in replacement fuel for both types of reactors.
Maintenance:
For BWRs and PWRs, replace wearing valves with coba't-free alternatives and improve valve maintenance procedures to remove debris.
Special enintenanco and repairs:
For
- SWRs, decontaminate, electropo'ish rep'acement piping, and air-condition or water profile replacement piping; for
- PWRs, decontaminate.
l electropolish. channel heads, and use low cobalt Inconel for replacement steam generator tubing.
Plnnt life extension:
For BWRs and PWRs, decontaminate complete pr' eary system.
The techniques above involve cobalt source reduction, preconditioning of out-of core surfaces, control of crud transport (water cheatstry control), and chemical decontamination.
Recent developments that promise to have a major impact on radiation fields are zinc injection at SWRs and use of elevated lithium hydroxide concentrations at PWRs.
Licensees should not be expected to implement a method for reducing out-of core radiation sources / fields until the method has been fully tested and proven by a full scale field demonstration in one or more nuclear power plants.
The term " fully tested and proven" means that 83750 Issue Date: 09/30/88
i j
t r
the technique has been fully scoped and reliable generic technical i
basis documentation (with lessons learned, costs, benefits, etc.) is available for the licensees tu use to evaluate the potential for their particular plant application.
{
b.
Worker Awareness and Involvement Discuss the ALARA program with several workers to determine whether t
they understand the program, understand their role in the program, j
and are actively involved in the program.
{
c.
ALARA Goals and Ob.iectives Goals and objectives may be qualitative and quantitative.
Means should be provided to track progress toward the goals and to take action on the findings.
Goals may be set for the facility as a whole i
and for different divisions or groups within the facility.
Facility goals might include a total annual collective dose (person-res)
{
value, and a percenta j
high radiation areas. ge reduction in preventive maintenance time in I
d.
ALARA Results As a minimum, consider the total annual collective dose (person-ree) for the facility.
Determine. whether that collective dose is increasing or decreasing, and whether it is higher or lower than the collective dose for other facilities of the same type and generating capacity.
Consider reasons for increases or higher than-avorage doses and discuss licensee's plans in relation to relatively high doses or upward dose trends.
Successes in meeting ALARA Nprogram effectiveness. goals and objectives provide measures of i
03.09 Shippino of Low-level Wastes for Disposal, and Transportation a.
Review and discuss records of two shipments. Determine on a sampling basis whether the licensee has adequately implemented his quality assurance program requirements relating to use of NRC-certified transport packages.
Consider the adequacy of:
1.
ileuie Lion ano contamination surveys of packages.and vehicles.
2.
Shipping paper documentation.
l 3.
Package marking and labeling.
1 4.
Loading and storage, blocking and bracing of packages.
5.
Vehicle placarding and driver's instructions, when required.
6.
Notifications to state agencies, when required.
L Issue Date: 09/30/88 83750 E.
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i b.
Review records and reports to determine whether the licensee made l
timely and adequate reports of incidents.
Consider especially any incident in which there was a
substantial reduction of the offectiveness of packagings.
Determine whether the licensee took prompt and adequate corrective actions to prevent a recurrence.
c.
(No guidance provided) j 83750 04 BIBLIOGRAPHY Appendix A contains general and speci fic references applicable to the t
subjects in this inspection procedure.
END Appendix A 1
I l
83750
- 13 Issue Date: 09/30/88
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l APPENDIX A i
BIBLIOGRAPHY Re2Wlations and License Conditions 10 CFR Part 19 10 CFR Part 20 49 CFR Parts 171 through 178.
USDOT Hazardous Materials Regulations l
- Subpart I, Radioactive Materials, Section 173.400 through 173.478, 2
i
- Subparts B F, Part 172 (All sections dealing with radioactive materials l
communications requirements),
- Parts 174.700,175.700,176.700 and 177.700, sections dealing with carrier requirements to radioactive materials shipments.
l i
10 CFR Part 71, " Packaging and Transportation of Radioactive Material."
l Federal Register, August 5,1983. Vol. 44, No.152, pp. 35600-35627, as cor-rected August 24, 1983, Vol. 48, No. 165, pp. 34449 50.
U.S. Postal Service Publication No. 6. Dec.1975, " Radioactive Material," as amended by U.S. Postal Bulletin, June 30, 1982, pp. 2-5.
IAEA " Regulations for the Safe Transport of Radioactive Material " Safety Series No. 6, 1973 (as amended).
IAEA, Vienna, Austria.
49 CFR 173.1(b), " Purpose and Scope."
Technical Specifications, Section 6. " Administrative Controls."
Renulatory Guides Regulatory Guide 1.8, " Qualification and Training of Personnel for Nuclear Power plants."
Regulatory Guide 1.33 " Quality Assurance Progree Requirements (Operation)."
Regulatory Guide 1.97, " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident."
Regulatory Guide 1.146, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants."
83750 A-1 Issue Date: 09/30/88
l l
Regulatory Guide 7.1, "Aeministrative Guide for Packaging and Transporting Radioactive Material."
Regulatory Guide 7.2, "Packa j
nated Biological Material." ging and Transportation of Radioactive 1y contami-Regulatory Guide 7.3
" Procedures for Picking Up and Receiving Packages of Ranicactive Materials."
l Regulatory Guide 7.4, " Leakage Tests on Packages for Shipment of Radioactive l
Materials."
Regulatory Guide 7.5, " Administrative Guide for obtaining Exemptions From Certain NRC Requirements Over Radioactive Material Shipments."
l Regulatory Guide
- 7. 6,
" Design Criteria for the Structural Analysis of Shipping Cask Containment Vessels."
" Administrative Guide for Verifying Compliance With i
Packaging Requirements for Shipments of Radioactive Materials (For Comment)."
l Regulatory Guide 7.8, " Load Combinations for the $tructural Analysis of Ship-d ping Casks (For Comment).
Regulatory Guide 7.9, " Standard Format and Content of Part 71 Applications for Approval of Packaging of Type 8 Large Quantity, and Fissile Radioactive Material."
i a
l Regulatory Guide 7.10. " Establishing Quality Assurance Programs for Packag-l ings Used in the Transport of Radioactive Material."
Regulatory Guide 8.2, " Administrative Practices in Radiation Monitoring."
l i
Regulatory Guide 8.3, " Film Badge Perf m ance Criteria."
Regulator Guide 8.4,
" Direct-Reading and Indirect Reading Pocket Desi-meters." y Regulatory Guide
- 8. 7,
" Occupational Radiation Exposure Records Systems."
Regulatory Guide 8.8 "Information Relevant to Ensuring that occupational Radiation Exposures at Nuclear Power Station Will 8e as Low as is Reasonably Achievable."
Regulatory Guide 8.9, " Acceptable Concepts, Models, Equations, and Assump-tions for a 81oassay Program."
~
" Operating Philosophy for Maintaining occupational radiation Exposures as low as is Reasonably Achievable (Nuclear Power Reactors)."
Regulatory Guide 8.12. " Criticality Accident Alare Systems."
Issue Date: 09/30/88 A-2 83750
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Regulatory Guide 8.13. " Instruction Concerning Prenatal Radiation Exposure."
Regulatory Guide 8.14. " Personnel Neutron Dosimeters."
" Acceptable Programs for Respiratory Protection."
i Regulatory Guide 8.19. " Occupational Radiation Dose Assessment in Light Water l
i l
Reactor Power Plants Design 5tage Man Rem Estimates."
i Regulatory Suide 8.20 " Applications of Bioassay for 1 125 and 1 131."
i Regulatory Guide 8.25. "Calibratior, and Error Limits of Air Sampling Instru-r ments for Total Volume of Air Sampled."
Regulatory Guide 8.26. "Appilcations of Bloassay for Fission and Activation i
froducts."
" Radiation Protection Training for Personnel at Light Water Cooled Nuclear Power Plants."
Regu,latory Guide 8.28, " Audible-Alare Dosimeter."
Regulatory Guide 8.29, " Instruction Concerning Risks from Occupational Radia-tion Exposure."
ANSI Standards ANSI /ANS 3.11987, " Selection, Qualification, and Training of Personnel for l
Nuclear Power Plants" (supersedes ANSI N18.1-1971 77).
ANSI /ANS 3.2 1982, Administrative Control and Quality Assurance of the Operational Phase of Nuclear Power Plants" (revision and redesignation of ANSI N18.7 1976).
ANSI /ASME N45.2.231978, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants."
ANSI N13.51972 (R1982), "Perfomance Specifications for Direct Reading and Indirect Reading Pocket Dosimeters for X-and Gamma Radiation."
i ANSI N13.6 1966 (R1982), Practice for Occupational Records Systems."
ANSI N13.7-1993, "Photographie Film 00simeters Criteria for Perfnemance."
ANSI N13.11 1983, " Criteria for Testing Personnel Dosimetry Performance."
ANSI N13.15-1985, " Performance of Personnel Thermoluminescence Dosimetry Systems."
ANSI N13.27 1981, " Performance Specifications for Pocket Sized Alarming Dosimeters /Ratemeters."
83750 A-3 1ssue Date:
09/30/88
.,.,,m,,...v-~
.m~w.-
,,.. ~,. -
...w.,
. ~. -
c ANSI N319-1976 (R1984), "American National Standard for Personnel Neutron Dosimeters (Neutron Energies Less Than 20 MeV).
A'151 N322-1977 (R1983), inspection and Test Specifications for Direct and Indirect Peading Quartz Fiber Pocket Oosimeters."
ANSI N13.1-1969 (R1982), " Guide to Sampling Airborne Radioactive Materials ~in Nuclear Facilities."'
ANSI N323-1978. (R1983), " Radiation Protection Instrumentation Test and-Calibration,"
ANSI /ANS HPSSC 6.8.1-1981, " Location and Design Criteria for Area Radiation monitoring Systems for Light-Water-Nuclear Reactors,"
ANSI /ANS 8.3 1979, " & lticality Accident Alarm System."
ANSI N13.2-1969 (R1982), " Administrative Practices in Radiation Monitoring (A-Guide for Management).
ANSI N13.6-1966 (R1982), " Practice' for20ccupational radiation Exposure Recor'ds Systems."-
ANSI N343-1978 (R1984), " Internal Dosimetry for Mixed Fission and Activation.
