IR 05000331/1997013

Insp Rept 50-331/97-13 on 970811-15.No Violations Noted. Major Areas Inspected:Review of Radiation Protection & Chemistry Programs

ML20217A244
Person / Time
Site:	Duane Arnold
Issue date:	09/15/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217A241	List: IR 05000331/1997013 ML20217A236
References
50-331-97-13, NUDOCS 9709190106
Download: ML20217A244 (20)

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U. S. NUCLEAR REGULATORY COMMISSION REGION 111 Docket No: 50-331 License No: DPR-49 Report No: 50-331/97013(DRS)

l Licensee: IES Utilities In Facility: Duane Arnold Energy Center Location: IES Utilities In First Street SE P.O. Box 351 Cedar Rapids, IA 52406-0351 Dates: August 11 - 15,1997 Inspector: Kara N. Selburg, Radiation Specialist Approved by: Gary L. Shear, Chlef, Plant Support 2

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Division of Reactor Safety

9709190106 970915 PDR 0 ADOCK 05000331 PM

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EXECUTIVE SUMMARY Duane Arnold Energy Center, Unit 1 NRC Inspection Report 50 331/97013 This inspection included a review of the radiation protection and chemistry program Specifically, the inspector reviewed the radiation protection and chemistry Instrumentation  ;

programs, the Internal dosimetry program, and the post accident sampling system (PASS).

• The licensee was effectively implementing the internal dosimetry program (Sections R1.1 R1.2, R1.3).

e The health physics department created several ALARA initiatives which increased the overall radiological protection and safety of radiation workers (Section R1.4).

• The licensee was adequately maintaining hand-held radiation detection and chemistry instrumentation in accoroance with procedures (Sectiort R2.1).

• The licensee's response to a 10 CFR Part 21 notification on an electrometer with a potentially faulty component was good (Section R2.2).

e The licensee effectively addressed and corrected an increasing trend in the number of pe' inel entering the controlled area without the appropriate dosimetry (Section R4.1).

• At( ilcian performing a routine surveillance on the PASS system appeared knowiedgeaole of the system's performance (Section RS.1).

• Numerous improvements implemented regarding communications between the maintenance department and radiation protection department personnel effectively corrected a violation regarding the failure of mechanical maintenance personnel to comply with health phys:cs instructions (Section R8.2).

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Bgoort Details IV.. PlanLSuppm1 R1 Radiological Protection and Chemistry (RP&C) Ct,ntrolo R internal Dmimetry Program imoection Scoco UP 83750)

The inspector reviewed the licensee's inter ;i dosimetry prok im. The inspector interviewed numerous personnel, and reviewed the following documents 'vhich evaluated the need for internal dose monitoring at the facility:

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" Passive Internal Monitoring Program at the DAEC Revised," NG 93-1691, dated April 21,1993; e " Prospective Evaluation 01 the Need for Internal Monitoring at the DAEC Revised," NG 931692, dated April 21,1993; and

" Periodic Evaluation on the Need for Internal Monitoring at the Duane Arnold Energy Center," Calculation No. 96-005A, NG 961358, dated June 18,199 Rhem11ons and Find'ngs The Eberline PCM 1B whole body counters were installed at the Health Physics Access Control point and were used as a contamination check for personnel exiting the power block. NNC Model Gamma 10 portal monitors were installed at the security egress point and at the Health Physics Control point, and were used to detect either the diversion of special nuclear material or gross contamination levels. The licensee performed an evaluation in 1993 to determine if these instruments could be effectively used to monitor workers for internally deposited radioactivit The licensee performed a prospective evaluation (NG 931692)which determined that personnel at the facility did not need to be monitored for an internal dose based on the criteria speelfied in 10 CFR 20.1204. The evaluation datermined that workers in every classification at the facility were not likely to receive, in one year, an intake in excess of 10 percent of the Annual Limit on intake (All). Therefore, the facility discontinued routine in vivo bloassays (10 whole body counts). This determination was based on an evaluation of past internal exposures, an evaluation of the maximum likely intemal exposure, and a comparison of maximum permissible concentrations versus derived air concentrations (DAC).

