ML061810013: Difference between revisions

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Exelon Generation Company, LLC
Exelon Generation Company, LLC
4300 Winfield Road
4300 Winfield Road
Warrenville, IL 60555
Warrenville, IL 60555
SUBJECT:         FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND
SUBJECT:
                  NOTICE OF VIOLATION (NRC INSPECTION REPORT 05000456/2006012;
FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND
                  05000457/2006012 (DRS)); BRAIDWOOD NUCLEAR POWER PLANT,
NOTICE OF VIOLATION (NRC INSPECTION REPORT 05000456/2006012;
                  UNITS 1 AND 2
05000457/2006012 (DRS)); BRAIDWOOD NUCLEAR POWER PLANT,  
UNITS 1 AND 2
Dear Mr. Crane:
Dear Mr. Crane:
The purpose of this letter is to provide you the final results of our significance determination of
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);
the preliminary White finding identified within Inspection Report 05000456/2006008(DRS);
05000457/2006008(DRS). The inspection finding was assessed using the Significance
05000457/2006008(DRS). The inspection finding was assessed using the Significance
Determination Process (SDP) and was preliminarily characterized as a White finding, which
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
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
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
circulating water blowdown line vacuum breakers and to assess the environmental impact of the
resultant onsite and offsite tritium contamination.
resultant onsite and offsite tritium contamination.  
In a telephone conversation with Ms. A. Boland of the NRC, Region III office, on June 2, 2006,
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
Mr. K. Polson of your staff indicated that Exelon Nuclear did not contest the characterization of
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The NRC recognizes the extensive, recent monitoring performed by your staff to identify the
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
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
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
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
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
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
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
and insignificant relative to the normal background radiation dose. Additional information
relative to tritium, its properties, and its radiological characteristics may be found at
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.
http://www.nrc.gov/reactors/operating/ops-experience/grndwtr-contam-tritium.html.  


C. Crane                                         -2-
C. Crane
-2-
Despite your recent monitoring activities to address the groundwater issue, we concluded that
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,
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
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
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
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
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
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
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 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
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,
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.
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
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
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
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
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.
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
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
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.
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
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
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
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
10 CFR 20.1501; 2) adequately implement a program to assess the cumulative dose
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environmental monitoring program to provide data on measurable levels of radiation and
environmental monitoring program to provide data on measurable levels of radiation and
radioactivity in the environment resulting from the releases, as required by Technical
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
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
within NRC Inspection Report 05000456/2006008; 05000457/2006008 (DRS). In accordance
with the NRC Enforcement Policy, the Notice of Violation is considered an escalated
with the NRC Enforcement Policy, the Notice of Violation is considered an escalated
enforcement action because it is associated with a White finding.
enforcement action because it is associated with a White finding.
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Because plant performance for this issue has been determined to be in the regulatory 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
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.
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
The NRC also determined that two other apparent violations, as discussed in NRC Inspection
Report 05000456/2006008; 05000457/2006008 (DRS), represented violations of NRC
Report 05000456/2006008; 05000457/2006008 (DRS), represented violations of NRC
requirements. Specifically, your staffs failure to maintain complete records of the spread of
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
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
of low safety significance (Green). This inspection finding was also determined to be a violation


C. Crane                                         -3-
C. Crane
-3-
of 10 CFR 50.75(g), which requires licensees to maintain records of information important to
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
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
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
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
NRC requirements. This finding was evaluated using the NRCs traditional enforcement  
process because inspection findings that involve reporting requirements are considered to have
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
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
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
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 (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,
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
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
denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington
DC 20555-0001; with copies to the Regional Administrator and the Enforcement Officer,
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,
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
Washington, DC 20555-0001; and the NRC Resident Inspector at the Braidwood Nuclear
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enclosure, and your response, if you choose to respond, will be made available electronically
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
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
(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
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
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
NRC also includes significant enforcement actions on its Web site at www.nrc.gov; select What
We Do, Enforcement, then Significant Enforcement Actions.
We Do, Enforcement, then Significant Enforcement Actions.
                                              James L. Caldwell
James L. Caldwell
                                              Regional Administrator
Regional Administrator
Docket Nos. 50-456; 50-457
Docket Nos. 50-456; 50-457
License Nos. NPF-72; NPF-77
License Nos. NPF-72; NPF-77
Enclosure: Notice of Violation
Enclosure: Notice of Violation  
DISTRIBUTION:
DISTRIBUTION:
See next page
See next page


