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radwaste scaling factors
This message is directed to my fellow power reactor radwaste people. My
concern is the calculation of scaling factors for our various waste
streams.
I noticed the following in an inspection report for Cooper (NRC
Inspection Report 50-298/01-06, dated November 19, 2001, available from
the NRC web page):
page 13: "A noncited violation ... was identified for failure to
properly classify and manifest radioactive waste shipments in 1999,
2000, and 2001. On August 21, 2001, the inspectors identified that the
licensee had incorrect shipping manifests and had underreported isotopic
and total shipment radioactivity. The licensee had utilized
nonconservative 3-year average waste stream analysis scaling factors in
each waste stream...Various isotopic scaling factors were low by a
factor of between 10 and 100..."
Although I have not talked with anyone at Cooper about this, I suspect
that this may have resulted from using software that uses rolling
averages for waste classification. Even if that's not the case, here,
this is a potential problem if you use such software. While rolling
averages may be good for smoothing out random fluctuations resulting
from the imprecision of the sampling and analysis processes, it may also
mask a significant shift in the radioisotopics of plant waste streams.
This creates the potential for nonconservative characterization and
classification.
I would recommend that you: (1) avoid using rolling averages, (2) be
sure to investigate any scaling factor shifts of more than an order of
magnitude, and (3) consider sampling and laboratory analysis for each
batch of low volume, high specific activity waste streams, such as (for
a BWR) RWCU and FPCCU resins.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com
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