ML20069F497

Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence

ML20069F497
Person / Time
Site:	Harris
Issue date:	03/21/1983
From:	Patricia Anderson CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	WILSON, R.
References
ISSUANCES-OL, NUDOCS 8303230186
Download: ML20069F497 (18)

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. March 21, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )  :

AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

APPLICANTS' INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO INTERVENOR RICHARD D. WILSON (THIRD SET)

Pursuant to 10 C.F.R. $$ 2.740b and 2.741 and to the Atomic Safety and Licensing Board's " Memorandum and Order (Reflecting Decisions Made Following Prehearing Conference)" of September 22, 1982, Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency hereby request that Intervenor Richard D. Wilson answer separately and fully in writing, and under oath or' affirmation, each of the following interrogatories, and produce and permit inspection and copying

~of the original or best copy of all documents identified in the 8303230186 830321 PDR ADOCK 05000400 i G PDR

responses to interrogatories below. Udder the Commission's Rules of Practice, answers or objections to these interroga-tories must be served within 14 days after service of the interrogatories; responses or objections to the request for production of documents must be served within 30 days after service of the request.

These interrogatories are intended to be continuing in nature, and the answers should promptly be supplemented or amended as appropriate, pursuant to 10 C.F.R. 5 2.740(e),

should you or any individual acting on your behalf obtain any new or differing information responsive to these interroga-tories. The request for production of documents is also continuing in nature and you must produce immediately any additional documents you, or any individual acting on your

. behalf, obtain which are responsive to the request, in accord-ance with the provisions of 10 C.F.R. 5 2.740(e).

Where identification of a document is requested, briefly describe the document (e.g., book, letter,. memorandum, tran-script, report, handwritten notes, test data) and provide the following information as applicable: document name, title, number, author, date of publication and publisher, addressee,

date written or approved, and the name and address of the i

person or persons having possession of the document. Also state the portion or portions of the document (whether sec-l l tion (s), chapter (s), or page(s)) upon which you rely.

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Definitions: As used hereinafter / the following defini-tions shall apply:

The "ER" is the Environmental Report - Operating License Stage for the Shearon Harris Nuclear Power Plant, as amended.

" Applicants" is intended to encompass Carolina Power &

Light Company, North Carolina Eastern Municipal Power Agency and their contractors for the Harris Plant.

" Document (s)" means all writings and records of every type in the possession, control or custody of Richard D. Wilson or any individual acting on his behalf, including, but not limited to, memoranda, correspondence, reports, surveys, tabulations, charts, books, pamphlets, photographs, maps, bulletins, minutes, notes, speeches, articles, transcripts, voice recordings and all other writings or recordings of any kind;

" document (s)" shall also mean copies of documents even though the originals thereof are not in the possession, custody, or control of Mr. Wilson; a document shall be deemed to be within the " control" of Mr. Wilson or any individual acting on his

! behalf if he has ownership, possession or custody of the

! document or copy thereof, or has the right to secure the I

r document or copy thereof, from any person or public or private entity having physical possession thereof.

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General Interrogatories 1(a). State the name, 3 resent or last known address, and present or last known employer of each person known to you to have first-hand knowledge of the facts alleged, and upon which you relied in formulating allegations in the contention which is the subject of this set of interrogatories.

(b). Identify those facts concerning which each such person has first-hand knowledge.

(c). State the specific allegation in the contention which you contend such facts support.

2(a). State the name, present or last known address, and present or last employer of each person, other than affiant, who provided information upon which you relied in answering each interrogatory herein.

(b'). Identify all such information which was provided by each such person and the specific interrogatory response in which such information is contained.

l 3(a). State the name, address, title, employer and l

education and professional qualifications of each person you intend to call as an expert witness or a witness relating to l

l the contention which is the subject of this set of interroga-I tories.

I- State the subject matter to which each such person (b).

j is expected to testify.

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4(a). Identify all documents in four possession, custody or control, including all relevant page citations, pertaining to the subject matter of, and upon which you relied in formulating allegations in the contention which is the subject of this set of interrogatories.

(b). Identify the contention to which each such document relates.

