ML20236K683

Rev 1 to Reg Guide 4.15, QA for Radiological Monitoring Programs (Normal Operations) Effluent Streams & Environ

ML20236K683
Person / Time
Issue date:	02/28/1979
From:	NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:
Shared Package
ML20236J837	List: ML20236J833 ML20236K683
References
FOIA-LA-P97-493 REGGD-04.015, REGGD-4.015, NUDOCS 9807100042
Download: ML20236K683 (10)

Text

Revision 1 February 1979 U.S. NUCLEAR REGULATORY COMMISSION 8' /. ." e c i,,%,

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OFFICE OF STANDARDS DEVE I

HEGULATORY GUIDE 4.15 t

QUALITY ASSURANCE FOR RADIOLOGICAL MONITORING PROGRAMS (NORMAL OPERATIONS) - EFFLUENT STREAMS AND THE ENVIRONMENT A. INTR'0 DUCTION Part 20 as is reasonably achievable, taking into j, .

account the state of technology and the economics of improvements in relation to public, This guide describes a method acceptable to the NRC staff for designing a program to as- health and safety and to the utilization of sure the quality of the results of measurements atomic energy in the public interest.

J of radioactive materials in the effluents and the envirot. ment outside of nuclear facilities during Section 30.34. " Terms and Conditions of Li-nonnal operations, ccnses " of 10 CFR Part 30, " Rules of General e

Applicability to Licensing of Byproduct Mate-The NRC regulations that require the control rial," provides that the Commission may incor-of releases of radioactive materials from nuclear porate in any byproduct material license such facilities, that require the measurements of ra- terms and conditions as it deems appropriate or diocctive materials in the effluents and envi- necessary in order to protect health.

'7

• ronment outside of these facilities, that require.

J quality assurance programs and establish Section 40.41, " Terms and Conditions of Li-quality assurance requirements for certain fa- censes," of 10 CFR Part 40, " Licensing of cilities, or that authorize license conditions not Source Material," provides that the Commission

} otherwise authorized in the regulations are'as may incorporate in any source matenal license k follows: sud terms and conditions as it deems appro-priate or necessary to protect health.

Section 20.106, " Radioactivity in Effluents to j 1 'I Unrestricted Areas ." of 10 CFR Part 20,

" Standards for Protection Arainst Radiction,"

Section 50.50, " Issuance of Licenses and Construction Permits " of 10 CFR Part 50, "Li-provides that a licensee shall not release to an censing of Production and Utilization Facil-unrestricted area radioactive materials in con- ities," provides that each operating license for I

t centrations that exceed limits specified in a nuclear power plant issued by the Nuclear n 10 CFR Part 20 or as oth wise authorized in a Regulatory Commission will contain such condi-license issued by the Commis s, ion. Section tions and limitations as the Commission deems 20.201, " Surveys," of 10 CFR Part 20 further appropriate and necessary.

kE requires that a licensee conduct surveys, Section 70.32, " Conditions of Licenses," of including measurements of levels of radiation or concentrations of radioactive materials , as 10 CFR Part 70, "Special Nuclear Material,"

necessary to demonstrate compliace with the provides that the Commission may incorporate such terms and conditions as it deems appro-h gj regulations in 10 CFR Part 20.

priate or necessary to protect health.

Paragraph (c) of Section 20.1, " Purpose," of 10 CFR Part 20 states that every reasonable Section IV.B of Appendix I, " Numerical

- effort should be made by NRC licensecs to Guides for Design Objectives and Limiting Cen-maintain radiation exposure, and releases of ditions for Operation to fIcet the Criterion 'As radioactive materials in effluents to unrestrict. Low As is Reasonably Achievable' for Radio-ed areas, as far below the limits specified in active Material in Light-Water-Cooled Nue! car Power lleactor Effluents," to 10 CFR Part 50, F " Licensing of Production and Utilization Facil-g *unes ind csie subetanuve changes trosi previous issue. itics," requires that licensees establish an ap-Comments shriuid to ww to ow secre.org of sie conwa.u.an. U s. Nuci ,

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[ 9807100042 980630 PDR FOIA Appendix 11

, DE LA P97-493 PDR ,

propriate surveillance and monitoring program Mills ," all give some guidance on means for to provide data on quantities of radioactive assuring the quality of the measu,*ements of ra-material released in liquid and gaseous efflu- dioactive materials in effluents and the envi-ents and to provide data on measurable levels ronment outside of nuclear facilities. More com-of radiation and radioactive materials in the plete and extensive guidance on this subject is

) environment. Section !!!.D of Appendix 1 to provided in this document for nuclear power 10 CFR Part 50 provides certain effluent and reactor facilities and for other facilities for environmental monitoring requirements with which radiological monitoring is required by respect to radioactive iodine if estimates of the N flC. This guidance does not identify exposure are made on the basis of existing sepa rately the activitics that are within the conditions and if potential changes in land and scope of Appendix B to 10 CFR P:.rt 50. How-water usage and food pathways could result in ever, this guidance is intended to be consist-exposures in excess of the guidelines of ent with the requirements of Appendixes A and Appendix I to 10 CFR Part 50, B to 10 CFR Part 50 in that quality assurance requirements should be consistent with the f' Ceneral Design Criterion 60, " Control of re- importance of the activity. For the monitoring l leases of radioactive matcrials to the environ- of production and utilization facilities that is ment," of Appendix A. " General Design Cri- within the scope of Appendix B to 10 CFR teria for Nuclear Power Plants," to 10 CFR Part 50, other regulatory guides that provide Part 50 requires that nuclear power plant guidance on meeting the quality assurance re-

