02.01 |
Inspection Planning and In-Office Inspection |
|
a. |
Review the most current Radiological
Effluent Release Report to verify that the
program was implemented as described in
RETS/ODCM. Review the report for
significant changes to the ODCM and to
radioactive waste system design and
operation. Determine whether the changes
to the ODCM were made in accordance
with Regulatory Guide 1.109 and NUREG-0133 and were technically justified and
documented (The licensee's documents
containing the technical justifications
should be reviewed during the onsite
inspection). Determine whether the
modifications made to radioactive waste
system design and operation changed the
dose consequence to the public. Verify that
technical and/or 10 CFR 50.59 reviews
were performed when required. Determine
whether radioactive liquid and gaseous
effluent radiation monitor setpoint
calculation methodology changed since
completion of the modifications. |
|
b. |
Determine if anomalous results reported in
the current Radiological Effluent Release
Report were adequately resolved. |
|
c. |
Review RETS/ODCM to identify the
effluent radiation monitoring systems and
its flow measurement devices. Review any
effluent radiological occurrence
performance indicator incidents for onsite
follow-up. Review licensee self
assessments, audits, and licensee event
reports that involved unanticipated offsite
releases of radioactive material. |
|
d. |
Review the Final Safety Analysis Report
(FSAR) description of all radioactive waste
systems. |
02.02 |
Onsite Inspection |
|
a. |
Walk-down the major components of the
gaseous and liquid release systems (e.g.,
radiation and flow monitors, demineralizers
and filters, tanks, and vessels) to observe
current system configuration with respect
to the description in the FSAR, ongoing
activities, and equipment material
condition. |
|
b. |
When possible, observe the routine
processing (including sample collection
and analysis) and release of radioactive
liquid waste to verify that appropriate
treatment equipment is used and that
radioactive liquid waste is processed and
released in accordance with procedure
requirements. If possible, observe the
sampling and compositing of liquid
effluent samples. In lieu of direct
observation, review several radioactive
liquid waste release permits, including the
projected doses to members of the public. |
|
c. |
When possible, observe the routine
processing (including sample collection
and analysis) and release of radioactive
gaseous effluent to verify that appropriate
treatment equipment is used and that the
radioactive gaseous effluent is processed
and released in accordance with
RETS/ODCM requirements. In lieu of
direct observation, review several
radioactive gaseous effluent release
permits, including the projected doses to
members of the public. |
|
d. |
Review the records of any abnormal
releases or releases made with inoperable
effluent radiation monitors. Review the
licensee's actions for these releases to
ensure an adequate defense-in-depth was
maintained against an unmonitored,
unanticipated release of radioactive
material to the environment. For example,
were appropriate compensatory sampling
and radiological analyses conducted at the
RETS/ODCM required frequency when
effluent monitors were declared out-of-service? For unmonitored releases, did the
licensee perform an evaluation of the type
and amount of radioactive material that was
released and the associated projected doses
to members of the public? |
|
e. |
Review changes made by the licensee to
the ODCM as well as to the liquid or
gaseous radioactive waste system design,
procedures, or operation since the last
inspection. For each system modification
and each ODCM revision that impacted
effluent monitoring or release controls,
review the licensee's technical justification
and determine whether the changes affect
the licensee's ability to maintain effluents
ALARA and whether changes made to
monitoring instrumentation resulted in a
non-representative monitoring of effluents.
For significant changes (factor of 5) to dose
values reported in the Radiological Effluent
Release Report from the previous report,
evaluate the factors which may have
resulted in the change. If the change was
not influenced by an operational issue (e.g.,
fuel integrity, extended outage, or major
decontamination efforts), independently
assess the licensee's offsite dose
calculations by using the NRC PC-DOSE
computer code (agreement should be within
a factor of 2) or by reviewing the
verification and validation records for the
licensee's dose calculation. |
|
f. |
Review a selection of monthly, quarterly,
and annual dose calculations to ensure that
the licensee has properly calculated the
offsite dose from radiological effluent
releases and to determine if any annual
TS/ODCM (i.e., Appendix I to 10 CFR Part
50 values) were exceeded and, if
appropriate, issued a PI report if any
quarterly values were exceeded. |
|
g. |
Review air cleaning system surveillance
test results or licensee specific
methodology to ensure that the system is
operating within the licensee's acceptance
criteria. Review surveillance test results or
methodology the licensee uses to determine
the stack and vent flow rates. Verify that
the flow rates are consistent with
RETS/ODCM or FSAR values. NOTE:
Differences between assumed and actual
stack and vent flow rates will affect the
methodology used to calculate projected
doses to members of the public as required
by the ODCM. |
|
h. |
Review records of instrument calibrations
performed since the last inspection for each
point of discharge effluent radiation
monitor and flow measurement device.
Review any completed system
modifications and the current effluent
radiation monitor alarm setpoint value for
agreement with RETS/ODCM
requirements. |
|
i. |
Review calibration records of radiation
measurement (i.e.,counting room)
instrumentation associated with effluent
monitoring and release activities. Review
quality control records for the radiation
measurement instruments. Look for
indications of degraded instrument
performance and at the corrective actions
taken. |
|
j. |
If the licensee is committed to follow the
guidance in Regulatory Guides 1.33 and/or
1.21, and/or 4.15, review the results of the
interlaboratory comparison program to
verify the quality of radioactive effluent
sample analyses performed by the licensee.
Review the licensee's quality control
evaluation of the interlaboratory
comparison test and associated corrective
actions for any deficiencies identified. If
applicable, review the licensee's
assessment of any identified bias in the
sample analysis results and the overall
effect on calculated projected doses to
members of the public. |
|
k. |
Review the results from the licensee's QA
audits to determine whether the licensee
met the requirements of the RETS/ODCM. |
02.03 |
Identification and Resolution of Problems |
|
a. |
Review the licensee's self assessments,
audits, Licensee Event Reports, and Special
Reports related to the radioactive effluent
treatment and monitoring program since the
last inspection. Determine if identified
problems are entered into the corrective
action program for resolution. |
|
b. |
Review corrective action reports related to
the radioactive effluent treatment and
monitoring program. Interview staff and
review documents to determine if the
follow-up activities are being conducted in
an effective and timely manner
commensurate with their importance to
safety and risk: |
|
- Initial problem identification, characterization, and tracking.
- Disposition of operability/reportability issues.
- Evaluation of safety significance/risk and priority for resolution.
- Identification of repetitive problems.
- Identification of contributing causes.
- Identification and implementation of effective corrective actions.
- Resolution of non-cited violations (NCVs) tracked in the corrective action system.
- Implementation/consideration of risk significant operational experience feedback.
Emphasis should be placed on ensuring problems are identified, characterized,
prioritized, entered into a corrective action, and resolved. |
|
c. |
For repetitive deficiencies or significant
individual deficiencies in problem
identification and resolution identified
above, determine if the licensee's self-assessment activities are also identifying
and addressing these deficiencies. |
The estimated hours to complete this procedure ranges from a minimum of 36 hours to a maximum of 44 hours, with a base of 40
hours.