ML103570133

Response to Request for Additional Information Regarding the Safety Evaluation Report for 10 CFR 70 License Application (TAC L32918)

ML103570133
Person / Time
Site:	Watts Bar, 07007018
Issue date:	07/30/2010
From:	Krich R Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
TAC L32918
Download: ML103570133 (16)

Text

Tennessee Valley Authority 1101 Market Street, LP 3R Chattanooga, Tennessee 37402-2801 R. M. Krich Vice President Nuclear Licensing July 30, 2010 10 CFR 70.5 ATTN: Document Control Desk Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C: 20555-0001 Watts Bar Nuclear Plant, Unit 2 Facility Docket No. 50-391 Special Nuclear Material Docket No. 70-07018

Subject:

Response to Request for Additional Information Regarding the Safety Evaluation Report for 10 CFR 70 License Application for Watts Bar Nuclear Plant, Unit 2 (TAC No. L32918)

References:

1. NRC Letter to TVA, "Request for Additional Information Regarding the Safety Evaluation Report for Part 70 License Application for Watts Bar Nuclear Plant, Unit 2 (TAC No. L32918)," dated May 10, 2010 2. TVA Letter to NRC, "Application for a Special Nuclear Material License for Watts Bar Nuclear Plant Unit 2 in Accordance with 10 CFR 70, Domestic Licensing of Special Nuclear Material," dated November 12, 2009 The purpose of this letter is to provide additional information in support of NRC's review of the 10 CFR 70 License Application for Watts Bar Nuclear Plant (WBN), Unit 2 as requested by the NRC in Reference

1. In its May 10, 2010 letter, the NRC requested that the response be provided within 30 days of receipt of the NRC letter, i.e., by June 9, 2010 at the earliest.

By phone calls with Mr. Rafael Rodriguez of the NRC staff on June 3, 2010 and July 15, 2010, as well as electronic mail messages to Mr. Rodriguez on June 4, 2010, June 29, 2010, July 12, 2010, and July 16, 2010, TVA made a number of notifications to the NRC of the need to extend the submittal date with the final submittal date being July 30, 2010.printed on recycled U.S. Nuclear Regulatory Commission Page 2 July 30, 2010 On November 12, 2009 (Reference 2), the Tennessee Valley Authority (TVA) submitted an application to the NRC for a Special Nuclear Material License for WBN, Unit 2 under 10 CFR 70, "Domestic Licensing of Special Nuclear Material." While preparing the safety evaluation report to support the evaluation of this license application, the NRC staff reviewed the submitted application materials and identified several topics requiring clarification.

Many of these topics were discussed during a conference call on May 5, 2010. Enclosure 1 provides the'NRC Requests for Additional Information (RAIs) and TVA's responses to these RAIs. Enclosure 2 provides corrected application pages.Enclosure 3 identifies those actions committed to by TVA in this letter.If you have any questions, please contact Bill Crouch at (423) 365-2004.Respectfully, R. M. Krich

Enclosures:

1. TVA Responses to NRC RAIs in Support of the Review of the 10 CFR 70 License Application for Watts Bar Nuclear Plant, Unit 2 2. Corrected Application Pages 3. List of Regulatory Commitments Enclosure 1 TVA Responses to NRC RAts in Support of the Review of the 10 CFR 70 License Application for Watts Bar Nuclear Plant, Unit 2 Tennessee Valley Authority Watts Bar Nuclear Plant, Unit 2 Application for a 10 CFR 70 License Facility Docket No. 50-391 Special Nuclear Material Docket No. 70-07018 A) Radiation Protection

1. NRC Request Sections 2.2.4 and 4.3 of the license application commit to Regulatory Guide (RG) 1.8 Revisions 1 and 2 (although this isn't stated consistently in these sections).

Revision 3 of this guidance is the most recent version of the document.