The licensee subsequently performed a periodic perspective evaluation in 1996 (NG 96-1358) to verifi that the original determination not to monitor was accurate. The methodology used in the 1996 eveluation was based on a DAC hour evaluation of the air sample data, an assessment of internal committed effective dose equivalent

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determinations, and a 10 CFR Part 61 Radioactive Waste Chain evaluation. This evaluation again concluded the following: workers would not have received 10 percent of an All based on DAC hour estimate for the highest exposed worker; internal evaluations performed on workers with suspected intakes confirmed that passive whole body monitoring alarms were low enough to ensure that intakes with the potential of exceeding 10 percent of an ALI were properly addressed; and the 10 CFR Part 61 sample results indicated that no substantial change in the radionuclide mix had occurred since the original prospective evaluction. Thorofore, the licensee determined that monitoring was still not require l While no monitoring was required to meet the applicable regulations, the licensee used the portal monitors and whole body counters as part of the passive surveillance program. Each radiation worker was procedurally required to use a whole body counter upon exiting the power block, and a portal monitor when exiting the radiologically restricted area, The licensee performed tests of the Gamma-10 portal monitors and the

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PCM 1B whole body counters, and determined that the detection of 1 percent of an All l was possible. These tests were performed using a phantom and placing cobalt 60 (Co-60) contaminated organs in the phantom's lung or gastrointestinal track compartment '

The isotope of Co-60 was used since it was present, in high relative abundance, in every air sample and contamination surveys at the facility, and because a portion of its gamma component would penetrate the body compartments and interact with the detector. The source size for testing was determined by normalizing the percent abundance of isotopes in 10 CFR Part 61 samples, based on All, and by using NUREG 4884 to determine the fraction remaining in various body regions after an intake. When testing the PCM 1Bs, the phantom was placed into position, and a count cycle was started. The monitor was deemed to have detected the intake if at least one alarm was received during the cycle (alarm setpoint was 5000 disintegrations per minute). When testing the Gamma 10 Portal Monitor, the phantom was held at arms length and " walked through" the monitor. The alarm setpoint was at any value in excest of the minimum detectable activity, which during the test was 32 nanocuries, Conclusions The inspector noted that the licensee had effectively implemented the internal dosimetry program. Radiation workers were adequately protected from airborne radioactive contaminants as Indicated by DAC hour evaluations and the radiological survey program such that formal internal monitoring was not required. Radiation workers were effectively monitored for internal deposition via the passive whole body counting program with the PCM 1B alarm setpoints set to indicate intakes of 1 to 2 percent of an All. Administrative procedures were established to classify and take appropriate action on potentialintakes of radioactive material at levels below 10 percent of an All. Once detected, workers who had an indication of an intake were evaluated via formal whole body counting techniques to determine the extent of the intake, and when necessary, were assigned a committed effective dose equivalen ..

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R1.2 Calibration and Maint.gnance of Internal Dosimetrv Eautoment and Internal Dogg 6&ntasmei;b

, Inspecilonicone flP 83750)

The inspector reviewed the licensee's calibration and maintenance progrcms for the PCM 1Bs located at the controlled area exit, the Gamma 10 monitors located at the ,

controlled area exit and at the security area exit, and the Canberra whole body counter The inspector also reviewed select evaluations which determined the assigned committed effective dose equivalent for individuals who had received intakes of .

radioactive materia * Observations and Findings The inspector reviewed select calibration records for the PCM 1Bs, Gamma 10s, and Canberra whole body counters and determined that the calibrations were conducted within the procedurally required frequency. Additionally, the inspector noted hat source

checks of the monitors were completed on a daily basis. The inspector also reviewed several dose assessments based on intakes in 1996. To determine the retention mode (inhalation versus ingestion) the licensee conducted a series of whole body counts with a Canberra Fastscan Whole Body Counter, The licensee then projected the intake using a vendor supplied software package (ABACOS PLUS) and performed dose assessments using ICRP 30 calculation methodology. The whole body count activity results were separated into a Summed Geometry, Upper Detector, and Lower Detector retention data for each nuclide identified and compared to the theoretical retention values in NUREG 4884. The retention modes and the assigned internal doses were reasonable, Conclusions The inspector noted that the licensee effectively maintained intemal dosimetry equipment, and that individuals who had received intakes of radioactive material were accurately assigned a committed effective dose equivalen R1.3 Minimization of Whole Body Counting Alarms Due to Radon Decav Products Insoection Scone (IP 83750)

The inspector Interviewed numerous personnel, and reviewed the following document regarding the elimination of spurious alarms on the PCM 1B portal monitor:

e " Establishment of the PCM 1B Sum Channel Sigma Factor to Eliminate Distributed Alarms Resulting from Radon Daughter (Decay) Product Contaminants," No.96-011 H, dated October 14,1996.

