ML082310335

RAI Application to Use Weighting Factors for External Exposure

ML082310335
Person / Time
Site:	Beaver Valley, Davis Besse, Perry
Issue date:	08/22/2008
From:	Gratton C Plant Licensing Branch III
To:	Hagan J FirstEnergy Nuclear Operating Co
Gratton C, NRR/DORL, 415-1055
References
TAC MD8286, TAC MD8287, TAC MD8288, TAC MD8289
Download: ML082310335 (10)

Text

August 22, 2008 Mr. Joseph J. Hagan President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 76 South Main Street Akron, OH 44308

SUBJECT:

BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2; DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1; AND PERRY NUCLEAR POWER PLANT, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RE:

APPLICATION TO USE WEIGHTING FACTORS FOR EXTERNAL EXPOSURE (TAC NOS. MD8286 THRU MD8289)

Dear Mr. Hagan:

By letter to the Nuclear Regulatory Commission (NRC) dated March 6, 2008, FirstEnergy Nuclear Operating Corpany (FENOC) submitted a request for approval to use weighting factors for external radiation exposures when demonstrating compliance with the Total Effective Dose Equivalent requirements contained in Title 10 of the Code of Federal Regulations, Part 20, Standards for Protection Against Radiation, for the subject plants.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. On August 13, 2008, your staff communicated to the NRC that a followup conference call was not necessary to clarify the intent of the draft questions faxed to FENOC July 31, 2008, and that FENOC staff could provide a response within 30 days from the date of the facsimile.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1055.

Sincerely,

/RA/

Christopher Gratton, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-334, 50-412, 50-346, and 50-440

Enclosure:

Request for Additional Information cc w/encl: See next page

ML082310335 OFFICE LPL3-2/PM LPL3-2/LA LPL3-2/BC NAME CGratton THarris RGibbs DATE 08/21/ 08 08/21/08 08/22/08 REQUEST FOR ADDITIONAL INFORMATION BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1 PERRY NUCLEAR POWER PLANT, UNIT NO. 1 DOCKET NOS. 50-334, 50-412, 50-346, AND 50-440 In reviewing the FirstEnergy Nuclear Operating Company (FENOC) submittal dated March 6, 2008, related to a request to use weighting factors for the whole body for determining effective dose equivalent from external exposures for the subject plants, the Nuclear Regulatory Commission (NRC) staff has determined that the following information is needed in order to complete its review:

1. On page 2 of 6 (Section 2.0) of the enclosure in your application you state, For the purposes of implementing workplace controls, and due to the difference in dosimetry, 10 CFR 20 breaks this [effective dose equivalent] EDE (HE) into two components:

(1) dose resulting from radioactive sources internal to the body, and (2) dose resulting from sources external to the body.

Title 10 of the Code of Federal Regulations, Section 20.1003 states that Total Effective Dose Equivalent (TEDE) means the sum of the EDE (for external exposures) and the committed effective dose equivalent (for internal exposures). By definition, EDE (HE) is the sum of the products of the dose equivalent to the organ or tissue (HT) and the weighting factors (W T) applicable to each of the body organs or tissues that are irradiated (HE = W THT).

Question: Did you intend to reference TEDE, rather than EDE in your statement, as described above? Please provide a written clarification or correction to your statement.

2. On page 5 of 6 (Section 3.3) in your application you state that, FENOC will monitor the part of the whole body within each compartment (and/or composite compartment) that receives the highest dose. The sentence that follows states, Consistent with current FENOC practice, a single dosimeter placed between the head and the waist is used to measure the dose to the whole body which includes the head, trunk (including male gonads), arms above the elbows, and legs above the knees.

The second statement appears to conflict with the first. Combining the head, trunk (including male gonads), arms above the elbows, and legs above the knees into a single compartment would not be consistent with the intent of the method for multiple dosimetry presented in the American National Standards Institute (ANSI)/ Health Physics Society (HPS) N13.41-1997, standard, Criteria For Performing Multiple Dosimetry, for non-uniform radiation fields, as previously approved by the NRC.