  C. Crane                                                                     -3-
    1 OE concurrence received on 06/28/2006 by D. Solorio per e-mail from D. Starkey
of 10 CFR 50.75(g), which requires licensees to maintain records of information important to
C. Crane
the safe and effective decommissioning of the facility. In addition, your staffs failure to fully
-3-
report the leaks from the vacuum breaker valves in annual reports submitted to the NRC, as
of 10 CFR 50.75(g), which requires licensees to maintain records of information important to
required by your Technical Specifications, was determined to be a Severity Level IV violation of
the safe and effective decommissioning of the facility. In addition, your staffs failure to fully
NRC requirements. This finding was evaluated using the NRCs traditional enforcement
report the leaks from the vacuum breaker valves in annual reports submitted to the NRC, as  
process because inspection findings that involve reporting requirements are considered to have
required by your Technical Specifications, was determined to be a Severity Level IV violation of
the potential to affect the NRCs ability to perform its regulatory function. The violation
NRC requirements. This finding was evaluated using the NRCs traditional enforcement  
associated with the Green inspection finding, which was characterized by the SDP as having
process because inspection findings that involve reporting requirements are considered to have  
very low significance, and the Severity Level IV violation are being treated as Non-Cited
the potential to affect the NRCs ability to perform its regulatory function. The violation
Violations (NCVs), consistent with Section VI.A.1 of the NRC Enforcement Policy. The
associated with the Green inspection finding, which was characterized by the SDP as having
violations have been entered into your corrective action program. If you contest these NCVs,
very low significance, and the Severity Level IV violation are being treated as Non-Cited
you should provide a response within 30 days of the date of this letter, with the basis for your
Violations (NCVs), consistent with Section VI.A.1 of the NRC Enforcement Policy. The
denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington
violations have been entered into your corrective action program. If you contest these NCVs,
DC 20555-0001; with copies to the Regional Administrator and the Enforcement Officer,
you should provide a response within 30 days of the date of this letter, with the basis for your
Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission,
denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington
Washington, DC 20555-0001; and the NRC Resident Inspector at the Braidwood Nuclear
DC 20555-0001; with copies to the Regional Administrator and the Enforcement Officer,  
Power Plant.
Region III; the Director, Office of Enforcement, United States Nuclear Regulatory Commission,
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
Washington, DC 20555-0001; and the NRC Resident Inspector at the Braidwood Nuclear
enclosure, and your response, if you choose to respond, will be made available electronically
Power Plant.
for public inspection in the NRC Public Document Room or from the NRCs document system
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its
(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To
enclosure, and your response, if you choose to respond, will be made available electronically
the extent possible, your response should not include any personal privacy, proprietary, or
for public inspection in the NRC Public Document Room or from the NRCs document system
safeguards information so that it can be made available to the Public without redaction. The
(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To
NRC also includes significant enforcement actions on its Web site at www.nrc.gov; select What
the extent possible, your response should not include any personal privacy, proprietary, or
We Do, Enforcement, then Significant Enforcement Actions.
safeguards information so that it can be made available to the Public without redaction. The
                                                                            James L. Caldwell
NRC also includes significant enforcement actions on its Web site at www.nrc.gov; select What
                                                                            Regional Administrator
We Do, Enforcement, then Significant Enforcement Actions.
Docket Nos. 50-456; 50-457
James L. Caldwell
License Nos. NPF-72; NPF-77
Regional Administrator
Enclosure: Notice of Violation
Docket Nos. 50-456; 50-457
DISTRIBUTION:
License Nos. NPF-72; NPF-77
See next page
Enclosure: Notice of Violation  
DOCUMENT NAME:E:\Filenet\ML061810013.wpd
DISTRIBUTION:
    Publicly Available                       G Non-Publicly Available                   G Sensitive                 Non-Sensitive
See next page
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
DOCUMENT NAME:E:\\Filenet\\ML061810013.wpd
OFFICE           RIII                   RIII                   RIII                   OE                   RIII                     RIII
Publicly Available
NAME             PPelke                 CPederson             KOBrien               DSolorio1             BBerson                 GGrant for JCaldwell
G Non-Publicly Available
DATE             06/28 /2006           06/28/2006             06/28/2006             06/28/2006           06/28/2006               06/28/2006
G Sensitive
                                                              OFFICIAL RECORD COPY
Non-Sensitive
      1
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
        OE concurrence received on 06/28/2006 by D. Solorio per e-mail from D. Starkey
OFFICE
RIII
RIII
RIII
OE
RIII
RIII
NAME
PPelke
CPederson
KOBrien
DSolorio1
BBerson
GGrant for JCaldwell
DATE
06/28 /2006
06/28/2006
06/28/2006
06/28/2006
06/28/2006
06/28/2006
OFFICIAL RECORD COPY


