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 Enclosure 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 (H E) 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 (H E) "is the sum of the products of the dose equivalent to the organ or tissue (H T) and the weighting factors (W T) applicable to each of the body organs or tissues that are irradiated (H E = W T H T)." 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.

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 FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3065 5501 North State Route 2 Oak Harbor, OH 43449-9760

Director, Ohio Department of Commerce Division of Industrial Compliance Bureau of Operations & Maintenance 6606 Tussing Road P.O. Box 4009 Reynoldsburg, OH 43068-9009

Resident Inspector U.S. Nuclear Regulatory Commission 5503 North State Route 2 Oak Harbor, OH 43449-9760

Stephen Helmer Supervisor, Technical Support Section Bureau of Radiation Protection Ohio Department of Health 35 East Chestnut Street, 7 th Floor Columbus, OH 43215

Carol O=Claire, Chief, Radiological Branch Ohio Emergency Management Agency 2855 West Dublin Granville Road Columbus, OH 43235-2206

Zack A. Clayton

DERR Ohio Environmental Protection Agency P.O. Box 1049 Columbus, OH 43266-0149

State of Ohio - Transportation Department Public Utilities Commission 180 East Broad Street Columbus, OH 43266-0573 Principal Assistant Attorney General Environmental Enforcement Section State Office Tower 30 East Broad Street, 25 th Floor Columbus, OH 43215

President, Board of County Commissioners of Ottawa County Port Clinton, OH 43252

President, Board of County Commissioners of Lucas County One Government Center, Suite 800 Toledo, OH 43604-6506

The Honorable Dennis J. Kucinich United States House of Representatives Washington, D.C. 20515

The Honorable Dennis J. Kucinich United States House of Representatives 14400 Detroit Avenue Lakewood, OH 44107

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

David W. Jenkins, Attorney FirstEnergy Corporation Mail Stop A-GO-15 76 South Main Street Akron, OH 44308

Danny L. Pace Senior Vice President, Fleet Engineering 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 FirstEnergy Corporation Mail Stop A-GO-15 76 South Main Street Akron, OH 44308

Resident Inspector's Office U.S. Nuclear Regulatory Commission P.O. Box 331 Perry, OH 44081-0331

Sue Hiatt OCRE Interim Representative 8275 Munson Mentor, OH 44060

Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company Perry Nuclear Power Plant Mail Stop A-PY-A200 P.O. Box 97, 10 Center Road Perry, OH 44081-0097

Mayor, Village of North Perry North Perry Village Hall 4449 Lockwood Road North Perry Village, OH 44081

Dean Jagger, Chief Boiler Inspector Ohio Department of Commerce Division of Industrial Compliance Bureau of Operations & Maintenance 6606 Tussing Road P.O. Box 4009 Reynoldsburg, OH 43068-9009

Carol O'Claire, Chief, Radiological Branch Ohio Emergency Management Agency 2855 West Dublin Granville Road Columbus, OH 43235-7150

Mayor, Village of Perry P.O. Box 100 Perry, OH 44081-0100 Robert Owen Radiological Assistance Section Supervisor Bureau of Radiation Protection Ohio Department of Health P.O. Box 118 Columbus, OH 43266-0118

Zack A. Clayton

DERR Ohio Environmental Protection Agency ATTN: Mr. Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149

Chairman Perry Township Board of Trustees 3750 Center Road, Box 65 Perry, OH 44081

Daniel Z. Fisher Transportation Department Public Utilities Commission 180 East Broad Street Columbus, OH 43215-3793

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

Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308

Joseph J. Hagan President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 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 President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 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

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

Paul A. Harden Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308

David W. Jenkins, Attorney FirstEnergy Corporation Mail Stop A-GO-15 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 Ohio EPA-DERR ATTN: Zack A. Clayton P.O. Box 1049 Columbus, OH 43266-0149

Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, Ohio 44308

Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-A P.O. Box 4, Route 168 Shippingport, PA 15077

Commissioner James R. Lewis West Virginia Division of Labor 749-B, Building No. 6 Capitol Complex Charleston, WV 25305

Director, Utilit ies Department Public Utilities Commission 180 East Broad Street Columbus, OH 43266-0573

Director, Pennsylvania Emergency Management Agency 2605 Interstate Dr.

Harrisburg, PA 17110-9364

Dr. Judith Johnsrud Environmental Coalition on Nuclear Power Sierra Club 433 Orlando Avenue State College, PA 16803

Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 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 O'Claire 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