ML20125C317
| ML20125C317 | |
| Person / Time | |
|---|---|
| Issue date: | 11/25/1992 |
| From: | Callan L Office of Nuclear Reactor Regulation |
| To: | Bangart R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9212110141 | |
| Download: ML20125C317 (10) | |
Text
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_ Jg NUCLEAR REGULATORY COMMISSION I
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611 RYAN PLAZA ORIVE. SUITE 400 Y-8 ARLINoTON, TEXAS 76011-8064 NOV 2 51992 -
MEMORANDUM FOR:
Richard L. Bangart, Director Division of low-level Waste Management and Decomissioning Office of Nuclear Material Safety and Safeguards FROM:
L. J. Callan, Director Division of Radiation Safety and Safeguards
SUBJECT:
REVIEW 0F THE DRAFT DECOMMISSIONING INSPECTION PROGRAMS FOR FUEL CYCLE FACILITIES AND MATERIAL LICENFEES In response to your memorandum dated October 19, 1992, Region IV reviewed the draft Decomissioning Inspection Programs for Fuel Cycle Facilities and Material Licensees.
The enclosure presents our comments and suggestions concerning these inspection programs.
Generally, these draft inspection procedures are appropriate for most decommissioning programs. The flexibility vested in the Regions for optimizing their inspection resources and the ability to adapt an inspection program to the requirements of a specific decommissioning project are very important and desirable.
Region IV utilized a license condition in the Pathfinder reactor decommissioning that might be useful in future decommissioning acti,Mies.
This license condition addressed approved of licensee initiated changes.
This is discussed in the first enclosure.
An attachment contains the Pathfinder Decommissioning Inspection Procedure-developed by Region IV, which was used as thr inspection guidance for the first public utility reacter decommissioning in the United States.
If you have any questions, please contact Wesley Holley of my staf at (817) 860-8198.
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Comments on Proposed Decommissioning Programs with Attachment 9212110141 921125 PDR ORG NRRB
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{'j COMMENTS ON THE PROPOSED DECOMMISSIONING INSPECTION PROGRAMS FOR FUEL CYCLE FACILITIES / MATERIAL LICENSEES General Comments The two inspection programs could be combined, since the only differences presently are the names, Fuel Cycle Facilities / Material Licensees, and Procedure Nos. 26XX-0X/28XX-0X.
In all Fuel Cycle Facilities and some large Materials Licensee decommissioning procedures, a QA Program inspection procedure, such as No. 35741B for audits, should be included as part of the core inspection program.
Region IV developed a license condition that proved to be very valuable in the decommissioning of the Pathfinder reactor.
This license condition was for NRC approval of licensee initiated changes for the solution of problems unforeseen when the EA, SER, and other license application attachment items were written.
The following is an example of the licer.se condition.
All such licensee approved changes shall be transmitted to the Regional Administrator or appropriate Headquarters personnel.
Such licensee approved changes shall not be implemented prior to licensee receipt of confirmation by telephone or other means that the licensee approved change has been received and examined by a cognizant member of the NRC Region / Headquarters technical staff.
We recommend that this be incorporated in to all decommissioning licenses.
We have attached an inspection procedure developed by Region IV for the Pathfinder decommissioning.
This procedure may be useful.
Specific Comments Some of the following comments may not be very pertinent to your Draft Dacommissioning Inspection Programs for Fuel Cycle Facilities and Material Licensees, since the draft gives the regions the needed latitude and flexibility in designing a specific decommissioning inspection program.
Pages 2 and 6, first paragraph: Region IV recommends inspecting a facility in an active dismantlement phase more than once every 24 months. We recommend the inspection frequency of once every 12 months as a minimum. Our experience has been that greater regulatory attention is required, if for no other reason than to let the licensee known that his slecommissioning is important to the NRC.
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LPages 2 and 6, second paragraph:
Region IV recommends that an1 inspection be ~
performed during the remedial /r'.ean-up portion of the decommissioning. Also, a pre-final survey inspection is needed to insure that the licensee follows NUREG/CR-5849 during the final: survey.
Pages 2 and 6, third paragraph:
The flexibility given to the regions in this paragraph should be very helpful in designing different inspection programs as needed for various decommissions.
Pages 2 and 6, last parr9taph:
Region IV recommends.that all licensee decommissioning procedures and manuals be reviewed before the decommissioning begins or as soon as possible thereafter so that errors and unacceptable-procedures will be identified before they affect the decommissioning.