C. Crane                                 -4-
C. Crane
cc w/encl: Site Vice President - Braidwood Station
-4-
          Plant Manager - Braidwood Station
cc w/encl:
          Regulatory Assurance Manager - Braidwood Station
Site Vice President - Braidwood Station
          Chief Operating Officer
Plant Manager - Braidwood Station
          Senior Vice President - Nuclear Services
Regulatory Assurance Manager - Braidwood Station
          Vice President - Operations Support
Chief Operating Officer
          Vice President - Licensing and Regulatory Affairs
Senior Vice President - Nuclear Services
          Director Licensing
Vice President - Operations Support
          Manager Licensing - Braidwood and Byron
Vice President - Licensing and Regulatory Affairs
          Senior Counsel, Nuclear, Mid-West Regional
Director Licensing  
            Operating Group
Manager Licensing - Braidwood and Byron
          Document Control Desk - Licensing
Senior Counsel, Nuclear, Mid-West Regional
          Assistant Attorney General
  Operating Group
          Illinois Emergency Management Agency
Document Control Desk - Licensing
          State Liaison Officer
Assistant Attorney General
          Chairman, Illinois Commerce Commission
Illinois Emergency Management Agency
State Liaison Officer
Chairman, Illinois Commerce Commission


Letter to C. Crane from J. Caldwell dated June 29, 2006
Letter to C. Crane from J. Caldwell dated June 29, 2006
SUBJECT:       FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND
SUBJECT:
                NOTICE OF VIOLATION
FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND
NOTICE OF VIOLATION  
ADAMS Distribution:
ADAMS Distribution:
ADAMS (PARS)
ADAMS (PARS)
Line 237: Line 264:
DRSIII
DRSIII
PLB1
PLB1
ROPreports@nrc.gov
ROPreports@nrc.gov  


