02.01 |
Inspection Planning and In-Office Inspection |
|
a. |
When possible, coordinate the inspection
schedule with the licensee to coincide with
a Type B shipment or other non-excepted
package shipments. |
|
b. |
Review the scope of the licensee's audit
program to verify that is meets the
requirements of 10 CFR 20.1101(c). |
02.02 |
Radioactive waste system walk-down |
|
a. |
Walk-down the liquid and solid radioactive
waste processing systems to verify and
assess that the current system configuration
and operation agree with the descriptions
contained in the FSAR and in the Process
Control Program (PCP). |
|
b. |
Review the status of any radioactive waste
process equipment that is not operational
and/or is abandoned in place. Review the
licensee's administrative and physical
controls (i.e., has the system been drained
and isolated from other systems) to ensure
that the equipment will not contribute to an
unmonitored release path and/or affect
operating systems or be a source of
unnecessary personnel exposure. |
|
c. |
Review the adequacy of any changes made
to the radioactive waste processing systems
since the last inspection. Verify that the
changes were reviewed and documented in
accordance with 10 CFR 50.59, as
appropriate. Review the impact, if any, to
radiation doses to members of the public. |
|
d. |
Review current processes for transferring
radioactive waste resin and sludge
discharges into shipping/disposal
containers to determine if appropriate waste
stream mixing and/or sampling procedures,
and methodology for waste concentration
averaging provide representative samples
of the waste product for the purposes of
waste classification as specified in
10CFR61.55 for waste disposal. |
02.03 |
Waste characterization and classification |
|
a. |
Review the radio-chemical sample analysis
results (i.e., "10 CFR Part 61" analysis) for
each of the licensee's radioactive waste
streams (e.g., dry active waste (DAW), ion
exchange resins, mechanical filters, and
sludges and activated materials). Review
the licensee's use of scaling factors and
calculations used to account for difficult-to-measure radionuclides (refer to the
Branch Technical Position, "Waste Form
Technical Position," IE Information Notice
86-20, Technical Position on Concentration
Averaging, and NUREG-1608). Verify
that the licensee's program assures
compliance with 10 CFR 61.55 and 10
CFR 61.56 as required by Appendix G of
10 CFR Part 20. |
|
b. |
Review the licensee's program to ensure
that the waste stream composition data
accounts for changing operational
parameters and thus remains valid between
the annual or biennial sample analysis
update. For example, the shipping staff
may monitor reactor coolant radio-chemistry to ensure the stability of the
waste stream analyses. Changes in reactor
coolant chemistry (e.g., fuel integrity or
corrosion film morphology) can result in
changes to the waste stream compositions. |
02.04 |
Shipment preparation |
|
a. |
Observe shipment packaging, surveying,
labeling, marking, placarding, vehicle
checks, emergency instructions, disposal
manifest, shipping papers provided to the
driver, and licensee verification of
shipment readiness. Verify that the
requirements of any applicable transport
cask Certificate of Compliance have been
met (refer to NUREG-1660). Verify that
the receiving licensee is authorized to
receive the shipment packages. If
applicable, verify that the licensee's
procedures for cask loading and closure
procedures are consistent with the vendor's
current approved procedures. |
|
b. |
Observe radiation workers during the
conduct of radioactive waste processing
and radioactive material shipment
preparation activities. Determine if the
shippers are knowledgeable of the shipping
regulations and whether shipping personnel
demonstrate adequate skills to accomplish
the package preparation requirements for
public transport with respect to NRC
Bulletin 79-19 and 49 CFR Part 172
Subpart H. If direct observation is limited,
review the technical instructions presented
to workers during routine training. Verify
that the licensee's training program
provides training to personnel responsible
for the conduct of radioactive waste
processing and radioactive material
shipment preparation activities |
02.05 |
Shipping Records. Sample at least 5 non-excepted package shipment (LSA I, II, III,
SCO I, II, Type A, or Type B) records. Review these records for compliance with NRC
and DOT requirements. For example, ensure the shipping documents contain
emergency response information and a 24-hour contact telephone number as required
by 49 CFR Part 172 (refer to NUREG-1660). |
02.06 |
Identification and Resolution of Problems |
|
a. |
Review the licensee's Licensee Event
Reports, Special Reports, audits, State
agency reports, and self assessments related
to the radioactive material and
transportation programs performed since
the last inspection. Determine if identified
problems are entered into the corrective
action program for resolution. |
|
b. |
Review corrective action reports written
against the radioactive material and
shipping programs since the previous
inspection. Interview staff and review
documents to determine if the following
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 corrective action
system(s).
- 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 34 hours to a maximum of 46hours, with a base of 40
hours.