ML20211A679
| ML20211A679 | |
| Person / Time | |
|---|---|
| Issue date: | 02/03/1987 |
| From: | Mckee P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | James Buchanan, Liza Cunningham, Mckee P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| RTR-REGGD-04.015, RTR-REGGD-4.015 NUDOCS 8702190214 | |
| Download: ML20211A679 (10) | |
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NUCLEAR REGULATORY COMMISSION E
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February 3.1987 MEP.0F.ANDUM FOR:
Those on Att6ched List FROM:
Phillip F. McKee, Chief Operating Reactor Programs Branch Division of Inspection Programs Office of Inspection and Enforcement
SUBJECT:
NEW NBS-AIF PROGRAM FOR RADI0 ACTIVITY MEASUREMENTS AT NUCLEAR POWER PLANTS The purpose of this memorandum is to provide information about the subject program and to request comments concerning possible limited Regional participa-tion in it.
Enclosed is a letter, with attachments, from the Atomic Industrial Forum (AIF)
(Enclosure 1) that describes a new program with the National Bureau of Standards (NBS) to provide checks on the accuracy of radionuclide measurements for nuclear power plants. The program was proposed by AIF members who obtained AIF support for the program. The details of the program as presented in the enclosure are the result of a series of meetings of interested individuals from industry and of meetings between industry representatives and NBS staff.
Dave McCurdy, of Yankee Atomic, has been a leader in establishing this program. Both NBS and industry representatives have kept us informed about the development of this program during the past year and we have infonnally encouraged this develop-ment as an industry initiative that should help ensure the quality of radioactivity measurements at nuclear power plants and which is consistent with the guidance of Regulatory Guide 4.15. contains supplemental information about the NBS-AIF program and possible limited Regional laboratory participation in this program.
We request your comments concerning possible Regional participation in the new AIF-NBS program.
In particular, we are interested in your answers to the following questions:
1.
Shoulo the Regional Laboratories participate this new AIF-NBS program?
If so, to what extent?
2.
Assurring Regional participation to some specified extent, what should be the cost (FTEs)?
3.
Assuming, Region 61 participation, what should be the predetermined limit (as percent of NBS value) on the acceptable difference between NBS and the NRC labcrutories?
07021902M Q%
i hultiple Addressees 2-4.
Should NRC results be identified as such in any published compilations of the results of this program?
?
Please provide your comments within 20 working days of the date of this memorandum.
If you have any questions concerning.this matter, please' contact John Buchanan or L. J. Cunningham.
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Phill p F. McKee, Chief Operating Reactor Programs Branch Division of Inspection Programs Office of Inspection and Enforcement
Enclosures:
1.
Ltr fm C. Walske, AIF, dtd August 28, 1986.
2.
Supplemer.tal Information...
cc:
D. Huppes, NBS Distribution:'
DCS ORPB reading DI reading J. D. Buchanan. IE L. J. Cunningham, IE P. F. McKee, IE R. L. Spessard, IE J. G. Portlow, IE J. E. Wigginton, IE W. J.. Pasciak, RI J. B.'Kahle, RII M. C.'Schumacher, RIII B. liurray, RIV G. P. Yuhas, RV E. W. Brach, EDO J. Bell, TMI
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Addressees for Memorandum Dated 02/03/87 Ronald R. Bellary, Chief Emergency Preparedness and Radiological Protection Branch Region I Douglas M. Collins, Chief Emergency Preparedness and Radiological Protection Branch Region II Wayne D. Shafer, Chief Emergency Preparedness and Radiological Protection Branch Region III William L. Fisher, Chief Radiological and Safeguards Programs Branch Region IV Frank A. Wenslawski, Chief Emergency Preparedness and Radiological Protection Branch Region V 4.,-
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Pteesdent August 28, 1986 i
Dear :
Over the past several months, we have at the request of_sev-eral nuclear utility members, been wor, king with them, a couple i
of commercial source suppliers, and the National Bureau of i
Standards on the formulation of an AIF/NBS Research Associate Program that would take as its objective the check of radio-activity measurements for the nuclear power industry.
The purp' official representative" of AIF member organizationsose of this to the operating nuclear power plants, is to describe that program in outline form, including its implementation, potential benefits and funding and.to seek your reaction and expression of inter-est in participating.
The program would be patterned after an AIF/NBS Research Assoc-inte Program for the radiopharmaceutical industry that has been successfully operating for the past 12 years.
