Regulatory Guide 1.33

Quality Assurance Program Requirements (Operation)

ML13350A365
Person / Time
Issue date:	01/31/1977
From:	NRC/OSD
To:
References
RG-1.033, Rev. 1
Download: ML13350A365 (8)

Revision 1 U.S. NUCLEAR REGULATORY COMMISSION January 1977

• REGULATORY GUIDE

OFFICE OF STANDARDS DEVELOPMENT

REGULATORY GUIDE 1.33 QUALITY ASSURANCE PROGRAM REQUIREMENTS

(OPERATION)

A. INTRODUCTION

for the Operational Phase of Nuclear Power Plants.'"

by tile American National Standards Institute on Appendix B, "Quality Assurance Criteria for February 19, 1976.

N2ii'h:* r P~nis.'s, Ph:nl nr anfl Fns't R nrncetcinr'

Plants." to 10 CFR Part 50, "Licensing of Produc- Some uncertainty has arisen with regard to the tion and Utilization Facilities." establishes quality NRC staffs position when a regulatory guide en- assurance requirements for the operation of nuclear dorses. as an acceptable method, the "guidelines as power plant safety-related structures. svstems. and well as the "requirements" included in a standard.

components. This regulatory guide describes a The NRC staff has evaluated the guidelines con- methiid acceptable to the NRC staff for complying tained in N 18.7-1976/ANS-3.2.with respect to impor.

with the Commission's regulations with regard to tance to safety. This~regulatory guide is intended to overall quality assurance program requirements for clarify the NRC .:staff's position on the "re- the operation phase of nuclear power plants. quiretnents" ',anid "guidelines" included in ANSI

N 18.7-1976/NS-3.2.' cWhere conformance to the

B. DISCUSSION

reconimendatiotns-`. of this regulatory puide is in- dicaited inn :.application without further qualifica- Subcommittee ANS-3. Reactor Operations. of the ...* tion.-this indicates thle applicant will comply with the American Nuclear Society Standards Committee*c.>reqUlrcrnent" of ANSI N18.7-1976/ANS-3.2. as developed ANSI N 18.7-1972 that contained critcria t-**sppleiented or modified by the regulatory position for administrative controls for nuclear powerpiants-, *,.of tIis guide.

during operation. This standard. along with.\ANS1'" S

• nc*ection . ... o.

N45.2-1971. "Quality Assurance Pro. .. u.. c... s" tectton i. Scopetd of ANSI NIc.7-19ri/,,aNS-

ments for Nuclear Power Plants, Vus endors&eFdb 3.2 ". "a . ....

Reguator Guide Regulatory Gue .3.1.33. The . , eolaorsewent The, dual dti-. *;or:se'n 1 was,,

" ministrative controls., and .qualitV. assurance .. t for .

- .* . . ,*:; ,,- ..',;,.... nuclear power nlants dutnn the operational h',se of necessary in order for the guidance conta ied in the ' he p,, of regulatory gui. e to btvvonsistent with the require- plant life and that this phase is generally considered ments of Appending' t10 CFR Part 50: however, to commence with initial fuel loading. except for cer- this dualendosem~~ A someconfusionamong tain preoperational activities. In this regard. a users. To is ! ttio*'ii04 ANSI N!8.7-1972 was separate regulatory guide addressing the quality as- revisedso .at - . !ngstandard would define the surance program for the preoperational phase will he ge*g utii nri a*irance program Vu "requirements"

rgam*rqieet* 'tyaba issued. Other regulaory guides may he issued or this for Aimrb 'phase. This revised standard was regulatory, guide may be revised, if necessary, to appr7 d by the American National Standards Coin- amplify the general requirements contained in this mittee* I8. Nuclear Design Criteria. It was sub.,e- standard.

quently approved and designated N 18.7-1976/ANS- Copic%ma. hbeobtained from American Nucle:r Sriciety. 244 IVa.st

3.2. "Administrative Controls and Quality Assurance Ogden Avenue. Htinsdale. Illinoi 60521 USNRC REGULATORY GUIDES C-',avents Should ho' Sam0 to 11h0Srlysetary of It, Corn.rr,',,i U S N., 1'.,i Regulatory Guitdes a'e issued to d scribe and m.,ke Availatble to the, public SRviegltrS oetiron~sr a$.. fin 0,5 treoe o&,

nreithods d cCeptab le to the NAC s.tafft of mp~irem..t~rg specific pat,%of int- Conre,tus'.in s agegatiorns, to delineate tech q.0%tased by sthe.101 .' -0. .. ~The gude' resu,!d

0 in Sthefollowing for%bto.id d-%i'.ns, dm5.3specific prohlemns uspostulated Accullentr of to p'ovide guidwice it) apple cants. Regulatory Guides .sre not substitutill tor regulations. and comipliance I P.ee Rear~~.

