CNRO-2002-00037, Entergy Nuclear Northeast, Response to NRC Request for Additional Information on Application for Exemption from Definition of Total Effective Dose Equivalent
| ML021710162 | |
| Person / Time | |
|---|---|
| Site: | Indian Point, Grand Gulf, Pilgrim, Arkansas Nuclear, River Bend, Waterford, FitzPatrick  |
| Issue date: | 06/13/2002 |
| From: | Kansler M Entergy Nuclear Northeast, Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CNRO-2002-00037, ENO Ltr.-1.2.02.053, IPN-02-047, JPN-02-017, NL-02-085 | |
| Download: ML021710162 (11) | |
Text
Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
440 Hamilton Avenue Entergy White Plains, NY 10601 Tel 914 272 3200 Fax 914 272 3205 Michael R. Kansler Senior Vice President &
Chief Operating Otficer June 13, 2002 NL-02-085 I PN-02-047 JPN-02-01 7 ENO Ltr.-1 .2.02.053 CN RO-2002-00037 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137 Washington, DC 20555-0001
SUBJECT:
Indian Point Energy Center, Units 1, 2 and 3 Docket Nos.50-003, 50-247 and 50-286 Pilgrim Nuclear Power Station Docket No. 50-293 Arkansas Nuclear One, Units 1 and 2 Docket Nos. 50-313 and 50-368 James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Waterford 3 Steam Electric Station Docket No. 50-382 Grand Gulf Nuclear Station Docket No. 50-416 River Bend Station Docket No. 50-458 Response to NRC Request for Additional Information on Application for Exemption from the Definition of Total Effective Dose Equivalent
Reference:
Letter from Thomas W. Alexion, Project Manager, Section 1, Project Directorate IV, Division of Licensing Project Management, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission to Mr. Michael R. Kansler, SVP&COO, Entergy Nuclear Operations, Inc., dated May 14, 2002
Dear Sir:
Entergy is providing the attached responses to the NRC staff request for additional information included with the referenced letter.
If you have any questions, please contact Mr. J. Kelly at (914) 272-3370. Entergy's Response to NRC's May 14, 2002 Request for Additional Information on Application for Exemption from the Definition of Total Effective Dose Equivalent (TEDE) cc:
ENTERGY Mr. Hubert J. Miller Regional Administrator, Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 PILGRIM Mr. Travis Tate, Project Manager Project Directorate 1-2 Office of Nuclear Reactor Regulation Mail Stop: O-8B-1A One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Senior Resident Inspector Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Mr. Robert Hallisey Radiation Control Program Center for Communicable Diseases Mass. Dept. of Public Health 305 South Street Jamaica Plain, MA 02130 2
INDIAN POINT 1 Mr. John L. Minns, Project Manager Project Directorate IV-1 Office of Nuclear Reactor Regulation Mail Stop: O-7D-1 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 INDIAN POINT 2 and 3 Mr. Patrick Milano, Project Manager Project Directorate I-1 Office of Nuclear Reactor Regulation Mail Stop: O-8-C2 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Senior Resident Inspector's Office Indian Point Unit 2 U. S. Nuclear Regulatory Commission P. 0. Box 38 Buchanan, NY 10511-0038 Resident Inspector's Office Indian Point 3 Nuclear Power Plant U. S. Nuclear Regulatory Commission P. O. Box 337 Buchanan, NY 10511-0337 JAMES A. FITZPATRICK Mr. Guy Vissing, Project Manager Project Directorate I Office of Nuclear Reactor Regulation Mail Stop: OWFN 8C2 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Resident Inspector's Office James A. FitzPatrick Nuclear Power Plant U. S. Nuclear Regulatory Commission P. 0. Box 136 Lycoming, NY 13093 3
INDIAN POINT and JAMES A. FITZPATRICK Mr. William M. Flynn, President New York State Energy, Research, And Development Authority Corporate Plaza West 286 Washington Avenue Extension Albany, NY 12203-6399 ENTERGY OPERATIONS INC.
