Mike,

Palo Verde provides the following response:

1.    What are the radiological controls at your station for activities in 
areas outside the RCA, but within the Protected Area, that involve renovation, 
repair, excavation, drilling, digging or cutting of material, components or 
soil that contain or may  contain radioactive material? Radiological controls 
in this area are limited to items such as excavation and digging (soil 
related), we evaluate the proposed location against our decommissioning file, 
and inside of our Turbine Building and ancillary areas (systems affected by 
past tube leaks.  in my instance we have identified these systems and assign an 
RWP to the work order during the review process.

        What are the radiological controls for these activities in the 
Controlled Area (as defined in 10 CFR 20)?  Outside of the Protected Area 
within the owner controlled area we have numerous satellite RCAs such as the 
ISFSI, low-level radioactive material storage building and a central chem. lab 
for various analysis.  Besides the other requirements, our concern here is 
mostly 1801 and 1801 (access to, and control of radioactive material).

2.    If applicable, is there guidance on determining: "contain or may contain 
radioactive material"? Yes, see above.  This is also covered extensively in our 
material release procedure.

3.    Is any allowance made for residual Cs-137 in soil from weapons fallout 
that is not considered licensed radioactive material from plant operations?  
Yes, if there is no licensed material is identified we will compare the 
concentrations against the initial site radiological characterization study.

4.    How is RP notified of these types of activities outside the RCA?  Thru 
the work control process

5.    If an RWP is required:

        a.    What general controls are specified?  Contact RP prior to 
starting and prior to removing materials from systems or the Turbine Building

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?  No. if they are doing a short duration job that has minimal 
radiological significance we will use the escort process.  if there is more 
complexity and proximity to significant areas they go thru RWT training and are 
badged.

c.     Do the workers log-on the exposure control system with an electronic 
dosimeter for the RWP and wear the dosimeter during work activities?  If 
required by the RWP, yes.  And when they return they will be monitored by a 
contamination and portable monitor and their tools surveyed in a tool monitor.

Seth.

From: [email protected] [mailto:[email protected]] On Behalf Of 
Michael C Wynn
Sent: Thursday, July 07, 2011 7:40 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?

        What are the radiological controls for these activities in the 
Controlled Area (as defined in 10 CFR 20)?

2.    If applicable, is there guidance on determining: "contain or may contain 
radioactive material"?

3.    Is any allowance made for residual Cs-137 in soil from weapons fallout 
that is not considered licensed radioactive material from plant operations?

4.    How is RP notified of these types of activities outside the RCA?

5.    If an RWP is required:

        a.    What general controls are specified?

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?

c.     Do the workers log-on the exposure control system with an electronic 
dosimeter for the RWP and wear the dosimeter during work activities?

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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