Regulatory Guide 4.15

Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and Environment

ML003739945
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Issue date:	02/28/1979
From:	Office of Nuclear Regulatory Research
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Reg Guide 4.15, Rev 1
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U.S. NUCLEAR REGULATORY COMMISSION

Revision I

February 1979 W) REGULATORY GUIDE

OFFICE OF STANDARDS DEVELOPMENT

REGULATORY GUIDE 4.15 QUALITY ASSURANCE FOR RADIOLOGICAL MONITORING PROGRAMS

(NORMAL OPERATIONS) -

EFFLUENT STREAMS AND THE ENVIRONMENT

A.

INTRODUCTION

This guide describes a method acceptable to the NRC staff for designing a program to as sure the quality of the results of measurements of radioactive materials in the effluents and the environment outside of nuclear facilities during normal operations.

The. NRC regulations that require the control of releases of radioactive materials from nuclear facilities, that require the measurements of ra dioactive materials in the effluents and envi K ronment outside of these facilities, that require quality assurance programs and establish quality assurance requirements for certain fa cilities, or that authorize license conditions not otherwise authorized in the regulations are as follows:

"Section 20.106, "Radioactivity in Effluents to

"\\Unrestricted Areas,"

of

10 CFR

Part 20,

tA

tdards for Protection Against Radiation,"

des that a licensee shall not release to an unre'atricted area radioactive materials in con centrations that exceed limits specified in

10 CFR Part 20 or as otherwise authorized in a license issued by the Commission.

Section

20.201,

"Surveys," of 10 CFR Part 20 further requires that a licensee conduct surveys, including measurements of levels of radiation or concentrations of radioactive materials, as necessary to demonstrate compliance with the regulations in 10 CFR Part 20.

Paragraph (c) of Section 20.1, "Purpose," of

10 CFR Part 20 states that every reasonable effort should be made by NRC licensees to maintain radiation exposure, and releases of radioactive materials in effluents to unrestrict ed areas, as far below the limits specified in Lines indicate substantive changes from previous issue.

USNRC REGULATORY GUIDES

Regulatory Guides are issued to deicibe and make available to the public methods acceptable to the NRC staff of implementing specific parts of tn Commission's regulations, to delnst technlques used by the staff in evslu sting specific problems or poeulsted accidents, or to provide guidance to epplcents. Regulatory Guides are not substltutes for regulations, and com

=iInce wIth them is not requied. Methods end solutions different from those est out in the guides win be acceptable if they provide a bemb for the findings reluisite to the isuance or continuance of a permit or lice by the Comnission.

Comments snd suggestions for improver ntsin these guides ar enouragd at eol times, and guides wiN be revised, as appropriate, to accommodate comments and to rflect now informatron or xporience. This guide wss revised as a result Of substantive comments received from the public end additional steff review.

Part 20 as is reasonably achievable, taking into account the state of technology and the economics of improvements in relation to public health and safety and to the utilization of atomic energy in the public interest.

Section 30.34, "Terms and Conditions of Li censes," of 10 CFR Part 30, "Rules of General Applicability to Licensing of Byproduct Mate rial," provides that the Commission may incor porate in any byproduct material license such terms and conditions as it deems appropriate or necessary in order to protect health.

Section 40.41, "Terms and Conditions of Li censes,"

of

10 CFR Part 40,

"Licensing of Source Material," provides that the Commission may incorporate in any source material license such terms and conditions as it deems appro priate or necessary to protect health.

Section 50.50,

"Issuance of Licenses and Construction Permits," of 10 CFR Part 50, "Li censing of Production and Utilization Facil ities," provides that each operating license for a nuclear power plant issued by the Nuclear Regulatory Commission will contain such condi tions and limitations as the Commission deems appropriate and necessary.

Section 70.32,

"Conditions of Licenses," of

10 CFR Part 70,

"Special Nuclear Material,"

provides that the Commission may incorporate such terms and conditions as it deems appro priate or necessary to protect health.

Section IV.B

of Appendix I,

"Numerical Guides for Design Objectives and Limiting Con ditions for Operation to Meet the Criterion 'As Low As Is Reasonably Achievable' for Radio active Material in Light-Water-Cooled Nuclear Power Reactor Effluents," to 10 CFR Part 50,

"Licensing of Production and Utilization Facil ities," requires that licensees establish an ap- Comment should be sent to the Secretary of the Commison, U.S. Nuclear Regulatory Commission, Washington, D.C. 2015. Attentio: Docketing aGr Service Branch.

The gukles are issued in the following ten brood divisiio:

6. Products

2. Research and Tert Reactor

7. Transportation

3. Fuels and Materials Facilities B. Occupational oe-lfth

4. Environmental and Siting

9. Antitrust end Financial Review

5. Materials and Plant Protection

10. General Requests for single copies of issued guides (which may be reproduced) or for placement on an automatic distribution list for single copies of future guides in specific divisions should be made in writing to the U.S. Nuclear Regulatory Commission, Washington, D.C. 2066., Attention:

Director, Division of Technical Information and Document Control.

propriate surveillance and monitoring program to provide data on quantities of radioactive material released in liquid and gaseous efflu ents and to provide data on measurable levels of radiation and radioactive materials in the environment.