Mr. Ellis W. Merschoff Regional Administrator, Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 70611-8064 ARKANSAS NUCLEAR ONE Units 1 and 2 Mr. R. L. Bywater NRC Senior Resident Inspector P. 0. Box 310 London, AR 72847 Mr. William Reckley NRR Project Manager Region IV/ANO-1 U. S. Nuclear Regulatory Commission Mail Stop 7-D-1 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Thomas W. Alexion NRR Project Manager Region IV/ANO-2 U. S. Nuclear Regulatory Commission Mail Stop 7-D-1 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Mr. Bernard R. Bevill Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street Little Rock, AR 72205 4
GRAND GULF NUCLEAR STATION Mr. T. L. Hoeg, NRC Senior Resident Inspector P. 0. Box 399 Port Gibson, MS 39150 Mr. David H. Jaffe NRR Project Manager Region IV/GGNS U. S. Nuclear Regulatory Commission Mail Stop 7-D-1 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Dr. D. F. Thompson State Health Officer State Board of Health P. 0. Box 1700 Jackson, MS 39205 RIVER BEND STATION Mr. P. J. Alter NRC Senior Resident Inspector P. 0. Box 1051 St. Francisville, LA 70775 Mr. R. E. Moody NRR Project Manager Region IV/RBS U. S. Nuclear Regulatory Commission Mail Stop 7-D-1 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 WATERFORD 3 Mr. T. R. Farnholtz NRC Senior Resident Inspector P. 0. Box 822 Killona, LA 70066 Mr. N. Kalyanam NRR Project Manager Region IVIVF3 U. S. Nuclear Regulatory Commission Mail Stop 7-D-1 One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 5
RIVER BEND and WATERFORD 3 Mr. Prosanta Chowdhury Radiation Emergency Response Supervisor Louisiana Department of Environmental Quality P. 0. Box 82215 Baton Rouge, LA 70884-2215 6
ATTACHMENT 1 to NL-02-085, IPN-02-047, JPN-02-017, ENO Ltr. 1.2.02-053, CNRO-2002-00037 ATTACHMENT 1 NL-02-085 IPN-02-047 JPN-02-017 ENO Ltr.-1.2.02.053 CNRO-2002-00037 ENTERGY'S RESPONSE TO NRC's MAY 14, 2002 REQUEST FOR ADDITIONAL INFORMATION ON REQUEST FOR EXEMPTION FROM THE DEFINITION OF TOTAL EFFECTIVE DOSE EQUIVALENT (TEDE)
June 13, 2002 1
ATTACHMENT 1 to NL-02-085, IPN-02-047, JPN-02-017, ENO Ltr. 1.2.02-053, CNRO-2002-00037 Question I The response to Question 1 in Attachment 2 to the July 20, 2001, letter appears to conflict with the exemption request in the body of the letter itself. Verify that Entergy intends to estimate effective dose equivalent (not deep-dose equivalent) with the EPRI method referenced, when you are demonstrating compliance with 10 CFR 20.1201(a)(1)(i) using the requested alternate definition of TEDE. Also verify that compliance with the limit on total organ dose will be demonstrated using deep-dose equivalent (as specified in 10 CFR 20.1201 (a)(1)(ii) and 20.1201 (c)) instead of as stated in your response.
Response
Entergy intends to estimate effective dose equivalent (not deep-dose equivalent) with the EPRI method referenced when we are demonstrating compliance with 10 CFR 20.1201 (a)(1)(i) using the requested alternate definition of TEDE.
Question 2 Your July 20, 2001, letter states that the EPRI method is applicable to "all radiation exposure situations" (see Attachment 1, page 3) and requests approval to use the weighted two-badge algorithm (A3)* when "there is expected to be a significant difference between the deep-dose equivalent [DDE] and the effective dose equivalent [EDE]." However, the algorithms used in the EPRI method for estimating EDE were developed for directional, broad parallel beam gamma exposures. They are not valid for all non-uniform exposure situations. Verify that the method will only be applied in those situations that approximate exposure to directional parallel gamma beams (e.g., no significant dose-rate gradient across the space occupied by the body, ignoring the shielding of the body itself).
- Since the one-badge (Al) "algorithm" discussed in the EPRI documents is consistent with dosimetry practices allowed under the current regulation, no exemption from Part 20 is needed.
Response
In the exemption request of July 20, 2001 on page 3 of Attachment I Entergy stated: "Using the simple algorithms applied to two dosimeters (on the front and the back) yielded a more accurate and numerically lower effective dose equivalent under all radiation exposure situations." This question states, "Verify that the method will only be applied to those situations that approximate exposures to directional parallel gamma beams (e.g. no significant dose-rate gradient across the space occupied by the body, ignoring the shielding of the body itself)."
Reference 5.5 of Entergy's exemption states, "Doses from point sources three meters or more away from the phantom can be predicted using beam geometry results". Since a point source is a limiting case, Entergy will treat any source at a distance of three meters or more as a planar source.
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ATTACHMENT 1 to NL-02-085, IPN-02-047, JPN-02-017, ENO Ltr. 1.2.02-053, CNRO-2002-00037 In reference 5.4 of the exemption request, in Table 8 on page 4-3 and in tables and graphs of , calculated effective dose equivalent information is provided for a point source 44 cm from the phantom centerline (approximately 30 cm from the surface). This data demonstrates that use of EPRI algorithm [A3] as requested in our response to Question 6 (letter of July 20, 2001) will result in a conservative assessment of dose for the case of a point source at 44 cm from the centerline or approximately 30 cm from the body. Entergy is requesting permission to use the EPRI methodology for planar radiation sources and other radiation sources at a distance of 30 cm or more from the body. This will result in a conservative estimate of dose.
Entergy is not requesting use of this EPRI methodology in a water environment such as experienced by divers.
Question 3 Your response to the question above need not discuss body-to-dosimeter self shielding, since it is covered by your response in the July 20, 2001, letter (Question 2 in Attachment 2), to ensuring that at least one dosimeter "see" the major exposure source at all times. However, the statement in this response that "job-specific Radiation Work Permits will require the worker to move about to ensure this requirement is met" seems impractical. Please clarify.