. designs provide means to control suitably the quirements of Appendix B to 10 CFR Part 50 release of radioactive materials in gaseous and should also be consulted.

liquid effluents. General Design Criterion 64, 7, " Monitoring radioactivity releases," of Appen. B. DISCUSSION 8 i dix A to 10 CFR Part 50 requires that nuclear 3 power plant designs provide means for monitor- As used in the context of this guide, quality ing effluent discharge paths and the plant assurance comprises all those planned and sys-environs for radioactivity that may be re. cased tematic actions that are necessary to provide

'J . . from nonnal operations, including anticipated adequate confidence in the results of a mon-operational occurrences, and from postulated itoring program, and quality control comprises accidents. those quality assurance actions that provide a means to control and measure the character-General Design Criterion 1, " Quality stand- istics of measurement equipment and processes d ards and records," of Appendix A to 10 CFR to established requirements; therefore, quality Part 50 requires that a quality assurance pro- assurance includes quali.ty t control.

m gram be established for those structures, sys-tems, and components of a nuclear power plant To assure that radiological monitoring meas-an that are important to safety in order to provide urements are reasonably valid, organizations )

acequate assurance that they will satisfactorily performing these measurements have found it perform their safety functions. necessary to establish quality assurance pro-h- grams. These programs are needed for the L. Appendix B, " Quality Assurance Criteria for following reasons: (1) to identify deficiencies Nucicar Power Plants and Fuel Reprocessing in the sampling and measurement processes to

, Plants " to 10 CFR Part 50 establishes quality those responsible for these operations so that i

assurance requirements for the design, con- corrective action can be taken , and (2) to l

,j struction , and operation of those structures, obtain some measure of confidence in the systems, and components of these facilities that results of the monitoring programs in order to prevent or mitigate the consequences of postu- assure the regulatory agencies and the public

'l lated accidents that could cause undue risk to that the results are valid.

j the health and safety of the public.

Existing published f.aidance on specific qual-p" The need of quality assurance is implicit in ity assurance actions that are applicable to ra-au requirements for effluent and environmental diological monitoring is limited and, in general,

,a monitering, and this need has been widelY is restricted to quality control practices for recognized. Regulatory Guide 1.21 " Mea s u r- radionnalytical laboratories (Refs.1-5). How-ing, Evaluating, and Reporting lladioactivity in ever, quality assurance should be applied to all P Solid Wastes and Releases of Radioactive Mate- steps of the monitoring process, which may

,; rials in Liquid and Caseous Effluents from include sampling, shipment of samples, receipt Light-Water-Cooled Nuclear Power Plan ts ;" of samples in the laboratory, preparation of Regulatory Guide 4.1, " Programs for Monitor- s amples , measurement of radioactivity y , data

? ing Radioactivity in the Environs of Nuclear reduction , date evaluation, and reporting of m Power Plants;" Regulatory Guide 4.8, "Envi- the monitoring results.

ronmental Technical Specifications for Nuclear Power Plants;" and Regulatory Guide 4.14 j' ' Mea s u rin g , Evahtating, and Hcporting Radio- l I

activity in Releases of lladioactive Material in toermemns et inecia scr=, u ed in im ruiJe are twen in Liquid and Airborne Effluents From Uranium tu chry oa me C15 it

}

i 4.15-2 Appendix II

3. Specification of Qualifications of Personnel The scope of this guide is limited to the ele-

. ment:; of a quality assurance program, which is .The . qualifications of individuals perfonning a planned, systematic, and documented pro- radiological monitoring' to carry out their

' gram that includes quality control. Guidance on assigned functions should be s peci.fied and principles and good practice in the monitoring that documented (e.g. , as in a job description). I process itself and guidance on activitics can affect the quahty of the monitoring results An indoctrination and orientation program, (e.g., design of facilities and equipment) are appropriate to the si2e and complexity of the outside the scope of this guide. However, some organization and to the activities performed, I references are provided to documents that do should provide that (a) personnel perfonning provide some guidance i these 'a rea s . The quality-related activities are trained and quali-citation of these references does not constitute fied in the principles and techniques of the ac-an endorsement of all of the guidanec in these livities performed , (b) personnel are made documents by the NRC staff. Rather, these aware of the nature and goals of the quality references are provided as sources of informa- assurance program, and (c) proficiency of per-r tion to aid the licensec and the licensee's con- sonnel who perform activities affecting quality tractors in developing and maintaining a is maintained by retraining, reexamining, and decertifying or by' periodic performance re-

- monitoring program.

views, as appropriate.

• - Every organization actually performing efflu-ent and environmental monitoring, whether an 3. Operating Procedures and Instructions i -

• NRC licensee or the licensee's contractor, should

• include the quality assurance program Written procedures should be prepared, re-

• elements presented in this guide. viewed, and approved for activities involved in ,

7 '

! carrying out the monitoring program, including

,e '. sample collection; packagin g, shipment, and ,l C. REGULATORY POSITION receipt of samples for offsite analysis; prepa-

, ration and analysis of samples; maintenance, )

The quality assurance program of each storage, and use of radioactivity reference  !

a organization perfonning effluent or environ- standards; calibration and checks of radiation l mental monitoring of nuclear facilities for nor- and radioactivity measurement systems; and l mal operations should be documented by reduction, evaluation, and reporting of data. .

written policies and procedures and records. Individuals wno review and approve these pro- I I

o These documents should include the elements cedures should be knowledgeable in the sub-given in this section.

