ML063170275
| ML063170275 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 11/13/2006 |
| From: | Jamnes Cameron NRC/RGN-III/DNMS/DB |
| To: | Berg W Dairyland Power Cooperative |
| References | |
| IR-06-003 | |
| Download: ML063170275 (11) | |
See also: IR 05000409/2006003
Text
November 13, 2006
Mr. W. L. Berg
General Manager
Dairyland Power Cooperative
3200 East Avenue South
P.O. Box 817
La Crosse, WI 54602-0817
SUBJECT: NRC INSPECTION REPORT 050-00409/06-03(DNMS) AND
NOTICE OF VIOLATION - LA CROSSE BOILING WATER REACTOR
(LACBWR)
Dear Mr. Berg:
On November 8, 2006, the NRC completed an inspection in response to the Notification of
Unusual Event (NOUE) declared at the La Crosse Boiling Water Reactor (LACBWR) facility on
October 16, 2006. The purpose of the inspection was to determine the sequence of events that
prompted the declaration of the NOUE, the implementation of the facilitys emergency response
procedures, and the subsequent recovery from the event conditions. At the conclusion of the
onsite inspection on October 17, 2006, the NRC inspector discussed the preliminary findings
with members of your staff. On November 8, 2006, at the conclusion of our in-office review of
the circumstances related to the NOUE declaration, the inspector and I conducted a final exit
meeting with Mr. Roger Christians, Plant Manager.
The inspection consisted of an examination of activities at the facility as they relate to safety
and compliance with the Commissions rules and regulations. Areas examined during the
inspection are identified in the enclosed report. Within these areas, the inspection consisted of
a selective examination of procedures and representative records, field observations of
activities in progress, and interviews with personnel.
Based on the results of this inspection, the NRC has determined that one Severity Level IV
violation of NRC requirements occurred. The violation was evaluated in accordance with the
NRC Enforcement Policy. The current Enforcement Policy is included on the NRCs Web site
at www.nrc.gov; select What We Do, Enforcement, then Enforcement Policy. The violation is
cited in the enclosed Notice of Violation (Notice). The violation involves failure to immediately
respond to an emergency condition by declaring an Unusual Event in accordance with your
emergency plan following the identification of airborne radioactivity on the main floor of the
reactor building exceeding the emergency action level described in your plan.
Please note that you are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response. In your response to this letter,
please describe why your proposed corrective actions are expected to be more successful in
preventing future or similar violations than the actions and commitments stated in the past. The
NRC will use your response, in part, to determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
W. Berg -2-
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter
and its enclosure will be available electronically in the NRC Public Document Room or
from the Publicly Available Records (PARS) component of NRC's document system
(ADAMS). The NRCs document system is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html.
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
/RA/
Jamnes L. Cameron, Chief
Decommissioning Branch
Docket No. 050-00409
License No. DPR-45
Enclosures:
1. Notice of Violation
2. Inspection Report 050-00409/06-03(DNMS)
cc w/encls: Roger Christians, Plant Manager
B. D. Burks, P.E., Director, Bureau of Field Operations
J. Mettner, Chairman, Wisconsin Public
Service Commission
Spark Burmaster, Coulee Region Energy Coalition
State Liaison Officer
Chief, Radiation Protection Section
WI Department of Health and
Social Services, Division of Health
DISTRIBUTION:
Docket File
PUBLIC IE-01
RIII PRR
K. I. McConnell, NMSS
K. L. Banovac, NMSS
C. M. Craig, NMSS
G. E. Grant, RIII
S. A. Reynolds, RIII
RIII Enf. Coordinator
DOCUMENT NAME:C:\FileNet\ML063170275.wpd
X Publicly Available G Non-Publicly Available G Sensitive X Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE RIII RIII
NAME PJLee:mb JLCameron
DATE 11/13/06 11/13/06
OFFICIAL RECORD COPY
NOTICE OF VIOLATION
Dairyland Power Cooperative Docket No. 050-00409
La Crosse Boiling Water Reactor License No. DPR-45
During an NRC inspection conducted on October 17, 2006, with continuing in-office review
through November 8, 2006, a violation of NRC requirements was identified. In accordance with
the "General Statement of Policy and Procedure for NRC Enforcement Actions," the violation is
listed below:
10 CFR 50.54(q) requires, in part, that a licensee authorized to possess and operate a
nuclear power reactor follow and maintain in effect emergency plans which meet the
standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR Part 50.
