ML062120154

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GGNS, IP-1, IP-2, IP-3, Pilgrim, River Bend, Vermont Yankee, and Waterford - Application to Use Effective Dose Equivalent Weighting Factors for External Exposure
ML062120154
Person / Time
Site: Indian Point, Grand Gulf, Pilgrim, Arkansas Nuclear, River Bend, Vermont Yankee, Waterford  Entergy icon.png
Issue date: 10/02/2006
From: Terao D
Plant Licensing Branch III-2
To: Burford F
Entergy Operations
Vaidya B, NRR/DORL/LP4, 415-3308
References
TAC MD1736, TAC MD1739, TAC MD1740, TAC MD1741, TAC MD1742, TAC MD1743, TAC MD1744, TAC MD1745
Download: ML062120154 (16)


Text

October 2, 2006 Mr. F. G. Burford Acting Director Nuclear Safety and Licensing Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213-8298

SUBJECT:

ARKANSAS NUCLEAR ONE, UNIT 1, GRAND GULF NUCLEAR STATION, UNIT 1, INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, PILGRIM NUCLEAR POWER STATION, RIVER BEND STATION, UNIT 1, VERMONT YANKEE NUCLEAR POWER STATION, AND WATERFORD STEAM ELECTRIC STATION, UNIT 3 - APPLICATION TO USE EFFECTIVE DOSE EQUIVALENT WEIGHTING FACTORS FOR EXTERNAL EXPOSURE (TAC NOS. MD1736, MD1739, MD1740, MD1741, MD1742, MD1743, MD1744, AND MD1745)

Dear Mr. Burford:

By letter dated May 16, 2006, Entergy Operations, Inc., and Entergy Nuclear Operating, Inc.

(Entergy or the licensee), requested the U.S. Nuclear Regulatory Commission's (NRC's) approval for the use of the weighting factors provided in the American National Standard Institute (ANSI) HPS N13.41-1997 (the Standard) for external radiation exposures when demonstrating compliance with total effective dose equivalent (TEDE), based on requirements in Part 20 of Title 10 to the Code of Federal Regulations (10 CFR) for Arkansas Nuclear One, Unit 1 (ANO-1), Grand Gulf Nuclear Station, Unit 1 (GGNS), Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3), Pilgrim Nuclear Power Station (Pilgrim), River Bend Station, Unit 1 (RBS), Vermont Yankee Nuclear Station (VY), and Waterford Steam Electric Station, Unit 3 (Waterford 3).

The NRC staff has completed its review. Enclosed is the NRC staffs related safety evaluation that concludes that your request for the use of the weighting factors provided in the Standard for external radiation exposures when demonstrating compliance with TEDE, based on requirements in Part 20 of 10 CFR for ANO-1, GGNS, IP2, IP3, Pilgrim, RBS, VY, and Waterford 3, is acceptable.

F. Please contact me at (301) 415-1302 or Bhalchandra K. Vaidya at (301) 415-3308, if you have any questions on this matter.

Sincerely,

/RA/

David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313, 50-416, 50-247, 50-286, 50-293, 50-458, 50-271, and 50-382

Enclosure:

Safety Evaluation cc w/encl: See next page

F. Please contact me at (301) 415-1302 or Bhalchandra K. Vaidya at (301) 415-3308, if you have any questions on this matter.

Sincerely,

/RA/

David Terao, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-313, 50-416, 50-247, 50-286, 50-293, 50-458, 50-271, and 50-382

Enclosure:

Safety Evaluation cc w/encl: See next page DISTRIBUTION:

PUBLIC RidsOgcRp RidsAcrsAcnwMailCenter RidsNrrDorlLpl1-1(RLaufer)

LPLIV r/f LPL1-1 r/f RPedersen, DIRS SBernal, DIRS RidsNrrDorlLpl4 (DTerao)

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BSosa (RI)

RidsRgn4MailCenter (DGraves/KKennedy)

RidsRgn1MailCenter (ECobey/RPowell)

ACCESSION NO: ML062120154 NRR-106

  • No substantial change in the SE Input OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/IHPB/BC
  • OGC-NLO NRR/LPL4/BC NAME BVaidya LFeizollahi TFrey KWinsberg DTerao DATE 8/3/06 8/3/06 6/23/2006 8/10/06 10/2/06 OFFICIAL RECORD COPY E:\\Filenet\\ML062120154.wpd