I~6 P~odlutts witht then, is not faquited Methods .sndsoluto,'.s different fromt those %atout -~ 2 RC'.Oa,c1,.snt Ti,,1 R.',tct 7 t,.itttit the ofuides. wilt be acceptable it they p~rovide.s abase%"for the find~ng,, requisite to 3FWels .,nslMate',,..m I..,clrte'. 9 Uec-aum.rt1n H-1lt the ,ssuineeo, cooitti itceotatternti or licenste byt the Catnrnnssittn 4 0tr,.eirneent.'.l -tdSoling 9 Antitru'.t tlei.iev Coniroit,e~t anfd ouggestiors toe improvementtels onthese guides are encoruraged 5 Nlatevials.trid PlasntP'otect~oos t0 Generasl

.st alt titos,es..Id guides wilt he retvised. JS appropriate. to ACCOMniUSjtIALUM1 n.1-t .rrd to feflect stew nslornitrristoror experutenr.oHowever. conriiin1t' otn Copies of published guides. mayrbe obtained by wr,otte,.vttuetl -d',di...,i I th'

thi'%guide. it #received wIth,., about two nsor,th%.tle 1%'issuabnce. will he. Lid' divst'ions' de',ouedto top U S Nuclear Regulatory Cuorn-mlaiis W.rsh,,iqtiii' 1) C

tI~ua evao.atl...iq tlre need for an,earty ,esis-on usef'ul ... 2055.Attention Director Ottice of Standard'. Oevelopnsen'"

Appendix A to this guide has been revised as a Design and Procurement Phase of result of comments received on the guide and ad- Nuclear Power Plants," (Grey Book) and ditional staff review. WASH-1309. "Guidance on Quality As- surance Requirements During the

C. REGULATORY POSITION

Construction Phase of Nuclear Power Plants," (Green Book) and will be en- The overall quality assurance program require- dorsed by a regulatory guide upon its ap- ments for the operation phase that are included in proval as an ANSI standard.

ANSI N18.7-1976/ANS-3.2 are acceptable to the NRC staff and provide an adequate basis for comply- 3. Section 4.5, "Audit Program," of ANSI N 18.7- ing with the quality assurance program requirements 1976/A NS-3.2 states that audits of selected aspects of of Appendix B to 10 CFR Part 50, subject to the fol- operational phase activities shall be performed with a lowing: frequency commensurate with their safety significance and in such a manner as to ensure that an I. ANSI NI8.7-1976/ANS-3.2 requires the audit of all safety-related functions is completed preparation of many procedures to carry out an effec- within a period of 2 years. In amplification of this re- tive quality assurance program. Appendix A, quirement, the following program elements should be

"Typical Procedures for Pressurized Water Reactors audited at the indicated frequencies:

and Boiling Water Reactors," to this regulatory guide should be used as guidance to ensure minimum a. The results of actions taken to correct procedural coverage for plant operating activities, in- deficiencies that affect nuclear safety and occur in cluding related maintenance activities. Appendix A facility equipment. structures, systems. or method of lists typical safety-related activities that should be operation-at least once per 6 months.

covered by written procedures but does not provide a complete listing of needed procedures. Many. other b. The conformance of facility operation to activities carried out during the operation phase of a provisions contained within the technical specifica- nuclear power plant require written procedures not tions and applicable license conditions-at least once included in Appendix A. Appendix A may also con- per 12 months.

tain procedures that are not applicable to an appli- cant because of the configuration of the nuclear c. The performance. training, and qualifications power plant. The procedures listed in Appendix A of the facility staff-at least once per 12 months.

may be combined, separated. or deleted to conform to the applicant's procedures plan. 4. The guidelines (indicated by the verb "should")

of ANSI N 18.7-1976/ANS-3.2 contained in the fol-

2. Throughout ANSI N18.7-1976/ANS-3.2, other lowing sections have sufficient .,afety importance to documents required to be included as a part of this be treated the same as the requirements (indicated by standard are identified at the point of reference. The the verb "shall") of the standard:

specific acceptability of these standards listed in ANSI

N 18.7-1976/ANS-3.2 has been addressed in the latest a. Section 4.,4-The guidelines concerning revision of the following regulatory guides: review activities of ihe onsi~e operating organization.

except the guideline that refers to screening subjects ANSI Standard Regulatory Guide of potential concern.