(c). State the specific allegation in each contention which you contend each document supports.

5(a). Identify all documents in your possession, custody or control, including all relevant page citations, upon which you relied in answering each interrogatory herein.

(b). Identify the specific interrogatory response (s) to which each such document relates.

6(a). Identify any other sturce of information, not previously identified in response to-Interrogatory 2 or 5, which was used in answering the interrogatories set forth herein.

(b). Identify the specific interrogatory response (s) to which each such source of information relates.

7(a). Identify all documents which you intend to offer as exhibits during this proceeding to support the contention which is the subject of-this set of interrogatories or which you intend to use during cross-examination of witnesses presented 4

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- r by Applicants and/or the NRC Staff on the contention which is' ,

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the subject of this set of interrogatories. .

(b). Identify the particular pag %bscitations of each '

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document applicable to the contention.s ,

t x y , 's Interrogatories on Wilson IVC (Radiological Monitoring) s

' ,s IVC-1. The deriviation of the formula L.L.D. = 4.66Sb E x V x 2.2 x Y x.e;ggg s

is described in Applicants' Environmental Report at Tab'le'- ' "

6.1.5-9 and at Table 4.12-1 of the most recent draft of-NUREG-0472, dated January 4, 1983, attached hereto. In" light a s

of this explanation, do you now understand that Sb will not -

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vary with conditions of season', time or weather? .If so, wi11

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you withdraw Part 1 of Contention IVC? '

If the answer to Interrogatory IVC-1 is other than' .

.s affirmative: '

IVC-2. Explain in detail why you believe that "Sb" will vary with the seasons of the year; ,

IVC-3. Describe in detail how you expect "Sb" to vary at different seasons and state the magnitude of variance that you expect to occur in measurements obtained from Applicants

equipment;

• IVC-4. Explain in detail why you believe that "Sb" will vary at different times of day; i

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IVC-5. Describe in detail how yod expect "Sb" to vary at different times of day ano state the magnitude of variance that you expect to occur in measurements obtained from Applicants' equipment; IVC-6. Explain in detail why you believe that "Sb" will vary with different weather conditions; IVC-7. Describe in detail how you expect "Sb" to vary with different weather conditions and state the magnitude of variance that you expect to occur in measurements obtained from Applicants' equipment.

IVC-8. Applicants intend to be bound by the reporting requirements set out at $ 3.12.1 of the January 4, 1983 draft of NUREG-0472, attached hereto, which require a licensee to report measurements in excess of the levels specified in Table 3.12-2 of NUREG-0472. Will you withdraw part 2 of Contention IVC if Applicants comply with the above-cited specifications?

IVC-9. If the answer to Interrogatory IVC-8 is other than affirmative, explain why you believe that the methodology and reporting requirements set forth in the above-cited materials are inadequate to ensure compliance with the requirements of 10 C.F.R. $ 50, Appendix I.

IVC-10. The use of split sample technique is explained in Applicants' Environmental Report at S 6.1.5.5. Explain in detail your definition of the term " split' sample" as it is used in part 3 of Contention IVC.

IVC-11. In proposing Contention IVC, were you aware that Applicants conduct split sample analyses using a test sample of known activity only as a technique for evaluating the perform-ance of equipment and counting techniques?

IVC-12. If the answer to Interrogatory IVC-11 is other than affirmative, will you withdraw Part 3 of Contention IVC?

IVC-13. Regulatory Guide 4.15, pages 4.15-6 and 4.15-7 of which are attached hereto, explains the purpose of split sample analysis and states that where the "mean result of' cross-check analysis exceeds the control limit . . . an investigation should be made to determine the reason for this deviation and corrective action should be taken as necessary." Reg. Guide at 4.15-6. Thus Applicants are required to resolve the problem, whether caused by human error or equipment malfunction. Does this procedure satisfy your concern with regard to part 3 of

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Contention IVC? If so, will you withdraw Part 3 of Contention IVC?

IVC-14. If the answer to Interrogatory IVC-13 is other than affirmative, explain what you believe to be an appropriate l

procedure for resolution of discrepancies during split sample i

analyses.

