RS-06-051, Amergen, Response to Request for Additional Information - Application to Use Weighting Factors for External Exposure

Amergen, Response to Request for Additional Information - Application to Use Weighting Factors for External Exposure

ML061110339
Person / Time
Site:	Dresden, Peach Bottom, Oyster Creek, Byron, Three Mile Island, Braidwood, Limerick, Clinton, Quad Cities, LaSalle, 07201027
Issue date:	04/18/2006
From:	Cowan P AmerGen Energy Co, Exelon Generation Co
To:	Document Control Desk, NRC/FSME
References
%dam200606, 2130-06-20262, 5928-06-20388, RS-06-051, TAC MC9247, TAC MC9263
Download: ML061110339 (6)

Text

10 CFR 20.1003 April 18, 2006 RS-06-051 5928-06-20388 2130-06-20262 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. S I N 50-454 and STN 50-455 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Station, Units 1, 2 and 3 Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-10, 50-237, 50-249 and 72-37 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. STN 50-373 and STN 50-374 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Oyster Creek Generating Station Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15

U S. Nuclear Regulatory Commission April 18, 2006 Page 2 Peach Bottom Atomic Power Station, Units 1, 2 and 3 Facility Operating License No. DPR-12 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-171, 50-277, 50-278 and 72-1027 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254. 50-265 Three Mile Island Nuclear Station, Unit 1 Facility Operating License No. DPR-50 NRC Docket Nos. 50-289

Subject:

Response To Request For Additional Information - Application to Use Weighting Factors for External Exposure (TAC Nos. MC9247-MC9263)

Reference:

(1) Letter from P. B. Cowan (Exelon/AmerGen) to USNRC, Application to Use Weighting Factors for External Exposure, dated December 14, 2005 This letter provides additional information in response to the NRC draft request for additional information received via NRC email, dated January 25, 2006, regarding the Exelon Generation Company, LLC (Exelon) and AmerGen Energy Company, LLC (AmerGen) application to use weighting factors for calculating external whole body dose, pursuant to 10 CFR 20.1003. The Exelon/AmerGen application was previously provided in Reference 1. Enclosed is a detailed response to the NRC request for additional information.

Reference 1 above, originally requested NRC approval of this application by February 15, 2006 in order to support use during the Spring 2006 refueling outages. This approval date is no longer needed to support Exelon/AmerGen refueling outages occurring in early Spring 2006.

Although not directly required for any outage implementation, receipt of NRC approval by August 2006 would enable use of the weighting factors for the Fall 2006 refueling outages.

If any additional information is needed, please contact Mr. David J. Distel at (610) 765-5517.

Sincerely, Pamela 13.Cowan Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC AmerGen Energy Company, LLC

Enclosures:

(1) Response to Request for Additional Information

U.S. Nuclear Regulatory Commission April 18, 2006 Page 3 cc: Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill NRC Project Manager, NRR - Braidwood Station NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Oyster Creek Generating Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - TMI Unit I NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - TMI Unit 1 NRC Senior Resident Inspector - Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Director, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA Mayor of Lacey Township, Forked River, NJ R. I. McLean, State of Maryland R. R. Janati, Commonwealth of Pennsylvania K. N. Jabbour, NRC Project Manager, NRR - (Exelon/AmerGen Fleet)

ENCLOSURE 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Response to RAI Page 1 of 2

1. NRC Question Section 2.4 of the enclosure, DOSIMETER SELECTION AND PLACEMENT, states that Exelon/AmerGen will use the criteria in the current Radiation Protection Procedure RP-AA-210, Dosimetry Issue, Usage and Control for determining dosimeter selection and placement. Later, the same section lists the criteria (e.g., greater than 30 percent of the expected dose equivalent and the potential to exceed 100 mrem) for multiple dosimetry. Please state whether these criteria are specifically listed in Exelon/AmerGens procedure RP-AA-210.

Resoonse These criteria are specifically listed in the Exelon/AmerGen Radiation Protection Procedure RP-AA-210, Section 4.5, Evaluation for Use of Multiole Dosimetry, Step 4.5.1.

This procedure establishes the following criteria:

1. The radiation dose to any portion of the whole body has the potential to be greater than 30% of the expected dose equivalent at the reference dosimeter location on the body, and

2. The dose equivalent for the evolution has the potential to exceed 100 mrem when a significant component of the effective dose equivalent comes from a non-uniform field, or

3. When specified by Radiation Protection Supervision.

2. NRC Question Please discuss whether the multiple dosimetry criteria of Section 2.4, discussed in Exelon/AmerGens Radiation Protection Procedure RP-AA-210, are consistent with the criteria for dosimeter selection and placement found in the current NRC inspection procedures.

Resoonse The criteria in the ExelonlAmerGen Radiation Protection Procedure RP-AA-210 are consistent with ANSllHPS N13.41-1997, Criteria for Performing Multiple Dosimetry, in lieu of NRC inspection procedure criteria. Section 4 of the ANSI/HPS N13.41-1997 Standard states: Therefore, multiple dosimeters, if their use has been deemed appropriate, should be used for each individual whose potential exposure to radiation during a specific time period or activity satisfies the following two conditions:**

(1) The radiation dose to any portion of the body has the potential to exceed 30% of the expected dose equivalent at the reference dosimeter location on the body; and (2) The dose equivalent has the potential to exceed 10% of the limiting value when a significant component of the effective dose equivalent comes from a non-uniform radiation field.

Response to RAI Page 2 of 2 Exelon/AmerGen Radiation Protection Procedure RP-AA-210, Step 4.5.1 , Criterion 1, states that multiple dosimetry is used when the radiation dose to any portion of the whole body has the potential to be greater than 30% of the expected dose equivalent at the reference dosimeter location on the body. This criterion is fully consistent with Item 1 in the ANSVHPS N13.41-1997 Standard. Exelon/AmerGen Procedure RP-AA-210, Step 4.5.1, Criterion 2 states that multiple dosimetry is used when the dose equivalent for the evolution has the potential to exceed 100 mrem when a significant component of the effective dose equivalent comes from a non-uniform field. The Exelon/AmerGen threshold of 100 mrem is based on implementation of Item 2 from the ANSVHPS N13.41-1997 Standard, and utilizes a limiting value of 1000 mrem. Based on this limiting value, the 10% criterion equates to the 100 mrem threshold. Therefore, the Exelon/AmerGen criteria for evaluating the use of multiple dosimetry, as specified in Radiation Protection Procedure RP-AA-210, Step 4.5.1, is fully consistent with the ANSVHPS N13.41-1997, and complies with the requirements of 10 CFR 20.1201(c).

3. NRC Question Section 2.6 of the enclosure, CONCLUSION, states that The proposed method will monitor the part of the whole body expected to receive the highest dose using the criteria for dosimeter selection and placement found in current NRC inspection procedures. Please state the specific NRC inspection procedures that Exelon/AmerGen proposes to utilize for monitoring the part of the whole body expected to receive the highest dose.

Response

The intent of this statement in Section 2.6 of the enclosure is that the Exelon/AmerGen Radiation Protection Procedure, RP-AA-210, method and criteria for evaluating dosimeter selection and placement provides reasonable evaluation criteria and thresholds, and fully complies with the requirements of 10 CFR 20.1201(c), as described above in response to Question No. 1.