Publication Date: 10/1/83
    Pages: 11
    Date Entered: 2/23/84
    Title: IN SITU ASSAY OF ENRICHED URANIUM RESIDUAL HOLDUP (8/74)
    Revision 1
    October 1983
    U.S. NUCLEAR REGULATORY COMMISSION
    REGULATORY GUIDE
    OFFICE OF NUCLEAR REGULATORY RESEARCH
    REGULATORY GUIDE 5.37
    (Task SG 047-4) IN SITU ASSAY OF ENRICHED URANIUM RESIDUAL HOLDUP
A. INTRODUCTION
    Part 70, "Domestic Licensing of Special Nuclear Material," of
    Title 10 of the Code of Federal Regulations requires licensees
    authorized to possess more than 350 grams of contained (235)U to conduct
    a physical inventory of all special nuclear material in their possession
    at intervals not to exceed 12 months. Certain licensees authorized to
    possess more than one effective kilogram of special nuclear material are
    required to conduct more frequent measured physical inventories of their
    special nuclear materials. Further, these licensees are required to
    conduct their nuclear material physical inventories in compliance with
    specific requirements set forth in Part 70. Inventory procedures
    acceptable to the NRC staff are described in Regulatory Guide 5.13,
    "Conduct of Nuclear Material Physical Inventories."
    Residual holdup is defined as the inventory component remaining in
    and about process equipment and handling areas after those collection
    areas have been prepared for inventory. In situ assay is used to ensure
    that a measured value of residual holdup is included in each material
    balance. This guide describes procedures acceptable to the NRC staff
    for the in situ assay of the residual enriched uranium holdup.(1)
    Because of the difficulty in measuring in-process holdup, the procedures
    described in this guide for calibration and error evaluation differ from
    general guidance on measuring residual holdup in more accessible
    controlled situations.
    Any guidance in this document related to information collection
    activities has been cleared under OMB Clearance No. 3150-0009.
B. DISCUSSION
    Uranium accumulates in cracks, pores, and zones of poor
    circulation within and around process equipment. The walls of process
    vessels and associated plumbing often become coated with uranium during
    processing of solutions. Uranium also accumulates in air filters and
    associated ductwork. Whenever possible, process equipment should be
    designed(2) and operated to minimize the amount of holdup. The absolute
    amounts of uranium holdup must be small for efficient processing and
    proper hazards control. However, the total holdup can be large
    (relative to the plant inventory difference (ID)) but have no
    significance on the ID if it remains reasonably constant. It is the
    change in the holdup between beginning inventory and ending inventory
    that may impact the inventory difference. The amounts of holdup must
    therefore be determined by an in situ assay.
    ----------
    (1) Assay of residual plutonium holdup is the subject of
    Regulatory Guide 5.23, "In Situ Assay of Plutonium Residual Holdup." A
    proposed revision to this guide has been issued for comment as Task SG
    045-4.
    ----------
    Assay information can be used in one of two ways:
1. When the standard error of uranium holdup is compatible(3)
    with the plant standard error (estimator) of inventory difference
    (SEID), the material balance can be computed using the measured contents
    of uranium holdup. Additional cleanout and recovery for accountability
    will then not be necessary.
2. When the standard error of uranium holdup is not compatible
    with the plant SEID, the information obtained in the holdup survey can
    be used to locate principal uranium accumulations. Once located,
    substantial accumulations can be recovered, transforming the uranium to
    a more accurately measurable inventory component. Having reduced the
    amount of uranium holdup, the standard error on the remeasurement of the
    remaining holdup may be sufficiently reduced to be compatible with
    overall plant SEID requirements.
    ----------
    (2) Design features to minimize holdup in drying and fluidized bed
    operations, equipment for wet process operations, and equipment for dry
    process operations are the respective subjects of Regulatory Guides 5.8,
    5.25, and 5.42.
    (3) Compatibility exists when the contribution of the standard
    error of the holdup to the total plant SEID is not large enough to cause
    the overall SEID to exceed allowed limits. If the plant SEID exceeds
    allowed limits because of an excessive contribution from the holdup
    standard error, compatibility does not exist, and the remedial steps of
    paragraph 2 need to be taken.
    ----------
    The measurement procedures described in this guide involve the
    observation of the 185.7-keV gamma ray emitted in association with the
    decay of (235)U. The amount of (235)U holdup in a piece of equipment is
    proportional to the measured intensity of this gamma ray after suitable
    corrections are made (1) for attenuation by intervening materials, (2)
    for gamma ray self-attenuation by the uranium, (3) for geometrical
    factors that relate the measurement and calibration configurations, and
    (4) for background radiation from nearby sources of (235)U not being
    measured. The proportionality factors are best determined prior to the
    holdup measurement by assays of known quantities of (235)U distributed
    in well-defined and representative geometries as discussed below.
    Note that there may be some cases in which gamma ray measurements
    with electronic detectors may not be practical or even feasible.
    Another gamma ray detection technique that might be attempted is
    thermoluminescence dosimetry (see References 1 and 2). This technique
    may be useful either as an independent check of a conventional gamma ray
    assay or as a substitute for it in environments or geometries where
    conventional detectors cannot be used. This technique will not, however,
    be discussed further in this guide.
