ML082540435

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Stations Units 1 and 2 - Requested Licensing Action the Use of Weighting Factors for External Exposure Ure (TAC Nos. MD9472, MD9473, MD9474, MD9475, MD9476,
ML082540435
Person / Time
Site: Millstone, Kewaunee, Surry, North Anna  
(DPR-032, DPR-037, DPR-043, DPR-065, NPF-004, NPF-007, NPF-049)
Issue date: 09/11/2008
From: Stang J
Plant Licensing Branch II
To: Christian D
Virginia Electric & Power Co (VEPCO)
Wright D 301- 415 - 1864
References
TAC MD9472, TAC MD9473, TAC MD9474, TAC MD9475, TAC MD9476, TAC MD9477, TAC MD9478
Download: ML082540435 (6)


Text

September 11, 2008 Mr. David A. Christian President and Chief Nuclear Officer Virginia Electric and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

SUBJECT:

KEWAUNEE POWER STATION, MILLSTONE POWER STATION, UNITS 2 AND 3, NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2, SURRY POWER STATION, UNIT NOS. 1 AND 2 - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION RE:

THE USE OF WEIGHTING FACTORS FOR EXTERNAL EXPOSURE (TAC NOS. MD9472, MD9473, MD9474, MD9475, MD9476, MD9477, AND MD9478)

Dear Mr. Christian:

By letter dated August 18, 2008, Dominion Energy Kewaunee, Inc. (DEK), Dominion Nuclear Connecticut, Inc. (DNC), and Virginia Electric and Power Company (Dominion), submitted a request for Kewaunee Power Station, Millstone Power Station, Units 2 and 3, and North Anna and Surry Power Stations, Unit Nos. 1 and 2. The proposed request would allow the use of weighting factors for calculating external whole body dose. The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff=s acceptance review of this request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

Section 20.1003 of Title 10 of the Code of Federal Regulations (10 CFR) states, for the purpose of weighting the external whole body dose (for adding it to the internal dose), a single weighting factor, 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.

Section 20.1201(c) of 10 CFR addresses the technical information of how individual dose is determined.

The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed request in terms of regulatory requirements and the protection of public health and safety and the environment.

In order to make the application complete, the NRC staff requests that DEK, DNC and Dominion, supplement the application to address the information requested in the enclosure by September 24, 2008. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staff=s request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC staff will

cease its review actions associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the NRC staff=s detailed technical review by separate correspondence.

The information requested and associated time frame in this letter were discussed with Geoff Wertz of your staff on September 9, 2008.

If you have any questions, please contact the Project Manager, Donna Wright, at (301) 415-1864.

Sincerely,

/RA LOlshan for/

John Stang, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-305, 50-336/423, 50-338/339, and 50-280/281

Enclosure:

As stated cc w/encl: See next page

ML082540435 OFFICE DORL/LP2-1 DORL/LPL2-1/PM DORL/LPL2-1/LA IRIB/BC DORL/LPL2-1/BC NAME DWright JStang MOBrien TKobetz MWong DATE 9 / 11 /2008 9 / 11 /2008 9 / 11 /2008 9 / 11 /2008 9 / 11 /2008

Kewaunee Power Station, Millstone Power Station, Units 2 and 3, North Anna Power Station, Unit Nos. 1 and 2, and Surry Power Station, Unit Nos. 1 & 2 cc:

Mr. David A. Christian President and Chief Nuclear Officer Virginia Electrical and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711 Ms. Lillian M. Cuoco, Esq.

Senior Counsel Dominion Resources Services, Inc.

120 Tredegar Street, RS-2 Richmond, VA 23219 Mr. Donald E. Jernigan Site Vice President Surry Power Station Virginia Electric and Power Company 5570 Hog Island Road Surry, Virginia 23883-0315 Senior Resident Inspector Surry Power Station U. S. Nuclear Regulatory Commission 5850 Hog Island Road Surry, Virginia 23883 Chairman Board of Supervisors of Surry County Surry County Courthouse Surry, Virginia 23683 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation Post Office Box 1197 Richmond, Virginia 23218 State Health Commissioner Office of the Commissioner Virginia Department of Health Post Office Box 2448 Richmond, Virginia 23218 Office of the Attorney General Commonwealth of Virginia 900 East Main Street Richmond, Virginia 23219 Mr. Chris L. Funderburk, Director Nuclear Licensing & Operations Support Dominion Resources Services, Inc.

Innsbrook Technical Center 5000 Dominion Blvd.

