10 CFR 20.1501 requires that each licensee make or cause to be made surveys that may be necessary for the licensee to comply with the regulations in Part 20 and that are reasonable under the circumstances to evaluate the extent of radiation levels, concentrations or quantities of radioactive materials, and the potential radiological hazards that could be present. Pursuant to
10 CFR 20.1003, survey means an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.
10 CFR 20.1301 requires the licensee to conduct operations so that the total effective dose equivalent to individual members of the public from the licensed operation does not exceed 0.1 rem (1 mSv) in a year. Between November 1996 and March 2005, the licensee did not make surveys to evaluate the potential hazards and to assure compliance with 10 CFR 20.1301, which limits radiation exposure to members of the public from licensed operations to 0.1 rem. Specifically, in November 1996, December 1998, and November 2000, failed vacuum breakers in the licensees radioactive waste blowdown line resulted in large volumes of liquid contaminated with licensed material to leak in an uncontrolled manner to the unrestricted areas. Following the identified releases of radioactive material, the licensee failed to perform an adequate radiological survey to identify the extent of radiation levels, to evaluate the potential hazards associated with the radioactive material, and to ensure that the dose to the public did not exceed the levels specified in 10 CFR 20.1301. (AV 05000456, 457/2006008-01). Technical Specification 6.8.4.e.5 requires that the licensee maintain and implement a program to determine the cumulative dose contributions from liquid effluents for the current calendar quarter and the current calendar year in accordance with the methodology and parameters in the Offsite Dose Calculation Manual (ODCM) at least once per 31 days.
Between November 1996 and March 2006, the licensee failed to determine the cumulative dose contributions from liquid effluents that inadvertently leaked into onsite and offsite groundwater (resulting from failed vacuum breakers along the circulating water blowdown line in 1996, 1998, and 2000) in accordance with the methodology and parameters in the
ODCM within 31 days. Specifically, an estimated 250,000 gallon leak from Vacuum Breaker No.1 in November 1996 released water with radioactive material to the groundwater pathway; however, the licensee did not determine the dose from the release. In December 1998, an estimated 3 million gallon leak from Vacuum Breaker No. 3 released water with radioactive material to the groundwater pathway; however, the licensee did not determine the dose from the release. In November 2000, an estimated 3 million gallon leak from Vacuum Breaker No. 2 released water with radioactive material to the groundwater pathway; however, the licensee did not determine the dose from the release. (
AV 05000456, 457/2006008-02).
Technical Specification 6.9.1.6 requires that the
Annual Radiological Environmental Operating Report include summaries, interpretations, and analyses of trends of the results of the radiological environmental monitoring program for the reporting period and that the material shall be consistent with the objectives outlined in the
Offsite Dose Calculation Manual (
ODCM) and in
10 CFR Part 50, Appendix I, Sections IV.B.2, IV.B.3, and IV.C.
10 CFR Part 50, Appendix I, Section IV.B.2 states the licensee shall establish an appropriate surveillance and monitoring program to provide data on measurable levels of radiation and radioactive materials in the environment to evaluate the relationship between quantities of radioactive material released in effluents and resultant doses to individuals from principal pathways of exposure. Between November 1996 and March 2006, the licensee did not establish an appropriate surveillance and monitoring program to evaluate the relationship between quantities of radioactive material released in effluents and resultant doses to individuals from principal pathways of exposure. Specifically, the unplanned radioactive material released in 1996, 1998, and 2000 from the circulating water blowdown line vacuum breakers constituted new principal pathways of exposure (i.e., the groundwater pathway) which the licensee had not adequately evaluated with the existing Radiological Effluent Monitoring Program (
REMP). (
AV 05000456, 457/2006008-03). After considering the information developed during the inspection, the NRC has concluded that the inspection finding is appropriately characterized as White. 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