    The measurement of holdup in a complex plant environment can
    involve a very large number of measurements, as is implied in the text
    that follows. In a stable plant environment where the process behavior
    is well known and well characterized, it may be possible to arrange the
    holdup measurement program so that careful and extensive holdup
    measurements are made at infrequent intervals (for example, annually);
    at more frequent intervals (for example, at inventory times), careful
    measurements are again made in the (presumably fewer) known problem
    areas, and "spot check" measurements are made in the less problematic or
    less used zones where accumulations are known to be low. Such
    management of measurement resources can result in a very effective
    holdup measurement program at minimum cost.
1. DELINEATION OF COLLECTION ZONES
    To accomplish the gamma ray assay, it is essential to consider the
    facility in terms of a series of zones that can be independently
    assayed. Such zones are designated "collection zones." Each uranium
    processing facility can be conceptually divided into a series of
    contiguous collection zones. Individual process machines, air filters,
    and separate item areas that can be isolated from one another may be
    suitable discrete collection zones. Great care needs to be taken to
    define all collection zones in such a way that (1) the assay of the zone
    can be performed with a minimum of interference and background from
    nearby zones (i.e., so that effective shadow shielding and reliable
    background subtraction can be accomplished); (2) the gamma ray detector
    can be positioned reproducibly and in such a way that the gamma rays
    experience a minimum or easily predicted attenuation in the apparatus
    being measured; and (3) the distribution of material in the zone is
    represented, as much as possible, by one of the distribution geometries
    used in the calibration procedure (see Section B.4.1).
2. GAMMA RAY HOLDUP ASSAY
    Two considerations are critical to the holdup assay. First, to
    perform an assay, the (235)U gamma rays must reach the detector and be
    detected. Second, the observed response must be attributable to the
    collection zone being assayed. Therefore, the assay scheme is
    calibrated to compensate for the poor penetration of the (235)U gamma
    ray. Also, the detector is collimated to separate a collection zone
    from its neighboring zones and from the radiation background. Finally,
    some effort may be necessary to employ external "shadow shielding" to
    block the field of view of the collimated detector from radiation being
    produced in collection zones other than the one being assayed.
    For each gram of (235)U, the 185.7-keV gamma ray is emitted at a
    rate of 4.3 x 10(4) per second. This gamma ray is the only radiation
    emitted in the decay of (235)U that is useful for this assay
    application. Unless mixed with plutonium or thorium, all other gamma
    rays are usually attributable to the Compton scattering of high-energy
    gamma rays emitted by the (234)Pa daughter of (238)U. The background at
    185.7 keV due to this source of radiation varies depending on the length
    of time between the separation of the (238)U daughters from the uranium
    (as frequently occurs during conversion processes) and the assay. This
    interference is very important for low-enrichment uranium but much less
    important at very high-enrichment values.
    On uranium recycled after exposure in a nuclear reactor (where
    plutonium will be produced from the fertile (238)U), a sufficient
    quantity of (232)U or (237)U may be present to emit a measurable amount
    of interfering gamma radiation.
    When uranium is mixed with thorium, the background gamma ray
    spectrum becomes much more complex. The background spectrum may vary
    because the daughters of (232)Th can be volatilized to different extents
    during typical fuel processing. Further information on gamma ray
    interferences at energies near 185.7 keV may be found in Reference 3.
    To ascertain total uranium holdup from the gamma ray assay of
    (235)U holdup, it is necessary to determine from separate measurements
    the enrichment of the uranium holdup and to measure the emitted
    185.7-keV gamma ray with sufficient resolution to enable the intensity
    of that gamma ray to be determined in the presence of the interfering
    radiations encountered. However, there are situations (for example, in
    multi-enrichment processing) in which holdup enrichment cannot be
    accurately measured because (1) the holdup enrichment may not be uniform
    and (2) the samples of holdup material may not be representative. In
    such cases, the uncertainty in the total uranium holdup is increased
    drastically because of the uncertainty in the uranium enrichment used to
    convert the measured fissile holdup to total uranium holdup.
    2.1 Gamma Ray Detection Instruments
    Data processing electronics include a single-channel analyzer for
    the 185.7-keV photopeak, a timer-scaler unit, and a second
    single-channel analyzer used to determine the background radiation
    correction. Both detection channels get their signals from the same
    detector, and the signals are processed through the same electronics
    system. Battery-powered gamma ray analysis systems suitable for this
    application are commercially available and can enhance operational
    convenience. Methods for determining energy window settings are
    provided in References 4 and 5.
    The detection efficiency and resolution of thallium-activated
    sodium iodide, NaI(T1), detectors are generally adequate for this
    application when the uranium is not mixed with plutonium or thorium.
    Cadmium telluride (Refs. 6, 7, and 8) has better resolution than NaI and
    may prove adequate to resolve the 185.7-keV gamma ray from thorium or
    plutonium gamma rays. Lithium-drifted germanium, Ge(Li), and
    high-purity germanium, HPGe (also referred to as intrinsic germanium,
    IG), semiconductor gamma ray detectors have very high resolution but are
    less efficient than the other detector types and are more difficult to
    operate and maintain.(4) Detector crystal dimensions are selected to provide a high
    probability of detecting the 185.7-keV gamma ray and a low probability
    of detecting higher energy radiation. For NaI, a crystal diameter of
    1-1/2 in. (3.8 cm) and a thickness of 1/2 to 1 in. (1.3 to 2.5 cm) is
    recommended. For Ge(Li) and HPGe detectors, a planar crystal
    approximately 10 mm in depth is recommended.
    2.2 Collimators and Absorbers for Gamma Rays
    A shaped shield constructed of any heavy-element nonradioactive
    material is appropriate for gamma ray collimation. More than 98 percent
    of all 185.7-keV gamma rays striking a 0.35-cm-thick sheet of lead are
    absorbed or scattered.
