IR 05000409/2006003

Errata to La Crosse Boiling Water Reactor Inspection Report 05000409-06-003 (DNMS) and Notice of Violation

ML063470622
Person / Time
Site:	La Crosse File:Dairyland Power Cooperative icon.png
Issue date:	12/08/2006
From:	Jamnes Cameron NRC/RGN-III/DNMS/DB
To:	Berg W Dairyland Power Cooperative
Shared Package
ML063170275	List: IR 05000409/2006003
References
IR-06-003
Download: ML063470622 (12)

Text

ber 8, 2006

SUBJECT:

ERRATA TO LA CROSSE BOILING WATER REACTOR INSPECTION REPORT 050-00409/06-03(DNMS) AND NOTICE OF VIOLATION

Dear Mr. Berg:

As discussed with Mr. Robin Cota of your staff on December 5, 2006, the NRC issued an inspection report (NRC Inspection Report 050-00409/06-03) and Notice of Violation (NOV) on November 13, 2006, which contained minor errors. That inspection report has been revised to correct the minor errors, which included correcting references to a section number and the associated title quoted from the LACBWR Emergency Plan. In addition, the wording of the NOV and portions of the inspection report were revised to better articulate the NRCs findings.

The enclosed errata contains the revised NOV and Inspection Report.

We apologize for any inconvenience to you and your staff.

Sincerely,

/RA/

Jamnes L. Cameron, Chief Decommissioning Branch Docket No. 050-00409 License No. DPR-45

Enclosures:

Errata to Inspection Report 050-00409/06-03 and Notice of Violation

REGION III==

Docket No.: 050-00409 License No.: DPR-45 Report No.: 050-00409/06-03(DNMS)

Licensee: Dairyland Power Cooperative 3200 East Avenue South La Crosse, WI 54602 Facility: La Crosse Boiling Water Reactor Location: La Crosse Site Genoa, Wisconsin Dates: October 17, 2006 (onsite)

November 8, 2006 (in-office review)

Inspector: Peter J. Lee, Ph.D., CHP, Health Physicist Approved by: Jamnes L. Cameron, Chief Decommissioning Branch Enclosure 2

EXECUTIVE SUMMARY La Crosse Boiling Water Reactor (LACBWR)

NRC Inspection Report 050-00409/06-03(DNMS)

This was a special, reactive inspection, performed in response to the licensees October 16, 2006 Notification of Unusual Event. The licensees basis for the emergency declaration was the identification of airborne concentrations in the general areas of the reactor building that exceeded 10 times the normal level. On October 13, 2006, the licensee identified 3 to 5 derived air concentrations (DACs) of americium-241 in the reactor building, outside of the area in the lower levels of the building where licensee staff were cutting piping associated with the control rod drive mechanisms. The licensee did not normally observe any detectable concentrations of americium-241 in the reactor building, however, the minimum detectable concentration of americium-241 for the licensees radioanalytical counting equipment was approximately 1.0 DAC.

Subsequent investigation by the licensee determined that the counting equipment was contaminated with americium-241, which resulted in false indications of airborne americium-241. Recounting of the air samples taken between October 13 and 17, 2006, determined that airborne concentrations were below the minimum detectable concentration.

Notwithstanding the licensees subsequent determination that the results of earlier air sampling in the reactor building were not valid, the licensee made a declaration of an Unusual Event on October 16, 2006, based on airborne concentrations of americium-241 that it had identified on every air sample taken since October 13. As a result, the licensee should have made the declaration based on those conditions on October 13, rather than waiting until October 16.

The licensees failure to make a timely emergency declaration constitutes a violation of 10 CFR 50.54(q).

The licensees actions following the declaration were timely and appropriate, including notification to the NRC and the subsequent recovery from the event. The event did not result in any exposures to workers or release of radioactive material to the environment.

2 Enclosure 2

Report Details1 1.0 Radiological Safety 1.1 Occupational Radiation Exposure (83750)

a. Inspection Scope The inspector reviewed the sequence of events associated with the licensees October 16, 2006, declaration of a Notification of Unusual Event. The review included interviews of licensee personnel, evaluation of the results of air sampling taken between October 13 and 17, 2006, and examination of the licensees counting system used to analyze the samples.

b. Observations and Findings On October 12, 2006, the licensee removed the reactor expansion ring, the cover for the failed fuel system located in the upper cavity, and the leak off tubes for the upper control rod drive mechanisms. Air samples taken from the main floor of the reactor building indicated the presence of airborne americium-241 at approximately 8 derived air concentrations (DACs). The licensee verified the results on October 13, 2006, by gamma analysis.

At this time, the licensee postulated that the americium-241 was caused by the work in the cavity. However, when setting up for the lower cavity work, the licensee built an enclosure around the work area, which included dedicated ventilation using high efficiency particulate air (HEPA) filters. The licensee could not explain the presence of americium-241 outside the enclosed work and on the main floor of the reactor building.

The licensee stopped all work on the expansion ring, however, other work in the reactor building continued. Surveys, including large area surface wipes for removable contamination, did not identify the presence of americium-241. An air sample taken on the main floor of the reactor building taken late October 13, 2006, continued to indicate airborne americium-241 at about the 3 DACs level. At this time, the licensee declared the reactor building an airborne radioactivity area and restricted access to only those personnel qualified to wear respiratory protection. As an additional measure, the licensee installed HEPA filtration units to draw air from the upper cavity in an attempt to remove the airborne radioactivity.

