ML20134H709
| ML20134H709 | |
| Person / Time | |
|---|---|
| Issue date: | 02/04/1997 |
| From: | Greeves J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Gillespie F NRC (Affiliation Not Assigned) |
| References | |
| REF-WM-3 NUDOCS 9702110426 | |
| Download: ML20134H709 (22) | |
Text
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February 4,1997 MEMORANDUM TO:
Frank P. Gillespie. Director Division of Inspections and Support Programs i
Office of Nuclear Reat or Regulation i
FROM:
John T. Greeves. Director [0riginal signed by]
Division of Waste Management Office of Nuclear Material Safety and Safeguards i
SUBJECT:
REVISION TO INSPECTION MANUAL CHAPTER 2401 j
Attached please find a Docuru Issuing Form and the revised Inspection Manual Chapter entitled "Near-Surface low-Level Radioactive Waste Disposal 1
i Facility Inspection Program" The revisions were made by staff from the ffice of Nuclear Material Safety and Safeguards in conjunction with staff from the regional offices. the Office of Nuclear Reactor Regulation, the f
Office of State Programs, and the Office of the General Counsel.
Please update this Manual Chapter in the NRC Inspection Manual.
Because the revisions were developed via a consensus process between participating organizations, a discussion of the comments and their resolution is not i
i included.
Attachment:
As stated
Contact:
Tim Harris. NMSS 415-6613 1
1 DISTRIBUTION:
'CentraPF11e DWM r/f PUBLIC NMSS r/f LLDP r/f hll Ig; ij Regional Administrators BMallet/RII CHosey/RII RScarano/RIV FWenslawski, WCF0 EGarcia, WCF0 i
- SEE PREVIOUS CONCURRENCE
/
DOCUMENT NAME:
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Qlfh h NAME THarris/cv RNelson JHickey MFekrline keNes DATE 1/16/97 1/27/97 1/27/97
//)97 ht/ /97 j
OFFICIAL RLCORD COPJ ACNW: YES
.L NO Category:
Proprietary or CF Only IG : YES x
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y LSS YES NO x Delete file after distribution:
Yes x No 970211o42'6'970204"
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UNITED STATES s
j NUCLEAR REGULATORY COMMISSION t
WASHINGTON. D.C. 2066H1001 February 4,1997 MEMORANDUM T0:
Frank P. Gillespie. Director Division of Inspections and Support Programs Office of Nuclear Reactor Regulation JohnT.Greeves. Director,[
FROM:
DivisionofWasteManagempt Office of Nuclear Materi Safety 1
and Safeguards
SUBJECT:
REVISION TO INSPECTION MANUAL CHAPTER 2401 l
Attached please find a Document Issuing Form and the revised Inspection Manual Chapter entitled "Near-Surface Low-Level Radioactive Waste Disposal Facility Inspection Program". The revisions were made by staff from the
{
Office of Nuclear Material Safety and Safeguards in conjunction with staff from the regional offices. the Office of Nuclear Reactor Regulation. the Office of State Programs, and the Office of the General Counsel.
Please update this Manual Chapter in the NRC Inspection Manual.
Because the revisions were developed via a consensus process between participating organizations, a discussion of the comments and their resolution is not included.
Attachment:
As stated
Contact:
Tim Harris NMSS 415-6613
February 4, 1997 MEMORANDUM TO:
Frank P. Gillespie. Director Division of Inspections and Support Programs Office of Nuclear Reactor Regulation FROM:
John T. Greeves. Director [0riginalsignedby]
Division of Waste Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
REVISION TO INSPECTION MANUAL CHAPTER 2401 Attached please find a Document Issuing Form and the revised Inspection Manual Chapter entitled "Near-Surface Low-Level Radioactive Waste Disposal Facility Inspection Program" The revisions were made by staff from the Office of Nuclear Material Safety and Safeguards in conjunction with staff from the regional offices, the Office of Nuclear Reactor Regulation the Office of State Programs, and the Office of the General Counsel.
Please update this Manual Chapter in the NRC Inspection Manual.
Because the revisions were developed via a consensus process between participating organizations, a discussion of the comments and their resolution is not included.
Attachment:
As stated
Contact:
Tim Harris. NMSS 415-6613 DISTRIBUTION:
Central File DWM r/f PUBLIC NMSS r/f LLDP r/f Regional Administrators BMallet/RII CHosey/RII RScarano/RIV b'f FWenslawski. WCF0 EGarcia. WCFO T
- SEE PREVIOUS CONCURRENCE
/
DOCUMENT NAME:
S:\\DWM\\LLDP\\TEH\\TRAN.MC
/gp S:\\DWM\\LLDP\\TEH\\DIF.MC S:\\DWM\\LLDP\\TEH\\MC2401.REV 0FC LLDP*
LLDP*
LLDP*
DKM,
M h NAME THarris/cv RNelson JHickey MFekrline keNes DATE 1/16/97 1/27/97 1/27/97
// /97 hl/ /97 0FFICIAL RECORD CDPf ACNW: YES x
NO Category:
Proprietary or CF Only IG YES x
NO LSS YES NO x Delete file after distribution:
Yes x No
DOCUMENT ISSUING FORM To: NRR. DISP. Director From: John T. Greeves (Originating Director) 1.