    The collimator will be most effective when it is concentric about
    the crystal and, for NaI detectors, the photomultiplier and its base.
    Extending the collimator forward of the crystal a distance equal to at
    least half the diameter of the crystal, and preferably the full
    diameter, is recommended (Refs. 4 and 5). Making this distance
    adjustable to reproducible settings will facilitate use of the
    collimated detectors for a range of collection zone sites. However, it
    is highly desirable to select collection zones and counting geometries
    so that one collimator setting will suffice for all measurements. This
    will simplify the calibration procedures since the calibration constants
    depend strongly on the collimator settings.
    ----------
    (4) For further information on germanium detectors, see Regulatory
    Guide 5.9, "Specifications for Ge(Li) Spectroscopy Systems for Material
    Protection Measurements," and references cited therein. A proposed
    revision to this guide has been issued for comment as Task SG 042-2 with
    the title "Guidelines for Germanium Spectroscopy Systems for Measurement
    of Special Nuclear Material."
    ----------
    The detector collimator serves the purpose not only of defining
    the effective field of view but also of shielding the detector from
    unwanted radiation. To accomplish this latter purpose effectively, the
    collimator (heavy-element) material must also cover the rear of the
    detector as much as possible. This is usually easy to achieve with
    portable NaI detectors but requires more effort when Ge(Li) or HPGe
    detectors are used.
    Often there is intensive X-ray radiation (in the energy range of
    50 to 100 keV) coming from process equipment, and this radiation can tie
    up the detector electronics unnecessarily. To alleviate this problem, a
    1/32-in.-thick (0.8-mm) layer of cadmium metal can be placed on the
    front face of the detector. This will absorb more than 90 percent of
    the (lower energy) X-rays incident upon the detector with a much smaller
    effect on the 185.7-keV gamma ray and will therefore render the
    detection system more sensitive in the energy region of interest.
    2.3 Check Source for Gamma Ray Assay
    It is important to check the operation of the detection system
    each time the instrumentation is moved or otherwise disturbed (e.g.,
    power outage) during the course of each inventory sequence. An
    appropriate check source enables the stability of the assay instrument
    to be tested at any location. Such a source can be prepared by
    implanting a small encapsulated uranium source (containing about 0.5
    gram of uranium) in the face of a plug of shielding material. The plug
    is shaped to fit and close the collimator channel, and the source is
    positioned adjacent to the crystal when the plug is in place. When the
    response from the check source remains within the expected value, the
    previous calibration data are assumed to be valid. If not, the energy
    window may have shifted, or the unit may be in need of repair and
    recalibration.
3. ISOLATION OF COLLECTION ZONES
    To ensure that each collection zone is independently assayed, it
    is necessary to screen all radiations from the detector except those
    radiations emanating from the collection zone being assayed. This is
    principally accomplished through the use of the collimators described in
    Section B.2.2. Two additional means exist to further isolate a
    collection zone.
    3.1 Detector Positioning
    When uranium is located in back of the zone under assay in another
    collection zone or in a storage facility, the detector can be positioned
    between the radiation sources or above or below the collection zone to
    isolate the zone for assay.
    3.2 Shadow Shielding
    When it is not possible to avoid interfering radiations through
    the collimator design or through choosing the detector position for
    assay, it may be possible to move a shield panel between the source of
    interfering radiations and the collimator zone under assay. If the
    shield panel is sufficiently thick and its dimensions match or exceed
    the near portion of the collection zone under assay, no interfering
    radiations will penetrate through the shadow shield to the detector. A
    lead sheet 0.4 to 0.5 cm thick, which might be mounted on wheels as an
    upright panel, is generally adequate for this application.
4. CALIBRATION FOR HOLDUP MEASUREMENTS
    4.1 Basic Counting Geometries
    There are three fundamental counting geometries that can be used
    to represent most of the distributions of holdup in process equipment.
    These geometries are distinguished by the spatial distribution of the
    source material and the resulting dependence of the detector counting
    rate on the source-to-detector distance, r.
    4.1.1Point Source
    If the material being assayed is distributed over an area with
    dimensions that are small compared with the source-to-detector distance
    and if the material resides entirely within the detector field of view,
    the zone can be treated as a point source. The detector count rate for
    a point source varies inversely as the square of the source-to-detector
    distance (count rate is proportional to 1/r(2)). Any equipment measured
    at great distances or any small pieces of equipment or equipment parts
    fall in this category. (Caution: small-sized sources of uranium could
    have very large self-attenuation of the 185.7-keV gamma ray and could
    therefore require great care in analysis.) 4.1.2Line Source
    If the material being assayed is evenly distributed along a linear
    path so that only a segment of that distribution length is contained in
    the detector field of view, this material can be treated as a line
    source. The detector count rate for a line source varies inversely as
    the source-to-detector distance (count rate is proportional to 1/r).
    Examples of this type of holdup geometry include isolated sections of
    piping and long, narrow trays or columns.
    4.1.3Area Source
    If the material being assayed is spread over an area large enough
    for the material to cover the full field of view of the detector for a
    range of source-to-detector distances, the material can be assayed as an
    area source. As long as the material being viewed is uniformly
    distributed, the detector count rate will be independent of the
    source-to-detector distance. However, for holdup applications, uniform
    material distribution is rare; therefore, the source-to-detector
    distance can affect the instrument response and needs to be specified.
