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 January 1977 U.S. NUCLEAR REGULATORY

COMMISSION

• REGULATORY

GUIDE OFFICE OF STANDARDS

DEVELOPMENT

REGULATORY

GUIDE 1.33 QUALITY ASSURANCE

PROGRAM REQUIREMENTS (OPERATION)

A. INTRODUCTION

Appendix B, "Quality Assurance Criteria for N2 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 on February 19, 1976.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 of ANSI N18.7-1976/ANS-3.2.

as developed ANSI N 18.7-1972 that contained critcria or modified by the regulatory position for 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 for Regulatory Guide 1.33. The dual eolaorsewent was,, ., ....t .-...,,- ..', ;,.... 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 !

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 nri 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, to appr7 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.st 3.2. "Administrative Controls and Quality Assurance Ogden Avenue. Htinsdale.

Illinoi 60521 USNRC REGULATORY

GUIDES C-',avents Should ho' Sam0 to 11h0 Srlysetary 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 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) 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 .snd soluto,'.s different fromt those %at out -~ 2 RC'.Oa,c1, .snt Ti,,1 R.',tct 7 t,.itttit the 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-1lt the ,ssuineeo, cooitti itceotatternti or licenste byt the Catnrnnssittn

4 0tr,.eirneent.'.l -td Soling 9 Antitru'.t tlei.iev Coniroit,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

LUM1 n.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) C tI~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 a result 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 in ANSI N18.7-1976/ANS-3.2 are acceptable to the NRC staff and provide an adequate basis for comply-ing with the quality assurance program requirements of Appendix B to 10 CFR Part 50, subject to the fol-lowing: I. ANSI NI8.7-1976/ANS-3.2 requires the preparation of many procedures to carry out an effec-tive quality assurance program. Appendix A,"Typical Procedures for Pressurized Water Reactors and Boiling Water Reactors," to this regulatory guide should be used as guidance to ensure minimum procedural coverage for plant operating activities, in-cluding related maintenance activities.

Appendix A lists typical safety-related activities that should be covered by written procedures but does not provide a complete listing of needed procedures.

Many. other activities carried out during the operation phase of a nuclear power plant require written procedures not included in Appendix A. Appendix A may also con-tain procedures that are not applicable to an appli-cant because of the configuration of the nuclear power plant. The procedures listed in Appendix A may be combined, separated.

or deleted to conform to the applicant's procedures plan.2. Throughout ANSI N18.7-1976/ANS-3.2, other documents required to be included as a part of this standard are identified at the point of reference.

The specific acceptability of these standards listed in ANSI N 18.7-1976/ANS-3.2 has been addressed in the latest revision of the following regulatory guides: Design and Procurement Phase of Nuclear Power Plants," (Grey Book) and WASH-1309. "Guidance on Quality As-surance Requirements During the Construction Phase of Nuclear Power Plants," (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 of operational phase activities shall be performed with a frequency commensurate with their safety significance and in such a manner as to ensure that an audit of all safety-related functions is completed within a period of 2 years. In amplification of this re-quirement, the following program elements should be audited at the indicated frequencies:

a. The results of actions taken to correct deficiencies that affect nuclear safety and occur in facility equipment.

structures, systems. or method of operation-at least once per 6 months.b. The conformance of facility operation to provisions contained within the technical specifica- tions and applicable license conditions-at least once per 12 months.c. The performance.

training, and qualifications of 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 to be treated the same as the requirements (indicated by the verb "shall") of the standard: a. Section 4.,4-The guidelines concerning review activities of ihe onsi~e operating organization.

except the guideline that refers to screening subjects of potential concern.b. Section 5.2.3-The guideline concerning review and updating of standing orders.c. Section 5.2.4-The guideline concerning review, updating, and cancellation of special orders.d. Section 5.2.7.1-The guidelines that address adequate design and testing of replacement parts.e. Section 5.2.13.4-The guideline concerning special handling tools and equipment.

f. Section 5.2.19(2)-The guideline for checking plant operating procedures during the testing program.g. Section 5.2.19.1-The guidelines for preoperational tests, except the guideline that refers to a run-in period for equipment.