Number and title of document Decommissionina Procedures for Fuel Cycle and Materials Licensees i
2.
Type of document 3.
Type of action X Manual Chapter (MC)
Inspection Procedure (IP)
New document Appendix Temporary Instruction (TI)
X Revision Technical Guidance 10 CFR Guidance Deletion l
4.a.
If a new IP is being prepared, state its need or purpose, whether it is for f
the " Core" Inspection Program, the SALP category it applies to, the direct Inspection hours needed to perform it, and the inspection frequency.
b.
If a TI or IP is being revised, state the reason for the revision, and if applicable, the resulting change in direct inspection hours or FTE, if any.
Core Program:
X Yes No SALP Category:
DIE:
inspection Frequency:
C Statement:
b c.
For any proposed addition in direct inspection hours that results from a or b above, state the increase in proposed hours and identify where the proposed corresponding reduction in direct inspection hours is to occur (Note: the total " Core" hours is a fixed number and cannot be increased without permission from the NRR Office Director).
DIE increase resulting from 4a or 4b:
N/A Proposed reduction, IP No.:
N/A i
Issue Date: 09/27/95 El-1 0040, Exhibit 1 Attachment I
4 Details of reduction:
N/A d.
If new training requirements or the revision of current training requirements are needed as the result of the new IP, TI or revision of existing procedures, these should be identified.
The group responsible for establishing and 4
presenting the training should also be identified.
New training course required?
Yes X No Revision to existing training course?
Yes X No 4
Lead Branch for establishing training:
Training to be given by:
Brief description of proposed training:
f 5.
Provide a floppy disk with the file in the current version of Wordperfect and attach a hard copy of the document, a.
Has document been reviewed by the technical editor? X Yes No If not, state why 6.
Special exhibits (anything that cannot be put in Wordperfect such as drawings, reductions, or block diagrams) are attached?
Yes No X N/A 7.
Attach a summary of comments and resolutions. State comment, its source, and if not adopted why.
Is summary attached?
Yes X No N/n i
l 8.
All approval signatures must be obtained in the order listed below:
Check items 1-7 above and ensure all documents (floppy disk with file in Wordperfect & hard copy, special exhibits, comment summary and resolution, and any background information) are attached to this form before routing it for approvals.
4 N'
4 t! u %7 d.
a.
Ofiginator/Date PIPB, Manual Coord./Date 4
b.
a$bYC ki e.
Originator ~ Tnch Chjef/Date PIPB, Branch Chief /Date l
(/%>M.$--7A 'IO 7 f.
c.
iginator Division Director /Date DISP, NRR, Director /Date 9.
Date received by PIPB 10.
Change notice number and issue Manual Coordinator date:
i i
+
a Issue Date:
09/27/95 El-3 0040, Exhibit 1
_.~
NRC INSPECTION MANUAL LLDP l
MANUAL CHAPTER 2401 NEAR-SURFACE LOW-LEVEL RADI0 ACTIVE WASTE DISPOSAL FACILITY INSPECTION PROGRAM I
l 2401-01 PURPOSE This chapter establishes the radiological safety inspection program for near-surface low-level radioactive waste (LLW) disposal facilities licensed and regulated under 10 CFR Part 61. Included in the program are inspection procedures (IPs) related to all phases of LLW facility activity:
construction, pre-operations, operations, closure, and post-closure. IPs presented cover both those facilities licensed and regulated in their entirety by NRC and those facilities that are licensed and regulated by HRC for special nuclear material (SNM) only, and which are otherwise regulated by the Agreement State pursuant to Subsection 274b of the Atomic Energy Act of 1954, as amended.
The primary purpose of the inspection program is to determine that LLW facilities are managed throughout their entire life cycle in a manner that provides protection from radioactivity to employees, members of the public, and the environment.
2401-02 OBJECTIVES 2
02.01 To establish general policy and priorities for the inspection of LLW disposal facilities.
02.02 To establish a uniform process for the inspection of LLW disposal facilities.
02.03 To define specific requirements for inspection of LLW disposal facility licensees.
2401-03 PROGRAM APPLICABILITY This program has been develope.f to respond to existing and developing needs for:
(1) IPS for NRC-licensed SNH disposal operations at facilities regulated in all other aspects by Agreement States; and (2) procedures related to construction, pre-operation, operations, closure, and post-closure for sites licensed by NRC in non-Agreement St ates. Where LLW disposal sites are operating under Agreement State regulation, except for SNM disposal, it is expected that responsibility for regulation and inspection of closure and post-closure activities at those sites will continue to reside with the Agreement States. The only procedure applicable to those cases where NRC only regulates SNM disposal (such as the Hanford and Barnwell LLW facilities) is IP 84100.