Response
Radiation Work Permits and radiation worker training will provide guidance to assure that the personnel dosimeter remains exposed to the radiation source. Similar instruction is currently provided to workers wearing only one personnel dosimeter for routine work in radiation areas.
Question 4 Verify that the front and back dosimeters used in the A3 method of assessing EDE will be calibrated to read DDE at the point of measurement.
Response
The front and back dosimeters used in the A3 method of assessing EDE will be calibrated to read DDE at the point of measurement.
Question 5 The published paper, "Two Methods For Examining Angular Response of Personnel Dosimeters," by P. Plato, et. al. (Reference 5.13 in the July 20, 2001, letter), provides evidence that the Panasonic UD-802 dosimeter, currently in use in the Entergy system, has angular dependent response characteristics suitable to support the EPRI algorithms. Is the Entergy request narrowly restricted to the use of the UD-802 dosimeter? If not, commit to using 3
ATTACHMENT 1 to NL-02-085, IPN-02-047, JPN-02-017, ENO Ltr. 1.2.02-053, CNRO-2002-00037 dosimeters that have an angular response at least as good as that described in the paper, "A Study of the Angular Dependence Problem in Effective Dose Equivalent Assessment," by X. Xu, et. al. (Reference 5.7 in the July 20, 2001, letter).
Response
Entergy's request is not restricted to the use of the UD-802 dosimeter. Entergy will use dosimeters that have an angular response at least as good as that described in the paper, "A Study of the Angular Dependence Problem in Effective Dose Equivalent Assessment," by X. G.
Xu, et al (Reference 5.7 in the July 20, 2001 letter).
Question 6 The guidelines for implementation of the EPRI methodology for assessing EDE in Reference 5.8 in the July 20, 2001, letter are vague as to whether the EPRI algorithms (specifically A3) are valid for assessing EDE from point sources (or hot particles) on or near the surface of the body.
Therefore, it is unclear if assessing EDE from external point sources is included in the Entergy request. The information in Volumes 1 and 2 of EPRI TR-1 01909 (July 20, 2001, letter, References 5.4 and 5.6, respectively), is insufficient for the staff to conclude that the A3 method is valid for assessing EDE from point sources in all cases. Verify that Entergy does not intend to use this method for assessing EDE from point sources on or near the surface of the body or provide the following information.
6.1 The "true" EDE (calculated by Monte Carlo method) values resulting from point source exposures, provided in Tables 5, 6 and 7 of Volume 1, are not based on the organ weighting factors given in Part 20 and therefore not appropriate for demonstrating compliance with the requirement in 20.1201 (a)(11)(i). The geometry of these calculations is constrained to locations on the trunk of the body (from 6 cm to 61 cm above the point the legs join the body). It is easy to describe an exposure situation, outside the bounds of these calculations, where a point source (i.e., located on the inside of upper thigh) would result in a significant EDE. Describe how a conservative EDE, consistent with the definition in Part 20, will be assessed for all exposures to point sources located on, or near, the surface of the entire body.
6.2 The data in Table 9 of Volume 2 is too limited to demonstrate that the EDE values assessed with the EPRI methodology are valid for hot particle exposures. The geometry of the exposure situation, discussed in 6.1 above, is further restricted such that the two dosimeters are located either at the hip or mid-torso, with the point sources located at the same height (e.g., in the same plane cutting horizontally through the body) as the dosimeters. No information is provided on how the calculated, or indicated, EDE varies as the source is moved up or down the body away from the plane of the dosimeters. The ratio of the EDE calculated by the A3 method to the "true" EDE is presented for just five grid locations radially around the body in each dosimeter plane.
The potential for self-shielding of both dosimeters from the point source is not addressed since the source grid locations evaluated are not on the surface of the body. Provide 4
ATTACHMENT 1 to NL-02-085, IPN-02-047, JPN-02-017, ENO Ltr. 1.2.02-053, CNRO-2002-00037 data that demonstrates that the EDE calculated with the A3 method is a conservative (e.g., the ratio of the calculated to "true" EDE is greater than or equal to one) estimate of the EDE for all point source locations on, or near, the surface of the entire body.
Response
The method will not be used to assess effective dose equivalent for point sources less than 30 cm from the body or hot particles.
Question 7 Verify that the values for parallel beam sources, in units of "E-1 5 rad-cm squared per photon,"
as stated in EPRI TR-1 01909, Volume 2, Table 8, are off by 5 orders of magnitude, and will not be used specifically for calculating EDE in a real exposure situation.
Response
The values for parallel beam sources, in units of "E-15 rad-cm squared per photon," as stated in EPRI TR-1 01909, Volume 2, Table 8, are off by 5 orders of magnitude; the correct units should be "E-10 rad-cm squared per photon." These values will not be used specifically for calculating EDE in a real exposure situation.
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