Proposed Guidance for Calibration and Surveillance
Requirements to Meet Ite
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
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