Publication Date: 10/1/83
    Pages: 13
    Date Entered: 2/23/84
    Title: NONDESTRUCTIVE ASSAY OF HIGH-ENRICHMENT URANIUM FUEL PLATES BY GAMMA-RAY SPECTROMETRY (9/74)
    Revision 1
    October 1983
    U.S. NUCLEAR REGULATORY COMMISSION
    REGULATORY GUIDE
    OFFICE OF NUCLEAR REGULATORY RESEARCH
    REGULATORY GUIDE 5.38
    (Task SG 048-4) NONDESTRUCTIVE ASSAY OF HIGH-ENRICHMENT URANIUM
    FUEL PLATES BY GAMMA RAY SPECTROMETRY
A. INTRODUCTION
    Part 70 of Title 10 of the Code of Federal Regulations requires
    each licensee authorized to possess more than 350 grams of contained
    (235)U to conduct a physical inventory of all special nuclear material
    in its possession at intervals not to exceed 12 months. Each licensee
    authorized to possess more than one effective kilogram of
    high-enrichment uranium is required to conduct measured physical
    inventories of special nuclear materials at bimonthly intervals.
    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 for
    complying with these provisions of Part 70 are detailed in Regulatory
    Guide 5.13, "Conduct of Nuclear Material Physical Inventories."
    The fuel for certain nuclear reactors consists of highly enriched
    uranium fabricated into flat or bowed plates. Typically, these plates
    are relatively thin so that a significant percentage of the (235)U gamma
    rays penetrates the fuel and cladding. When the measurement conditions
    are properly controlled and corrections are made for variations in the
    attenuation of the gamma rays, a measurement of the (235)U gamma rays
    can be used as an acceptable measurement of the distribution and the
    total (235)U content of each fuel plate. In lieu of assaying the
    product fuel plates, fuel plate core compacts may be assayed through the
    procedures detailed in this guide provided steps are taken to ensure the
    traceability and integrity of encapsulation of each assayed fuel plate
    core compact. This guide describes features of a gamma ray spectrometry
    system acceptable to the NRC staff for nondestructive assay of
    high-enrichment uranium fuel plates or fuel plate core compacts.
    Any guidance in this document related to information collection
    activities has been cleared under OMB Clearance No. 3150-0009.
B. DISCUSSION
    The number, energy, and intensity of gamma rays associated with
    the decay of (235)U provide the basis for nondestructive assay of
    high-enrichment fuel plates by gamma ray spectrometry (Ref. 1). The
    185.-7-keV gamma ray is the most useful (235)U gamma ray for this
    application; it is emitted at the rate of 4.25 x 10(4) gamma rays per
    second per gram of (235)U. Lower energy gamma rays emitted by (235)U
    are less penetrating and more sensitive to errors due to fluctuations in
    cladding and core thickness. In general, more accurate fuel plate
    assays may be made by measuring only the activity attributable to the
    185.7-keV (235)U gamma ray.
    Assay measurements are made by integrating the response observed
    during the scanning of single fuel plates and comparing each response to
    a calibration based on the response to known calibration standards.
1. GAMMA RAY MEASUREMENT SYSTEM
    1.1 Gamma Ray Detection System
    1.1.1Gamma Ray Detector
    High-resolution gamma ray detectors, i.e., high-purity germanium,
    HPGe, also referred to as intrinsic germanium (IG), or lithium-drifted
    germanium [Ge(Li)] detectors, provide resolution beyond that required
    for this assay application. While the performance of high-resolution
    detectors is more than adequate, their low intrinsic detection
    efficiency, higher maintenance requirements, and high cost make them
    unattractive for the measurements discussed here.
    Most sodium iodide [NaI(TI)] scintillation detectors are capable
    of sufficient energy resolution to be used for the measurement of the
    185.7-keV gamma rays. For plate assays by scanning techniques, the
    detector diameter is determined by the fuel plate width and the scanning
    method selected (see Section B.1.2 of this guide). For passive counting
    of the total fuel plate (see Section B.1.3 of this guide), the detector
    diameter is not a critical parameter, and detectors suitable for plate
    scanning would also be adequate for the passive counting measurements.
    In both cases, the thickness of the NaI crystal is selected to provide a
    high probability of detecting the 185.7-keV gamma rays and a low
    probability of detecting higher energy radiation. A crystal thickness of
    1/2 to 1 inch (13 to 25 mm) is recommended.
    For measurements to be reproducible, it is recommended that the
    detection system be energy stabilized. Internally "seeded" NaI crystals
    that contain a radioactive source (typically (241)Am) to produce a
    reference energy pulse are commercially available. The detection system
    is stabilized on the reference, and the amplifier gain is automatically
    corrected to ensure that the reference energy and the rest of the
    spectrum remain fixed.
    1.1.2Gamma Ray Collimator
    The detector collimator is intended to shield the detector from
    radiation from all sources except those that are to be measured. Thus
    the collimator shielding not only defines the front area of the detector
    crystal to be exposed but it also shields the sides and, if possible,
    the rear of the detector. The front opening of the collimator is
    designed to define the field of view appropriate for the measurement
    technique to be employed. Once a measurement system is calibrated with
    a particular collimator configuration, that configuration must be
    maintained for all subsequent assays. Any change in the collimation
    system will necessitate recalibration of the measurement system.
