ML20012D540
| ML20012D540 | |
| Person / Time | |
|---|---|
| Issue date: | 03/22/1990 |
| From: | Glenn J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20012D541 | List: |
| References | |
| NUDOCS 9003280027 | |
| Download: ML20012D540 (16) | |
Text
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g WAR Rt195 NEMORAt:0UM FOR: Robert J. Pate, Chief Nuclear Peterials safety and $afeguards Brar.ch, RV FRON:
' John E. 61een, Chief Medical, Academic, and Comercial Use Safety Branch Division of Industrial and Fedical Nuclear $4fety, NM$$
$UBJECT:
TECHNICAL A$$15TANCE RE00EST CONCERNING CALIPRATION OF COUNT RATE METER $ WITH PANCAKE PROBES This is in reference to a Technical Assistance Request (TAR) dated February 13, 1990 from H. D. Chaney Acting Chief, Region V, concerning a Health Physics consultant's use of rod game sources to calibrate count. rate meters.
Specifically, it was requested that we answer the following three questions:
1.
Is the licensee's use of rod sources an acceptable calibration for pancake probes used with count rate meters possessed by NRC licensees?
2.
If the answer to question 1 is no should we require the use of planchetsourcesasaconditionofrenewalforthislicense?
3.
Please reference any requirements or regulatory guideline that could be used to support either the acceptability or rejection of rod sources as appropriate.
It should be noted that there is no specific regulatory requirement to use properly calibrated survey instrument listed in 10 CFR Part 70
- Pather, 10 CFR 20.201 requires licensees to make surveys in order to evaluate radiation dose rate incident to the production, use release, disposai, or presence of radioactive material or other sources of radiation.
$urveys made with improperly calibrated instruments could defeat the basic objectives of the survey requirement in Part 70 and would therefore be unacceptable.
Accordingly, the instrument calibration requirements in 10 CFR Part 20 are an indirect requirement and therefore completely dependent on the intended use of the instrument and must be evaluated with this principle in mind on a case by. case basis.
However, the answer to the three specific question are as follows:
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After reviewing Mid Pacific Medical physics calitration procedur entitled, ' Calibration of CPM Survey meters' cith s pporting documentation Cted September 15 find the procedure acceptable for, 347 ud becaeer:to 19R9, we instruments used for routine surveys or other uses not reovired by regulation to l
measurements in units of activity such as disintegrations per minute e accurate (DPN).
We reached this decis4h beste or, the observation that the I
corsvitant's proceture using rod sovrtes does not include beta radiation and will mest itkel gamme/ beta radiation fields. y read tenservatively high in mised sees not accurately account for beta activity in mined field i
by regulation or license condition to measure ac test measurements.
2.
Rather than requiring the use of specific types of sources such as planchet sources and a similar geom)you should reouire the consvitant to that the source (s, used have similar phet,on ud beta energy ranges etric orientation as the samples to be sessured.
(In this specific case The consvitant may demo,nstrate the accuracy and precision calit' ration procedures by direct comparison with sources directly i
traceable to national standards.
theoretical calculation alone is not acceptable, Demonstration of accuracy b k
3.
i Draft Regulatory Guide, Task 0P 032 5 " Test and Calibration of ANSI N322 1978 Radiation Protection Instrumentation,", dated September 198 i
enclosing copies for your inforsation.are the guidance used to review this If we can be of further assistance, you may contact Michael Lamastra o I
staffat(FT$ 497-3416).
Q-John E. Glenn, Chief Medical, Academic, and Cosmercial Use safety Branch Division of Industrial and Medical Nuclear $4fety, NM$$
Inclosure: As stated l
*g U.S. NUCLEAR RESULATORY COMM!$510N I'P$'[,
0FFICE OF NUCLEAR RESULATORY RESEARCH Task p 0324 DRAFT REGU}ATORY GUIDE AND VALUE/!MPACT STATEMENT me.m u
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TEST AND CAL 18 RAT!0N OF RADIATION PROTECTION INSTRlMENTATION
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A.