Products."
Bulletins Circulars, and Information Notices
=
IE Bulletin No.80-10_, " Contamination of Nonradioactive Systems and Resulting Potential for Unmonitored. Uncontrolled Release to Environment," May 2, 1980.
IE Circular No. 79 21, " Prevention of Unplanned Releases of Radioactivity,"
October 19, 1979.
1 IE Circular No. 80-14, " Radioactive. Contamination = of Plant Domineralized Water System and' Resultant Internal Contamination of Personnel,"
June 24, 1980, IE Circular No. 81-07, " Control of Radioactively' Contaminated Material,"
May 8, 1981.
IE Information Notice No. 79-21, " Transportation and Commercial Burial of Radioactive Waste," September 7, 1979
[
IE Information Notice No. 80-22, " Breakdown-in Contamination' Control Programs," May 22, 1980.
IE Information Notice No. 80-24.
" Low-Level Waste Burial Criteria,"
May 30, 1980.
IE Information Notice No. 80-25, '" Transportation of Pyrophoric Uranium,"
May 30, 1980, issue Date: 09/30/88 A-4
'83750
.- ~.
IE Information Notice No, 80 32, " Clarification of Certain Requirements for Exclusive-use Shipments of Radioactive Materials, " August 29, 1980.
IE Information Notice No. 80 32 Rev. 1, February 12, 1982.
IE Information Notice No. 81-02, " Transportation of Radiography Devices,"
January 1981.
i lE Information Notice No. 81-26, Part 2, " Placement of Personnel Monitoring l
Devices for External Radiation Exposure," August 2,1981 and Supplement 1, July 19, 1982.
IE Information Notice No. 82-18
" Assessment of Intakes of Radioactive i
1 Material by Workers," June 11, 1982, i
IE Information Notice No. 82-32, " Contamination of Reactor Coolant System by Organic Cleaning Solvents," August 19, 1982.
j IE Information Notice No. 82 47, " Transportation of Type A Quantities ot' Non-Fissile Radioactive Material," November 30, 1982.
IE Information Notice No. 82 49, " Correction for Sample Conditions ' for Air and Gas Monitoring,' December 16, 1982.
i IE Information Notice No. 83-05, "0btaining Approval for Disposing of very-Low-Level Radioactive Waste - 10 CFR 20.302," February 24, 1980.
IE Information Notice No. 83-10. " Clarification of several Aspects Relating
. t to use of HRC-Certified Transport Packages," March 11, 1983.
IE Information Notice No. 83 33, " Nonrepresentative Sampling of Contaminated Oil," May 26, 1983.
IE Information Notice No. 83-59, " Dose Assignment for Workers'in Non-Uniform Radiation Fields," September 15, 1983.-
1 IE Information Notice No. 8414, Nighlights of Recent. Transport Regulatory i
1 Revisions by DOT and NRC." March 8,1984.
IE Information Notice No. 84-19, "Two Events Involving Unauthorized Entries Into PWR Reactor Cavities," March 21, 1984.
IE Information Notice No. 84-24, " Physical Qualifications of Individuals to use ilespiratory Protection Equipment," April 5,1984.
IE Information Notice No. 84-50, " Clarification of Scope-of Quality Assurance Programs for Transport Packages Pursuant to 10 CFR 50, Appendix 8 "
IE Information Notice No. 84-59, " Deliberate Circumventing of Station Health Physics Procedures," August 6, 1984.
IE Information Notice No. 84 61, " Overexposure of Diver in Pressurized Water Reactor (PWR) Refueling Cavity," August 8,.1984.
83750 A-5 issue Date:
09/30/88
l l
IE Information Notice No. 84 82, " Guidance for Posting Radiation Areas,"
November 19, 1984.
IE Information Notice No. 85-06, " Contamination o'f Breathing Air Systems "
January 23, 1985.
'E Information Notice No. 85 42, " Loose Phosphor in Panasonic 800 Series J
Badge Thermoluminescent Oosimeter," May 29, 1985; Rev. 1, August 12, 1985.
IE Information Notice No. 85-43, " Radiography Events at Power Reactors,"
May.30, 1985.
IE Information Notice No. 85-46, " Clarification of Several AsDects of Surface Contamination Limits for Transport Packages."
IE Information Notice No. 85-81, " Problems Resulting in Erroneously High Reading with Panasonic 800 Series
.Thermoluminescent Oosimeters,"
October 17, 1985.
IE Information Notice No. 85-87, "Hasards of taerting Atmospheres,"
November 18, 1985.
IE Information Notice No. 85-88, " Licensee Control-of Contracted Services-Providing Training," November 18, 1985.
IE Information Notice No. 85-92, " Surveys of Wastes Before Disposal from Nuclear Reactor Facilities," December 2,1985.
IE Information Notice No. 86-23, " Excessive Skin Exposures Due to Contamina-tion with Hot. Particles."
IE Information Notice No. 86-42, " Improper Maintenance of Radiation Moni-toring Systems," June 9, 1986.
IE Information Notice No. 86-43, " Problems with - Silver Zeolite Sampling of Airborne Radioiodine," June 10, 1986.
IE Information Notice No. 86-44, " Failure to Follow Procedures When Working in High Radiation Areas," June 10, 1986.
IE Information Notice No. 86-46, " Improper Cleaning and Decontamination of Respiratory Protection Equipment," June 12, 1986.
l IE Information Notice No. 86-76, " Problems Noticed in Control Room Emergency l
Ventilation Systems," August 28, 1986.
IE Information Notice No. 86-90,, " Requests to Dispose of Very-Low-Level Radioactive Waste Pursuant to 10 CFR 20.302," November 3, 1986.
l IE-Information Notice No.86-107, " Entry into PWR Cavity with Retractable Incore Detector Tnimbles Withdrawn," December 29, 1986.
Issue Date:
09/30/88 A-6 83750
IE Information Notice No. 87 03, " Segregation of Nazardous and Low-Level Radioactive Waste," January 15, 1987.
IE Inforsation Notice No. 87-07, " Quality Control of Onsite Dewatering /
Solidification Operation by Outside Contractors," Febr'uary 3, 1987.
IE Information Notice No. 87-13. " Potential for High Radiation Fields Follow-ing Loss of Water from Fuel Pool," February 24, 1987.
NRC Information Notice No. 87-31, " Blocking, Bracing and Securing of Radioactive Materials Packages in Transportation," July 10, 1987.
NRC Information Notice No. 87-32, "Deficier.:ies in the Testing of Nuclear-Grade Activated Charcoal," July 10, 1987.
l NRC Information Notice No. 87-39, " Control of Hot Particle Contamination at Nuclear Power Plants," August 21, 1987.
NUREG and NUREG/CR Documents NUREG-0041, " Manual of Respiratory Protection Against Airborne Radioactive Materials," J. L. Caplin, et al. (1976).
NUREG-0383, " Directory of Certificates of Compliance for Radioactive Material Packagings," revised annually in three volumes.
NUREG 0938, "Information for Establishing Bioassay Measurements and Evalua-tions of Tritium Exposure," A. Brodsky (1983).
NUREG/CR-0564, " Pocket-Sized "m:tronic Dosimeter Testing," 0. R. Mulhern, et al., Pacific Northwest L C.3 <'y (1979)
NUREG/CR-1452, "Further
!N
- f Pocket-Sized Electronic Dosimeters,"
R. A. Fox, et ai., Pacific W
- A.4 Laboratory (1980).
NUREG/CR-2019, " Third Phase of Pocket-Sized Electronic Dosimeter Testing,"
R. A. Fox, et al., Pacific Northwest Laboratory (1982).
NUREG/CR-2233, " Neutron Oosimeter Performance and Associated Calibrations at Nuclear Power Plants," R. B. Schwartz, et al., National Bureau of Standards (1982).
NUREG/CR-2892, "Perfomance Testing of Personnel Dosimetry Services:
A Revised Procedures Manual,"
J.
Miklos and P.
Plato, The University of Michigan (1983),
" Correlation of Neutron Oata Taken at Commercial Nuclear Sites,"
L. A.
Rathbun and G. W. R. Endres, Pacific Northwest Laboratory (1983).
83750 A-7 Issue Date: 09/30/88 l
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NUREG/CR 3400, " Analysis of Measurements with Personnel 00simeters and Port-able Instruments - for Determining Neutron Dese Equivalent (1983).
at. Nuclear Power Plants," C. M. Eisenhauer and R. B. - Schwartz =, National Bureau of Standards NUREG/CR-3544
" Beta Particle Measurementand Dosimetry Requirements at.
A NRC licensed Facilities," L. A. Rathbun et al,, Pacific Northwest Laboratory (1984),
NUREG/CP-0066, " Proceedings of an International Workshop on Historic - Dose 3
Experience and Dose Reduction (ALARA) at Nuclear Power Plants," Brookhaven l
National Laboratory and U.S. Nuclear Regulatory Commission, 290 pages (1985).
NUREG/CR-3469, Vol. 2, " Occupational Dose-Reduction at Nuclear Power Plants, Annotated Bibliography of Selected Readings in Radiation Protection and ALARA,"
J. W.
Baum-and C.
Weilandics, Brookhaven National Laboratory, 150 pages (1985).
NUREG/CR-4033, "The Role of Personal Air Sampling in Radiation Safety Pro-grams and Results of a Laboratory Evaluation of Personal Air-Sampling Equip-ment," P. D. Ritter, et al.,
Idaho National. Engineering Laboratory,- EG&G, 82 pages (1985).
NUREG/CR-4239, " Analysis of the Ability of Current Health Physics Instruments to Predict Oose in Exposed Individuals," G. A. Armantrout, Lawrence Livermore National-Laboratory, 320 pages (1985).
NUREG/CR-4254, " Occupational Dose ' Reduction and ALARA-at Nuclear Power i
Plants:
Study on High-Dose Jobs, Radwaste Handling, and ALARA Incentives,"
B.. J.
Dionne and J.
W.
Baum, Brookhavan National Laboratory, 106 pages _
(1985).
NUREG/CR-4297, " Extremity Monitoringi Considerations for Use, Dosimeter Placement, and Evaluation," W.
D.
