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 1January 1977U.S. NUCLEAR REGULATORY COMMISSION* REGULATORY GUIDEOFFICE OF STANDARDS DEVELOPMENTREGULATORY GUIDE 1.33QUALITY ASSURANCE PROGRAM REQUIREMENTS(OPERATION)

A. INTRODUCTION

Appendix B, "Quality Assurance Criteria forN2 r P~nis.'s, Ph:nl nr anfl Fns't R nrncetcinr'for the Operational Phase of Nuclear Power Plants.'"by tile American National Standards Institute onFebruary 19, 1976.Plants." to 10 CFR Part 50, "Licensing of Produc- Some uncertainty has arisen with regard to thetion 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 aspower 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 tooverall 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 ANSIN 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 theAmerican Nuclear Society Standards of ANSI N18.7-1976/ANS-3.2. asdeveloped ANSI N 18.7-1972 that contained critcria or modified by the regulatory positionfor administrative controls for nuclear powerpiants-, tIis guide.during operation. This standard. along with.\ANS1'" S * .... 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 Gue .3. The, dti-. ., 1 " ministrative controls and qualitV assurance forRegulatory Guide 1.33. The dual eolaorsewent was,, ., ....t .-...,,- ..', ;,.... nuclear power nlants dutnn the operational h',se ofnecessary in order for the guidance conta ied in the he ' p,, ofregulatory gui. e to btvvonsistent with the require- plant life and that this phase is generally consideredments 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. ausers. To is ! 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 henri utii a*irance program "requirements" issued. Other regulaory guides may he issued or thisVu 'tyaba rgam*rqieet*for Aimrb 'phase. This revised standard was regulatory, guide may be revised, if necessary, toappr7 d by the American National Standards Coin- amplify the general requirements contained in thisI8. Nuclear Design Criteria. It was sub.,e- standard.quently approved and designated N 18.7-1976/ANS- Copic% ma. hbe obtained from American Nucle:r Sriciety. 244 IVa.st3.2. "Administrative Controls and Quality Assurance Ogden Avenue. Htinsdale. Illinoi 60521USNRC REGULATORY GUIDES C-',avents Should ho' Sam0 to 11h0 Srlysetary of It, Corn.rr,',,i U S N., 1'.,iRegulatory Guitdes a'e issued to d scribe and m.,ke Availatble to the, public SRviegltr S oetiron~sr a$.. fin 0,5 treoe o&,nreithods d c Ceptab 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 0 gude resu,!d in Sthe following for% bto.id d-%i'.ns,dm5.3 specific prohlemns us postulated Accullentr of to p'ovide guidwice it) applecants. Regulatory Guides .sre not substitutill tor regulations. and comipliance I P.ee Rear~~. I~6 P~odluttswitht then, is not faquited Methods .snd soluto,'.s different fromt those %at out -~ 2 RC'.Oa,c1, .snt Ti,,1 R.',tct 7 t,.itttitthe of uides. wilt be acceptable it they p~rovide.s abase%" for the find~ng,, requisite to 3FWels .,nsl Mate',,..m I..,clrte'. 9 Uec-aum.rt1n H-1ltthe ,ssuineeo, cooitti itceotatternti or licenste byt the Catnrnnssittn 4 0tr,.eirneent.'.l -td Soling 9 Antitru'.t tlei.ievConiroit,e~t anfd ouggestiors toe improvementtels on these guides are encoruraged 5 Nlatevials.trid Plasnt P'otect~oos t0 Generasl.st alt titos,es ..Id guides wilt he retvised. JS appropriate. to ACCOMniUSjtIA LUM1n.1-t .rrd to f eflect stew nslornitrristor or experutenr.o However. conriiin1t' otn Copies of published guides. mayr be 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',oued to top U S Nuclear Regulatory Cuorn-mlaiis W.rsh,,iqtiii' 1) CtI~ua usef'ul ... evao.atl... iq tlre need for an, earty ,esis-on 2055. Attention Director Ottice of Standard'. Oevelopnsen'"

Appendix A to this guide has been revised as aresult of comments received on the guide and ad-ditional staff review.