INTRODUCTION i
Section 20.201 of 10 CFR Part 20, Standards for Protection Against Radia-l f
tion," requires that licensees make surveys in order to evaluate tion dose rates incident to the productica, use, release, disposal, or p radio-j active materials or other sources of radiation.
Portable r p
ection j
instruments are frequently employed in conducting these hough the i
requirement to use properly calibrated instruments is pipiktlymentioned l
in i 20,201, it is implicit in the requirement to c c
surveys as are l
l necessary to ensure compliance with Part 20 and e 19te the extent of radia-l tion hazards that may be present.
Surveys e
h roperly calibrated l
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instruments may not be adequate because the f 1 to provide sufficiently l
1 accurate measurements of radiation leve negntrations of racioactive mate-rial. To rely on such surveys coul feat the basic ob,jectives of the survey l
requirement.
l This guide provides info io its icensees on criteria acceptable to the NRC staff for the test a calprationofhandheldportableinstruments used to make surveys,
- llench,
~, or portal radiation monitors; passive i
personnel dosimeters laboratory counting equipment; and air monitoring equip-ment are not cons e'.d portable survey instruments for the purposes of this guide.
No de churesfortestorcalibrationofradiationprotection f
l instruments ep e ed herein because the specific techniques to be used for any giv e
libration must be tailored to the need and peculiarities of the umentation, radionuclide sources, environment, and circumstances j
of each li see or applicant.
This guide emphasizes the criteria necessary l
to relate instrument calibrations to national radiation standards.
1 i
This Peevlettey eut#e has the essetieted value/lopect statement are helng issues in etef t f ate to invette l
the publit in the early stoets of the develapsent of e regulatory positten in this stee. They have net I
ettelved teelete staff review and et not represent en Of fitle) sett staf f positinti, Pelic tements ett being soittites on both stef ts, the euloe (latluding any telementation scheowle) and the value/tw ett ststonent. Comments on the value/teett statement should be ettempenfee by supportine Gete. CREhents en both draf ts snoglg be sent to the lettetery of the (samission, U.S. yl It*0u l e t o ry l
Commissten, washington. O C. Posts. Attention-Dotseting and service Branth, by 30V $ g se4 vests for single (Defes of etef t gulges (w%tch ety be reptpeuted) Of f 0F Dietement en en svitsmatie, i
filtribution 116% f0F single t091es of future 6tef t evipes in spetifit divisiens thould be tede in vfiling to the V,l, slut teet begulatory (geselss ten, Weshington. O C. 20stl. Attention: Otretter, t
01ris ten of technical Infer *4t ten en0 DDCWeent Contt01.
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Any informaticn collection activities mepti neid in this draft regulatory guide are contained as requirements in 10 CFR Part 20, which provides the l
repuistory basis for this guide.
The information collection requirements in 10 CFR Part 20 have been cleared under OMB Clearance No. 3150 0014.
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0l$CU$$!0N With certain exceptions and supplements, this guide endorses AN$! N3231978, 4
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- Radiation Protection Instrumentation Test and Calibration,"* as the basis for
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j the criteria for test and calibration of survey instruments.
This standard was l
l approved by the American National Standards Institute (AN51) on September 13,
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j 1977.
It contains information needed for test and calibration of portable
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radiation protection instruments used for the measurement of ionizing radiation.
The AN$1 Joint Subcommittee N13/42, which was responsible for development of j
this standard, was composed of about equal numbers of manufacturers and users l
I of survey instruments.
Therefore, this standard benefits from the experience and recommendations of both groups.