Issue Date: 2401
It is noted that existing IPs from other NRC progra2s can be applied, in full or in part, to many aspects of LLW facility inspections, and that additional LLW IPs specific to disposal technology and phase of on-site activity can be developed and employed incrementally, as needed.
1 Table 1 provides a listing of procedures that are either currently available or in preparation, and includes comments concerning their applicability. Minimum and normal frequencies of inspection are listed; adoption of the minimum frequency of inspection should be tailored to both the level of disposal activity and to the performance of the licensee.
2401-04 PROGRAM DESCRIPTION 04.01 General. The LLW disposal facility inspection program has been divided into five parts.
The parts are designed to respond to the various inspection needs during the different phases of disposal facility life:
construction, pre-operations, operations, closure, and post-closure.
Each phase of the l
inspection program varies with respect to applicable IPs, inspection frequency, and degree to which a given procedure may be applied.
The inspection programs for each phase are discussed in narrative form in Section 2401-07.
Table 1 presents information for the operations and closure phases. Information related to the construction, pre-operations, and post-closure phases will be deveioped later.
04.02 BLlustments.
The program provides regional offices the flexibility to adjust the frequencies of inspections within the various program areas based on an evaluation of the inspection findings and enforcement experience with a particular licensee. Alternate frequencies of inspection for various procedures are specified in Table 1 Under certain conditions, the inspection frequency may be further extended as outlined below.
The higher frequency of inspection specified for the procedure shall be the normal inspection frequency for the program.
There is no maximum frequency expressed in Table 1.
It is expected that any level of effort (4,e.,
equency of inspection) above that specified as the normal frequency woulc be established at a level commensurate with whatever is needed to resolve identified problems and their importance to safety.
04.03 Decrease of Inspection Freauency The inspection frequency shall be decreased (lengthen the interval between inspections) beyond that specified in Table 1 on the basis of good licensee performance.
The main consideration in decreasing the inspection frequency should be evidence of well-managed and effective radiation and criticality safety programs that show a history of compliance.
Specifically, the inspection frequency shall be decreased, for licensees meeting the following conditions:
l 1.
the violations identified during the licensee's current and preceding inspections met the criteria for documentation on an NRC Form 591 and no more than two violations per inspection are Severity Level IV or more severe; and 2.
the licensee has not had a significant program change since the preceding inspection. Significant program changes d.ould relate to changes in the scope or type of operations, changes in the authorized materials or possession limits, changes in key personnel, or changes in locations of use.
(NOTE: Extension should not be considered for j
licensees that have undergone significant program changes, to ensure 2401 Issue Date:
12/31/91
that the licensees can maintain adequate performance over the next inspection period.)
Licensees that meet the above criteria could have their minimum inspection 1
frequency shown in Table 1 doubled (i.e. inspections would be performed every 2 years instead of annually).
The designated inspection priority for these licensees should not be changed in the licensing tracking system (LTS). However, the inspector is responsible for i
initiating the change in the "next inspection date" field in the LTS, which will contain the extended date for the next inspection.
To identify the extended inspection date in the LTS, the letter "E" shall be entered under "Special Inspection Codes" on the " Inspection and Enforcement Screen" of the LTS.
To document the decrease in inspection frequency, a brief note (e.g., in the field notes) should be written by the inspector, approved and signed by the inspector's immediate supervisor, and placed in the licensing file.
The decision to decrease the inspection frequency should be made immediately after each routine inspection.
04.04 Inspection Interface with Aareement States. LLW facilities may be fully l
regulated by NRC, or regulated by NRC for disposal of SNM only, such that all other :,ite activities are otherwise regulated by the Agreement State.
Where Agreement State regulatory authorities are responsibic for inspection of licensed activities related to disposal of source and byproduct material, the NRC program for inspection of SNM disposal operations may be condensed. The Agreement States then bear the major burden related to the inspection of such LLW facilities; NRC will then normally inspect only matters addressed by the NRC license for SNM disposal, whereas the Agreement State regulatory agency will undertake inspection for items governed by the State license.
It is desirable that Agreement State and NRC inspectors coordinate inspection activities and, if possible, schedule M
inspections concurrently to maximize efficient use of inspector resources and to foster a mutual understanding of each other's inspection program. Where there is concern for the safety of employees, members of the public, or the environ-ment, the scope of the SNM inspection by NRC can be increased to incorporate additional aspects of facility operations, in accordance with NRC regulations and the operating license of the facility.
2401-05 REVIEW 0F EVENTS All inspections should include, as appropriate, a review of licensee reportable and non-reportable events that involve contamination, releases, equipment malfunctions, or other similar events that have generic significance. The review should cover corrective actions taken by the licensee and follow-up actions taken to prevent recurrence.
Non-reportable events should continue to be exar.ined during inspections, to determine appropriate corrective act'ons or follow-up: these events may involve safety issues that should be followed up by the Occupational Safety and Health Administration (OSHA), and existir.g or potential operational difficulties not otherwise reportable, such as bio-intrusion in disposal units, erosion or sloughing of trench walls, or uncontrolled wind erosion. Additional guidance on non-reportable events is contained in individual IPs.