    1.1.2.1 Collimation for Scanning Techniques. To ensure that
    the only gamma ray activity detected originates from a well-defined
    segment of the fuel plate, the detector is shielded from extraneous
    background radiations and collimated to define the plate area "seen" by
    the detector crystal. The collimator consists of a disk of appropriate
    shielding material. A slit is machined through the center of the disk
    to allow only those gamma rays emitted within the slit opening to strike
    the detector. The disk thickness is a minimum of six mean free path
    lengths to effectively stop all 185.7-keV gamma rays emitted from
    outside the field of view. For more compact counting geometries, higher
    density shielding materials (such as tungsten or lead) can be used. The
    linear dimensions of other shielding materials scale down according to
    the decrease in mean free path length.(1) The probability of detection for gamma rays emitted at the center
    of the collimator slit is greater than that for gamma rays emitted near
    the ends of the slit. This effect becomes increasingly important at
    small detector-to-plate spacing, especially when scanning near the edge
    of a plate. To minimize this detection nonuniformity and to minimize
    the sensitivity to vibration, the detector-to-plate distance can be made
    large, especially with respect to the dimensions of the slit opening.
    As an alternative means of reducing the detection nonuniformity across
    the slit, the slit opening can be divided into channels by inserting a
    honeycomb baffle into the slit or by fabricating the collimator by
    drilling holes through the disk in a pattern that ensures that each hole
    is surrounded by a minimum wall thickness of 0.2 mean free path length.
    A 7.0-cm-thick iron disk with holes less than 0.5 cm in diameter drilled
    in a pattern having 0.2 cm of wall between adjacent holes is one example
    of a collimator that would perform satisfactorily. A large number of
    small-diameter holes is preferable to a few large-diameter holes.
    ----------
    (1) For the 185.7-keV gamma ray from (235)U, a thickness
    equivalent to six mean free path lengths in lead is approximately 0.45
    cm; in tungsten it is approximately 0.33 cm; and in iron it is
    approximately 4.9 cm.
    ----------
    1.1.2.2 Collimation for Total Plate Counting. For total plate
    counting (see Section B.1.3), the collimator opening is circular with a
    diameter less than that of the NaI crystal. Furthermore, the collimator
    diameter and detector-to-plate distance are chosen so that the field of
    view includes the entire fuel plate. (Note that in this more relaxed
    counting geometry, the viewing area may have to be isolated from nearby
    sources of the 185.7-keV gamma rays in the line of sight of the
    detector. This can be accomplished by shadow shielding with small
    pieces of lead or tungsten.) 1.1.3Multiple Detectors
    Several detectors may be used to shorten the measurement time.
    The detectors can be positioned to measure different segments of a
    single fuel plate or several separate fuel plates simultaneously. In
    some cases it may be useful to sum the response from two detectors
    positioned on opposite sides of a plate to increase counting efficiency.
    In such cases, it is essential that the relative response of such
    detectors be known and checked at frequent intervals for continued
    stability.
    1.2 Scanning Techniques
    It is critical that the scanning apparatus for moving the plates
    relative to the detector provide a uniform and reproducible scan. The
    importance of a well-constructed mechanically stable conveyor cannot be
    overemphasized. Either the detector can be moved and the plate held
    stationary, or the plate can be moved past a fixed detector. If the
    detector collimator field of view extends beyond the edges of the fuel
    plate, care must be exercised to maintain the detector-to-plate spacing
    within close tolerances to minimize errors caused by the resulting
    dependence of count rate on this spacing. This is especially important
    in the case of close spacing, which is sometimes desirable to maximize
    the count rate. However, a superior collimator configuration from this
    point of view would be one in which the field of view is filled with
    active material over a range of detector-to-plate distances. In this
    case, the measured material acts as an area source for which the
    counting rate is nearly independent of the detector-to-plate spacing.
    Therefore, in the "sweeping spot scan" technique discussed in Section
    B.1.2.2, the spacing is not as critical a measurement parameter. Various
    commercial conveying systems have been used and found to be adequate.
    Such systems may significantly reduce the cost of designing and building
    new scanning mechanisms. High-precision tool equipment such as milling
    machines, lathes, and x-y scanning tables can be investigated.
    Numerically controlled units offer additional advantages when they can
    be incorporated into a scanning system. This is particularly true when
    an automated scanning system is being developed.
    Fuel plate core compacts may be sufficiently small to permit total
    assay in a fixed-geometry counting system without scanning (see Section
    B.1.3). The scanning techniques for fuel plates discussed in the
    following subsections can also be used for core compacts when total
    fixed compact counting is not possible.
    1.2.1Linear Total Scan
    The detector collimation consists of a rectangular opening that
    extends across the width of the fuel plates beyond the edges of the
    uranium core contained within the plate cladding. Scanning the total
    plate is accomplished by starting the count sequence on the end of a
    plate and continuing to count until the entire length of plate has been
    scanned.
    To ensure that gamma rays emitted anywhere across the face of the
    fuel plate have an equal probability of being detected, it is necessary
    that the diameter of the detector crystal exceed the plate width or that
    the detector be positioned away from the plate.
    Use of the spot or circular collimator scan technique eliminates
    or reduces to insignificance most of these edge effects.