Reece, et al., Pacific Northwest Labora-tory, 120 pages (1985).
NUREG-CR-4381, " Summary of Comparative Assessment of U.S. and Foreign Nuclear Power Plant Oose Experience," J. W. Baum and J. R.-Horan, Brookhaven National Laboratory, 23 pages (1985).
NUREG/CR-4445, " Effectiveness and Safety Aspects.of Selected-Decontamination Processes," 5. W. Duce and J. T. Case, EG&G, August 1986, NUD EC #.P-ARM, "iM.orpretation cf Bioassay Huasurements,' Eoware I.
Lessard i
et al,, Brookhaven National Laboratory (1987).
1 NUREG-1156, " Accuracy and Detection Limits for Bioassay Measurements. in Radiation Protection, Statistical Considerations," A. Brodsky (1986).
NUREG/CR-3469 Vol.
3,. " Occupational Dose Reduction at Nuclear Power Plants:
?
Annotated Bibliography of -Selected Readings in Radiation Protection and' ALARA," J. W. Baum and C. Weilandics, Brookhaven National Laboratory (1986).
Issue Date: 09/30/88 A-8 83750
a NUREG/CR 4373, " Compendium of Cost effectiveness Evaluations of Modifications for Dose Reduction at Nuclear Power Plants," J.
W. Baum and G. Matthews, Brookhaven National Laboratory (1985).
NUREG/CR-4409 Vol.1, " Data Base on Nuclear Power Plant Dose Reduction Re-search Projects," T. A. Khan, B. J. Dionne, J. W. Baum, Brookhaven National Laboratory (1985).
NUREG/CR 4409, Vol. 2
" Data Base on Nuclear Power Plant Dose Reduction Research Projects," T. A. Khan and J. W. Baum, Brookhaven National Laboratory (1987).
Electric Power Research Institute (EPRI) Publications EPRI NP-4505-SR, " Manual of Recent Techniques for LWR Field Control,"
March 1986.
EPRI NP-4474, "BWR Radiation Field control Using Zinc Injection Passivation,"
March 1986.
EPRI NP-4725, "BWR Startup Chemistry Control," August 1986.
EPRI NP-4614 "Electropolishing of Steam Generator Channel Heads,"
. April 1986.
EPRI.NP-5056, "PWR Secondary Water Chemistry Guidelines, Revision 1,"
March 147 EPRI NP-4762, " PWR Primary Water Chemistry Guidelines," March 1987.
EPRI NP-4946, "BWR Normal Water Chemistry Guidelines 1986 Revision."
EPRI NP-4947, "BWR Hydrogen Water Chemistry Guidelines "
EPRI NP '500
" Guidelines for Permanent BWR hydrogen Water Cher istry Installation."
AIF and INP0 Publications AIF/NESP-020, " Compendium of Design Features to Reduce Occupational 4adiation Exposure at Nuclear Power Plants," April 1981.
AIF Subcommittee on Engineering Techniques for Reducing occupat'onal Expo-sures, "An,$ssessment of Engineering Techniques for Reducing Gecupational l
Radiation Exposure at Operating Nuclear Power Plants," February 1980.
INPO Good hPactice, 82-001-EPN-02, " Conduct of ~ a Direct Reading Dosimeter.
Program (quartz Fiber Pocket Dosimeters)," September 1982.-
INPO Good Practice, 82-001-EPN-03,
" Comparison of Dosimetry Results,"
September 1982.
1 83750 A-9 Issue Date: 09/30/88
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INPO Good Practice, 82-0010EN-03, "Desimetry Placement for Steam Generator Workers," January 1982.
INPO Good Practice, 82-001-0EN-04, "Fersonnel Protection from Beta Parti-cles'," January 1982.
INPO REN/FDO-01,
" Respiratory Cleaning and Maintenance Packages,"
November 1981.
INPO Report 82-001 EPN-01, "High Sensitivity Portal Monitors - A Review,"
January 1982.
INPO Good Practice. 82-001-F00-02,
" Modular Contamination Enclosures "
September 1982.
INPO OEN-01, "Str'ippacie Decontamination Coatings " November 1981.
INPO Good Practice 82-001-0EN-10, " Monitoring Personnel for Radioactive Contamination," September 1982.
INPO Good Practice 82-001-0EN-07, " Corporate' Radiological Protection Commit-tee," September 1982.
t INPO Good Practice 82-001-0EN-08A, "ALARA Planning for Station Work,"
September 1982.
INP0 Good Practice 82-001-0EN-06, " Selection of Contract Radiological Protec-tion Technicians," April 1982 (Preliminary).
INPO Guideline 82-004, " General Employee Training," February-1982.
INP0 Guideline 82-006, " Radiological Protection Technician Qualifications,"
February 1982.
INPO Guideline 82-007, " Chemistry-' Technician Training," September 1982.
.NPO Guideline 85-004, " Guidelines for Radiological. Protection at Nuclear Power Stations," 1985.
Additional Hot Particle References Warnock, R. V., et al., "A Nealth Physics Program for Operation with Failed
- fuei, kaoiation Protection Management 4 (#4), 21-30 (July / August 1987).
Russell, M. J., et al., "A Hot Particle Training Program for Health Physics Technicians," Radiation Protection Management 5 (#1), 35-40 (Jan./Feb. 1988).
Traub, R. J., W. D. Reece, R. I. Scherpelz, and L. A. Sigalla, " Dose Calcula -
tion for Contamination of the Skin Vsing the Computer code VARSKIN, PNL-5610 (NUREG/CR-4418).
Battelle Northwest Laboratory, August 1987.
Bartlett, William T.,
" Calculation of -Skin Dose from Small Area Beta Sources," Radiation Protection Management 4 (#4), 31-38 (July / August 1987) l Issue Date:
09/30/88 A-10 83750
~ ___. -. _ _ _ - _
Farrell, Wayne E.,
" Selection of Skin Dose Calculatiori Methodologies "
Radiation Protection Management 4 (#4), 17-19 (July / August 1987).
Kocher, D. C. and K. F. Eckerman, " Election Dose-Rate Conversion Factors for External Exposure of the Skin from Uniformly Deposited Activity on Body Sur-face," Health Physics 53 (#2), 135-141 (August 1987).
Bray, L. G., et al., " Skin Oose Calculations for Fuel Particles,"
Radiation Protection Management 4 (#5), 25-30 (Sep./Oct. 1987).
Rohloff, F., and M. Heinzelmann, " Calculation of Dose Rates for Skin Contami-i nation by Beta Radiation," Radiation Protection Dosimetry 14 (#4), 279-287 (1986).
Lantz, Michael W.. and John B. Steward, " Accounting for Self-Absorption of Beta in Cobalt-60 ' Hot Particles'," Radiation Protection Management 5 (#1),
25-29 (Jan./Feb. 1988).
Institute of Nuclear Power Operations, Significant Event Report 18 87 (Rev. 2), " Radiation Exposure From Small Particles," July 16, 1987.
Moeller, M. P., G. F. Martin, and D. L. Haggard, "The Impact of Fuel Cladding Failure Events on Occupational Radiation Exposures at Nuclear Power Plants.
Case Study:
PWR During Routine Operations," NUREG/CR-4485 (PNL-5606),
l January 1986.
Heard, D. B., and R. J. Freeman, " Cobalt Contamination Resulting From Valve i
Maintenance," Electric Power Research Institute, EPRI NP-3220, Final Report, August 1983.
Wells, J., " Problems Associated With Localized Skin Exposures," in " Radiation Damage to Skin:
Fundamental and Practical Aspects," Proceedings of a Work-shop held at Saclay, France, on October 9-11, 1985, Brit. J. Radiolony, Supplement No. 19, pp. 146-150 (1986).
Charles, M. W., "The Biological Bases of Radiation Protection Criteria for Superficial, Low Penetrating Radiation Exposure," in " Dosimetry of Beta Par-ticles. and Low Energy X-Rays," Proceedings of a Workshop held at Saclay, France, October 7-9, 1985 "
Radiation Protection 00simetry 14 (No.
2),
pp. 79-90 (1986).
Charles, M.- W., " Skin, Eye, and Testis:
Current Exposure Problems and Recent Advences in Radiobiology," J. Soc. Radici. Prot. 6 (No. 2), pp. 69-81 (1986).
Shen, Li, et al., " Experimental and Computational-Techniques for p Particle Dosimetry," Health Physics 53 (#1), 37-47 (July 1987).
Other References Pamphlet "A Review of the 00T Regulations for Transportation of Radioactive Materials," Revised Fall 1983.
83750 A-11 Issue Date:
09/30/88
i
)
" Advisory Material for the.- Application : of the IAEA Transport Regulations,"
Safety Series 37, Second Edition; IAEA, Vienna. Austria, 1982.
j
" Radioactive Materials Transportation Information and-Incident Guidance,"
USDOT Publication 00T/RSPA/MTB-81-4.
NCRP Report No. 39, " Basic Radiation Protection Criteria," January 15, 1971.
]
NCRP Report No. 57, " Instrumentation and Monitoring ~ Methods for Radiation Protect 1on~," May l',
1978.
l NCRP Report No. 65, " Management of Pers'ons Accidentall'y Contaminated-with Radionuclides," April 15, 1980.
NCRP Report No. 71, " Operational Radiation Safety - Training," March:1983. -
HASL-312. " Guidance for Air Sampling At Nuclear Facilities," A. J. Breslin, November.1978.
LA-4558-MS,
" Surface Contamination:
" Decision Levels,"
J.
W.
- Healy,
.[
September 1971.
.DHHS (NIOSH), Publication No.82-106
" Supplement ; to ~ the NIOSH Certified Equipment List," October'1, 1981,-and Subsequent Supplements.-
Ocken J.,
and - C.. J.
Wood, " Radiation Field Reduction," Nuclear Plant Journal Mar.-April 1988, pp 43-46.
s Wood, Christopher J., "Techniquesf for -Reducing Radiation Fields in Nuclear Power Plants," Radiation Protection Management 4 (#5), 37-42;(1987),
l Flood,. John R., Rob L. Coleman, and ' C. Glenn Hudson,'" Calculation of. Skin Dose for Exposure to Noble Gas-Isotopes," Radiation Protection Management 5
(#4), 41-48 (Jan./Feb.-1988).
