United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Proposed Guidance for Calibration and Surveillance Requirements to Meet Item II.F.1 of NUREG-0737

HPPOS-001 PDR-9111210074

Title: Proposed Guidance for Calibration and Surveillance

Requirements to Meet Item II.F.1 of NUREG-0737

See the memorandum from D. G. Eisenhut to Regional

Administrators dated August 16, 1982. This memo includes

"Proposed Guidance for Calibration and Surveillance

Requirements for Equipment Provided to Meet Item II.F.1,"

prepared by the Division of Systems Integration, NRR.

Presented below is a brief description of the Proposed

Guidance. It is strongly recommended that the entire

document be reviewed. The health physics position was

written in the context of 10 CFR 20.201, but it also

applies to "new" 10 CFR 20.1501 (a) and 20.1501 (b).

The noble gas effluent monitors, particulate and

radioiodine samplers, and in-containment radiation monitors

described in NUREG-0737, Item II.F.1, Attachments 1, 2, and

3, are substantial departures from conventional designs and

operating concepts in detecting and measuring plant

radiological conditions. The nature and purpose of these

monitors and samplers dictates an approach to calibration

and surveillance requirements that differs widely from

existing requirements and procedures established for

conventional monitors. The proposed guidance addresses

concerns relative to review of licensees implementing

procedures and provides guidance on certain matters

pertaining to calibration.

APPLICATION OF ANSI N323-1978: ANSI N323-1978

recommendations as requirements for the review of fixed

area and effluent monitors are not appropriate for either

normal range or NUREG-0737 monitors. The standards

contained in ANSI N323-1978 specifically address

hand-portable survey instrumentation and are not applicable

to fixed area or effluent monitors.

MC 2515, INSPECTION PROCEDURE 84710: MC 2515, Inspection

Procedure 84710 was written specifically for monitors

designed to operate at very low concentrations of

radioactive materials and is not appropriate for use in

conjunction with NUREG-0737 noble gas effluent monitors for

the following reasons: (1) ALARA considerations limit the

handling of gamma-emitting noble gases in concentrations

sufficient to perform onsite upper range calibration of

these monitors; (2) Inspection Procedure 84710 suggests

using Kr-85, a gas not suitable for calibration of most

NUREG-0737 effluent monitors; (3) the only practicable

means of in-place calibration of NUREG-0737 effluent

monitors in the upper ranges, "solid" sources, is not

consistent with 84710; and (4) release of calibration gases

to the environment after calibration could result in

violations of plant Technical Specifications.

NRR STAFF RECOMMENDATIONS FOR CALIBRATION OF NOBLE GAS

EFFLUENT MONITORS: An acceptable approach calls for a

one-time "type" calibration of a limited number of

production-model monitors using radioactive gases, an

acceptable alternative to in-place testing with radioactive

gases due to ALARA considerations. The calibration, at

either the manufacturer's facility or suitable contractor

facility, would use NBS-traceable radioactive gas sources

of the appropriate emissive characteristics at a minimum of

three on-scale values separated by not less than two

decades of scale. One or more "Laboratory Standard

Sources" could be established using solid radioactive

source material having emissive radiation characteristics

similar to those of the calibration gas. The solid sources

could then be used to develop "Secondary Calibration

Sources" used for on-site in-place calibration. It is

suggested that periodic confirmation or verification of

calibration source values be made a part of surveillance

procedures.

IN-CONTAINMENT HIGH-RANGE RADIATION MONITORS: NRR

recommends that licensees verify monitor design

characteristics by requiring type-testing at sufficient

points to demonstrate linearity through all scales up to

106 R/hr. In addition, licensees should specify that each

production detector be tested at 103 R/hr to assure

satisfactory response to high levels of radiation.

PARTICULATE AND RADIOIODINE SAMPLING FROM EFFLUENT GAS

STREAMS: NRR would accept empirical data on sampling line

losses based on actual tests of either the installed system

or a full-scale mockup in lieu of calculations based on

ANSI N13.1-1969 appendices.

NRR recommends OIE revise MC 2515, Inspection Procedure

84710 or consider preparation of a separate inspection

procedure or temporary instruction for NUREG-0737 items.

The suggested guidance in NUREG-0737 and this memorandum

with its attachments should provide the basis to initiate

action.

Regulatory references: 10 CFR 20.201, 10 CFR 20.1501,

NUREG-0737, Technical Specifications,

Subject codes: 6.4, 7.3, 12.16

Applicability: Reactors

Page Last Reviewed/Updated Thursday, March 29, 2012