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' NAIyations and Findings The licenseo had been receiving numerous PCM 1B distributed contamination alarms caused by personal clothing which had been impregnated with radon decay product The alarms primarily occurred during the spring and the fall during temperature inversions. The PCM 1Bs would alarm via the sum channel alarm function upon detection of the radon decay products, indicating that these decay products were low levels of distributed contamination. The contamination levels at which the sum channel would alarm were less than the detection capability of the individual or zoned detector The licensee's evaluation (number 96 011 H) determined a sum channel sigma factor which would be high enough to avoid the nuisance alarms due to radon decay products, but be low enough to detect distributed contamination. The establishment of the PCM-1B as a passive whole body counter was based on multiple and single alarms, not distributed alarms. Therefore, changing the sum channel sigma factor had no impact on using the PCM 1Bs as passive internal monitors. The licensee implemented this evaluation, and determined that the nuisance alarms had been decrease Conclusions The inspector noted that the licensee had effectively reduced the number of spurious whole body counter alarms caused by radon decay products without reducing the at4tity of the monitors to Indicate potentialintakes of radioactive materia R1.4 Radiation Protection Initiatives insnection Scone (IP 83750)

The inspector Interviewed numerous personnel within the radiation protection department to review recent ALARA initiatives. The inspector performed inspections of the reactoc building instrument and control's instrument racks, and reviewed selected radiation work permits and radiological survey maps, Natyations and Findings The inspector reviewed recent initiatives established in the radiation protection department. One of these initiatives involved the reduction of the number of contaminated areas located around instrument and control's instrument racks. These areas had been historically contaminated at the fecility. Since the contaminated areas around the racks were physically small, work performed in these areas was often cumbersome. The health physics staff, with the assistance of decontamination personnel, systematically performed detailed surveys of these racks, and determined which valves were potentially seeping, thus causing the spread of contamination. After these valves were identified, instrument and control's personnel tightened the packing nuts on these valves, and the decontamination department personnel decontaminated the racks under the guidance of health physics. The licensee had successfully released three instrument racks including the 1C52 (second floor of the reactor building),1C121 A (reactor building north), and 1C121B (reactor building south). The licensee planned to

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continue with decontamination efforts on the other instrument racks, and planned to maintain the cleaned racks through routine surveys and decontamination following any work performed on the racks, The health physics department was also working on intograting occupational safety concerns into some radiation work permits. An example of this was Radiation Work Permit 61, job step 1 which provided guidance to maintenance workers who were performing activities around moving quipment. This procedure specified that gloves worn for contamination control purposes should not be taped to the worker's protective clothing (to ensure that if the glove was caught in moving equipment, the glove would be removed prior to the worker being injured). These additions to the radiation work permits were clear and ensured overall worker safety without reducing the radiological protectio Conclusions The health physics department was creating several ALARA initiatives which increased the overall radiation protection and safety of radiation worker R2 Status of RP&C Facilities and Equipment R2.1 Instrumentation- Insoection Scoos (IP 83750. IP 84750)

The inspector reviewed the RP&C instrumentation programs. This included a review of calibration and maintenance records for hand held radiation detection instruments and chemistry equipment. The inspector also reviewed the calibration methodologies used in the metrology lab for the calibration of the hand held radiation detection equipmen Observations and Findinas The inspector reviewed calibration results of both radiation detection instruments and chemistry instrumentation. The instruments were calibrated within the scheduled calibration frequency. Additionally, for the radiation detection instruments, health physics technicians had established a computer data base which indicated instrument location and calibration due dates. Most radiation detection instruments were calibrated by the metrology laboratory at the facility. The inspector observed several instrument calibrations and noted that the metrologist was cognizant of procedural requirements, and was knowledgeable of the calibration process. The metrology laboratory maintained an instrument maintenance history folder which recorded any problems encountered with specific instruments. The inspector noted that the metrologists referred to this folder after performing the calibrations to ensure that previous problems l were not recurring. Neutron detection equipment was sent off site for a vendor calibration. The inspector reviewed documents describing these calibrations, and noted no problem L

