RS-04-187, Supplement to Request for Amendment to Technical Specifications to Eliminate Requirements to Provide Monthly Operating Reports and Annual Occupational Radiation Exposure Reports

Supplement to Request for Amendment to Technical Specifications to Eliminate Requirements to Provide Monthly Operating Reports and Annual Occupational Radiation Exposure Reports

ML050940465
Person / Time
Site:	Dresden, Three Mile Island
Issue date:	01/04/2005
From:	Jury K AmerGen Energy Co, Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, NRC/FSME
References
RS-04-187
Download: ML050940465 (8)

Text

www.exeloncorp.com AmerG r~- Cc )any, LLC EmIn C 4300 1 Koact e,

Wane - - 60555 a00 to WannBlE 10 CFR 50 .90 RS-04-187 January 4, 2005 U . S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Unit 1 Facility Operating License No . DPR-2 N RC Docket No. 50-01 0 Three Mile Island Station, Unit 1 Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

Supplement to Request for Amendment to Technical Specifications to Eliminate Requirements to Provide Monthly Operating Reports and Annual Occupational Radiation Exposure Reports References : 1) Letter from J. A. Benjamin (Exelon/AmerGen), to U . S. NRC, "Request for Amendment to Technical Specifications to Eliminate Requirements to Provide Monthly Operating Reports and Annual Occupational Radiation Exposure Reports," dated October 21, 2004

2) Technical Specifications Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-369, Revision 1, "Removal of Monthly Operating Report and Occupational Radiation Exposure Report" In Reference 1, Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) requested changes to the Technical Specifications (TS) of Facility Operating License Nos. DPR-50 for Three Mile Island Station, Unit 1 (TMI-1) and DPR-1 9 and DPR-25 for Dresden Nuclear Power Station (DNPS), Units 2 and 3 . The proposed changes requested the deletion of the requirements to provide Monthly Operating Reports and Annual Occupational Radiation Exposure Reports to the NRC.

Subsequent review of the proposed amendment by TMI-1 site personnel identified that, although General Public Utilities Nuclear is the licensee for Three Mile Island Unit 2 (TIVII-2),

AmerGen has included the information related to radiation exposure received during TMI-2 activities in the Annual Radiation Exposure Reports submitted by AmerGen for TMI-1 .

Therefore, in Reference 1, AmerGen should have included a regulatory commitment for TMI-1 to provide information to the NRC annually to support the apportionment of the station radiation doses to differentiate between the operating and shutdown units . Enclosure 1 of this letter contains a revised Attachment 4-1 from the original submittal (i.e., Reference 1) to document this regulatory commitment for TMI-1 .

January 4, 2005 U. S. Nuclear Regulatory Commission Page 2 Following the submission of Reference 1, it was also noted that the TS for the permanently shutdown DNPS, Unit 1, Facility Operating License No. DPR-2, contain a requirement to provide an Annual Report similar in content to the Occupational Radiation Exposure Report. In the pat, the radiation exposure received in support of DNPS Unit 1 activities has been included in the Annual Occupational Radiation Exposure Report for DNPS Units 2 and 3. Enclosures 2 and 3 of this letter include the marked up and retyped DNPS Unit 1 TS page to delete the requirement for submittal of this particular annual report of occupational radiation exposure .

The commitment to apportion the radiation exposure between the operating and permanently shutdown units at DNPS was included in Attachment 4-D of Reference 1 .

The clarification of the regulatory commitment for AmerGen to apportion the radiation exposure received between the operating and permanently shutdown units at Three Mile Island Station, and the request to delete the 1)NPS Unit 1 TS requirement for the annual radiation exposure report, do not impact the evaluation of the change or the proposed finding of no significant hazards consideration provided in Reference 1 .

EGC and AmerGen are notifying the States of Illinois and the Commonwealth of Pennsylvania of this supplement to the request for a change to the TS by sending a copy of this letter and its enclosures to the designated officials in accordance with 10 CFR 50 .91, "Notice for public comment; State consultation ."

Should you have any questions concerning this letter, please contact Ms . Alison M. Mackellar at (630) 657-2817 .

I declare under penalty of perjury that the foregoing is true and correct.