In addition to these ANSI Standard N45.2 N45.2.1 N45.2.2 N45.2.3 N45.2.4 N45.2.5 N45.2.6 N45.2.8 N45.2.9 N45.2. 10 N45.2. II N45.2.13 N 18.1 N 18.17 N 101.4 Regulatory Guide 1.28 1.37 1.38 1.39 1.30 1.94 1.58 1.116 1.88 1.74 1.64 1.123 1.8 1.17 1.54 Note: N45.2.12 is discussed in NRC documents WASH-1283, "Guidance on Quality Assurance Requirements During 1.33-2 U ----guidelines, the prerequisite steps for each equipment test should be completed prior to the commencement oft the preoperational test.h. Section 5.3.2-The guidelines that describe the content (excluding format) of procedures.

except 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 5.3.2(3).

and (3) inclusion of quantitative control guides in Section 5.3.2(6).i. Section 5.3.9-The guideline concerning emergency procedures requiring prompt implementa- tion of immediate operator actions when required to prevent or mitigate the consequences of a serious condition.

j. Section 5.3.9.1-The guidelines that describe the content (excluding format) for: the tith,! in Section 5.3.9.1(1):

the inclusion of svmploms to aid in iden-tificaltion in Section 5.3.9.1(2):

automatic actions in Section 5.3.9.1(3):

immediate operator action, ex-cluding those guidelines contained in the examples, in Section 5.3.9.1(4):

and subsequent operator actions in Section 5.3.9.1(5).

D. IMPLEMENTATION

The purpose of this section is to provide informa-tion to applicants and licensees regarding the NRC staff's plans for using this regulatory guide. Except in those cases in which the applicant proposes an alter-native method for complying with specified portions or the Commission's regulations.

the method described herein will he used in the evaluation ofsub-inittals for operating license applications docketed after September I. 1977. If an applicant whosc ap-plication for an operating license is docketed on or prior to September I. 1977. wishes to use this regulatory guide in developing submittals for applic.-lions, the pertinent portions of the application kwill be evaluated on the basis of this guide.1.33-3 APPENDIX A TYPICAL PROCEDURES

FOR PRESSURIZED

WATER REACTORS AND BOILING WATER REACTORS The following are typical safety-related activities that should be covered by written procedures.

This appendix is not intended as an inclusive listing of all needed procedures since many other activities carried out during the operation phase of nuclear power plants should be covered by procedures not included in this list.1. Administratiie Procedures a. Security and Visitor Control b. Authorities and Responsibilities for Safe Operation and Shutdown c. Equipment Control (e.g.. locking and tagging)d. Procedure Adherence and Temporary Change Method e. Procedure Review and Approval f. Schedule for Surveillance Tests and Calibration g. Shift and Relief Turnover h. Log Entries, Record Retention, and Review Procedures i. Access to Containment j. Bypass of Safety Functions and Jumper Control k. Maintenance of Minimum Shift Complement and Call-In of Personrel I. Plant Fire Protection Program m. Communication System Procedures

2. General Plant Operating Procedures a. Cold Shutdown to Hot Standby b. Hot Standby to Minimum Load (nuclear startup)c. Recovery from Reactor Trip d. Operation at Hot Standby e. Turbine Startup and Synchronization of Generator f. Changing Load and Load Follow (if applicable)

g. Power Op.ration and Process Monitoring h. Power Operation with less than Full Reactor Coolant Flow i. Plant Shutdown to Hot Standby j. Hot Standby to Cold Shutdown k. Preparation for Refueling and Refueling Equip-ment Operation I. Refueling and Core Alterations

3. Procedures for Startup, Operation, and Shutdown of Safety-Related PWR Systems Instructions for energizing, filling, venting, drain-ing, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the following systems:* Linc. indicate substantive changes from previous issue.a. Reactor Coolant System b. Control Rod Drive System (including part-length rods)c. Shutdown Cooling System d. Emergency Core Cooling System e. Component Cooling Water System

f. 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 System g. Atmosphere Cleanup Systems h. Fuel Storage Pool Purification and Cooling System i. Main Steam System j. Pressurizer Pressure and Spray Control Systems k. Feedwater System (feedwater pumps to steam generator)

I. Auxiliary Feedwater System m.Service Water System n. Chemical and Volume Control System (including Letdown/Purification System)o. Auxiliary or Reactor Building Heating and Ventilation p. Control Room Heating and Ventilation q. Radwaste Building Heating and Ventilation r. Instrument Air System s. Electrical System (1) Offsite (access circuits)(2) Onsite (a) Emergency Power Sources (e.g., diesel generator, batteries)(b) A.C. System (c) D.C. System t. Nuclear Instrument System (I) Source Range (2) Intermediate Range (3) Power Range (4) Incore System u. Reactor Control and Protection System