] jects of the procedures.

l 4 In addition to its own program, a licensee Guidance on principles and good practice in g

should require any contractor or subcontractor many of these activities is presented in NRC l performing monitoring activities for the li- regulatory guides (Refs. 6-9) and other publi-censee to provide a quality assurance program cations (Refs. 2-5, 10-35). In addition to these I

' and to routinely provide program data publications , Scientific Committee 18A of the sumtnaries (sufficiently detailed to aermit on- NCRP has prepared NCRP Report 58, "A Ifand-j going quality assurance program evaluation by the licensee) consistent with the provisions of book of Radioactivity Measurements Procc-dures," (Ref. 36) that is a revision of NCRP I this guide, as follows: Report 28, NBS llandt.ook 80. " A Manual of i

. Radioactivity Procedures." l

" 1. Organizational Structure and Responsibilities of Managerial and Operational Personnel The structure of the organization as it re- The records necessary to document the ac-

- lates to the management and operation of the tivities performed in the monitoring program )

monitoring program (s), including quality as- should be specified in the quality assurance l

- surance policy and functions, should be pre-sented. The authorities, dutics, and responsi- p rogram .

% bilities of the positions within this organization One key aspect of quality control is maintain-down to the first-line supervisory level should ing the ability to track and control a sample in p , be described. This should include responsibC- its progress through the sequence of monitor-itics for review and approval of written proce- ing processes. Records to accomplish this e '

dures and for the preparation, review, and should cover the following processes: field and evaluation of monitoring data and reports, j

,! inplant collection of samples for subsequent y analysis, including sample description; smnple l 4

Persons and organizations performing quality receipt and laboratory identification coding;

's sample preparation and radiochemical process-assurance functions should have sufficient ing (e.g., laboratory notebooks); radioactivity 1 authority and organi?ntional freedom to identify measurements of samples, instrument back-1 7 quality problems; to initiate, recommend, or i grounds, and analytical blanks ; and data j

/ provide solutions; and to verify implementation reduction and verification.

of solutions.

i st.

4.15-3 Appendix 11

{

. l Quality control records for laboratory severe prob! cms has been encountered with

. .crunting systems should include the results of . aqueous . samples of radioactive wastes from measurements of radioactive check sources, operating nuclear reactor:s (Ref. 23).

calibration sources, backgrounds, and blanks. '

.)

Records relating to overall laboratory per-formance should include the results of analysis Guidance on the principles and practice of sampling in environmental monitoring is pro-vided in several publications (Refs. 2. 4. 5, of quality control samples such as analytical 21, 23-31, 33, 35, 37). In addition, workers at blanks, duplicates, interlsboratory cross-check the National Bureau of Standards (NBS) have samples and other quality control analyse >; use published the results of a survey of infonna-of standards (radioactivity) to prepare working tion on sampling, sample handling. and long-standards; p.eparation I n t. standardization of term storage for environmental materials carrier solutions; and calibration of analytical (Ref.15). Some guidance on the principles and balances. practice of air sampling is provirled in Refer-enecs 17, 19, 24, 28-31, 33. Guidance on the r- Additional records that are needed should in- principles and practice of water sampling is l i clude the calibration of inline radiation detec- provided in numerous publications (Refs.13, tion equipment, air samplers , and thermo- 14, 25-27, 35, 37).

luminescence dosimetry systems; verification i l

r-and documentation of computer programs; 6. Quality Controlin the Radioanalytical Laboratory i qualifications of personnel; and results of '

audits. 6.1 Radionuclides Reference Standards-Use for The minimum period of retention of the rec- " '" " "*"' * *"* I'* *

• ords should be specified. For nuclear power Reference standards are used to determine o plants, requirements for record retention are counting efficiencies for specific radionuclides given in the plant technical specifications. In or, in the case of gamma-ray-spectrometry

-, general, for other types of facilities, only the systems, to detennine counting efficiency .as a final results of the monitoring programs need functi n of gamma-ray energy. A counting effi-a be retained for the life of the facility. ciency value is used to convert a sample count-ing rate to the decay rate of a radionuclides or '

, 5. Quality Control in Sampling (including Pack- to a radionuclides concentration. Guidance on l aging. Shipping. and Storage of Samples) the calibration ana usage of germanium de-

tectors for measurement of gamma-ray emission

% Continuous sampling of liquids and gases in- rates of radionuclides has been prepared as an l i

volves the measurement of . sample flow rates

) ANSI standard (Ref. 38). For converting

.- -/~

and/or sample volumes. The accuracy of the gamma-ray emission rates to nuclear decay

,2 devices used for this purpose should be deter- rates, two reports from the Oak Ridge National mined on a regularly scheduled basis, and ad- Laboratory (Refs. 39 and 40) provide useful justments should be made as needed to bring compilations of gamraa-ray intensities and other

' tha performance of the devices within specified nuclear decay data for radionuclides in routine j limits. The results of these calibrations should releases from nuclear fuel cycle facilities. The l be recorded. The frequency of these calibra- data from Reference 40 are included in NCRP l tions should be specified and should be based Report 53 (Ref. 36).