Pages 4 and 8, Appendix A: The Regions need guidance on interfacing with EPA similar to that for OSHA, Inspection Procedure No.1007. Also, guidance is needed concerning RCRA and CERCLA material encounterad during decommissioning.
activities.
Page 8, Appendix A:
For some material decommissions, it would be beneficial.
to include Inspection Procedure No. 87100. Licensed Materials Programs.
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Pathfinder Decommissioning Inspection Procedure INSPECTION OBJECTIVE The objective of this procedure is to verify-that Pathfinder' will-be-
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decommissioned in a safe manner so that no harmful radiological hazard,will be presented _ to radiation workers or a member of.the general public. Also, to assure that the facility will be decontaminated _to acceptable levels and will not present _a radiation hazard to future occupants.
1.
INSPECTION REQUIREMENTS 1.1 Organization'and Responsibilities i
Determine the adequacy of the decommissioning staff ana tneir respective activities and res:ensibilities in a functional organization that is referenced in the SER and EA.
1.2 Personnel Training Review the training, general and speciali:ed.
1.3. Quality Assurance (QA)
Determine whether the QA-plan is adequate to ensure ' decommissioning quality, ' safety, compliance with applicable regulations and ALARA, and appropriate record keeping.
1.4 Decommissioning Plan Verify that the licensee is following the decommissioning plan according to the license, SER, and EA.
1.5 Radioactive Waste'Manacement Waste Generation - Evaluate the program to determine theEvolume.
and radioactivity oof ' waste generated by cecommissioning activities.
Waste Handlino and Packaging - Determine whether-the licensee's-waste handling and packaging are consistent.with the. applicable, 1
provisions of 10 CFR Parts 20 and-61, the Commission's Technical-Position on waste classification and-waste form, andtlicense-Conditions 18:and'19.
Waste Transportation.and Disposal - Determine whether.thei
-licensee's waste. transportation and' disposal are consistent with the applicable requirements of'10 CFR Parts 20, 61, and 71, and-with DOT regulations.
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1.6. Radiological Controls Verify that the licensee's effluent release controls, worker exposure controls, and environmental monitoring meet'the requiramentsL specified in the SER,-EA, and the applicable requirements of -10_CFR Part 20, License Conditions 15,16, and 17, in regards to the following:
Health Physics Program Instruments, Equipment and Facilities Procedures Airborne Control and Protection Environmental Monitoring Records 1.7 Reactor Pressure Vessel Removal, Rail Car Loading /Off-Loading, Transoorting, and Burial Ensure that the licensee will fcilow the procedures presented in,tne license, SER, and EA.
1.8 Unrestricted Use-Criteria Determine whether the_ licensee is following the criteria presentaa in the EA and SER for unrestricted release of the FHB and RB structures.
1.9 Final Closecut Inspection and Survey Review the _ licensee's final plan and survey data l and-perform a _ final ~
survey to meet'the requirements of 10.CFR 30.36(c)(1) and SER.
2.
INSPECTION GUIDANCE 2.1 No guidance 2.2 Personnel Training Training should_ include:
General employee training (GET) to all unescorted personnel.
ANSI N18.1-1971, Selection and : Training of-- Nuclear _ Power Plant -
Personnel, Section 5;4.
Radiological Controls and radiation protection from 10 CFR Part 19. Notices, Instructions, and Reports'to Workers and 10 CFR Part 20, Standards for Protection Against Radiation.
Radiation protection personnel trained in accordance with ANSI /ANS-3,1-1981, T
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W Respirator training "for personnel.in airborne' areas which include NRC Regulatory Guide 8.15, October 1976,' Acceptable-1 Programs for-Respirator Protection, and NUREG-0041, Respirator-Protection for Airborne Radicactive Materials.
Prenatal exposure' training from NRC Regulatory Guide-8.13, Revision 1, Instruction Concerning Prenatal Radiation Exposure.
Plant security, fire protection, quality assurance, industrial safety, and indoctrination of the-fitness for duty program.
Examinations and records.
2.3 Quality Assurance Review the QA organization and staff qualifications.
..t Review the 15 specific procedures which govern the conduct of the project QA personnel in the QA program (e.g., 30AP 2.1,
" Standard Audic Procedure").
Review the QA records, aucits, and corrective actions in all functional areas.