N45.2 1.28 N45.2.1 1.37 b. Section 5.2.3-The guideline concerning N45.2.2 1.38 review and updating of standing orders.

N45.2.3 1.39 c. Section 5.2.4-The guideline concerning N45.2.4 1.30

N45.2.5 1.94 review, updating, and cancellation of special orders.

N45.2.6 1.58 d. Section 5.2.7.1-The guidelines that address N45.2.8 1.116 adequate design and testing of replacement parts.

N45.2.9 1.88 N45.2. 10 1.74 e. Section 5.2.13.4-The guideline concerning N45.2. II 1.64 special handling tools and equipment.

N45.2.13 1.123 N 18.1 1.8 f. Section 5.2.19(2)-The guideline for checking N 18.17 1.17 plant operating procedures during the testing N 101.4 1.54 program.

Note: N45.2.12 is discussed in NRC g. Section 5.2.19.1-The guidelines for documents WASH-1283, "Guidance on preoperational tests, except the guideline that refers Quality Assurance Requirements During to a run-in period for equipmen

t. In addition to these

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guidelines, the prerequisite steps for each equipment Section 5.3.9.1(3): immediate operator action, ex- test should be completed prior to the commencement cluding those guidelines contained in the examples, in oft the preoperational test. Section 5.3.9.1(4): and subsequent operator actions in Section 5.3.9.1(5).

h. Section 5.3.2-The guidelines that describe the content (excluding format) of procedures. except

D. IMPLEMENTATION

for the guidelines that address (I) a separate state- ment of applicability in Section 5.3.2(2). (2) inclusion of references in procedures, as applicable, in Section The purpose of this section is to provide informa-

5.3.2(3). and (3) inclusion of quantitative control tion to applicants and licensees regarding the NRC

guides in Section 5.3.2(6). staff's plans for using this regulatory guide. Except in those cases in which the applicant proposes an alter- i. Section 5.3.9-The guideline concerning native method for complying with specified portions emergency procedures requiring prompt implementa- or the Commission's regulations. the method tion of immediate operator actions when required to described herein will he used in the evaluation ofsub- prevent or mitigate the consequences of a serious inittals for operating license applications docketed condition. after September I. 1977. If an applicant whosc ap- plication for an operating license is docketed on or j. Section 5.3.9.1-The guidelines that describe prior to September I. 1977. wishes to use this the content (excluding format) for: the tith,! in Section regulatory guide in developing submittals for applic.-

5.3.9.1(1): the inclusion of svmploms to aid in iden- lions, the pertinent portions of the application kwill be tificaltion in Section 5.3.9.1(2): automatic actions in evaluated on the basis of this guide.

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APPENDIX A

TYPICAL PROCEDURES FOR PRESSURIZED WATER REACTORS

AND BOILING WATER REACTORS

The following are typical safety-related activities a. Reactor Coolant System that should be covered by written procedures. This b. Control Rod Drive System (including part- appendix is not intended as an inclusive listing of all length rods)

needed procedures since many other activities carried c. Shutdown Cooling System out during the operation phase of nuclear power d. Emergency Core Cooling System plants should be covered by procedures not included e. Component Cooling Water System in this list.

f. Containment

1. Administratiie Procedures (!) Maintaining Containment Integrity

(2) Special Containment Systems a. Security and Visitor Control b. Authorities and Responsibilities for Safe (a) Atmospheric Operation and Shutdown (b) Subatmospheric c. Equipment Control (e.g.. locking and tagging) (c) Double-Wall Containment with Con- d. Procedure Adherence and Temporary Change trolled Interspace Method (d) Ice Condenser e. Procedure Review and Approval f. Schedule for Surveillance Tests and Calibration (3) Containment Ventilation S)stem g. Shift and Relief Turnover (4) Containment Cooling System h. Log Entries, Record Retention, and Review Procedures g. Atmosphere Cleanup Systems i. Access to Containment h. Fuel Storage Pool Purification and Cooling j. Bypass of Safety Functions and Jumper Control System k. Maintenance of Minimum Shift Complement i. Main Steam System and Call-In of Personrel j. Pressurizer Pressure and Spray Control Systems I. Plant Fire Protection Program k. Feedwater System (feedwater pumps to steam m. Communication System Procedures generator)