On October 14, 2006, air sampling continued to indicate airborne americium-241 levels in the building in the 3 to 5 DACs range. The licensee closed all drain valves to the expansion ring and shut off the HEPA filtration units, which were still taking a draw on the upper cavity, in an attempt to locate the source of the americium-241. The licensee maintained normal reactor building ventilation to try and clear the airborne radioactivity.

On October 15, 2006, the levels of airborne radioactivity remained at 3 to 5 DACs.

NOTE: A list of acronyms used in the report is included at the end of the report.

3 Enclosure 2

An air sample taken in the early morning of October 16, 2006, indicated no change in the reactor building airborne concentration of americium-241. The licensee put all work in the reactor building on hold and declared an Unusual Event and notified NRC. The licensee based its decision on an emergency action level of airborne concentrations greater than 10 times normal levels in the plant, as described in Table D-1 of the licensees Emergency Plan.

Surveys in the basement of the reactor building indicated high levels of americium-241 contamination. The licensee decontaminated the basement area and continued normal ventilation. However, air samples taken in the afternoon of October 16 continued to indicate americium-241 concentrations at 3 to 5 DACs. The licensee started another stack fan to increase the air flow through the reactor building and the building ventilated overnight.

On October 17, 2006, early morning air samples indicated no change in the americium-241 concentrations. The licensee examined its air sample counting equipment and discovered that the sample holder was contaminated with americium-241. On October 12, 2006, the licensee calibrated the gas proportional counter using an americium-241 counting standard that it had made. Evidently, a small piece of this source likely broke free and remained on the sample holder. The licensee had not noticed the contaminated sample holder previously, since the holder was not used during analyses for background radiation levels. The licensee surveyed the counting room and did not identify any contamination. The licensee re-analyzed the air samples taken from October 12 through 17. The results indicated only background levels.

On the morning of October 17, 2006, the inspector observed the sample analyses and evaluated the analytical results. Based on the review of analytical results of all the air samples, no detectable airborne americium-241 actually existed in the reactor building.

Title 10 of CFR 50.54(q) states, in part, that a licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b). Title 10 of CFR 50.47(b)(4) requires the facility licensee to have a standard emergency classification and action level scheme in use. The licensee maintained an emergency plan, "LACBWR Emergency Plan,"

Revision 25, dated December 2004. The Emergency Plan Emergency Action Level (EAL) matrix (Table D-1) states that an Unusual Event will be declared for Any Unplanned or Unexpected Release of Radioactive Materials within the Plant, which involves Any uncontrolled increase in radiation levels or airborne contamination levels greater than 10 times normal. The licensees failure to declare an Unusual Event on October 13, 2006, when airborne contamination levels of americium-241 were detected at greater than 10 times normal in the reactor building constitutes a violation of 10 CFR 50.54(q). This is a Severity Level IV violation (VIO 05000409/2006003).

c. Conclusions The inspector concluded that the licensees October 16, 2006, declaration of an Unusual Event was based on erroneous information due to contamination of equipment used to analyze air samples. Based on a subsequent re-analysis of the air samples in question, the licensee determined that no detectable airborne contamination existed.

4 Enclosure 2

As such, there was no detectable exposure to workers or releases to the environment.

However, the licensees failure to make the event declaration on October 13, 2006, based on the air sample information available at the time, constitutes a violation of 10 CFR 50.54(q). The licensees corrective actions will be evaluated following receipt of the response to the Notice of Violation and during a future inspection.

2.0 Exit Meeting The inspector presented the preliminary inspection results to members of the licensees staff at the conclusion of the inspection on October 17, 2006. An additional telephone exit meeting was conducted on November 8, 2006. The licensee did not identify any of the documents or processes reviewed by the inspector as proprietary.

ATTACHMENT: SUPPLEMENTAL INFORMATION Enclosure 2

SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED

• R. Christians, Plant Manager

• R. Cota, Training/Security Supervisor

• J. Henkelman, Quality Assurance Specialist

• M. Johnsen, Tech Support Engineer

• L. Nelson, Health and Safety Supervisor

• S. Rafferty, Reactor Engineer

• M. Moe, Captain, Burns Security

• D. Egge, Quality Assurance Supervisor

• R. Lewton, Electrician & Instrument Technician

• J. McRill, Tech Support Engineer

• Persons present at the exit meeting.

INSPECTION PROCEDURES USED IP 83750: Occupational Radiation Exposure LIST OF DOCUMENTS REVIEWED The licensee documents reviewed and utilized during the course of this inspection are specifically identified in the Report Details above.

ITEMS OPENED, CLOSED, AND DISCUSSED Opened 050-00409/2006-003 VIO Failure to make a timely declaration of an Unusual Event in accordance with emergency plan following identification of airborne concentration in the main floor of the reactor building exceeding the emergency action level.

Closed None Discussed None Attachment

INITIALISMS AND ACRONYMS ACP Administrative Control Procedure ADAMS Agencywide Documents Access and Management System CFR Code of Federal Regulations DAC Derived Air Concentration DNMS Division of Nuclear Materials Safety HEPA High Efficiency Particulate Air LACBWR La Crosse Boiling Water Reactor NOV Notice of Violation NRC Nuclear Regulatory Commission PARS Publicly Available Records VIO Violation 2 Attachment