T on the required accuracy, purpose, degree of

,s usage, stability characteristics, and other con- Radionuclides standards that have been ditions affecting the measurement. Procedures certified by NBS or standards that have been for continuous sampling should use methods obtained from suppliers who participate in

5 that are designed to ensure that the sample is measurement assurance activities with NBSa representative of the material volumes sampled.

The collection efficiencies of the samplers used , g,,, y ,, _ , ,,, _ , ,,,n,,,, ,,,

should be documented; usually such documen- source suppuers and xes invoive two basie mechanisms: (1) i'* tation is aVailable from manufacturers of the The sup6.her subatts a cabbrated rad.oaetaval.e source (pref a l

<1 samp}jgg equipment. erably selected from a tratch or prepared series of sources) to '

'g was ter confiron,on that the suppber's sabbration vajue strees with NBs results within certaa specified b:mits or (2)

Procedures for grab samples should include ses prendes cabbraied radioneunte ourees of undtsenosed steps designed to ensure that the sample is ,,"j,j',',l,7[ll,8 '(*,,'*, PPA" * "M * * '$ ",*,"* **""

representative of the material sampled. Hep- certua specified i;>:ts mtn the measurements of xas. For the rounae proJuctwo of comnerad raa.cacunty standards. the licate grab. samples should be taken periodically to determine the reproducibility of sampling.

,f.rst mechanism

,,,,bie. is preferat.le Trese two meaanisms to arethe second used both t,ut is not always in Measurements Assurance Fregrams (mms) with key laboratories and an eLher Procedures for sampling, packaging, ship- ** s sur'on' "*u'*nde uunne s.

ping, and storage of samples should be Two her tabarcorv source surphers parucipsie in Mars mth designed to maintain the integrity of the haraple was and use tmath of tne two basse meenanstrss (1) The NRC l l frout time of collection to time of analysis. "ference tidor.iory ror the confirnateer M 2.urements Pro- l 18- gram (ftr etnuent tunatorone) of the NRr 0frace of InsP*Chon

.% Aqueous samples may present a particular and Intereceent and (:) The trA Ennmn <nus Monitonar l

) prvblem in this regard, and one of the most and support taboratorr in t . veras. which prepares and tb 4.15-4 r

.i;. Appendix II

_ _ _ . _ _ _ _ _ ______.__._____________J

~

investigative and corre.ctive action should bc should be used when such standards are avail. taken when the measurement value f aus outside a ble . In these measurement assurance activ- the predetermined control value, ities , the supplier's cabbration value should agree with the Nils value within the overaU A check source for determining changes in uncertainty stated by the supplier in its certi- counting rate or counting efficiency should be fication of the same batch of sources (when of sufficient radiochemical purity to allow <

these are sampled for measurement by NBS) or correction for decay but need not have an l in its certification of similar sources, accurately known disintegration rate, i.e.,

I An " International Directory of Certified Ra- need not be a standard source.

dioactive Materials" has been published by the For systems in which samples are changed

• international Atomic Energy Agency (Ref. 41).

manually, check sources are usuauy measured Acceptable standards for certain natural ra- daily . For systems with automat 0 sample dionuclides may be prepared from commerciaDy changers, it may be more convenient to include the check source within each batch of samples available high-purity chemicals. For example, potassium-40 standards for gross beta-particle and thus obtain a measurement of this source l within each Counting cycle. For proportional measurements or gamma-ray spectrometry may counter systems, the plateau (s) or response (s) be prepared gravimetricauy from dried reagent-grade potassium chloride. to the check source (s) should be checked after each gas change. Background measurements 9' should be made frequently, usually daily or I The details of the preparation of working before each use, to ensure that levels are 5 standards from certified standard solutions within the expected range. For systems with should be recorded. The working standard automatic sample changers, background meas-a shoul' be prepared in the same form as the un-known samples, or close approximation thereto. urements should be included within each meas-urement cycle.

a Efficiency calibrations should be checked For alpha- and gamma-ray-spectrometry sys-a periodically (typically monthly to yearly) with tems, energy-calibration sources (i.e. , a standard sources. In addition, these checks source containing a radionuclides, or mixture of 6 should be made whenever the need is in- radionuclides, emitting two or more alpha or l dicated, such as when a significant change in i the measurement system is detected by routine gamma rays of known energies) are counted to determine the relationship between channel

) measurements with a check source. number and alpha- or gamma-ray energy. The W 6.2 Performance Checks of Radiation Measurement frequency of these energy calibration checks Systems depends on the stability of the system but g usually is in the range of daily to weekly. The Detennination of the background counting results of these measurements should be a

rate and the response of each radia'. ion detec- recorded and compared to predetermined limits tion system to appropriate check sources in order to determine whether or not system should be performed on a scheduled basis for gain and zero level need adjus tment.

systems in routine use. The results of these Adjustments should be made as necessary.

g l measurements should be recorded in a log and Additional checks needed for spectrometry plotted on a control chart. Appropriate systems are the energy resolution of the distnbutes calibrated redaoactmty standards pn:maruy to '.an- system and the count rate (or counting