I. Auxiliary Feedwater System

2. General Plant Operating Procedures m.Service Water System n. Chemical and Volume Control System a. Cold Shutdown to Hot Standby (including Letdown/Purification System)

b. Hot Standby to Minimum Load (nuclear o. Auxiliary or Reactor Building Heating and Ventilation startup)

c. Recovery from Reactor Trip p. Control Room Heating and Ventilation d. Operation at Hot Standby q. Radwaste Building Heating and Ventilation e. Turbine Startup and Synchronization of r. Instrument Air System Generator s. Electrical System f. Changing Load and Load Follow (if applicable)

g. Power Op.ration and Process Monitoring

(1) Offsite (access circuits)

(2) Onsite h. Power Operation with less than Full Reactor Coolant Flow i. Plant Shutdown to Hot Standby (a) Emergency Power Sources (e.g., diesel j. Hot Standby to Cold Shutdown generator, batteries)

k. Preparation for Refueling and Refueling Equip- (b) A.C. System ment Operation (c) D.C. System I. Refueling and Core Alterations t. Nuclear Instrument System

3. Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems (I) Source Range Instructions for energizing, filling, venting, drain-

(2) Intermediate Range

(3) Power Range ing, startup, shutdown, and changing modes of (4) Incore System operation should be prepared, as appropriate, for the following systems:

u. Reactor Control and Protection System

• Linc. indicate substantive changes from previous issue.

v. Hydrogen Recombiner

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4. Procedure for Startup, Operation, and Shutdown of y. Reactor Protection System Safety-Related BWR Systems z. Rod Worth Minimizer Instructions for energizing, filling, venting, drain- 5. Procedures for Abnormal, Offnormal. or Alarm ing, startup, shutdown, and changing modes of Ccnditions operation should be prepared, as appropriate, for the following systems: Since these procedures are numerous and corres- pond to the number of alarm annunciators, the a. Nuclear Steam Supply System (Vessel and Re- procedures are not individually listed. Each safety- circulating System) related annunciator should have its own written b. Control Rod Drive System procedure, which should normally contain (I) the c. Reactor Cleanup System meaning of the annunciator, (2) the source of the d. Liquid Poison System (Standby Liquid Control signal, (3) the immediate action that is to occur System) automatically, (4) the immediate operator action, and e. Shutdown Cooling and Reactor Vessel Head (5) the long-range actions.

Spray System.

6. Procedures for Combating Emergencies and Other f. High Pressure Coolant Injection g. Reactor Core Isolation Cooling System Significant Fients h. Emergency Core Cooling Systems a. Loss of Coolant (including significant PWR

i. Closed Cooling Water System steam generator leaks) (inside and outside primary j. Containment containment) (large and small, including leak-rate (I) Maintaining Integrity determination)

(2) Containment Ventilation System b. Loss of Instrument Air

(3) Inerting and Deinerting c. Loss of Electrical Power (and/or degraded power sources)

k. Fuel Storage Pool Purification and Cooling d. Loss of Core Coolant Flow System c. Loss of Condenser Vacuum I. Main Steam System (reactor vessel to turbine) f. Loss of Containment Integrity m.Turbine-Generator System g. Loss of Service Water n. Condensate System (hotwell to feedwater h. Loss of Shutdown Cooling pumps. including demineralizers and resin i. Loss of Component Cooling System and Cool- regeneration) ing to Individual Components o. Feedwater System (feedwater pumps to reactor j. Loss of Feedwater or Feedwater System Failure vessel) k. Loss of Protective System Channel p. Makeup System (filtration, purification, mid I. Mispositioned Control Rod or Rods (and rod water transfer) drops)

q. Service Water System m.Inability to Drive Control Rods r. Reactor Building Heating and Ventilation n. Conditions Requiring Use of Emergency Bora- Systems tion or Standby Liquid Control System s. Control Room Heating and Ventilation Systems o. Fuel Cladding Failure or High Activity in Reac- t. Radwaste Building Heating and Ventilation tor Coolant or Offgas Systems p. Fire in Control Room or Forced Evacuation of u. Standby Gas Treatment System Control Room v. Instrument Air System q. Turbine and Generator Trips w. Electrical System r. Other Expected Transients that may be Ap- plicable (I) Offsite (access circuits) s. Malfunction of Automatic Reactivity Control