Consistent with Title 10 of the Code of Federal Regulations (10 CFR)70.22(a)(6) and 10 CFR 70.23(a)(2), justify why Tennessee Valley Authority (TVA) is not committing to the most recent revision of Regulatory Guide 1.8.TVA Response As applicable, Nuclear Power Group (NPG) personnel at the Watts Bar Nuclear Plant (WBN), Unit 1 currently meet the qualification and training recommendations of NRC Regulatory Guide (RG) 1.8, Revisions 1 and 2, American National Standards Institute (ANSI) Standard N18.1-1971, and ANSI/American Nuclear Society (ANS) Standard 3.1-1981 with the alternatives as outlined in the NRC approved TVA Nuclear Quality Assurance Plan (QAP), TVA-NQA-PLN89-A.

Accordingly, TVA has committed to the WBN site Radiation Protection Manager meeting the education and experience as described in Regulatory Guide (RG)1.8, "Personnel Selection and Training," Revisions 1 and 2, in the context of RG 1.8 and the endorsed ANSI N18.1-1971 and ANSI/ANS-3.1-1981 standards.

Because of TVA's commitment to both documents, the Radiation Protection Manager must meet the more restrictive of the composite qualifications and training of both documents.

The applicable TVA personnel meet the recommendations of RG 1.8, Revision 2, for personnel qualifying on positions identified in regulatory position C.1 after January 1, 1990. Personnel qualified on these positions prior to this date still meet the recommendations of RG 1.8, Revision 1-R. As specified in regulatory position C.2, all other positions meet the recommendations of ANSI/ANS N 18.1-1971.

E1-1 Enclosure I TVA Responses to NRC RAIs in Support of the Review of the 10 CFR 70 License Application for Watts Bar Nuclear Plant, Unit 2 Personnel will be shared between WBN, Units 1 and 2. Therefore, WBN, Unit 2 is committing to the same revision(s) of RG 1.8 as committed to by WBN, Unit 1, in order to maintain program and process consistency between the two units.2. NRC Request Section 4.5 of the license application states that: 'A radiation protection training program shall be developed, documented, and administered consistent with expectations as outlined in NEI 95-04, 'Guideline for General Access Training."'

This document was not submitted as part of the license application, and was not readily available by the reviewer.

Consistent with 10 CFR 70.9, provide a copy of this document so this commitment can be adequately assessed.

Alternatively, describe how TVA's radiation protection training program meets the expectations in Nuclear Energy Institute (NEI) 95-04.TVA Response The reference to NEI 95-04 was incorrect.

TVA's radiation protection training program is developed, documented, and administered consistent with expectations as outlined in NEI 03-04, "Guideline for General Access Training." The radiation protection training program is implemented by TVA Nuclear (TVAN)Training Procedure, TRN-2, "General Employee Training," for all TVA nuclear power plants. In accordance with the completeness requirement of 10 CFR 70.9, TRN-2 is provided in Attachment 1 and will be used to provide radiation protection training for personnel at WBN, Unit 2.3. NRC Reouest In Section 4.7 of the license application, commitments are made to American Standards Institute (ANSI) N13. 11 -1983 and ANSI N13.30- 1989. ANSI N13. 11-1983 is not the most recent revision of this guidance; ANSI N13.30-1989 is a draft version of the guidance.

Consistent with 10 CFR 70.22(a)(7) and 10 CFR 70.23 (a)(3), justify why the most recent and final versions, respectively, of these guidance documents are not used.TVA Response Personnel dose monitoring equipment and the processing of personnel dosimetry will be shared between WBN, Units 1 and 2. Therefore, WBN, Unit 2 is committing to the same version of ANSI N13.11 -1983 as committed to by WBN, Unit 1 to maintain program and process consistency between the two units. The reference to ANSI-N 13.30, September 1989, Table 1, "Acceptable Minimum Detectable Activities," in the 10 CFR 70 application was incorrect.

The correct El -2 Enclosure I TVA Responses to NRC RAIs in Support of the Review of the 10 CFR 70 License Application for Watts Bar Nuclear Plant, Unit 2 reference is ANSI-N13.30, 1996, Table-C.3, "Direct Radiobioassay Minimum Detectable Activities." In accordance with the accuracy requirements of 10 CFR 70.9, the corrected page from the application is included in the attachment.