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE APPROVAL TO USE WEIGHTING FACTORS FOR EXTERNAL RADIATION EXPOSURES ENTERGY OPERATIONS, INC., AND ENTERGY NUCLEAR OPERATING, INC.,

ARKANSAS NUCLEAR ONE, UNIT 1, GRAND GULF NUCLEAR STATION, UNIT 1, INDIAN POINT NUCLEAR GENERATING UNIT NOS. 2 AND 3, PILGRIM NUCLEAR POWER STATION, RIVER BEND STATION, UNIT 1, VERMONT YANKEE NUCLEAR POWER STATION, AND WATERFORD STEAM ELECTRIC STATION, UNIT 3 DOCKET NOS. 50-313, 50-416, 50-247, 50-286, 50-293, 50-458, 50-271, and 50-382

1.0 INTRODUCTION

By letter dated May 16, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML061430359), Entergy Operations, Inc., and Entergy Nuclear Operating, Inc. (Entergy or the licensee), requested the U.S. Nuclear Regulatory Commission's (NRC's) approval for the use of the weighting factors provided in the American National Standard Institute (ANSI) HPS N13.41-1997 (the Standard) for external radiation exposures when demonstrating compliance with total effective dose equivalent (TEDE), based on requirements in Part 20 of Title 10 of the Code of Federal Regulations (10 CFR) for Arkansas Nuclear One, Unit 1 (ANO-1), Grand Gulf Nuclear Station, Unit 1 (GGNS), Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3), Pilgrim Nuclear Power Station (Pilgrim), River Bend Station, Unit 1 (RBS), Vermont Yankee Nuclear Station (VY), and Waterford Steam Electric Station, Unit 3 (Waterford 3). The effect of granting this request would be to allow the licensee the option to control TEDE using the weighted external exposure measurements in those cases where it is a more accurate predictor of the risk from occupational radiation exposure.

2.0 REGULATORY EVALUATION

The radiation protection approach, and dose limits contained in Part 20 of 10 CFR are based on the recommendations of the International Commission on Radiation Protection (ICRP) in their 1977 Publication No. 26 (ICRP 26). For stochastic effects, the ICRPs recommended dose limitation is based on the principle that the risk should be equal, whether the whole body is irradiated uniformly or there is non-uniform irradiation (such as when radioactive materials are taken into the body and, depending on their physical and chemical properties, concentrate in certain tissues and organs). Therefore, the ICRP 26 recommendations are based on controlling the sum of the risk weighted doses to selected organs.

Effective dose equivalent (EDE or E) is defined in 10 CFR 20.1003 as the sum of the products of the dose equivalent to the organ or tissue (T) and the weighting factors (WT) applicable to each of the body organs or tissues that are irradiated (E = WTT ).

For the purposes of implementing workplace controls, and due to the difference in dosimetry, 10 CFR Part 20 breaks this EDE into two components: (1) dose resulting from radioactive sources internal to the body, and (2) dose resulting from sources external to the body. Dose limits and other requirements in Part 20 are based on the sum of these external and internal exposures. For radioactive material taken into the body, the occupational dose limit is based on the resulting dose equivalent integrated over 50 years, or committed effective dose equivalent (CEDE) defined in 10 CFR 20.1003 as WTT,50.

The TEDE is defined in 10 CFR 20.1003 as the sum of the deep-dose equivalent (DDE) (for external exposures), and the committed effective dose equivalent (for internal exposures).

TEDE = DDE + CEDE The organ weighting factors (WT) are the proportion of the risk of stochastic effects resulting from the dose to that organ or tissue to the total risk of stochastic effects when the whole body is irradiated uniformly. The weighting factors are applicable to the organs and tissues whether the dose results from radiation sources internal or external to the body. However, measuring the dose to the various organs and tissues with a dosimeter worn outside the body, presents some practical difficulties. If the body is irradiated uniformly, the external component of TEDE can be determined with a single DDE measurement on any part of the whole body. However, if the body is not irradiated uniformly, a single-dose measurement cannot determine the dose to the various organs and tissues for an accurate determination of the external EDE (EDEex). To ensure a conservative determination of TEDE, 10 CFR 20.1201(c) requires that the DDE component be determined from the part of the whole body receiving the highest exposure.