Issue Date: 2401 l
2401-06 REGIONAL RESPONSIBILITY FOR LICENSEES The responsibility for inspection resides with the regional office in wh'ich the
~
licensee operation is located.
For efficiency in resource use, the regional office may request another regional office or Headquarters to assist in the conduct of inspections when specialized technical expertise is needed and is not available within the responsible region.
In some cases, a region may wish to transfer all or part of the inspection responsibility to another region or to Headquarters. These arrangements may be made with mutual agreement between the offices involved. If a permanent transfer of total inspection responsibility is involved, the affected regional offices should ensure that the appropriate changes are made to the computurized license data file by informing the Office of Nuclear Material Safety and Safeguards (NMSS) of the change in inspection responsibility for the license and requesting a change in the file. The regional office assuming inspection responsibility will be credited with the caseload in budgeting and allocating resources.
l i
2401-07 INSPECTION DURING VARIOUS PHASES OF FACILITY LIFE 07.01 Part 1 - Insoection Durina the Construction Phase This section is reserved for future use.
07.02 Part II - Inspectic
..ao the Pre-Operations Phase This section is reserved fcr future use.
07.03 Part III - Inspection Durina the Operations Phase l
a.
Purpose The purpose of this instruction is to provide guidance for planning and q
conducting inspections during the operations phase of facility life.
Activities encompassed during the operations phase include receipt and 1
inspection of incoming waste, retention of the LLW in secure temporary storage as needed, emplacement of the LLW for disposal, the placement of cover, and satisfaction of record keeping requirements in accordance with applicable management controls and quality assurance procedures.
b.
Imolementation This inspection program begins upon issuance of the facility license and continues until the facility ceases active receipt and disposal of waste.
Guidance and requirements for the closure phase are found in Part IV of this section.
Situations may arise in which inspection requirements specified in other parts of this section may apply concurrently with those specified here for the operations phase. For example, certain requirements contained under Parts 1 and 11 may apply in the construction, pre-operational checks, and startup of a major modification to the facility, in accordance with 10 CFR 61.25.
The LLW disposal-facility operations inspection program is defined by selection from among the list of procedures in Table 1. The areas covered during an inspectior, need not be limited only to those elements discussed l
in the procedures, but may need to include examination of other activities 2401 Issue Date:
12/31/91 i
.. _ - ~ -..
~. -.
1 j
not expressly delineated or cover:d in existing procedures.
In such j
cases, the inspector must exercise good professional judgment in modifying j
the inspection and in identifying to the program office the possible need for development of supplemental guidance. Conformance with the principles of ALARA should be a principal concern at all times. When a licensee is being inspected solely for conformance with an NRC lict.nse for disposal 1
of LLW SNM, the inspection should be coordinated with the nuclear regulatory agency of the Agreement State.
l For the normal inspection frequency, each procedure should be completed j
whenever possible for each specified frequency. In practice, part or all i
of an individual procedure may need to be examined during each inspection visit.
Emphasis should be placed on physical examinations, observation of conduct of operations, independent measurements, and personnel interviews.
Attention should. be directed toward the availability of 1
written procedures, the degree to which they are being followed, and the state of training of on-site personnel. When necessary, effort should be concentrated on areas of perceived concern.- With the exception of the review of changes made under 10 CFR 61.25 and the tracing of lost or overdue shipments, which should be examined fully, review of records 4
should otherwise involve only a sampling of those records important to safety of personnel and the general public.
For example, if the organizational structure has not changed with respect to personnel and assigned functions and responsibilities, the inspector should not pursue the subject of organization in any detail, unless there is reason to believe that such is not the case. Discretion in such areas is left to the judgement of the inspector.
c.
Reaulatory Considerations The inspector should be especially familiar with current license requirements; previous inspection reports; applicable codes, standards and guides; and the following regulations:
d 10 CFR Part 19 Notices, Instructions, and Reports to Workers: Inspection and Investigations 10 CFR Part 20 Standards for Protection against Radiation 10 CFR Part 61 Licensing Requirements for Land Disposal of Radiological Waste 10 CFR Part 70 Domestic Licensing of Special Nuclear Material i
10 CFR Part 73 Physical Protection of Plants And Materials d.
Guidance for Use of Inspection Procedures Durino Operations j
The IPs indicated in Table 1 (enclosed) for the Operations Phase are applicable to inspections conducted at LLW disposal facilities during operations. The inspection staff can determine the applicable elements of each procedure by reviewing the procedure, the facility license, and reports of previous inspections.
Issue Date: 2401
i
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07.04 Part IV - Insoection Durina the Closure Phase a.
Puroose
~
The purpose of this instruction is to provide guidance for planning and conducting inspections during the period of closure of a LLW disposal facility.