    It should be further noted that, when there are several measurement
    locations covering a large area (such as a floor), it is important to
    maintain the same source-to-detector distance (even if material
    distribution is uniform within a given measurement area) so that the
    number of measurement areas needed to cover the entire area remains
    constant. Examples of this type of assay geometry include floors,
    walls, glovebox floors, and any large-area pieces of equipment.
    4.2 Calibration of Detector Response
    4.2.1Mockup of Known Material Distributions
    For a given collimator setting, the detector response for the
    three basic source distribution geometries listed above needs to be
    determined. For the point source, the response is expressed as (counts
    per minute)/gram of (235)U at a specified source-to-detector distance.
    For the line source, the response is expressed as (counts per
    minute)/(gram of (235)U per unit length) at a specified
    source-to-detector distance. For the area source, the response is
    expressed as (counts per minute)/(gram of (235)U per unit area) at a
    specified source-to-detector distance. Corrections to the point and
    line source calibrations for different detector distances in the actual
    holdup measurements are made using their 1/r(2) and 1/r count-rate
    dependences, respectively. For further detailed discussion of the
    measurement of detector responses for these basic geometries, see
    Reference 9.
    The measurement of the point source response can be accomplished
    with an encapsulated uranium foil smaller in size than the detector
    collimator opening. This foil can also serve as the check source for
    verification of the continued stability of the instrument settings in
    the field.(5) Care must be taken in the preparation of this calibration
    standard to ensure that the amount of (235)U is well known. It is also
    important to measure the gamma ray attenuation through the encapsulating
    material and the self-attenuation of the uranium foil and to
    subsequently correct the calibration standard response to compensate for
    these effects. Enough (235)U needs to be present in this standard to
    provide count rates that will ensure good statistical precision of the
    calibration in a reasonable period of time.
    The measurement of the line source response is best accomplished
    by constructing a cylindrical surface distribution of (235)U with the
    aid of large uranium foils rolled into a cylindrical shape. (It is also
    possible to establish the line source response using a point source, as
    described in Reference 5). The line source geometry is closest to that
    of the pipes and ducts likely to be encountered in actual measurements.
    The amount of (235)U in the foils must be well known to ensure an
    accurate calibration. The area source response can also be measured
    with the same uranium foils laid flat to simulate the expected uranium
    distribution on surfaces such as walls and floors. Self-attenuation by
    the foils must also be taken into account in order for the calibration
    to be as accurate as possible.
    ----------
    (5) Note that a calibration source can be used as a check source,
    but a check source cannot be used as a calibration source.
    ----------
    There may be special material distribution geometries in the
    facility that are not readily represented by one of the three basic
    configurations described above. These special geometries may be mocked
    up as carefully as possible with large uranium foils and point sources
    to produce a usable detector response calibration for these special
    cases. Examples of special cases might be concave or convex equipment
    surfaces or the internal volume of a rectangular cavity (see Reference
    9). Because material particle sizes (or material deposit thicknesses)
    have a significant effect on the self-attenuation of the gamma ray
    signals, it is important to use (whenever practical) well-characterized
    process material for preparing calibration standards and to duplicate to
    the extent possible process holdup distribution relative to particle
    size or thickness. Furthermore, holdup in floors is often deposited at
    various depths into the floor, rather than on the surface. Thus,
    calibration standards for such measurements need to incorporate the
    appropriate geometry and matrix effects. Core samples of a floor may be
    needed to establish typical concentrations at various floor depths.
    Calibration of the holdup measurement system using this procedure
    is recommended until a history of comparisons between predicted and
    recovered holdup quantities is developed. If it is possible to take
    holdup measurements before and after the cleanout of a piece of
    shut-down process equipment, these can be used to establish this history
    of comparisons and improve the accuracy of the calibration for each
    collection zone.
    4.2.2Measurement of Check Sources in Actual Process Equipment
    One method for calibrating detector response to holdup radiation
    in process equipment is to place a known calibration source in various
    positions in that equipment and record the detector responses. In this
    way, the overall detector response (including all corrections for
    attenuation and geometry) is determined empirically. Unfortunately,
    this procedure is impractical, if not impossible, in process equipment
    already in operation. However, those responsible for holdup assays need
    to be aware of occasions when new process equipment is brought into the
    plant for installation. At that time, before installation, calibration
    sources can conveniently be placed in the equipment and the empirical
    measurements of the detector responses can be made. This procedure
    would be a valuable supplement to calibration data obtained from mockups
    of standard counting geometries and comparisons with cleanout recovery
    data.
5. HOLDUP MEASUREMENTS AND STANDARD ERROR
    5.1 Assay Measurements
    In performing the holdup measurements, one must be aware of the
    large uncertainties in holdup assays arising primarily from variability
    in the measurement conditions (e.g., background, geometry, gamma ray
    attenuation, material distribution). Accordingly, every effort should
    be made to perform the assays from as many vantage points as possible
    for each collection zone. If this is impractical on a routine basis
    because of time or space constraints, one might consider multiple
    measurements on a collection zone initially followed by fewer routine
    measurements at representative assay sites. Careful thought in
    selecting measurement points and measurement strategy will minimize
    ambiguities in the interpretation of the data.
    5.1.1Detector Positioning
    Location and configuration of collection zones are established on
    the basis of a detailed physical examination and a radiation survey of
    the physical layout of the facility. Preliminary measurements are
    needed to determine the optimum detector positions for the holdup
    assays. If nonuniform distribution of material in a collection zone is
    suspected or if the process apparatus is sufficiently complicated to
    require extensive attenuation corrections for certain counting
    geometries, multiple measurements are advisable for that collection zone
    and more than one detector position may be necessary. If radiation
    surveys have indicated zones of high holdup, extra care will be
    necessary in the holdup measurements for these zones to minimize the
    contribution of their holdup uncertainties to the SEID. Selecting
    optimum detector positions includes consideration of the need to
    conveniently measure the line-of-sight background by moving the detector
    to one side without changing its orientation.
