Limiting Condition for Operation: TRU Waste Storage Facility MAR Inventory Control ACTION(s) - Continued

DOE-STD-1186-2004

ACTIONS B.1 through B.2.2

If a waste container in WASTE STORAGE FACILITY contains

more that the specified nuclear material at risk limits, all

container movement in the vicinity of the non-compliant waste

container must be suspended within 1 hour. Based upon the

simplicity of the container movement activities in WASTE

STORAGE FACILITY, one hour is judged to be adequate to

notify all workers in the vicinity to suspend movement

activities and to safely secure the handling equipment and

waste containers involved.

If a waste container in WASTE STORAGE FACILITY contains

more than the specified nuclear material limits, the waste

container is to be removed from the facility or brought into

compliance to re-establish the assumptions of the WASTE

STORAGE FACILITY specific safety analyses within 3 weeks.

Compliance may be established by re-assay to obtain a more

accurate count or expert review of an existing assay. Three

weeks is considered adequate time for facility management to

identify, communicate with, and coordinate a transfer to an

appropriate on-site facility or to re-establish container

compliance.

An increase in a specific waste container MAR does not have

any impact on contiguous waste containers, other than for

issues dealing with criticality. Therefore, for all accidents not

involving a criticality, high MAR containers do not require

container segregation. The Criticality Safety Program is

credited for handling any criticality issues related to high MAR

containers and their movement.

The likelihood of an occurrence of an accident involving

identified high MAR waste container(s) is small during the

maximum three-week interval for removal.2

SR 3.3.1 and 3.3.2

Performance of SR 3.3.1 and 3.3.2 on a monthly basis

assurances WASTE STORAGE FACILITY compliance with

material at risk limits. Performance of SR 3.3.1 and 3.3.2

"before shipment" OR "at receipt" assures that WASTE

STORAGE FACILITY is operated within the bounds of the

safety analysis. A WEMS query may be used to perform SR

3.3.1, and SR 3.3.2.

Each facility must provide technically a defensible basis for Action Statement time limits based on analyses

performed for the respective LCOs and associated Action Statements.