C. REGULATORY POSITION

The overall quality assurance program require-ments for the operation phase that are included inANSI N18.7-1976/ANS-3.2 are acceptable to theNRC staff and provide an adequate basis for comply-ing with the quality assurance program requirementsof Appendix B to 10 CFR Part 50, subject to the fol-lowing:I. ANSI NI8.7-1976/ANS-3.2 requires thepreparation of many procedures to carry out an effec-tive quality assurance program. Appendix A,"Typical Procedures for Pressurized Water Reactorsand Boiling Water Reactors," to this regulatoryguide should be used as guidance to ensure minimumprocedural coverage for plant operating activities, in-cluding related maintenance activities. Appendix Alists typical safety-related activities that should becovered by written procedures but does not provide acomplete listing of needed procedures. Many. otheractivities carried out during the operation phase of anuclear power plant require written procedures notincluded in Appendix A. Appendix A may also con-tain procedures that are not applicable to an appli-cant because of the configuration of the nuclearpower plant. The procedures listed in Appendix Amay be combined, separated. or deleted to conformto the applicant's procedures plan.2. Throughout ANSI N18.7-1976/ANS-3.2, otherdocuments required to be included as a part of thisstandard are identified at the point of reference. Thespecific acceptability of these standards listed in ANSIN 18.7-1976/ANS-3.2 has been addressed in the latestrevision of the following regulatory guides:Design and Procurement Phase ofNuclear Power Plants," (Grey Book) andWASH-1309. "Guidance on Quality As-surance Requirements During theConstruction Phase of Nuclear PowerPlants," (Green Book) and will be en-dorsed by a regulatory guide upon its ap-proval as an ANSI standard.3. Section 4.5, "Audit Program," of ANSI N 18.7-1976/A NS-3.2 states that audits of selected aspects ofoperational phase activities shall be performed with afrequency commensurate with their safetysignificance and in such a manner as to ensure that anaudit of all safety-related functions is completedwithin a period of 2 years. In amplification of this re-quirement, the following program elements should beaudited at the indicated frequencies:a. The results of actions taken to correctdeficiencies that affect nuclear safety and occur infacility equipment. structures, systems. or method ofoperation-at least once per 6 months.b. The conformance of facility operation toprovisions contained within the technical specifica-tions and applicable license conditions-at least onceper 12 months.c. The performance. training, and qualificationsof the facility staff-at least once per 12 months.4. The guidelines (indicated by the verb "should")of ANSI N 18.7-1976/ANS-3.2 contained in the fol-lowing sections have sufficient .,afety importance tobe treated the same as the requirements (indicated bythe verb "shall") of the standard:a. Section 4.,4-The guidelines concerningreview activities of ihe onsi~e operating organization.except the guideline that refers to screening subjectsof potential concern.b. Section 5.2.3-The guideline concerningreview and updating of standing orders.c. Section 5.2.4-The guideline concerningreview, updating, and cancellation of special orders.d. Section 5.2.7.1-The guidelines that addressadequate design and testing of replacement parts.e. Section 5.2.13.4-The guideline concerningspecial handling tools and equipment.f. Section 5.2.19(2)-The guideline for checkingplant operating procedures during the testingprogram.g. Section 5.2.19.1-The guidelines forpreoperational tests, except the guideline that refersto a run-in period for equipment. In addition to theseANSI StandardN45.2N45.2.1N45.2.2N45.2.3N45.2.4N45.2.5N45.2.6N45.2.8N45.2.9N45.2. 10N45.2. IIN45.2.13N 18.1N 18.17N 101.4Regulatory Guide1.281.371.381.391.301.941.581.1161.881.741.641.1231.81.171.54Note: N45.2.12 is discussed in NRCdocuments WASH-1283, "Guidance onQuality Assurance Requirements During1.33-2 U ----guidelines, the prerequisite steps for each equipmenttest should be completed prior to the commencementoft the preoperational test.h. Section 5.3.2-The guidelines that describethe content (excluding format) of procedures. exceptfor the guidelines that address (I) a separate state-ment of applicability in Section 5.3.2(2). (2) inclusionof references in procedures, as applicable, in Section5.3.2(3). and (3) inclusion of quantitative controlguides in Section 5.3.2(6).i. Section 5.3.9-The guideline concerningemergency procedures requiring prompt implementa-tion of immediate operator actions when required toprevent or mitigate the consequences of a seriouscondition.j. Section 5.3.9.1-The guidelines that describethe content (excluding format) for: the tith,! in Section5.3.9.1(1): the inclusion of svmploms to aid in iden-tificaltion in Section 5.3.9.1(2): automatic actions inSection 5.3.9.1(3): immediate operator action, ex-cluding those guidelines contained in the examples, inSection 5.3.9.1(4): and subsequent operator actions inSection 5.3.9.1(5).