    1.2.2Sweeping Spot Scan
    If the collimator channel width is smaller than the fuel plate
    width, the viewing area (spot) can be swept across the plate as the
    detector scans along the length of the plate (Ref. 2). This scanning
    technique can be readily adapted to scanning bowed plates through the
    use of a cam that is designed to maintain the detector-to-plate distance
    constant over the entire fuel plate. The collimator channel dimensions
    can be selected to provide compatible information on the uniformity of
    the fuel plate, which is frequently obtained by comparing fixed (static)
    spot counts at a variety of locations to reference counts.
    1.2.3Sampled Increment Assay
    When used in conjunction with radiographic dimensional
    measurements performed on all fuel plates, the (235)U content of a fuel
    plate can be measured by scanning the ends of each fuel plate and
    sampling the balance of the plate. It is necessary to measure the
    dimensions of the fuel core loading radiographically through gamma ray
    scanning along the length of the plate or by spot-scanning the fuel
    plate ends and measuring the distance between end spots where the fuel
    loading stops. The (235)U content of the plate is then determined by
    averaging the results of sample spot measurements of the (235)U content
    per unit area at a number of sites along the plate and multiplying this
    average value by the measured area of the fuel core. The radiograph of
    each plate is examined to ensure that the core filler is uniform since
    nonuniformities would invalidate this type of assay.
    The collimator shape and dimensions can be selected to provide
    compatible information on the uniformity of the fuel plate.
    1.3 Passive Total Counting Techniques
    A single passive gamma count of a fuel plate can be used to obtain
    the information of primary concern, namely the total (235)U content of
    the plate. The detector response in a "wide-angle" counting geometry
    can be converted to grams of (235)U in the plate if the response with
    standard fuel plates is known for the same counting geometry and if
    appropriate attenuation corrections are made with suitable transmission
    sources.
    The detector collimator and detector-to-plate distance defines a
    field of view that (a) includes the entire fuel plate and (b) is
    isolated from other sources of radiation in the line of sight of the
    detector. Provide a measurement platform to facilitate the reproducible
    placement of the fuel plates, transmission sources, detector, and
    collimator shielding in a standard measurement configuration.
    Core compacts are also to be assayed in this way provided
    representative standards are used to calibrate the measurement for the
    geometry pertaining to these items.
    Additional details on passive total sample counting and the
    associated attenuation corrections for assay of special nuclear
    materials are given in References 3 and 4.
    1.4 Computer Control
    Computer control of the plate scanning techniques can greatly
    reduce the associated manpower requirements and improve measurement
    reproducibility. The computer can be used to control data acquisition
    by accumulating counts according to a predetermined scheme. Also, the
    computer can be used for data analysis, including background and
    attenuation corrections and intermachine normalization, calibration,
    error analysis, and diagnostic test measurements and analyses. Report
    preparation and data recording for subsequent analysis are also readily
    accomplished through an appropriately designed computer-controlled
    system. Use of a computer can be of great value in many of these
    functions for the total passive gamma counting technique as well.
2. INTERPRETATION OF MEASUREMENT DATA
    The raw measurement data from either a scanning or a total passive
    counting technique can be distorted by several effects for which
    corrections should be made for accurate assays. The three factors
    discussed below are the most important potential sources of measurement
    error that can give rise to significant misinterpretation of the data.
    2.1 Enrichment Variations
    Licensees authorized to possess highly enriched uranium are
    required to account for each element and isotope as prescribed in
    Section 70.51. Under the conditions detailed in this guide, the (235)U
    content of individual plates is measured. To determine the total uranium
    content of each plate, the (235)U enrichment of the core filler must be
    known from separate measurements.
    Enrichment variations may also alter the radiation background in
    the gamma ray energy region of interest and cause fluctuations in the
    (235)U assay. The (238)U decays by alpha particle emission to (234)Th.
    The (234)Th then decays by beta particle emission with a half-life of
    24.1 days to (234)Pa which, in turn, decays by beta particle emission to
    (234)U. Approximately 1 percent of the (234)Pa decays are followed by
    high-energy (e.g., 1001 keV, 766 keV) gamma rays. These gamma rays
    frequently lose energy through Compton scattering and may appear in the
    185-keV spectral region. It is important to note that activity from
    (234)Pa may be altered by disturbing the equilibrium between (235)U and
    (234)Th, as frequently occurs in uranium chemical conversion processes.
    The interference due to variations in (238)U daughter activity becomes
    less important as the enrichment of (235)U increases. At enrichment
    levels above 90 percent, this problem can essentially be ignored.
    2.2 Radiation Attenuation
    Attenuation of gamma radiation may range from complete absorption
    of the radiation by the intervening material to partial energy loss of
    the emitted radiation through scattering processes. Both effects reduce
    the number of full-energy gamma ray events that are detected. Gamma
    rays from (235)U are attenuated in the uranium, in the cladding, and in
    the inert material that may be added with the uranium to form the core
    of the fuel plate. Through well-controlled product tolerance limits,
    each of these potential sources of signal variability can be controlled
    to permit accurate accountability assays.
    2.2.1Self-Attenuation
    The photon attenuation coefficient of uranium for gamma ray
    energies corresponding to (235)U emissions is quite large (Ref. 5).
    Small changes in uranium density resulting from increased fuel loading
    or from variations in the manufacturing process can therefore
    significantly change the number of gamma rays that escape from the fuel
    plate.