" Hudson, C.
G.,
"The Need for Dosimetry Multibadging at' Nuclear Power Plants," Radiation Protection Management 1 (#2),.43-49 (Jan. 1984).
- Farrell, W.
E., et al., "Multibadging Reductions at.the H.
B.
Robinson Plant," Radiation Protection Mananement 4 - (#5),,.31 (Sep. /0ct. 1987).
Huggins, T. E.,. and J. E. Watson, " Routine Hand Doses vs.MonitorinD Regula-s tions at a
Nuclear Power Plant,'? Health: Physics 46 (#4),
775-781 (April 1984).
Flood, John R.,." Calculation of Skin Dose for Exposure ' to Noble Gas-Isotopes," Radiation Protection Management 5 (#1), 41 (Jan./Feb. 1988).
- Thind, K.
S., " Extremity ' Dose:
It's Definition Standards and Regulatory Limits. Radiobiological Significance, Measurement and Practical Considera-tions," Health Physics 5J (#6), 695-705 (June 1987).
Issue Date:
09/30/88 A-12 83750 i
t
+
Rogers, D. W. O., "Why Not to Trust a Neutron Remmeter," Health Physics E, 735-742 (December 1979).
l Schwartz.. R.
- 8., and C.
M. Eisenhauer, " Procedures for Calibrating Neutron Personnel Dosimeters," N85 Special Publication 633 (May 1982).
Jackson, Thomas P., " Optimizing the-Performance of Direct-Reading Dost-meters," Health Physics 49 (#1), 49-54 (July 1985)..
t Kent, Charles E.
and Paul E..Knapp, "A Program Evaluation of Pocket loniza-tion Cham W Usage," Radiation Protection Management vol. 2 {#_2), 47-52 (Jano:ry 1985).
Marshall, M., and D. C. Stevens, "The Purposes, Methods and Accuracy of Sam-l-
pling for. Airborne Particulate Radioactive Materials," Nealth Physics 39, 409 423 (Sept. 1980).
END
\\
1 l
l l
l 83750 A-13 Issue Date:
09/30/88 I
[*""%
UNITED STATES j' '
't NUCLEAR REGULATORY COMMISSION g
wasmorow. o c. acons t
)
g'.
NRC INSPECTION MANUAL pres i
INSFECTION PROCEDURE 84750 77--
RA010A T ATER CNEMISTRY; CONFIRMATORY ADIOLOG CAL ENVIRONMENTAL MONITORING PROGRAM APPLICABILITY: 2515 and 2525 84750-01 INSPECTION OBJECTIVES 01.01 To determine whether the licensee effectively controls and quantifies
. radioactive solids, liquids, gases and particulates during normal and emer-i-
gency operations.
01.02 To determine whether the licensee is adequately controlling the quali-ty of plant process water to ensure long term integrity of the reactor cool-l ant pressure boundary and minimize out-of-core radiation field buildup.
01.03 To evaluate the licensee's analytical capability to make consistently accurate radioactivity measurements during. nomal and emergency operations
'e and chemical measurements under emergency conditions.
01.04 To ensure that radiological environmental monitoring fectively implemented during normal and emergency operations. programs are ef-84750-02 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 commitments and corrective action.
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 ac-tions timely and technically acceptable 7 02.02 Chances i
Review changes ~ in the licensee's organization and in the equipment, facilities, instrumentation, procedures, contractors, and implementa-tion thereof, of the radioactive waste systems, water chemistry, confirmatory measurements, and radiological environmental monitoring programs made since the last inspection.
i Issue Date: 09/30/88
_ _ ~.., -.. _ _ _ _ _. _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _
02,03 Implementation of Procram Implementation of Solid. Liquid. Gaseous and Particulate Radioactive a.
Waste Program 1.
Processino and Storace Determine the adequacy of [4casadag,,mt&gndat,orage of solid wastes.
J w.
2.
Effluents
'l 1
Determine compliance' with effluent-requirements and efforts to keep effluents ALARA.
3.
Instrumentation I
Determine whether process and effluent' monitors are maintained, calibrated, and operated as_ required.
Limit : the review to - the following monitors --in the gaseous and particulate radioactive waste program:.
(s) BWRs i
(1) Main steam line radiation monitors.-
~
(2) Air-ejector off gas radiation monitors; post treatment.
(b) PWRs Containment or parge effluent (extended-range) noble gas monitors.
I-4.
Air Cleaning Systems (a)
Determine -whether post-accident engineered safety -feature i
air cleaning' systems are maintained and operated as required..
t 5.
Reactor Coolant and Secondary Water Deur?.ine whethcr rccctor coolant wet 6r and,i for rWRn, seconoary water meets chemical and radiochemical requirements.-
b.
ImplementationoftheWaterChemistryControlProcrami This program will be conducted every other SALP cycle -at each site.
The inspector should become knowledgeable of the operating history of-
- the plant (through interviews-of cognizant personnel and review of pertinent records) to the extent that he is aware of any significant off-normal chemical behavior.
Issue Date: 09/30/88 84750 e
4 Detemine whether the water chemistry control program is being imple-mented' in-accordance with existing policies,and procedures.
This re-view may include the following:
2 1.
Reviews of records of completed chemical-analyses to determine whether the analyses have been completed on schedule, j
-2.
Reviews and discussions of the recorded trends of water quality
- data and reviews of these data-by plant chemistry personnel.
3.
Reviews of investigative (diagnostic) and corrective actions tak-en when chemical variables have exceeded the established levels
-I limits, _ including consideration of the timeliness of these or
- actions, i
4.
Review and discussion of the effectiveness of measures taken to' prevent the introduction of cheetcal contaminants into primary and-secondary water -and to detect the presence of these i
contaminants.
l Taplementation of the Quality Assurance Procram for Chemical c.
Measurements 1
Thisl program:will be conducted every other SALP cycle at each site.
Determine whether the quality assurance program for chemical asasure-ments is being implemented in accordance with existing policies and procedures. This review may include:
1.
Reviews of records of maintenance and calibration-of continuous monitors.
~
1 2.
Reviews of the results, of inter-laboratory cross checks, i
3.
Reviews of the. use of the blind, spike, and replicate samples.
I 4.
Reviews of the use of control charts.
5.
Review of the use of approved laboratory procedures for chemical analysis including instrument calibration, preventive mainte-nance, and operation.
Imolementation of the Ouality Assurance and Confirmatory Measurements d.
Progras This program will be conducted every other SALp cycle -at each site.
1.
Confirmatory Measurements.
Evaluate the licensee's capability -
for safely collecting and accurately asasuring radioactivity in.
the following samples during. normal operations:
(a) An actual sample from a liquid waste tank.
84750 Issue Date: 09/30/88
(b) A gaseous waste sample (from the off gas system for BWRs and gas waste holdup tanks for PWRs).
(c)
The most recent stack-sampler charcoal filter or cartridge the licensee has analyzed prior to the inspection.
1 (d) The most recent air particulate filter the licensee has ana-lyzed prior to the inspection.
(e) - A reactor primary coolant water sample.
-i 2.
Postaccident Sample Analysis.
Determine the adequacy of the I
licensee's capability to safely 'and-accurately = analyze highly radioactive reactor coolant and containment atmosphere samples under accident conditions.
Consider both radiochemical analyses and chemical analyses.
3.
Implementation of the Quality Assurance (QA) Procrami Verify that the licensee's QA program-for radiochemical measurements is being effectively. implemented.
i Implementation of the Radiolocical Environmental Monitorina Procram e.
Determine - whether the radiological - environmentall monitoring program i
described in the technical specifications is. effectively-implemented.'
.f.
Implementation of the Meteorolocical'Monitorina Procram
~
Determine whether the meteorological instrumentation and equipment i
described in the licensee's - technical specifications are operable, calibrated, and maintained, 4
i g.
Implementation of Environmental Monitorina Quality Assurance'(QA) i Program l
Verify that the quality assurance program provides adequate control with regard to sampling, processing..and analyzing samples, and evalu-ating data obtained= in the radiological environmental monitoring pro-gram and the meteorological monitoring program.
84750 03 INSPECTION GUIDANCE 02.01 Audiu, 0,r.d t.::praissis Review reports of required audits since-the last. inspection.
Look particu-larly 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?
03.02 Changes Discuss changes in license organization and in equipment, instrumenta -
tion and procedures with cognizant management.
Issue Date: 09/30/88 84750 j
l
(
03.03 Implementation of Program 4.
Implementation of Solid. Liould, Gaseous and Particulate Radioactive Waste Program 1.
Processing and Storage of Solid Radioactive Waste (a) Inspect selected records to determine whether quantity and radionuclide composition are being measured or estimated as required.
1 (b) Review the licensee's experience in maintaining and using waste solidification systems.
2.
Effluents (a) Briefly review Semiannual Radioactive Effluent Release Re-ports for obvious mistakes, anomalous measurements, omis-sions, and trends.
(b) Review selected records (including release permits) to de-termine compliance with ef fluent requirements.
Verify dose calculations using the licensee's 00CM for a major-nuclide :
(e.g., Cs-137 or Co-60) for one pathway for the last report.
ing interval.
(c) Identify significant sources of radioactive solids, liquids, gasses. and particulates released within and from the f acil _ity.
(d) 1.ook for unmonitored release paths.
3.
Instrumentation l
(a) Where possible, compare monitor readings with laboratory measurements to ensure -- that monitors respond acceptably.
(b) Observe remote-and local process and effluent monitor read-outs to determine operability.
Identify recurrent mainte-nance problems and assess-licensee's corrective actions, both short and long' term.
l 4.
Air Cleanino Systems Briefly review records of tests of air cleaning systems.
Include both in place test of HEPA filters and lodine adsorber units, and laboratory tests of activated carbon.
Identify recurrent test and maintenance problems and licensee's corrective actions, both I
long and short term.
1 84750 Issue Date:
09/30/88 e
e.----,----
v
,w,
---r
-w
8 0
t b.
Implementation of the Water Chemistry Control Program Briefly review selected records of. required chemical and radiochemical determinations for reactor coolant and-secondary water. Verify wheth-er these determinations have been performed as required and whether the results are within: limits.
.c.
