ML20212A074
| ML20212A074 | |
| Person / Time | |
|---|---|
| Issue date: | 09/02/1997 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20212A051 | List: |
| References | |
| REF-WM-3 MC-2801, NUDOCS 9710230149 | |
| Download: ML20212A074 (14) | |
Text
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UNITED STATES
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wAswiwatow o.c. ix ooi NRC INSPECTION MANUAL NMSS/ URB MANUAL CHAPTER 2801 URANIUM MILL AND 11e.(2) BYPRODUCT MATERIAL DISPOSAL SITE l
AND FACILITY INSPECTION PROGRAM 2801-01 PURPOSE l
This chapter establishes the safety inspection program for uranium mills and l
11e.(2) byproduct material disposal sites and faci lities (11e.(2) sites) licensed and regulated under 10 CFR Part 40 including mills authorized to take 11e.(2) byproduct material.
The disposal sites include both commercial disposal facilities and sites associated with licensed uranium mills, included in the program are inspection procedures related to all phases of activities:
construction and pre operations, operations, and reclamation / closure. Procedures l
gresented cover those facilities licensed and regulated in their entirety by NRC.
the primary purpose of the inspection program is to obtain sufficient information through observations, personnel interviews, inde)endent measurements, and review of facility records and procedures, to ascerta'n. in a timely manner, whether
/9 facility operations, and radiological and non-radiological programs regulated by
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the U.S. Nuclear Regulatory Commission conform with regulatory requirements and the conditions of the applicable license. As a result, the inspection program determines that uranium mills and 11e.(2) sites are managed throughout their l
entire life cycle in a manner that provides protection from radioactivity to employees, members of the public, and the environment.
2801-02 OBJECTIVES 02.01 To establish general policy and priorities for the inspection of urtnium mills and 11e.(2) byproduct material disposal sites.
02.02 To establish a uniform process for the inspection of uranium mills and l
11e.(2) byproduct material disposal sites.
02.03 To define specific requirements for inspection of uranium mills and l
11e.(2) bypraduct material disposal sites 2801 03 DEFINITIONS 03.01 11e.(2) Bvoroduct Material, as defined in Section 11 of the Atomic Energy l
Act of 1954, as amended, means tailings or waste produced by the extraction of uranium or thorium from any ore processed primarily for its source material
~ content.
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03.02 Closure, as defined in Appendix A to 10 CFR Part 40, means the activities.
after operations, to decontaminate and decommission the buildings and site used Issue Date: 09/02/97 2801 971023o149 971003,
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e s
to produce byproduct materials and reclaim the tailings and/or waste disposal area (s). Also, comonly referred to as decommissioning or reclamation.
03.03 Decommission. as defined in 10 CFR 40.4. means to remove safely from service and reduce residual radioactivity to a level that permits release of the property for unrestricted use and termination of the license.
Would include remediation of the disposal area to be deeded to the Department of Energy.
03.04 Decommissionina Plan, as defined in Appendix A to Part 40, for the purposes of Criterion 6A. means the plan detailing activities to accomplish reclamation of the tailings or waste disposal area in accordance with the technical criteria of Appendix A.
In practice, the Decommissioning Plan usually details the demolition and/or cleanup of the mill buildings and large equipment, tanks. etc.
The plan for stabilization of the tailings and/or waste disposal areas and cleanup of contaminated soil is often referred to as the Reclamation Plan.
03.05 Doeration, for a mill is the process of extracting uranium from ore. For an He.(2) disposal facility, it is receipt and emplacement of M e.(2) byproduct material.
03.06 Performance-Based License (PBL). allows the licensee to make changes to the facility without prior NRC approval if certain conditions are met.
These conditions are specified in the performance based license condition contained in the PBL. Consistent with the regulatory reduction effort initiated by the staff in 1994, the staff is currently issuing all new and renewed operating licenses as performance-based.
2801 04 PROGRAM APPLICABILITY This program has been developed to respond to needs for inspection procedures l related to construction, pre operation, operations, and reclamation / closure for sites licensed by NRC.
Where lle.(2) byproduct material disposal sites are operating under Agreement State regulation, it is expected that responsibility for regulation and inspection activities at those sites will continue to reside with the Agreement States. It is noted that existing inspection procedures from other NRC programs can be applied in full or in part, to many aspects of uranium mill and 11c.(2) byproduct material disposal site inspections, and that additional inspection procedures specific to disposal technology, and on-site activity can be developed and employed incrementally, as needed.