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Source control for both chemistry and radiation protection equipment was maintained by

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the radiation protection department. The inspector reviewed the licensee's computer data base of all nonexempt sources stored at the facility, and reviewed this data against

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the original records of receipt. The inspector noted that there was good control over the sources, l

Chemistry instrumentation was primarily maintained by the chemistry department, with most calibraGons and maintenance completed by the technician staff. The equipment was maintained as required by procedure Conclusions l The inspector concluded that the licensee was adequately maintaining hand held l radiation detection equipment and chemistry instrumentation in accordance with l

procedures.

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R2.2 ylcioteen Model 530 Insoection Scone (IP 83750)

In April 1997, Victoreen (vendor) filed a 10 CFR Part 21 report on a problem with the Victoreen Model 530 Electrometer/Dosemeter. The problem identified with some of these electrometers involved the potential for a component failure which, under very specific circumstances, may have caused the electrometer to calculate radiation exposures or rates incorrectly. The inspector reviewed the licensee's action to determine if this component failure affected the instrument performance at the facilit Ohicriations and Findings l In response to the 10 CFR Part 21 notification, the radiation protection and metrology j department personnel returned the electrometer to the vendor to have the machine analyzed. Upon receipt of the electrometer, the vendor replaced the potentially faulty component. However, the vendor did not perform an as found analysis to deterrnine if the component had in fact been at fault. The solo use of the electrometer at the facility, during the celibration cycle in question, was the initial on site certification of the J. L. Shepard calibrator. After the acceptable repair of the electrometer, the licensee used the unit to recertify and verify the J. L. Shepard calibrator. The recertification and verification of the J. L. Shepard calibrator (performed on August 6,1997) substantiated and validated the acceptable integrity of the unit since its initial certifica*lon on April 15, 1996. The recertification and verification process found the calibrator to be within the published specifications with the largest magnitude of error at .3.32 percent at 20 millirem per hour. The inspector reviewed the licensee's documentation from the vendor (including calibration results), reviewed the J. L. Shepard recertification and verification results, and agreed with the licensee's determination that the initial calibration was adequat w

. _ _ _ _ _ _ _ _ _ _ _ _ _ - Conclusions The licensee's response to a 10 CFR Part 21 nutification on an electrometer with a potentially faulty component was good. No instrumentation at the facility was adversely affected by the potentially faulty electrometer, R4 Staff Knowledge and Performance in RP&C R4.1 Failure to Wear Electronic DosimetcIs Insoection Scoce (IP 83750)

The inspector interviewed radiation protection personnel regarding the recent increase in the number of recorded personnel entering the controlled area (power block) without wearing the appropriate dosimetry. The inspector reviewed event descriptions, and the associated dose assessments for those occurrences. The inspector also reviewed the following procedure:

• Acministrative Control Procedure (ACP) 1411.18, revision 7 " Personnel Dosimetry." Observations and Findings l From March 6,1997, through August 7,1997, there were fifteen recorded incidents in which individuals entered the controlled area without wearing their electronic dosimeters (EDs). These events appeared isolated, and the inspector did not identify a person specific or department specific trend. The inspector reviewed the licensee's dose assessrnents for the individual's who failed to wear the EDs, and noted that each individual received no dose. The licensee identified severalinnovative corrective 7 actions to this self identified issue, including:

I e Memorandums were issued stressing the importance of wearing EDs;

Signs were posted at the controlled area to remind personnel to wear dosimetry; e Motion activated recording was placed at the controlled area entrance which asked personnelif they had their ED; and e Personnel actions were issued against individuals who failed to wear their ED which included the requirement to spend fours hours of the following shift at the entrance to the controlled arco verbally reminding personnel to wear their ED Since the frequency and number of these incidents had decreased since the corrective actions have been in place, it appeared that the corrective actions were effectiv Additionally, since these events were examples of one problem, and no similar problems had been identified within at least the last two years, this problem was not considered repetitive. However, the failure to wear the ED prior to entering the power block is

