We inventory at the same 6 mo freq as leak tests. As a starting point, we take unused sources out of the normal inventory and lock them in a drum with an inventory and seal. That minimizes sources in inventory and sources needing leak test before use. If a source is in the long-term storage drum and isn't needed for 2yrs for some weird plant cal or other unforeseen reason, we put it in the drum for disposal.
Our operating licenses are vague and you can't find meaningful info in regs for tracking sealed/unsealed, leak testing, or inventory. While 10CFR30 has a generic section about having records for materials for inspection, you don't find detail of reg requirements for a source program. There is a nureg out there for creating rad licenses and maybe it has a little info that regulators use to create those requirements, but I don't recall finding what I was looking for. You can also look on the internet at diff licenses and see how diff licensee vary on what they track. When we change procedures we're supposed to reference the reg to ensure we know we're bounded by the controlling reg. I have never seen an inventory freq requirement in the regs. I only see those details in licenses. In order to leak test every 6 months as required by our license, that means you must find (inventory), so we inventory all sources at that time. Glen Vickers, CHP Exelon Corp RP Technical Lead 815-216-2723 (work/cell) From: Powernet <[email protected]> On Behalf Of Neil A Szuch via Powernet Sent: Tuesday, January 28, 2020 19:49 To: [email protected] Cc: Neil A Szuch <[email protected]> Subject: [EXTERNAL] Re: [Powernet] Physical Source Inventory Frequency Fermi 2 currently performs a physical inventory of all licensed sources annually. We also perform leak checks on all sources that are classified as Leak Check required every 6 months. For exempt sources we perform a physical inventory every two years. Neil Szuch Get Outlook for iOS<https://nam04.safelinks.protection.outlook.com/?url=https%3A%2F%2Faka.ms%2Fo0ukef&data=02%7C01%7Cglen.vickers%40exeloncorp.com%7Cb4829869bf204046ac1508d7a45d7605%7C600d01fc055f49c6868f3ecfcc791773%7C0%7C0%7C637158593645086989&sdata=G5XBJohBx%2Bp8qC1F%2FM%2FRBp1EIp4t3y4Zri12t4Gj5XU%3D&reserved=0> ________________________________ From: Powernet <[email protected]<mailto:[email protected]>> on behalf of Hewitt, Timothy via Powernet <[email protected]<mailto:[email protected]>> Sent: Tuesday, January 28, 2020 5:47:58 PM To: [email protected]<mailto:[email protected]> <[email protected]<mailto:[email protected]>> Cc: Hewitt, Timothy <[email protected]<mailto:[email protected]>> Subject: [EXTERNAL] [Powernet] Physical Source Inventory Frequency DCPP is evaluating the frequency of our physical source inventory. Currently our process is "shall not exceed six months." Recently, a peer evaluation identified that most plants are less strict (e.g., semi-annual) and some are moving to less frequent inventories (e.g., annually). How often does your site perform the physical inventory? Is there any difference in frequency's for different classifications/locations of sources (e.g., exempt and non-exempt, inside or outside the RCA)? Have you recently changed your physical inventory frequency? Thank you for your time and help! Regards, Tim Hewitt DCPP RP Engineer 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
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