• ' ' Wi ' " """ '23 ""'* rta r - efficiency) of a check source. These should be

"***'",***d Additec.nally seven maior r*Jxphar axei.twal manuf acturers determined periodically (usually weekly to (so.oe of which suppiy rsewaeiinie sianJar.is eem.,rci.nty) monthly for energy resolution and daily to e particip.ie m a Mar orcanaed or tne Ata.c Industnal rerum and NDS. In thas mar NDS dastnbetes standards as test same week]f for Count ratc) and after system 3.les to the manuf acturer (second rechants:n) anJ receives cer. changes, such as power f ailurcs or repairs, to tifwa samp'.es free the manufacturer for venficai.on by .sss determine if there has been any significant uirst mechawa).

change in the system. The results of these

• .Me a s u r eme nt assurance ini,ractions that use the first me. measurements should be recorded.

chaone are avadable na speciai .sas estibration sernees. Nas b wdl. on request and for a fee. perform cabbratons et repre-sentative samp6cs of stanJJrds pronJed by the suspLer for 6.3 Analysis of Quality Control Samples

. BS confirmatun vf the suppher's rererted values. L'aubration N

sernces are avadable for a tarte variety of r iwnuchdes pro-

{ tiJed certaan requirements tas to sacp.e , tat.d.ty and suitable ThC analysis of Quality Control samples pro-e

• at tiv.t y range) sie set. .teasuremans assuraane mieractions Vides a means to determine the precision and g .

that use the secenJ sechann are ava:lante vn ene issuance ef accuracy of the monitoring processes and in-test stanJards be . sus. For a nominal charre t r emna trie e,nc, et the sianJard). sns raJautiniy aanaard iteter nce cludes both intralaboratory and interlaboratory

, scrista (sitMs) can Le purvnesed as te.t s.earces of unJae- rDeasu rcfDent s.

i (bsc J ac tivity that c an be used ta Jeesnair ste a g re ement .

I ' * .t h an (e t t am s ped 6e d l$mit s . Let-cen the wurre su p piee r's measures (nts and those of $liS. A !iegvrt of Test (f ^r the first m.Clunemi er a hqvrl ..f .venurea:ent t secer J me.nanaam h The analysis of replicate samples (containing vvs.t.eming teth the saurce .uppl.es a a.nJ *. 6h v s.uc e . i. is sue J to siu o wuo ni in, muur supruer pari,apaiwn in ih, significant detectable activity) provides a l

me s.orement a.suranee actiuty .

means to determine precision; the analyas of 3

4.15-5

9 e samples containing known concentrations ' of should be included frequently in groups of un-known environmental samples that are analyzed i

~

' radionuclides provides a means . to determine *

- accuracy. The analysis of laboratory blanks radiochemicauy.' Spiked and blank samples

. provides a . means to detect and measure should be submitted for analysis as unknowns -

radioactive contamination of analytical samp!cs, to provide an intrataboratory basis for estimat-a common source of crror in radiochemical ing the accuracy of the analytical results.

analysis t,f low-level samp!*s. 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 Inte laboratory Analyses -

The fr0ction 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.

, perforinance of that laboratory in the analysis intralaboratory measurements alone. When j of quality control samples. However, for- possible, these independent laboratories should 1

, environmental laboratories, it is found that at be those whose measurements are traceable to I

least 5%, and typically 10%, of the analytical NBS.8 j load should consist of quality control samples.

Analysis of split field samples, such as sam-6.3.1 Intralaboratory Analyses ples of milk, water, sou or sedircent, and 9 vegetation, is particularly important 6 envi-p Replicate samples, usually duplicates, should ronmental monitoring programs to provide an independent test of the abihty to measure .

be analyzed routinely. These replicates should be prepared from samples that are as homo- radionuclides at the very low concentrations l 4 geneous as possible, such as weU-stirred or present in most environmental samples. j mixed . liquids (water or milk) and solids i

' (dried, ground, or screened soil, sediment, or The NRC Office of Inspection' and' Enforce-  !

y vegetationi or the ash of these materials), ment conducts a Confinnatory Measurements l Program for laboratories of licensees that meas-

6. ,

h These samples may be replicates of monitoring program samples, replicates of ' reference test ure nuclear reactor effluents. The analyses of I

materials, or both. The size and other physical liquid waste holdup tank samples, gas samples, 8 and chemical characteristics of the replicate charcoal ' cartridges, and stack particulate 9 samples should be simuar to those of single filters are included in this progra:n. The j samples analyzed routinely, results of the licensee's measurements of sam- i G ples split with the NRC are compared to those  ;

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 i

. au laboratories or for au types of samples. For Standards. Thus the results of this comparison d 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 licensce's analyses.

a aware that particular samples are replicates of '

one another. Laboratories of licensees or their contractors -

$- that perforin environmental measurements l Obtaining true replicates of all types of should participate in the EPA's Environmental

. . samples - also is not practicable. For example, Radioactivity Laboratory Intercomparison Stud-obtaining replicate samples of airborne mate- f as (Cross-chea.k) Program, or an equivalent b rials usually is not practicable on a routine program. This participation should include all basis because it requires either a separate of the deterininstions (sample medium /radionu- ,

y sampling system or splitting a single s:unplc clide combinations) that are both offered by  !

EPA and included in the licensee's environ-(e.g., cutting a filter in half). Use of replicate  !

k samplers usuaUy is not economically feasible mental monitoring program. Participation in the and splitting ' of samples results in replicates EPA program provides an objective measure of that do not represent the usual sample size or the accuracy of the analyses because the EPA '

)

measurement configuration (counting geometry) measurements ' are traceable to the National s for direct measurement. Ilowever, simulated Bureau of Standards. If the mean result of a samples of airborne materials may be prepared cross-check analysis exceeds the control hmit in replicate nnd submitted for analysis as as defined by EPA (Ref. 42), an ir.vestigation 1 P unknowns. should be made to determine the reason for this j'

Analysis of intralaboratory blank and spiked deviation and corrective action should be taken samples is nn important part of cach environ- ANDS saJ MC staffs re.menee the need far a tiester defms.