Tables 1 and l 2 provide a listing of procedures that are currently available and include 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 site activity and to the performance of the licensee.
2801 05 PROGRAM DESCRIPTION 05.01 General.
The insaection program for sites specifically licensed for 11e.(2) byproduct materia' disposal and for uranium mills has been divided into three parts. The parts are designed to be responsive to the various inspection needs during the different phases of facility life: construction / pre-operations.
operations, and reclamation / closure. Each phase of the inspection program varies with respect to applicable inspection procedures, inspection frequency, and degree to which a given procedure may be applied. The inspection programs for 2801 Issue Date: 09/02/97 i
o s
l each phase are discussed in narrative form in Section 2801 08. Tables 1 and 2 present information for the pre operations, operations, and closure phases.
O This chapter identifies requirements-for the inspection of the health, safety, and environmental aspects of licensee activities.
The inspector should be completely familiar with the current regulatory requirements and commitments associated with the license. These include the comparable aarts of title 10.
U.S. Code of Federal Regulations, the license application, apiicable guides, and other codes to which licensees may commit by reference. In t1e case that Nuclear Regulatory Commission guidance documents are updated after a license or amendment is issued, the licensee is generally only committed to follow the original guidance. Thus, the particular revision of the guidance to which the licensee has been committed is of importance.
The sco>e of inspection procedures (IPs). taken as a whole. is not intended to be limi".ed to only those elements discussed M1 the procedures. The descriptions and examples contained in the procedures are provided primarily for illustrative purposes, as examples of things that should be examined.
Examination of other safety significant activities not expressed or inplied in a procedure is left to the inspector's judgment. in consideration of the relative degree of safety risk I
posed by the subject activity.
The environmental aspects of the activities relate to those license conditions that have been olaced on the Operation by the Nuclear Regulatory Comission as a result of rev9ews conduct'J under the authority of the National Environmental health and safety inspections.pections would be conducted at the same time as Policy Act.
Environmental ins l
05.02 Adiustments.
The program provides regional offices the flexibility to O-adjust the frequencies of inspections, within the various program areas, based on an evaluation of the inspection findings and enforcement experience with a i
particular licensee. Alternate frequencies of inspection for various 3rocedures are specified in Tables 1 and 2.
The lower frequency specified is t1e minimum frequency to which the inspection may be reduced by the regional office.
The higher frequency of inspection specified fo" the procedure shall be the normol inspection frequency for the program. Thera is no maximum frequency expressed in Tables 1 and 2.
It is expected that any level of effort (i.e., frequency of inspection) above that specified as the normal frequency would be established at a level commensurate with whatever is needed to resolve identified problems and their importance to safety.
05,03 Performance Based License. At sites operating under a PBL. the inspector should ensure that changes authorized under the PBL do not erode the basis for NRC's licensing decision.
In evaluating the changes-made to the facility, i
inspectors should recognize that the reviews conducted by the licensee's i
evaluation panel are not reviews of safety nor environmental acceptability.
Rather, the evaluation panel reviews under the PBL are a determination of whether the proposed changes require prior NRC review, ' Licensees are obligated to ensure that any change considered to the facility should be safe and environmentally acceptable.
Then the evaluation panel is responsible for determining if the proposed changes need to be submitted to NRC. There will be circumstances where the licensee finds that the proposed changes are acceptable: however, the change may still require an NRC review.
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As a general set of guidelines, those changes that will require NRC review include changes to:
Issue Date: 09/02/97 2801
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1)
Those things described in the application or subsequent submittals that would reduce the safety basis of the facility:
2)
Procedures conditioned in the license or outlined, summarized, or included in the application: and 3)
Things specifically conditioned in the license.
Additional guidance on the inspection of PBL activities undertaken by licensees can be found in IP 37001. "10 CFR 50.59 Safety Evaluation Program.
Although this IP is applicable to 10 CFR Part 50 licenses, the basic philosophy and inspection process can be adopted to PBLs since the PBL concept was derived from 10 CFR 50.59.
2801-06 REVIEW 0F EVENTS All inspections should include, as appropriate, a review of licensee reportable and non reportable events that involve contamit e' lon. releases, equipment 6difunctions, 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.