Sponsors of that program are able to demonstrate, to the degree established by periodic assays of calibrated radioactivity samples prepared by an AIF Research Associate stationed at the Bureau, continuing competence to maintain the instrument systems and standards necessary for accurate measurements, i.e. to demonstrate trace-ability to NBS.
Assurance of the proper application of that capability to ultimate consumer products, however, is the res-ponsibility of each manufacturer and of cognizant regulatory agencies.
The program envisioned here would basically provide the same
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kind of assurance to those engaged in radiochemistry measure-ments associated with reactor operations.
It would, for example, give sponsoring nuclear utilities an independent verification, traceable to NBS, of their capability to make l
a'ccurate radioactivity measurements.
The program is not intended to replace routine quality assurance programs which t
are necessary to assure control of measurements on a continuing basis.
It would provide an otherwise unavailable means of demonstrating such capability to NRC (see Regulatory Guide 1
4.15), to INPO and to such other organizations as may be con-l corned with t.he excellence of reactor operations. Je would
4
- August 28, 1986
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also give participating commercial laboratories supplying sources and. measurement related services the means of docu-menting their dedication to quality control by demonstrating j
continuing traceability to NBS.
This would be of direct i
- benefit to organizations utilizing commercial laboratories and I
suppliers and could reduce the frequency or eliminate the need for performance audits.
Specific elements of the program, including the selection of standards and test samples, as well as funding levels and mech-l anisms, would be determined by a steering committee comprised I
of program sponsors working with representatives of AIF and the
' Bureau.
Examples of such program elements are provided in At-tachment A to this letter, which you may wish to have reviewed i
by your laboratory personnel.
Suffice it here to say that the program would supply on a bisonthly schedule standards and test samples (most of them as blinds) of radionuclides of a type and at a level of activity experienced in reactor laboratory mes-surements.
Preliminary estimates put the ' annual cost of the program at approximately $180,000.
In order to fix individual sponsorship fees at a reasonable level, e.g. $8,000-10,000, it would be necessary at the outset for 18-20 AIF member organizations to commit to participate in the program.
The commitment of addi-tional sponsors would proportionately reduce the annual parti-cipation fee.
Attachment B is a sample "semorandum of agree-ment" between AIF and the sponsoring organization which further addresses program funding.
Incid'entally, the up-front collec-i tion of sponsor fees, which would be held in escrow on behalf of the program, is patterned after the on-going radiopharma-cautical program.
Should you wish additional information on the proposed program, 4
please ask someone on your laboratory staff to call Dave Harvard, AIF's Environmental Projects Manager, who will be administering the program.
Dave, in turn, could put that person in touch with radiochemists at Commonwalth Edison, TVA and Yankee Atomic Electric, each of when was instrumental in formulating the program outline.
Please let us have your reaction to this proposal and your interest in participating in the program.
If we are to launch l
the' program by January 1, 1987, we shall need to hear from you soon.
Sincerely.
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NA Standards and salibration services to be provided by the AIF/NBS Research Associate Program he following/ tables give examples of the schedste of standards and services whisk this program will offer for the first five years. Oase a~ steering eessittee is formed from the subseribers to,this program, they will have the opportamity to further refine these schedules.
Table 1 shows the standard materials which would be prepared darias the first five years. nose standards were seleeted based on the following skaracteristles:
a) stability b) long useful life e) durability d) flezability (allow for dispensing and/or d!! sting, especially into other seemetries) e) assaracy f) test and salibrate procedures, where possible, over the entire range of use g) start with materials la simple form, then progress to more semplex mixtures and more semples forms h) duplicate or staslate the radiosselide and form seed la actual measurements as closely as practical.
Im general standards will be prepared at two levels of activity la order to meet the requirements of those participants who need higher activity samples. no complexity of the star.derds semerally increases as the years progress, which will mesa a greater R and D offert to develop the standards.
He technology developed for the production of 'special form' standards will be published la order to essourage sommercial prodsstions of these standards.
Wader the existing AIF/NBS radiopharancestical program participants are allowed to sabait two samples per year for es11bration or verification at NBS. Under the new power plant program the asaber and type of semples esbeitted will differ depending on the asede of the partielpants.
He types of salibrations and the espected number from the various participants are shown is Table 2.
nose are gives in order of increasing l
difficulty. He average sost vos1d be $1000 for the type 1 es11brations.
h e type 2 salibrations eest $1200-81500. Type 3 enlibrations vos1d use the asse sources as types 1 and 2.