! mental laboratory's quahty control program. To i.on er the tern irace,tubiv- .,it appbe, io raaistion sad check for contamination from reagents and "*'*"'*""""*'a"- T h"' " *"' '" -ma r 'cui wr 1

) '* "# ' " * " * " ' ' "" " "

other hources . known analytical _ blank samples ,,p,$,7y*

Appendix II

1 I

I as necessary. Similarly, an investigation and concentrations and/or release rates of radio.

sny necessary corrective action should take active material in the monitored release path.

place if the " normalized range," as calculated

)[. by EPA, exceeds the control limit, as defined by EPA. A series of results that is within the These correla tions should be based on the results of analyses for specific radionuclides in grab samples from the release path. -

control limits but that exhibits a trend toward l these limits may indicate a need for an investi. Any flow-rate sneasurir.g devices associated l gation to determine the reason for the trend, i with the system should be calibrated to deter-6A Computational Checks mine actual flow rates at the conditions of temperature and pressure under which the system will be opera ted. These flow rate l Procedures for the computation of the con. devices should be recalibrates periodically, centration of radioactive materials should in-clude the independent verification of a sub. Whenever practicable, a check source that is stantial fraction of the results of the compute. actuated remotely should be installed for in- i 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. i tions, the input data should be verified by a knowledgeable individual. All computer pro. 8. Review and Analysis of Data ,

grams should be documented and verified before initial routine use and after each modifi. Procedures for review and analysis of data cation of the program. The verification process should be developed. These procedures should .

should include verification, by a knowledgeable cover examination of data from actual samples '

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 a should be performed on a timely basis. General criteria for recognizing deficiencies in data values that are known or determined independ. l ently of the computer calculation. Documenta. should be established.  !

tion of the program should include a descrip- 1 l tion of the algorithm an d , if possible, a Provisions should be made for investigation l current listing of the program. Guidelines for and correction of recognized deficiencies and l the documentation of digitaj computer programs for documentation of these actions.

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

9. Audits l

7. Quality Control fer Continuous Effluent Monitoring Systems Planned and periodic audits should be made  ;

to verify implementation of the quality assur- i Guidance on specification and performance of ance program. The audits should be performed '

onsite instrumentation for continuously men. by ind*viduals qualified in radiochemistry and j itoring radioactivity in effluents is given in monitting techniques who do not have direct .

ANSI N13.10-1974 (Ref.18). 8csponsibilities in the areas being audited, i The specified frequency of calibration for a Audit results should be documented and re-particular systern should be based on con. viewed by management having responsibility in siderations of the nature and stability of that the area audited. Foljowup action, including system. For nuclear power plants, specific re. reaudit of deficient areas, should be taken quirements for calibrations and checks of par. where indicated.

ticular effluent monitoring systems usually are included in the technical specifications for the D. IMPLEMENTATION j plan t.

The purpose of this section is to provide in- I Initial calibration of each measuring system formation to applicants and licensees regarding l should be performed using one or more of the the NRC staff's plans for using this regulatory l reference standards that are certified by the guide. j National Rureau of Standards or standards that l have been obtained from suppliers that partici. Except in those cases in which the applicant  !

pate in measurement assurance activitics with or licensee proposes an accep able alternative  !

NDS (see footnote 2). These radionuclides method, the staff will use the methods de-  !

standards should permit calibrating the system scribed herein in evaluating an applicant's or j over its intended range of energy and rate licensee's capability for and performance in capabilities. For nuclear power plants, sources complying with specified portions of the Com- j that have been related to this initial calibration mission's regulations af ter blarch 30,19'i9. q should be used to check this inits.il cabbration i s

at least once per 18 rnonths (normally during if an applicant or licensee wishes to use the '

) refueling outages). method described in this regulatory guide on (

or before blarch ~10,19N. the pertinent portions I Periodic correlations should be made during of the appheation or the licensee's perfonnance i operation to relate monitor rea dings to the will be evaluated on the ba:i> of thi> guide. I i

I 1 4.15-7 l

i.

A-

, .y

• } ./ . . REFERENCES

').' Section 6.2, , " Validation of Analyses," . ronmental Protection Agency Report, Office of Chapter 6, " Validity of Results," Methods of Research and Development, Environmental Mon-Radiochemical Analysis, World llcalth Organiza- itoring Support Laboratory, EPA-600/4-76-Ol9, Hon, Geneva,1966. ~ September 1976

2. ' Analytical Quality Control Methods," Envi. 15. E.J. , Maienthat and D. A. Becker, "A Sur-ronmental Radioactive . SurveiUance Guide, vey on Current Literature on Sampling. Sample U.S. Environn cntal Protection Agency Report, Handling, and Long-Term Storage for Environ-ORP/SID 72-2, June 1972. asental Materials ," Interface 5 (s4), 49-62 0976). Also available from the " Superintendent

3. Environmental Radiation Measurements, Re- of Documents , U.S. Government ' Printing port . of NCHP SD35, NMP Report No. 50, .