Enclosure

Question: How does the second statement relate to your intended use of the ANSI/HPS standard? Do you intend to combine compartments while monitoring dose in non-uniform radiation fields? Please provide a written clarification for how you intend to monitor each of the compartments described in the ANSI/HPS standard, as approved by the NRC, compared to your current practice for using multiple dosimeters in non-uniform radiation fields.

Davis-Besse Nuclear Power Station, Unit No. 1 cc:

Manager, Site Regulatory Compliance Principal Assistant Attorney General FirstEnergy Nuclear Operating Company Environmental Enforcement Section Davis-Besse Nuclear Power Station State Office Tower Mail Stop A-DB-3065 30 East Broad Street, 25th Floor 5501 North State Route 2 Columbus, OH 43215 Oak Harbor, OH 43449-9760 President, Board of County Director, Ohio Department of Commerce Commissioners of Ottawa County Division of Industrial Compliance Port Clinton, OH 43252 Bureau of Operations & Maintenance 6606 Tussing Road President, Board of County P.O. Box 4009 Commissioners of Lucas County Reynoldsburg, OH 43068-9009 One Government Center, Suite 800 Resident Inspector Toledo, OH 43604-6506 U.S. Nuclear Regulatory Commission 5503 North State Route 2 The Honorable Dennis J. Kucinich Oak Harbor, OH 43449-9760 United States House of Representatives Washington, D.C. 20515 Stephen Helmer Supervisor, Technical Support Section The Honorable Dennis J. Kucinich Bureau of Radiation Protection United States House of Representatives Ohio Department of Health 14400 Detroit Avenue 35 East Chestnut Street, 7th Floor Lakewood, OH 44107 Columbus, OH 43215 Joseph J. Hagan Carol O=Claire, Chief, Radiological Branch President and Chief Nuclear Officer Ohio Emergency Management Agency FirstEnergy Nuclear Operating Company 2855 West Dublin Granville Road Mail Stop A-GO-19 Columbus, OH 43235-2206 76 South Main Street Akron, OH 44308 Zack A. Clayton DERR David W. Jenkins, Attorney Ohio Environmental Protection Agency FirstEnergy Corporation P.O. Box 1049 Mail Stop A-GO-15 Columbus, OH 43266-0149 76 South Main Street Akron, OH 44308 State of Ohio - Transportation Department Public Utilities Commission Danny L. Pace 180 East Broad Street Senior Vice President, Fleet Engineering Columbus, OH 43266-0573 FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308

Davis-Besse Nuclear Power Station, Unit No. 1 (continued) cc:

Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Paul A. Harden Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 James H. Lash Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308

Perry Nuclear Power Plant, Unit No. 1 cc:

