ML19347B803
| ML19347B803 | |
| Person / Time | |
|---|---|
| Issue date: | 09/26/1980 |
| From: | Kerr G NRC OFFICE OF STATE PROGRAMS (OSP) |
| To: | Cashman T NEW YORK, STATE OF |
| Shared Package | |
| ML19347B802 | List: |
| References | |
| NUDOCS 8010160007 | |
| Download: ML19347B803 (6) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION t
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l SEP 2 61980 Ref: SA/KNS Mr. Thomas J. Cashman, Chief Radiation Control Section New York State Department of Environmental Conservation 50 Wolf Road Albany, New York 12233
Dear Mr. Cashman:
This is to confirm the coments made to you at the conclusion of the recent radiation control program review by Mrs. Kathleen Schneider.
It was noted that copies of permits issued since the last review had not been routinely sent to the Office of State Programs. We again request that we receive copies of new or amended pennits on a quarterly basis.
We comend the effort the staff has begun in formal documentation of the assessment of the permit application, especially for the more complex permitting applications. However the staff indicated that they did not believe that there would be sufficient time at the present staffing levels to continue this practice. We recomend that this formal documentation be continued and that such a document contain all the important aspects of the reviewer's assessment and actions.
We noted that survey instruments used for independent measurements in inspections were not being calibrated. We recommend these instruments be calibrated and have enclosed Infonnation Notice H.2 - Calibration of Radiation Detection Survey Instruments.
During the review of selected compliance files, it was noted that several sections of the inspection report were not completed.
Information on the permit number, radioactive license number, independent measurements by inspector and permittee's monitoring sections were missing in several cases.
We recommend that all sections of the inspection report be covered during the inspection and documented in the report.
During the review of the NLI file, it was noted that handwritten notes and documentation of meetings and telephone conversations were incomplete.
It was not possible to determine author, date and subject.
We recommend that all information sent to files should be dated, signed, and completed as to pertinent information.
80.10.16o 007
- e-Mr. Thomas J. Cashman 2-2 I would appreciate receiving your comments on these findings and appreciate the courtesy and cooperation extended to Mrs. Schneider during +he review.
Sincerely, n av<
. Wayne Kerr, Assistant Director for State Agreements Program Office of State Programs
Enclosure:
As stated cc: Robert Flacke, Consnissioner i
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STATE AGREEMENTS BRANCH
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DIVISION III INFORMATION NOTICE Other H.2 - Calibratidn of Radiation Detection Survey Instruments The purpose 'of this Information Notice is to provide SAP staff and the Agreement States with guidance for calibration of survey meters used by Agreement States in independent measurements during compliance inspec-tions.
I.
Calibration Frecuency A.
A survey instrument used for independent measurements in a
. compliance inspection should be calibrated at a date such that the interval between the calibration date and the date of inspection does not exceed the interval imposed upon the licensee.
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Example - Industrial radiographers are required to maintain survey instruments which have been calibrated at intervals not to exceed three months (and after each servicing of the instrument).
The survey instrument used by the inspecting agency should have been cali-brated at a date not more than three =enths previous to the date the instrument is used at the inspection.
2.
Example - A hospital's license requires their beta-ga=ma survey meter to be calibrated at intervals not to exceed six months. The beta-gacma survey instrument used by the inspecting agency should have been calibrated at a
date not more than six months previous tc the date the instrument is used at the inspection.
B.
In some cases, the only requirement upon a licensee may be that the survey instrument be " checked".
In such cases, the instrument used'by the inspecting Agency should be calibrated according to :
guidelines in paragraph I.C (following).
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Example - An indestrial licensee is required by his license to " check" his alpha survey instrunent against a calibrated RaDEF source daily.
The inspecting agency's instrument should have been calibrated against i
a calibrated alpha source within one year (see paragraph 1.C).
In addition, the inspector should carry a s=all alpha check source to use to check for proper response of the instrument. This should be used each day the instrument is used for independent measurements.
(See j
paragraphs III.A.1 and 2.)
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.C.