Implementation of the Quality Assurance Program for Chemical Measurements 1.
Data plotting and trending programs are crucial to pinpoint erro-neous analyses or chemical-interferences as distinguishable from developing out-of-specification trends.
2.
The results of the analysis of interlaboratory cross-check' am-ples,. if available, provide..information-on the. quality of chemi-cal analyses. -Some chemical cross-check samples are commercially available, d.
Implementation of the Quality Assurance and Confirmatory Measurements Program 1.
(Quality Assurance) Program.
Regulatory Guide:4.15
" Quality Assurance for Radiological Monitoring. Programs,(Normal Opera-
~
tions) - Effluent Streams in the Environment," provides guidance on the content and extant of an acceptable program.
Consider r
especially the results-of inter-and intra-laboratory comparisons..
2.
Confirmatory Measurements Program (a)' General.
Using the : Verification Test, evaluate the licensee's mea urement by comparing the._ licensee's: measure-ment with the NRC: measurement or the measurement of the Ra-diological Environmental-Sciences Laboratory (RESL).
Ensure that both measurements' are made on the same samples or. on split samples.
If cartridge - or filter samples are not available, substitute'a simulated cartridge or filter sample prepared by RESL.
Whenever possible, observe 'the sampling and splitting of samples. Improper techniques may. cause incorrect results.
l regardless of the accuracy of.the measurements.
The licensee should analyze NRC or split samples in a rou-r tine manner. 'The methodology, procedures, equipment, per-sonnel, sample size and counting times should be the same as the licensee normally uses.
(b) Verification by calculation.
Using the counting efficien-cies, counting times, and other parameters, verify that the licensee can' meet' the lower level of detection (LLD) spect-fied in the OL.
Issue Date: 09/30/88 84750 c
]
y l-If multiple detectors are used with a single counting sys-tem, comparisons should be made for all detectors when it-is feasible to do so, Analyses should be performed by the NRC inspection staff in the mobile laboratory or at the Regional Office, i
.t (c) Verification Test i
~
1.
Analyses (a) Liquids and Gases - Gamma Emitters.
Identify all radionuclides detected in the NRC samples. ~The licensee should identify and. quantify all the nuclides that are detectable 1with the licensee's.
system using-normal counting times.
Compare re-sults as described below.
(b) Liouids and Gases - Other Radionuclides.
For radionuclides that cannot be determined by gamma-ray spectrometry (e.g., H-3, Sr-89, Sr-90, Fe-55),
compare RESL's results with-the licensee's - as. de-scribed below.
l (c) Air Particulate Filters and Charcoal / Silver =Zeo -
lite Cartridoes (1) Identify all radionuclides detected in the NRC sample, i
(2) Compare the NRC measurements with the licensee's as described below.
l
- 11. Comparison (a) Divide each NRC result by its associated uncer-tainty to obtain the resolution.
(Note:
For pur-poses of.this procedure,. the uncertainty is defined as the relative standard deviation, one sigma, of the NRC result as calculated from count-ing statistics.)
(b) Divide each licensee result by the corresponding NRC result to obtain the ratio (licensee result /NRC).
(c) The -Itcensee's measurement is in agreement if the value of the ratio. falls within the limits shown in the ~following table for. the-corresponding-resolution.
84750 Issue Date: 09/30/88
.._.. _.._.,-,_ __,.. ~,
2 l
I I
lii.
Criteria for Accepting the Licensee's Measurements L
Resolution-Ratio q
<g
-\\
4 7
0.5 - 2.0 l
8 15 0.6 - 1.66 16 50 0.75 - 1.33 51 - 200
'0.80 - 1.25
>200 0.85 1.18 iv.
Action Taken for Measurement Not in Agreement.
Perform another' Verification. Test, if. practical, during the inspection.. If measurements are still in disagreement, remedial actions should be taken.
Remedial: action to resolve a disagreement may _ include the following:
l (a) A review of calibrations.and/or recalibration:by
~
the licensee.
(b) Consideration of ways in. which the licensee's radioanalytical methods and radioactivity measure-ment algorithms may contribute to disagreement.
(c) Licensee analysis of a spiked sample supplied by RESL. -
s (d) Reanalysis of:the sample by RESL.
(e) - Consultation with RESL for technical advice and assistance.
1 Note that some discrepancies may result from the use of dif forent ' equipment 'and-techniques.. This should be considered in' attempting to resolve disagreements.
e.
Implementation of the Radiolonical Environmental Monitorina Program 1.
Aeview tne licensee's J Annual Environmental Monitoring Report; changes to the 1iconsee's 00CM, with' respect to environmental monitoring; and compliance with the technical specifications,'
license conditions, and/or commit.nents in, terms of sampling,loca -
a tions, monitoring and messi'rement frequencies, land use census, interpretation, and evali:. tion of' data.
2.
Review the reports for omissions; obvious mistakes; anomalous measurements; observed biases; or trends in the data, ' state licensee intercomparisons, and NRC-licensee TLD measurements.
1 Issue Date: 09/30/88
-f 84750'
)
1 a
i 3,
Determine whether timely and appropriate followup and corrective actions were taken for anomalous measurements results.
f.
Inclementation of the Meteorolocical Monitorina Program Verify : by direct instrumentation is operable and maintained. observation and record ~ review th Emplementation of Environmental Monitorinc Quality Assurance (OA) 9 I'rocram -
Regulatory Guide 4.15, "Qualit Programs (Normal-Operations y Assurance for Radiological Monitoring Effluent Streams in the Environment I
provides guidance for the content and extent of an acceptable progra)m,.
S4750-04 BIBLIOGRAPHY Appendix A contains-general and specific references applicable to the i
sub,jects in this inspection procedure, i
j END Appendix A t
l i
t 84750 Issue Date: 09/30/88
~
l L
l l-l i
l' APPENDIX A BIBLIOGRAPHY This appendix contains general and specific references applicable to the-subjects in Inspection Procedure 84750.
For each reference listed, there 3
are one or more letters shown under " Applicability" to indicate the subjects i
to which the rafarance g lies. The applicability codes are as follows:
i lidRadioactiveWaste]
B - Radioactive Liquids and Liquid Wastes 3
C - Gaseous Waste System l
0 - Water Chemistry Control and Chemical Analysis i
E - Quality Assurance and Confirmatory Measurements i
F - Radiological Environmental Monitoring,
!~
The references are divided into groups by type of documents.
Reculations and License Conditions Applicability 40 CFR 141, " Interim Primary Orinking Water Regulations,"
F.
41 FR 28402 Reculatory Guides Regulatory Guide 1.21, " Measuring and Reporting Radioactivity A, 8, C, E in Solid Wastes and Releases of Radioactive Materials in Liquid ' ~
i I
and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants."
Regulatory Guide 1.23, "0ns'ite Meteorological Programs."
F Regulatory Guide 1.33, " Quality Assurance Program Requirements D
(Operation)."
- l Regulatory Guide 1.'52, " Design, Testing, and Maintenance Cri-C teria for Post-Accident Engineered Safety Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-l Water-Cooled Nuclear Power Plants"' (Endorses ANSI M509-1976 and N510-1975).
I Regulatory Guide 1.56, " Maintenance;of Water Purity in Boiling 0
Water Reactors."
A-1
' Issue Date: 09/30/88 e
-~
-+,
,,n-
.i Applicability Regulatory Guide 1.97 " Instrumentation for Light-Water Cooled BC Nuclear Power Plants to Assess Plant' Conditions During and Following an Accident."
Regulatory Guide 1.101,." Emergency Planning and Preparedness E
for Nuclear Power Reactors."
Regulatory Guide 1.109, " Calculation of Annual Doses to Man B
from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix 1."
i t
Regulatory Guide.l.140, " Design, Testing, and Maintenance Cri-C teria for Normal Ventilation Exhaust System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants."-
l Regulatory Guide 1.143, " Design Guidance for Radioactive Waste A,' B, C-Management Systems, Structures, and Components in Light-Water-Cooled Nuclear Power Plants."
Regulatory Guide 1.146, " Qualification of Quality' Assurance A,B,C,E.F Program Audit Personnel for Nuclear Power Plants."-
_j Regulatory Guide 4.1, " Programs for Monitoring Radioactivity F,
=
in the Environs of Nuclear Power Plants."
Regulatory Guide 4.5, " Measurements of Radionuclides in the F
Environment -- Sampling end Analysis of Plutonium in Soil."
1 Regulatory Guide 4.6, "Meausrements of Radion'uclides.in the F.
Environment -- Strontium-89 and Strontium-90 Analyses..
t Regulatory Guide 4.13 " Performance, Testing, and Procedural F.
Specifications for Thermoluminescense Oosimetry: Environmental-Applications."
Regulatory Guide 4.15. " Quality-Assurance for Radiological
~ B, C, E, F Monitoring Programs (Normal Operations) - Effluent Streams 1
and the Environment."
Nyh tm y Gi.W 4.16,. "Heuud ng, Evaluat tog, and c.erotting F
3 Radioactivity in Releases of Radioactive Materials in Liquid and Airborne Effluents from Nuclear Fuel Processing and Fabri-cation Plants."
t ANSI Standards 4
%SI N13.1-1969 (R 1982), " Guide to Sampling Airborne Radio-C
^
active Materials in Nuclear Facilities."~
Issue Date: 09/30/88 A-2 84750 4
.---,e
-- - - - _ - _ _ - _ _ - - - _. _ _.. ~ _ _ _ _ _ - _ _ -
ADP1(cability ANSI N42.18 1980 (Reaffirmation and Redesignation'of ANSI B, C N13.10 1974, " Specification and Performance of Onsite Instru-mentation for Continuously Monitoring Radioactivity in i
Effluents."
ANSI /ASME N45.2.23-1978, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plant Personnel."
A,B,C,E,F ANSI /ASME N55.1-1979, " Solid Radioactive Waste Processing Sys-A tem for Light-Water-Cooled Reactor Plants."
ANSI /ANS N55.4-1979, " Gaseous Radioactive Waste Processing C
Systems for Light-Water Reactor Plants."
ANSI /ANS H55.6-1979, " Liquid Radioactive Waste Processing B
System for Light-Water-Cooled Reactor Plants."