    2.2.2Cladding Attenuation
    Small variations in cladding thickness may cause significant
    variations in attenuation. These variations in attenuation can be
    measured by a simple gamma ray absorption test using thin sheets of
    cladding material as absorbers and varying the clad thickness over the
    range of thicknesses to be encountered in normal product variability.
    2.2.3Core Filler Attenuation
    Radiation intensity measurements may be made of plates fabricated
    with different ratios of uranium to filler to show the effects of this
    type of attenuation. If significant effects are noted, plates can be
    categorized by core composition characteristics and the assay system can
    be independently calibrated for each category of fuel plates.
    2.2.4Attenuation Corrections
    When the thickness of the core and cladding and the composition of
    the core material are known, an attenuation correction can be calculated
    and applied to improve the accuracy of the assay. These corrections
    must also be applied to the assays of the standards in the calibration
    procedure. Ultrasonic gauging may provide such a measure if the
    metallographic zones within the plate are sufficiently defined to
    provide a detectable interface.
    The alternative attenuation correction can be based on a
    micrometer measurement of the total thickness of each plate. The clad
    thickness of a plate is estimated by subtracting the mean core thickness
    of the product plates, which is determined by periodically sampling
    product plates and cutting a cross section to permit visual measurement
    of clad and core thickness.
    As long as the gamma ray attenuation corrections are computed on
    the basis of declared component thicknesses and composition (or on the
    basis of occasional measurements of these quantities), unnoticed
    plate-to-plate fluctuations in these parameters will undermine the
    accuracy of the assays. A far more reliable approach to the application
    of attenuation corrections is to measure the gamma ray transmission
    property of each plate (standard as well as unknown) as it is being
    assayed. This approach increases the complexity of the assay
    procedures, but poses the further advantages of (1) rendering the
    calibration dependent only upon the (235)U loading of the standard
    plates and independent of other plate properties and (2) making the
    sample plate assays insensitive to possible fluctuations in cladding
    thicknesses and core composition and thickness. General discussions of
    gamma ray attenuation corrections accompanying passive assays are given
    in References 3, 4, and 6. Specific details of a correction procedure
    for Materials Testing Reactor (MTR) fuel plates are given in the
    appendix to this guide.
    2.3 Interfering Radiations
    As noted in Section B.2.1 of this guide, an internal background
    variation may arise from changes in the amount of (238)U present in a
    fuel plate or from changes in the ratio of (234)Th to (238)U resulting
    from fuel manufacturing processes. Fluctuations in the internal
    background cause the response of the unknown items to be different from
    the calibration standards, thereby creating a fluctuating measurement
    bias. In addition, some discrete gamma ray interferences may be present
    at energies near 185.7 keV. For further information on these possible
    interferences, see Reference 7. Both the background and discrete gamma
    ray interferences are generally of minor importance, but they can be
    corrected for by measurement of additional regions of the gamma ray
    spectrum. Pertinent nuclear data for such measurements are available in
    Reference 1.
    Other interfering radiations may come from external sources, from
    fuel plates awaiting assay, or from nearby radiation sources used for
    other measurements. This is not expected to be a major problem and can
    be controlled through (1) removing radiation sources, (2) shielding the
    detectors, and (3) monitoring the background at frequent intervals.
3. CALIBRATION AND VERIFICATION
    3.1 Initial Operations
    Calibration and the verification of assay predictions is an
    ongoing effort where performance is periodically monitored and the
    calibration relationship is modified to improve the accuracy of assay
    predictions. During initial operations, two means of basing preliminary
    calibrations are appropriate.
    3.1.1Foil Calibration Technique
    Methods for calibrating scanning systems for high-enrichment
    uranium fuel plates through the assay of prepared clad uranium foils are
    described in Reference 2. These methods may be used in place of or in
    addition to the technique described in the following subsection.
    3.1.2Fabricated Calibration Plates
    Calibration standard fuel plates can be fabricated using special
    precautions to ensure that the amounts of uranium, (235)U, inert matrix,
    and cladding are accurately measured and that these parameters fall
    within manufacturing tolerances for product plates.
    3.2 Routine Operations
    The performance of the assay system is periodically monitored to
    ensure that the response of the assay system has not shifted since its
    last calibration. Control limits for acceptable performance can be
    established for the response to an appropriate working standard. The
    control chart of the responses to the working standard can be checked
    for indications of short-term instrument drift or malfunction. The
    control chart can also be analyzed to detect long-term shifts within the
    measurement-to-measurement control limits that may be corrected by
    recalibrating the system. In general, however, it is important that
    observed instrument drifts and performance changes be investigated and
    remedied rather than compensated for by recalibration.
    To ensure that the calibration remains valid during normal
    operations and that accuracy estimates are rigorously justified, assay
    predictions are periodically compared with more accurate measurements of
    the content of typical fuel plates (see Regulatory Postion 4 of this
    guide). Guidance on methods to relate this assay to the national
    measurement system and to reconcile verification measurements is
    addressed in Regulatory Guide 5.58, "Considerations for Establishing
    Traceability of Special Nuclear Material Accounting Measurements."
C. REGULATORY POSITION
    The content and distribution of (235)U in high-enrichment uranium
    plates can be measured through the gamma ray assay methods discussed in
    this guide. Combining this measurement with the results of an
    independent measurement of the (235)U enrichment enables the total
    uranium content of the fuel plates to be determined. The factors
    presented below should be taken into consideration for this assay method
    to be acceptable to the NRC staff.