    5.1.2Holdup Measurements
    The measurement and analysis of the 185.7-ke V gamma ray intensity
    from a collection zone may be carried out by treating the material
    distribution as one of the three basic geometries described in Section
    B.4.1 or as one of the special cases that may have been measured, as
    mentioned in Section B.4.2. If the nature of the material distribution
    is uncertain for a particular detector position, a measurement of the
    detector counting-rate dependence on the source-to-detector distance, r,
    may indicate the most appropriate counting-rate geometry with which to
    interpret the data.
    After the assay positions for the detector and shadow shields are
    established for each collection zone, permanent markings that indicate
    detector location (including height) and orientation will ensure
    reproducibility of subsequent measurements for these positions.
    Uniquely labeling each assay site will facilitate unambiguous reference
    to each measurement and its location in the assay log.
    After measuring the 185.7-ke V gamma ray intensity at each
    detector position in a given collection zone, the line-of-sight
    background is measured by moving the detector and collimator to one side
    of the zone (still pointing in the same direction as during the assay)
    and counting the 185.7-ke V gamma ray intensity from the surrounding
    materials. During the background measurement, the vessel in which the
    holdup is being measured must not be in the field of view of the
    detector. This procedure is repeated at all measurement positions and
    in all counting geometries designated for each collection zone. The
    final holdup value for the zone is obtained from the average of the
    individual measurements (each one being corrected for the effects of
    attenuation and any variation in geometry relative to the calibration
    measurement).
    Whenever possible, the collection zone is assayed in a variety of
    ways. For example, one could measure an apparatus at close range,
    treating it as an area source, and then repeat the measurement at long
    range, treating the zone as a point source. It may be better to measure
    some zones from several different directions-especially if complicated
    attenuation corrections are called for in some of the counting
    geometries. The averaging of several independent measurements of one
    zone helps both to smooth out imprecisions due to incomplete knowledge
    of the measurement conditions and to provide a measure of the magnitudes
    of the fluctuations in the measurement results as an estimate of the
    measurement variability.
    5.1.3Gamma Ray Attenuation Corrections
    To obtain useful assay results by detecting the 185.7-ke V gamma
    ray, it is necessary to correct each assay for attenuation of the
    signal, either within the uranium holdup material or by structural
    materials. Without this critical correction, the assay is no more than
    a lower limit on the true holdup value. Details for establishing an
    appropriate attenuation correction are given in Laboratory Exercise No.
    4 of Reference 5. Additional treatment of gamma ray attenuation
    corrections is given in Reference 10.
    5.1.4Uranium Enrichment
    The 185.7-ke V gamma ray measurement provides the amount of (235)U
    holdup. Total uranium holdup is obtained by dividing the assay result
    by the declared material enrichment in (235)U. For accountability of
    fissile uranium, this step is not necessary. However, as is discussed
    below, conversion of the measurement results to total uranium is
    necessary when making comparisons with other assay techniques that use
    elemental analysis. Also note that, at low enrichment (and to a lesser
    extent at high enrichment), some knowledge of the total amount of
    uranium holdup is necessary to facilitate proper gamma ray
    self-attenuation corrections to the measurements.
    5.2 Assignment of Standard Error
    The assignment of a standard error (i.e., twice the standard
    deviation, sigma) to a holdup measurement is extremely difficult on a
    rigid statistical basis. This situation exists because the only
    statistically predictable fluctuations (i.e., counting statistics) in
    this application are frequently negligible compared with the variability
    due to counting geometry (including material distribution), gamma ray
    attenuation, gamma ray background and interferences, and instrument
    instabilities. Therefore, the variability can be large and it is
    necessary to guard against underestimating the standard deviation of the
    overall holdup value in a collection zone. Careful measurements are
    needed during the calibration procedure to determine the range of
    detector responses resulting from variations in measurement parameters.
    A useful discussion of these ideas is presented in Reference 9.
    A reasonable estimate of the uncertainty in the measured holdup
    for a given collection zone may be obtained by considering the range of
    holdup values obtained from the variety of measurements performed on
    that collection zone as suggested in the previous section. The mean
    value for the holdup is defined as the average of the various
    (corrected) measurement results on the collection zone. In view of the
    well-known uncertainty of holdup measurement, the standard deviation for
    that mean value is conservatively estimated as one-half of the range of
    holdup values obtained in the measurements.
    In some cases, counting statistics may be so poor that they
    contribute significantly to the measurement variability. In such an
    instance, the standard deviation of the overall holdup sigma((h-u)) is
    defined as the square root of the sum of the squares of the standard
    deviation due to counting sigma((stat)) standard deviation due to
    measurement fluctuations sigma((meas)); that is,
    (Due to database constraints, this equation is not included. Please
    contact LIS to obtain a copy.)5.3 Estimation of Bias
    When a single collection zone is cleaned out, it is desirable to
    perform a holdup assay before (H(before)) and after (H(after)) the
    cleanout if possible. By comparing the amount of uranium removed, U(r),
    to the amount predicted through the in situ holdup assays, U(a), the
    collection zone calibration can be updated, and the calibration and
    assay standard deviations can be based on relevant data. The amount of
    uranium recovered, U(r), during the cleanout of a specific collection
    zone can be assayed through sampling and chemical analysis or through
    other applicable nondestructive assay methods.(6) The update data is computed as the difference in the holdup assays
    before and after the cleanout:
    (Due to database constraints, this equation is not included. Please
    contact LIS to obtain a copy.) The percentage difference between the assay and recovery values
    for the uranium holdup,
    (Due to database constraints, this equation is not included. Please
    contact LIS to obtain a copy.)is then computed. A running tabulation of the quantities U(a), U(r),
    and DELTA (as well as their standard deviations, sigma(a), sigma(r), and
    sigma(DELTA)) is kept in the assay log for each collection zone.