v. Hydrogen Recombiner

1.33-4 I--4. Procedure for Startup, Operation, and Shutdown of Safety-Related BWR Systems Instructions for energizing, filling, venting, drain-ing, startup, shutdown, and changing modes of operation should be prepared, as appropriate, for the following systems: a. Nuclear Steam Supply System (Vessel and Re-circulating System)b. Control Rod Drive System c. Reactor Cleanup System d. Liquid Poison System (Standby Liquid Control System)e. Shutdown Cooling and Reactor Vessel Head Spray System.f. High Pressure Coolant Injection g. Reactor Core Isolation Cooling System h. Emergency Core Cooling Systems i. Closed Cooling Water System j. Containment (I) Maintaining Integrity (2) Containment Ventilation System (3) Inerting and Deinerting k. Fuel Storage Pool Purification and Cooling System I. Main Steam System (reactor vessel to turbine)m.Turbine-Generator System n. Condensate System (hotwell to feedwater pumps. including demineralizers and resin regeneration)

o. Feedwater System (feedwater pumps to reactor vessel)p. Makeup System (filtration, purification, mid water transfer)q. Service Water System r. Reactor Building Heating and Ventilation Systems s. Control Room Heating and Ventilation Systems t. Radwaste Building Heating and Ventilation Systems u. Standby Gas Treatment System v. Instrument Air System w. Electrical System (I) Offsite (access circuits)(2) Onsite (a) Emergency Power Sources (e.g.. diesel generator, batteries)(b) A.C. System (c) D.C. System x. Nuclear Instrument System (i) Source Range (2) Intermediate Range (3) Power Range (4) TIP System y. Reactor Protection System z. Rod Worth Minimizer 5. Procedures for Abnormal, Offnormal.

or Alarm Ccnditions Since these procedures are numerous and corres-pond to the number of alarm annunciators, the procedures are not individually listed. Each safety-related annunciator should have its own written procedure, which should normally contain (I) the meaning of the annunciator, (2) the source of the signal, (3) the immediate action that is to occur automatically, (4) the immediate operator action, and (5) the long-range actions.6. Procedures for Combating Emergencies and Other Significant Fients a. Loss of Coolant (including significant PWR steam generator leaks) (inside and outside primary containment) (large and small, including leak-rate determination)

b. Loss of Instrument Air c. Loss of Electrical Power (and/or degraded power sources)d. Loss of Core Coolant Flow c. Loss of Condenser Vacuum f. Loss of Containment Integrity g. Loss of Service Water h. Loss of Shutdown Cooling i. Loss of Component Cooling System and Cool-ing to Individual Components j. Loss of Feedwater or Feedwater System Failure k. Loss of Protective System Channel I. Mispositioned Control Rod or Rods (and rod drops)m.Inability to Drive Control Rods n. Conditions Requiring Use of Emergency Bora-tion or Standby Liquid Control System o. Fuel Cladding Failure or High Activity in Reac-tor Coolant or Offgas p. Fire in Control Room or Forced Evacuation of Control Room q. Turbine and Generator Trips r. Other Expected Transients that may be Ap-plicable s. Malfunction of Automatic Reactivity Control System t. Malfunction of Pressure Control System u. Reactor Trip v. Plant Fires w.Acts of Nature (e.g.. tornado, flood, dam failure, earthquakes)

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

7. Procedures for Control of Radioactiity For limiting materials released to emironment and limiting personnel exposure)a. Liquid Radioactive Waste System 1.33-5 (I) Collection, Demineralizing, Filtering.

Evaporating and Concentrating, and Neutralizing

(2) Sampling and Monitoring

(3) Discharging to Effluents b. Solid Waste System (I)(2)(3)Spent Resins and Filter Sludge Handling Baling Machine Operation Drum Handling and Storage c. PWR Gas Systems (1)(2)(3)(4)Collection, Storage, and Discharge Sampling and Monitoring Air Ejector and Stack Monitoring Clean 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 Radioactivity Removal 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 Time Tests (1) Reactor Protection System Tests and Calibrations (m) Permissives-Tests and Calibrations (n) Refueling System Circuit Tests (o) Emergency Boration System Functional Tests (p) DNB Checks and Incore-Excore Flux Monitor Correlations (q) Emergency Power Tests (r) Auxiliary Feedwater System Tests (s) NSSS Pressurization and Leak Detection (t) Inspection of Reactor Coolant System Pressure Boundary (u) Inspection of Pipe Hanger Settings (v) Control Rod Drive System Functional I d. BWR Air Extraction and Offgas Treatment System (1)(2)(3)(4)(5)Mechanical Vacuum Pump Operation Air Ejector Operation Packing Steam Exhauster Operation Sampling Air Ejector and Stack Monitoring e. Personnel Monitoring and Special Work Permit (I) Restrictions and Activities in Radiation Areas and High Radiation Areas (2) Respirator Equipment (3) Surveys and Monitoring

(4) Protective Clothing (5) Radiation Work Permit Procedure r, Area Radiation Monitoring System Operation g. Process Radiation Monitoring System Opera-tion h. Meteorological Monitoring

8. Procedures for Control of Measuring and Test Equipment and for Suncillance Tests. Procedures.

and Calibrations a. Procedures of a type appropriate to the circum-stances should be provided to ensure that tools, gauges, instruments, controls, and other measuring and testing devices are properly controlled, calibrated, and adjusted at specified periods to main-tain accuracy.