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contrary to ACP 1411.18. Failure to comply with this procedure is a violation of technical specification 6.9.1 which requires that procedures for personnel radiation protection be prepared consistent with 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposur However, this licensee-ldentified, non-repetitive and corrected violation is being treated as a Non Cited Violation, consistent with Section Vil.B.1 of the NRC Enforcement Policy (NCV 50-331/97013 01). Conclusions

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The inspector noted that the licensee had effectively addressed and corrected an increasing trend in the number of pc sonnel entering the controlled area without the appropriate dosimetry. One Non-Cited Violation of technical specification 6.9.1 was identifie R5 Staff Training and Qualifications in RP&C RS.1 Post Accident Samoling System Training Insoection Scone (IP 34750)

The inspector interviewed chemistry and training personnel to determine if training on post accident sample acquisition was completed. The inspector also reviewed the following correspondences which discussed this type of training for personnel:

Letter to Mr. Denton of the USNRC, from Mr. Root of the lowa Electric Light and Power Company, dated November 5,1982, LDR 82-285, "NUREG 0737, ll.B.3.-

Post Accident Sampling."

• Letter to Mr. Liu, Iowa Electric Light and Power Company, from Mr. Vassallo of the USNRC, dated November 30,1983,"NUREG-0737 item II.B.3 Post Accident Sampling System."

• Letter to Mr. Denton of the USNRC, from Mr. McGaughy of the Iowa Electric Light and Power Company, dated January 19,1984, "NUREG 0737, ll.B.3. Post Accident Sampling."

Letter to Mr. Denton of the USNRC from Mr. McGaughy of the Iowa Electric Light and Power Company, dated April 15,1985," Post Accident Sampling System Request fer Additional Information (NUREG-0737, ll B.3.)."

• Letter to Mr. Liu, Iowa Electric Light and Power Company, from Mr. Vassallo of the USNRC, dated June 11,1985," Post Accident Sampling System (safety evaluation report],"

Additionally, the inspector observed a chemistry technician performing the following surveillance:

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• Post Accident Sampling System (PASS) Leakage Inspection," STP # 685003-Q,CY, completed on August 13,1997.

l Obserydons and FindiD25 Through routine interviews with chemistry personnel, the inspector discovered that chemistry personnel were not r6ceiving continuing training on the operation of the PASS l system. While the PASS system was routinely operated (annually, quarterly, and for l emergency preparedness drills), ti,vre were no tracking mechanisms to ensure that each technician performed a sample acquisition. The licensee had routinely trained personnel through 1993, however, the licensee then made a decision to stop the training in this are Correspondence between the NRC and the licensee regarding the implementation of NUREG 0737, item ll.B.o, Post Accident Sampling Indicated the following:

• In the letter dated April 15,1985, the licensee stated that "DAEC PASS operators undergo formal retraining on PASS procedures every two years.

l Beginning the current refueling outage, the two-year operator training cycle will l

i be staggered such that at least one operator is trained every six months. In addition to the DAEC formal training, some PASS operators demonstrate the ability to obtain PASS samples during the Tech. Spec. (technical specification)

required PASS operability surveillance testing (performed once per operating cycle). Further, PASS operators demonstrate the ability to obtain and analyze PASS samples during the annual emergency drill."

Subsequent to this letter, the NRC issued a safety evaluation report on June 11, 1985, which stated that the PASS system described in the licensee's submittals met the eleven criteria specified in item ll.B.3 of NUREG 0737, and that this item was resolved at the facility. The evaluation of Criterion Ten, which required that the " accuracy, range, and sensitivity shall be adequate to provide pertinent data to the operator in order to describe the radiological and chemical status of the reactor coolant system," discussed retraining of the system operator Speelfically, the evaluations stated that the " retraining of operators for post accident sampling is scheduled at a frequency of once every six months."

The licensee was unable to produce records which indicated that operators were receiving training for post accident sampling. This item will remain unresolved pending a review of the basis for the NRC evaluation, and a review of the licensee's determination to stop routine training (URI 50-331/97013-02(a)).

