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ECCLOSURE 2 m' -
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. April 20, 1982 l 14CMORA'.D3 FOR: R. J. Mattson, Director, Division of Systems Integration, f;RR THRU: John T. Collins, Regional Administrator, Region I ' f l FRGM: Glen D. Brown, Chief, Technical Frogram Branch,_ Region IV -
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SUBJECT:
It'.PLEMEN11NG PROCT 0VRES FOR fiUREG-0737,11EM ll,F.1 This Region is in the procers of reviewing licensee implerienting procedures for the roble ges ef fluent nonitors and contain..ent high-range radiation monitors described in f.UREG-0737., item JI.F.1, Attachments 1 and 3. As a result of these initial reviews, several problem arcas have been identified l
l regarding established guidance for an acceptable program for these instru:ents. Under normal operating conditions, this Region has usually
,. required that licensees satisfy the recorm.endations of AN51-N323-1978 for j fined area conitors and ef fluent monitors. At:51-h323 recorrends that instrur+-ts he calibrated with radiation sources over the range of the instrunent at approximately 20% and 80% of full scale and be within
!20% of the known value. The following is a discussion of some of the concerns:
- 1. fioble Gas Effluent Monitors (
MC 2515, inspection Procedure 84710 requires the inspector to verify that etfhent monitors are calibrated over the entire range with a radioactive source traccable to the !!ational Bureau of Standards. Licensees normally calibrate noble gagnonitors by filling the sample charcer with various con:entrations of Kr. For pre-THI instrur atation, concentrations bet.een about E-05 uti/cc - E-02 uti/cc were required to establish '
calibr.ition points at 1/4,1/2, and 3/4 of the full scale range.
iGIG-0737 new requires raonitors with an upper range capacity of j
[405 uCi/cc. Some of the problems involved with !.UREG-0737 noble gas ef f ?uent monitors include:
85 i . Availability of Kr in concentrations cf E40: uti/cc.
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.Will full range gas calibrations be s equir ed?
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. AL ARA considerations associated with handling [405 uCi/cc calibration sources. g 6C j p# o
.. 9e R. J. Mattson *
. 2. Containment High-Range Monitors NUREG-0737 acknowledges the difficulties of performing a full range calibration of the containment monitors. As such, the NUREG only requires a radioactive source calibration at one decade below 10 R/h for installed monitors. This establishes a calibration point at about 0.00001 percent of the full scale range. An electronic response test of the electrical circuit is considered acceptable for ranges above 10 R/h.
Some of the concerns with the containment monitors include: .
.Is it necessary to periodically demonstrate that the detector will properly respond to a radiation source over the designated range (E407 R/h)?
. Licensees have stated that it is dif ficult to obtain pulse generators with the necessary range to perform full scale electronic response tests of the electrical circuit.
.Should procedures include calculations for converting mc,nitor readings (R/h) into concentrations (uti/cc) for dose. assessments?
Discussions with other Regions indicate that a uniform approach has not been taken regarding the review of item II.F.1 instrumentation. With some licensees, it appears that the review of installed instrumentation and implementing procedures is folic,wed closely'as part of routine inspections. These reviews show that certain licensees have expended a considerable ef fort in establishing a comprehensive program. However, workload demands in some Regions are such that only limited reviews have been possible. ,
The above concerns have been discussed with Doug Collins, RAB and Dave l Verrelli, ORAB. rrom these discussions, it is our understanding that NRR l plans to initirt:: a post-implementation review of NUREG-0737 items. We assume that this review will include participation by Regional personnel.
Before such a review is started, it is suggested that representatives from fiRR and the Regions convene for the purpose of establishing guidelines for an acceptable program. Items that should be discussed include:
.iechnical Specification requirements i
. Surveillance frequencies for checks, tests, and calibrations
.Ccmpliance with ANSI standards, tiRC Inspection procedures, Fegulatory Guides, etc. >
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- 2 t R. J. Mattson '
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.ALARA considerations ip ,
. Calibration sources f
. Electronic response tests
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. Dose assessrent requiren,ents
. Periodic verification of full range detector response i 1 l G_
- . Acceptance Criteria i'
Jr Af ter guidelines are established, this inforr.ation should be made f=
available to the licensees and included in MC 2515 inspection J procedures.
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, /A G n . ro.m. Chief J
Technical Program Branch g
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cc: Regional Adminis'.rators
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H. R. Denton, NM R- R. C. DeYoung, NRR R. W. Houston, NRR hl
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J. M. Taylor, IE B. K. Grimes , IE i '
C. A. Hackney , RIV -
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