ML063170275

IR 05000409-06-003; La Crosse Boiling Water Reactor; 10/17/2006 - 11/08/2006; La Crosse Site

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

Enclosure 2

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

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.

1NOTE: A list of acronyms used in the report is included at the end of the report.

Enclosure 2

3

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.

Enclosure 2

4

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

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

Attachment

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

2

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