The term " closure," as used herein, encampasses those activities that must be carried out by the licensee after the cessation of waste receipt and disposal operations, to allow the Commission to formally issue a license amendment for disposal-site closure.
In some cases, as specifically allowed or required by license condition, some closure activities may occur for some parts of a facility during active waste receipt and disposal operations at other parts.
Closure is dissimilar from decommissioning in that closure is followed by a period of post-closure observation and maintenance, followed by an institutional control period of 100 years, rather than release for unrestricted use.
l b.
Imolementation i
This program is initiated when the licensee begins implementation of any portion of the approved site-closure plan.
The foundation for planning and scheduling inspections will thus be the closure plan. The criteria for inspections will be license conditions and applicable regulations some of which will directly address closure activities. It is likely that in many cases, portions of the closure plan may be implemented for part of a site while active operations continue elsewhere on site.
In these cases, the appropriate portions of this program should be implemented in conjunction with the operations inspection program.
The closure plan itself, as amended during site operation, pursuant to 10 CFR 61.28, should be reviewed by the regional office to determine if procedural or scheduling modifications are necessary to enable planning of an efficient inspection program. The inspection program continues in effect until the licensee has implemented all elements of the closure plan, and NRC has approved the initiation of the post-closure observation and maintenance phase.
c.
Reaulatory Considerations The information in Table 1 is designed to inspect programs for conformance with the following regulations:
10 CFR Part 20 Standards for Protection against Radiation 10 CFR Part 61 Licensing Requirements for Land Disposal of Radioactive Waste 10 CFR Part 70 Domestic Licensing of Special Nuclear Material d.
Guidance for Use of Inspection Proceduras Durina Closure The IPs indicated in Table 1 (enclosed) are applicable (as noted in comments) to inspections conducted at LLW disposal facilities during facility closure.
The inspection staff can determine the applicable elements of each procedure by reviewing the procedure, the facility license, and the licensee's closure plan.
2401 Issue Date:
12/31/91
07.05 Part V - Inspection Durina the Post-Closure Phase This section reserved for future use.
END I
1
'l i
4 i
Issue Date: 2401 Yw T
TABLE 1 - I::SPECTION PROCEDURES APPLICABLE TD INSPECTION OF A LOW-LEVEL RADIOACTIVE WASTE DISPOSAL FACILITY DURIW2 OPERATIONS AND CLOSURE OPERATIONS PHASE CLOSURE PflASE Anoticability of Proce&re to '
Inspect. Frequen.
j Anoticability of Proce &re to Procedures' Proce &re Title
{
Inspection Freauency ;
Normal Inspection of LLW Disposal Min.
Normat Inspection of a LLW Disposal l Min.
N@r Facility Facility I
30703
- Management Each Each LLW Inspectors should
[ Each Each LLW Inspectors should Entrance / Exit Inspection Inspection s4 scribe to the general e Inspection Inspection s 4 scribe to the general I Principles established in this principles established in Interview fprocedure.
this procedure.
1 36100 10 CFR Part 21 As As Inspectors should be sensitive As As Inspectors should be Inspection at Necessary Necessary to the underlying principle Necessary Necessary sensitive to the underlying Nuclear Power driving this procedure as it principle driving this Reactors may pertain to some LLW proce&re as it may pertain disposal facilities. Future to some LLW disposet guidance is appropriate facilities. Future guidance related to specific types of is appropriate related to disposal facilities.
specific types of disposal facilities.
83822 Radiation Annually Twice per This proce& re is applicable Each Each The inspection staff should Prctection Year in its entirety to inspections Inspection Inspection initially follow the entire of LLW disposal facilities (Frequency may proce&re to determine that
& ring facility operations.
reduce as closure the approved program is being Some discretion should be progresses.)
implemented and to establish exercised in using the the degree of potentist for guidance in section 3.07.
exposures. Subsequent inspections can be taitored I
to concentrate er. Identified areas of risk.
83890 Closecut N/A N/A
] N/A As Necessary This procedure is generally Inspection during implementation applicable toward the end of of Closure Plan the closure phase of !LW and Survey facility life. Specific guidance should be developed in order to use the procedure as a " closure" proce&re rather than a "decomunissioning" proce&re.
1 The guidance will address the facts that 1) most if not att of the RAM will be disposed of on site ano 2) the facility is not being returned to mrestricted use.
4 Issue Date: 12/31/91 T-1 2401 Table 1
TABLE 1 - ICSPECTION PROCEDURES APPLICA8LE' TS INSPECTION OF A LOW-LEVEL RADI0 ACTIVE WASTE DISPOSAL FACILITY DURING OPERATIONS Als CLOSURE OPERATIONS PHASE C1OglRE PHASE s
m j Procedure Title j
Insoection Freesency j AmplicabilityofProceduretol Insoect. Fremaan.
lAnoticabilityofProcessreto l Min.
Normat Insoection of LLW Discosat Min.