David W. Jenkins, Attorney Robert Owen FirstEnergy Corporation Radiological Assistance Section Supervisor Mail Stop A-GO-15 Bureau of Radiation Protection 76 South Main Street Ohio Department of Health Akron, OH 44308 P.O. Box 118 Columbus, OH 43266-0118 Resident Inspector's Office U.S. Nuclear Regulatory Commission Zack A. Clayton P.O. Box 331 DERR Perry, OH 44081-0331 Ohio Environmental Protection Agency ATTN: Mr. Zack A. Clayton Sue Hiatt P.O. Box 1049 OCRE Interim Representative Columbus, OH 43266-0149 8275 Munson Mentor, OH 44060 Chairman Perry Township Board of Trustees Manager, Site Regulatory Compliance 3750 Center Road, Box 65 FirstEnergy Nuclear Operating Company Perry, OH 44081 Perry Nuclear Power Plant Mail Stop A-PY-A200 Daniel Z. Fisher P.O. Box 97, 10 Center Road Transportation Department Perry, OH 44081-0097 Public Utilities Commission 180 East Broad Street Mayor, Village of North Perry Columbus, OH 43215-3793 North Perry Village Hall 4449 Lockwood Road James H. Lash North Perry Village, OH 44081 Senior Vice President of Operations and Chief Operating Officer Dean Jagger, Chief Boiler Inspector FirstEnergy Nuclear Operating Company Ohio Department of Commerce Mail Stop A-GO-14 Division of Industrial Compliance 76 South Main Street Bureau of Operations & Maintenance Akron, OH 44308 6606 Tussing Road P.O. Box 4009 Director, Fleet Regulatory Affairs Reynoldsburg, OH 43068-9009 FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 Carol OClaire, Chief, Radiological Branch 76 South Main Street Ohio Emergency Management Agency Akron, OH 44308 2855 West Dublin Granville Road Columbus, OH 43235-7150 Joseph J. Hagan President and Chief Nuclear Officer Mayor, Village of Perry FirstEnergy Nuclear Operating Company P.O. Box 100 Mail Stop A-GO-19 Perry, OH 44081-0100 76 South Main Street Akron, OH 44308

Perry Nuclear Power Plant, Unit No. 1 (continued) cc:

Danny L. Pace Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308 Paul A. Harden Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308

Beaver Valley Power Station, Unit Nos. 1 and 2 cc:

Joseph J. Hagan Ohio EPA-DERR President and Chief Nuclear Officer ATTN: Zack A. Clayton FirstEnergy Nuclear Operating Company P.O. Box 1049 Mail Stop A-GO-19 Columbus, OH 43266-0149 76 South Main Street Akron, OH 44308 Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company James H. Lash Mail Stop A-GO-2 Senior Vice President of Operations 76 South Main Street and Chief Operating Officer Akron, Ohio 44308 FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 Manager, Site Regulatory Compliance 76 South Main Street FirstEnergy Nuclear Operating Company Akron, OH 44308 Beaver Valley Power Station Mail Stop A-BV-A Danny L. Pace P.O. Box 4, Route 168 Senior Vice President, Fleet Engineering Shippingport, PA 15077 FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 Commissioner James R. Lewis 76 South Main Street West Virginia Division of Labor Akron, OH 44308 749-B, Building No. 6 Capitol Complex Jeannie M. Rinckel Charleston, WV 25305 Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Director, Utilities Department Mail Stop A-GO-14 Public Utilities Commission 76 South Main Street 180 East Broad Street Akron, OH 44308 Columbus, OH 43266-0573 Paul A. Harden Director, Pennsylvania Emergency Vice President, Nuclear Support Management Agency FirstEnergy Nuclear Operating Company 2605 Interstate Dr.

Mail Stop A-GO-14 Harrisburg, PA 17110-9364 76 South Main Street Akron, OH 44308 Dr. Judith Johnsrud Environmental Coalition on Nuclear Power David W. Jenkins, Attorney Sierra Club FirstEnergy Corporation 433 Orlando Avenue Mail Stop A-GO-15 State College, PA 16803 76 South Main Street Akron, OH 44308 Director Bureau of Radiation Protection Manager, Fleet Licensing Pennsylvania Department of FirstEnergy Nuclear Operating Company Environmental Protection Mail Stop A-GO-2 Rachel Carson State Office Building 76 South Main Street P.O. Box 8469 Akron, OH 44308 Harrisburg, PA 17105-8469

Beaver Valley Power Station, Unit Nos. 1 and 2 (continued) cc:

Mayor of the Borough of Shippingport P.O. Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 15077 Ms. Carol OClaire Chief, Radiological Branch Ohio Emergency Management Agency 2855 West Dublin-Granville Road Columbus, OH 43235-2206 Mr. Dan Hill Chief, Radiological Health Program West Virginia Department of Health and Human Resources Capitol & Washington Streets 1 Davis Square Suite 200 Charleston, WV 25305-0360