Recuest for Production of Documents l

Applicants request that Richard D. Wilson respond in writing to this request for production of documents and produce the original or best copy of each of the documents identified i

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or described in the answers-to each-of the above interrogatories at a place mutually convenient to the parties.

Respectfully submitted,

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, Gw John H. O'Neill, Jr.

Pamela H. Anderson SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.

Washington, D.C.. 20036 (202) 822-1000 Richard E. Jones .

Samantha Francis Flynn CAROLINA POWER & LIGHT COMPANY.

P.O. Box 1551 Raleigh, North Carolina 26602 (919) 836-7707 Dated: March 21, 1983 i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .b '

/"" ' 22 e BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN ) Docket Nos. 50-400 OL MUNICIPAL POWER AGENCY ) 50-401 OL

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Applicants' Interrogatories And Request For Production Of Documents To Intervenor Richard D.

Wilson (Third Set)" were served this 21s~t day of March, 1983, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.

0444 Pamela H. Anderson i

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN Docket Nos. 50-400 OL

) 50-401 OL MUNICIPAL POWER AGENCY ) .

)

(Shearon Harris Nuclear Power )

Plant, Units 1 and 2) )

SERVICE LIST James L. Kelley, Esquire Atonic Safety and Licensing Board John D. Runkle, Esquire U.S. Nuclear Regulatory Carmission Conservation Council of North Carolina Washington, D.C. 20555 307 Granville Road Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright Atcmic Safety and Licensing Board M. Travis Payne, Esquire U.S. Nuclear Regulatory Ccmnission Edelstein and Payne Washington, D.C. 20555 P.O. Box 12643 Raleigh, North Carolira 27605 Dr. James H. Carlanter Dr. Richard D. Wilson Atomic Safety and Licensing Board 729 Hunter Street U.S. Nuclear Regulatory cn mission Apex, North Carolira 27502 Washington, D.C. 20555 Mr. Wells FMlanan Charles A. Barth, Esquire 718-A Iredell Street IWron Kannan, Esquire Durhan, North Carolira 27705 Office of Executive legal Director i U.S. Nuclear Regulatory Ccmnission Ms. Patricia T. Newnan Washington, D.C. 20555 Mr. Slater E. Newman Citizens Against Nuclear Pcwer

, Docheting and Servi Sed.on 2309 Wepouth Court Office of the Secretary Raleigh, North Carolina 27612 U.S. Nuclear Regulatory Ccmnission Washington, D.C. 20555 Richard E. Jones, Esquire Vi President & Senior Counsel Mr. Daniel F. Read, President Carolira Power & Light Ccmpany Chapel Hill Anti-Nuclear Group Effort P.O. Box 1551 P.O. Box 524 Raleigh, Ibrth Carolira 27602 Chapel Hill, North Carolina 27514 Dr. Phyllis Intchin 108 Bridle Run~

Chapel Hill, North Carolina 27514 l

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Deborah Greer.blatt, Esydre 1634 Crest Road Raleigh, North Carolina 27606 Bradley W. Jones, E O e U.S. Nuclear Regulatory c' = ission Region II 101 Marrietta Street Atlanta, Georgia 30303 Ruthanne G.. Miller, Esquire -

Atanic Safety and Licensing Board Panel .

U.S. Nuclear Regulatcry Ceinsicn '

Washirx;rton, D.C. 20555 e

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4 TABLE 4.12-1 (Continued)

TABLE NOTATION ,

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f The LLD is the smallest concentration of r a probabilitya of represents falsely "real" signal.concluding that a blank observation chemical separation)

For a particular measurenent system ( -

LLD = 4.66 s b

E.V 2.22 . Y . exp(-AAt) '

where o w

LLD per unitismass theorlower volume)limit of detection as defined above (asC I_

s b N is the standard deviation of the background ae counting r t >he or of the counts counting rate of a blank sample as appropriate per minute) (as t F

h E is the counting efficiency (as counts per transfomation) VE Y is. the sample size (in units of mass or volume) t c1 2.22 is the picocurie number of transformation per minute per N c

Y is the fractional radiochemical yield (when applicable)

Ais the radioactive. decay constant for the particular radionuclide

.atis the elapsed time between sample collection (o~r end of t-the sample collection period) and time of counting g g

tion system sh The value of s!11 be basedused in the calculation +,

the background counting rate or of the counting rate of theon{ t -

blank samples theoretically (as variance.

predicted appropriate) rather than on an unverified D In calculating the LLD for h ground shall include the typical contributions of W E

nuclides nomally present in the samples (e.g., potassium-40 in%

milk samples). '

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TABLE 4.12-1 (Continued) T.'