Section III.B of Appendix I

to

10 CFR Part 50 provides certain effluent and environmental monitoring requirements with respect to radioactive iodine if estimates of exposure are made on the basis of existing conditions and if potential changes in land and water usage and food pathways could result in exposures in excess of the guidelines of Appendix I to 10 CFR Part 50.

General Design Criterion 60, "Control of re leases of radioactive materials to the environ ment," of Appendix A,

"General Design Cri teria for Nuclear Power Plants,"

to 10 CFR

Part 50

requires that nuclear power plant designs provide means to control suitably the release of radioactive materials in gaseous and liquid effluents. General Design Criterion 64,

"Monitoring radioactivity releases," of Appen dix A to 10 CFR Part 50 requires that nuclear power plant designs provide means for monitor ing effluent discharge paths and the plant environs for radioactivity that may be released from normal operations, including anticipated operational occurrences, and from postulated accidents.

General Design Criterion 1, "Quality stand ards and records," of Appendix A to 10 CFR

Part 50 requires that a quality assurance pro gram be established for those structures, sys tems, and components of a nuclear power plant that are important to safety in order to provide adequate assurance that they will satisfactorily perform their safety functions.

Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to 10 CFR Part 50 establishes quality assurance requirements for the design, con struction, and operation of those structures, systems, and components of these facilities that prevent or mitigate the consequences of postu lated accidents that could cause undue risk to the health and safety of the public.

The need of quality assurance is implicit in all requirements for effluent and environmental monitoring, and this need has been widely recognized.

Regulatory Guide 1.21,

"Measur ing, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Mate rials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants;"

Regulatory Guide 4.1, "Programs for Monitor ing Radioactivity in the Environs of Nuclear Power Plants;" Regulatory Guide 4.8, "Envi ronmental Technical Specifications for Nuclear Power Plants;"

and Regulatory Guide 4.14,

"Measuring, Evaluating, and Reporting Radio activity in Releases of Radioactive Material in Liquid and Airborne Effluents From Uranium Mills,"

all give some guidance on means for assuring the quality of the measurements of ra dioactive materials in effluents and the envi ronment outside of nuclear facilities. More com plete and extensive guidance on this subject is provided in this document for nuclear power reactor facilities and for other facilities for which radiological monitoring is required by the NRC.

This guidance does not identify separately the activities that are within the scope of Appendix B to 10 CFR Part 50. How ever, this guidance is intended to be consist ent with the requirements of Appendixes A and B to 10 CFR Part 50 in that quality assurance requirements should be consistent with the importance of the activity. For the monitoring of production and utilization facilities that is within the scope of Appendix B to 10 CFR

Part 50, other regulatory guides that provide guidance on meeting the quality assurance re quirements of Appendix B to 10 CFR Part 50

should also be consulted.

B.

DISCUSSION 1 As used in the context of this guide, quality assurance comprises all those planned and sys tematic actions that are necessary to provide adequate confidence in the results of a mon itoring program, and quality control comprises those qualit assurance actions that provide a means to control and measure the character istics of measurement equipment and processes to established requirements; therefore, quality assurance includes quality control.

To assure that radiological monitoring meas urements are reasonably valid, organizations performing these measurements have found it necessary to establish quality assuraice pro grams.

These programs are needed for the following reasons:

(1) to identify deficiencies in the sampling and measurement processes to those responsible for these operations so that corrective action can be taken, and (2)

to I

obtain some measure of confidence in the results of the monitoring programs in order to assure the regulatory agencies and the public that the results are valid.

Existing published guidance on specific qual ity assurance actions that are applicable to ra diological monitoring is limited and, in general, is restricted to quality control practices for radioanalytical laboratories (Refs.

1-5). How ever, quality assurance should be applied to all steps of the monitoring process, which may include sampling, shipment of samples, receipt of samples in the laboratory, preparation of samples, measurement of radioactivity, data reduction, date evaluation, and reporting of the monitoring results.

'Definitions of special terms used in this guide are given in the giossary on page 4.15-10.

4.15-2

The scope of this guide is limited to the ele ments of a quality assurance program, which is a planned, systematic, and documented pro gram that includes quality control. Guidance on principles and good practice in the monitoring process itself and guidance on activities that can affect the quality of the monitoring results (e.g., design of facilities and equipment) are outside the scope of this guide. However, some references are provided to documents that do provide some guidance in these areas.

The citation of these references does not constitute an endorsement of all of the guidance in these documents by the NRC staff. Rather, these references are provided as sources of informa tion to aid the licensee and the licensee's con tractors in developing and maintaining a

monitoring program.

Every organization actually performing efflu ent and environmental monitoring, whether an NRC

licensee or the licensee's contractor, should include the quality assurance program elements presented'in this guide.

C.

