IR 05000456/2006012
| ML061810013 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 06/29/2006 |
| From: | Caldwell J L Region 3 Administrator |
| To: | Crane C M Exelon Generation Co, Exelon Nuclear |
| References | |
| EA-06-081, FOIA/PA-2010-0209, IR-06-008, IR-06-012 ea-06-081 | |
| Preceding documents: |
|
| Download: ML061810013 (9) | |
Text
June 29, 2006
EA-06-081Mr. Christopher M. CranePresident and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT: FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING ANDNOTICE OF VIOLATION (NRC INSPECTION REPORT 05000456/2006012;05000457/2006012 (DRS)); BRAIDWOOD NUCLEAR POWER PLANT, UNITS 1 AND 2
Dear Mr. Crane:
The purpose of this letter is to provide you the final results of our significance determination ofthe preliminary White finding identified within Inspection Report 05000456/2006008(DRS);
05000457/2006008(DRS). The inspection finding was assessed using the Significance Determination Process (SDP) and was preliminarily characterized as a White finding, which may require additional NRC inspections. This White finding involved multiple failures by yourstaff to adequately evaluate the radiological hazards associated with the leaks from the circulating water blowdown line vacuum breakers and to assess the environmental impact of the resultant onsite and offsite tritium contamination. In a telephone conversation with Ms. A. Boland of the NRC, Region III office, on J une 2, 2006,Mr. K. Polson of your staff indicated that Exelon Nuclear did not contest the characterization ofthe significance of this finding and that you declined your opportunity to discuss this issue in a Regulatory Conference or provide a written response.The NRC recognizes the extensive, recent monitoring performed by your staff to identify theextent of the contamination from the circulating water blowdown line vacuum breaker historicalleaks. In this case, the contamination was limited to a single radionuclide, tritium. Tritium is a low energy beta emitter and represents a very low radiological risk as compared to other radionuclides. Based upon the current radiological conditions and the concentrations of tritium identified in the vicinity of the Braidwood site, the NRC estimated that the doses from thecontamination to be a very small fraction of the NRC's limit for doses to members of the publicand insignificant relative to the normal background radiation dose. Additional information relative to tritium, its properties, and its radiological characteristics may be found at http://www.nrc.gov/reactors/operating/ops-experience/grndwtr-contam-tritium.html
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C. Crane-2-Despite your recent monitoring activities to address the groundwater issue, we concluded thatyour staff did not perform adequate, timely radiological evaluations following the historical leaks, which impacted your ability to assess the environmental impact from the releases and tomitigate the releases; did not account for the potential public impact; and did not adequatelycontrol licensed material. After considering the information developed during the inspection, the NRC has concluded that the inspection finding is appropriately characterized as White. TheNRC's Public Radiation Safety SDP was developed to assess the risk of noncompliance withregulatory requirements and licensee programs and procedures. In this case, the significance of the inspection finding was not based on the risk from offsite doses. Instead, the significance of the inspection finding was based upon an evaluation of the adequacy of your controls to preclude and to assess environmental impact of releases of radioactive material. Specifically, the Public Radiation Safety SDP also considers the potential impact of program breakdowns.
In developing the Reactor Oversight Program, the NRC recognized that a licensee's control ofradioactive material is of interest to members of the public, even when, as in this case, very low levels of radioactive material are involved. Consequently, the NRC integrated a deterministicfactor into the Public Radiation Safety SDP, which provides for a higher level of significance than would be warranted based solely on the risk from exposure to the radioactive material. You have 30 calendar days from the date of this letter to appeal the staff's determination ofsignificance for the identified White finding. Such appeals will be considered to have merit onlyif they meet the criteria given in NRC Inspection Manual Chapter 0609, Attachment 2.The NRC also determined that the inspection finding involved three violations of NRCrequirements, as cited in the attached Notice of Violation (Notice). The three violations involved your staff's failure to: 1) perform adequate radiological surveys, as required by 10 CFR 20.1501; 2) adequately implement a program to assess the cumulative dose contributions, as required by Technical Specification 6.8.4.e.5; and 3) conduct an adequateenvironmental monitoring program to provide data on measurable levels of radiation and radioactivity in the environment resulting from the releases, as required by Technical Specification 6.9.1.6. The circumstances surrounding the violations are described in detailwithin NRC Inspection Report 05000456/2006008; 05000457/2006008 (DRS). In accordancewith the NRC Enforcement Policy, the Notice of Violation is considered an escalated enforcement action because it is associated with a White finding.You are required to respond to this letter and should follow the instructions specified in theenclosed Notice when preparing your response.Because plant performance for this issue has been determined to be in the regulatory responseband, we will use the NRC Action Matrix to determine the most appropriate NRC response forthis event. We will notify you, by separate correspondence, of that determination.The NRC also determined that two other apparent violations, as discussed in NRC InspectionReport 05000456/2006008; 05000457/2006008 (DRS), represented violations of NRC requirements. Specifically, your staff's failure to maintain complete records of the spread of contamination from the vacuum breaker valve leaks was determined to be an inspection finding of low safety significance (Green). This inspection finding was also determined to be a violation C. Crane-3-of 10 CFR 50.75(g), which requires licensees to maintain records of information important tothe safe and effective decommissioning of the facility. In addition, your staff's failure to fullyreport the leaks from the vacuum breaker valves in annual reports submitted to the NRC, as required by your Technical Specifications, was determined to be a Severity Level IV violation of
NRC requirements. This finding was evaluated using the NRC's traditional enforcement process because inspection findings that involve reporting requirements are considered to have the potential to affect the NRC's ability to perform its regulatory function. The violationassociated with the Green inspection finding, which was characterized by the SDP as having very low significance, and the Severity Level IV violation are being treated as Non-Cited Violations (NCVs), consistent with Section VI.A.1 of the NRC Enforcement Policy. The violations have been entered into your corrective action program. If you contest these NCVs, you should provide a response within 30 days of the date of this letter, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator and the Enforcement Officer, Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission,Washington, DC 20555-0001; and the NRC Resident Inspector at the Braidwood NuclearPower Plant.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response, if you choose to respond, will be made available electronicallyfor public inspection in the NRC Public Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Tothe extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction. TheNRC also includes significant enforcement actions on its Web site at www.nrc.gov; select WhatWe Do , Enforcement , then Significant Enforcement Actions
.James L. CaldwellRegional AdministratorDocket Nos. 50-456; 50-457License Nos. NPF-72; NPF-77
Enclosure:
Notice of Violation DISTRIBUTION:See next page 1 OE concurrence received on 06/28/2006 by D. Solorio per e-mail from D. Starkey