2.4 Decommissionino Plan Ensure that. deviations from uecommissioning plan are reviewed, approved, and documented in accordance with License Conditions 121 and 13, 2.5 Radioactive Waste Manaaement Review procedures that determine the radioactivity and volume cf the waste generated; Review waste records andLcompare~with'
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estimates presented in the SER and EA.
Review radwaste segregation-program.
-Review procedures and personnel responsible for_ waste 1 classification, characterization, and' shipping = manifest.
Determine whether~this is1 audited by QA.
Review the~ licensee's.
waste shipment ' labeling, t-acking,- investigation, ~ and notification _of waste _ shipment. Review adequacy of low-level' waste storage area / building and. clean waste disposal.
Review waste compaction program.
Verify' that the licensee maintains current copies -of DOT /NRC _
1 regulations,Lburial site license, and documentation for: shipping packages.
Review QC offpackage construction or packageEvendor certification. -Verify proper package: marking and labeling and' t
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I radiation and contamination-surveys lbefore_-shipping.
Veri fy adequate placarding of vehicles-and' advance notificatton of consignee and state notification, ifs required.
Determine total =
activity and volume of waste shipped.
ReviewLnonradioactive-waste disposal 1(Runge Landfill).
2.6 Radiological Controls Review personal dosimetry, radiation and contamination survey-progrrn, radiation control area check point procedures, anticontamination_ methods, health. physics _ personnel responsibilities and organization, radwaste sampling program,.
ALARA program, posting of hazardous areas,10 CFR 19.11 required postings personnel _ Form NRC-5 dose records, radiation _ work.
permit (RWP) program, emergency-response crogram,-bicassay program, and internal dose assessment.
Also, review tne handling and reporting of inciaentse Review adequacy of portable survey instruments as to types and y
numoer/ availability, operation response checks, and calibration -
procedures. Also, review these factors, as necessary,:for area-radiation monitors, air grab' samplers,-CAMS, and laooratory-analytical instruments.
Determine the acequacy and-controls of.
the emergency ccmmunication equipment.
Review selected radiation protection program procedures _out.of approximately 80, which includes health physics instruments, 4
equipment-and facilities, portable radiation survey instruments,.
personnal monitoring equipment, portable: area and airoorne radicactivity monitors, laboratory-equipment, air samplers, respiratory protection,-and contamination control.
Review building air filtration'and. ventilation. systems-forfair movement, prefilters, HEPA filters, automatic isolation dampers =,:.
CAMS, and alarms.
Review engineering-controls.such as portable; 3
ventilation units- (fans and filters) and-isolation. tents.
Review filter loading, testing, and replacement,. Verify that-f.
the-licensee has an adequate assessment program (M?C-hr W
controls) and adequate respiratory protection. equipment (SCBA units, face mask and filters, adequate air supply,:etc.=).
Also review the adequacy of the respiratcry protection program in regards?to storage',-. selection,_ issuance, fitting,> testing c return, maintenance,. training ;and' medical examination.
Review
~ the air sampling program with regard to proper analytical-
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procedures (gross beta gamma,- specific radionuclides.' alpha, etc.), placement of CAMS,.when and where grab.. samples are
-collected,' alarm set points, adequate. laboratory counting equipment, and breathing. zone airJsampling-f t
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q Reviewithe environmental monitoring.concerning Incationsk sample j
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procedures,. time-schedules for river water, _f_ish',: plant
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discharge basin sediment and-water, well water,.nilk, plant 1
material from discharge ditch, soil, 'and sample ' analysis. ?In a
addition, review onsite and'offsite_TLD a'nd air sampling procedures and data.
Determine whether records are clear, pertinent, complete,Tand maintained in all areas of. inspection, espec$ ally.these required' by License; Condition 22.
2.7 Reactor Pressure Vessel Removal. Rail Car Loadino/Off-loading.
Transporting and Burial In addition to~the procedures presented in the -license, 5ER,_and EA,:
also review activities according to'29 CFR 1926,l5ubpart N.
2.8 Unrestricted Use Criteria Review survey data for acceptable surface contamination-criteria presented in Regulatory' Guide 1.86,-Table:1, (Review-the licensee's determination of background) and that gamma exposure 1 rates.measurec 1 m from surfaces did not exceed 5-uR/h above background.
2.9 Final Closecut Insoection and Survey Review backfill over area of removed RS and perform _ fin'al; servey according to NUREG/CR-2082 and 10 CFR 30.35(c)(1).
Review licensee's t'
final survey, environmental 1 records and final records;cf-various '
11 ascects of Pathfinder decommissioning.
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