D. IMPLEMENTATION

The purpose of this section is to provide informa-tion to applicants and licensees regarding the NRCstaff's plans for using this regulatory guide. Except inthose cases in which the applicant proposes an alter-native method for complying with specified portionsor the Commission's regulations. the methoddescribed herein will he used in the evaluation ofsub-inittals for operating license applications docketedafter September I. 1977. If an applicant whosc ap-plication for an operating license is docketed on orprior to September I. 1977. wishes to use thisregulatory guide in developing submittals for applic.-lions, the pertinent portions of the application kwill beevaluated on the basis of this guide.1.33-3 APPENDIX ATYPICAL PROCEDURES FOR PRESSURIZED WATER REACTORSAND BOILING WATER REACTORSThe following are typical safety-related activitiesthat should be covered by written procedures. Thisappendix is not intended as an inclusive listing of allneeded procedures since many other activities carriedout during the operation phase of nuclear powerplants should be covered by procedures not includedin this list.1. Administratiie Proceduresa. Security and Visitor Controlb. Authorities and Responsibilities for SafeOperation and Shutdownc. Equipment Control (e.g.. locking and tagging)d. Procedure Adherence and Temporary ChangeMethode. Procedure Review and Approvalf. Schedule for Surveillance Tests and Calibrationg. Shift and Relief Turnoverh. Log Entries, Record Retention, and ReviewProceduresi. Access to Containmentj. Bypass of Safety Functions and Jumper Controlk. Maintenance of Minimum Shift Complementand Call-In of PersonrelI. Plant Fire Protection Programm. Communication System Procedures2. General Plant Operating Proceduresa. Cold Shutdown to Hot Standbyb. Hot Standby to Minimum Load (nuclearstartup)c. Recovery from Reactor Tripd. Operation at Hot Standbye. Turbine Startup and Synchronization ofGeneratorf. Changing Load and Load Follow (if applicable)g. Power Op.ration and Process Monitoringh. Power Operation with less than Full ReactorCoolant Flowi. Plant Shutdown to Hot Standbyj. Hot Standby to Cold Shutdownk. Preparation for Refueling and Refueling Equip-ment OperationI. Refueling and Core Alterations3. Procedures for Startup, Operation, and Shutdownof Safety-Related PWR SystemsInstructions for energizing, filling, venting, drain-ing, startup, shutdown, and changing modes ofoperation should be prepared, as appropriate, for thefollowing systems:* Linc. indicate substantive changes from previous issue.a. Reactor Coolant Systemb. Control Rod Drive System (including part-length rods)c. Shutdown Cooling Systemd. Emergency Core Cooling Systeme. Component Cooling Water Systemf. Containment(!) Maintaining Containment Integrity(2) Special Containment Systems(a) Atmospheric(b) Subatmospheric(c) Double-Wall Containment with Con-trolled Interspace(d) Ice Condenser(3) Containment Ventilation S)stem(4) Containment Cooling Systemg. Atmosphere Cleanup Systemsh. Fuel Storage Pool Purification and CoolingSystemi. Main Steam Systemj. Pressurizer Pressure and Spray Control Systemsk. Feedwater System (feedwater pumps to steamgenerator)I. Auxiliary Feedwater Systemm.Service Water Systemn. Chemical and Volume Control System(including Letdown/Purification System)o. Auxiliary or Reactor Building Heating andVentilationp. Control Room Heating and Ventilationq. Radwaste Building Heating and Ventilationr. Instrument Air Systems. Electrical System(1) Offsite (access circuits)(2) Onsite(a) Emergency Power Sources (e.g., dieselgenerator, batteries)(b) A.C. System(c) D.C. Systemt. Nuclear Instrument System(I) Source Range(2) Intermediate Range(3) Power Range(4) Incore Systemu. Reactor Control and Protection Systemv. Hydrogen Recombiner1.33-4 I--4. Procedure