    The average value, Overline DELTA, of the percentage differences
    between U(a) and U(r) will serve as an estimate of the bias in the
    holdup assay for that collection zone and will also provide quantitative
    justification for revision of the assay calibration for that zone to
    remove the bias. The root-mean-square deviations, s(DELTA), of the
    percentage differences, DELTA(i), from their mean value, Overline DELTA,
    serves as a check on the appropriateness of the size of the estimated
    standard deviations of the holdup measurements. To the extent that the
    standard deviation of U(r) is small compared with the standard deviation
    of U(a) (usually an adequate assumption), the quantity s(DELTA) should
    be comparable in size to the standard deviation of U(a). For K
    measurements of the percentage differences DELTA(i) for a given
    collection zone, the quantity s(DELTA) is given by:
    (Due to database constraints, this equation is not included. Please
    contact LIS to obtain a copy.)----------
    (6) See, for example, Regulatory Guide 5.11, "Nondestructive Assay
    of Special Nuclear Material Contained in Scrap and Waste." A proposed
    revision to this guide has been issued for comment as Task SG 043-4.
    ----------
    Equation 4 assumes that all of the sigma(DELTA)'s are equal. For a
    calculation of s(DELTA) using weighted sums, see Reference 11.
    Note that, if the holdup measurements (i.e., H(before) or
    H(after)) contain a constant bias, their difference can still provide
    useful information in the comparison with U(r). However, a small
    difference between U(a) and U(r) does not necessarily mean that the
    error associated with H is small. This ambiguity is reduced in
    importance if the cleanout is such that H(after) is much smaller than
    H(before). In addition, the use of several holdup measurements from
    various vantage points, as suggested earlier, will help to minimize the
    bias associated with incorrect geometrical or attenuation corrections in
    one measurement configuration.
    5.4 Effect of Enrichment Uncertainty
    The gamma ray measurements described here provide a direct
    determination of the fissile uranium (i.e., (235)U) holdup in the zone
    under consideration. However, the comparison and verification
    measurements made with chemical techniques provide elemental analysis
    without consideration of the isotopic makeup of the samples. While
    (235)U accountability does not require it, knowledge of the uranium
    enrichment of the material being measured is necessary for meaningful
    comparisons with the chemical analyses. Thus, the holdup assays must be
    divided by the material enrichment to make the comparisons outlined in
    Equations 2 through 4, which are expressed in terms of total uranium.
    If the process equipment is thoroughly cleaned each time the
    enrichment of the uranium feed is changed, the holdup will consist
    primarily of the current material. In that case, the declared
    enrichment can be used. When mixing occurs, use of the stream-averaged
    enrichment is appropriate. The enrichment uncertainty bounds are
    estimated by considering the batches of highest and lowest enrichment
    and computing the corresponding range. The uncertainty in the material
    enrichment must then be incorporated into the quoted holdup uncertainty
    before making direct comparisons with the chemical analyses.
C. REGULATORY POSITION
    To develop a program acceptable to the NRC staff for the periodic
    in situ assay of enriched uranium residual holdup as a method for
    measuring this inventory component, the factors in the following
    sections should be considered.
1. DELINEATION OF COLLECTION ZONES AND ASSAY SITES
    Preliminary radiation survey measurements of the uranium
    processing facility should be used to establish independent collection
    zones and detector positions within the zones.
    At each collection zone, detector positions (assay sites) should
    be chosen so that the material holdup can be measured from several
    vantage points around the zone. At each assay site, the detector should
    have exclusive view of the collection zone being assayed. If necessary,
    shadow shielding should be used to isolate the region being assayed from
    other collection zones. Detector positions should be chosen to minimize
    the measurement ambiguities, as described in Section B.5.1.1.
    Each assay site should be permanently marked with paint or colored
    tape on the floor to ensure reproducible assay positions. Detector
    height and orientation should be clearly indicated in the assay log for
    each measurement site and, if possible, included with the site markings.
    The markings should be protected (for example, with clear epoxy) to
    ensure their long-term durability.
    Each assay site should be uniquely labeled to facilitate
    unambiguous reference to that site in the assay log.
    Areas may be denoted as "problem areas" so that careful holdup
    measurements will be made there each time plant holdup is to be
    determined, or an area may be labeled as a "spot check" zone where
    accumulations are known to be low and careful holdup assays are needed
    less frequently.
2. ASSAY SYSTEM
    2.1 Detector Selection
    NaI(T1) detectors are generally suitable for this application when
    the uranium is not mixed with thorium or plutonium. The crystal depth
    should be sufficient to detect a significant percentage of 185.7-ke V
    gamma rays. For NaI(T1), a 1-inch (2.5-cm) crystal depth is
    recommended. Cadmium telluride, Ge(Li), or HPGe detectors should be used
    when NaI resolution is inadequate to separate the (235)U activity from
    interfering radiations.