Authority to permit the use of other weighting factors is found in footnote 2 to the table of organ weighting factors in 10 CFR 20.1003, which states, [f]or the purpose of weighting the external whole body dose (for adding to the internal dose), a single weighting factor, of WT = 1.0, has been specified. The use of other weighting factors for external exposure will be approved on a case-by-case basis until such time as specific guidance is issued.

This approach to determining TEDE can be overly conservative for extremely non-uniform irradiations (i.e., when only a small portion of the whole body is irradiated). As discussed in the NRC Regulatory Issue Summaries 2002-06, 2003-04, and 2004-01, the NRC has approved several methods for determining EDEex, and has encouraged the use of EDEex in place of DDE for demonstrating compliance with the TEDE requirements in Part 20 of 10 CFR.

3.0 TECHNICAL EVALUATION

3.1 Evaluation The NRC staff has reviewed the technical approach for estimating EDEex provided in the Standard. This multiple dosimetry method divides the whole body into seven separate compartments. Each compartment, or composite compartment (since the Standard allows combining adjacent compartments), is monitored separately. The results of the dose measurement for each compartment are weighted with an associated compartment factor.

The resulting weighted doses are then summed to determine the EDEex for the whole body.

The compartment factors are listed in Table 1 of the Standard. The factor for each compartment was developed by summing the stochastic weighting factors given in ICRP 26 (Part 20 organ weighting factors) for all the organs located within that compartment. For each tissue that resides in more than one compartment (e.g., red bone marrow), the weighting factor was apportioned between the compartments based on the fraction of the total mass of the tissue residing in each, using the information in ICRP 23.

The ANSI/HPS 13.41 multiple dosimeter method of determining EDEex is based on the assumptions that (1) the average dose to the tissues in each compartment can be reasonably measured (with one or more dosimeters), and (2) that the dose distribution across the compartment is sufficiently constant so that this average dose can be applied to each tissue in the compartment. The compartments defined in the Standard are small enough so that under most normal exposure situations these assumptions are met and a single determination of DDE in each compartment is sufficient. However, this may not be the case in those unusual situations where a significant dose gradient exists across one or more compartments (particularly the thorax and abdomen compartments). In these cases, the number and placement of dosimeters in each compartment become critical to ensuring that the EDEex is not underestimated.

To ensure that the estimates of EDEex are conservative, the licensee has committed to measuring the dose to each compartment (or composite compartment) by locating the dosimeter, calibrated to DDE, at the highest exposed portion of that compartment. The dosimeter location for each compartment will be subject to the same criteria currently used for demonstrating compliance with 10 CFR 20.1201(c).

The licensee has stated that in most normal exposure situations they intend to provide one dosimeter for a combined thorax-abdomen composite compartment, consistent with the Standard and their current multi-badging practice.

3.2 Regulatory Commitments The following table identifies the regulatory commitments made by Entergy.

List of Regulatory Commitments COMMITMENT TYPE (Check one)

SCHEDULED COMPLETION DATE (If Required)

ONE-TIME ACTION CONTINUING COMPLIANCE Entergy will monitor the part of the whole body within each compartment (and/or composite compartment) that receives the highest dose.

Entergy is developing a fleet wide Nuclear Management Manual procedure EN-RP-204, Special Monitoring Requirements, for determining dosimeter selection and placement. This procedure guidance will be consistent with that found in NRC Inspection Procedure 71121.01, issue date 03/06/02.

x Based on the NRCs approval of this request, Entergy will account for dose consistent with the guidance of the Standard as follows:

The DDE for each compartment will be determined from dosimeters worn at that location. When no dosimeter is worn at a particular compartment, the DDE will be determined from the dosimeter positioned where the exposure is judged to be similar.

The assigned EDE will be the sum of each DDE measurement multiplied by its appropriate compartment factor.

The assigned lens dose equivalent (LDE) will be the higher of the head or chest dosimeters.

The assigned shallow dose equivalent (SDE) will be the highest of any whole body dosimeter.

x The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments are provided by the licensees administrative processes, including its commitment management program.