A national directory of commercial calibration services has recently been published as a cooperative project of the Conference of Radiation Control j
Program Directors and the National Bureau of Standards (NS$).** The directory
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provides a listing of the types of radiation services offered, the calibration l
f methods used and the est.imated accuracy of the calibrations, the radiation
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j energies and intensity ranges available for calibrations, and the types of j
instruments and radioactive sources that vendors are prepared to calibrate.
l Users should be aware that instruments calibrated by a fire listed in this directory may not meet all the criteria outlined in this guide and that all I
firms offering calibration services may not be listed in the directory, i
" Copies are available from the American National Standards Institute, 1430 Broadway, New York, N.Y. 10018.
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- This directury is designated NBS GCR 80 296 "The Directory of Commercial Calibration Services for Ionizing Radiation Survey Instruments," April 1981.
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It may be purchased as stock number PB 87 206401 from the National Technica) l Information Service, Springfield, Virginia 22161.
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REGULATORY PO$1710N 0
Instrument calibration programs that meet the requirements and recommen-l dations of AN$1 N323 1978, " Radiation Protection Instrumentation Test and
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Calibration," are generally acceptable to the leRC staff for test and c411 bra-i tion of hand held portable instruments used for complying with the survey l
requirements of 6 20.201 of 10 CFR Part 20 subject to the following:
l 1.
In all calibration precedures, the type, geometry, intensity, and l
energy spectrum of the radiation field in which the survey instrument is to be
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calibrated should be appropriate to the instrument's intended use, and the j
field should remain essentially stable during the time interval in which the l
calibration is actually performed.
If scattering contributions to instrument readings are significant, they should be added to the value of the radiation f'
field for all detector positions used for calibration purposes as recommended in Section 6.2 of AN$1 N323 1978.
Sources suitable for use in calibration are listed in the Appendix to AN$1 N323 1978.
2.
Uncalibrated scales or ranges should be identified on the instrument with a tag (or label) attached to the instrument that is marked " Calibration t
has not been verified since (enter date)."
3.
For each scale normally used for radiation protection surveys, a j
periodic performance test (sometimes called constancy check) as described in l
Sections 4.6. 4.7, and 5.4 of AN$1 N323 1978 should be applied to each survey j
instrument prior to each use in order to check its operability and its response l
relative to the reference readings recorded at the last calibration as recom-
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mended in Section 4.6 of ANSI N3231978.
4.
This guide takes no position on section 4.5, " Calibration Records,"
of AN$1 N323 1978.
5.
In addition to the guidance given in Section 5.1 of ANSI N323 1978
,P for the selection of a laboratory standard when national (or derived) standards are not available, the information given in Appendix A to this guide may be used.
6.
The NRC staff considers testing and calibration of radiation protec-tion instrumentation to be an important part of the efforts to maintain occupa-i tional radiation exposures as low as is reasonably achievable (ALARA).
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0.
IIIPLDIENTATION O
The purpose of this section is to provide information to appiteents and licensees regarding the NRC staff's plans for using this regulatory guide.
This guide applies to all licensees required to make surveys according to
$ 20.201 of 10 CFR Part 20.
j This proposed guide has been released to encourage public participation in its development.
Emcept in these cases in which the applicant or Iftensee proposes acceptable alternative criteria for the test and calibration of port-able survey instruments, the information to be described in the active version I
of this guide reflecting public comments will be used by the NRC staff as guidance in the following ways:
NRR will use the guide in connection with the l
review of new and renewal license applications or for amendments to a license J
resulting from mejor revisions to the instrument calibration program; NM55 considers that this guide could provide guidance to their licensees in the l
establishment of instrument calibration programs; IM will reforence this guide I
in its inspection procedures for reactor 6.
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APPENDIX A ADDITIONAL METHOD $ FOR $ ELECT! M LABORATORY $TANDARDS FOR U$t IN CAL!tRAT! M RADIATION PROTECTION INSTRUMENTATION Section 5.1 of AN$1 N323 1978, " Radiation Protection Instrumentation Test and Calibration," provides information for selecting laboratory calibration standards when national standards or derived standards are not available.