4. NRC Request Section 4.7 of the license application commits to RG 1.88. This RG was withdrawn in 1991. Consistent with 10 CFR 70.9, remove the reference and replace it with a current RG that is equivalent to RG 1.88. Alternatively, describe it in sufficient detail so this commitment can be adequately assessed.TVA Response In accordance with the accuracy requirements of 10 CFR 70.9, the reference to RG 1.88 is removed from the application.

The guidance contained within RG 1.88 is essentially included in RG 1.28. The TVA QAP documents TVA's commitment to RG 1.28. Accordingly, the revised application page is provided as an enclosure.

5. NRC Request Section 4.7.7 of the license application commits to U.S. Nuclear Regulatory Commission (NRC) Technical Communication, "Radiation Records Data Collection and Analysis to TVA, " dated January 4, 1994. This document was not submitted as part of the license application, and was not readily available by the reviewer.

Consistent with 10 CFR 70.9, provide a copy of this document or describe it in sufficient detail so this commitment can be adequately assessed.TVA Response TVA has determined that it will not commit to the NRC document specified in the NRC request, and therefore the reference to NRC Technical Communication, dated January 4, 1994, should be removed from the application.

In accordance with the accuracy requirements of 10 CFR 70.9, the revised application page is provided as an enclosure.

B) Nuclear Criticality Safety 1. NRC Request Chapter 5 of the license application does not make any reference to the use of ANSI/ANS-8.23, "Nuclear Criticality Accident Emergency Planning and Response," as part of the nuclear criticality safety program. ANSI/ANS-8.23 is E1-3 Enclosure I TVA Responses to NRC RAIs in Support of the Review of the 10 CFR 70 License Application for Watts Bar Nuclear Plant, Unit 2 endorsed in RG 3. 71, but is not discussed in the license application.

Consistent with 10 CFR 70.22(a) (8) and 10 CFR 70.23(a) (4), clarify if TVA is committing to using ANSI/ANS-8.

23 for the purpose of the license application and indicate what version (i.e., year) TVA is committing to. Alternatively, justify the use of alternative approaches that meet the intent of ANSI/ANS-8.23.

TVA Response RG 3.71, "Nuclear Criticality Safety Standards for Fuels and Material Facilities," states that, "This guide is not intended to be used by nuclear reactor licensees." TVA evaluated RG 3.71 and determined that it is not applicable to WBN because the SNM for WBN, Unit 2 (i.e., nuclear fuel) will be received, handled, and stored in areas that are shared with WBN, Unit 1. Unit 1 is licensed to operate by the NRC under the requirements of 10 CFR 50. Accordingly, the receipt, handling, and storage of the Unit 2 SNM will meet the applicable requirements under 10 CFR 50. As a result, TVA has performed a criticality analysis in accordance with 10 CFR 50.68(b) for the Unit 2 SNM. Therefore, an alternate means of ensuring criticality safety is not required.

Since RG 3.71 is not applicable to WBN, Unit 2, ANSI/ANS-8.2.3 is also not applicable.

2. NRC Request Chapter 5 of the license application did not describe any compensatory measures while the criticality accident alarm system (CAAS) is out of service, and did not define any criteria for establishing when it is not safe to shut down fissile material movement.

