Most of not all of us are all familiar with this requirement. 10 CFR 20.1501(c) The licensee shall ensure that instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) are calibrated periodically for the radiation measured.
Generally regulators recognize that if a portable instrument calibration program is written and implemented based on ANSI N323 or N323A, that that program would be expected to meet their expectation. ANSI N323 and N323A both say that the calibration frequency should not exceed an annual calibration. The NIST and NCSL reference are written for M&TE and are good references and certainly can be applied. A good link to review the NRCs thoughts on apply ANSI N323 to plant area and effluent instruments, Proposed Guidance for Calibration and Surveillance Requirements to Meet Item II.F.1 of NUREG-0737 HPPOS-001 PDR-9111210074 can be follow here: http://www.nrc.gov/about-nrc/radiation/protects-you/hppos/hppos001.html The position paper talks about how ANSI N323 is applied to portable instruments. NRC REQUIREMENTS FOR EVALUATION OF WIPE TEST RESULTS; CALIBRATION OF COUNT RATE SURVEY INSTRUMENTS may be found following this link: http://www.nrc.gov/reading-rm/doc-collections/gen-comm/info-notices/1993/in93030.html Some sites have applied the calibration extensions permitted for plant instruments to their RP portable instrument program. If that is something that site wants to do, can justify it, and their regulator is fine with it so be it. With the use that most portable instruments go through, an annual calibration is just easier to manage and defend in my opinion. As a RP instrument inventory ages, applying RP-1 will often result in shortening the calibration frequency. We track on instrument performance quarterly at each of our sites and as a fleet. I think most of us follow the ANSI N323 or N323A recommendations. From: [email protected] [mailto:[email protected]] On Behalf Of Benjy P Bertossi Sent: Tuesday, April 08, 2014 8:57 AM To: [email protected] Subject: RE: Powernet: Benchmarking on instrument calibration due dates Dewey, who would have thought....as long as your process is documented and in compliance with any site specific requirements.... from ISO/IEC 17025 5.10.4.4 A calibration certificate (or calibration label) shall not contain any recommendation on the calibration interval except where this has been agreed with the customer. This requirement may be superseded by legal regulations. from NIST Recommended Calibration Interval Q. Does NIST require or recommend specific recalibration intervals for measuring instruments, devices or calibration standards? A. In general, NIST does not require or recommend any set recalibration interval for measuring instruments, devices, or standards. Specific recalibration intervals depend on a number of factors including: • Accuracy requirements set by customers • Requirements set by contract or regulation • Inherent stability of the specific instrument or device • Environmental factors that may affect the stability and for a really in-depth method for determining calibration interval (100+ pages) NCSL International document RP-1, Establishment and Adjustment of Calibration Intervals Benjy Bertossi Fermi2 - RP Supervisor 734-586-4935 [email protected]<mailto:[email protected]> [Inactive hide details for "Thompson, Dewey L" ---04/07/2014 03:32:15 PM---Good question Benjy. Callaway's answer is "That's th]"Thompson, Dewey L" ---04/07/2014 03:32:15 PM---Good question Benjy. Callaway's answer is "That's the way we've always done it........" (Yeah, I kn From: "Thompson, Dewey L" <[email protected]<mailto:[email protected]>> To: "[email protected]<mailto:[email protected]>" <[email protected]<mailto:[email protected]>> Date: 04/07/2014 03:32 PM Subject: RE: Powernet: Benchmarking on instrument calibration due dates Sent by: [email protected]<mailto:[email protected]> ________________________________ Good question Benjy. Callaway's answer is "That's the way we've always done it…….." (Yeah, I know). Another point would be vendors performing calibrations generally set the due date as the complete date plus one year. Not to "justify the practice", but our program allows a grace period, however it requires a conscious decision each time you invoke the grace period. The action has to be logged with the name of who provided the authorization. Most folks that use the end of the month rubric started doing so in order to reduce time and headaches. The idea being that you would pull everything once a month. I'm not convinced this saves all that much, however would welcome feedback from the folks actually doing it. Questions or comments, email or call Dewey at Callaway. Thanks Dewey : : : : : : : : : : : : : : : : : : : : : : : : : Dewey Thompson Staff HP Radiation Protection Department T 314.225.1061 F 573.676.4484 E [email protected]<mailto:[email protected]> ......................... Ameren Missouri Junction CC & Highway O Fulton, MO 65251 Please consider the environment before printing this e-mail. From: [email protected]<mailto:[email protected]> [mailto:[email protected]] On Behalf Of Benjy P Bertossi Sent: Monday, April 07, 2014 2:06 PM To: [email protected]<mailto:[email protected]> Subject: Re: Powernet: Benchmarking on instrument calibration due dates Fermi - due date is end of the month. You could make the case for using the periodicity allowance in your TS / TRM for calibration / functional surveillance grace period, say +25% of calibration periodicity, thus semi annual / annual cals due at the end of month would be well within grace period. For those that use exact due date, what technical reference is used for basis? Benjy Bertossi Fermi2 - RP Supervisor 734-586-4935 [email protected]<mailto:[email protected]> [Inactive hide details for sglee---04/07/2014 11:39:17 AM---Presently Perry RP uses a cal due date for RP instrumentation that e]sglee---04/07/2014 11:39:17 AM---Presently Perry RP uses a cal due date for RP instrumentation that equals the cal frequency (semi a From: [email protected]<mailto:[email protected]> To: <[email protected]<mailto:[email protected]>> Date: 04/07/2014 11:39 AM Subject: Powernet: Benchmarking on instrument calibration due dates Sent by: [email protected]<mailto:[email protected]> ________________________________ Presently Perry RP uses a cal due date for RP instrumentation that equals the cal frequency (semi annual, annual) plus the time to the end of the month. The other plants in the FENOC fleet use the exact cal date plus frequency as a due date. What does your organization use? A. Due date at the end of the month? B. Exact due date (cal date + frequency)? 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