The inspector reviewed the licensee's technical specifications (TS 6.8.1.12) which required, in part, that written procedures be prepared covering the program to ensure the capability to accurately determine the airborne lodine concentration in vital areas under accident conditions including the training of personnel. These procedures were required to be reviewed by the operations committee and the Plant Superintendent Nuclear. Through interviews with training and chemistry personnel, the inspector noted

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that they were unaware of any formally reviewed procedures goveming training in this area. However, at the exit interslew, the licensee indicated that these procedures may be located in the emergency preparedness area. This item will remain unresolved pending a review of any emergency preparedness procedures which cover the areas specified in this technical specification (URI 50-331/97013-02(b)).

The inspector observed a chcmistry technician perform portions of the quarterly PASS surveillance (STP # 685003 0,CY). The technician did not recall receiving formal training on the PASS system. However, the inspector noted that the technician was knowledgeable of the system and the surveillance test. Procedural compliance during this surveillance was good, Conclusions The inspector noted that PASS sample acquisition training did not appear to be conducted in accordance with the licensee's descriptions to the NRC or in accordance with technical specifications. This resulted in two unresolved items. The inspector also noted that a technician performing a routine surveillance on the PASS system appeared knowledgeable of the system's performance, R6 RP&C Organization and Administration (IP 83750,IP 84750)

The inspector noted that the licensee had assigned an individual in the radiation protection department to provide oversight for all instrumentation activities within the radiation protection and chemistry area. The inspector noted that this change could provide more efficiency and continuity in the instrumentation progra R8 Miscellaneous RP&C lasues (IP 92904)

R (Closed) VIO 50-331/97009-05: Failure to post VIO 50-331/97002 in accordance with 10 CFR 19.11. The inspector interviewed licensing department personnel, and reviewed documentation regarding this event. The corrective actions for this violation included posting the violation for the specified period of time, reviewing and training licensing personnel Procedure 114.6 for posting requirements, and changing the internal concurrence stamp as a reminder to post certain violations. These corrective actions appear adequate, and this violation is close R8.2 (Closed) VIO 50-331/97002-01: Failure to comply with health physics instruction for the February 10,1997, condensate demineralizer work. The inspector noted that corrective actions for this event had effectively prevented recurrence. These corrective actions included the following:

• The continuation of weekly working level meetings between health physics and mechanical maintenance personnel to discuss upcoming work activities; e Health physics department participation in mechanical maintenance pre-job briefings;

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The continued use of the maintenance health physics team to prepare, plan, coordinate, and cover specific maintenance activities when the schedule allowc; ano e Health physics foreman observations and performance evaluations of various maintenance work activities which require health physics coverag The inspector noted that these corrective actions effectively addressed the root causes of the February 10,1997, event. This violation is close R8.3 (Closed) IFl 50-331/97008-03: Determination of appropriate PASS sampling requirements. During the licensee's noble metal chemical addition safety evaluation, the licensee became aware of a potential discrepancy between the Updated Final Safety Analysis Report (UFSAR) and the actual PASS system operation. Section 12.3.4.2.3 of the UFSAR stated that heat tracing of the gaseous sample lines would be sized to maintain the line at 250 degrees Fahrenheit and that these lines would be insulate This line was actually maintained at 95 degrees Fahrenheit and the entire line was not insulated. The licensee contacted General Electric (manufacturer of the skid) to deterrnine the actual system requirement The vendor's evaluation determined that the licensee could not obtain a representative gaseous lodine sample using the PASS skid if the gaseous sample lines were maintained at the current temperature. However, through further evaluation, the licensee and vendor determined that gaseous lodine samples were not procedurally required or used to determine core damage following an accident. The licensee also determined that the above mentioned temperature discrepancy was actually with the continuous air monitor (CAM) sample lines which were shared with the PASS syste Specifically, portions of the piping to the hydrogen / oxygen monitors and the containment radiation monitors were not properly insulated or heat trace The inspector noted that, as installed, the PASS portion of the system was capable of performing all of its design functions as they would be relied upon in current plant conditions. Therefore, this item (50 331/97008-03)is close However, technical specification 6.8.1.12 requires that written procedures shall be propared covering the program to ensure the capability to accurately determine the alrborne lodine concentration in vital areas under accident conditions. Since the licensee was unable to obtain a representative sample via the PASS system, the inspector reviewed various post accident procedures to determine if the methodology existed to obtain the technical specification required procedures. While none were identified at the time of the inspection, this item will remain unresolved pending a review of licensing documents to determine if this capability exists at the facility (URI 50-331/97013-03).