Norant Insometion of a LLW Discosal mater Facility Facility I
M850 Inspection of Every Annuelty This procedure has minimal N/A N/A N/A Weste Generator other applicability at a LLW i-Rogsf rements Year disposal facility. It may be useful as e cross check of the seens by which the facility j
operator verifies compliance by clients. It would also be applicebte for inspecting the disposition of on-site generated weste.
I M100 SNM Inspection Annual Annuel This processre is specificetty N/A N/A g N/A et LLW Disposet l applicable to SMN inspections i Facilities i et LLW disposal facilities j
] during operations.
l
=
1 1
I MKXX operations Review Annual Twice per l This procedsre is specifically N/A N/A N/A of a LLW disposet year I applicable to inspections of facility (in l operating LLW disposal deve1opment focitities.
84XXX l Facility Annual Twice per l "in procedure is applicable l N/A N/A l N/A g to inspection of engineering Engineering (in yeer l development) g and construction espects of a l
l l LLW disposal faclLity being l
luplemented during operations.
I I
I I
8650 Solid Weste Annuelty Twice per This procedure has As needed As needed use processre enty if closure r
Management &
year applicability during the results in RAM to be
[
Transportation of inspection of operations et a transported off site. The RAM i LLW disposal facility. The
[ specifics of the licensee's inspector should verify that packaging and transportation the facility operator co, firms activities should be reviewed compliance with transportation to determine which elements l
regsirements by customers.
of Procedure 865 0 will be The procedure should also be g inspected. It would be i
employed if the operator shipsi Il prudent to discuss the RAM offsite for any reeson regulations and the (e.g., shipment of RAM to a 3 inspection procedsre early g
Lab fo analysis).
l lwiththelicensee.
i I
2&O1 Tebte 1 T-2 Issue Date: 12/31/93
taste 1 - INSPECTION PROCtJURES APPLICABLE T3 INSPECTION OF A LOW-LEVEL RADI0 ACTIVE W4STE DISPOSAL FACILITY DURING OPERATIONS AND CLOSURE OPERATIONS PMASE CLOIURE PHASE Procedsresj Procedure Title Inspection Freauerry l Anoticability of ProcedJre to l Inspect. Fremaan.
j Anoticability of Procedare to g
l Min.
Normet Insoection of LLW Discoset Min.
Normal Inspection of a LLW Discosat 1
Facility Facitity 88005 Management Annuel Twice per This procedure is applicebte Annuelty Amuelty Procedare Control.
Organization year in its entirety to inspections In most cases, the closure and Controls of LLW disposet facilities.
License application and Section 3.05, 0/A Programs, license conditions will should be supplemented with specify the procedures for specific guidance applicable clean @ opirations, to LLW fec! titles.
laptementation of disposal of l
residJet radioactive l
materiet, and radiation protection and administrative controls. Inspections should determine ut. ether or not the approved procedure controts are being implemented, and if NMSS and the safety corenittee are properly involved with any changes made to the Procc h e.
I Records Control & Storage.
The focus of this inspection is to determine that records g
g of exposures, surveys, and the nature and quantity of removed contamination are property managed. This independent essessment should be laptemented even if not regaired by license condition.
i Internet Review & Audit.
[
I The first consideration is whether or not the process for tryiependent internal g
reviews and audits is being implemented in accordance with licence conditions. The l
Inspection staff should j
essure itself that the licensee is independently controtting the safety of att operttions even if a program or system is not explicitly defined or required by license condition.
Issue Date: 12/31/91 T-3 2401 Table 1
TABLE 1 - INSPECTIOP PROCEDURES APPLICA8LE TO INSPECTION OF A LOW-LEVEL RADIDACTIVE WASTE DISPCSAL FACILITY DURING OPERATIOh5 AND CLOSURE OPERATIONS PMASE CLO$LRE PNA5E Proc 4res { Procedure Title Inspection Frequency AnoticabilityofProcesareto{
Inspect. Freauen.
- AnDtICabIlity of ProCetharPJ Ngr l
Nin.
Normat Inacection of LLW Disposal Min.
Normal Inspection of a LLW Discosal i
Facility Facitity I
I 88005 Management See Previous Page See Previous Page Annually Annually Safety Committee.
Organization During closure operatione, 4 Controls the safety committee may l
consist of one or two people.
l Even so, all clearup and safety activities should be tracked, recorded and evaluated, and reviewed
{
periodically by the Safety l
Consmittee.
i Quality Assurance Program Amuel Review.
The licensee's closure plan will include manageriet and administrative controls to be used to ensure safe tuplementation. Although an inspection frequency other than annuet may be appropriate, the controts should be inspected often enough to ensure that they are being laplemented consistent with license conditions.
I 1
Annual This procedure l# applicable N/A N/A 88010 operator Training / l Every l N/A Retraining
- Other in its entirety to a LLW l,
fYear disposal facility.
