ML20093D721

Proposes That American Electric Power Svc Corp (Aepsc) Employees Be Treated as Util Employees Re Reporting Worker Radiation Exposure Info.Since Aepsc Personnel Visit Plant Irregularly,Administrative Burden Would Be Less

ML20093D721
Person / Time
Site:	Cook
Issue date:	06/27/1984
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20093D720	List: ML20093D721
References
AEP:NRC:0867, AEP:NRC:867, NUDOCS 8407170183
Download: ML20093D721 (2)

Text

. _. ..

Y.

INDIANA-& MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHK. 43216

.gWCYfp g

' RA/

June 27, 1984 dC :L AEP:NRC:0867 h6 OL Gh 01 Donald C. Cook Nuclear Plant Unit Nos.1 and 2 AC M Docket Nos. 50-315 and 50-316 RN License Nos. DPR-58 and DPR-74 INDIVIDUALS' EXPOSURE REPORTS Mr. James G. Keppler, Regional Administrator U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

10 CFR 20.408(b) and 10 CFR 20.409(b) provide the licensee requirements regarding the timely provision of worker radiation exposure information to the NRC and the worker. The reporting requirements apply to terminated employees, and to individuals assigned to ' work in a licensee's facility but who are not employees of the licensee and have completed their work at the licensee's facility.

American Electric Power Service Corporation is the corporate support organization for the D. C. Cook Plant and is a wholly owned subsidiary of American Electric Power Company, Inc. , which owns all of the common stock of Indiana & Michigan Electric Company (the licensee for the D. C. Cook Nuclear Plant). In the performance of their duties, numerous AEPSC personnel travel to the Plant on a frequent, irregular basis.

The current practice at the Cook Nuclear Plant is to consider AEPSC personnel as non-licensee employees with respect to the above regulations.

This practice significantly increases the complexity (and quantity of paperwork) associated with tracking the on-site presence, departure date, return t.: site date, or "no return to site within 90 days of last departure" l for AEPSC personnel. A report of the individual's radiation exposure is  ;

generated in accordance with the cited regulations if an AEPSC individual does I not return to the Plant within 90 days of last departure. If the AEPSC l individual returns to the site within 90 days of last departure, then the "90-day clock" is started again upon completion of the trip.

Clearly, the above practice is a conservative program but in our opinion is not the intent of 10 CFR 20.408(b) and 10 CFR 20.409(b). Therefore, we request your concurrence with our intention to treat AEPSC employees, as members of a common corporate crganization, the same as licensee employees. Your concurrence would relieve us of a complex and unnecessary burden on the Plant administrative staff.

8407170183 840711 * '2, PDR ADOCK 05000315 P pog $b i l

l

., v.

Mr. James G.Keppler AEP:NRC:0867 We would like to place this program into effect on July 15, 1984. Your comments, concurrence with this interpretation, or additional guidance in this matter is requested in support of this schedule.

i This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signattre by the undersigned.

Very truly yours, 4

. P. Al rich gl dl Vice President y th cc: John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff E. R. Swanson, NRC Resident Inspector .. Bridgman s

, -, y v , , - - - , , , - + , - - -*