Office, Washington, D.C.- 20402, as NBS Tech-

'. nical Note #929, October 1976, C 13.46:929, 1976, S/N 003-003-01694-2.

4. L.G. Kanipe, . Handbook for Analytical ualit Control in RadioanalyticalTaboratories, 16. Tritium Measurement Techniques, Report

'~ *

. . 'nvironmeIItal Protection Agency Report of NCIPTC'36, NcRP IWport No. 47, 1976.

EPA-600/7-77-088, August 1977.

17. " Guide to Sampling Airborne Radioactive

5. J.M. Mullins, C. Blincoe, J.C. Daly, et Materials in Nuclear Facilities," ANSI N13.1-

• al., " Radiochemistry." Chapter 17, pp.1007 1969.

1031, Quality Assurance Practices for Health

$ Laboratories , Stanley' L. Inhorn Teditor),

- ~

18. " Specification and Perfomance of On-Site American Public Health Association,1978. Instrumentation for Continuously Monitoring q Radioactivity in Effluents," ANSI N13.10-1974.

6. Regulatory Guide 1.21, " Measuring, Eval-unting, and Reporting Radioactivity in Solid 19. Air Sampling Instruments for Evaluation of

d. . s Atmospheric Contaminan ts , fourth Edition, Wastes and Releases of Radioactive Materials in .3 American Conference of Industrial Hygienists, Liquid and Gaseous Effluents from Light Water.

D~ Cooled Nuclear Power Plants." 1972.

D

7. Regulatory Guide 4.5, . " Measurements of 20. Users' Guide for Radioactivity Standards, Radionuclides in the Environment-Sampling and Subcommittee on Radiochemistry and Subcom-Analyses of Plutonium in Soil."

mittee on the Use of Radioactivity Standards, g Committee on Nuclear Science. National

8. Regulatory Guide 4.6,; " Measurements of Academy of Sciences-National Research Council  !

Report, NAS-NS-3115, February 1974,

, . Radionuclides in the Environment-Strontium-89 and Strontium-90 Analyses."

j- 21. Environmental Impact Monitoring for Nu-clear Power Plants, Source Book of Monitoring

9. Regulatory

• Guide 4.13 "Perfomance, Testing, and Procedural Specifications for. Methods, Vol.1, Atomic industrial Forum He-

• Thermoluminescence Dosimetry: Environmental port AIF/NESP-004, February 1975.

4 Applications."

22. Instrumentation for Environmental Monitor-

10. H ASL Procedures Manus), U.S. Energy in,g: Radiatjon , Lawrence Ucrkeley Laboratory

? . Research and Development . Administration Report, LDL-1. Vol. 3, First Ed., May 1972; Report, HASL-300,1972 (updated annually). First update February 1973; Second update, 5 October 1973.

31. A Guide for Environmental Radiological N SurveIbance at EHDA Installations, Energy He. 23. C.W. Sill. " Problems in Sample Treatment in Trace Analysis," National Bureau of Stand-

{ search and Development Administration Report, ERDA 77-24, March 1977. ards Special Publication 4-22, Accurney, irl Traec Analnis: 'iampling, Sampg llandling,

12. Handbook of Radiochemical Analvtical Meth-  ?.!1.d Analysis, pp. 4G3-490 August 1976.

~

ods, T).S. Environmental Protection Agency lieport. EPA-G80/4-75-001, February 1975. 24. " General Principics for S: pling Airborne Radioactive Materials," International Standard,

13. Standard Methods for the Examination of 1S 0-2889, 1975.

N1~ Water and Wastewater, Thirteenth Edition 7 L American Public Ilealth Association,1975. 25. Manual of Methorf s for Chemical A_n,aly,,si_s of Water and Wastes. EPA-G;'L/6-76003. Lt.S.

~

Envir~onidKtal - Prot ection A r.cnc y , Office of

14. l_lan,dhook for Sampling a_nd n .$ampic Pres- Technology Transfer, Washington, D.C. 20100, y1 ervation of Water and wastewater, U.S. Enva- 3974,

! 4.15-8 .

O -

, 26. ' Standard Practices for Sampling Water." 34. L. l!. Ziegler and ll . M . Hunt. Qualit y 'l

.. Method D 3370$7G, Annual Book of ASTM Stand- Control for Environmental Me.esurements' LEng 'I ards (Part 31), W.itir ""~Am e rican Socic't y'~l6r C5mma-Riiy h}cetrometry, U3~Tnviron5chtal q Tesiing and Materilis Philadelphia, PA,1977. I" rot ec tion Agincy Report EPA 600/7-77-14, i December 1977.

1

( ~ ~/ 27. Biological Field and I.aboratory Methods

- ~ ~

for IfeTdanTg tre Qtiility 5T- Surface Waters

~

35. L.L. Thatcher, V.J. Janzer, and K.W.

and Elfl'ulnts, WA GJ RiT4-73 001- OT(iceFRT Edwards. " Methods for the Determination ofi seli'rc'h ancf~ Development, U.S. Environmental Radioactive Substances in Water and Fluviali Protection Agency, Cincinnati, Ohio, Sediment s." Chapter AS, llook 5 (Laboratory ,

July 1973. Analysis) of Techniques of Water-Resources .