1. MEASUREMENT SYSTEM
    1.1 Gamma Ray Measurement System
    1.1.1Gamma Ray Detector
    Thallium-activated sodium iodide [NaI(Tl)] scintillation detectors
    are recommended for this assay application. When more than one detector
    is to be incorporated into the measurement system, the performance
    characteristics of the detectors should be matched as closely as
    possible, and the relative response of the detectors should be checked
    periodically to verify continued stability of the system. The diameter
    of the crystal should be larger than the projected view onto the crystal
    face through the collimator channel. A crystal thickness of 1/2 to 1 in.
    (13 to 25 mm) is recommended. The crystal should contain an internal
    seed that is doped with a suitable alpha emitter (typically (241)Am) to
    produce a reference energy peak for spectral stabilization. The seed
    should produce approximately 1,000 counts per second at the reference
    energy.
    1.1.2Collimator and Detector Shielding
    The collimator should be fabricated of appropriate gamma ray
    shielding material such as iron, lead, or tungsten. The shielding should
    completely surround the detector and photomultiplier assembly and should
    be sufficiently thick to completely shield the detector from extraneous
    radiation.
    1.1.3Electronic Apparatus
    All electronic systems should be powered by filtered, highly
    regulated power supplies. The ambient temperature and humidity in the
    vicinity of the scanning system should be controlled so that permitted
    fluctuations do not significantly affect the assay measurements. All
    electronic circuitry in signal-processing components should feature
    temperature compensation. Residual sensitivity to fluctuations in the
    ambient environment should be tested and monitored periodically.
    The capability for multichannel gamma ray pulse height analysis
    with cathode ray tube spectral display should be provided.
    Signal-processing electronics capable of stabilizing on the reference
    energy peak produced by the alpha-emitterdoped seed should be provided
    to stabilize the energy spectrum.
    1.2 Measurement System
    Plate scanning should be accomplished by one of the three
    techniques discussed in Section B.1.2 of this guide. With these
    techniques, a mechanically sound, highly reproducible, automated
    scanning system should be employed. When more than one scanning system
    is employed, the assay responses of each system should be normalized so
    that each instrument provides consistent results. Verification data to
    estimate the bias for each assay system should be obtained with the same
    standard plate.
    If a passive total counting technique is used, a stable, carefully
    constructed measurement platform should be employed to ensure the
    achievement of a reproducible measurement geometry.
    1.3 Computer Control
    A dedicated minicomputer to control data acquisition, calibration,
    diagnostic testing, and report preparation should be employed for fuel
    plate assay operations.
2. MEASUREMENT INTERPRETATION
    2.1 Enrichment Variations
    Procedures should be developed to ensure that the enrichment of
    the plates being scanned is known through separate measurements. Fuel
    plates generally satisfy the gamma ray penetrability criteria for
    quantitative (235)U assay; they do not satisfy the criteria for
    nondestructive enrichment measurement through gamma ray spectrometry.(2)
    Facilities processing more than one uranium enrichment should maintain
    strict isotopic control and characterize the enrichment through
    appropriate measurement methods.
    2.2 Attenuation Corrections
    If computed attenuation corrections are used, attenuation
    variations arising from plate-to-plate changes in core thickness, core
    composition, and clad thickness should be determined over the range of
    product tolerance specifications. When such variations cause the assay
    standard deviation to exceed the standard deviation realized without the
    variations by 33 percent or more, procedures should be implemented to
    measure and apply a correction to the assay of each plate. It should be
    noted that routine measurement of attenuation corrections for each plate
    is recommended since such a procedure will remove the necessity of
    monitoring the variations in plate cladding thicknesses and core
    composition and thickness. For further detail on such corrections, see
    References 4 and 6 as well as the appendix to this guide.
    ----------
    (2) Criteria for gamma ray uranium enrichment measurements are
    given in Regulatory Guide 5.21, "Nondestructive Uranium-235 Enrichment
    Assay by Gamma Ray Spectrometry." A proposed revision to this guide has
    been issued for comment as Task SG 044-4.
    ----------
    2.3 Radiation Interferences
    A graphic record of an acceptable (reference) gamma ray spectrum
    display (i.e., free of interferences and exhibiting nominal background)
    should be prepared. When radioactive interference may be encountered,
    the assay spectrum should be compared at appropriate intervals to the
    reference spectrum for indications of interference. Background
    radiation should be measured periodically during each operating shift.
3. MEASUREMENT CALIBRATION AND CONTROL
    During initial operations, the assay system should be calibrated
    either by the foil calibration method or with specially prepared sample
    fuel plates as described in Section B.3.1 of this guide. Instrument
    response to appropriate working standards should also be checked
    periodically to verify the continued stability of the assay system
    calibration.
4. SOURCES OF VARIATION AND BIAS
    4.1 Random Assay Standard Deviation Estimation
    A replicate assay program should be established to generate data
    for the evaluation of the random assay standard deviation during each
    material balance period. During each bimonthly interval, a minimum of
    fifteen plates should be selected for replicate assay. The second assay
    of each plate selected for replicate assay should be made at least four
    hours after the first assay. Replicate assay data should be collected
    and analyzed at the end of the material balance period. The
    single-measurement standard deviation of the replicate assay differences
    should be computed as described in Reference 8. Replicate measurements
    should be made under the same conditions as routine measurements,
    performed throughout the production run, and checked for consistency.