In the case of reports received by NRC involving radiological health and safety. the region is responsible for determining the seriousness of the reported incident and whether an immediate reactive inspection is necessary. When such reports involve programmatic areas normally addressed by Headquarters programs, the region shall confer with Headquarters, to jointly determine what response. if any. is recuired including whether the NRC response should include personnel from the Heaciquarters.
Non reportable events are those determined by the licensee to fall outside criteria requiring them to be reported to NRC, Although. these events are not reported formally to NRC. licensees occasionally may contact regional staff informally to describe the event and explain it is not required to ae reported.
Still, licensees are of ten required, through license conditions or commitments, to maintain records of non reportable events onsite.
Non reportable events should be examined during ins)ections, to determine appropriate corrective actions or follow-up to precluce recurrence:
these events may involve safety issues that should be followed up by the Occupational Safety and Health Administration. Mine Safety and Health Administration, and existing or potential operational difficulties not otherwise reportable, such as biointrusion in disposal units, erosion or sloughing of trench walls, or uncontrolled wind erosion. Additional guidance on non-reportable events is contained in individual inspection procedures.
2801 07 INDEPENDENT INSPECTION EFFORT Each inspector should spend some onsite inspection time performing independent inspection effort.
The amount of time spent should be commensurate with the level of risk, the complexity of the facility, and the degree to which inspection resources have already been comitted to significant safety and environmental issues that have already been identified in the facility.
This effort may include more in-depth inspection in selected technical areas than that normally called for by the formal procedures. The major objective of this effort should be to gain increased understanding of potential safety and environmental hazards of particular activities of interest, such as those that may have been involved in a series of recent non reportable events.
2801 Issue Date: 09/02/97
e Comparison of the findings from this type of effort with the licensee's findings may uncover unresolved safety and environmental questions, improper maintenance
)ractices, and other problems that may not be discovered through other means.
)iscovered hazards outside the scope of Nuclear Regulatory Commission IPs or O
Nuclear Regulatory Comission regulatory authority should be conveyed to the licensee at the exit interview (as set forth in IP 88002), described to regional management during debriefing. and included in the formal inspection report.
In cases where regulatory jurisdiction for the observed potential hazard is clear, the finding shall be reported to the responsible agency for action (i.e., State.
Mine Safety and Health Administration, Environmental Protection Agency. etc.).
In all cases where the finding involves a potential effect on radiological health and safety, the finding shall be followed during subsequent inspections until the licensee has addressed the concern.
However, special follow up inspections solely on the basis of Mine Safety and Health Administration issues are not required unless the potential hazard also directly involves radiological health or safety.
2801-08 RANDOM SELECTION AND EXAMINATION OF RECORDS Many of the inspection procedures normally require the inspector to select certain types of records at random for closer examination.
However, random selection 1s not always required. The inspector may seek out certain records of interest when so inclined.
Random selection is a technique that recognizes the fact that the Nuclear Regulatory Commission does not have the resources to inspect every detail of plant. The Nuclear Regulatory Commission inspection program is predicated on the fact that the licensee is ultimately responsible for the safety of the licensed facility, Random selection, where specified in a orocedure, allows the inspector
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to sample specific aspects of the licensee's safe ~y and environmental program to be studied at a level of detail that would be impractical if exercised uniformly across the entire safety program.
When random selection in a procedure is specified, the inspector should select records corresponding to activities that relate to the Nuclear Regulatory Commission's regulatory role, such as effluent monitoring records or ground water restoration records. Also included should be records required to be retained for later decommissioning.
To reasonably verify that activities are conducted safely and in an environmen-tally acceptable manner, the ins)ector also should randomly select personnel for interviews. The extent and dept 1 to which random selections or examinations are needed are left to the ins)ector's judgment, depending on how satisfied the inspector is that operational and safety safeguards procedures are being followed uniformly.
2801-09 REGIONAL RESPONSIBILITY FOR LICENSEES The responsibility for inspection resides with the regional office in which 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 T
offices involved. If a permanent transfer of total inspection responsibility is
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involved, the affected regional offices should ensure that the ap)ropriate changes are made to the computerized license data file by informing tie Office Issue Date: 09/02/97
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4 of Nuclear Material Safety and Safeguards 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 4
budgeting and allocating resources.
i 2801 10 INSPECTION DURING VARIOUS PHASES OF FACILITY LIFE 10.01 Part 1 - InsDection Durina the Construction and Pre-00erational Phase a.
