Technical paper - No Corrosion products - will generally assume Oxide form (which is also typically the conservative option)
Fission products -typically choose most conservative class unless there is an obvious reason not to Transuranics - Oxide form is usually the obvious choice for Plutonium based on the source being UO2 (10CFR20 doesn't give you options for Am/Cm). However, there is also industry OE (e.g. Bruce Power event) that demonstrates that as the source term ages, the alpha recoil interactions can change the retention class (i.e. increase solubility). If you have a significant uptake of TRUs, it is probably worth the effort to attempt to validate the retention class assumptions. Have not had this discussion in any detail with a regulator. -Steve Stephen J Holmes, CHP, PE Sr Radiation Protection Technical Specialist [email protected]<mailto:[email protected]> 315-791-3577 (desk) 845-476-0796 (mobile) [cid:[email protected]] R.E. Ginna Nuclear Power Plant 1503 Lake Rd Ontario, NY 14519 From: Robinson, Brent [mailto:[email protected]] Sent: Thursday, December 03, 2015 3:35 PM To: '[email protected]' Subject: [EXTERNAL] [powernet] Technical Basis (paper) for Solubility Class Does anyone have a technical basis document they would be willing to share justifying the use of solubility class ALI and DAC values in 10CFR20 Appendix B? If NO: 1. What are you using? 2. Are you using the most restrictive value? 3. If no, how did you determine the proper class? 4. Have you been challenged by regulators on this? A private email response may be appropriate!! Thanks!! Brent L. Robinson TECHNICAL RP SUPERINTENDENT Florida Power & Light St. Lucie Plant 6501 S. Ocean Drive Jensen Beach, Florida 34957 (772) 467-7308 [email protected]<mailto:[email protected]> This Email message and any attachment may contain information that is proprietary, legally privileged, confidential and/or subject to copyright belonging to Exelon Corporation or its affiliates ("Exelon"). This Email is intended solely for the use of the person(s) to which it is addressed. If you are not an intended recipient, or the employee or agent responsible for delivery of this Email to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this Email is strictly prohibited. If you have received this message in error, please immediately notify the sender and permanently delete this Email and any copies. Exelon policies expressly prohibit employees from making defamatory or offensive statements and infringing any copyright or any other legal right by Email communication. Exelon will not accept any liability in respect of such communications. -EXCIP