(2) Onsite System t. Malfunction of Pressure Control System (a) Emergency Power Sources (e.g.. diesel u. Reactor Trip generator, batteries) v. Plant Fires (b) A.C. System w.Acts of Nature (e.g.. tornado, flood, dam (c) D.C. System failure, earthquakes)

x. Irradiated Fuel Damage While Refueling x. Nuclear Instrument System y. Abnormal Releases of Radioactivity

7. Procedures for Control of Radioactiity For (i) Source Range limiting materials released to emironment and

(2) Intermediate Range limiting personnel exposure)

(3) Power Range

(4) TIP System a. Liquid Radioactive Waste System

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(I) Collection, Demineralizing, Filtering. (1) Pressurized Water Reactors Evaporating and Concentrating, and Neutralizing

(2) Sampling and Monitoring (a) Containment Leak-Rate Tests

(3) Discharging to Effluents (b) Containment Isolation Tests (c) Containment Local Leak Detection Tests b. Solid Waste System (d) Containment Heat and Radioactivity Removal Systems Tests (I) Spent Resins and Filter Sludge Handling (e) Containment Tendon Tests and Inspec-

(2) Baling Machine Operation tions

(3) Drum Handling and Storage (f) Service Water System Functional Tests (g) Main Steam Isolation Valve Tests c. PWR Gas Systems (h) Fire Protection System Functional Tests (i) Boric Acid Tanks-Level Instrumenta-

(1) Collection, Storage, and Discharge tion Calibrations

(2) Sampling and Monitoring (j) Emergency Core Cooling System Tests

(3) Air Ejector and Stack Monitoring (k) Control Rod Operability and Scram Time

(4) Clean Air Monitoring Tests

(1) Reactor Protection System Tests and d. BWR Air Extraction and Offgas Treatment Calibrations I System (m) Permissives-Tests and Calibrations (n) Refueling System Circuit Tests

(1) Mechanical Vacuum Pump Operation (o) Emergency Boration System Functional

(2) Air Ejector Operation Tests

(3) Packing Steam Exhauster Operation (p) DNB Checks and Incore-Excore Flux

(4) Sampling Monitor Correlations

(5) Air Ejector and Stack Monitoring (q) Emergency Power Tests e. Personnel Monitoring and Special Work Permit (r) Auxiliary Feedwater System Tests (s) NSSS Pressurization and Leak Detection (I) Restrictions and Activities in Radiation (t) Inspection of Reactor Coolant System Areas and High Radiation Areas Pressure Boundary

(2) Respirator Equipment (u) Inspection of Pipe Hanger Settings

(3) Surveys and Monitoring (v) Control Rod Drive System Functional

(4) Protective Clothing Tests

(5) Radiation Work Permit Procedure (w) Heat Balance-Flux Monitor Calibra- tions r, Area Radiation Monitoring System Operation (x) Pressurizer and Main Steam Safety Valve g. Process Radiation Monitoring System Opera- Tests tion (y) Leak Detection Systems Tests h. Meteorological Monitoring (z) Axial and Radial Flux Pattern Deter- minations

8. Procedures for Control of Measuring and Test Equipment and for Suncillance Tests. Procedures. (aa) Area Radiation Monitor Calibrations and Calibrations (bb) Process Radiation Monitor Calibrations (cc) Environmental Monitor Calibrations (dd) Safety Valve Tests a. Procedures of a type appropriate to the circum- (ee) Turbine Overspeed Trip Tests stances should be provided to ensure that tools, (f) Water Storage Tanks-Level In- gauges, instruments, controls, and other measuring strumentation Calibration and testing devices are properly controlled, calibrated, and adjusted at specified periods to main- tain accuracy. Specific examples of such equipment (2) Boiling Water Reactors to be calibrated and tested are readout instruments, interlock permissive and prohibit circuits, alarm (a) Containment Leak-Rate and Penetration devices, sensors, signal conditioners, controls, protec- tive circuits, and laboratory equipment. Leak-Rate Tests (b) Containment Isolation Tests (c) Containment Vacuum Relief Valve Tests b. Specific procedures for surveillance tests, in- (d) Containment Spray System Tests spections, and calibrations should be written (e) Standby Gas Treatment System Tests (implementing procedures are required for each sur- (including filter tests)

veillance test, inspection, or calibration listed in the (M) Main Steam Isolation Valve Tests technical specifications): (g) Nitrogen Inerting System Tests