This appendix provides additional ways that may be used in such cases.
Examples of national measurement standards that need to be developed (or improved) l include standards for high energy photons, high energy electrons, beta radia-i tion, and fast neutrons.
The technical terminology used in this appendix has been taken from Sec-f tion 0, " Definitions," of ANS! N323 1974.
Several of the definitiens are l
reprinted here with the pemission of the Institute of Electrical and Elec-l
(
tronics Engineers, Inc.
l reproducibility (precision).
The degree of agreement of repeated measure-f O
ments of the same property expressed quantitatively as the standard deviation computed from the results of the series of measurements, sensitivity.
The ratio of a change in response to the corresponding change j
in the field being measured, f
standard (instrument or source) l (1) national standard.
An instrument, source, or other system or device maintained and promulgated by the U.S. National Bureau of Standards as such.
(2) derived or secondary standard.
A calibrated instrument, source, or g
other system or device directly relatable (that is, with no intervening steps) to one or more U.S. national standards.
P O) laboratory standard.
A calibrated instrument, source, or other system or device without direct, one step relatability to the U.$. National Bureau of Standards, maintained and used primarily for calibration and standardination.
,111,1 A procedure whereby the instrument, component, or circuit is evaluated for satisfactory operation.
transfer instrument.
Instruner.t. or dosimeter exhibiting high precision l
which has been standardized against a national or derived standardized source, j
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l uncertainty.
The estimated bounds of the devistion from the mean value, l
generally expressed as a percent of the mean value. Ordinarily taken as the sum of (1) the random errors at the 964 confidence level and (2) the estimated upper limit of the systematic error.
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CALIBRATION STANDARD 5 FOR PHOTON RADIATION Fl[LD5 l
l 1.1 Photon Radiation Field of Certified Intensity I
The user's survey instrument is exposed to a photon radiation field emitted i
l by a laboratory standard source that has been certified
- by the source supplier to have either a specified exposure rate at unit distance (e.g., one meter) i l
under specified scattering conditions (for calculating exposure rates over a range of distances) or specified exposure rates at various distances under i
specified scattering and exposure conditions.
The supplier's certificate should state that the specified exposure rates
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l from the laboratory standard source are known with an uncertainty no greater
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than 110% of the exposure rates that would be generated from a similar national I
standard source containing the same amount of radionuclide under specified exposure and scattering conditions.
l The sourcG supplier should determine the exposure rates for the 16boratory l
l standard source by comparison with a secondary standard source of radiation I
maintained in the supplier's laboratory.
In the intercalibration of these f
sources, at least three replicate comparisons should be made in order to avoid f
errors that might result from operator mistakes, instrument drift, instrument j
malfunction, etc.
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If possible, the exposure rates at a fixed distance (e.g., one meter) from f
the supplier's secondary source should be certified by the National Bureau of f
Standards according to one of its standard calibration services.
The changes i
in exposure rate (or intensity) of the supplier's secondary source thould be f
measured with the supplier's radiation measu 4 nent system at least monthly.
"The supplier should provide any pertinent data on source purity that may, over time, affect calibration values, as specified in International Commission on l
Radiation Units and Measurements Report No. 12, " Certification of Standardized Radioactive Sources," September 15, 1978.
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i This new exposure rate should,be verified to remain within $2% of the calcu-lated value that is obtained by correcting the initial value (certified by the National Bureau of Standards) for radioactive decay. As an alternative, the source supplier may determine the exposure rates for very strong sources by using a transfer instrument as discussed in Section 5.1 of AN$1 N32 bit?8.
A transfer instrument used as discussed in the preceding paragraph and in j
Sections 1.2 and 1.3 of this appendix should be calibrated by exposure to stan-i h
dard fields at the National Bureau of Standards or at a laboratory that has l
satisfactorily participated in an appropriately documented measurement quality assurance program with the National Bureau of Standards.* The transfer instru-ment should hava a reproducibility of at least $2% as recommended in Sec-tion 5.1(1) of ANSI N323-1978.