                                      NOTICE OF VIOLATION
NOTICE OF VIOLATION
Exelon Nuclear                                               Docket No.: 50-456; 50-457
Exelon Nuclear
Braidwood Nuclear Power Plant                                 License No.: NPF-72; NPF-77
Docket No.: 50-456; 50-457
Units 1 and 2                                                 EA-06-081
Braidwood Nuclear Power Plant  
License No.: NPF-72; NPF-77
Units 1 and 2
EA-06-081
During an NRC inspection completed on May 25, 2006, violations of NRC requirements were
During an NRC inspection completed on May 25, 2006, violations of NRC requirements were
identified. In accordance with the NRC Enforcement Policy, the violations are listed below:
identified. In accordance with the NRC Enforcement Policy, the violations are listed below:
1.       10 CFR 20.1501 requires that each licensee make, or cause to be made, surveys that
1.
        may be necessary for the licensee to comply with the regulations in Part 20 and that are
10 CFR 20.1501 requires that each licensee make, or cause to be made, surveys that
        reasonable under the circumstances to evaluate the extent of radiation levels,
may be necessary for the licensee to comply with the regulations in Part 20 and that are
        concentrations or quantities of radioactive materials, and the potential radiological
reasonable under the circumstances to evaluate the extent of radiation levels,
        hazards that could be present. Pursuant to 10 CFR 20.1003, survey means an
concentrations or quantities of radioactive materials, and the potential radiological
        evaluation of the radiological conditions and potential hazards incident to the production,
hazards that could be present. Pursuant to 10 CFR 20.1003, survey means an
        use, transfer, release, disposal, or presence of radioactive material or other sources of
evaluation of the radiological conditions and potential hazards incident to the production,
        radiation.
use, transfer, release, disposal, or presence of radioactive material or other sources of
        10 CFR 20.1301 requires the licensee to conduct operations so that the total effective
radiation.  
        dose equivalent to individual members of the public from the licensed operation does
10 CFR 20.1301 requires the licensee to conduct operations so that the total effective
        not exceed 0.1 rem (1 mSv) in a year.
dose equivalent to individual members of the public from the licensed operation does
        Contrary to the above, as of March 2006, the licensee did not make surveys to assure
not exceed 0.1 rem (1 mSv) in a year.
        compliance with 10 CFR 20.1301, which limits radiation exposure to 0.1 rem. As
Contrary to the above, as of March 2006, the licensee did not make surveys to assure
        examples, in November 1996 and December 1998, failed vacuum breakers in the
compliance with 10 CFR 20.1301, which limits radiation exposure to 0.1 rem. As
        licensees radioactive waste discharge line resulted in large volumes of liquid
examples, in November 1996 and December 1998, failed vacuum breakers in the
        contaminated with radioactive material to leak in an uncontrolled manner to the
licensees radioactive waste discharge line resulted in large volumes of liquid
        unrestricted areas. Following identification of the leaks of radioactive material, the
contaminated with radioactive material to leak in an uncontrolled manner to the
        licensee failed to perform adequate surveys to identify the extent of radiation and
unrestricted areas. Following identification of the leaks of radioactive material, the
        contamination levels and the potential hazards associated with the radioactive material
licensee failed to perform adequate surveys to identify the extent of radiation and
        and to take actions necessary to control the material.
contamination levels and the potential hazards associated with the radioactive material
        This violation is associated with a White Significance Determination Process finding for
and to take actions necessary to control the material.
        Units 1 and 2.
This violation is associated with a White Significance Determination Process finding for
2.       Technical Specification 6.8.4.e requires, in part, that the cumulative dose contributions
Units 1 and 2.
        from liquid effluents for the current calendar quarter and the current calendar year be
2.
        determined in accordance with the methodology and parameters in the Offsite Dose
Technical Specification 6.8.4.e requires, in part, that the cumulative dose contributions
        Calculation Manual (ODCM) at least once per 31 days.
from liquid effluents for the current calendar quarter and the current calendar year be
        Contrary to the above, between November 1996 and March 2006, the licensee did not
determined in accordance with the methodology and parameters in the Offsite Dose
        determine the cumulative dose contributions from liquid effluents inadvertently leaked to
Calculation Manual (ODCM) at least once per 31 days.  
        on-site and off-site locations resulting from failed vacuum breakers along the radioactive
Contrary to the above, between November 1996 and March 2006, the licensee did not
        waste discharge line in 1996, 1998, and 2000 in accordance with the methodology and
determine the cumulative dose contributions from liquid effluents inadvertently leaked to
        parameters in the ODCM within 31 days of the leaks. Specifically, the licensee did not
on-site and off-site locations resulting from failed vacuum breakers along the radioactive
        determine the dose resulting from a: 1) November 1996 release from a Vacuum Breaker
waste discharge line in 1996, 1998, and 2000 in accordance with the methodology and
        No. 1 leak of 250,000 gallons of water that included radioactive material to the
parameters in the ODCM within 31 days of the leaks. Specifically, the licensee did not
determine the dose resulting from a: 1) November 1996 release from a Vacuum Breaker
No. 1 leak of 250,000 gallons of water that included radioactive material to the  


