ML13322B227

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G. Suber Memo Surry Power Station Trip Report for October 21-25, 2013
ML13322B227
Person / Time
Site: Surry  Dominion icon.png
Issue date: 11/20/2013
From: Don Lowman
NRC/FSME/DWMEP/EPPAD/LLWD
To: Gregory Suber
NRC/FSME/DWMEP/EPPAD/LLWD
Lowman D
References
Download: ML13322B227 (3)


Text

November 20, 2013 MEMORANDUM TO: Gregory Suber, Chief Low-Level Waste Branch Environmental Protection and Performance Assessment Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs FROM: Donald Lowman, Project Manager /RA/

Low-Level Waste Branch Environmental Protection and Performance Assessment Directorate Division of Waste Management and Environmental Protection Office of Federal and State Materials and Environmental Management Programs

SUBJECT:

OCTOBER 21-25, 2013, TRIP REPORT: SURRY POWER STATION On October 21-25, 2013, I shadowed the U.S. Nuclear Regulatory Commissions (NRC)

Region II inspectors Ruben Hamilton and Robert Kellner during their inspection of Surry Power Stations Health Physics and Radioactive Waste Management Programs. The purpose of the trip was to: (1) gain insight on use of scaling factors in radioactive waste processing to support revisions to NUREG/BR-0204 Instructions for Completing NRCs Uniform Low-Level Radioactive Waste Manifest; (2) determine the effect of revisions to the Branch Technical Position (BTP) on Concentration Averaging and Encapsulation on nuclear plants; and (3) to complete one of my On-the-Job Activities (OJT-4) per the Low-Level Waste Project Manager Qualification Journal. Below are several activities which I observed:

  • Entrance interview with plant management
  • Meeting with plant Health Physics and Radwaste management
  • Tour of Auxiliary Building
  • Tour of Radwaste Facility
  • Tour of Independent Spent Fuel Storage Installation (ISFSI)
  • Review of radioactive waste shipping manifests
  • Discussions on classifying radioactive waste with Radioactive Material Control technical staff CONTACT: Donald Lowman, FSME/DWMEP (301) 415-5452

G. Suber Below are my observations:

  • Inspection Procedure Procedure IP-71124.08 was used during the inspection of Surrys radioactive waste management program. Section 02.04a states:

Verify that the licensees use of scaling factors and calculations to account for difficult-to-measure radionuclides is technically sound and based on current 10 CFR Part 61 analysis.

My observations led me to believe that inspectors may not grasp the concepts of scaling factors used in waste classification. I met with Steve Garry, Senior Health Physicist, who is in the branch that manages the inspection procedures. Steve provided me a copy of the Training and Qualification Journal to review to verify whether training in scaling factors/waste classification was adequately covered. Steve also suggested I speak with Ron Nimitz in Region I as he is very familiar with scaling factors/waste classification and inspection of these programs.

ACTION ITEM: I will review the training manual and talk with Mr. Nimitz; if the inspection procedure and training is found to be deficient, I will recommend appropriate changes.

  • Almost all utilities use WMG, Inc.s RADMAN computer software to classify their waste.

In 1983, the NRC approved a Topical Report for use of the software. There is also HPPOS-288 Acceptance for Referencing, RADMAN Topical Report which states that approval of the Topical Report is based on the condition that if NRC criteria or regulation change, WMG, Inc. will be expected to revise or resubmit their respective documentation or submit justification that RADMAN continues to meet NRC conclusions found in the Topical Report. There have been many updates to RADMAN since it received NRC approval and it will need to be revised again based on changes to the BTP, Part 61, and NUREG/BR-0204.

ACTION ITEM: I will contact vendor auditing to ensure they are aware that revisions to the BTP, Part 61, and NUREG/BR-0204 will require changes to RADMAN.

Please let me know if you have any questions.

G. Suber Below are my observations:

  • Inspection Procedure Procedure IP-71124.08 was used during the inspection of Surrys radioactive waste management program. Section 02.04a states:

Verify that the licensees use of scaling factors and calculations to account for difficult-to-measure radionuclides is technically sound and based on current 10 CFR Part 61 analysis.

My observations led me to believe that inspectors may not grasp the concepts of scaling factors used in waste classification. I met with Steve Garry, Senior Health Physicist, who is in the branch that manages the inspection procedures. Steve provided me a copy of the Training and Qualification Journal to review to verify whether training in scaling factors/waste classification was adequately covered. Steve also suggested I speak with Ron Nimitz in Region I as he is very familiar with scaling factors/waste classification and inspection of these programs.

ACTION ITEM: I will review the training manual and talk with Mr. Nimitz; if the inspection procedure and training is found to be deficient, I will recommend appropriate changes.

  • Almost all utilities use WMG, Inc.s RADMAN computer software to classify their waste.

In 1983, the NRC approved a Topical Report for use of the software. There is also HPPOS-288 Acceptance for Referencing, RADMAN Topical Report which states that approval of the Topical Report is based on the condition that if NRC criteria or regulation change, WMG, Inc. will be expected to revise or resubmit their respective documentation or submit justification that RADMAN continues to meet NRC conclusions found in the Topical Report. There have been many updates to RADMAN since it received NRC approval and it will need to be revised again based on changes to the BTP, Part 61, and NUREG/BR-0204.

ACTION ITEM: I will contact vendor auditing to ensure they are aware that revisions to the BTP, Part 61, and NUREG/BR-0204 will require changes to RADMAN.

Please let me know if you have any questions.

ML13322B227 OFC DWMEP:PM DWMEP:LA DWMEP:PM NAME DLowman TMoon DLowman DATE 11/19/13 11/19/13 11/20/13 OFFICIAL RECORD COPY