ML20080S636

Forwards Comparison of Beaver Valley Power Station Dose Projection Methodology Vs NRC Interactive Rapid Dose Assessment Model, Due to NRC Reported Dose Projection Results from Recent Emergency Planning Exercise

ML20080S636
Person / Time
Site:	Beaver Valley
Issue date:	10/03/1983
From:	Carey J DUQUESNE LIGHT CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML20080S640	List: ML20080S636 ML20080S645
References
TAC-52555, NUDOCS 8310180432
Download: ML20080S636 (3)

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'Af Dxpesnelet October 3,1983 Nuclear Division P.O. Box 4 Shippingport, PA 150774004 birector of Nuclear Reactor Regulation

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United States Nuclear Regulatory Commission Attn: Mr. Steven A. Varga, Chief Operating Reactors Branch No.1 Division of Licensing Washington, DC 20555

Reference:

Beaver Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 ,

Dose Projection Using IRDAM Gentlemen:

It has come to the attention of Duquesne Light that in a recent emergency planning exercise conducted at another nuclear facility, NRC personnei reported dose projection results directly to the respect-ive state governor. It was reported that the NRC results were a factor of 10-12 higher than the results reported by the licensee or state agencies.

In follow-up conversations with Region 1 personnel, Duquesne Light deter-mined that this reporting was a matter of policy with the NRC, and that the flRC results were obtained using the IRDAM micro-computer code.

' We also note that the USNRC Inspection and Enforcement Manual, pro-cedure 82207 Dese Calculation and Assessment, provides the following guidance l to inspection personnel: " ... Verify the results [from licensee methods]

by comparison with standard berchmark problems or by direct comparison with l.RC accident dosimetry models (e.g., Interactive Rapid Dose Assessment Model (IRDAM)...."

l Duquesne Light personnel perfomed a review of the Beaver Valley Power Station (BVPS) dose projection procedures aga)nst those in IRDAM. The report of that evalt.ation is attached for your information. In our review of that

report, Duquesne Light noted cases where the BVPS methods resulted in dose

! projections both higher and lower than the IRDAM results due mainly to dif-ferences between t.he site-specific assumptions and methods and the generic IRDAM methods. IRDAM should not be used as a standard against'which licensee and state dose projection methods are assessed, nor for inspection evaluations

! as directed by the IE procedure. A better course of action for the NRC wauld be to review the licensee's methodology rather than elying on comparisons with IRDAM.

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9310190432 831003 PDRADOCK05000g

Beaver Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 Dose Projection Using IRDAM Page 2.

'Duquesne Light and the state agencies responsible for accident assessment in Pennsylvania, Ohio, and West Virginia have endeavored over the past several years to-establish an orderly approach to per-fonning dose assessments and making protective action recommendations in the event of an emergency. We believe that.this goal has been sub-

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stantially achieved. The dose projection methods in the three states i are compatible with those used onsite, and in some degree, are based -

directly on the onsite methods._ Duquesne Light has conducted training on these rethods with personnel of these agencies. Another consideration is the soon-to-be-operational class A and class B model computer-assisted dose projection system. The results of these models will be directly accessible to the agencies via a remote terminal, consistent with the guidance of NUREG-0654. With the effort thus expended in establishing apprcpriate formal dose assessment and protective action recommendation mechanisms, Duquesne Light believes that the NRC policy regarding the provision of dose assessment results to the state governor should be withdrawn, for the following reasons:

1. The practice bypasses the carefully established mcchanisms  ;

provided for in the licensee, State (s) and local plans.

Each state in~ the BVPS EPZ has established a mechanism by which'the licensee dose assessments and protective action L recommendations are evaluted by technical personnel from 3

agencies assigned to this function (e.g.: Pennsylvania's l Bureau of Radiation Protection). This practice would bypass these lines of protocol and tends to have a negative' impact on coordination and credibility during an event.

2. In providing the governor with information in this manner, the i NRC is shifting the techr.ical decision of which dose projection is appropriate from the personnel having the expertise to make these evaluations to the governor. This situation raises two

. possible scenarios, both of which are undesirable. In one case,

! an imoroper assessment could be made and an improper or un-justified protection action set in motion. In a second case, the governor could delay a protective action order until the technical staff (s) evaluate the difference. Both scenarios are undesirable and could be avoided if the NRC provides the infor-l mation directly to the technical agencies assigned assessment l responsibilities in the state plan.

3. This practice'seems to be inconsistent with the NRC/ FEMA memo-randums of understanding in which FEMA has the lead federal re-sponsibility for coordination with the states.

4. As noted above, IRDAM is not a standard and differences between the IRDAM results and the site-specific methods of the licensee and/or the state agencies are to be expected. This situation can be expected to deteriorate with the use of the sophisticated class B models onsite and the relatively unsophisticated IRDAM code.

Beaver Vallcy Power Station, Unit No.1

. D:cket No. 50-334, License No. DPR-66 l

.. Dose Projection Using IRDAM Page 3

5. In the response to the THI incident, the NRC relayed in-accurate data and made unjustified dose projection recom-medations to the Governor of Pennsylvania regarding a measured dose rate of 1200 mrem / hour. The state agency, DER /BRP, had the proper data. This is described in great detail on pages 61 and 62 of Volume 2 of the Rogovin Report on the TMI accident. The Kememy Commission recommended that federal response plans ".. .be reexamined and revised by the appropriate federal authorities in light of the experience of the TMI accident, to provide for better coordination and more efficient federal support capability ..." Duquesne Light is concerned that the NRC practice is a step Jawa from coordin-ation and is forgetful of the lessor.s of the Three Mile Island accident.

Duquesne Light has discussed this issue with the emergency management agencies in the three states in the BVPS EPZ. All three states feel that this NRC practice is inappropriate. Duquesne Light respectfully requests that tne NRC reconsider this policy and _to notify the appropriate state agencies, rather than the state governor of NRC dose assessments and/or pro-tective action recommendations. Preferably, this would be done through the Federal Emergency Management Agency.

The higher degree of coordination which would result from this revised protocol would benefit the emergency response efforts both from the standpoint of technical appropriateness and improve public confidence in the plar,ning effort in concert with our mutual goals.

Very truly yours,

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l J. . Carey Vice President, Nuclear Attachment cc: "dr. W. M. Troskoski, Resident Inspector l U. S. Regulatory Commission l

Beaver Valley Power Station Shippingport, PA 15077

. U. S. Regulatory Commission

( c/o Document Management Branch Washington, DC 20555 l

U. S. Nuclear Regulatory Commission i

Office of Inspection and Enforcement Attn: R. W. Starostecki, Director Division of Project and Resident Programs Region I 631 Park Avenue King of Prussia, PA 19406

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