ML20244B941

Comments on Several Problem Areas Identified in Establishing Guidance for Acceptable Program for Implementing NUREG-0737, Item II.F.1.Upon Establishment of Guidelines,Info Should Be Incorporated in Insp Procedures

ML20244B941
Person / Time
Issue date:	08/20/1982
From:	Brown G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Mattson R Office of Nuclear Reactor Regulation
Shared Package
ML16342B348	List: IA-87-121, Discusses Inservice Test Programs Re Full Stroke Exercising of Normally Closed Swing or Tilting Disk Check Valves Per 10CFR50.55a & Section XI of ASME Code ML16342B347 ML20235B266 ML20235B268 ML20235B295 ML20235B304 ML20235B322 ML20235B406 ML20235B470 ML20235B514 ML20235B581 ML20235B613 ML20235B673 ML20235B768 ML20235B785 ML20235B799 ML20235B859 ML20235B877 ML20235B922 ML20235C007 ML20235C967 ML20235C970 ML20235D014 ML20235D041 ML20235D091 ML20235D157 ML20235D188 ML20235D233 ML20235D400 ML20235D433 ML20235D484 ML20235D532 ML20244B491 ML20244B568 ML20244B571 ML20244B913 ML20244B937 ML20244B941 ML20244B943 ML20244C126 ML20244C271 ML20244C361 ML20244C777 ML20244C785 ML20244C833 ML20244C935 ML20244C940 ML20244C986 ML20244D413 ML20244D552 ... further results
References
FOIA-87-121, RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM NUDOCS 8209270147
Download: ML20244B941 (3)

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NUCLEAR REGULATORY COfAfAIESION m'

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April 20, 1982 l

14CMORA'.D3 FOR:

R. J. Mattson, Director, Division of Systems Integration, f;RR f

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John T. Collins, Regional Administrator, Region I 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

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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:

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. 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.

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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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j-i 2 t R. J. Mattson i

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.ALARA considerations ip f

. Calibration sources

. Electronic response tests

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. Dose assessrent requiren,ents 1

. Periodic verification of full range detector response i

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. Acceptance Criteria i'

Af ter guidelines are established, this inforr.ation should be made Jr f=

available to the licensees and included in MC 2515 inspection J

procedures.

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G n ro.m. Chief J

Technical Program Branch g

y Regional Adminis'.rators cc:

7 H. R. Denton, NM

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R-R. C. DeYoung, NRR hl R. W. Houston, NRR

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J. M. Taylor, IE i

B. K. Grimes, IE C. A. Hackney, RIV ne a

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