For the last two estegories, types 4 and 5, the sosts and availability weste depend spon how soon these estibrations can be developed and to what extent they can be automated. During the first year, only the first three vos1d be available.
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BarYise 1
os11bration or verification of activity for slagle radioaselides in solation la the alerocarie range, 2
verification of mixed samma-ray standards as sola-tions and point soareas, 3
reference laboratory messarements for split stam-dard sample between commercial supplier, eastomer, and M S, 4
estibration of submitted single-radioaselide samples la the assocarie range by NaI(TI) spectro-metry or lignid-scintillation somating, 5
onlibration of submitted "special form" semples.
Projected amasal use of these services Number of Number of Partieinant
'Onen Months' Calibrations IEE1 15 Utilities 2
10 - 20 1,2,3,4 7 Commerical Labs 2
7 - 14 1,2,4 2 Soarse suppliers 5
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Su)plement Information and Questions Concerning the N 35-AIF Program _for Radioactivity Measurements at Nuclear Power Plants and Potential Regional Laboratory Participation in this Program The most recent meeting between AIF representatives and NBS staff to discuss this program was held on December-11, 1987. Dr. Dale Hoppes of NBS has informed us of the results of that meeting. Those at the meeting supported the program described in the enclosure. The first four of the six blind samples (in enclosed Attachment A, Table 1) are expected to be available to the power plants in calendar 1987.
If the recruitment of the new Research Associate goes as planned, the program would be active in April. The commercial standards suppliers would also measure the blinds if they supply like materials, and would also be expected to submit 13 samples for checking at NBS if they deliver all types of radionuclides. This would include samples of each issuance of the old NBS mixed-radionuclide standards by Analytics and Amersham; although Dr. Hoppes felt this was excessive, the power plants con-sidered it important.
Dr. Hoppes expects that many of the samples to be supplied to RESL by NBS, under the NRC program for establishing " traceability" of RESL to NBS, will be the same as those supplied to participants in the NBS-AIF program provided that the samples meet the requirements of both programs.
r Dr. Hoppes also has informed us that the question of NRC Regional laboratory participation in the NBS-AIF program arose during the December meeting and that industry representatives indicated that they would welcome such partici-pa_ tion. Regional participation would provide, for the first time, a direct comparison of Regional radioactivity measurements with those of the NBS.
There is a precedent for participation of a Federal regulatory agency in an NBS-AIF program; a laboratory of the Food and Drug Administration (FDA) participates in the analogous AIF-NBS program for assay of radiopharmaceuticals.
Because of the limitations of Regional laboratory capabilities, any Regional participation probably would of necessity be limited to gamma-ray categories.
The proposed NRC participation this program would be arranged directly with NBS. NRC/IE would arrange with NBS to obtain some of the standards being distributed in the AIF-NBS program for analysis by Regional laboratories.
For all five Regions to obtain all standard in the gamma-ray category, but j
none in the alpha or beta categories, NBS estimates total annual cost to i
the NRC would be about $10,000. Unlike the AIF participants, NRC would have no say in the selection of the standards to be included in the program.
Regional participation would raise the question of identification of NRC results as NRC results in any published compilation of the results of this new program.
It has been agreed that power plant results will only be revealed in such compilations in a way such that individual participants are not identified.
(Individual power plants results would, of course, be available to NRC inspectors at the plants). To date, FDA results have not been identified as such in published compilations of the results of the AIF-NES radiopharmaceutical program; however, we understand that FDA has no objection to their results being identified publicly as FDA results.
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' d RESL results have been identified as such in published NBS compilations of the results of NRC's program for establishing " traceability" of RESL to NBS.
Another question that arises when considering Regional participation in this program is the magnitude of a predetermined limit on the acceptable difference between Regional results of measurements and the NBS value. This predeter-
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mined limit is specified by the participants; it is not specified by NBS.
In the analogous NRC program for establishing " traceability" of RESL to NBS, these predetermined limits of the acceptable differences range from 5 to 8 percent of the NBS value. The NBS staft recognizes that NBS measurement uncertainties should be a relatively small part of any differences that might be observed and that this may mean that better NBS calibrations are required. NBS plans to develop new or improved basic calibrations for radionuclides measured by power plants where current NBS calibrations are very old or uncertain; however, this will take time. Such new calibrations will be substantiated internationally by NBS as they are made.
A final consideration concerning possible Regional participation is, of course, the impact on Regional resources, i.e. consideration of the additional time that would be necessary for performing radioactivity measurements as a result of participation in this new program.
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