Should the licensee choose to incorporate a regulatory commitment into the emergency plan, the Updated Final Safety Analysis Report, or other documents with established regulatory controls, the associated regulations would define the appropriate change-control and reporting requirements. The NRC staff has determined that the commitments do not warrant the creation of regulatory requirements, which would require prior NRC approval of subsequent changes.

The NRC staff has agreed that Nuclear Energy Institute 99-04, Revision 0, Guidelines for Managing NRC Commitment Changes, provides reasonable guidance for the control of regulatory commitments made to the NRC staff (see Regulatory Issue Summary 2000-17, Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff, dated September 21, 2000). The commitments should be controlled in accordance with industry guidance or comparable criteria employed by a specific licensee. The NRC staff may choose to verify the implementation and maintenance of these commitments in a future inspection or audit.

4.0 CONCLUSION

S The NRC staff concludes that calculating TEDE using EDEex in place of DDE provides a more accurate estimate of the risk associated with the radiation exposures experienced by radiation workers at a nuclear power plant. The NRC staff finds that limiting TEDE such that EDEex + CEDE < 5 rem is consistent with the basis for the dose limits, and footnote 2 to the Organ Dose Weighting Factors table in 10 CFR Part 20.1003.

Additionally, the NRC staff concludes that the multiple dosimetry method to estimate EDEex using the weighting factors listed in Table 1 of the Standard, as proposed by the licensee, is technically sound and is acceptable for the purposes of demonstrating compliance with the TEDE-based requirements in Part 20 of 10 CFR.

Therefore, based on the above discussion and the information provided by Entergy in its submittal, the NRC staff approves the use of the weighting factors provided in the ANSI HPS N13.41-1997 (the Standard) for external radiation exposures when demonstrating compliance with TEDE, based on requirements in 10 CFR Part 20 for ANO-1, GGNS, IP2, IP3, Pilgrim, RBS, VY, and Waterford 3.

Principal Contributor: R. Pedersen Date: October 2, 2006

Arkansas Nuclear One, Unit 1 Grand Gulf Nuclear Station River Bend Station Waterford Steam Electric Station, Unit 3 cc:

May 2006 Senior Vice President

& Chief Operating Officer Entergy Operations, Inc.

P. O. Box 31995 Jackson, MS 39286-1995 Director, Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Winston & Strawn 1700 K Street, N.W.

Washington, DC 20006-3817 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 310 London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County Pope County Courthouse Russellville, AR 72801 Vice President, Operations Support Entergy Operations, Inc.

P. O. Box 31995 Jackson, MS 39286-1995 Wise, Carter, Child & Caraway P. O. Box 651 Jackson, MS 39205 Mr. Jeffrey S. Forbes Vice President Operations Arkansas Nuclear One Entergy Operations, Inc.

1448 S. R. 333 Russellville, AR 72801 Chief Energy and Transportation Branch Environmental Compliance and Enforcement Division Mississippi Department of Environmental Quality P. O. Box 10385 Jackson, MS 39289-0385 President Claiborne County Board of Supervisors P. O. Box 339 Port Gibson, MS 39150 Senior Resident Inspector U. S. Nuclear Regulatory Commission P. O. Box 399 Port Gibson, MS 39150 General Manager, GGNS Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 State Health Officer State Board of Health P. O. Box 1700 Jackson, MS 39205 Attorney General Department of Justice P. O. Box 94005 Baton Rouge, LA 70804-9005

Arkansas Nuclear One, Unit 1 Grand Gulf Nuclear Station River Bend Station Waterford Steam Electric Station, Unit 3 cc: May 2006 Office of the Governor State of Mississippi Jackson, MS 39201 Attorney General Asst. Attorney General State of Mississippi P. O. Box 22947 Jackson, MS 39225 Director Nuclear Safety Assurance Entergy Operations, Inc.

P.O. Box 756 Port Gibson, MS 39150 Director Nuclear Safety and Licensing 1340 Echelon Parkway Jackson, MS 39213-8298 Richard Penrod, Senior Environmental Scientist State Liaison Officer Office of Environmental Services Northwestern State University Russsell Hall, Room 201 Natchitoches, LA 71497 Mr. William R. Brian Acting Vice President, Operations Grand Gulf Nuclear Station Entergy Operations, Inc.