2401 Tabte 1 T4 Issue Date: 12/31/91
TAgtE 1 - INSPECTION PROCEDURES APPLICAglE TO INSPECTION OF A LOW-LEVEL RADIDACTIVE WASTE DISPOSAL FACILITY DURING OPERATIONS AND CLO5URE OPERAfl0NS PMASE CLOSURE PliASE ProcedJresj Procedure Title Inspection FreaJency ; Anoticability of Procedure to ;
Inspect. Freesen.
l Anoticability of Procedure to Mr Min.
Normat inspection of LLW Discosat l Min.
Nortest l Inscoction of a LLW Dianosal-Facititv Facititv 8
I 80025 surveillance Amuel Twice per The concepts presented in this Annust Twice per These procedures are directed Testing year procedure are applicable to year to operations, but the LLW disposal facility underlying concerns may be o. rations. Specific guidance present during closure required to address the operations. Egaipment that 5
difGrant systems encomtered is being used to remove t e LLW disposal facility.
residuet radioective meterial could have timitations that if exceeded could result in disperset of radioactive materiet. Such systems should be monitored and periodicotty tested.
Instruments should be checked l to ensure that established calibration fregsencies have been met. The inspection should include both process and health physics instrumentation.
88035 Radioactive Annual Twice per sections 2.01-2.06 are Annual Twice per sections 2.01-2.07 are Weste Management year generetty applicable to year generally applicable to inspections of LLW disposet inspections of LLW disposal facilities. Section 2.07 facilities in the closure needs to be expended to phase.
provide specific details g
related to the inspection of weste disposet at a facility whose purpose is weste disposet.
section 2.08 does not apply.
88045 Envirorvuental l Annual Twice per This procedure is applicable l Annual Twice per l This procedure is applicabte year in its entirety to the year in its entirety to the Programs f
inspection of LLW disposet inspection of LLW disposal facilities. Furthermore, facilities. Furthennore, i
specific guldence regarding g
specific guldence regarding i
its implementation at such its implementation at such l
[ facilities is needed.
l lfacilitiesisneeded.
Issue Date: 12/31/91 T-5 2401 febte 1
TAgtE 1 - INSPECTION PROCEDURES APPLICAgLE TO INSPECTION OF A LOW-LEVEL RADI0 ACTIVE WASTE DISPOSAL FACILITY DURING OPERATIONS Aam ClogURE OPERATIONS PNASE MORRE PflASE Procedures j Procedure Title inacection Freauency j AnticabilityofProceduretoj Insanct. Freauan.
j &goticability of Procedre to j
thster i
Min.
Normal Insosction of LLW Disomt Min.
Normal Inamaction of a LLW Diacomat 1
Facility Facility i
I I
License conditions wilt The potentist for offsite 88045 8 Erwirorumentet see Previous Page specify offsite monitoring ardl See Previous Page i Programs release ullt be less durins l saapting locations, closure than during fregsencies, and applicable ItimitsonLevelsand operations, but envirorusental lapact is still a concern and concentrations of l sust be inspected.
I radioactivity.
g I
88050 Emergency Annual Twice per
. This procedure is generetty Every two annual gecause of the potential for Planning year l applicable to the inspection years dispersing radioactive of LLW disposal facilities materials, and of sustaining during facility operations.
exposures and injuries durins Inspector discretion is a fire, the fire prevention required regarding the degree and protection program must to which att requirements are be inspected. The frequency f
inspected against. The and depth of inspection are inspector should keep in mind at the inspection staff's
} that the nature and severity discretion and are dependent g
of an emergency at an on the type of facility and l
g operating LLW disposal the methods of closure.
facility is likely to differ from that at a fuel facility.
The rumber of dritts, number of trained individuets ard the nature and amassit of onsite 5 amergency equipment is likely to differ from that expected j at a Fuel Facility.,
Therefore, the inspector is cautioned to use existing l
guidance in this procedure l
advisedly.
2401 Table 1 T-6 Issue Date: 12/31/91
...m
~
e MEMCRANDUM TO:
Frank P. Gillespie. Director Division of Inspections and Support Programs-Office of Nuclear Reactor Regulation FROM:
John T. Greeves. Director Division of Waste Management
/
Office of Nuclear Material Safety and Safeguards
SUBJECT:
REVISION TO INSPECTION MANUAL CHAPTER 2401 l
Attached please find a Document Issuing Form and th revised Inspection Manual Chapter entitled "Near-Surface Low-Level Radioa ive Waste Disposal
/
Facility Inspection Program" Therevisionsweregdebystafffromthe Office of Nuclear Material Safety and Safeguardp/ n conjunction with staff i
from the regional offices, the Office of Nuc]dar Reactor Regulation, the Office of State Programs, and the Office 9 gf General Counsel.
Please update this Manual Chapter in the NRC Inspecti,o/
n Manual.
Because the revisions were developed via a consensus process bet een participating organizations, a
/
discussion of the comments and their resolution is not included.