Notice of Violation                               -2-
Notice of Violation
        groundwater pathway; 2) December 1998 release from a Vacuum Breaker No. 3 leak of
-2-
        3 million gallons of water that included radioactive material to the ground water pathway;
groundwater pathway; 2) December 1998 release from a Vacuum Breaker No. 3 leak of
        and 3) November 2000 release from a Vacuum Breaker No. 2 leak of 3 million gallons of
3 million gallons of water that included radioactive material to the ground water pathway;
        water that included radioactive material to the groundwater pathway.
and 3) November 2000 release from a Vacuum Breaker No. 2 leak of 3 million gallons of
        This violation is associated with a White Significance Determination Process finding for
water that included radioactive material to the groundwater pathway.
        Units 1 and 2.
This violation is associated with a White Significance Determination Process finding for
3.     Technical Specification 6.9.1.6 requires, in part, that the Annual Radiological
Units 1 and 2.
        Environmental Operating Report include summaries, interpretations, and analyses of
3.
        trends of the results of the radiological environmental monitoring program for the
Technical Specification 6.9.1.6 requires, in part, that the Annual Radiological
        reporting period and that the material shall be consistent with the objectives outlined in
Environmental Operating Report include summaries, interpretations, and analyses of
        the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I,
trends of the results of the radiological environmental monitoring program for the
        Sections IV.B.2, IV.B.3, and IV.C.
reporting period and that the material shall be consistent with the objectives outlined in
        10 CFR 50, Appendix I, Section IV.B.2 states the licensee shall establish an appropriate
the Offsite Dose Calculation Manual (ODCM), and in 10 CFR 50, Appendix I,  
        surveillance and monitoring program to provide data on measurable levels of radiation
Sections IV.B.2, IV.B.3, and IV.C.
        and radioactive materials in the environment to evaluate the relationship between
10 CFR 50, Appendix I, Section IV.B.2 states the licensee shall establish an appropriate
        quantities of radioactive material released in effluents and resultant doses to individuals
surveillance and monitoring program to provide data on measurable levels of radiation
        from principal pathways of exposure.
and radioactive materials in the environment to evaluate the relationship between
        Contrary to the above, as of March 2006, the licensee did not establish an appropriate
quantities of radioactive material released in effluents and resultant doses to individuals
        surveillance and monitoring program to evaluate the relationship between quantities of
from principal pathways of exposure.
        radioactive material released in effluents and resultant doses to individuals from
Contrary to the above, as of March 2006, the licensee did not establish an appropriate
        principal pathways of exposure. Specifically, the radioactive material released in the
surveillance and monitoring program to evaluate the relationship between quantities of
        1996, 1998, and 2000 vacuum breaker leaks constituted new principal pathways of
radioactive material released in effluents and resultant doses to individuals from
        exposure (i.e., the groundwater pathway) which the licensee had not adequately
principal pathways of exposure. Specifically, the radioactive material released in the
        evaluated with the existing Radiological Effluent Monitoring Program (REMP).
1996, 1998, and 2000 vacuum breaker leaks constituted new principal pathways of
        This violation is associated with a White Significance Determination Process finding for
exposure (i.e., the groundwater pathway) which the licensee had not adequately
        Units 1 and 2.
evaluated with the existing Radiological Effluent Monitoring Program (REMP).
This violation is associated with a White Significance Determination Process finding for
Units 1 and 2.
Pursuant to the provisions of 10 CFR 2.201, Exelon Nuclear is hereby required to submit a
Pursuant to the provisions of 10 CFR 2.201, Exelon Nuclear is hereby required to submit a
written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document
written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document
Control Desk, Washington, DC 20555 with copies to the Regional Administrator and
Control Desk, Washington, DC 20555 with copies to the Regional Administrator and
Enforcement Officer, Region III, and to the NRC Resident Inspector at the Braidwood Nuclear
Enforcement Officer, Region III, and to the NRC Resident Inspector at the Braidwood Nuclear
Power Plant, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
Power Plant, 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; EA-06-081" and should
This reply should be clearly marked as a "Reply to a Notice of Violation; EA-06-081" and should
include for each violation: (1) the reason for the violation, or, if contested, the basis for
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
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
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
(4) the date when full compliance will be achieved. Your response may reference or include
previously docketed correspondence, if the correspondence adequately addresses the required
previously docketed correspondence, if the correspondence adequately addresses the required  


Notice of Violation                               -3-
Notice of Violation
response. If an adequate reply is not received within the time specified in this Notice, an order
-3-
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,
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.
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
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
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
basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Commission, Washington, DC 20555-0001.
If you choose to respond, your response will be made available electronically for public
If you choose to respond, your response will be made available electronically for public
inspection in the NRC Public Document Room or from the NRCs document system (ADAMS),
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. Therefore, to
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. Therefore, to
the extent possible, it should not include any personal privacy, proprietary, or safeguards
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
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
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
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
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
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
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
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
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
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.
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
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working
days.
days.  
Dated this 29th day of June 2006
Dated this 29th day of June 2006
}}
}}

Latest revision as of 08:13, 15 January 2025

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  Constellation icon.png
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


See also: IR 05000456/2006012

Text

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

DISTRIBUTION:

See next page

1 OE concurrence received on 06/28/2006 by D. Solorio per e-mail from D. Starkey

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

DISTRIBUTION:

See next page

DOCUMENT NAME:E:\\Filenet\\ML061810013.wpd

Publicly Available

G Non-Publicly Available

G Sensitive

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

RIII

OE

RIII

RIII

NAME

PPelke

CPederson

KOBrien

DSolorio1

BBerson

GGrant for JCaldwell

DATE

06/28 /2006

06/28/2006

06/28/2006

06/28/2006

06/28/2006

06/28/2006

OFFICIAL RECORD COPY

C. Crane

-4-

cc w/encl:

Site Vice President - Braidwood Station

Plant Manager - Braidwood Station

Regulatory Assurance Manager - Braidwood Station

Chief Operating Officer

Senior Vice President - Nuclear Services

Vice President - Operations Support

Vice President - Licensing and Regulatory Affairs

Director Licensing

Manager Licensing - Braidwood and Byron

Senior Counsel, Nuclear, Mid-West Regional

Operating Group

Document Control Desk - Licensing

Assistant Attorney General

Illinois Emergency Management Agency

State Liaison Officer

Chairman, Illinois Commerce Commission

Letter to C. Crane from J. Caldwell dated June 29, 2006

SUBJECT:

FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND

NOTICE OF VIOLATION

ADAMS Distribution:

ADAMS (PARS)

SECY

OCA

L. Reyes, EDO

W. Kane, DEDR

M. Johnson, OE

D. Solorio, OE

D. Starkey, OE

J. Caldwell, RIII

G. Grant, RIII

L. Chandler, OGC

B. Jones, OGC

J. Dyer, NRR

S. Richards, Chief, IIPB, NRR

M. Tschiltz, Chief, SPSB, NRR

D. Merzke, NRR

J. Stang, NRR

D. Holody, Enforcement Officer, RI

C. Evans, Enforcement Officer, RII

K. OBrien, Enforcement Officer, RIII

K. Fuller, Enforcement Officer, RIV

R. Pascarelli, Enforcement Officer, NRR

M. Cheok, RES

E. Brenner, OPA

H. Bell, OIG

G. Caputo, OI

J. Schlueter, OSTP

P. Pelke, RIII:EICS

J. Strasma, RIII:PA

R. Lickus, RIII

J. Lynch, RIII

S. Ray, RIII

OEWEB

OEMAIL

DXC1

MXB

RidsNrrDirsIrib

CAA1

DRPIII

DRSIII

PLB1

ROPreports@nrc.gov

NOTICE OF VIOLATION

Exelon Nuclear

Docket No.: 50-456; 50-457

Braidwood Nuclear Power Plant

License No.: NPF-72; NPF-77

Units 1 and 2

EA-06-081

During an NRC inspection completed on May 25, 2006, violations of NRC requirements were

identified. In accordance with the NRC Enforcement Policy, the violations are listed below:

1.

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.

Contrary to the above, as of March 2006, the licensee did not make surveys to assure

compliance with 10 CFR 20.1301, which limits radiation exposure to 0.1 rem. As

examples, in November 1996 and December 1998, failed vacuum breakers in the

licensees radioactive waste discharge line resulted in large volumes of liquid

contaminated with radioactive material to leak in an uncontrolled manner to the

unrestricted areas. Following identification of the leaks of radioactive material, the

licensee failed to perform adequate surveys to identify the extent of radiation and

contamination levels and the potential hazards associated with the radioactive material

and to take actions necessary to control the material.

This violation is associated with a White Significance Determination Process finding for

Units 1 and 2.

2.

Technical Specification 6.8.4.e requires, in part, that the cumulative dose contributions

from liquid effluents for the current calendar quarter and the current calendar year be

determined in accordance with the methodology and parameters in the Offsite Dose

Calculation Manual (ODCM) at least once per 31 days.

Contrary to the above, between November 1996 and March 2006, the licensee did not

determine the cumulative dose contributions from liquid effluents inadvertently leaked to

on-site and off-site locations resulting from failed vacuum breakers along the radioactive

waste discharge line in 1996, 1998, and 2000 in accordance with the methodology and

parameters in the ODCM within 31 days of the leaks. Specifically, the licensee did not

determine the dose resulting from a: 1) November 1996 release from a Vacuum Breaker

No. 1 leak of 250,000 gallons of water that included radioactive material to the

Notice of Violation

-2-

groundwater pathway; 2) December 1998 release from a Vacuum Breaker No. 3 leak of

3 million gallons of water that included radioactive material to the ground water pathway;

and 3) November 2000 release from a Vacuum Breaker No. 2 leak of 3 million gallons of

water that included radioactive material to the groundwater pathway.

This violation is associated with a White Significance Determination Process finding for

Units 1 and 2.

3.

Technical Specification 6.9.1.6 requires, in part, 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 50, Appendix I,

Sections IV.B.2, IV.B.3, and IV.C.

10 CFR 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.

Contrary to the above, as of 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 radioactive material released in the

1996, 1998, and 2000 vacuum breaker leaks 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).

This violation is associated with a White Significance Determination Process finding for

Units 1 and 2.

Pursuant to the provisions of 10 CFR 2.201, Exelon Nuclear 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 copies to the Regional Administrator and

Enforcement Officer, Region III, and to the NRC Resident Inspector at the Braidwood Nuclear

Power Plant, 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; EA-06-081" 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

previously docketed correspondence, if the correspondence adequately addresses the required

Notice of Violation

-3-

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.

If you choose to respond, 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. Therefore, 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 29th day of June 2006

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