Since the CAAS is the primary means to identify a criticality accident and mitigate its effects, TVA needs to provide further justification for allowing fissile material movement to continue if the CAAS is out of service for an extended time. Consistent with 10 CFR 70.24: A) NRC Request Revise the license application to include a statement indicating that all movement of special nuclear material (SNM) must cease until the alarm service has been restored, should the CAAS be out of service for any amount of time; however, routine testing, calibration, and/or maintenance of the system is permitted without suspension of fissile material movement.TVA Response As explained above in response to NRC Request B.1, the receipt, handling, and storage of SNM at WBN, Unit 2 will be in compliance with the provisions of 10 CFR 50.68(b) by virtue of the fact that receipt, handling, and storage of Unit 2 SNM will occur in areas shared with Unit 1, an operating nuclear power plant licensed under 10 CFR 50. As such, a criticality analysis has been E1-4 Enclosure 1 TVA Responses to NRC RAIs in Support of the Review of the 10 CFR 70 License Application for Watts Bar Nuclear Plant, Unit 2 performed and the requirements of 10 CFR 50.68(b)(1) will be met for the SNM at Unit 2. Note that 10 CFR 70.24(d)(1) states that the requirements of 10 CFR 70.24(a) through 10 CFR 70.24(c) do not apply to a 10 CFR 50 licensee if the licensee complies with the requirements of 10 CFR 50.68(b).B) NRC Request Revise the license application to include a statement indicating that in the event that suspension of fissile material movement, even to make this activity safe, carries a larger risk than being without a CAAS for a short period of time, TVA commits to implementing compensatory measures (e.g., limiting access, providing continuously attended portable monitoring, etc.), approved by the nuclear criticality safety function, for the time needed to either restore complete functionality of the CAAS or to safely shut fissile material movement.TVA Response See the response to NRC Request B.2.A above.C) NRC Request Define the criteria that will be used at Watts Bar, Unit 2 to determine when it is not safe to shut down fissile material movement such that compensatory measures will be used. In addition, justify the time period required to safely shut down fissile material movement on a risk basis.TVA Response See the response to NRC Request B.2.A above.E1-5 Enclosure 1 TVA Responses to NRC RAls in Support of the Review of the 10 CFR 70 License Application for Watts Bar Nuclear Plant, Unit 2 3. NRC Request Chapter 5 of the license application does not describe the basis for determining that double contingency protection is ensured when only using administrative controls, especially in those instances when only two administrative controls are used. Consistent with 10 CFR 70.61, provide such information and describe how these administrative controls are unlikely to fail for those instances, if any. The double contingency principle states that process designs should incorporate sufficient factors of safety to require at least two unlikely, independent, and concurrent changes in process conditions before a criticality accident is possible.TVA Response See the response to NRC Request B.2.A above.Note that WBN, Unit 2 SWM (i.e., fuel assemblies) will comply with 10 CFR 50.68(b)(1) which prohibits the handling and storage at any one time of more fuel assemblies than have been determined to be safely subcritical under the most adverse moderation conditions.

C) Material Control and Accounting 1 .NRC Request Enclosure 3 of the license application does not state if a Fundamental Nuclear Material Control Plan (FNMCP) will be required in support of the license application.

Consistent with 10 CFR 70.22(b), revise the enclosure to clearly state the exception from the requirements for an FNMCP in support of a license application.

TVA Response 10 CFR 70.22(b) states: "Each application for a license to possess special nuclear material ... except for those uses involved in the operation of a nuclear reactor licensed pursuant to Part 50 of this chapter ... must contain a full description of the applicant's program for control and accounting of such special nuclear material ...". As explained in response to NRC Request B. 1 above, WBN, Unit 2 meets the exception in 10 CFR 70.22(b) and, therefore, a Fundamental Nuclear Material Control Plan is not required to be part of the application submittal.

E1-6 Enclosure 1 TVA Responses to NRC RAIs in Support of the Review of the 10 CFR 70 License Application for Watts Bar Nuclear Plant, Unit 2 2. NRC Request Enclosure 3 of the license application does not describe in sufficient detail how TVA will meet the requirements in 10 CFR 74 Subpart B, "General Reporting and Recordkeeping Requirements" for Watts Bar, Unit 2. Since TVA is relying on shared systems, structures, components, and administrative controls currently in place for Watts Bar Unit 1, provide a copy of such procedures, updated specifically to reflect its applicability to Unit 2, to demonstrate how the requirements of 10 CFR 74 Subpart B are met. Alternatively, describe each one of the nine elements in Enclosure 3 in sufficient detail to enable NRC to assess TVA's regulatory compliance for WB-2.TVA Response WBN implements the following procedures for SNM control, accounting, and reporting.