for Startup, Operation, and Shutdown ofSafety-Related BWR SystemsInstructions for energizing, filling, venting, drain-ing, startup, shutdown, and changing modes ofoperation should be prepared, as appropriate, for thefollowing systems:a. Nuclear Steam Supply System (Vessel and Re-circulating System)b. Control Rod Drive Systemc. Reactor Cleanup Systemd. Liquid Poison System (Standby Liquid ControlSystem)e. Shutdown Cooling and Reactor Vessel HeadSpray System.f. High Pressure Coolant Injectiong. Reactor Core Isolation Cooling Systemh. Emergency Core Cooling Systemsi. Closed Cooling Water Systemj. Containment(I) Maintaining Integrity(2) Containment Ventilation System(3) Inerting and Deinertingk. Fuel Storage Pool Purification and CoolingSystemI. Main Steam System (reactor vessel to turbine)m.Turbine-Generator Systemn. Condensate System (hotwell to feedwaterpumps. including demineralizers and resinregeneration)o. Feedwater System (feedwater pumps to reactorvessel)p. Makeup System (filtration, purification, midwater transfer)q. Service Water Systemr. Reactor Building Heating and VentilationSystemss. Control Room Heating and Ventilation Systemst. Radwaste Building Heating and VentilationSystemsu. Standby Gas Treatment Systemv. Instrument Air Systemw. Electrical System(I) Offsite (access circuits)(2) Onsite(a) Emergency Power Sources (e.g.. dieselgenerator, batteries)(b) A.C. System(c) D.C. Systemx. Nuclear Instrument System(i) Source Range(2) Intermediate Range(3) Power Range(4) TIP Systemy. Reactor Protection Systemz. Rod Worth Minimizer5. Procedures for Abnormal, Offnormal. or AlarmCcnditionsSince these procedures are numerous and corres-pond to the number of alarm annunciators, theprocedures are not individually listed. Each safety-related annunciator should have its own writtenprocedure, which should normally contain (I) themeaning of the annunciator, (2) the source of thesignal, (3) the immediate action that is to occurautomatically, (4) the immediate operator action, and(5) the long-range actions.6. Procedures for Combating Emergencies and OtherSignificant Fientsa. Loss of Coolant (including significant PWRsteam generator leaks) (inside and outside primarycontainment) (large and small, including leak-ratedetermination)b. Loss of Instrument Airc. Loss of Electrical Power (and/or degradedpower sources)d. Loss of Core Coolant Flowc. Loss of Condenser Vacuumf. Loss of Containment Integrityg. Loss of Service Waterh. Loss of Shutdown Coolingi. Loss of Component Cooling System and Cool-ing to Individual Componentsj. Loss of Feedwater or Feedwater System Failurek. Loss of Protective System ChannelI. Mispositioned Control Rod or Rods (and roddrops)m.Inability to Drive Control Rodsn. Conditions Requiring Use of Emergency Bora-tion or Standby Liquid Control Systemo. Fuel Cladding Failure or High Activity in Reac-tor Coolant or Offgasp. Fire in Control Room or Forced Evacuation ofControl Roomq. Turbine and Generator Tripsr. Other Expected Transients that may be Ap-plicables. Malfunction of Automatic Reactivity ControlSystemt. Malfunction of Pressure Control Systemu. Reactor Tripv. Plant Firesw.Acts of Nature (e.g.. tornado, flood, damfailure, earthquakes)x. Irradiated Fuel Damage While Refuelingy. Abnormal Releases of Radioactivity7. Procedures for Control of Radioactiity Forlimiting materials released to emironment andlimiting personnel exposure)a. Liquid Radioactive Waste System1.33-5 (I) Collection, Demineralizing, Filtering.Evaporating and Concentrating, and Neutralizing(2) Sampling and Monitoring(3) Discharging to Effluentsb. Solid Waste System(I)(2)(3)Spent Resins and Filter Sludge HandlingBaling Machine OperationDrum Handling and Storagec. PWR Gas Systems(1)(2)(3)(4)Collection, Storage, and DischargeSampling and MonitoringAir Ejector and