/
Attachment:
As stated
/
i
Contact:
Tim Harris. NMSS /
415-6613
/
/
DISTRIBUTION:
Central File DWM r/f PUBLIC NMSS'r/f LLDP r/f
~
Regional Administrators BMallet/RII CHosey/RII RScarano/RIV FWenslawski. WCF0 EGarcia. WCFO P aa u c-
- SEE PREVIOUS CONCURRENCE DOCUMENT NAME:
S:\\DWM\\LLDP\\TEH\\TRAN.MC S:\\DWM\\LLDP\\TEH\\DIF.MC i-i S:\\DWM\\LLDP\\TEH\\MC2401.REV l
([
OFC LLDP*
6 LLDP/Jfd6 LLDP M
DWM DWM NAME
-THarris/cv RNeNon JHkkey MFederline JGreeves DATE 1/16/97 1/1/97 1M7/97 1/ /97 1/ /97 0FFICIAL RLLORD LOPY ACNW: YES x
NO Category:
Proprietary or CF Only IG YES x
N0 i
LSS YES _. NO x Delete file after distribution:
Yes x No
., e i
TABLE 1 - INSPECTION PROCEDURES APPLICA8LE T3 INSPECTION OF A LOW-LEVEL RADIDACTIVE WASTE DISPOSAL FACILITY DURING OPERATIONS AIS CLO5UNE OPERAfl0NS PNASE CLORRE PIIASE Proceduresj Procedure Title l
Inacection Freauency AeolicabilitycfProceduretoj Insoect. Frecuen.
l Anoticability of Procedure to shster l
[ Nin.
Morant Inacection of LLW Discosal Nin.
Normal Inacection of a LLW Dianosat
- Facility Facility I
90712 In office Review As As This procedure should be used l As As See guidance for Operations of Written Necessary Necessary conceptually and sparingly at Necessary Necessary Phase Reports of Non-LLW disposet facilities until routine Events an alternate procedure is at Power developed. The concept of follotapbothbyLicenseeandl Reactor inspector on non-routine Facilities events is valid for LLW disposal facilities. Neuever, nature and severity of e
non-routine events needs to be established specifically for LLW disposal facilities.
i l As As i Generic Procedure applicable As As Generic Procedure applicable 92701 Follotap Necessary Necessary to LLW Disposal.
Necessary Necessary to LLW Disposal.
4 I
I 92702 Foltouup on As As Generic Procedure applicable As As Generic Procedure applicable Violations /
Necessary Necessary to LLW Disposal.
Necessary Necessary to LLW Disposal.
Deviations l
I Corfirmatory As As i Generic Procedure applicable As As Generic Procadare applicable 92703 gActionLetters Necessary Necessary to LLW Disposat.
Necessary Necessary to LLW Disposal.
i gGenericProcedureapplicable As As l Generic Procedure applicable V3007 OSHA Interface As As to LLW Disposal.
Necessary Necessary to LLW Dispusal.
Activities Necessary Necessary i
i I
94702 Participation in l As lGenericProcedureapplicable As As As Generic Proceduee applicable Licensee Neetings Necessary Necessary to LLW Disposal.
Necessary Necessary to LLW Disposal.
i I
i l
i P
k i
i t
i t
Issue Date: 12/31/91 T-7 2401 Table 1 i
MEMORANDUM T0:
Frank P. Gillespie, Director Division of Inspections and Support Programs Office of Nuclear Reactor Regulation FROM:
John T. Greeves, Director Division of Waste Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
REVISION TO INSPECTION MANUAL CHAPTER 2401 bachedpleasefindaDocumentIssuingFormandtherevised nspection Manual s
Chapter entitled "Near-Surface low-Level Radioactive WastepIsposal Facility dud 4 0 Inspection Program".
The revisions were made by staff frpm the Office of Nuclear Material Safety and Safeguards in conjunction with staff from the regional effices, the Office of Nuclear Reactor Regulat' ion, the Office of State Programs, and the Office of General Counsel. pleaseupdatethisManual Chapter in the NRC Inspection Manual.
Because the pevisions were developed via a consensus process between participating orgphizations, a discussion of the comments and their resolution is not includ Attachmenti$ As stated
Contact:
Tim Harris, NMSS 415-6613 DISTRIBUTION:
Central File DWM r/f PUS IC NMSS r/f Regional Administrators LLDP r/f N S Dir. Off. r/#
BMallet, RII CHosey, RII RScarano, R FWenslawski, WCF0 EGarcia, WCF0 DOCUMENT NAME:
S:\\DWM\\LLDP\\TEH\\TRAN.MC S:\\DWM\\l/DP\\TEH\\DIF.MC S:\\DWMitLDP\\TEH\\MC2401.REV 0FC LLDP 6
[LLDP LLDP DWM DWM NAME THarrisYc#v/
RNelson JHickey MFederline JGreeves DATE 1/w/97[
1/ /97 1/ /97 1/ /97 1/ /97 0FFICIAL RECORD COPY ACNW: YES x
NO Category:
Proprietary or CF Only IG : YE5 x.
NO LSS : YES
/
N0 x Delete file after distribution:
Yes x No
/
/