Purpose The purpose of this instruction is to provide guidance for planning and conducting inspections during the construction / pre-operations phase of facility life.
Activities encom)assed during the construc-l tion / pre operations phase of a uranium mi'l or disposal site include disposal trene.h construction: liner placement: observation and verifica-tion of placement and compaction of cover materials; equipment use: fire protection program (equipment and training procedures):
and compliance with applicable con;truction specifications requirements in accordance with ap)licable management controls and quality assurance procedures.
of a mill that has been on stand-Activit'es encompassed during start up/ function and safety, by, would include equipment operation b.
Lmolementation.
This inspection program begins on issuance of the icense, or license amendment to restart the mill, and continues until the site begins active receipt and disposal of waste, or processing of ore at a mill. Situations may arise in which inspection requirements specified are-operational phase.pply concurrently with those specified here for the for other phases may a For example, certain requirements contained under
) arts I and 11 may appl in the construction, pre operational checks, and start-up of a major mogification to the site.
l The uranium mill or 11e.(2) by)roduct material disposal site pre-operational inspection )rogram is cefined by selection from among the list of procedures in Table
. The areas covered during an inspection need not be limited only to those elements discussed in the procedures, but may need to include examination of other activities not expressly delineated or covered in existing procedures, in such cases, the inspector must exercise good professional judgment in modifying the inspection and in identifying to the program office the possible need for development of supplemental guidance.
Conformance with the 3rinciples of reducing radiation exposure to as low as is reasonably ac11evable (ALARA) should be a principal concern at all times.
For the normal inspection frequency, each procedure should be executed for each specific frequency.
In practice, part or all of the procedure element wy need to be examined during each inspection visit.
l During inspections, emphasis should be placed on physical examinations, observation of conduct of operations. independent measurements, and personnel interviews.
Attention should be cirected toward the avail-ability of written procedures, the degree to which they are being be concentrated on areas of perceived concern (personnel.
followed, and the state of training of on-site Effort should highest taiety risk) and site activities performed since the last inspection.
Review of records should 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 2801 Issue Date: 09/02/97
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 O9 the inspector's judgement.
c.
Reaulatory Considerations. The inso' or should be familiar with current license requirementt previous 0
. tion reports: applicable codes.
standards and guides: and the fo ving regulations-10 CFR Part 19.
" Notices. Instruct ns, and Reports to Workers: Inspectivo and Investigations."
j*
" Standards for Protection against Radiation."
" Reporting of Defects and Noncompliance "
"Doaestic Licensing of Source Material."
" Commission Inspection of Land Disposal Facilities (Commercial Disposal Only)."
d.
Guidance for Use of Insoection Procedures durina the Pre-00erational
>hase. The inspection procedures indicated in Table 1 for the construc-tion / pre o)erations phase are-applicable to inspections conducted at uranium m'lls and 11e.(2) bypaoduct material disposal sites during l
construction / pre operations.
The inspection staff can determine the applicable elements of each procedure by reviewing the procedure, the facility license, and reports of previous inspections.
10.02 Part II Insoection durina the Ooerations Phase a.
Purcose.
The purpose of this instruction is to provide guidance for planning r.nd conducting inspections during the operations )hase of the facility.
Activities encompassed during the operations plase include receipt and handling of incoming 11e.(2) b processing of ore and packaging of yellowcake:yproduct material, or the emplacement of the 11e.(2) -
byproduct material for disposal: radiation safety and environmental monitoring activities: and records management.
b.
Imolementation.
This inspection program begins on issuance of the f acility license, or a license amendment to allow a uranium mill on stand-by to restart, and continues until the facility ceases active receipt of materials and/or disposal of waste. Situations may arise in which inspec-tion requirements specified for other phases may apply concurrently with those specified here for the operations phase.
For example, certain requirements contained under Parts I and III may apply in the operations, or start-up of a facility.
The uranium mill or 11e.(2) byproduct material disposal site operations l
inspection program is defined by selection from among the list of procedures in Table 2.
The areas ccvered during an inspection need not be limited only to those elements discussed in the procedures, but may need to include examination of other activities not expressly delineated or covered'in existing procedures.