P. O. Box 756 Port Gibson, MS 39150 Manager - Licensing Entergy Operations, Inc.

River Bend Station 5458 US Highway 61N St. Francisville, LA 70775 Senior Resident Inspector P. O. Box 1050 St. Francisville, LA 70775 President of West Feliciana Police Jury P. O. Box 1921 St. Francisville, LA 70775 Ms. H. Anne Plettinger 3456 Villa Rose Drive Baton Rouge, LA 70806 General Manager - Plant Operations Entergy Operations, Inc.

River Bend Station 5485 US Highway 61N St. Francisville, LA 70775 Director - Nuclear Safety Entergy Operations, Inc.

River Bend Station 5458 US Highway 61N St. Francisville, LA 70775 Attorney General State of Louisiana P. O. Box 94095 Baton Rouge, LA 70804-9095 Mr. Brian Almon Public Utility Commission William B. Travis Building P. O. Box 13326 1701 North Congress Avenue Austin, TX 78701-3326

Arkansas Nuclear One, Unit 1 Grand Gulf Nuclear Station River Bend Station Waterford Steam Electric Station, Unit 3 cc: May 2006 Mr. Paul D. Hinnenkamp Vice President - Operations Entergy Operations, Inc.

River Bend Station 5485 US Highway 61N St. Francisville, LA 70775 Director Nuclear Safety Assurance Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751 General Manager Plant Operations Waterford 3 SES Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751 Licensing Manager Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751 Resident Inspector/Waterford NPS P. O. Box 822 Killona, LA 70066-0751 Parish President Council St. Charles Parish P. O. Box 302 Hahnville, LA 70057 Chairman Louisiana Public Service Commission P. O. Box 91154 Baton Rouge, LA 70825-1697 Mr. Joseph E. Venable Vice President Operations Entergy Operations, Inc.

17265 River Road Killona, LA 70066-0751

Indian Point Nuclear Generating Pilgrim Nuclear Power Station Vermont Yankee Nuclear Power Station cc:

May 2006 Mr. Gary J. Taylor Chief Executive Officer Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Mr. John T. Herron Sr. VP and Chief Operating Officer Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Christopher Schwarz Vice President, Operations Support Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. John F. McCann Director, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Ms. Charlene D. Faison Manager, Licensing Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Michael J. Colomb Director of Oversight Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Assistant General Counsel Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. Charles Donaldson, Esquire Assistant Attorney General New York Department of Law 120 Broadway New York, NY 10271 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Paul Eddy New York State Dept. of Public Service 3 Empire State Plaza Albany, NY 12223-1350 Mr. James H. Sniezek BWR SRC Consultant 5486 Nithsdale Drive Salisbury, MD 21801-2490 Mr. Michael D. Lyster BWR SRC Consultant 5931 Barclay Lane Naples, FL 34110-7306 Mr. Garrett D. Edwards 814 Waverly Road Kennett Square, PA 19348 Mr. Michael Kansler President Entergy Nuclear Operations, Inc.

440 Hamilton Avenue White Plains, NY 10601 Mr. David R. Lewis Pillsbury, Winthrop, Shaw, Pittman, LLP 2300 N Street, N.W.

Washington, DC 20037-1128

Indian Point Nuclear Generating Pilgrim Nuclear Power Station Vermont Yankee Nuclear Power Station cc: May 2006 Mr. David OBrien, Commissioner Vermont Department of Public Service 112 State Street Montpelier, VT 05620-2601 Mr. James Volz, Chairman Public Service Board State of Vermont 112 State Street Montpelier, VT 05620-2701 Chairman, Board of Selectmen Town of Vernon P.O. Box 116 Vernon, VT 05354-0116 Operating Experience Coordinator Vermont Yankee Nuclear Power Station 320 Governor Hunt Road Vernon, VT 05354 G. Dana Bisbee, Esq.

Deputy Attorney General 33 Capitol Street Concord, NH 03301-6937 Chief, Safety Unit Office of the Attorney General One Ashburton Place, 19th Floor Boston, MA 02108 Ms. Carla A. White, RRPT, CHP Radiological Health Vermont Department of Health P.O. Box 70, Drawer #43 108 Cherry Street Burlington, VT 05402-0070 Mr. James M. DeVincentis Manager, Licensing Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Resident Inspector Vermont Yankee Nuclear Power Station U. S. Nuclear Regulatory Commission P.O. Box 176 Vernon, VT 05354 Director, Massachusetts Emergency Management Agency ATTN: James Muckerheide 400 Worcester Rd.