Stack MonitoringClean Air Monitoring(1) Pressurized Water Reactors(a) Containment Leak-Rate Tests(b) Containment Isolation Tests(c) Containment Local Leak Detection Tests(d) Containment Heat and RadioactivityRemoval Systems Tests(e) Containment Tendon Tests and Inspec-tions(f) Service Water System Functional Tests(g) Main Steam Isolation Valve Tests(h) Fire Protection System Functional Tests(i) Boric Acid Tanks-Level Instrumenta-tion Calibrations(j) Emergency Core Cooling System Tests(k) Control Rod Operability and Scram TimeTests(1) Reactor Protection System Tests andCalibrations(m) Permissives-Tests and Calibrations(n) Refueling System Circuit Tests(o) Emergency Boration System FunctionalTests(p) DNB Checks and Incore-Excore FluxMonitor Correlations(q) Emergency Power Tests(r) Auxiliary Feedwater System Tests(s) NSSS Pressurization and Leak Detection(t) Inspection of Reactor Coolant SystemPressure Boundary(u) Inspection of Pipe Hanger Settings(v) Control Rod Drive System FunctionalId. BWR Air Extraction and Offgas TreatmentSystem(1)(2)(3)(4)(5)Mechanical Vacuum Pump OperationAir Ejector OperationPacking Steam Exhauster OperationSamplingAir Ejector and Stack Monitoringe. Personnel Monitoring and Special Work Permit(I) Restrictions and Activities in RadiationAreas and High Radiation Areas(2) Respirator Equipment(3) Surveys and Monitoring(4) Protective Clothing(5) Radiation Work Permit Procedurer, Area Radiation Monitoring System Operationg. Process Radiation Monitoring System Opera-tionh. Meteorological Monitoring8. Procedures for Control of Measuring and TestEquipment and for Suncillance Tests. Procedures.and Calibrationsa. Procedures of a type appropriate to the circum-stances should be provided to ensure that tools,gauges, instruments, controls, and other measuringand testing devices are properly controlled,calibrated, and adjusted at specified periods to main-tain accuracy. Specific examples of such equipmentto be calibrated and tested are readout instruments,interlock permissive and prohibit circuits, alarmdevices, sensors, signal conditioners, controls, protec-tive circuits, and laboratory equipment.b. Specific procedures for surveillance tests, in-spections, and calibrations should be written(implementing procedures are required for each sur-veillance test, inspection, or calibration listed in thetechnical specifications):TeststionsTests(w) Heat Balance-Flux Monitor Calibra-(x) Pressurizer and Main Steam Safety Valve(y) Leak Detection Systems Tests(z) Axial and Radial Flux Pattern Deter-minations(aa) Area Radiation Monitor Calibrations(bb) Process Radiation Monitor Calibrations(cc) Environmental Monitor Calibrations(dd) Safety Valve Tests(ee) Turbine Overspeed Trip Tests(f) Water Storage Tanks-Level In-strumentation Calibration(2) Boiling Water Reactors(a) Containment Leak-Rate and PenetrationLeak-Rate Tests(b)(c)(d)(e)(including(M)(g)Containment Isolation TestsContainment Vacuum Relief Valve TestsContainment Spray System TestsStandby Gas Treatment System Testsfilter tests)Main Steam Isolation Valve TestsNitrogen Inerting System Tests1 33-6 (h) Reactor Building Inleakage Tests(i) Emergency Core Cooling System Tests(j) Control Rod Operability and Scram TimeTests(k) Reactor Protection System Tests andCalibrations(I) Rod Blocks-Tests and Calibrations(m) Refueling System Circuit Tests(n) Liquid Poison System Tests(o) Minimum Critical Heat Flux Checks andIncore Flux Monitor Calibrations(p) Emergency Power Tests(q) Isolation Condenser or RCIC Tests(r) NSSS Pressurization and Leak Detection(s) Inspection of Reactor Coolant SystemPressure Boundary(t) Inspection of Pipe Hanger Settings(u) Control Rod Drive System FunctionalTests(v)(w)(x)09(z)(aa)minations(bb)(cc)tionsHeat BalanceSafety Valve TestsTurbine Overspeed Trip TestLeak Detection