Glen Allen, Virginia 23060-6711 Mr. C. Lee Lintecum County Administrator Louisa County Post Office Box 160 Louisa, Virginia 23093 Old Dominion Electric Cooperative 4201 Dominion Blvd.

Glen Allen, Virginia 23060 Senior Resident Inspector North Anna Power Station U. S. Nuclear Regulatory Commission P. O. Box 490 Mineral, Virginia 23117 Mr. Daniel G. Stoddard Site Vice President North Anna Power Station Virginia Electric and Power Company Post Office Box 402 Mineral, Virginia 23117-0402 Mr. William R. Matthews Senior Vice President, Nuclear Operations Virginia Electrical and Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060-6711

Kewaunee Power Station, Millstone Power Station, Units 2 and 3, North Anna Power Station, Unit Nos. 1 and 2, and Surry Power Station, Unit Nos. 1 & 2 cc:

Edward L. Wilds, Jr., Ph.D.

Director, Division of Radiation Department of Environmental Protection 79 Elm Street Hartford, CT 06106-5127 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 First Selectmen Town of Waterford 15 Rope Ferry Road Waterford, CT 06385 Charles Brinkman, Director Washington Operations Nuclear Services Westinghouse Electric Company 12300 Twinbrook Pkwy, Suite 330 Rockville, MD 20852 Senior Resident Inspector Millstone Power Station c/o U.S. Nuclear Regulatory Commission P. O. Box 513 Niantic, CT 06357 Mr. J. W. "Bill" Sheehan Co-Chair NEAC 19 Laurel Crest Drive Waterford, CT 06385 Ms. Nancy Burton 147 Cross Highway Redding Ridge, CT 00870 Mr. Evan W. Woollacott Co-Chair Nuclear Energy Advisory Council 128 Terrys Plain Road Simsbury, CT 06070 Mr. Joseph Roy Director of Operations Massachusetts Municipal Wholesale Electric Company P.O. Box 426 Ludlow, MA 01056 Mr. William D. Bartron Licensing Supervisor Dominion Nuclear Connecticut, Inc.

Building 475, 5th Floor Roper Ferry Road Waterford, CT 06385 Mr. J. Alan Price Site Vice President Dominion Nuclear Connecticut, Inc.

Building 475, 5th Floor Rope Ferry Road Waterford, CT 06385 Ms. Leslie N. Hartz Dominion Energy Kewaunee, Inc.

Kewaunee Power Station N 490 Highway 42 Kewaunee, WI 54216 Resident Inspectors Office U. S. Nuclear Regulatory Commission N490 Highway 42 Kewaunee, WI 54216-9510 Mr. Thomas L. Breene Dominion Energy Kewaunee, Inc.

Kewaunee Power Station N490 Highway 42 Kewaunee, WI 54216

SUPPLEMENTAL INFORMATION NEEDED LICENSING ACTION REQUEST PER 10 CFR PART 20 DOMINION ENERGY KEWAUNEE, INC., DOMINION NUCLEAR CONNECTICUT, INC.

VIRGINIA ELECTRIC AND POWER COMPANY KEWAUNEE POWER STATION, MILLSTONE POWER STATION, UNITS 2 AND 3 NORTH ANNA POWER STATION, UNIT NOS. 1 AND 2 SURRY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-305, 50-336/423, 50-338/339, AND 50-280/281

1.

Section 2.4 "DOSIMETER SELECTION AND PLACEMENT," in the Attachment to the August 18, 2008, request references the dosimeter placement criteria in INPO 05-008.

This is not acceptable to the NRC staff since some of the criteria in INPO 05-008 are contrary to Title 10 of the Code of Federal Regulations (10 CFR), Part 20, and could lead to the licensee being in violation of Part 20. Reasonable dosimeter placement criteria can be found in NRC Inspection Procedure 83724, Section 02.04. Please address this issue.

2.

Section 2.6 "CONCLUSION," is written in a way that endorses the entire HPS N13.41 standard. HPS N13.41 has not been endorsed by the NRC staff. The dosimetry placement criteria as described in the standard are not sufficiently clear to ensure a conservative result. In addition, the discussion on when multi-badging is appropriate can be misinterpreted as providing criteria sufficient for meeting the requirements in 10 CFR 20.1201(c), which it does not. The previous licensing actions cited as precedents in the request have all been very clear that the licensee is only requesting approval of the use of the table of Compartment Factors and the methodology discussed in Section 6.2 of N13.41, as modified by the licensee's commitments. Please address this issue.

Enclosure