ANSl/ASNE N509-1980, " Nuclear Power Plant Air Cleaning Units C
and Components (Revision of ANSI /ASME N509-1976)
ANSl/ASME N510-1980, " Testing of Nuclear Air-Cleaning Systems C'
(Revision of ANSI /ASME N510 1975)."
l Bulletins. Circulars, and Information Notices IE Bulletin No. 80-10. " Contamination of Nonradioactive Systems 8 and Resulting Potential for Unmonitored. Uncontrolled Release of Radioactivity to the Environment," May 6, 1980.
IE Cirular No. 77-10. " Vacuum _ Conditions Resulting in Damage B
to Liquid Process Tanks," July 15, 1977.
IE,;rcular No. 77-14. "Sepa'ation of Contaminated Water B
Systems from Uncontaminated Plant Systems," November 22, 1977, 1E Circul:r No. 79-21, " Prevention of Unplanned Releases of 8
Radioactivtty," October 17, 1979..
IE Circular Mc. 80-14. " Radioactive Contamination of Plant B
Demineralizan Waste System and Resultant Internal Contamine-tion of Personnel," June 24, 1980.
IE Circular No. 80-18. "10 CFR 50.59 Safety Evaluations for A, 6, C Changes to Radioactive Wute Treatment Systems,"
August 22, 1980.
IE Circular No. 81-09, " Containment Effluent Water That B
Bypasses Radioactivity Monitor," July 10, 1981.
IE Information Notice No. 79-07, " Rupture of Radwaste Tanks,"
B March 26, 1979.
84750 A-3 Issue Date:
09/30/88
1 Applicability IE Information Notice No. 79-09, " Spill of Radioactively Con-A taminated Resin," March 30, 1979.
IE Information Notice No. 82 32, " Contamination of Reactor-0 Coolant System by Organic Cleaning Solvents," August 19, 1982.
IE Information Notice No. 82-43, " Deficiencies in LWR Air C
t Filtration / Ventilation Systems," November 16, 1982,
!E Information Notice No. 82 49, " Correction for Sample Con-C' ditions for Air and Gas Monitoring," December 16, 1982.
IE Information Notice No. 83-14. "Dowatered Spent Ion-Exchange-.A Resin Susceptibility to Exothermic Chemical Reaction,"-
March 21,~1983.
[
IE Information Notice No. 83 49, " Sampling and. Prevent un of 0
Intrusion of Organic Chemicals Into Reactor Coolant Systems,"
l July 25, 1983.
~
IE Information Notice No. 83-52, " Radioactive Waste System.
C Events," August 9, 1983.
i.
NUREG and NUREG/CR Documents NUREG-0133, " Preparation of Radiological Effluent Technical A,-8, F Specifications for Nuclear Power Plants," October 1978.
I NUREG-0472, " Radiological Effluent Technical Specifications:
A, B, C, F l
for PWRs,", February 1980.
l NUREG-0473,' " Radiological Effluent Technical-Specifications A, B, C.LF for BWRs," February 1980.-
NUREG-0654, " Criteria for Preparation and Evaluation of Radio-E l
logical Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980.
NUREG-0737, " Clarification of TMI Action Plan' Requirements,"
B, C, E November 1980.
NUREG/CR-1413, "A Radionuclide Decay Data Base Index and
.E' Summary Table," May 1980.
Electric Power Research Institute (EPRI) Publications EPRI NP-2734 " Solid Radweste Radionuclide Measurements,"
A November 1982.
EPRI NP-2900, " Low-Level Radwaste Solidification," March 1983.
A Issue Date: 09/30/88 34750 r
l i
l s.
l Applicability EPRI NP-3589-SR-LO, "BWR Water Chemistry Guidelines,"
O' p
Apri1 1985.
EPRI NP-4762 SR, "PWR Primary Water Chemistry Guidelines,"
O September 1986.
I EPRI NP 5056-SR, "PWR Secondary Water Chemistry Guidelines,"
- 8. O Revision 1, March 1987.
Industry Documents ASTM, Annual Book of ASTM Standards, Section 11. Wata and 0
Environmental Technolony, Volumes 11.01 Water (!) and 11.02 Water (II),1983 ASTM STP 150, ASTM Manual on " Presentation of Data and Control 0
Chart Analysis," ASTM 1976.
INP0 Guideline 82-007, " Chemistry Technician Qualification,"
0 September 1982.
INPO Good Practice CY-701, " Quality Control Program,'or Chemis-O try Instrumentation," INPO 83-016, May 1983.
INPO Good Practice CY-702, " Verification of Analytical-Per-O formance," INPO 83-017, May 1983.
INPO Good Practice 82-001-0EN 05, " Reduction of PWR Radiation.
O Level Buildup by Maintenance'of High Reactor Coolant pH,"
November 1982.
INPO SOER, " Intrusion of Resin, Lubricating 011, and Organic 0
Chemicals into Reactor Coolant Water,"_ December 13, 1982.
l Other References Generic Letter 81-38, " Storage of Low-Level. Wastes at Power A, B Reactor Sites," and Enclosure, " Radiological Safety Guidance for Onsite Contingency Storage Capacity," November 10, 1981.
Generic Letter 85-02, " Staff Recommended Actions Steaming from 0
l NRC Integrated Program for the Resolution of Unresolved Safety Issues Regarding Steam Generator Tube Integrity," April.17, 1985.
Memorandum from D. G. Eisenhut to Regional Administrators, C
" Proposed Guidance for Calibration and Surveillance Reouirement.
for Equipment Provided to Meet Item II.F.1, Attachments 1, 2, and 3, NUREG-0737," with enclosures, August 16, 1982.
Memorandum from J. E. Wigginton to R. R. Bellamy et al., " Air 0
Intrusions into BWR Primary Systems," April 15, 1983.
84750 A-5 Issue Date: 09/30/88
\\
i Applicability Memorandum from R. C. DeYoung to J. P. O'Reilly, " Inspector DE Followup on INPO Identified Deficiencies," December 7,1984.
Radiological Assessment Branch-Technical Position, F
November 1979, Revision 1.
DOE / TIC 11026, " Radioactive Decay Data Tables, D. C. Kocher, E
1981.
EPA-520/5-84 006, " Eastern Environmental Radiation Facility E
Radiochemistry Procedures Manual," R. Lieberman,1984.
EPA-600/4-82 062, " Quality Assurance Handbook for Air Pollu-F tion Measurement Systems: Volume IV, Meteorological Measure-4 ments," February 1983.
HASL-300, "Envire'l.$cntal Measurements Laboratory Procedures E
Manual," H. L. kv '"ok and G. dePlanque, 1982.
100-12096, "RESL Analytical Chemistry Branch Procedures E
Manual," L. Z. Bodnar and D,. R. Percival, U.S. Department-of Energy, 1982.
Erdtmann, G., and Soyka, W., "The Gamma Rays of the Radio-E nuclides:
Tables for Applied Gamma Ray Spectroscopy,"
Verlag Chemie, New York, 1979.
v
" LWR Coolant Impurity Control," EPRI Journal, pp. 56 59, 0
September 1984.
i Strauss, Sheldon 0., " Polishing Cuts Condensate Impurities O
Below 0.1 ppb Level," Power, pp. 18-24, Octcber 1984.
Taylor, John J., " Controlling PWR Radiation Fields,"
D EPRI Journal, pp. 56-58,' May 1983.
Taylor, John J., "BWR Water Chemistry," EPRI Journal, D
pp. 52-54, January / February,1983.
Taylor,. John K., " Principles of Quality Assurance of. Chemical 0
Measurements," National Bureau of Standards Report N851R 85-3105 February 1985.
Wood, C. J., " Current Status and Future Direc+ie- -f the EPRI O
Radiation Control Program," Radiation Prote negement 1 (No. 2), 65-75 (January 1984).
END Issue Date:
09/30/88 A-b 84750
/
UNITED STATES l
>I E
NUCLEAR REGULATORY COMMISSION
/
OFFICE OF INSPECTION AND ENFORCEMENT g,
,/
Washington, D.C. 20555 INSPECTION AND ENFORCEMENT MANUAL-DQASIP INSPECTION PROCEDURE 84722 SOLID WASTES (MINIMUM AND BASIC)
PROGRAM APPLICABILITY:
2515 and 2525 i
84722-01 INSPECTION OBJECTIVE l
To determine whether the licensee effectively controls and quantifies i
radioactive solids during normal and emergency operations.
84722-02 INSPECTION REQUIREMENTS l
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 commitments and corrective action.
02.02 Changes Review changes in equipment and procedures and determine whether changes are in accordance with 10 CFR 50.59.
02.03 Processing and Storage Determine the adequacy of processing, control, and storage of solid wastes.
02.04 Disposal of Low-Level Wastes If the licensee has disposed of low-level radioactive waste, determine whether the licensee has established procedures for proper classification and -characterization of
- wastes, for preparation of waste manifests, marking of packages with the class of waste, and investiga?, ion of. lost shipments.
- Minimum inspection program requirement.
Issue Date:
01/01/84
.. ~
I
,84722-03 SOLID WASTES (MINIMUM AND BASIC)-
L 84722-03:
INSPECTION GUIDANCE 03.01 Audits and Appraisals a.
Review reports. of required audits since the last inspec-I tion.-
Look particularly for those audits that ' probe for programmatic weaknesses and assess the quality of the p.ogram.
Focus upon licensee followup actions for identi-fied deficiencies.
Are corrective actions timely and'
.I technically acceptable?
Requirements for reviews. and audits normally are contained in the-technical specifications.-
Audit teams should include someone knowledgeable in liquid and solid waste systems.
(Regulatory Guide 1.146 and ANSI /ASME ' N45.2.23-i 1978, Section 2.2.)
b.
Review reports of other audits, appraisals, assessments, evaluations (including INPO evaluations),- etc., that may i
provide information on program quality.
03.02 Changes Discuss significant changes in equipment and procedures with cognizant management.
(See IE Circular No. 80-18.')--
03.03 Processing and Storage a.
Requirements for a process control program usually are contained in the technical specifications.
IE Inspection Procedure 65051 covers ~ the adequacy of 6
construction of facilities for temporary onsite storage of low-level waste.
b.
Inspect selected records to determine'whether quantity and radionuclide composition are being measured or estimated as
- required, c.