System TestsAutoblowdown System TestsAxial and Radial Flux Pattern Deter-Area Radiation Monitoring CalibrationsProcess Radiation Monitoring Calibra-(dd) Water Storage Tanks-Level In-strumentation Calibrations(ee) Fire Protection System Functional Tests9. Procedures for Performing Maintenancea. Maintenance that can affect the performance ofsafety-related equipment should be properly preplan-ned and performed in accordance with writtenprocedures, documented instructions, or drawingsappropriate to the circumstances. Skills normallypossessed by qualified maintenance personnel maynot require detailed step-by-step delineation in aprocedure. The following types of activities areamong those that may not require detailed step-by-step written procedures:(1) Gasket Replacement(2) Trouble-Shooting Electrical Circuits(3) Changing Chart or Drive Speed Gears orSlide Wires on Recordersb. Preventive maintenance schedules should bedeveloped to specify lubrication schedules, inspec-tions of equipment, replacement of such items asfilters and strainers, and inspection or replacement ofparts that have a specific lifetime such as wear rings.c. Procedures for the repair or replacement ofequipment should be prepared prior to beginningwork. Such procedures for major equipment that isexpected to be repaired or replaced during the life ofthe plant should preferably he written early in plantlife. The following are examples of such proceduresfor major equipment:(I) Repair of PWR Steam Generator 'rubes(2) Replacement and Repair of Control RodDrives(3) Replacement of Recirculation Pump Seals(4) Replacement of Important Strainers andFilters(5) Repair or Replacement of Safety Valves(6) Repair of Incore Flux Monitoring System(7) Replacement of Neutron Detectorsd. Procedures that could he categorized either asmaintenance or operating procedures should hedeveloped for the following activities. Instructionsfor these activities may be included in systemsprocedures.(I) Exercise of equipment that is normally idlebut that must operate %%hen required(2) Draining and Refilling Heat Exchangers(3) Draining and Refilling Recirculation Loop(4) Draining and Refilling the Reactor Vessel(5) Draining and Refilling Steam Generators(6) Removal of Reactor Head(7) Disconnection and Reconnection of WiringPenetrating Reactor Vessel Head(8) Demineralizer Resin Regeneration orReplacemente. General procedures for the control ofmaintenance, repair. replacement, and modificationwork should be prepared before reactor eperation isbegun. These procedures should include informationon areas such as the following:(I) Method for obtaining permission andclearance for operation personnel to work and forlogging such work and(2) Factors to be taken into account, includingthe necessity for minimizing radiation exposure toworkmen, in preparing the detailed work procedures.10. Chemical and Radiochemical Control I'rcedure,Chemical and radiochemical control proceduresshould be written to prescribe the nature and fre-quency of sampling and analyses. the instructionsmaintaining water quality within prescribed limits.and the limitations on concentrations of agents thatmay cause corrosive attack or fouling of heat-transfersurfaces or that may become sources of radiationhazards due to activation. These procedures shouldspecify laboratory instructions and calibration oflaboratory equipment. Extreme importance must heplaced on laboratory procedures used to determineconcentration and species of radioactivity in liquidsand gases prior to release, including representativesampling, validity of calibration techniques. and ade-quacy of analyses.1.33-7 UNITECV STATESNUCLE~AR REGUiLATORY COMMISSIONWA%.INGTON, D. C. 20555OFFICIAL BUSINESSI'( NALTY IFOR PRIVAITE USE. $300POSTAGE AN40 PIES PAIDU.S NUCLEAR REGULATORYCOMMISSION1.33-8