When used as a secondary standard, a transfer instrument should have an uncertainty no greater than 110% (af ter the applica-
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tion of any necessary calibration factors) as recommended in Sections 5.1 and l
$.3 of ANSI N323 1978.
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l When used as a secondary standard, the transfer instrument should prefer-ably be operated by persons offering radiation dosimetry and calibration services such as those who are certified by the American Soard of Radiology in one of the areas of radiologieni physics, the American Board of Health Physics, f
or the American Board of Industrial Hygiene (radiological aspects).**
1.2 Photon Radiation Field of Measured Intensity The exposure rates at specified distances from a laboratory source to be f
used for instrument calibration can be measured using a transfer instrument as i
discussed in Section 5.1(2) of ANSI N32> 1978.
The exposure rates generated by the laboratory source should be known f
with an uncertainty no greater than 110% of the exposure rates that would be I
generated from a similar national standard source containing the same amount j
s
" Currently, the regional calibration laboratories accredited by the American Association of Physicists in Medicine participate periodically in a quality assurance program sponsored by the National tureau of Standards.
- A discussion of the accuracy to be expected for a transfer instrument is l
given in Technical Report Series No.133, " Handbook on Calibration of Radiation Protection Monitoring Instruments," pp. 55 56, published by the International Atomic Energy Agency in 1971.
This report is available from l
UNIPUB, 345 Park Avenue South, New York, N.Y. 10010.
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I of radionuclide under specified exposure and 6cattering conditions.
This i
uncertainty includes any uncertainty in the values indicated by the transfer l
instrument, which is discussed in Section 1.1 of this appendix.
1.3 Photon Radiation Field by Substitution l
The survey instrument may be calibrated by temparison with a transfer instrument used as a secondary standard (see Section 1.1 of this appendix) when f
both instruments are located at fixed points within any appropriate radiation l
l field. At each selected point, a technique involving either simultaneous expo-l j
sure or substitution is used to compare readings of the transfer instrument and of the survey instrument under calibration.
l The exposure rates should be known with an uncertainty no greater than f
l-110E of the exposure rates that would be generated from a similar national f
standard source containing the same amount of radionuclide under specified j
exposure and scattering conditions. This uncertainty includes any uncertainty l
in ths values indicated by the transfer instrument.
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CALIBRATION STANDARD $ FOR NEUTRON RADIATION Fl[LDS S!
A survey instrument that is to be used for e:timating neutron dose equive-l 1ent rates should be calibrated by a laboratory neutron source that has been certified by the source supplier to give known neutron dose equivalent rates at specified distances.
A technique for routine calibration of neutron reemeters I
with radioactive neutron sources is given in NBS $pecial Publication 633.*
The dose equivalent rate of the user's laboratory standard source should j
be determined by the supplier, taking into account the neutron emission rate
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(n/sec), the fluence rate (n/cm8 sec), and the spectral distribution of the f
source. The fluence rate of the usse's laboratory source should be determined I
by the source supplier by intercomparison with the same type of source cali-brated by the National Bureau of Standards.
Intercomparison of the sources may j
l be made by the supplier using systems such as a long counter.
For an unmoder-ated neutron source, conversion of fluence rate to dose equivalent rate should-I l
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"R. B. Schwartz and C. N. Eisenhauer, " Procedures for Calibrating Neutron Personnel Dosimaters," Center For Radiation Research, National Measurement Laboratory, National Bureau of Standards, NBS Special Publication 633, May
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1982. This publication may be obtained from the National Technical Informa-tion Service, Springfield, Virginia 22161, order number Pt42235961.
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be made in accordance with the table of Neutron Flux Dese Equivalents given in l.
$ 20.4 of 10 CFR Part 20 using the average energy of the neutron spectrum.