L TABLE NOTATION V

Analyses shall be perforrned in such a manner that the stated LLDs will be achieved under routine conditions. Occasionally background fluctuations, unavoidably small sample sizes, the presence of interferring nuclides, or other uncontrollable cir-In such cases, ,

cumstances may render these LLDs unachievable.

the contributing factors will be identified and described in the Annual Radiological Envirornental Operating Report, b - LLD for drinking water.

c - LLD for leafy vegetables.

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3/4.12 RADIOLOGICAL ENVIRONMENTAL MONITORING 3/4.12.1 MONITORING PROGRAM LIMITIN'G CONDITION FOR OPERATION 3.12.1 The radiological environmental monitoring program shall be conducted as specified in Table 3.12-1.

APPLICABILITY: At all times.

ACTION:

a. . With the radiological environmental monitoring program not being conducted as specified in Table 3.12-1, in lieu of a Licensee Event Report, prepare and submit to the Commission, in the Annual Radio-logical Environmental Operating Report required by Specification 6.9.1.11, a description of the reasons for not conducting the program as required and the plans for preventing a recurrence.

b. With the level of radioactivity as the result of plant effluents in an environmental sampling medium at a specified location exceeding the reporting levels of Table 3.12-2 when averaged over any calendar quarter, in lieu of a Licensee Event Report, prepare and submit to the Commission within 30 days, pursuant to Specification 6.9.2, a Special Report that identifies the cause(s) for exceeding the limit (s) and defines the corrective actions to be taken to reduce radioactive effluents so that the potential annual dose

• to A MEMBER OF THE PUBLIC is less than the calendar year limits of Specifications 3.11.1.2, 3.11.2.2, and 3.11.2.3. When more thca one of the radionuclides in Table 3.12-2 are detected in the sampling medium, this report shall be submitted if:

concentration (1) concentration (2) +

reporting level (1) reporting level (2) ***21.0 When radionuclides other than those in Table 3.12-2 are detected and are the result of plant effluents, this report shall be submitted if the potential annual dose

• to A MEMBER OF THE PUBLIC is equal to or greater than the calendar year limits of Specifications 3.11.1.2, 3.11.2.2 and 3.11.2.3. This report is not required if the measured level of radioactivity was not the result of plant effluents; however, in such an event, the condition shall be reported and described in the Annual Radiological Environmental Operating Report.

c. With milk or fresh leafy vegetable samples unavailable from one or more of the sample locations required by Table 3.12-1, identify loca-tions for obtaining replacement samples and add them to the radiological environmental monitoring program within 30 days. The specific

• The methodology and parameters used to estimate the potential annual dose to a MEMBER OF THE PUBLIC shall be indicated in this report.

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y REPORTING LEVELS FOR RADI0 ACTIVITY CONCENTRATIONS IN ENVIRONMENTAL SAMPLES us '

h Reporting Levels d

Water Airborne Particulate Fis'h Milk Food Products Analysis (pCi/1) or Gases (pCi/m3 ) (pCi/kg, wet) (pCi/1) (pCi/kg, wet) 11- 3 20,000* ,

Hn-54 1,000 30,000 .

Fe-59 400 10,000 .

Co-58 1,000 30,000 Co-60 300 10,000 y Zn-65 300 20,000 ,,

m Zr-Nb-95 400 I-131 2 0.9 3 100 Cs-134 30 10 1,000 60 1,000 Cs-137- 50 20 2,000 70 2,000 Ba-La-140 200 300'

^For drinking water samples. This is 40 CFR Part 141 value. If no drinking water pathway exists, a value of 30,000 pCi/2 may be used.