Investigations of the UniteiiStTtes. Geological'

28. G.C. Eadie and D.E. Bernhardt, " Sampling Burvey, 1977. " Chapter A5 is available from th'i; and Data Reporting Considerations for Air- Superintendent of Documents, U.S. Govern-borne Particulate Activity." U.S. Environ- ment Printing Office, Washington, D.C. 20402,

' mental Protection Agency Technical Note Stock Number 024-001-02928-G. ,

ORP/LV-7G-9, December,1976. i

36. A llandbook of Radioactivity Measurements I

29. ' A.J. Breslin, " Guidance for Air Sampling Proccdu res , RepoTt of NCRP~~SC-18A, ITCIlY at Nuclear Facilities " U.S. Energy Research Report No. 58, 1978.

• and Development Administration Report ilASL-L+ + 312, November 1976. 37. P.E. Shelley, Sampling of Water ~and Wastewater, U.S. Environment ~al ProtectiaH lt

30. " Reference Method for the Determination . Agency Report EPA-600/4-77-039, August j of Suspended Particulate in the Atmosphere 1977.

ll (High Volume Method)," Quality Assurance

38. " Calibration and Usage of Germanium De-l i

Nandbook for Air Pollution Measurement Svs- i

, tems, Volume if~Xmbient Air Spectfie MethTdi, tectors for Measurement of Gamma-Ray Emission' 'l l Section 2 U.S. Envir'5Hhental ProteEtion Rates of Radionuclides," ANSI N42.14-1978. l u Agency Report EPA 600/4-77-027a, May 1977.

39. D.C. Kocher (editor). Nuclear Decay-

31. E.D. Harward (editor), Program Reportt Data for Radionuclides Occurnne in Routtne.

I, '

Workshop on Methods for Measurtng Racbation Rite'ases~ from Nuclear Fuel Cvele 7actlities. ,

g,j In and AroTnd UraniumTillis, report based"'6Ii 6ak Ridge National Laboratorf^ Report ORNL/

presentations made at the workshop held in NUREG/TM-102, August 1977.

Albuquerque, New Mexico, May 23-26, 1977.

s Atomic Industrial Forum, Inc., August 1977. 40. M.J. Martin (editor), Nuclear Decav Data j ,,

for Selected Radionuclides, Oak Ridge National' IJiboratory Report ORNL-5114, March 1976.

32. Measurement of Low-Level Radioactivity,

' g 41. International Directory of Certified Radio-International Comniission on Radiatica Units and Measurements (ICRU) Heport 22, June 1, active Materials , International Atomic Energy

• 1972. Agency Report, STl/ PUB /393,1975.

i 42. Environmental Radioactivity Laboratorv

33. American Public !!calth Association Inter- Intercompanson Siudies -Procrani 197C

• society Committee on Methods of Air Sampling F TO'D/4 *lT-T01, January 19M-' , FY and Analysis Morris Katz (editor), Methods of Air Sampling "and Analysis, Second Edition 7 43. " Guidelines for the Documentation of Asierican Public"Ti'ealth Association,1977. Digital Computer Programs," ANSI N413-1974.

e

?9 N

1 9 l s i 2

I

> 4.15-9 Appendix II f

GLOSSARY Precision-a qualitative concept in the statis- g Accuracy-a. qualitative concept in the statis- tical treatment of measurement data used to tical treatment of measurement data used to de- describe the dispersion of a set of numbers scribe . the agreement between the central with respect to its central tendency.

tendency. of a set of numbers and their correct l:

• value (or the accepted reference value), It is Quality A:;surance (QQ-the planned .and

!, also used to describe the agreement between-an systematic actions that are necessary to pro-I ' individual value and the correct value (or the vide adequate confidence in the results of a accepted reference value). monitoring program.

_y.

Analytical Blank (Sample)-ideally, a sample Quality Control (QC)-those quality assurance .

having alIof; the constituents of the unknown .

~

<- actions that provide a means to control and sample except those to be determined. In ra- measure the chat w teristics of measurement

.- dioanalytical practice, the term often refers to equipment and pr s ssses to established re-5- the radiochemical processing of carrier (s) or quirements. Thus, pality assurance includes I' tracers without the sample matrix material. quality control.

" Blind" Replicate (Sample)-replicate samples Reference Test Material-a large batch of

' 7 that are noTidentified as replicates to the per- homogeneous material ~froT which kliquots may 1,

sons perforining the analysis, be taken for interlaboratory comparisons or for internal use by the laboratory. The material'

. Calibration-the process of determining the

~

must be uniform but need not be standardized.

numerical relationship between the observed L

g output of a measurement system and the value, based on reference standards, of the charac-teristics being measured. Spiked Sample-a sample to which a known Calibration Source-any radioactive - source ' amount of radio' active material has been added. j

. ,~~

Generally, spiked samples are submitted as that i. used for calibration of a measurement l

^ unknowns to the analysts. <

system.

, ], . Split Sample-a ~ homogeneous sample that is f divided into parts, each of which is analyzed

!."*' Check Source (or instrument check source or perferinance check source)-a radioactive source h l

independently by separat.e laboratory organi- ,

L used to determine if the detector and all elec- zations.

' tronic components of the system are operating [

correctly. Standard (radioactive) Source-a radioactive

- source having an accurately known radionu-Instrument Background-the response of the clide content and radioactive decay rate or rate 1: i instruments in the absence of a radioactive sam- of particle or photon emMsion,

.. pie or other radioactive source, ve l

'i he'.

, 1 e

. n "h

I 7p . .

q E

4.15-10 l - - - - __ _