In such cases, the inspector must exercise good professional judgment in modifying the inspection and in O
identifying to the program office the possible need for development of V
supplemental guidance. Conformance with the principles of ALARA should be a principal concern at all times.
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For the normal inspection frequency, each procedure should be executed for each specific frequency, in practice, part or all of the procedure element may necd to be examined during each inspection visit.
Emphasis should be placed on physical examinations, observation of conduct of o>erations, independent measurements, and personnel interviews. Attention siould be directed toward the availability of written procedures, the degree to which they are being followed, and the state of training of on-site personnel.
Effort should be concentrated on areas of perceived concern (highest safety risk) and licensee activities conducted since the last inspection.
Review of records should otherwise involve only a sampling of those records im>ortant to safety of personnel and the general public.
For example, i' the organizational structure has not changed with respect to personnel and assigned functions and responsibilities, the inspector should not puisue 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 inspector's judgment, c.
Reaulatory Considerations, The inspector should be familiar with current license requirements: previous inspection reports; applicable codes, s w?dards and guides: and the following regulations:
10 C R Part 19.
" Notices, Instructions, and Reports to Workers:
Inspection and Investigations."
" Standards for Protection against Radiation."
Reporting of Defects and Noncompliance,"
" Domestic Licensing of Source Material."
10 CFR Port 61.80,
" Maintenance of Records Reports, and Transfers."
" Commission Inspection of Land Disposal Facilities (Commercial Disposal Only) d.
Guidance for Use of Insoettion Procedures Durina 00erations.
The inspection procedures indicated in Table 2 for the Operations Phase are applicable to ins)ections conducted at uranium mills and 11e,(2) byproduct material disposa' sites, including mills authorized for disposal of in-situ leach facility waste and other 11e.(2) byproduct material.
The inspection staff can determine the applicable elements of each procedure by reviewing the procedure, the facility license, and reports of previous inspections.
Inspectors should also refer to a)plicable portions of Regul3 tory Guides 4.14, 8.22, and 8.30, for details.
10.03 Part 111 - Insoection Durina the Reclamation / Closure Phase, a.
Puroose.
The purpose of this instruction is to provide guidance for planning and conducting inspections during the period of reclama-tion / closure of a uranium mill site or 11e.(2) byaroduct material disposal site.
In some cases, as specifically allowec or required by license condition, some closure activities may occur for some parts of a facility during the operations phase. The purpose of the inspection is to verify, by field observations and review of licensee records that decontamination of soil, sediment, surface waters, and ground water, as well as 2801 Issue Date: 09/02/97
reclamation of the disposal cell, are being performed in accordance with NRC-approved plans.
O b.
Imolemontation.
This program is initiated when the licensee begins implementation of any portion of the approved reclamation / decommissioning
>1an. The foundation for planning and scheduling inspections will thus
)e the licensee's pro in implementing the reclamation plan (construction schedule).gressThe criteria for inspections will be license conditions and applicable regulations some of which will directly address reclamation activities.
In many cases, portions of the reclamation 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 reclamation plan itself, as amended during site operation and approved by NRC, 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 reclamation plan, the license is terminated, and the title l
to the land is transferred to the U.S. Department of Energy for long term surveillance and maintenance.
The 11e.(2) byproduct material disposal site or uranium mill reclamation and decommissioning inspection program is also defined by selection from among the list of procedures in Table 2.
The areas covered during an l
Inspection need not be limited only to those elements discussed in the l
procedures, but may need to include examination of other activities not expressly delineated or covered in existing procedures.
In such cases.
the inspector must exercise good professional judgment in modifying the O
inspection and in identifying to tne development of supplemental guidance. program office the possible need for Q
Conformance with the principles of ALARA should be a principal concern at all times.
For inspections during site remediation/ closure (includes licensee performing cleanup verification measurements), each procedure should be executed for each specific frequency, in
)ractice, part or all of the arocedure element may need to be examined curing each inspection visit.
Emphasis should be placed on physical examinations observation of conduct of operations, limited inde>endent mmv Mts (e.9.. s) lit samples), and personnel interviews.
At;ention ava _ ue directed ;oward the avail-6bility of the licensee's written procedures, the degree to which they are being followed, and the state of training of on-site personnel. Effort should be concentrated on areas of perceived concern. Discretion in such areas is left to the inspector's judgment in consultation with Headquarters staff (project tanager technical reviewers).