The following attached procedures (Attachments 2 through 9)demonstrate how the requirements of 10 CFR 74 subpart B are met. Note that these procedures already apply or will be changed to apply to WBN, Units 1 and 2.* 0-PI-RXE-1.0, "Annual Special Nuclear Material Inventory"* 0-SI-79-1, "Verification of Fuel Storage Configurations"" FHI-1, "Receiving, Returning, Inspecting and Storing New Fuel and Inserts" e NFTP-109, "Nuclear Fuel Database Updates and Special Nuclear Material Reporting" (Corporate Nuclear Fuels uses this procedure.)

• NFTP-1 13, "Spent Fuel Pool Management"" SPP-3.5, "Regulatory Reporting Requirements"" SPP-5.8, "Special Nuclear Material Control"" TI-7.006, "Preparing Special Nuclear Material Transfer Forms" The following delineates the appropriate procedures for the responses of Enclosure 3 of the license application:

E1-7 Enclosure I TVA Responses to NRC RAts in Support of the Review of the 10 CFR 70 License Application for Watts Bar Nuclear Plant, Unit 2 1. Establish, maintain, or follow written material control and accounting procedures to account for SNM.WBN implements the attached procedures (Attachments 2 through 9) for SNM material control and accounting procedures to account for SNM.Of the attached procedures, NFTP-109 will be revised to address Unit 2's Report Identification Symbol, and FHI-1 will be revised to state it is applicable to Unit 2. These two procedures will be revised prior to receipt of Unit 2 fuel.2. Maintain adequate records of the initial receipt or current inventory of SNM, including records of isotopic content, material received, material shipped, and material lost (material balance reports and physical inventory listing reports DOE/NRC forms 742 and 742C).SPP-5.8 is the governing document for SNM control practices and inventories and provides the recordkeeping requirements.

SPP-5.8 establishes the administrative controls for management of SNM including Supply/Receipt Control, Internal Control, Isotopic Inventories, and Shipping Control.In addition, FHI-1 is the procedure governing receipt of Fuel SNM and associated receipt records. TVA's policy concerning New Fuel and Inserts is one of zero defects. Therefore, FHI-1 provides instructions for Receiving, Returning, Inspecting, and Storing New Fuel and Inserts. By adhering to the requirements of this Fuel Handling Instruction, fuel handling and storage operations are in accordance with vendor recommendations and are sufficient to prevent fuel pellet damage that might reduce the margin to the PCI-type fuel failures.

FHI-1 includes instructions for the following:

• Receiving New Fuel and Inserts" Removing New Fuel from Shipping Containers, Inspecting Assemblies and Inserts, and Placing Fuel in Storage Racks" Re-assembly of Empty Shipping Container 0 Loading New Fuel Assemblies into Shipping Containers for Return to Manufacturer NFTP-1 09 is the procedure that provides Material Accounting (such as DOE/NRC forms 742 and 742C). One important aspect of SNM Control and Accountability is ensuring consistency between electronic database records, the physical inventory, and the isotopic reporting.

NFTP-109 provides guidance for preparation of SNM status reports, including collection and E1-8 Enclosure TVA Responses to NRC RAIs in Support of the Review of the 10 CFR 70 License Application for Watts Bar Nuclear Plant, Unit 2 generation of all supporting data and updating of the database, for fuel and non-fuel SNM. The purpose is to maintain accurate material accountability and ensure consistency throughout the process.3. Develop adequate inventory procedures or maintained adequate perpetual inventory records.SPP-5.8 governs SNM inventory practices.

It establishes the administrative controls for management of SNM including Supply/Receipt Control, Internal Control, Isotopic Inventories, and Shipping Control.0-PI-RXE-1.0 is a scheduling procedure to ensure yearly inventory of SNM.This Periodic Instruction (PI) verifies that the required annual SNM inventory has been completed and schedules the next performance (i.e., inventory)

NOT to exceed twelve (12) months. This PI is performed annually with zero extension time. Early performances may be requested by the SNM Custodian.

Each subsequent performance is scheduled eleven (11) months following the completion of the inventory.

NFTP-109 governs yearly material inventory reporting requirements.

