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EA-06-081, Braidwood Nuclear Power Plant, Units 1 and 2; Final Significance Determination for a White Finding and Notice of Violation (NRC Inspection Report Nos. 05000456/2006012; 05000457/2006012)
	ML061810013
Person / Time
Site:	Braidwood
Issue date:	06/29/2006
From:	Caldwell J; Region 3 Administrator
To:	Crane C; Exelon Generation Co, Exelon Nuclear
References
	EA-06-081, FOIA/PA-2010-0209, IR-06-008, IR-06-012 ea-06-081
	Download: ML061810013 (9)
	v • d • e

June 29, 2006

EA-06-081

Mr. Christopher M. Crane

President and Chief Nuclear Officer

Exelon Nuclear

Exelon Generation Company, LLC

4300 Winfield Road

Warrenville, IL 60555

SUBJECT: FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND

NOTICE 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 of

the 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 your

staff 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 June 2, 2006,

Mr. K. Polson of your staff indicated that Exelon Nuclear did not contest the characterization of

the 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 the

extent of the contamination from the circulating water blowdown line vacuum breaker historical

leaks. 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 the

contamination to be a very small fraction of the NRCs limit for doses to members of the public

and 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.

C. Crane -2-

Despite your recent monitoring activities to address the groundwater issue, we concluded that

your 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 to

mitigate the releases; did not account for the potential public impact; and did not adequately

control licensed material. After considering the information developed during the inspection, the

NRC has concluded that the inspection finding is appropriately characterized as White. The

NRCs Public Radiation Safety SDP was developed to assess the risk of noncompliance with

regulatory 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 licensees control of

radioactive 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 deterministic

factor 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 staffs determination of

significance for the identified White finding. Such appeals will be considered to have merit only

if 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 NRC

requirements, as cited in the attached Notice of Violation (Notice). The three violations involved

your staffs 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 adequate

environmental 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 detail

within NRC Inspection Report 05000456/2006008; 05000457/2006008 (DRS). In accordance

with 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 the

enclosed Notice when preparing your response.

Because plant performance for this issue has been determined to be in the regulatory response

band, we will use the NRC Action Matrix to determine the most appropriate NRC response for

this event. We will notify you, by separate correspondence, of that determination.

The NRC also determined that two other apparent violations, as discussed in NRC Inspection

Report 05000456/2006008; 05000457/2006008 (DRS), represented violations of NRC

requirements. Specifically, your staffs 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 to

the safe and effective decommissioning of the facility. In addition, your staffs failure to fully

report 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 NRCs traditional enforcement

process because inspection findings that involve reporting requirements are considered to have

the potential to affect the NRCs ability to perform its regulatory function. The violation

associated 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 Nuclear

Power Plant.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response, if you choose to respond, will be made available electronically

for public inspection in the NRC Public Document Room or from the NRCs document system

(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To

the 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. The

NRC also includes significant enforcement actions on its Web site at www.nrc.gov; select What

We Do, Enforcement, then Significant Enforcement Actions.

James L. Caldwell

Regional Administrator

Docket Nos. 50-456; 50-457

License Nos. NPF-72; NPF-77

Enclosure: Notice of Violation

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