The licensee's review of this issue also determined a pote.itially adverse effect on the CAM system, specifically with the ability to analyze for hydrogen and oxygen in post accident conditions. The initial heat trace design was to maintain the lines at 280

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degrees Fahrenho!t, however, sample piping was maintained at 95 degrees Fahrenhei The licenseo considered the current temperature to be acceptable since the lower the l temperature line, the more conservative the hydrogen and oxygen readings. However, this item will remain open pending a review of the representativeness of sample results at the current temperature rating (IFl 50 331/97013-04).

V, Management Meetinsa X1 Exit Meeting Summary On August 15,1997, the inspector presented the inspection results to licensee managemen The licensee acknowledged the findings presented. The inspector asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary Information was identified which related to inspection finding '

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PARTIAL LIST OF PERSONS CONTACTED Licensee J. Atkinson Budget Coordinator M. Atkinson Chemistry Trainer J. Bjorseth Maintenance Manager R. Brown Quality Assurance Specialist D. Curtland Operations Manager D. Ellers Materials Handling Supervisor J. Franz Vice President Nuclear R. Hite Radiation Protection Manager K. Jewett Radiation Protection Speciallot/ Engineer J. Karrick Licensing L. Kriege Chemistry Supervisor B. Lacey Manager Nuclear Business Unit -

R. Lewis Chemistry Foreman M. McDermott Engineering Manger R. McGee Outage Project Manger B. McVicker Chemistry Foreman J. Oldham Metrology Team Leader R. Perry Health Physics Supervisor K. Peveler Manager Regulatory Performance

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K. Putnam Licensing Supervisor ~

D. Schebler Quality Assurance R. Schlueter Health Physics Foreman E. Sorenson System Engineer B. Stout Metrologist J. Wiench Helper Foreman R,Zook Outage Manger HilC Christine Lipa Senior Resident inspector INSPECTION PROCEDURES USED IP 83750: Occupational Radiation Exposure IP 84750: Radioactive Waste Treatment and Effluent and Environmental Monitoring IP 92904: Follow up Plant Support

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k ITEMS OPENED, CLOSED, AND DISCUSSED Ooened

50 331/97013-02(a) URI Post accident sampling system training as described in licensee correspondenc /97013-02(b) URI Post accident sampling system training as described in licensee requirement /97013 03 URI Capability to determine airborne lodine concentration in vital areas under accident condition /97013-04 IFl Hydrogen / Oxygen monitoring in post accident condition ;

Closed 50 331/97013-01 NCV Failure to wear dosimetry as required by procedur /97009-05 VIO Failure to post NOV 50-331/97002 in accordance with 10 CFR 19.1 /97002-01 VIO Failure to comply with HP instruction for the 2/10/97  :

condensate domineraliser work, 50-331/97008 03 IFl Determination of appropriate PASS sampling requirement .

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LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable ACP Administrative Control Procedure ALI Annual Limit on Intake CAM Continuous Air Monitor CFR Code of Federal Regulations Co-60 Cobalt-60 DAC Derived Air Concentration dpm disintegrations per minute DRS Division of Reactor Safety ED Electronic Dosimeter GE General Electric HPP Health Physics Procedure l&C Instrument and Control ICRP international Council on Radiation Protection IFl Inspection Follow up Item IP Inspection Procedure IR Inspection Report NCV Non cited Violation NRC Nuclear Regulatory Commission PASAP Post Accident Sampling and Analysis Procedure PASS Post Accident Sampling System PCM Personal Contamination Monitor PDR Public Document Room RP&C Radiological Protection and Chemistry RWP Radiation Work Permit STP Surveillance Test Procedure TS Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved Itern USNRC United States Nuclear Regulatory Commission VIO Violation

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DOCUMENTS REVIEWED Action Requests: 970654,970658,970663,970927,971212,971215,971220,971248, 971272,971464,971468,971471,971472,971528,971635,971806,971876,971877, 97202 Administrative Control Procedure (ACP) 1411.18, revision 7, * Personnel Dosimetry."