    If the probability distributions for the data are not different, pooling
    of results from previous inventory periods can improve the random assay
    standard deviation estimates.
    4.2 Calibration Standard Deviation Estimation
    The calibration standard deviation associated with the assay of
    all fuel plates assayed during each calibration period throughout the
    material balance period can be determined through one of the procedures
    presented below. These methods are discussed in detail in ANSI
    15.20-1975, "Guide to Calibration of NDA Systems,"(3) and in Regulatory
    Guide 5.53, "Qualification, Calibration, and Error Estimation Methods
    for Nondestructive Assay" (a proposed revision to this guide has been
    issued for comment as Task SG 049-4).
    ----------
    (3) Available from the American National Standards Institute, 1430
    Broadway, New York, New York 10018.
    ----------
    To estimate the standard deviation arising from the calibration
    procedure, the calibration should be based on a least-squares fitting of
    the calibration data to an appropriate model, then part of the
    calibration standard deviation can be derived using the residual mean
    square. The standard deviation for the calibration standards includes
    the standard deviation of the reference values for the calibration
    standards. See ANSI 15.20-1975.
    To ensure the validity of the measurements, the stable performance
    of the instrument should be monitored and normalized through the
    response to appropriate working standards that are assayed at frequent
    intervals. The frequency for assaying working standards should be
    determined through testing but should not be lower than one test during
    each two-hour assay interval for spot response stability and one full
    scan test during each operating shift. For total passive counting
    techniques, assay of working standards should take place during each
    four-hour assay interval during each operating shift. Indications of
    shifting instrument performance should be investigated and the cause
    should be remedied. The instrument should then be recalibrated to
    ensure the validity of subsequent measurements.
    In order to ensure that the calibration standards continue to
    adequately represent the unknown fuel plates, key production parameters
    that affect the observed response should be monitored through separate
    tests. (If transmission corrections are being measured for each plate
    assayed, the monitoring of plate parameters is less critical for assay
    accuracy.) Data should be compiled and analyzed at the close of each
    material balance period. when a production parameter shifts from
    previously established values, the impact of the shift on the response
    of the assay instrument should be determined through an appropriate
    experiment or calculation (Ref. 9). A bias correction should be
    determined and applied to all items assayed from the point of the
    parameter change. The variance of the bias estimate should be combined
    with the variance due to the calibration procedure. When the bias
    exceeds 3 percent of the plate contents in a single material balance
    period, when a trend of 1.5 percent or more is observed in three
    consecutive material balance periods, or when the standard deviation in
    the estimated bias is sufficient to increase the standard error (i.e.,
    twice the standard deviation) of the assay above 0.5 percent, new
    calibration standards should be obtained and the scanning measurement
    system should be recalibrated.
    As a further check on the continued validity of the calibration
    standards, a program to introduce new calibration standards periodically
    should be implemented. A minimum of one new calibration standard fuel
    plate should be introduced during each six-month period.
    4.3 Bias Estimation
    When two sets of measurements are made on each of a series of
    items and the accuracy of one of the methods used is considerably better
    than the other, the corresponding estimates can be compared to establish
    an estimate of bias between the measurement methods and to estimate the
    random assay standard deviation associated with the less accurate
    measurement method. To determine precisely the bias in the
    nondestructive assay measurement, the fuel plates selected for
    comparative measurements should be randomly selected but should span the
    range of (235)U contents encountered in normal production. The fuel
    plates could have been selected from those rejected from the process
    stream for failing to meet quality assurance requirements. Each plate
    should be repeatedly assayed to reduce the random assay relative
    standard deviation (coefficient of variation) to less than 10 percent.
    To determine its (235)U and total uranium content, the plate should be
    completely dissolved and the resulting solution should be analyzed by
    high-accuracy assay procedures such as chemical and mass-spectrometric
    analyses.
    For one material balance period during the initial implementation
    of this guide, a product fuel plate should be randomly selected twice
    each week for an accuracy verification measurement. Following this
    initial implementation period, facilities manufacturing 100 or more fuel
    plates per week may reduce the verification frequency to one plate per
    week and pool the verification data (provided the two distributions can
    be tested to show no differences) for two consecutive material balance
    periods. Low-throughput facilities manufacturing less than 100 plates
    per week should verify at least 4 plates per material balance period
    through the procedures described above. At the close of each material
    balance period, data should generally be pooled (if allowable) to
    include the 15 most current data points. However, if the data are
    demonstrably stable over longer periods, using additional data points
    from previous compatible results is one method of reducing the random
    assay standard deviation estimate.
    Two methods are presented for estimating the bias. When the (235)U
    content of the plates assayed using a common calibration relationship
    varies over a range of plus or minus 5 percent or more of all plate
    loadings, the bias should be estimated by Method No. 1. When plate
    loadings are tightly clustered about a nominal value, the bias should be
    estimated by Method No. 2.
    Method No. 1. At the close of the reporting period, the assay
    value for each plate is plotted against the verified quantity. The
    verification data plot is examined for indications of nonlinearity or
    obvious outlier data. Anomalous indications should be investigated and
    remedied. Further details on handling outlier data are contained in
    Regulatory Guide 5.36, "Recommended Practice for Dealing with Outlying
    Observations." The comparison data should be analyzed as described in
    Regulatory Position 7.3 of Regulatory Guide 5.53, "Qualification,
    Calibration, and Error Estimation Methods for Nondestructive Assay." A
    proposed revision to this guide has been issued for comment as Task SG
    049-4.