A confirmatory survey may be performed as an audit of the licensee's final survey results. to independently confirm that the report is ac(urate and representative of site conditions. but is only necessary if there is significant doubt regarding the licensee's final survey results.
A confirmatory survey will be performed if one or more of the following apply to decommissioning of the site:
- 1) repeated violations, with the inclusion of a " management paragraph": 2) issuance of an order: 3) failure to take short-term corrective measures: 4) event requiring a reactive inspection: 5) limited financial and technical viability of the licensee:
3 and 6) significant problems identified with the reclamation plan or final (V
survey data.
Issue Date: 09/02/97 7801 a
a c.
Reaulatory Considerations.
The inspector should be especiall," familiar with current license requirements: previous inspection reports: applicable codes, standards and guides: and the following regulations:
" Standards for Protection against Radiation."'
" Domestic Licensing of Suarce Material."
" Commission Inspection of Land Disposal Facilities (Commercial Disposal Only)."
d.
Guidance for Use of Insoection Procedures Durina Closure The inspection procedures indicated in 1able 2 are applicable, as noted, to inspections
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conducted at 11e.(2) byproduct material disposal sites, or uranium mills during closure.
The most applicable procedure is under development and will be entitled. "Decouniss1oning Inspection Procedure for Uranium Mill Sites." The inspection staff can determine the applicable elements of each prcceJure by reviewing the procedure, the facility license, and the licensee's closure (reclamation) plan.
El1D Attachments:
Table 1. Inspection Procedures Ap)licable to Pre Operational Inspection of a Uranium Hill or 11e.(2) 3yproduct Material Disposal Site Table 2. Inspection Procedures Applicable to inspection of a Uranium Mill or 11e.(2) Byproduct Material Disposal Site during Operations and Closure l
O l
2801 Issue Date: 09/02/97 1
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TABLE 1
- Ik$PECil0N PROCEDURES APPLICABLE 10 PRE 0PERAflDNAL lhlPECilDN OF A URANIUM MILL OR 110.(2) BYPRCDUCT MAltRI AL Di$POSAL Slf t Procedare Procedure title inspection freq;ency Applicability of Procedure to the Nweet Minlan hormal Inspection 3*703 Menegement Entrance /talt toch toch the generet principles of the procedure Interview Inspection Inspection are omttcoble.
36100 10 CFR Part 21 Inspection As As inspectors should be sensitive to the et Nuclear Power Necessary hecessary underlying principle driving this Reactors procedure.
37001 10 CFR $0.$9 Safety As As As applicable to inplementation of twelustion Program hecessary Wecessary performance *besed license (PBL) since the PBL concept was derived f rom 10 CFR 50.$9.
88001 Construction Review Annual Key Construction Applicable to the inspection of Milestones engineering and construction espects.
g 88005 Management Orgenlaation Annual Annuet inspector should s escribe to the generet V) and Construction principles estebtished in this l
g procedure.
88045 Environmentet Protection Annual fulce per License conditions will specify of f site Year monitoring and senplIng locations, frequencies, and applicable limits on levels and concentrations of radioactivity.
92701 Follow-up As As Generic procedure applicable.
Necesenry hecestery 92702 Follow-up on As As Generic procedure applicable.
Vlotet tons /Devletions Wecessary Necessary 92703 Confirmatory Action As As Generic procedare applicable.
Letters kecessary kecessary XXXXX in Situ Leech (!$L)
Annual Twice per Amlicable to the operating espects facilities Programs Year generic to urentun ellts and in situ teach facilities.
A
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09/02/97 T1-1 2801
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_m TA8tE 2 - ImSPECTION PROCEDURES APPLI
) IWSPECTION OF A URAmitM CILL SITE OR N
112.(2) BYPRODUCT MATE 21AL 1 SITE DUR!aG OPERATIONS AND CLCSURE OPERAftDNS PIIASE CLOSURE PMASE Procethre Procedare Title Inspection Frequency Applicability of the Inspection Frespaency Applicability of the a
musber minim m monent Procethre minimum Normal Procetbre i
30703 management Each Each The generet principles As As The generat principles Entrance / Exit Inspection Inspection established in this procethre necessary necesseqr established in this Interview should be followed.
procedare should be fottowed.
s 37001 10 CFR 50.59 Safety As As As applicable to implementation As As As applicable to Evaluation Program Necessary necessary of performance-based license pacessary necessary isptementation of I
(PSL) since the PSL concept performance-based license was derived from 10 CFR 50.59.