REGULATORY

POSITION

The quality assurance program of each organization performing effluent or environ mental monitoring of nuclear facilities for nor mal operations should be documented by written policies and procedures and records.

These documents should include the elements given in this section.

In addition to its own program, a licensee should require any contractor or subcontractor performing monitoring activities for the li censee to provide a quality assurance program and to routinely provide program data summaries (sufficiently detailed to permit on going quality 'assurance program evaluation by the licensee) consistent with the provisions of this guide, as follows:

1. Organizational Structure and Responsibilities of Managerial and Operational Personnel The structure of the organization as it re lates to the management and operation of the monitoring program(s),

including quality as surance policy and functions, should be pre sented. The authorities, duties, and responsi bilities of the positions within this organization down to the first-line supervisory level should be described. This should include responsibil ities for review and approval of written proce dures and for the preparation, review, and evaluation of monitoring data and reports.

Persons and organizations performing quality assurance functions should have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.

2. Specification of Qualifications of Personnel The qualifications of individuals performing radiological monitoring to carry out their assigned functions should be specified and documented (e.g., as in a job description).

An indoctrination and orientation program, appropriate to the size and complexity of the organization and to the activities performed, I

should provide that (a)

personnel performing quality-related activities are trained and quali fied in the principles and techniques of the ac tivities performed, (b)

persoiinel are made aware of the nature and goals of the quality assurance program, and (c) proficiency of per sonnel who perform activities affecting quality is maintained by. retraining, reexamining, and recertifying or by periodic performance re views, as appropriate.

3. Operating Procedures and Instructions Written procedures should be prepared, re viewed, and approved for activities involved in carrying out the monitoring program, including sample collection; packaging, shipment, and receipt of samples for offsite analysis; prepa ration and analysis of samples; maintenance, storage, and use of radioactivity reference standards; calibration and checks of radiation and radioactivity measurement systems; and reduction, evaluation, and reporting of data.

Individuals who review and approve these pro cedures should be knowledgeable in the sub jects of the procedures.

Guidance on principles and good practice in many of these activities is presented in NRC

regulatory guides (Refs. 6-9) and other publi cations (Refs.

2-5, 10-35). In addition to these publications, Scientific Committee 18A of the NCRP has prepared NCRP Report 58, "A Hand book of Radioactivity Measurements Proce dures," (Ref. 36) that is a revision of NCRP

Report 28, NBS Handbook 80,

"A

Manual of Radioactivity Procedures."

4. Records The records necessary to document the ac tivities performed in the monitoring program should be specified in the quality assurance program.

One key aspect of quality control is maintain ing the ability to track and control a sample in its progress through the sequence of monitor ing processes.

Records to accomplish this should cover the following processes: field and inplant collection of samples for subsequent analysis, including sample description; sample receipt and laboratory identification coding;

sample preparation and radiochemical process ing (e.g., laboratory notebooks); radioactivity measurements of samples, instrument back grounds, and analytical blanks;

and data reduction and verification.

4.15-3

Quality control records for laboratory counting systems should include the results of measurements of radioactive check sources, calibration sources, backgrounds, and blanks.

Records relating to overall laboratory per formance should include the results of analysis of quality control samples such as analytical blanks, duplicates, interlaboratory cross-check samples and other quality control analyses; use of standards (radioactivity) to prepare working standards; preparation and standardization of carrier solutions; and calibration of analytical balances.

Additional records that are needed should in clude the calibration of inline radiation detec tion equipment, air samplers, and thermo luminescence dosimetry systems; verification and documentation of computer programs;

qualifications of personnel;

and results of audits.

The minimum period of retention of the rec ords should be specified. For nuclear power plants, requirements for record retention are

-given in the plant technical specifications. In general, for other types of facilities, only the final results of the monitoring programs need be retained for the life of the facility.

5. Quality Control in Sampling (Including Pack aging, Shipping, and Storage of Samples)

Continuous sampling of liquids and gases in volves the measurement of sample flow rates and/or sample volumes. The accuracy of the devices used for this purpose should be deter mined on a regularly scheduled basis, and ad justments should be made as needed to bring the performance of the devices within specified limits. The reslits of these calibrations should be recorded. The frequency of these calibra tions should be specified and should be based on the required accuracy, purpose, degree of usage, stability characteristics, and other con ditions affecting the measurement. Procedures for continuous sampling should use methods that are designed to ensure that the sample is representative of the material volumes sampled.

The collection efficiencies of the samplers used should be documented; usually such documen tation is available from manufacturers of the sampling equipment.

Procedures for grab samples should include steps designed to ensure that the sample is representative of the material sampled.

Rep licate grab samples should be taken periodically to determine the reproducibility of sampling.

Procedures for sampling, packaging, ship ping, and storage of samples should be designed to maintain the integrity of the sample from time of collection to time of analysis.

Aqueous samples may present a particular problem in this regard, and one of the most severe problems has been encountered with aqueous samples of radioactive wastes from operating nuclear reactors (Ref. 23).