Certificate of Calibration / Response Test Data for Victoreen # REP 39700, Model 530, serial number 244 (March 5,1996 and June 28,199 Correspondence Documents:

Letter to Mr. Denton of the USNRC, from Mr. Root of the Iowa Electric Light and Power Company, dated November 5,1982, LDR-82 285, "NUREG-0737, ll.B.3. Post Accident Sampling;"

Letter to Mr. Liu, Iowa Electric Light and Power Company, from Mr. Vassallo of the USNRC, dated November 30,1983, "NUREG 0737 ltem II.B.3 Post Accident Sampling System;"

Letter to Mr. Denton of the USNRC, from Mr. McGaughy of the Iowa Electric Ught and Power Company, dated January 19,1984,"NUREG 0737, ll.B.3. Post Accident Sampling;"

Letter to Mr. Denton of the USNRC from Mr. McGaughy of the lowa Electric Light and Power Company, dated April 15,1985," Post Accident Sampling System Request for Additional Information (NUREG-0737,11 B.3.);"

Letter to Mr. Liu, Iowa Electric Light and Power Company, from Mr. Vassallo of the USNRC, dated June 11,1985," Post Accident Sampling System (safety evaluation report);" and Letter to GE P DAEC Memorandum NG-97-099, dated May 2G,1957," Policies for Use of the Annex Door." ASS Users from Mr. Green of the General Electric Company, dated June 29,1987, " PASS UPGRADES- MAINTENANCE / SURVEILLANCE OF GAS TRAY."

DAEC Memorandum NG 971123, dated June 19,1997," Health Physics Support on Backshifts."

Defective Dosimetry Report: 97 1272,97-1220,97-0927,97-0654,97-1471,97-147 Dosimetry Filo records: 498422287; 505607616; 48864655 Health Physics Procedures (HPPs): Series 3109 and 311 .

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Memorandum to Mr. Perry from Mr. Louis, dated February 28,1997, * Monthly Foreman Tour with l&C Maintenance."

Memorandum to Mr. Perry from Mr. Louis, dated May 29,1997. " Monthly Foreman Tour with Mechanical Maintenance."

Memorandum to Mr. Perry from Mr. Schlueter, dated July 30,1997 " July 1997 Observation of Maintenance Activity Matching on PSV4407."

Memorandum to Mr. Hanr.en from PASS Task Force, dated September 11,1987,

" Recommendation of the PASS Task Force Disagreeing With the Removal of the Gaseous lodine and Particulate Sampling Capability,"

M&TE Calibration Data Sheets: (Serial numbers /date): 8149, 08/06/9 Nuclear Generating Division Procedure 114.6, revision 0,"10 CFR 19.11 &21.6 Posting Requirements."

Post Accident Sampling and Analysis Procedures (PASAP):

PASAP 7.0, revision 4, " Manual Reactor Building Effluent Grab Sample Procedure;"

PASAP 7.2, revision 3," Interpretation of Post Accident Sampling System Results;"

PASAP 7.2, revision 5 " Fuel Damage Assessment;"

PASAP 7.3, revision 4 " Interpretation of Containment Atmosphere Samples;"

PASAP 7.4, revision 1 " Containment High Range Radiation Monitors;" and PASAP 7.4, revision 2," Estimation of Potential Release Rate."

Radiological Engineering Calculations:

" Establishment of PCM1B Sum Channel Sigma Factor to Eliminate Distributed Alarms resulting from Radon Daughter Product Contamination," No.96-011 H, dated October 14,1996;

" Passive Internal Monitoring Program at the DAEC Revised," NG 931691, dated April 21,1993;

" Prospective Evaluation of the Need for Intemal Monitoring at the DAEC Revised," NG-931692, dated April 21,1993; and

" Periodic Evaluation on the Need for Intemal Monitoring at the Duane Arnold Energy Center," Calculation No. 96-005A, NG 961358, dated June 18,1996,

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1 Radiation Work Permits.

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Surveillance Test Procedure, STP # 685003 0,CY, completed on August 13,1997, " Post l Accident Sampling System (PASS) Leakage Inspection."

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