However, if a moderated neutron source is used, evaluati6n of the dose equiva-I lent rate per unit fluence rate should consider the entire spectral distribu-tion and not the average energy of this distribution, i
j The source supplier's certificate should specify that the dose equivalent rates calculated for the user's laboratory source are known to within e105 of i
l the dose equivalent rates that would be generated free a similar national stan-l j
dard source under the same exposure geometry and scattering conditions.
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l 3.
CAlletATION $TANDARD$ FOR DETA RADIATION FIELDS i
i No recommendations for selecting a standard are included in this guide.
Until techniques acceptable to the NRC staff are published and acceptable l
secondary standards become available, the applicant is advised to follow the i
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guidance given in section 5.1(3) of AN$1 N3231978 and the general reemenda-j tions in this guide.
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DRAFT REGULATORY ANALY$!$
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PROP 0$fD ACTION i
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1.1 Descristion In order to make accurate surveys as required by $ 20.201 of 10 CFR f
Part 20, portable hand held radiation protection instruments must be properly
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ca m,ated and, in addition, tested efore each use.
T*e,r.pe.ed tion is j
to provide methods acceptable to the NRC staff for calibrating and testing
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these survey instruments.
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1.2 htig I
l It is important to workers that radiation protection instruments be I
accurate and dependable.
The instrument reading provides information on the i
e radiation field in an area so that occupancy in that area may be limited during l
the performance of a required task.
NS$ $pecial Publication 603, " Require-
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ments for an Effective National lonizing Radiation Measurements Program, A
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Report to the Congress by the National Bureau of Standards,"* in cooperation with the Conference of Radiation Control Program Directors, Inc. (March 1941),
assigned first priority to establishing procedures for traceability of radiation I
protection measurements to national standards with the need for making accurate survey measurements and calibrations a second priority.
The proposed action is intended to provide reasonable guidelines for instrument testing and calibration.
1.3 Value/ Impact 1.3.1 3Rg The most significant impact of this proposed action on the NRC would be theexhenditureof1staffyeartodeveloptheguidance.
If the time of a staff i
" Copies may be obtained from the National Technical Information Service.
l Springfield, Virginia 22161, order number Ptt1177636.
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member of the NRC is valued at $40 per staff hour, the cost to implement the proposed action would be $40,000.
The value of this propose 1 action to the NRC is that it will improve the regulatory process because it will facilitate licensing actions and it will assist licensees in complying with the survey requirements in S 20.201 and the NRC staff in inspecting and enforcing this regulation, l
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1.3.2 Other Government Aaencies j
j The values and impacts of this proposed action on Agreement States are j
expected to be similar in kind to those described for the NRC (except for the j
costs of developing the guidance).
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1.3.3 Industry l
The impact of the calibration recommendations on the majority of the l
l licensees is judged to be einer since they are believed now to calibrate survey l
l instruments at least annually.
If a licensee decides to discontinue in-house calibrations and to use commercial calibration services, an expenditure of up j
to $1000 may be required to purchase a backup instrument for making surveys l
while the primary instrument is being serviced.
This impact is expected to be i
small because most large licensees are not expected to switch to commercial l
services, and most small licensees already use commercial calibration services.
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The value to licensees of this proposed action is that it provides thes l
with reasonable guidelines for instrument calibrations.
Of additional potential value to licensees are the technical improvements in some survey instruments that industry may introduce in order to meet the recommended criteria for the calibration and periodic performance test (constancy check),
f The proposed action would have a hidden economic benefit to the industry.
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Presumably, a survey meter out of calibration is just as likely to be in error in the conservative direction as in the nonconservative direction, and overly conservative readings will translate into work interruptions, unnecessary pre-cautions, delay, increased turnover and labor costs, etc.
1.3.4 Workers For the workers, the values of taproved calibrations of survey instruments
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include more accurate assessments of the quality of the working environment and l
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a probable reduction in external radiation exposure.