Guidance on the principles and practice of sampling in environmental monitoring is pro vided in several publications (Refs.

2,

4, 5,

21, 23-31, 33, 35, 37). In addition, workers at the National Bureau of Standards (NBS) have published the results of a survey of informa tion on sampling, sample handling, and long term storage for environmental materials (Ref. 15). Some guidance on the principles and practice of air sampling is provided in Refer ences 17,

19,

24, 28-31,

33. Guidance on the principles and practice of water sampling is provided in numerous publications (Refs.

13,

14, 25-27, 35, 37).

6. Quality Control in the Radioanalytical Laboratory

6.1 Radionuclide Reference Standards-Use for Calibration of Radiation Measurements Systems Reference standards are used to determine counting efficiencies for specific radionuclides or, in the case of gamma-ray-spectrometry systems, to determine counting efficiency .as a function of gamma-ray energy. A counting effi ciency value is used to convert a sample count ing rate to the decay rate of a radionuclide or to a radionuclide concentration.

Guidance on the calibration and usage of germanium de tectors for measurement of gamma-ray emission rates of radionuclides has been prepared as an ANSI

standard (Ref. 38).

For converting gamma-ray emission rates to nuclear decay rates, two reports from the Oak Ridge National Laboratory (Refs. 39 and 40) provide useful compilations of gamma-ray intensities and other nuclear decay data for radionuclides in routine releases from nuclear fuel cycle facilities. The data from Reference 40 are included in NCRP

Report 58 (Ref. 36).

Radionuclide standards that have been certified by NBS or standards that have been obtained from suppliers who participate in measurement assurance activities with NBS 2 1

2Satisfactory measurement assurance interactions between source suppliers and NBS involve two basic mechanisms: (1)

The supplier submits a calibrated radioactivity source (pref erably selected from a batch or prepared series of sources) to NBS

for confirmation that the supplier's calibration value agrees with NBS results within certain specified limits or (2)

NBS provides calibrated radioactivity sources of undisclosed activity (test samples) to a supplier who is able to make activity or emission-rate measurements on the source that agree within certain specified limits with the measurements of NBS. For the routine production of commercial radioactivity standards, the first mechanism is preferable to the second but is not always feasible. These two mechanisms are used both in Measurements Assurance Programs (MAPs) with key laboratories and in other measurement assurance activities.

"Two key laboratory source suppliers participate in MAPs with NBS and use both of the two basic mechanisms: (1) The NRC

reference laboratory for the Confirmatory Measurements Pro gram (for effluent monitoring) of the NRC Office of Inspection and Enforcement and (2) The EPA Environmental Monitoring and Support Laboratory in Las Vegas, which prepares and

4.15-4

should be used when such standards are avail able.

In these measurement assurance activ ities, the supplier's calibration value should agree with the NBS value within the overall uncertainty stated by the supplier in its certi fication of the same batch of sources (when these are sampled for measurement by NBS) or in its certification of similar sources.

An "International Directory of Certified Ra dioactive Materials" has been published by the International Atomic Energy Agency (Ref. 41).

Acceptable standards for certain natural ra dionuclides may be prepared from commercially available high-purity chemicals. For example, potassium-40 standards for gross beta-particle measurements or gamma-ray spectrometry may be prepared gravimetrically from dried reagent-grade potassium chloride.

The details of the preparation of working standards from certified standard solutions should be recorded.

The working standard should be prepared in the same form as the un known samples, or close approximation thereto.

Efficiency calibrations should be checked periodically (typically monthly to yearly) with standard sources.

In addition, these checks should be made whenever the need is in dicated, such as when a significant change in the measurement system is detected by routine measurements with a check source.

6.2 Performance Checks of Radiation Measurement Systems Determination of the background counting rate and the response of each radiation detec tion system to appropriate check sources should be performed on a scheduled basis for systems in routine use. The results of these measurements should be recorded in a log and plotted on a

control chart.

Appropriate distributes calibrated radioactivity standards primarily to lab oratories involved in radiological environmental monitoring.

Additionally, seven major radiopharmaceutical manufacturers (some of which supply radioactivity standards commercially)

participate in a MAP organized by the Atomic Industrial Forum and NBS. In this MAP, NBS distributes standards as test sam ples to the manufacturer (second mechanism) and receives cer tified samples from the manufacturer for verification by NBS

(first mechanism).

Measurement assurance interactions that use the first me chanism are available via special NBS calibration service

s. NBS

will, on request and for a fee, perform calibrations of repre sentative samples of standards provided by the supplier for NBS confirmation of the supplier's reported values, Calibration services are available for a large variety of radionuclides pro vided certain requirements (as to sample stability and suitable activity range) are met. Measurement assurance interactions that use the second mechanism are available via the issuance of test standards by NBS. For a nominal charge (beyond the price of the standard),

NBS

radioactivity Standard Reference Materials (SRMs) can be purchased as test sources of undis closed activity that can be used to demonstrate agreement.

within certain specified limits, between the source supplier's measurements and those of NBS. A Report of Test (for the first mechanism) or a Report of Measurement (second mechanism),

containing both the source supplier's and NBS values, is issued by NBS to document the source supplier's participation in the measurement assurance activity.

investigative and corrective action should be taken when the measurement value falls outside the predetermined control value.

