Response for Robinson
From: [email protected] [mailto:[email protected]] On Behalf Of
Michael C Wynn
Sent: Thursday, July 07, 2011 10:40 AM
To: [email protected]
Subject: Powernet: Bulk Volumetric Material Release from Protected or
Controlled Areas
Millstone Power Station would like to know concerning release of bulk
volumetric materials from the Protected or Controlled Areas the following
questions:
1. What are the radiological controls at your station for activities in
areas outside the RCA, but within the Protected Area (also known as Restricted
Area for radiation protection purposes), that involve renovation, repair,
excavation, drilling, digging or cutting of material, components or soil that
contain or may contain radioactive material? We find low levels of
contaminated materials (E-7 - E-8) in various areas of our protected area. Our
procedures require sampling and analysis by gamma spectroscopy to ODCM REMP
LLDs in order to evaluate acceptability for release. Our excavation procedure
includes an excavation permit which must be approved by RNP if the activity is
inside the Protected Area.
What are the radiological controls for these activities in the
Controlled Area (as defined in 10 CFR 20)? We do not evaluate such activities
if they are performed within the OCA but outside the PA fence.
2. If applicable, is there guidance on determining: "contain or may contain
radioactive material"? We evaluate all such materials if the intent is to
remove them from the protected area. Sampling requirements are specified by RP
supervision on a case by case basis.
3. Is any allowance made for residual Cs-137 in soil from weapons fallout
that is not considered licensed radioactive material from plant operations? No
and this is a problem sometimes for us. We would need to perform a study of
the nearby area in order to determine the level of contamination due to fallout
and this has not been performed at our site (I wish!!).
4. How is RP notified of these types of activities outside the RCA? Normally
either through our participation in work planning scheduling process or more
typically the Excavation Permit process.
5. If an RWP is required: Generally not if all of the work is outside of the
RCA.
a. What general controls are specified? See 1 above. Levels of
radioactive material are so low outside the RCA that we don't normally require
any special controls other than preventing material from being removed from the
PA. If we found higher levels of activity than anticipated (during sampling)
we would control commensurate with the radiological hazard.
b. Are all supplemental personnel (for example roofers, laborers) required
to have full radiation worker qualification, or a lower level such as escorted
radiation worker? We perform extensive area monitoring outside our RCA that
demonstrates personnel inside PA but O/S RCA do not require monitoring.
Personnel working inside the RCA must be trained radiation workers.
c. Do the workers log-on the exposure control system with an electronic
dosimeter for the RWP and wear the dosimeter during work activities? Generally
not.
Thank you all in advance for you help.
Michael C. Wynn
Supervisor Radiological Analysis
Millstone Power Station
Bldg. 437/2
Rope Ferry Road
Waterford, CT 06370
Office: (860) 447-1791 Ext. 4815
Fax: (860) 444-4241
http://www.dom.com/
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