Executed on Keith R. Jury Director- Licensing and Regulatory Affairs Exelon Generation Company, LLC AmerGen Energy Company, LLC  : Revised Attachment 4-1 from Reference 1 : Mark-up of Proposed Technical Specifications Change for DNPS, Unit 1 : Typed DNPS, Unit 1 TS Page with Proposed Change Incorporated

ENCLOSURE1 Revised Attachment 4-I THREE MILE ISLAND STATION - Unit 1

ATTACHMENT 4-1 REGULATORY COMMITMENTS FOR THREE MILE ISLAND STATION, UNIT 1 The following table identifies those actions committed to by AmerGen Energy Company, LLC (AmerGen) in this document . Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments. Please direct questions regarding these commitments to Alison Mackellar at (630) 657-2817 .

Regulatory Commitments Due Date / Event AmerGen Energy Company, LLC is making a regulatory Implemented by TS amendment commitment to provide to the NRC using an industry implementation date .

database the operating data (for each calendar month) that is described in Generic Letter 97-02 "Revised Contents of the Monthly Operating Report," by the last day of the month following the end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e .g ., the industry's Consolidated Data Entry (CDE) program, currently being developed and maintained by the Institute of Nuclear Power Operations). This regulatory commitment will be implemented to prevent any gaps in the monthly operating statistics and shutdown experience provided to the NRC (i.e., data for all months will be provided using one or both systems (monthly operating reports and CDE)) .

AmerGen is making a regulatory commitment to provide Implemented by TS amendment information to the NRC annually (e.g., with the annual implementation date.

submittal in accordance with 10 CFR 20.2206) to support the apportionment of station radiation doses to differentiate between operating and shutdown units. The data will provide the summary distribution of annual whole body doses as presented in Appendix B of NUREG-0713, "Occupational Radiation Dose at Commercial Nuclear Power Reactors and Other Facilities," for each operating and shutdown unit.

ENCLOSURE 2 Mark-up of Proposed Technical Specifications Page Change DRESDEN NUCLEAR POWER STATION - Unit 1 REVISED TS PAGE 6-8

Reporting Requirements 6 .9 ADMINISTRATIVE CONTROLS 6 .9 REPORTING REQUIREMENTS In addition to the applicable reporting requirements of Title 10, Code of Federal Regulation, the following identified reports shall be submitted to the Regional Administrator of the appropriate Regional Office of the NRC unless otherwise noted.

6 .9 .A Routine Reports

1. {DELETED}

Annual Report 111111ill 11 .4 .101 ra+f.vrr:.~ImgoI"ifI*

a. ulation of the number of station, utility, and other personn line lu ' contractors) receiving exposures greater than _ i mre mlyear a their associated person rem expos accord mg to work and job fu 'ons, e .g., surveillance, i rvice inspection, routine maintenance , s p ' I maintena describe maintenance), waste process fuel handling. The dose assignments to various duty ctio ay be estimated based on pocket dosimeter or L all exposur otaling less than 20%

of the individual dose need not be accoun or . In the aggregate ast 80% of the total whole body dose eived from em r al sources should be assigned to specific major k 0 s.

b. Specific Reactor Coolant Activity - {DELETED}

3. Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the decommissioning activities during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period . The material provided shall be consistent with the objectives outlined in (1) the ODCM and (2) Sections IV.B .2, IV.B .3, and IV.C of Appendix I to 10 CFR Part 50.

DRESDEN - UNIT 1 6-8 Amendment No. 39,

ENCLOSURE3 Typed Page for Technical Specifications Change DRESDEN NUCLEAR POWER STATION - Unit 1 REVISED TS PAGE 6-8

Reporting Requirements 6 .9 ADMINISTRATIVE CONTROLS 6 .9 REPORTING REQUIREMENTS In addition to the applicable reporting requirements of Title 10, Code of Federal Regulation, the following identified reports shall be submitted to the Regional Administrator of the appropriate Regional Office of the NRC unless otherwise noted .

6.9.A Routine Reports t {DELETED}

2. Annual Report

a. Annual Occupational Radiation Exposure Report - {DELETED}

b. Specific Reactor Coolant Activity - {DELETED}

3. Annual Radiological Environmental Operating Report The Annual Radiological Environmental Operating Report covering the decommissioning activities during the previous calendar year shall be submitted by May 15 of each year. The report shall include summaries, interpretations, and analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period . The material provided shall be consistent with the objectives outlined in (1) the ODCM and (2) Sections IV.B .2, IV.13.3, and IV.C of Appendix I to 10 CFR Part 50.

DRESDEN - UNIT 1 6-8 Amendment No. xx