A check source for determining changes in counting rate or counting efficiency should be of sufficient radiochemical purity to allow correction for decay but need not have an accurately known disintegration rate, i.e.,

need not be a standard source.

For systems in which samples are changed manually, check sources are usually measured daily.

For systems with automatic sample changers, it may be more convenient to include the check source within each batch of samples and thus obtain a measurement of this source within each counting cycle. For proportional counter systems,- the plateau(s) or response(s)

to the check source(s) should be checked after each gas change.

Background measurements should be made frequently, usually daily or before each use, to ensure that levels are within the expected range. For systems with automatic sample changers, background meas urements should be included within each meas urement cycle.

For alpha- and gamma-ray-spectrometry sys tems, energy-calibration sources (i.e.,

a source containing a radionuclide, or mixture of radionuclides, emitting two or more alpha or gamma rays of known energies) are counted to determine the relationship between channel number and alpha- or gamma-ray energy. The frequency of these energy calibration checks depends on the stability of the system but usually is in the range of daily to weekly. The results of these measurements should be recorded and compared to predetermined limits in order to determine whether or not system gain and zero level need adjustment.

Adjustments should be made as necessary.

Additional checks needed for spectrometry systems are the energy resolution of the system and the count rate (or counting efficiency) of a check source. These should be determined periodically (usually weekly to monthly for energy resolution and daily to weekly for count rate)

and after system cnanges, such as power failures or repairs, to determine if there has been any significant change in the system.

The results of these measurements should be recorded.

6.3 Analysis of Quality Control Samples The analysis of quality control samples pro vides a means to determine the precision and accuracy of the monitoring processes and in cludes both intralaboratory and interlaboratory measurements.

The analysis of replicate samples (containing significant detectable activity)

provides a

means to determine precision; the analysis of

4.15-5

samples containing known concentrations of radionuclides provides a means to determine accuracy.

The analysis of laboratory blanks provides a

means to detect and measure radioactive contamination of analytical samples, a common source of error in. radiochemical analysis of low-levw:1 samples. The analysis of analytical blanks also provides information on the adequacy of background subtraction, particularly for environmental samples.

The fraction of the analytical effort needed for the analysis of quality conti-ol samples depends to a large extent on (1) the mixture of sample types in a particular laboratory in a particular time period and (2)

the history of performance of that laboratory in the analysis pf quality control samples.

However, for environmental laboratories, it is found that at least 5%, and typically 10%, of the analytical load should consist of quality control samples.

6.3.1 Intralaboratory Analyses Replicate samples, usually duplicates, should be analyzed routinely. These replicates should be prepared from samples that are as homo geneous as possible, such as well-stirred or mixed liquids (water or milk)

and solids (dried, ground, or screened soil, sediment, or vegetation;

or the ash of these materials).

These samples may be replicates of monitoring program samples, replicates of reference test materials, or both. The size and other physical and chemical characteristics of the replicate samples should be similar to those of single samples analyzed routinely.

The analysis of the replicate samples as blind replicates is desirable but is not practicable for all laboratories or for all types of samples. For example, in small laboratories it may not be practicable to prevent the analysts from being aware that particular samples are replicates of one another.

Obtaining true replicates of all types of samples also is not practicable. For example, obtaining replicate samples of airborne mate rials usually is not practicable on a routine basis because it requires either a separate sampling system or splitting a single sample (e.g., cutting a filter in half). Use of replicate samplers usually is not economically feasible and splitting of samples results in replicates that do not represent the usual sample size or measurement configuration (counting geometry)

for direct measurement.

However, simulated samples of airborne materials may be prepared in replicate and submitted for analysis as unknowns.

Analysis of intralaboratory blank and spiked samples is an important part of each environ mental laboratory's quality control program. To check for contamination from reagents and other sources, known analytical blank samples should be included frequently in groups of un known environmental samples that are analyzed radiochemically.

Spiked and blank samples should be submitted for analysis as unknowns to provide an intralaboratory basis for estimat ing the accuracy of the analytical results.

These blanks and spikes may include blind replicates.

6.3.2 Interlaboratory Analyses Analysis of effluent and environmental sam ples split with one or more independent labora tories is an important part of the quality as surance program because it provides a means to detect errors that might not be detected by intralaboratory measurements alone.

When possible, these independent laboratories should be those whose measurements are traceable to NBS.

3 Analysis of split field samples, such as sam ples of milk, water, soil or sediment, and vegetation, is particularly important in envi ronmental monitoring programs to provide an independent test of the ability to measure radionuclides at the very low concentrations present in most environmental samples.

The NRC Office of Inspection and Enforce ment conducts a Confirmatory Measurements Program for laboratories of licensees that meas ure nuclear reactor effluents. The analyses of liquid waste holdup tank samples, gas samples, charcoal cartridges, and stack particulate filters are included in this program.