    Method No. 2. When all plates contain essentially the same (235)U
    content, the difference in the mean content values should be tested
    against zero as an indication of bias, and the standard deviation
    associated with an inventory of plates should be estimated as the
    standard deviation of the mean difference. For individual plates, the
    standard deviation should be estimated as the standard deviation of a
    single measurement.
5. CORE COMPACT ASSAY
    Final product assay in high-enrichment fuel plate manufacturing
    can also be accomplished through assaying each core compact following
    the procedures detailed in this guide and the following supplemental
    criteria:
1. Each core compact should carry a unique identification.
    Accountability records should be created for each compact. The fuel
    plate should carry an identification corresponding to the compact
    identification.
2. Each fuel plate should be radiographically examined to
    ensure that the entire compact has been encapsulated.
3. Each fuel plate should be checked with a gamma ray probe to
    ensure qualitatively that the plate core is uranium of the normal
    product enrichment.
4. Calibration and error evaluation should follow the
    procedures for fuel plate assay.
    APPENDIX
    SAMPLE ATTENUATION CORRECTION BY
    TRANSMISSION MEASUREMENT FOR MATERIALS
    TESTING REACTOR FUEL PLATES
1. BACKGROUND
    Gamma ray assay data are subject to distortions due to the attenuation
    of the gamma ray flux by the intervening sample material and sample
    container. The data must be corrected for this effect or the amount of
    nuclear material being assayed will be underestimated. The measured
    intensity I for the 185.7-keV gamma radiation from a Materials Testing
    Reactor (MTR) fuel plate is related to the (235)U content M(U) of the
    fuel plate by:
    (Due to database constraints, this equation is not included. Please
    contact LIS to obtain a copy.)where k is a calibration constant that includes effects such as detector
    efficiency, counting geometry, and nuclear properties of uranium. The
    factor C is the correction factor that adjusts the raw data for the
    attenuation of the 185.7-keV gamma ray by the plate cladding and core
    material.
    Determination of this attenuation correction factor can be
    accomplished using an external gamma ray source. (Ideally, this should
    be a (235)U source. For details on how to use a transmission source
    with a gamma ray energy different from that measured in the assay, see
    Reference 4.) The radiation from this source is detected after it passes
    through the fuel plate, and that transmitted gamma intensity I' is
    compared with the source intensity with no plate present I(o) to obtain
    the gamma ray transmission T through the plate materials:
    (Due to database constraints, this equation is not included. Please
    contact LIS to obtain a copy.) This total plate transmission can be subdivided as follows:
    (Due to database constraints, this equation is not included. Please
    contact LIS to obtain a copy.)where T(c) is the gamma ray transmission through one thickness of the
    plate cladding, and T(U) is the transmission through the core material.
    (The same cladding thickness on both sides of the plate is assumed.) The gamma ray transmission through a plate is dominated by the
    effect of the core material (i.e., T(U)
    treat the cladding transmission T(c) as a constant. Furthermore,
    variations in the core composition will cause more drastic fluctuations
    in the gamma ray attenuation than the small variations in the cladding
    thickness t(c). For example, a 20-mil (0.051 cm) aluminum cladding
    thickness attenuates the 185.7-keV gamma intensity according to:
    (Due to database constraints, this equation is not included. Please
    contact LIS to obtain a copy.)where micro(c) is the mass absorption coefficient of the cladding at
    185.7 keV (for aluminum, micro(c)=0.126 cm(2)/g) and rho(c) is the
    cladding density (for aluminum, rho(c)=2.7g/cm(3)). If the cladding
    thickness varies by as much as 10 percent, the corresponding variation
    in T(c) will be only 0.2 percent. Thus an assumption of invariant
    cladding attenuation for a particular type of fuel plate will contribute
    very little to the assay variance when the constant cladding attenuation
    correction is applied. One then determines T(c) for the fuel plates
    from careful measurement of the cladding thickness and application of
    Equation 4.
    Under the above assumption, one can then determine the
    transmission of the core material T(U) from the measured total plate
    transmission T, knowledge of T(c), and Equation 3. The attenuation
    correction factor in Equation 1 is then given by (see References 3 and
    4):
    (Due to database constraints, this equation is not included. Please
    contact LIS to obtain a copy.)2. IMPLEMENTATION
    2.1 The Scanning Techniques
    A small transmission source should be placed behind the fuel plate
    as shown in Figure 1. The transmission correction must be measured and
    applied at each scan point so that nonuniformities in core composition
    within a plate can be corrected for. The transmission of the plate T(i)
    is measured at each scan point i by determining (1) the plate count rate
    with the transmission source shielded I(i) (Figure 1A), (2) the total
    counting rate of the plate and unshielded transmission source I(T)(i)
    (Figure 1B), and (3) the transmission source count rate with no
    intervening plate I(o)(i) (Figure 1C).