A quantitative estimate l
of this reduction in dose is not available at this time, 1.3.5 Public This guidance pertains to worker protection programs.
But when survey instruments are used to measure dose rates in unrestricted areas, more accurate i
calibrations lead to a better assessment of the radiation risks to the public.
1.4 Decision on the Proposed Action i
Paragraph 20.1(c) of'the Commission's regulations in 10 CFR Part 20 states that radiation exposures to the public and to workers should be kept as low as is reasonably achievable (ALARA).
The proposed action can provide an improve-ment in instrument reliability and a reduction in radiological risk without s
substantial costs.
Therefore, the staff believes that the proposed action should be undertaken.
2.
TECHt.ICAL APPROACH e-The technical approach in the guidance is based on ANSI N323-1978, "Radia-L tion Protection Instrumentation Test and Calibration." The action proposed 3
here is to provide guidance on acceptable methods of calibration for portable t
hand-held survey instruments.
Calibration of survey instruments is now required l
of all NRC licensees who perform surveys as required by 10 CFR Part 20.-
It is j
our intent that acceptable methods of calibration be a component of licensee j
instrument survey procedures as required by paragraph 20.201(b).
3.
PROCEDURAL APPROACH L
3.1 Procedural Alternatives i
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The proposed action, to publish guidance on calibration and testing pro-cedures for portable hand-held survey instruments, could be accomplished by several methods:
publishing an NRC regulation requiring that specific calibra-
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tion procedures be used by all licensees, preparing or revising a regulatory 9
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guide (based on the existing 8,20.201 of 10 CFR Part 20) that endorses an ANSI standard on calibration procedures, or publishing a NUREG-series report or a branch position paper.
3.2 Discussion of Procedural Alternatives Implicit in the survey requirement of 6 20.201 of 10 CFR Part 20 is the need for adequate calibration of radiation protection instruments.
The NRC staff does not consider it desirable to incorporate detailed calibration requirements into a regulation because possible technical advances in the
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state of the art may require costly changes in the regulations to accommodate them.
A NUREG-series report would be an appropriate vehicle for reporting on technical studies of various calibration methods.' Regulatory guidance, how-ever, is not established through NUREG-series reports.
Since the proposed action includes establishment of an acceptable method for compliance with required surveying programs, a report is not considered suitable.
Branch position statements are intended as interim measures to be used when an immediate response is required.
They are usually superseded when a more permanent mode of guidance is developed.
A regulatory guide can be prepared at reasonable cost within a reasonable time.
A regulatory guide can establish acceptable methods and procedures for meeting a regulatory requirement.
Development of a regulatory guide allows extensive input from all segments of the nuclear industry and the public.
A regulatory guide can describe cali-bration procedures acceptable to the NRC staff or endorse existing acceptable i
standard calibration methods such as those in ANSI N323-1978. The staff does not consider that revision of any existing regulatory guides could provide the objectives proposed here.
3.3 Decision on Procedural Aooroach The staff has concluded that the development of a regulatory guide to endorse ANSI N323-1978 (with modifications) is the favored procedural approach.
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4.
STATUTORY CONSIDERATIONS 4.1 NRC Regulatory Authority l
Authority for this guide is derived from the Atomic Energy Act of 1954, as I
amended, and the Energy Reorganization Act of 1974, as amended, as implemented i
through the Commission's regulations.
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4.2 Need for NEPA Statement Issuance or amendment of guides for the implementation of regulations in 1
Title 10, Chapter I, of the Code of Federal Regulations is a categorical exclu-sion under 10 CFR Part 51, 6 51.22(c)(16).
Thus, an environmental impact I
statement or assessment is not required for this action.
5.
RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES No conflict with any existing regulation or other government policy is known to exist.
6.
SUMMARY
AND CONCLUSIONS The proposed action will reduce the time and effort required to process 1
license applications and will achieve improved radiological safety for workers by increasing the reliability of radiation protection measurements.
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