The results of the licensee's measurements of sam ples split with the NRC are compared to those of an NRC reference laboratory whose measure ments are traceable to the National Bureau of Standards. Thus the results of this comparison provide to the NRC an objective measure of the accuracy of the licensee's analyses.

Laboratories of licensees or their contractors that perform environmental measurements should participate in the EPA's Environmental Radioactivity Laboratory Intercomparison Stud ies (Cross-check)

Program, or an equivalent program. This participation should include all of the determinations (sample medium/radionu clide combinations) that are both offered by EPA and included in the licensee's environ mental monitoring program. Participation in the EPA program provides an objective measure of the accuracy of the analyses because the EPA

measurements are traceable to the National Bureau of Standards. If the mean result of a cross-check analysis exceeds the control limit as defined by EPA (Ref. 42), an investigation should be made to determine the reason for this deviation and corrective action should be taken

3NBS and NRC staffs recognize the need for a clearer defini tion of the term "traceability" as it applies Lo radiation and radioactivity measurements. These staffs are working together to develop such a

statement, which will be published separately.

4.15-6

as necessary.

Similarly, an investigation and any necessary corrective action should take place if the "normalized range," as calculated by EPA, exceeds the control limit, as defined by EPA.

A series of results that is within the control limits but that exhibits a trend toward these limits may indicate a need for an investi gat.ion to determine the reason for the trend.

6.4 Computational Checks Procedures for the computation of the con centration of radioactive materials should in clude the independent verification of a sub stantial fraction of the results of the computa tion by a person other than the one performing the original computation. For computer calcula tions, the input data should be verified by a knowledgeable individual. All computer pro grams should be documented and verified before initial routine use and after each modifi cation of the program. The verification process should include verification, by a knowledgeable individual, of the algorithm used and test runs in which the output of the computer computa tion for given input can be compared to "true"

values that are known or determined independ ently of the computer calculation. Documenta tion of the program should include a descrip tion of the algorithm and, if possible, a

current listing of the program. Guidelines for the documentation of digital computer programs are given in ANSI N413-1974 (Ref. 43).

7. Quality Control for Continuous Effluent Monitoring Systems Guidance on specification apd performance of onsite instrumentation for continuously mon itoring radioactivity in effluents is given in ANSI N13.10-1974 (Ref. 18).

The specified frequency of calibration for a particular system should be based on con siderations of the nature and stability of that system. For nuclear power plants, specific re quirements for calibrations and checks of par ticular effluent monitoring systems usually are included in the technical specifications for the plant.

Initial calibration of each measuring system should be performed using one or more of the reference standards that are certified by the National Bureau of Standards or standards that have been obtained from suppliers that partici pate in measurement assurance activities with NBS

(see 'footnote

2).

These radionuclide standards should permit calibrating the system over its intended range of energy and rate capabilities. For nuclear power plants, sources that have been related to this initial calibration should be used to check this initial calibration at least once per 18 months (normally during refueling outages).

Periodic correlations should be made during operation to relate monitor readings to the concentrations and/or release rates of radio active material in the monitored release path.

These correlations should be based on the results of analyses for' specific radionuclides in grab samples from the release path.

Any flow-rate measuring devices associated with the system should be calibrated to deter mine actual flow rates at the conditions of temperature and pressure under which the system will be operated.

These flow rate devices should be recalibrated periodically.

Whenever practicable, a check source that is actuated remotely should be installed for in tegrity checks of the detector and the asso ciated electrical system.

8. Review and Analysis of Data Procedures for review and analysis of data should be developed. These procedures should cover examination of data from actual samples and from quality-control activities for reason ableness and consistency.

These reviews should be performed on a timely basis. General criteria for recognizing deficiencies in data should be established.

Provisions should be made for investigation and correction of recognized deficiencies and for documentation of these actions.

9. Audits Planned and periodic audits should be made to verify implementation of the quality assur ance program. The audits should be performed by individuals qualified in radiochemistry and monitoring techniques who do not have direct responsibilities in the areas being audited.

Audit results should be documented and re viewed by management having responsibility in the area audited. Followup action, including reaudit of deficient areas, should be taken where indicated.

D.

IMPLEMENTATION

The purpose of this section is to provide in formation to applicants and licensees regarding the NRC staff's plans for using this regulatory guide.

Except in those cases in which the applicant or licensee proposes an acceptable alternative method, the staff will use the methods de scribed herein in evaluating an applicant's or licensee's capability for and performance in complying with specified portions of the Com mission's regulations after March 30, 1979.

If an applicant or licensee wishes to use the method described in this regulatory guide on or before March 30, 1979, the pertinent portions of the application or the licensee's performance will be evaluated on the basis of this guide.

4.15-7

REFERENCES

1. Section 6. 2,

"Validation of Analyses,"

Chapter 6,

"Validity of Results," Methods of Radiochemical Analysis, World Health Organiza tion, Geneva, 1966.