Framingham, MA 01702-5399 Jonathan M. Block, Esq.

Main Street P.O. Box 566 Putney, VT 05346-0566 Mr. Theodore Sullivan Site Vice President Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Ms. Stacey M. Lousteau Treasury Department Entergy Services, Inc.

639 Loyola Avenue New Orleans, LA 70113 Mr. Norman L. Rademacher Director, NSA Vermont Yankee Nuclear Power Station P.O. Box 0500 185 Old Ferry Road Brattleboro, VT 05302-0500 Mr. Raymond Shadis New England Coalition Post Office Box 98 Edgecomb, ME 04556

Indian Point Nuclear Generating Pilgrim Nuclear Power Station Vermont Yankee Nuclear Power Station cc: May 2006 Mr. James P. Matteau Executive Director Windham Regional Commission 139 Main Street, Suite 505 Brattleboro, VT 05301 Mr. William K. Sherman Vermont Department of Public Service 112 State Street Drawer 20 Montpelier, VT 05620-2601 Senior Resident Inspector U. S. Nuclear Regulatory Commission Pilgrim Nuclear Power Station Post Office Box 867 Plymouth, MA 02360 Chairman, Board of Selectmen 11 Lincoln Street Plymouth, MA 02360 Chairman Nuclear Matters Committee Town Hall 11 Lincoln Street Plymouth, MA 02360 Chairman, Duxbury Board of Selectmen Town Hall 878 Tremont Street Duxbury, MA 02332 Office of the Commissioner Massachusetts Department of Environmental Protection One Winter Street Boston, MA 02108 Office of the Attorney General One Ashburton Place 20th Floor Boston, MA 02108 Director, Radiation Control Program Commonwealth of Massachusetts Executive Offices of Health and Human Services 174 Portland Street Boston, MA 02114 Secretary of Public Safety Executive Office of Public Safety One Ashburton Place Boston, MA 02108 Mr. William D. Meinert Nuclear Engineer Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056-0426 Mr. Kevin H. Bronson General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Michael A. Balduzzi Site Vice President Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Stephen J. Bethay Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508

Indian Point Nuclear Generating Pilgrim Nuclear Power Station Vermont Yankee Nuclear Power Station cc: May 2006 Mr. Bryan S. Ford Manager, Licensing Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360-5508 Mr. Fred R. Dacimo Site Vice President Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Mr. Paul Rubin General Manager, Plant Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway P.O. Box 249 Buchanan, NY 10511-0249 Mr. James Comiotes Director, Nuclear Safety Assurance Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Mr. Patric Conroy Manager, Licensing Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P. O. Box 249 Buchanan, NY 10511-0249 Mr. Peter R. Smith, President New York State Energy, Research, and Development Authority 17 Columbia Circle Albany, NY 12203-6399 Senior Resident Inspectors Office Indian Point 2 U. S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Senior Resident Inspectors Office Indian Point 3 U. S. Nuclear Regulatory Commission P.O. Box 59 Buchanan, NY 10511 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. Raymond L. Albanese Four County Coordinator 200 Bradhurst Avenue Unit 4 Westchester County Hawthorne, NY 10532 Mr. William DiProfio PWR SRC Consultant 139 Depot Road East Kingston, NH 03827 Mr. Garry Randolph PWR SRC Consultant 1750 Ben Franklin Drive, 7E Sarasota, FL 34236 Mr. William T. Russell PWR SRC Consultant 400 Plantation Lane Stevensville, MD 21666-3232 Mr. Jim Riccio Greenpeace 702 H Street, NW Suite 300 Washington, DC 20001

Indian Point Nuclear Generating Pilgrim Nuclear Power Station Vermont Yankee Nuclear Power Station cc: May 2006 Mr. Phillip Musegaas Riverkeeper, Inc.

828 South Broadway Tarrytown, NY 10591 Mr. Mark Jacobs IPSEC 46 Highland Drive Garrison, NY 10524