The licensee maintained an emergency plan, "LACBWR Emergency Plan," Revision 25,
dated December 2004. Section 1.0 of the LACBWR Emergency Plan, "DPC Emergency
Organization And Responsibilities," requires, in part, that the emergency response
organization is intended to provide immediate response to an emergency condition at
LACBWR. Section 4.0 of the Emergency Plan, "Emergency Action Levels," Table 4.1,
lists potential plant conditions and their emergency classifications. For the plant
condition involving unplanned airborne concentrations greater than 10 times normal
levels, the corresponding emergency classification in Table 4.1 is a Notification of
Unusual Event.
Contrary to the above, on October 16, 2006, the licensee declared an Unusual Event
based on airborne americium-241 concentrations of 3 to 5 derived air concentrations
(DACs) in the general areas of the reactor building. As a result, the licensee failed to
provide immediate response to the emergency condition. Specifically, the licensee
identified americium-241 concentrations at those levels on October 13, 2006, but did not
declare an Unusual Event until October 16, 2006.
This is a Severity Level IV violation (Supplement VI).
Pursuant to the provisions of 10 CFR 2.201, Dairyland Power Cooperative is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator,
Region III, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
This reply should be clearly marked as a "Reply to a Notice of Violation and should include for
each violation: (1) the reason for the violation, or, if contested, the basis for disputing the
violation or severity level, (2) the corrective steps that have been taken and the results
achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date
when full compliance will be achieved. Your response may reference or include previous
docketed correspondence, if the correspondence adequately addresses the required response.
If an adequate reply is not received within the time specified in this Notice, an order or a
Demand for Information may be issued as to why the license should not be modified,
suspended, or revoked, or why such other action as may be proper should not be taken.
Where good cause is shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, United States Nuclear
Regulatory Commission, Washington, DC 20555-0001.
Enclosure 1
Notice of Violation -2-
Because your response 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, it should
not include any personal privacy, proprietary, or safeguards information so that it can be made
available to the public without redaction. If personal privacy or proprietary information is
necessary to provide an acceptable response, then please provide a bracketed copy of your
response that identifies the information that should be protected and a redacted copy of your
response that deletes such information. If you request withholding of such material, you must
specifically identify the portions of your response that you seek to have withheld and provide in
detail the bases for your claim of withholding (e.g., explain why the disclosure of information will
create an unwarranted invasion of personal privacy or provide the information required by
10 CFR 2.390(b) to support a request for withholding confidential commercial or financial
information). If safeguards information is necessary to provide an acceptable response, please
provide the level of protection described in 10 CFR 73.21.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days.
Dated this 13th day of November 2006
Enclosure 1
U.S. NUCLEAR REGULATORY COMMISSION
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
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.
1
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 4.1 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 CFR 50.54 (q) requires, in part, that a licensee authorized to possess and
operate a nuclear power reactor follow and maintain in effect emergency plans which
meet the standards in 10 CFR 50.47 (b) and the requirements in Appendix E to 10 CFR
Part 50. The licensee maintained an emergency plan, "LACBWR Emergency Plan,"
Revision 25, dated December 2004. Section 1.0 of the LACBWR Emergency Plan,
"DPC Emergency Organization And Responsibilities," requires, in part, that the
emergency response organization provide immediate response to an emergency
condition at LACBWR. Section 4.0 of the Emergency Plan, "Emergency Action
Levels," Table 4.1, lists potential plant conditions and their emergency classifications.
For the plant condition involving unplanned airborne concentrations greater than 10
times normal levels, the corresponding emergency classification in Table 4.1 is a
Notification of Unusual Event. The licensees failure to provide immediate response, by
delaying declaration of the Unusual Event until October 16, 2006, rather than on
October 13, 2006, 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 the
4 Enclosure 2
equipment used to analyze air samples. Although the licensees classification of the
event as an Unusual Event was conservative, based on plant conditions indicated by
the air sample analysis results, the decision to declare was not timely. The licensees
failure to make a timely event declaration constitutes a violation of 10 CFR 50.54(q).
Based on subsequent re-analysis of the air samples in question, the licensee
determined that no detectable airborne contamination existed. As such, there was no
detectable exposure to workers or releases to the environment. 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
NRC Nuclear Regulatory Commission
PARS Publicly Available Records
VIO Violation
2 Attachment