    (Due to database constraints, this equation is not included. Please
    contact LIS to obtain a copy.) If the transmission source is a small localized (235)U source, a
    plate assay with the attenuation correction will require two scans: one
    to get the I(T)(i) values and one to get the I(i) values. (The quantity
    I(o)(i) will be constant at all scan points and can be measured at a
    separate time.) If the transmission source is another fuel plate that
    remains stationary with respect to the plate being assayed, the I(o)(i)
    must be measured by scanning the transmission source fuel plate. That
    is, an unattenuated transmission source plate intensity I(o)(i) must be
    measured at the same scan points i and associated with the corresponding
    I(T)(i) and I(i) from the measurements with the unknown plate. The
    count arrays I(T)(i), I(i), and I(o)(i) must be stored in the computer
    memory as they are measured. The counts I(i) are then corrected by the
    factor in Equation 5 for each total plate transmission T(i).
    2.2 Total Passive Count Technique
    In this case, an average attenuation correction is determined by
    measuring T for the entire plate using a (235)U source behind the plate.
    An extended transmission source is recommended (ideally another fuel
    plate) in order to observe an average transmission over as much of the
    unknown plate as possible. The transmission source must not extend
    beyond or radiate around the edges of the fuel plate being assayed. In
    this case, the assay involves three counts: (1) fuel plate plus
    shielded transmission source I, (2) plate plus unshielded source I(T),
    and (3) unshielded source with no plate I(o). The average plate
    transmission T is then defined as:
    (Due to database constraints, this equation is not included. Please
    contact LIS to obtain a copy.)A single attenuation correction from Equation 5 is then applied to the
    passive count of the plate I.
3. MEASUREMENTS WITH HIGH-RESOLUTION SYSTEMS
    The transmission of the (235)U gamma ray can be inferred from
    measured transmission just above and just below 185.7 keV in energy. In
    one application using high-resolution gamma ray spectrometers (Reference
    10), a (169)Yb transmission source is used. Two of the gamma rays
    emitted by this isotope are at 177.2 and 198.0 keV, conveniently
    bracketing the 185.7-keV energy region. Measurement of T at these two
    energies and interpolating to 185.7 keV results in a determination of
    the attenuation correction factor C at the (235)U gamma ray energy. A
    high-resolution detector system must be used in order to resolve the
    177.2-, 185.7-, and 198.0-keV gamma ray peaks. In this way, the assay
    and transmission correction data are acquired simultaneously and
    multiple scans or multiple counts are not necessary. As a practical
    matter, (169)Yb has the short half-life of 32 days, so this source must
    be replaced frequently (or reirradiated in a reactor) in order to
    provide sufficient counts for a precise measurement of the attenuation
    corrections.
    (Due to database constraints, Figure 1 is not included. Please contact
    LIS to obtain a copy.)REFERENCES
1. J. E. Cline, R. J. Gehrke, and L. D. McIssac, "Gamma Rays Emitted
    by the Fissionable Nuclides and Associated Isotopes," ANCR-1029,
    1972.
2. N. S. Beyer, "Assay of (235)U in Nuclear Reactor Fuel Elements by
    Gamma-Ray Scintillation Spectrometry," Proceedings of the 4th
    International Conference on Nondestructive Testing, London, 1963.
3. R. Sher and S. Untermeyer, The Detection of Fissionable Material
    by Nondestructive Means, American Nuclear Society Monograph, 1980.
4. R. H. Augustson and T. D. Reilly, "Fundamentals of Passive
    Nondestructive Assay of Fissionable Material," Los Alamos
    Scientific Laboratory, LA-5651-M, 1974.
5. E. Storm and H. Israel, "Photon Cross Sections from 0.001 to 100
    MeV for Elements 1 Through 100," Los Alamos Scientific Laboratory,
    LA-3753, 1967.
6. J. L. Parker and T. D. Reilly, "Bulk Sample Self-Attenuation
    Correction by Transmission Measurement," Proceedings of the ERDA
    X-and Gamma-Ray Symposium, Ann Arbor, Michigan, Conf. 760639, p.
    219, May 1976.
7. T. D. Reilly, "Gamma-Ray Measurements for Uranium Enrichment
    Standards," Proceedings of the American Nuclear Society Topical
    Meeting on "Measurement Technology for Safeguards and Material
    Control," Kiawah Island, South Carolina, November 1979; National
    Bureau of Standards Special Publication No. 582, p. 103, June
    1980.
8. J. L. Jaech, "Statistical Methods in Nuclear Materials Control,"
    Atomic Energy Commission, Report No. TID-26298, 1973.
9. R. A. Forster, D. B. Smith, and H. O. Menlove, "Error Analysis of
    a Cf-252 Fuel Rod Assay System," Los Alamos Scientific Laboratory,
    LA-5317, 1974.
10. E. R. Martin, D. F. Jones, and J. L. Parker, "Gamma-Ray
    Measurements with the Segmented Gamma Scan," Los Alamos Scientific
    Laboratory, LA-7059-M, 1977.
    VALUE/IMPACT STATEMENT
1. PROPOSED ACTION
    1.1 Description and Need
    Regulatory Guide 5.38 was published in September 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 of Proposed Action
    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 the guide should have no adverse
    impact.
    1.2.4Public
    No adverse impact on the public can be foreseen.
    1.3 Decision on Proposed Action
    The regulatory guide should be revised to reflect the improvement
    in measurement techniques and to bring the language of the guide 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, and 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
    Regulatory Guide 5.38 should be revised to bring it up to date.
    39