    The crystal should be stabilized with a suitable radioactive
    source. An internal seed containing (241)Am is recommended for NaI
    applications. The electronics should be capable of stabilizing on the
    reference peak produced by the seed.
    Two single-channel analyzers should be provided with lock-set
    energy windows. These analyzers should be integrally packaged, should
    get their signals from the same detector, and should process the signals
    with the same electronics. One channel should be set to admit the
    185.7-ke V gamma rays from (235)U. The second channel should be set
    above the first window to provide a background correction for the assay
    window. The electronics unit should have a temperature stability of
    less than 0.1 percent per degree Celsius.
    2.2 Gamma Ray Collimator
    A cylinder of shielding material such as lead should be made
    coaxial with the gamma ray detector. The end of the cylinder opposite
    the crystal should be blocked with the shielding material. The
    thickness of the collimator should be chosen to provide sufficient
    directionality for the specific application (a lead thickness of 0.35 cm
    should be sufficient for most applications). The collimator shield
    should be fixed over the end of the detector crystal at a reproducible
    setting identical to that used in the calibration measurements.
    An absorber should be placed over the front face of the detector
    to filter out unwanted low-energy photons. A 1/32-in.-thick (0.8-mm)
    layer of cadmium metal is recommended.
    2.3 Gamma Ray Calibration and Check Sources
    Standard sources of (235)U should be provided for calibrating the
    measurement system for the basic measurement geometries described in
    Section B.4. A small encapsulated foil of enriched uranium can be used
    both as a calibration standard for the point-source counting geometry
    and as a check source for verification of instrument stability.(7)
    Standard sources for the line and area material distributions should be
    well-characterized uranium samples such as large-area uranium foils of
    well-known thickness and (235)U content, which can be arranged in
    reproducible configurations for the calibration measurements. Other
    well-characterized samples taken from the process may also be advisable
    for use as calibration standards to reflect more realistically actual
    process conditions. The gamma ray self-attenuation correction (or
    equivalently, the effective mass of (235)U without application of the
    correction) should be clearly specified for all of the uranium foils and
    check sources.
3. CALIBRATION
    3.1 Instrument Check
    The stability of the gamma ray detection system should be tested
    prior to each inventory. If the check-source measurement is consistent
    with previous data (i.e., is within plus or minus two single-measurement
    standard deviations of the mean value of previous data), previously
    established calibration data should be considered valid. If the
    measurement is not consistent, the operation of the unit should be
    checked against the manufacturer's recommendations and repaired or
    recalibrated as required.
    ----------
    (7) Recall that a calibration source may be used as a check
    source, but a check source should never be used for calibration.
    ----------
    3.2 System-Response Calibration
    The response of the detection system should be determined with
    well-known quantities of (235)U in the basic measurement geometries
    described in Section B.4. If there are special counting geometries in
    the facility that are not readily represented by one of the basic
    configurations, these geometries should also be mocked up and measured
    during the calibration procedure.
4. ASSAY PROCEDURES
    4.1 Assay Log
    An assay log should be maintained. Each collection zone or
    subzone should have a separate section in the assay log, with the
    corresponding calibration derived on the page facing the assay data
    sheet. Recording space should be provided for the date of measurement,
    gross counts, corrected counts, and the corresponding grams of uranium
    from the calibration in addition to verifying the position and
    electronic setting of the instrument. Also, space in the log should be
    provided for recording data from recovery operations and holdup assay
    comparisons as described in Section B.5.3.
    4.2 Preassay Procedures
    Prior to inventory, the enrichment of the uranium processed during
    the current operational period should be determined. Variations in the
    gamma ray yield data from the calibration standard should be calculated.
    Either the calibration data or the predicted holdup should then be
    corrected to reflect this change.
    Before each inventory, the operation of the gamma ray assay
    detection systems should be checked, as described in Regulatory Position
    3.1.
    Prior to any assay measurements, feed into the process line should
    be stopped. All in-process material should be processed through to
    forms amenable to accurate accountability. All process, scrap, and waste
    items containing uranium should be removed to approved storage areas to
    minimize background radiations.
    4.3 Measurements
    Before beginning the holdup measurements, it is advisable to
    conduct a preliminary gamma survey of the collection zones to point up
    the zones where holdup accumulations are the highest (and therefore
    where the most careful measurements should be made). In zones where
    accumulations are shown to be very low by the survey, spot check
    measurements may be adequate, as pointed out earlier.
    Before assaying each collection zone, the operator should verify
    that floor location, probe height, probe orientation, and electronics
    settings correspond to previous measurements. All check and calibration
    sources should be sufficiently removed (or shielded) to prevent
    interference with the measurement. Prior to taking a measurement, a
    visual check of the zone and the line of sight of the detector probe
    should be made to ensure that no obvious changes have been made to the
    process area and that no unintended accumulations of uranium remain
    within the collection zone. The operator should initial the measurement
    log to ensure compliance for each collection zone.
    When all the preceding steps have been completed, the measurements
    at each collection zone should be taken and recorded. An attenuation
    correction measurement should be made, and the corrected response should
    be converted to grams of (235)U and recorded in the assay log. To
    convert the result to grams of uranium, divide the previous result by
    the declared uranium enrichment. If a high response is noted, the cause
    should be investigated. If the collection zone contains an unexpectedly
    large content of uranium, that collection zone should be cleaned to
    remove the accumulation for conversion to a more accurately accountable
    material category. After the cleanout has been completed, the zone
    should be reassayed and the assay difference before and after cleanout
    should be compared with the recovered material quantity to test the
    validity of the zone calibration as described in Section B.5.3.