(Pet) since the PSL concept j
was derived from i
}
l 83822 Radiation Annual Twice per This procedJr= is applicable in Each Each Initially, the entire l
Protection Year its entirety.
Inspectiers Inspection procethre should be followed to determine that the approved program is being implemented e,d to establish the potential for exposures.
{
Sabsequent inspections can be tailored to concentrate on identified areas of risk.
J I
83890 Closecut Inspection N/A N/A N/A Finst inspection use this procedure in f
and Survey conjunction with the new decosamissioning procedure.
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8674D Inspection of Amuel Twice per The procedure should be used to As As use the procedJre only if l
Transoortation Year confirm compliance for necessary necessary source or byprothct meterlat Activities yellowcake or byprothct is transported off-site.
l shipments.
l 88001 (W Site Annuel Twice per This procedare is for the As needed As needed Key activities to be l
Construction Yeer engineering and construction inspected are construction f
aspects of a disposal cett and of the radan berrier and the j
implementation respaires the erosion protection toyer of assistance of Me=*y e ters the disposal cett.
4 staff.
f:
88005 Manageaient Annuel Annual This procethre is generetty Annual Annuel Inspections should determine organization and applicable. Section 03.05, if the approved processres l
Controts O/A Progress should be ar* being implesmented, and j
supplemented with guidance (if spess is property involved (e.g., mMSS Marwawwe).
with any changes made to a
[
procedsre.
88010 Operator Every Other Annual This procedure is applicable to Every Other Amust Ttis procedre is applicable j
Training / Retraining Yeer mit t and disposat sites.
Yeer to mitt eruf disposat sites.
88020 operations Review Annuel Twice per some sections of this procedure Annuel See Sections 02.01b, t
I Year aspty.
" Inspection of Tsiiings Dam" and cz.c2, -nouse*eepin c.
r 1
Issue Date: 09/02/97 T2-1 2801 1
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TABLE 2 - INSPECTION PROCEDURES APPLICABLE TO INSPECTION OF A URANtuM CTLL StTE OR 112.(2) BYPseuCT MATCI AL CISPOSAL SITE DURING OPERATIONS AND CLOSURE OPERATIONS PHASE CLOSURE PuASE Procedure Procedure Titie Inspection Frequmcy Appticabitity of the Inspection FregJency Amticabitity of the Ntaber minimum Normat Procedsre minism.s=
monmat Procedare 88025 Maintenance are Annust Twice per This procedJre is for reactors, Arruet Twice per This procedure amticetde Surveillance.
Year but some generetty a p licable Year enty to.,. er utility Testire points.
services and generat maintenance.
88035 Radioactive Weste Amust Twice per Sections 02.01 to 02.06 are Anruel Twice per Sections 02.01 to 02.07 of management tear generatty applicable. The Yeer this procedJre are generetty procedure needs to be updated applicable.
to refer to sections of new 10 CFR Part 23.
8t%5 Envirorunental Annual Twice per This procedure is applicable in Annual Twice per This procedare is applicable Protection Year its entirety.
Year in its entirety. The potential for off-site releases will be less during etosure, but aust stitt be insoccted.
88050 Emergency Every 2 Every 2 This procedJre is generally Every 2 Every 2 The fire protection and Prepare @ess years years agoticable. Discretion is years years prevention program must be required regarding the degree inspected. The fregaency to which att regJirements are ard depth of inspectier, inspected against as the depend on the type of severity of an emergency at a facility and the methods of disposat site is much tess rectamation.
than that at an operating sitt, or other fuel cycle facilities.
88104 Deconomissioning N/A N/A N/A Every Every Portions of th!s procedJre Inspection Inspection Inspection are applicable to sitt and Procedure for Fuet disposal sites, but IP 88KKI Cycle Facilities is specif te for uranium sitt sites.
92701 Follow-w As As This precedsre is generally As As This p m edure is generetty Necessary Necessary aceticable.
Nece sary Necessary appli d te.
i 2
Issue Date:
/97.
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