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samples containing known concentratiens of should be included frequently in groups of un- '

j known environmental samples that are analyzed radionuclides provides a means to determine '

accuracy. The analysis of laboratory blanks radiochemicany. Spiked and blank samples .

provides a means to detect and measure should be submitted for analysis as unknowns to provide an intralaboratory basis for estimat-radioactive contamination of analytical samples, 5

a common source of error in radiochemical ing the accuracy of the analytical results.

analysis of low-level samples. The analysis of These blanks and spikes may include blind analytical blanks also provides information on replicates.

the adequacy of background subtraction ,

particularly for environmental samples. 6.3.2 Interlsboratory Analyses The fraction of the analytical effort needed Analysis of effluent and environmental sam-for the analysis of quality control samples ples split with one or more independent labora-

depends to a large extent on (1) the mixture of tories is an important part of the quality as- _

sample types in a particular laboratory in a surance program because it provides a means particular time period and (2) the history of to detect errors that might not be detected by y performance of that laboratory in the analysis intralaboratory measurements alone. When og of quality control samples. However, for possible, these independent laboratories should i '

environmental laboratories, it is found that at be those whose measurements are traceable to least 5%, and typically 10%, of the analytical NBS.3 g load should consist of quality control samples. -

6.3.1 Intralaboratory Analyses ples of milk , water, soil or sediment, and vegetation is particularly important in envi-Replicate samples, usually duplicates, should ronmental monitoring programs to provide an ,

be analyzed routinely. These replicates should independent test of the ability to measure

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be prepared from samples that are as homo- radionuclides at the very low concentrations '

geneous as possible, such as well-stirred or present in most environmental samples.

mixed liquids (water or milk) and solids .

(dried, ground, or screened soil, sediment, or The NRC Office of Inspection and Enforce-vegetation ; or the ash of these materials). ment conducts a Confirmatory Measurements These samples may be replicates of monitoring Program for laboratories of licensees that meas- '

program samples, replicates of reference test ure nuclear reactor effluents. The analyses of materials, or both. The size and other physical liquid waste holdup tank samples, gas samples, and chemical characteristics of the replicate charcoal cartridges, and stack particulate samples should be similar to those of single filters are included in this program. The "

samples analyzed routinely. results of the licensee's measurements of sam-

. ples split with the NRC are compared to those i The analysis of the replicate samples as blind of an NRC reference laboratory whose measure-replicates is desirable but is not practicable for ments are traceable to the National Bureau of all laboratories or for all types of samples. For Standards. Thus the results of this comparison l example , in small laboratories it may not be provide to the NRC an objective measure of the practicable to prevent the analysts from being accuracy of the licensee's analyses.

sware that particular samples are replicates of one another. Laboratories of licensees or their contractors g that perform environmental measurements ,

Obtaining true replicates of all types of should participate in the EPA's Environmental '

r samples also is not practicable. For example, Radioactivity Laboratory Intercomparison Stud-obtaining replicate samples of airborne mate. ies (C oc -check) Program, or an equivalent i rials usually is not practicable on a routine program. This participation should include all basis because it requires either a separate of the determinations (sample medium /radionu- 7 a

sampling system or splitting a single sample clide combinations) that are both offered by -

1 (e.g. , cutting a filter in half). Use of replicate EPA and included in the licensee's environ- M samplers usually is not economically feasible mental monitoring program. Participation in the I

i and splitting of samples results in replicates EPA program provides an objective measure of N I that do not represent the usual sample size or the accuracy of the analyses because the EPA .

I measurement configuration (counting geometry) measurements are traceable to the National '~b j for direct measurement. However, simulated Bureau of Standards. If the mean result of a l samples of airborne materials may be prepared cross-check analysis exceeds the control limit ,

I in replicate and submitted for analysis as as defined by EPA (Ref. 42), an investigation  ;

I unknowns, should be made to determine the reason for this q l deviation and corrective action should be taken e Analysis of intralaboratory blank and s' piked [

samples is an important part of each environ-2Nas and Nac starts recogmae the need for a ciesrer deru19 mental laboratory's quality control program. To twn er the term trac admty as a appues to recauon and ,

check for contamination from reagents and racosc y ure2e s eu it rs,arQeryg togety ._

e, , , c ether sources, known analytical blank samples .. par.ceiy.