5. ESTIMATION OF HOLDUP UNCERTAINTY
    During the initial implementation of the holdup measurement
    program, the holdup uncertainty for each collection zone should be
    estimated from the range of values obtained in the various measurements
    on that zone as described in Section B.5.2. As a history of comparisons
    between holdup measurements and cleanout recovery data becomes
    available, these data should be used to adjust for bias and to revise
    the magnitudes of the holdup uncertainties as described in Section
    B.5.3.
    During each physical inventory, the calibration in at least 10
    percent of the collection zones should be updated on the basis of the
    comparison between holdup and cleanout recovery measurements. In small
    plants with less than ten collection zones, at least one zone should be
    updated during each physical inventory.
    To ensure that error predictions remain current, data from only
    the 12 preceding independent tests should be used to estimate the assay
    uncertainty.
    REFERENCES
1. H. E. Preston and W. J. Symons, "The Determination of Residual
    Plutonium Masses in Gloveboxes by Remote Measurements Using Solid
    Thermoluminescent Dosimeters," UKAEA-Winfrith Report No. AAEW-R
    1359, 1980.
2. A. Ohno and S. Matsuura, "Measurement of the Gamma Dose Rate
    Distribution in a Spent Fuel Assembly with a Thermoluminescent
    Detector," Nuclear Technology, Vol. 47, p. 485, 1980.
3. T. D. Reilly, "Gamma Ray Measurements for Uranium Enrichment
    Standards," in "Measurement Technology for Safeguards and Material
    Control," in Proceedings of the ANS Topical Meeting held at Kiawah
    Island, S.C., November 1979, National Bureau of Standards Special
    Publication 582, p. 103, June 1980.
4. R. B. Walton et al., "Measurements of UF(6) Cylinders with
    Portable Instruments," Nuclear Technology, Vol. 21, p. 133, 1974.
5. R. H. Augustson and T. D. Reilly, "Fundamentals of Passive
    Nondestructive Assay of Fissionable Material," Los Alamos
    Scientific Laboratory, LA-5651-M, 1974; and its supplement, T. D.
    Reilly et al., "Fundamentals of Passive Nondestructive Assay of
    Fissionable Material: Laboratory Workbook," Los Alamos Scientific
    Laboratory, LA-5651-M, 1975.
6. W. Higinbotham, K. Zanio, and W. A. Kutagawa, "CdTe Gamma
    Spectrometers for Nondestructive Analysis of Nuclear Fuels," IEEE
    Transactions on Nuclear Science, Vol. 20, p. 510, 1972.
7. H. B. Serreze et al., "Advances in CdTe Gamma Ray Detectors," IEEE
    Transactions on Nuclear Science, Vol. 21, p. 404, 1974.
8. M. de Carolis, T. Dragnev, and A. Waligura, "IAEA Experience in
    the Development and Use of CdTe Gamma Spectrometric Systems for
    Safeguards Application," IEEE Transactions on Nuclear Science,
    Vol. 23, p. 70, 1976.
9. W. D. Reed, Jr., J. P. Andrews, and H. C. Keller, "A Method for
    Surveying for U-235 with Limit of Error Analysis," Nuclear
    Materials Management, Vol. 2, p. 395, 1973.
10. J. L. Parker and T. D. Reilly, "Bulk Sample Self-Attenuation
    Correction by Transmission Measurement," in Proceedings of the
    ERDA X- and Gamma Ray Symposium, Ann Arbor, Michigan (Conf
    760639), p. 219, May 1976.
    11. P. R. Bevington, Data Reduction and Error Analysis for the
    Physical Sciences, McGraw-Hill, New York, 1969.
    VALUE/IMPACT STATEMENT
1. PROPOSED ACTION
    1.1 Description and Need
    Regulatory Guide 5.37 was published in August 1974. The proposed
    action, a revision to this guide, is needed to bring the guide up to
    date with respect to advances in measurement methods and changes in
    terminology.
    1.2 Value/Impact Assessment
    1.2.1NRC Operations
    The regulatory positions will be brought up to date.
    1.2.2Other Government Agencies
    Not applicable.
    1.2.3Industry
    Since industry is already applying the methods and procedures
    discussed in the guide, updating these should have no adverse impact.
    1.2.4Public
    No adverse impact on the public can be foreseen.
    1.3 Decision on the Proposed Action
    Revised guidance should be developed to reflect the improvement in
    measurement techniques and to bring the language into conformity with
    current usage.
2. TECHNICAL APPROACH
    Not applicable.
3. PROCEDURAL APPROACH
    Of the procedural alternatives considered, revision of the
    existing regulatory guide was selected as the most advantageous and cost
    effective.
4. STATUTORY CONSIDERATIONS
    4.1 NRC Authority
    Authority for the proposed action is derived from the Atomic
    Energy Act of 1954, as amended, and the Energy Reorganization Act of
    1974, as amended, as implemented through the Commission's regulations.
    4.2 Need for NEPA Assessment
    The proposed action is not a major action that may significantly
    affect the quality of the human environment and does not require an
    environmental impact statement.
5. RELATIONSHIP TO OTHER EXISTING OR PROPOSED REGULATIONS OR POLICIES
    The proposed action is one of a series of revisions of existing
    regulatory guides on nondestructive assay techniques.
6. SUMMARY AND CONCLUSIONS
    A revised guide should be prepared to bring Regulatory Guide 5.37
    up to date.
    36