Since WBN, Unit 2 SNM is nuclear fuel, there is not yet a national repository in place for the ultimate disposal of this fuel after it is used.4. Inventory SNM within the 12 month prescribed frequency.

SPP-5.8 governs SNM inventory practices, and O-PI-RXE-1.0 is a scheduling procedure to ensure yearly inventory of SNM.5. Report SNM inventories on the applicable forms.Proper reporting is governed by SPP-5.8 and NFTP-109.6. Establish an individual responsible for the control and accountability of SNM.SPP-5.8 defines the individual responsible for SNM control and accountability at WBN.E1-9 Enclosure 1 TVA Responses to NRC RAIs in Support of the Review of the 10 CFR 70 License Application for Watts Bar Nuclear Plant, Unit 2 7. Report the loss of or inability to find SNM items in a timely manner.Reporting of loss or inability to find SNM is covered in SPP-5.8 and SPP-3.5.8. Control access to SNM.SNM control is governed by SPP-5.8, which establishes the administrative controls for management of SNM including Supply/Receipt Control, Internal Control, Isotopic Inventories, and Shipping Control. Physical access to SNM at Unit 2 will be governed by the WBN Physical Security Plan/Contingency Plan. A summary of these plans was provided in Enclosure 4 of the license application submitted to the NRC by our letter dated November 12, 2009.9. Control the shipping and transfer of SNM.Shipping and transfer of SNM is governed by SPP-5.8 and FHI-1. Associated procedures are 0-SI-79-1, NFTP-1 13, and TI-7.006.NFTP-1 13 describes the development of Fuel Assembly Transfer Forms (FATFs) to be implemented at all TVA NPG sites as required by SPP-5.8.All transfers of SNM onsite are documented on transfer forms. TI-7.006 provides guidance for generating Summary of Planned Transfer Operations (SOPTO), FATFs, and Nonfuel SNM Transfer Forms. TI-7.006 also provides guidance for approval of, use of, and final distribution of SOPTOs, FATFs, and Nonfuel SNM Transfer Forms.El-10 Enclosure 2 Corrected Application Pages operations when containment and/or the annulus is open to the Auxiliary Building ABSCE spaces. An isolation barrier is thus formed between the building and the outdoor environment, and the ABGTS is started up automatically (see FSAR Section 6.2.3) to maintain the ABSCE at less than a 1/4-inch water gauge negative pressure during these high radiation or accident periods.The fuel-handling area ventilation system is located completely within Seismic Category I structures and all safety-related components are fully protected from floods and tornado-missile damage.4.7 RADIATION SURVEYS AND MONITORING PROGRAM COMMITMENTS Prospective monitoring determinations for internal and external dose monitoring are performed for individuals or group of individuals entering the restricted area. Personnel monitoring, for dose from sources external to the body, is conducted using appropriate dosimeters as required by 10 CFR 20. TVA maintains accreditation as a processing laboratory for dosimeters, as described inAmerican Standards Institute (ANSI) N13.1 1-1983, "Personnel Dosimeter

-Criteria for Performance".

This accreditation is under the National Voluntary Laboratory Accreditation Program conducted by the National Institute of Standards and Technology.

Dosimeters may be processed onsite by WBN, an accredited sub-facility, or by another processing laboratory within the scope of TVA's accreditation.

Dose information for whole body (total effective dose equivalent), external exposure of the skin, lens of the eye, and extremities is recorded in a dose tracking system and retained in a permanent historical database for generating required reports.Real time control is generally implemented using information from direct reading dosimeters.

Official doses of record are taken from dosimeters.

However, doses are calculated when dosimeter results are not available or do not accurately represent actual dose received.Personnel monitoring and confirmatory monitoring for dose from intakes of radioactive material is conducted using DAC-HR tracking and bioassays, including whole body counting.

Monitoring is performed for each person required to be monitored by 10 CFR 20. The whole body counter is calibrated with standard radioisotopes in configurations that approximate the human body. It is able to detect expected gamma emitting radionuclides per ANSI-N13.30, 1996, Table-C-3, "Direct Radiobioassay Minimum Detectable Activities." Routine radiological Surveys to detect radiation, radioactive contamination, and airborne radioactivity are performed throughout the plant on periodic schedules.