Specific examples of such equipment to be calibrated and tested are readout instruments, interlock permissive and prohibit circuits, alarm devices, 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 the technical specifications):

Tests tions Tests (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 Penetration Leak-Rate Tests (b)(c)(d)(e)(including (M)(g)Containment Isolation Tests Containment Vacuum Relief Valve Tests Containment Spray System Tests Standby Gas Treatment System Tests filter tests)Main Steam Isolation Valve Tests Nitrogen Inerting System Tests 1 33-6 (h) Reactor Building Inleakage Tests (i) Emergency Core Cooling System Tests (j) Control Rod Operability and Scram Time Tests (k) Reactor Protection System Tests and Calibrations (I) Rod Blocks-Tests and Calibrations (m) Refueling System Circuit Tests (n) Liquid Poison System Tests (o) Minimum Critical Heat Flux Checks and Incore Flux Monitor Calibrations (p) Emergency Power Tests (q) Isolation Condenser or RCIC Tests (r) NSSS Pressurization and Leak Detection (s) Inspection of Reactor Coolant System Pressure Boundary (t) Inspection of Pipe Hanger Settings (u) Control Rod Drive System Functional Tests (v)(w)(x)09 (z)(aa)minations (bb)(cc)tions Heat Balance Safety Valve Tests Turbine Overspeed Trip Test Leak Detection System Tests Autoblowdown System Tests Axial and Radial Flux Pattern Deter-Area Radiation Monitoring Calibrations Process Radiation Monitoring Calibra-(dd) Water Storage Tanks-Level In-strumentation Calibrations (ee) Fire Protection System Functional Tests 9. Procedures for Performing Maintenance a. Maintenance that can affect the performance of safety-related equipment should be properly preplan-ned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

Skills normally possessed by qualified maintenance personnel may not require detailed step-by-step delineation in a procedure.

The following types of activities are among 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 or Slide Wires on Recorders b. Preventive maintenance schedules should be developed to specify lubrication schedules, inspec-tions of equipment, replacement of such items as filters and strainers, and inspection or replacement of parts that have a specific lifetime such as wear rings.c. Procedures for the repair or replacement of equipment should be prepared prior to beginning work. Such procedures for major equipment that is expected to be repaired or replaced during the life of the plant should preferably he written early in plant life. The following are examples of such procedures for major equipment: (I) Repair of PWR Steam Generator

'rubes (2) Replacement and Repair of Control Rod Drives (3) Replacement of Recirculation Pump Seals (4) Replacement of Important Strainers and Filters (5) Repair or Replacement of Safety Valves (6) Repair of Incore Flux Monitoring System (7) Replacement of Neutron Detectors d. Procedures that could he categorized either as maintenance or operating procedures should he developed for the following activities.

Instructions for these activities may be included in systems procedures.(I) Exercise of equipment that is normally idle but 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 Wiring Penetrating Reactor Vessel Head (8) Demineralizer Resin Regeneration or Replacement e. General procedures for the control of maintenance, repair. replacement, and modification work should be prepared before reactor eperation is begun. These procedures should include information on areas such as the following: (I) Method for obtaining permission and clearance for operation personnel to work and for logging such work and (2) Factors to be taken into account, including the necessity for minimizing radiation exposure to workmen, in preparing the detailed work procedures.

10. Chemical and Radiochemical Control I'rcedure, Chemical and radiochemical control procedures should be written to prescribe the nature and fre-quency of sampling and analyses.

the instructions maintaining water quality within prescribed limits.and the limitations on concentrations of agents that may cause corrosive attack or fouling of heat-transfer surfaces or that may become sources of radiation hazards due to activation.

These procedures should specify laboratory instructions and calibration of laboratory equipment.

Extreme importance must he placed on laboratory procedures used to determine concentration and species of radioactivity in liquids and gases prior to release, including representative sampling, validity of calibration techniques.

and ade-quacy of analyses.1.33-7 UNITECV STATES NUCLE~AR REGUiLATORY

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WA%.INGTON, D. C. 20555 OFFICIAL BUSINESS I'( NALTY IFOR PRIVAITE USE. $300 POSTAGE AN40 PIES PAID U.S NUCLEAR REGULATORY

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1.33-8