Briefly review solid radwaste reports for obvious mistakes, anomalous measurements, omissions, and trends.
d.
Review the licensee's experience in ' maintaining and using waste solidification systems, Inspect the operation of solid waste processing activities.
e.
Consider whether process or other engineering controls are being used to the extent practicable to limit airborne concentrations.
1 Issue Date:
01/01/84 -
([ ~
I 3
l
,- SOLIO WASTES (MINIMUM AND BASIC) 84722-03.03f p
1 f.:
If mobile waste. solidification systems are used, determine by discussion and review of: records whether the systmes 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.
Datermine whether the i
l integrity of the existing plant / mobile radwaste interface is tested periodically (e.g., system hydrostatic testing L
and visual checks for leakaget i
Disposal of Low-Level Waste f
l a.
Prior to shipping low-level wastes for disposal, the licensee must have procedures properly approved by manage-6 ment for:
l i
\\
1.
Classifying wastes pursuant to 10 CFR 61.55.
]
2.
Assuring that wastes meet -the characteristics of-l 10 CFR 61.56.
3.
Preparation of waste manifests pursuant to 10 CFR 20.311.
j L
4.
Marking packages with the class of ' waste pursuant to 10 CFR CO.311(d)(2).
5.
Investigation of lost shipments pursuant to 10 CFR 1
20,311(h).
b.
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 evalua-tion of audits pursuant to 10 CFR 20.311(d)(3).
1 84722-04 BIBLIOGRAPHY.
a.
Regulatory Guide 1.21, " Measuring and Reporting Radioactiv-ity in Solid Wastes and Releases of Radioactive Materials in Liquid' and Gaseous Effluents from-LigHyWater-Cooled-Nuclear Power Plants."
l b.
Regulatory Guide 1.143, " Design Guidance for Radioactive-Waste Management Systems, Structures, and Components in L
Light-Water-Cooled Nuclear Reactor Power Plants."
L i
i c.
Regulatory Guide 1.146, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants."
d.
NUREG-0133, " Preparation of Radiological Effluent Technical Specifications for Nuclear Power Plants," 0ctober. 1978.1
, Issue Date:
01/01/84
g-64722 04e SOLID WASTES (MINIMUN AND 8ASIC) i e.
NUREG 0472, " Radiological Effluent Technical Specifications for PWRs," February 1980.
f.
NUREG-0473, " Radiological Effluent Technical Specifications for BWRs," July 1979.
I g.
ANSI /ASME N45.2.23-1978, " Qualification of Quality Assur-l ance Program Audit Personnel for Nuclear Power Plants."
h.
ANSI /ANS-55.1-1979,
" Solid Radioactive Waste Processing System for Light-Water-Cooled Reactor Plants."
j i.
EPRI NP-2734, " Solid Radwaste Radionuclide Measurements,"
November 1982.
j.
EPRI NP-2900, " Low-Level Radwaste Solidification," March
}
1983.
k.
IE Inspection Procedure 65051, " Low-Level Radioactive Waste Storage Faciliti'es," January 1, 1983.
1.
IE Inspection Proccudre 84850, " Radioactive Waste Manage-Inspection of Waste Generator Requirements of ment 10 CFR 20 and 10 CFR 61."
r m.
IE Circular No. 80-18 "10 CFR 50.59 Safety Evaluations for Changes to Radioactive Waste Treatment Systems,"
i August 22, 1980.
j n.
'I E Information Notice No. 79-09, " Spill of Radioactively Contaminated Resin," March 30, 1979, o.
IE Information Notice No. 83-14 "Dewatered Spent Ion-Exchange Resin Susceptibility to Exothermic Chemical Reactor," March 21, 1983.
Generic Letter 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.
END Issue Date:. 01/01/84 -
m l-1 l
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1
[
A.
UNITED STATES n
NUCLEAR REGUAATORY COMMISSION
(..... )!
(
5 OFFICE OF INSPECTION AND ENFORCEMENT Washington, D.C. 20885
(
j INSPECTION AND ENFORCEMENT MANUAL l
00ASIP 1
INSPECTION PROCEDURE 84850 j
i RADIDACTIVE WASTE MANAGEMENT - INSPECTION OF WASTE GENERATOR REQUIREMENTS OF 10 CFR 20 AND 10 CFR 61 i
PROGRAM APPLICABILITY:
2500, 2515, 2600, an'd 2800 l
84850-01 INSPECTION OBJECTIVE 1
i To determine whether the licensee has established and is maintaining ade-quate management controlled procedures and quality assurance which reason-ably assure compliance with the requirements of 10 CFR 20 and 10 CFR 61 applicable to low-level radweste form, classification, stabilization, and shipment manifests / tracking.
l 84850-02 INSPECTION REQUIREMENTS 02.01 Management Conttols.
Review the licensee's written procedures for radweste processing, specifically identifying the primary documentation thereof.
Verify that the following aspects are adequately addressed:
a.
that the individual (s) and organizational entities which have been assigned the responsibility for radwaste pro-cest.ing for low-level land burial have been clearly desig-nated in writing; b.
that there has been a clear delineation of the authorities and responsibilities of those individuals and organizational entities;
' c.
that written management-approved instructions have been established to carry out the various radwaste processing and packaging activities, including authorized changes
- thereto, and the promulgation / distribution of such instructions to the appropriate line/ staff organization.
02.02 Quality control (OC). Verify that the licensee-has established and maintains an adequate QC program to assure compliance with'
(.
the waste classification and characterit.ation requirements of 10 CFR 61.55 and 61.!6.
Verify whether the QC program includes 1
the required audits and management evaluation of such audits.
Review the results of the most recent audit and corrective actions (10 CFR 20.311(d)(3)].
.c RADIDACTIVE WASTE MANAGEMENT -
t-
?
INSPECTION OF WASTE GENERATOR REQUIREMENTS OF 10CFR20 & 10CFR61 84450-02.02 I
For nuclear power plant licensees, QC activities related to I
implementation of 10 CFR Part 61 and 10 CFR 20.311 are not required to be included under the licensee's corporate leve,1, quality assurance program for " Nuclear Safety Related items.
p, view the licensee's procedures and records to Westo Manifesti.
1 02.03 veri"y that each shipment of redweste intended for offsite dispo-to a broker or a licensed land burial facility is accompa-sa) nied by a shipment manifest which includes all of the required l
information (10 CFR 20.311(b) and (c)).
i Review the licensee's documentation and 3
Waste Classification.
02.04 records of activities which have been established and are being J
maintained to assure that all low-level 'redwestes are properly i
classified according to 10 CFR 61.55.
Verify whether such l
efforts reasonably assure that a realistic representation has l
been accomplished [10 CFR 20.311(d)(1)].
i 02.05 Waste Form and Characteriution.
Review the licensee's documen i
tat' on and records of ac t,1vities, which have been established and are being maintained, to assure that all low-level radweste s
meets the waste characteristics of 10 CFR 61.56.
Verify whether l
the methods and determinations of the licensee provide reasonable, assurance that the waste form requirements are met (10 CFR 20.311
,,s
'-C (d)(1)).
i 02.,06 Weste Shipment '.abelina. Review the licensee's procedures and records to ver' fy that each package of radweste intended for shipment to a licensed land burial facility is labeled, as appro-priate, to' identify it as Class A, 8, or C waste in accordance with the classification criteria of 10 CFR 61.55 (10 CFR-20.311 (d)(2)).
e Trackina of Waste Shionents.
Review the licensee's procedures 02.07 and records to verify that a system has been established to for-ward to recipients or deliver to waste collutors at the time of shipment, a copy of the waste manifest. Verify that acknowledge-Verify that the ment of receipt of the manifest is obtained.
licensee has a procedure in place to effect an investigation in any instances wherein ackncwledgement of receipt of shipment has not been received within the specified period. Verify that proca-dures are in place to report such investigations to the appropri-ate NRC Regional Officn and file the required written report.
[10 CFR 20.311(d),(e),(f), and (h)].
Disposal Site License Conditions.
Review the licensee's proco-02.08 dures and records to verify that the applicable disposal site i
license conditions are being met.
Verify that the 1.icensee has on file a current version of the disposal site license.
Issue Date:
02/21/84 2
i.
E i
q i
)
l
/
RA010ACT!vE WASTE MANAGEMENT -
INSPECTION OF WASTE GENERATOR REQUIREMENTS OF 10 CFR20 & 10 CFR61 84850-03 84850 03 INSPECTION GUIDANCE 03.01 General Guidanco.
NMSS has stated that with respect to the' new requirements o"
waste generators pursuant to 10 CFR 20 and j
r 10 CFR 61 it "is prepared to be flexible in the adaptation of a particular program to a particular waste generating facility. A 3
1 principal consideration for the acceptability of a particular 1
program will be whether a reanonable (emphasis added) effort has been made to ensure a realfst"c (emphasis added) distribution of radionuclides within wastes, given the physical limitations, and j
to classify wastes in a consistent manner."
IE's position is to reaffirm this " flexibility " particularly during the first year or so after the new rule comes into effect.
This flexibility '
should apply more specifically to the waste classification and waste characterization requirements rather than to the waste l
manifest requirements.
Specific guidance for inspectors as well-t as licensees has been provided by Low Level Waste Licensing l
Branch (NMSS) in the form of Branch Technical Positions on Weste
)
Classification and Waste Form, dated May 1983 (BTPs) (see Federal Reaistor, Vol. 48, No.110, June 7,1983. ) In addition to the i
- BTPs, iMSS has stated pubilcly (48 FR 40512. Vol. 48, No.175, l
Sept. 8, 1983) that
" topical reports" of licensees which have l
been reviewed by NMSS may be useful in demonstrating compliance with the new requirements.
Inspectors should be aware of and be l
prepared to accept results referenced in such topical reports as demonstration of compliance in specific inspection cases.
03.02 Specific Guidance i
a.
Inspection Reevirement 02.01. Manaconent Controls.
Inspection effort should be tr eacted at veri"ying that written procedures have been established in a manner approved by management.
The procehres should, be readily available to any persons having responsibility for low-level waste classification and prepara-tion for transfer of such wastes to land disposal facilities.