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as nscessary. Similarly , an investigation end conczntrations and/or rels:sa rat:s of radio-r any necessary corrective action should take active material in the monitored release path. W

[ place if the normalized range," as calculated These correlations should be based on the results of analyses for specific radionuclides in N

W by EPA, exceeds the control hmit, as defined by EPA. A series of results that is within the grab samples from the release path.

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control limits but that exhibits a trend toward these limits may indicate a need for an investi. Any flow-rate measuring devices associated l gation to determine the reason for the trend, with the system should be calibrated to deter- - .

mine actual flow rates at the conditions of 6.4 Computational Checks temperature and pressure under which the system will be operated. These flow rate '

Procedures for the computation of the con- devices should be recalibrated periodically.

centration of radioactive materials should in- Whenever practicable, a check source that is clude the independent verification of a sub-stantial fraction of the results of the computa. actuated remotely should be installed for in-tion by a person other than the one performing tegrity checks of the detector and the asso-the original computation. For computer calcula. ciated electrical system. -

tions, the input data should be verified by a M.

knowledgeable individual. All computer pro. S. Review and Analysis of Data ~~-7 grams should be documented and verified Procedures for review and analysis of data before initial routine use and after each modifi. should be developed. These procedures should cation of the program. The verification process should include verification, by a knowledgeable cover examination of data from actual samples 1 individual, of the algorithm used and test runs and from quality-control activities for reason- -

in which the output of the computer computa- ableness and consistency. These reviews tion for given input can be compared to "true" should be perfomed on a timely basis. General values that are known or determined independ. criteria for recognizing deficiencies in data ently of the computer calculation. Documenta. should be established. ,

tion of the program should include a descrip- Provisions should be made for investigation l tion of the algorithm and, if possible, a and correction of recognized deficiencies and current listing of the program. Guidelines for k, the documentation of digital computer programs for documentation of these actions.

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( are given in ANSI N413-1974 (Ref. 43).

.7. Quality Control for Continuous Effluent Monitoring Systems

9. Audits Planned and periodic audits should be made to verify implementation of the quality assur-p

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g Guidance on specification and performance of ance program. The audits should be performed -

onsite instrumentation for continuously non- by individuals qualified in radiochemistry and itoring radioactivity in effluents is given in monitoring techniques who do not have direct ,

responsibilities in the areas being audited. g ANSI N13.10-1974 (Ref.18).

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The specified frequency of calibration for a Audit results should be documented and re- '

particular system should be based on con- viewed by management having responsibility in siderations of the nature and stability of that the area audited. Followup action, including .

system. For nuclear power plants, specific re.

reaudit of deficient areas, should be taken i 1

quirements for calibrations and checks of par. where indicated.

I ticular effluent monitoring systems usually are included in the technical specifications for the D. IMPLEMENTATION b.

plant, The purpose of this section is to provide in-

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Initial calibration of each measuring system fomation to applicants and licensees regarding . y*

should be performed using one or more of the the NRC staff's plans for using this regulatory reference standards that are certified by the guide. .

National Bureau of Standards or standards that M

have been obtained from suppliers that partici- Except in those cases in which the applicant 3 pate in measurement assurance activities with or licensee proposes an acceptable alternative method , the staff will use the methods de-W Jq NBS (see footnote 2). These radionuclide scribed herein in evaluating an applicant's or h standards should permit calibrating the system licensee's capabili:v for and performance in M l

over its intended range of energy and rate capabilities. For nuclear power plants, sources complying with specified portions of the Com- E'n mission's regulations after March 30, 1979.

that have been related to this initial calibration 7 should be used to check this initial calibration If an applicant or licensee wishes to use the V at least once per 18 months (normally during method described in this regulatory guide on  %

refueling outages). or before March 30,1979, the pertinent portions -4 Periodic correlations should be made during of the application or the licensee's performance will be evaluated on the basis of this guide. S 4

operation to relate monitor readings to the W

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