1 33-6

(h) Reactor Building Inleakage Tests the plant should preferably he written early in plant (i) Emergency Core Cooling System Tests life. The following are examples of such procedures (j) Control Rod Operability and Scram Time for major equipment:

Tests (k) Reactor Protection System Tests and (I) Repair of PWR Steam Generator 'rubes Calibrations (2) Replacement and Repair of Control Rod (I) Rod Blocks-Tests and Calibrations Drives (m) Refueling System Circuit Tests (3) Replacement of Recirculation Pump Seals (n) Liquid Poison System Tests (4) Replacement of Important Strainers and (o) Minimum Critical Heat Flux Checks and Filters Incore Flux Monitor Calibrations (5) Repair or Replacement of Safety Valves (p) Emergency Power Tests (6) Repair of Incore Flux Monitoring System (q) Isolation Condenser or RCIC Tests (7) Replacement of Neutron Detectors (r) NSSS Pressurization and Leak Detection (s) Inspection of Reactor Coolant System d. Procedures that could he categorized either as Pressure Boundary maintenance or operating procedures should he (t) Inspection of Pipe Hanger Settings developed for the following activities. Instructions (u) Control Rod Drive System Functional for these activities may be included in systems Tests procedures.

(v) Heat Balance (w) Safety Valve Tests (I) Exercise of equipment that is normally idle (x) Turbine Overspeed Trip Test but that must operate %%hen required

(2) Draining and Refilling Heat Exchangers

09 Leak Detection System Tests (3) Draining and Refilling Recirculation Loop (z) Autoblowdown System Tests (aa) Axial and Radial Flux Pattern Deter- (4) Draining and Refilling the Reactor Vessel minations (5) Draining and Refilling Steam Generators (bb) Area Radiation Monitoring Calibrations (6) Removal of Reactor Head (cc) Process Radiation Monitoring Calibra- (7) Disconnection and Reconnection of Wiring tions Penetrating Reactor Vessel Head (dd) Water Storage Tanks-Level In- (8) Demineralizer Resin Regeneration or strumentation Calibrations Replacement (ee) Fire Protection System Functional Tests e. General procedures for the control of maintenance, repair. replacement, and modification

9. Procedures for Performing Maintenance work should be prepared before reactor eperation is begun. These procedures should include information a. Maintenance that can affect the performance of on areas such as the following:

safety-related equipment should be properly preplan- ned and performed in accordance with written (I) Method for obtaining permission and procedures, documented instructions, or drawings clearance for operation personnel to work and for appropriate to the circumstances. Skills normally logging such work and possessed by qualified maintenance personnel may (2) Factors to be taken into account, including not require detailed step-by-step delineation in a the necessity for minimizing radiation exposure to procedure. The following types of activities are workmen, in preparing the detailed work procedures.

among those that may not require detailed step-by- step written procedures: 10. Chemical and Radiochemical Control I'rcedure,

(1) Gasket Replacement Chemical and radiochemical control procedures

(2) Trouble-Shooting Electrical Circuits should be written to prescribe the nature and fre-

(3) Changing Chart or Drive Speed Gears or quency of sampling and analyses. the instructions Slide Wires on Recorders maintaining water quality within prescribed limits.

and the limitations on concentrations of agents that b. Preventive maintenance schedules should be may cause corrosive attack or fouling of heat-transfer developed to specify lubrication schedules, inspec- surfaces or that may become sources of radiation tions of equipment, replacement of such items as hazards due to activation. These procedures should filters and strainers, and inspection or replacement of specify laboratory instructions and calibration of parts that have a specific lifetime such as wear rings. laboratory equipment. Extreme importance must he placed on laboratory procedures used to determine c. Procedures for the repair or replacement of concentration and species of radioactivity in liquids equipment should be prepared prior to beginning and gases prior to release, including representative work. Such procedures for major equipment that is sampling, validity of calibration techniques. and ade- expected to be repaired or replaced during the life of quacy of analyses.

1.33-7

UNITECV STATES

NUCLE~AR REGUiLATORY COMMISSION

WA%.INGTON, D. C. 20555 POSTAGE AN40 PIES PAID

U.S NUCLEAR REGULATORY

OFFICIAL BUSINESS COMMISSION

I'( NALTY IFOR PRIVAITE USE. $300

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