2. "Analytical Quality Control Methods," Envi ronmental Radioactivity Surveillance Guide, U. S. Environmental Protection Agency Report, ORP/SID 72-2, June 1972.

3. Environmental Radiation Measurements, Re port of NCRP SC-35, NCRP Report No.

50,

1976.

4. L. G.

Kanipe, Handbook for Analytical Quality Control in Radioanalytical Laboratories, U.S. Environmental Protection Agency Report EPA-600/7-77-088, August 1977.

5. J.M. Mullins, C. Blincoe, J.C. Daly, et al.,

"Radiochemistry," Chapter 17, pp. 1007

1031, Quality Assurance Practices for Health Laboratories, Stanley L.

Inhorn 7'editor, American Public Health Association, 1978.

6. Regulatory Guide 1.21, "Measuring, Eval uating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power Plants."

7. Regulatory Guide 4.5, "Measurements of Radionuclides in the Environment-Sampling and Analyses of Plutonium in Soil."

8. Regulatory Guide 4.6, "Measurements of Radionuclides in the Environment-Strontium-89 and Strontium-90 Analyses."

9. Regulatory Guide 4.13,

"Performance, Testing, and Procedural Specifications for Thermoluminescence Dosimetry: Environmental Applications."

10.

HASL Procedures Manual, U.S. Energy Research and Development Administration Report, HASL-300, 1972 (updated annually).

11.

A Guide for Environmental Radiological Surveillance at ERDA Installations, Energy Re:

search and Development Administration Report, ERDA 77-24, March 1977.

12. Handbook of Radiochemical Analytical Meth ods, U.S.

Environmental Protection Agency Report, EPA-680/4-75-001. February 1975.

13. Standard Methods for the Examination of Water and Wastewater, Thirteenth Edition, American Public Health Association, 1975.

14. Handbook for Samplin and Sample Pres ervation of Water and Wastewater, U.S. Envi- ronmental Protection Agency Report, Office of Research and Development, Environmental Mon itoring Support Laboratory, EPA-600/4-76-049, September 1976.

15. E.J. Maienthal and D.A. Becker, "A Sur vey on Current Literature on Sampling, Sample Handling, and Long-Term Storage for Environ mental Materials,"

Interface

5

(#4),

49-62

(1976).

Also available from the Superintendent of Documents, U.S.

Government Printing Office, Washington, D.C. 20402, as NBS Tech nical Note #929, October 1976, C 13.46:929, S/N 003-003-01694-2.

16. Tritium Measurement Techniques, Report of NCRP SC-36, NCRP Report No. 47, 1976.

17. "Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities," ANSI N13.1

1969Property "ANSI code" (as page type) with input value "ANSI N13.1</br></br>1969" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..

18. "Specification and Performance of On-Site Instrumentation for Continuously Monitoring Radioactivity in Effluents," ANSI N13.10-1974.

19. Air .Smlng Instruments for Evaluation of Atmospheric Conaminants Fourth Edition, American Conference of Industrial Hygienists,

1972.

20. Users' Guide for Radioactivity Standards, Subcommittee on Radiochemistry and Subcom mittee on the Use of Radioactivity Standards, Committee on Nuclear Science, National Academy of Sciences-National Research Council Report, NAS-NS-3115, February 1974.

21. Environmental Impact Monitoring for Nu clear Power Plants, Source Book of Monitorinig Methods, Vol. 1, Atomic Induastrial Forum Re port, AIF/NESP-004, February 1975.

22. Instrumentation for Environmental Monitor ing: Radiation, Lawrence Berkeley Laboratory Report, LBL-1, Vol. 3, First Ed.,

May 1972;

First update, February 1973; Second update, October 1973.

23. C.W. Sill, "Problems in Sample Treatment in Trace Analysis," National Bureau of Stand ards Special Publication 4-22, Accuracy in Trace Analysis:

Samplin, Sampl Handling, and Analysis, pp. 463-490, August 1976.

24. "General Principles for Sampling Airborne Radioactive Materials," International Standard, ISO-2889, 1975.

Manual of Methods for Chemical Analysis of Water and Wastes, EP--625/6-74-003, U.S.

Environmental Protection Agency, Office of Technology Transfer, Washington, D.C. 20460,

1974.

4.15-8

26. "Standard Practices for Sampling Water,"

Method D 3370-76, Annual Book of ASTM Stand ards (Part 31),

Water, American Society for Tthing and MaterhW, Philadelphia, PA, 1977.

27. Biological Field and Laboratory Methods for Measuring the Qu'ty of Surace Waters and Effluients, EPA- 670/473S-001, Ofice -o Re search and Development, U.S. Environmental Protection Agency, Cincinnati, Ohio, July 1973.

28. G.G. Eadie and D.E. Bernhardt, "Sampling and Data Reporting Considerations for Air borne Particulate Activity,"

U.S.

Environ mental Protection Agency Technical Note ORP/LV-76-9, December, 1976.

29. A.J. Breslin, "Guidance for Air Sampling at Nuclear Facilities," U.S. Energy Research and Development Administration Report HASL

312, November 1976.