The inspector should confirm that the written procedures include l
provisions for all of the applicab,le activities pertaining to Section 84850-02 requi reme,nts.
4 b.
Inspection Reevirement 02.02 Quality Control (QC).
The written operating procedures and quality control-procedures of the licen-see collectively are intended to accomplish compliance with the 10 CFR 20 and 10 CFR 61 regulatory reouirements.
The nature and.
scope of the-licensee's QA/QC program will vary depending upon the nature and complexity of the specific waste stream.
Inspec-tors should observe whether the program and procedures are offec-tive in causing the licensee to perform the required waste form classification and characterizations when chances to the waste stream occur.
3 Issue Date:
02/21/84
I. ~ *, +.
RAD 10 ACTIVE WA$TE MANAGEMENT -
1) i INSPECTION OF WASTE GENERATOR REQUIREMENTS OF 10 CFR20 & 10 CFR61 j
i
- S0 03.02c Inspection Reauirement 02.03. Waste Manifests. Inspectors should
)'
be aware that it is permissible for the licensee to utilize the c.
same shipping paper documents which are required to meet D0T shipping paper and EPA hazardous waste requirements, as the provided that the combined documentation con watte-manifelt,the information required by 10 CFR 20.311. Addi-c ta' ns all o
waste manifest information may also be required by the tional l
operator of the land disposal facility.
I
- nspection Roottrement 02.04. Weste C1astification.
The inspec-d.
';or's effort s )ould be directed to ';he review' ng of the adequacy c
of the method used by the licenses to detemine radionuclide The NMSS STP on concentrations in ordee to classify his waste.
waste classification describes four acceptable methods for I
classifinfl wastes. The inspector should.use this BTP as his basic l
i guidance un implementing this inspection requirement.
L For those licensees who use correlation factors for classi-1.
fying wastes, correlation factors should be based on actual waste stream analysis.
i Generic PWR, BWR or facility scaling factors are acceptable 2.
if actual sample analysis data correlate with the generic' data base.
t If generic scaling factors are not appropriate for an indi-3.
vidual waste stream, scaling factors should be based on the specific waste stream data.
It i; acceptable to base correlation factors on a single set 4.
of analyses, repeated annually.
If sample analyses have not been completed, calculational 5.
methods for scaling factors are acceptable while analyses 1
are in progress.
$amples should be off site for analysis to be considered in progress.
Following the receipt of the-sample analyses, calculational. methods may continue to be used provided the results correlate with.the actual sample analyses.
NRC-approved topical reports for waste classification are 6.
acceptable for demonstrating compliance with 10 CFR 61.55.
'nspection Reovirement 02.00. Westo Form and Characterization.
'he inspector's ef fort shou' d be d' rected to determining the test -
e.
methods and acceptability of such tests used by the licenses to t
In cases where a "high integrity characterize his waste stream.
container" is used to stabilize the waste, the type and accept-ability of the specific container should be verified. The inspec-ter should use the NMSS BTP on waste form as hisWsic guidance in implementing this inspection requirement.
In addition:
Issue Date:
02/21/84' 4
+
Li,....
RADICACTIVE WASTE MANAGEMENT -
INSPECTION OF WA$TE GENERATOR REQUIREMENTS OF 10CFR20 & 10CFR61 84850-03.02e.1 1.
Class B and C solidified waste programs should contain test data on compressive strength, leaching, irradiation stabil-i l
- ity, biodegradation, and thermal stability.
Results of I
tests should be consistent with the Branch Technical Post-tion on waste form.
Test data packages which do not address all of the above areas may be acceptable, provided that I
toting is under way to complete the data package.
A sched-uel for completion of the testing should be available for NRC inspection.
Solidification media currently being used (coment, vinyl-ester-styrene, asphalt) are acceptable, waste forms for shipment and burial, provided that qualification testing is in progress and.there are procedures and controls I
in use to ensure the consistent ' production of waste capable of existing as a free-standing monolith.
2.
The licensee's solidification process control program should incorporate the testing information from the sol' dification agent stability qualification.
i 3.
NRC-approved topical reports on high integrity containers and solidification agents are acceptable for demonstrating compliance with 10 CFR 61.56(3).
4.
A Certificate of Compliance issued by a state for high 6
integrity container is acceptable for demonstrating compli-ance for waste shipped to that state.
f.
Inspection Recuirement 02.06. Weste Shineent '.abelina. Inspectors as well as the 1Scensee should be aware tha ; Classes A, B, & C wastes bear no relationship to Types A or B packeninn for trans '
port purpqpes under 49 CFR or 10 CFR 71.
The label ng of waste packages pursuant to this requirement is, therefore, in addition to any other package markings and labels required by the trans-port regulations, g.
Inspection Re0uirement 02.07. Trackina of Weste Shinnents.
In-spectors shou' d be aware of the differences < n the 10 CFR 20.311 requirements on waste manifest tracking for' shipments by genera-tors by generators to waste collectors, as opposed to shipments i
directly to land disposal facilities.
There are also some dif l
forences in the specific requirements of a waste collector who processes the waste before shipping it to the disposal facility, i
as contrasted with a collector who simply stms the material before transferr'ng it to the land disposal fac'1'ty.
1 1
i
(-
7 5
Issue Date:
02/21/84
l L' '
- RA010 ACTIVE WA5TE MANAGEMENT -
INSPECTION OF WA$TE GENERATOR 44850-04 REQUIRENENTS OF 10CFR20 & 10CFR61
)!
t 44850-04 REFERENCES 04.01 Raoulations
" Final 'Rulemaking on Land Disposal of Low-Level Radioactive Waste," sailed to all NRC licensees on Feb. 11, 1983 containing the Federal Reaister of Dec. 27, 1982 with the new 10 CFR 61 and 10 CFR 20,311 amendments, plus a question / answer " fact sheet" on the new requirements.
5 e
04.02 Other References a.
Fedoral Renistor. Vol.
44, No. 110, June 7, 1983, NRC Not ce,
" ow-level Waste Licensing Branch Technical Position Papers on Radioactive Weste Classification and Waste Form; Availability."
b.
" Final Waste Classification and Waste Fom Technical Position Papers",
mailed to all NRC licensees on May 11, 1983 by NM$5, Low-level Weste Licensing Branch, c.
IE Manual Temporary Instruction 84850/1
" Radioactive Licensee Preparation for Compliance Waste' Nanagement With 10 CFR Part 61",
issued June 21, 1983, expired December 27, 1983.
d.
Fedoral Recister, Vol. 48, No. 175, Sept.
8, 1983; NRC Not' ce " Topical Reports in Support of the Implementation of Waste Classification and Weste Fore Requirements", a l
notice of the waiver of fees for NRC rgviews of such reports until June 30, 1984.
END Issue Date:
02/21/84 6
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TECilNICAL ASSISTANCE REQUEST FROM
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THE STATE OF CALIFORNIA Lohaus 7/10 f n /[' M,L.
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l July 6,1990 le f
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[f s MEMORANDUM FOR:
Richard Bangart, Director I
Division of Low-Level Waste Management
'f/J ar1 Decommissioning, NMSS f
FROM:
Yandy L. Miller, Assistant Direc y
for State Agreements Program State Programs, GPA
SUBJECT:
TECHNICAL ASSISTANCE REQUEST FR THE STATE OF CALIFORNIA Attached is a letter from Don Womeldorf, Chief of the Environmental Branch, requesting technical assistance from the NRC in licensing and regulating a low-level waste disposal facility.
The four items of the letter are not specific to processing a low-level waste application as envisioned in SP/LLWM procedure for technical assistance to Agreement States.
I would like to request your input to the four items raised by California so that we can at least give California NRC's status or additional information as appropriate for each of these items. A
[
response by July 18, 1990 would be appreciated.
If you have any questions, please contact Kathleen Schneider at X20320.
Attachment:
As stated l
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fit 4ve h cAtwon,u-mattu me wmA Aoewer oeceos wunaew. wYl8 I DEPARTMENT OF HEALTH SERVICES m/ne'e itnert e.o. nos e4:n 6AceAAneNto. CA 942341370 (916)'445-0498 i
June 18, 1990 i
i le e
a n.
Mr. Carlton Kamarer
-L office of Cargrassional Affaizu 1.
U.S. Nuclear Regulatory *==1on 2
!~.
Washirgten, DC 20555 Q
Dear Mr. Kamarer:
'Ibe california Im -Invel Radioactive Waste (LUW) pr4mru requests
'Woal assistance fra the Nuclear Hagulatory Carmission (NRC) in several areas as we pr w toward licensing and regulating the operation of a new LUM di===1 facility.
Assistance to states party to the Southwestern carpact would be useful to other states, of ocurse.
i
'Ihe specific items are as follows, in no particular order o Verification of wasta. We are planning to deal with this frtz several aspects.
Point-of-origin spot inspections will be made at generators' ard brokers' facilities. Manifests will be checked.
Inspectors at the d 4 =r==1 facility will also be involved.
'Ihe details of the e
verification system have not been developed.
Assistance fra NRC should be geared tward a cradle-to-grave appread to wasta quantity, quality, and fom verification.
o Uniform manifest.
If indeed a uniform manifest system is to be yd by rulemaking, we would want to have it in place by the time l
that our facility begins operations in late 1991.
o long-term care. Planning for the pericd of time when the facility is closed and under the-institutional custody of the State of California should begin many years in advance of closure.
Our program has not begun to address the several finem1, liability, program, and other issues whi& mast be considered. Of particular early interest is the amount of money whis sanst be set aside to cover future costs as an assurance that needs will be met, o Regulatory uncertainties.
'Ihe focus here is on those unoortainties whid are resulting and will result fra irglenentation by the Environmental Protection Agency of laws sus as those governing wasta disposal, clean air, and so forth. You are working with the states on these issues now, of course, but I note them here because the need continues.
i
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- Mr. Carlton Xamarer hge 2 June 18, 1990 Thank yoa for considering these requests.
Please ocmtact ) uben Junkert, ID6f Project Director, at (916) 323-3021 if there are any questions. We look forward to contiming to work with NRC staff on these and other areas of mutual concern.
Sinonr'aly, t
\\
dogr Ibn Chief Dw Maragement Branch cc: Richard Bangart Office of Conaressional Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 I
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