We do not do this at Ginna. Oil samples from the RCA are sent to a licensed 
facility unless they meet the criteria for unrestricted release.

Seems like there could be a challenge to validate no "no special nuclear 
material or byproduct material other than that included in 10CFR71 Schedule B" 
if you have any transuranics in your site source term

Steve

Stephen J Holmes, CHP
Manger, Radiation Protection Programs
stephen.hol...@exeloncorp.com<mailto:stephen.hol...@exeloncorp.com>
315-791-3577 | 845-476-0796 (mobile)

[cid:image004.png@01CFD817.5B92ABA0]
R.E. Ginna Nuclear Power Plant
1503 Lake Rd
Ontario, NY 14519



From: Powernet <powernet-boun...@hpspowernet.org> On Behalf Of Noble, Douglas L 
via Powernet
Sent: Thursday, May 23, 2019 8:07 AM
To: powernet@hpspowernet.org
Cc: Noble, Douglas L <dlno...@firstenergycorp.com>
Subject: [EXTERNAL] [Powernet] HPPOS-189 Transfer of Exempt Quantities of 
Byproduct Material

At Davis-Besse small volume oil samples from equipment within the RCA are sent 
to a licensed laboratory for analysis due to inability to attain environmental 
lower limits of detection.

Health Physics Position Statement 189 discusses parameters which if met,  would 
make it permissible to send the low volume sample to an unlicensed laboratory.

Like to know if anyone uses the HPPOS as a basis for transferring samples.

Douglas L Noble
Radiation Protection Manager
Davis-Besse Nuclear Power Station
5501 North State Route 2
Oak Harbor Ohio 43449

419.321.7780 (work)
419.304.0068 (cell)


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