If there is no applicable requirement in the regulations or in the license regarding calibration frequency, the following i
j guidelines may be applied to survey instruments used by the i
inspecting agency for independent measurements:
a Type
' Frequency
- 1.
Gamma (CM, " Cutie pie", etc.)
6 months 2.
Alpha
<1 year prior to use 3.
Neutron
<1 year prior'to use 3
4.
Beta See footnote a 5.
Other See footnote a
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II.
Calibration Practices A.
1.
For gamma survey instruments used by inspecting agc cies, the calibration should be traceable to the National bs-eau of Standards (NBS).b a.
Circumstances may dictate other calibration practices. For example, a gamma scintillator kept for use in searching for lost sources would not normally be calibrated except, perhaps, af ter servicing.
If used for a compliance survey, however, a ti=ely re-calibration may be needed.
l b.
Calibrations using a source of uncertain origin or output can meet I
this objective if the output is established by using, for example, an R-chamber whose calibration is traceable to N3S.
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't II. Calibration Practices (continued) -
A.
2.
For alpha and neutron survey instruments, calibrations
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i using alpha or neutron sources prepared specifically for use for calibration, or sources whose outputs are certified by the manufacturer, are acceptable.
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3.
For beta dose measurements, calibration can be t
i established by using a. plated source of the same i'sotope as will be measured in the field. However,
- this objective can rarely be met (exceptiens may be 4
l uranium or 90 r). An acceptable alternative would be S
to select a beta-ga*.ima survey instrument properly calibrated against t gamma source and whose beta response is well established.
It is highly desirable in such cases that the license and the inspecting agency use the same model instrument (detector,
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window thickness, etc.) and that agreement is reached beforehand concerning factors for convercing scale readings to dose rates.
B.
The survey instrument should bear ciecr evidence of calibra-l tion.,This may be accomplished by means of a tag, sticker i
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or other suitable means. At a minimum, the date of the last calibration (or alternatively, the date when the current l
calibration expires) and the name of the person, agency or contractor who provided the calibration should appear.
III. Operational Use A.
1.
When possible, small check sources should be carried by the inspector and used by him to assure the instrument is operational. In some cases, a check source and a calibra-
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tion source may be the same, e.g.,
a small calibrated alpha source.
2.
Although normally, check sources are not used for cali-bratior, an inspector should be familiar with the typical response of an instrument to a check source. A significant deviation from the usual response is a signal that there may be a problem with the instrument, e.g.,
low batteries,c contaminscion, defective detector, improper voltage setting, moisture, etc.
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c.
The inspector should be acquainted with the battery requiraments of his instrument and its battery test circuit. On some commercial survey instruments using multiple sets of batteries, not all batteries are included in the battery test circuit.
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s IV.
Calibration Services A.
Calibracion services can be provided by the inspecting Agency using in-house resources, by persons exe pt from licensing (e.g., a national labcratory), or by persons licensed by the NRC or an Agreement State.
B.
If calibration services are provided to an Agreement State by a licensee of that State, the following practices should be follewed:
i 1.
Services (including calibration, repair, co=ponent j
i replacement, delivery, etc.) should not be accepted i
gratis;d l
2.
All services are covered by a formal agreement, contract, l
or letter agreement; I.
3.
Regulatory matters should not be mixed with service l
activities:
1 a.
If an inspector who conducts an inspection of i '~
a calibration service license is asked, in the I
interests of cost savings, to deliver or receive instruments for calibration at the sa=e tire,
.l he should cleariy separate these two functions g
during his visit.
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b.
Enforcement or licensing correspondence should l
not contain references to calibration service matters unrelated to the regulation of the licensee.
i 4.
Any practice or circumstance that may suggest an appearance of a conflict of interest should be avoided.
S'.
If possible, the Agency should prohibit the person providing calibration services to the Agency from advertising this fact.
d.
An exception could be another State agency (e.g., State' university).
In such cases, care should_pe exercised to assure that the provision of such services does not co= promise the regulatory agency in the exercise of its duties.
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