Survey frequencies are determined by the RADCON Superintendent based upon the actual or potential radiological conditions.

Schedules for completion of routine surveys are issued to the technicians.

As plant conditions change, the schedule will be updated.Radiological surveys may be performed whenever personnel enter potential or actual radiological areas and there is any doubt as to the existing conditions.

Retention of survey records follows the requirements of 10 CFR 20.2103 and the TVA Quality Assurance Plan (QAP).Radiation and contamination surveys will be made on the new fuel shipments by Radiological Control personnel.

The purpose of the survey is to protect personnel from unnecessary exposure to radiation and/or contamination.

Smears shall be counted for alpha and beta-gamma radiation.

Page 4-8

• Written procedures shall be established that address: selection, fitting, issuance, maintenance, and testing of respirators, including testing for operability immediately prior to each use; program audits; minimum qualifications of program supervisors and implementing personnel; limitations on periods of respirator use and relief from respirator use; maintaining TEDE ALARA and performing evaluations; supervision and training of personnel; monitoring (including air sampling and bioassays), and recordkeeping; a description of the applications of respirators for routine, non-routine, and emergency respirator use; and periodic medical evaluation (NRC Regulatory Guide 8.15).* Determination by a physician prior to the initial fitting of respirators, and annually (quarter ending) thereafter or periodically at a frequency determined by a physician, that the individual user is medically fit to use the respiratory protection equipment.

Internal dose monitoring (DAC-hr tracking including bioassay) is required for: Adult workers that are likely to receive an occupational intake in excess of 0.1 ALl or 200 DAC-h in a year.4.7.7 Evaluation of Dose A dose record system shall be implemented by RP for purposes of maintaining historical dose records for all persons for whom personnel monitoring or dose calculations are performed.

These records are collected and maintained pursuant to and in accordance with the Privacy Act of 1974, 5 U.S.C. 552a and TVA's Privacy Act regulations (18 CFR 1301 Subpart B). The records maintained shall include: the deep-dose equivalent to the whole-body, lens dose equivalent, shallow-dose equivalent to the skin, and shallow-dose equivalent to the extremities; the estimated intake of radionuclides; the committed effective dose equivalent assigned to the intake of radionuclides; and the specific information used to assess the committed effective dose equivalent pursuant to 10 CFR 20.1204(a) and (c), and when required by 10 CFR 20.2106.Deep Dose Equivalent, Lens Dose Equivalent, Shallow Dose Equivalent (Whole-body), Shallow Dose Equivalent (Maximum extremity), Committed Effective Dose Equivalent, Committed Dose Equivalent, Total Effective Dose Equivalent, and Total Organ Dose Equivalent dose information shall be calculated, maintained, and reported to the NRC and individuals according to NRC Regulatory Guides 8.7 and 8.34. The dose record system shall make a clear distinction among the quantities entered on the records (e.g., total effective dose equivalent, shallow-dose equivalent, lens dose equivalent, deep-dose equivalent, committed effective dose equivalent).

Those individuals who receive occupational exposure and require monitoring per 10 CFR 20.1502 shall have their doses reported annually to the NRC and the individuals with greater than 100 mrem of TEDE, EDE, DDE, LDE, SDE, SDEME, CEDE, or CDE on an NRC FORM-5 or an electronic record containing all the information required by a FORM-5.Page 4-13 Enclosure 3 List of Regulatory Commitments Tennessee Valley Authority Watts Bar Nuclear Plant, Unit 2 Application for a 10 CFR 70 License Facility Docket No. 50-391 Special Nuclear Material Docket No. 70-07018 Item No. RAI Commitment Committed Response Date/Milestone C) 2. NFTP-109 will be revised prior to receipt of new Unit 2 Prior to fuel to address Unit 2's Report Identification Symbol. receipt of new Unit 2 fuel 2 C) 2. FHI -1 will be revised to state it is applicable to Unit 2. Prior to receipt of new Unit 2 fuel