30. "Reference Method for the Determination of Suspended Particulates in the Atmosphere (High. Volume Method),"

Quality Assurance Handbook for Air Pollution Measurement Sys tems, Vo-ui If-Amb-ient Air Specific Methods, e-tion 2, U.S.

Envir-a-ent-I

Protection Agency Report EPA-600/4-77-027a, May 1977.

31. E.D. Harward (editor), Program Report:

Workshop on Methods for Measuring Radiation In and Around ranium iills, report based on presentations made at the workshop held in Albuquerque, New Mexico, May 23-26,

1977.

Atomic Industrial Forum, Inc., August 1977.

32. Measurement of Low-Level Radioactivity, International Commission on Radiation Units and Measurements (ICRU) Report 22, June 1,

1972.

33. American Public Health Association Inter society Committee on Methods of Air Sampling and Analysis, Morris Katz (editor), Methods of Air Sampling and Analysis, Second Edition, American Public Health Association, 1977.

34. L.H.

Ziegler and H.M.

Hunt, Quality Control for Environmental Measurements Gamma-Ray Spectrometry, U.S. Environmental Protection Agency Report EPA-660/7-77-14, December 1977.

35. L.L. Thatcher, V.J. Janzer, and K.W.

Edwards,

"Methods for the Determination of Radioactive Substances in Water and Fluvial Sediments,"

Chapter A5, Book B (Laboratory Analysis)

of Techniques of Water-Resources Investigations of the United States. Geological Survey, 1977. Chapter A5 is available from the Superintendent of Documents, U.S. Govern ment Printing Office, Washington, D.C. 20402, Stock Number 024-001-02928-6.

36. A Handbook of Radioactivity Measurements Proceduires, Rep6ot of NCRP SC-18A,

NCR

Report No. 58, 1978.

37..P.E.

Shelley, Sampling of Water and Wastewater, U.S.

Environmental -TF-ec,-i-i Agency Report EPA-600/4-77-039, August

1977.

38. "Calibration and Usage of Germanium De tectors for Measurement of Gamma-Ray Emission Rates of Radionuclides," ANSI N42.14-1978.

39. D.C.

Kocher (editor),

Nuclear Dec Data for Radionuclides Occurring in Routine R-lases from Nuclear Fel Ccle -- aciFtie Ua-kRidge N-ationVa-lab o ry-hror eort ORNL/

NUREG/TM-102, August 1977

40. M.J. Martin (editor), Nuclear Decay Data for Selected Radionuclides, OakRidge aiton

-iabo(atory Report ORNL-5114, March 1976.

41. International Directory of Certified Radio active Materials, Internatioa Atomic En--ergy Agency Report, STI/PUB/398, 1975.

42.

Environmental Radioactivity Laboratory Intercparison Studies Program, FY

1977, EPA-6

4-7-001, J---ury 1977.

43. "Guidelines for the Documentation of Digital Computer Programs," ANSI N413-1974.

4.15-9

GLOSSARY

Accuracy-a qualitative concept in the statis tical treatment of measurement data used to de scribe the agreement between the central tendency of a set of numbers and their correct value (or the accepted reference value). It is also used to describe the agreement between an individual value and the correct value (or the accepted reference value).

Analytical Blank (Sample)-ideally, a sample having all of the constituents of the unknown sample except those to be determined. In ra dioanalytical practice, the term often refers to the radiochemical processing of carrier(s) or tracers without the sample matrix material.

"Blind" Replicate (Sample)-replicate samples that are not identified as replicates to the, per sons performing the analysis.

Calibration-the process of determining the numerical relationship between the observed output of a measurement system and the value, based on reference standards, of the charac teristics being measured.

Calibration Source-any radioactive source that is used for calibration of a measurement system.

Check Source (or instrument check source or performance check source)-a radioactive source used to determine if the detector and all elec tronic components of the system are operating correctly.

Instrument Background-the response of the instrument in the absence of a radioactive sam ple or other radioactive source.

Precision-a qualitative concept in the statis tical treatment of measurement data used to describe the dispersion of a set of numbers with respect to its central tendency.

Quality Assurance (QA)-the planned and systematic actions that are necessary to pro vide adequate confidence in the results of a monitoring program.

Quality Control (QC)-those quality assurance actions that provide a means to control and measure the characteristics of measurement equipment and processes to established re quirements.

Thus, quality assurance includes quality control.

Reference Test Material-a large batch of homogeneous material from which aliquots may be taken for interlaboratory comparisons or for internal use by the laboratory. The material must be uniform but need not be standardized.

Spiked Sample-a sample to which a known amount of radioactive material has been added.

Generally, spiked samples are submitted as unknowns to the analysts.

Split §Saple-a homogeneous sample that is divided into parts, each of which is analyzed independently by separate laboratory organi zations.

Standard (radioactive)

Source-a radioactive source having an accurately known radionu clide content and radioactive decay rate or rate of particle or photon emission.

4.15-10

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