IR 05000331/1998011

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Insp Rept 50-331/98-11 on 980803-07.No Violations Noted. Major Areas Inspected:Evaluation of Effectiveness of Aspects of Radiation Protection & Chemistry Program
ML20237C142
Person / Time
Site: Duane Arnold NextEra Energy icon.png
Issue date: 08/14/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20237C141 List:
References
50-331-98-11, NUDOCS 9808200253
Download: ML20237C142 (18)


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U. S.' NUCLEAR REGULATORY COMMISSION REGION 111 Docket No: 50-331 License No: DPR-49 i Report No: 50-331/98011(DRS)

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Licensee: Alliant, IES Utilities In Facility: Duane Arnold Energy Center Location: Palo, Iowa Dates: August 3-7,1998 Inspector: Steven K. Orth, Senior Radiation Specialist Approved by: Gary L. Shear, Chief, Plant Support Branch 2 Division of Reactor Safety l

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EXECUTIVE SUMMARY Duane Arnold Energy Center, Unit 1

NRC Inspection Report 50-331/98011 This announced inspection included an evaluation of the effectiveness of aspects of the radiation protection (RP) and chemistry programs. Specifically, the inspector reviewed the chemistry program, including the monitoring and control of plant water chemistry, chemistry instrument quality control, technician sampling and analysis techniques, and self assessment In addition, the inspection also reviewed the implementation of the radiological environmental monitoring and meteorological programs. The report covers a one-week inspection concluding on August 7,1998, performed by a senior radiation specialist. No violations of regulatory requirements were identifie Plant Succort

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The staff's control of plant water chemistry was effective in reducing corrosive impurities in the reactor coolant system. Measured values of chloride and sulfates were routinely below the licensee's limit of detection. Additionally, the licensee continued to demonstrate a strong commitment to advanced technologies (e.g., noble metal chemical  ;

addition, hydrogen water chemistry, and zinc addition). The chemistry staff closely i monitored and evaluated chemistry parameters and evaluated excursions. (Section R1.1)

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The radiological environmental monitoring program (REMP) was properly implemented in accordance with the Offsite Dose Assessment Manual and program procedures. Air sampling equipment was properly calibrated, and the REMP technician demonstrated good analytical techniques. With the exception of minor amounts of cobalt-60 detected in the sewage discharge canal sediments, the REMP sample results were consistent with normal background. However, the licensee had not fully evaluated the sewage discharge canal sediment results, and the 1996 and 1997 annual reports did not thoroughly explain the source of the cobalt-60 nor its relationship to previous sample results. (Section R1.2)

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The chemistry staff properly implemented an analytical and radiochemistry instrument quality control program that was consistent with industry and NRC guidance. Generally, quality control results indicated that instruments were performing with a good degree of accuracy and precision. However, the inspector noted a high degree of variance in chloride analysis via the ion chromatograph, which the licensee was evaluatin (Section R2.1)

. The chemistry staff performed good monitoring of system operability for the meteorological tower. The calibrations and surveillance for the meteorological tower were properly performed and the licensee properly maintained the monitoring l instrumentation. Although the control room chart recorder had been out of service for

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over 3.5 years, the plant computer system provided equivalent data recording and display for the control room. (Section R2.2)

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During routine chemistry sampling, chemistry technicians demonstrated excellent ,

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analytical practices and procedure adherence. When anomalies were experienced, l technicians acted in a conservative manner and requested assistance from chemistry supervision. However, the inspector identified some minor problems concerning ,

radiological practices. (Section 4.1)  !

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.- The chemistry, RP, and quality assurance staffs performed comprehensive reviews of the chemistry program and REMP. The inspector observed that the chemistry organization was critical of its performance and had taken corrective actions to address ;

identified deficiencies. (Section R7)

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! Reoort Details IV. Plant Suonort-R1 Radiological Protection and Chemistry (RP&C) Controls R Plant Water Chemistrv Control

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I Insoection Scoce (IP 84750)

l The inspector reviewed the licensee's control and mitigation of chemical contaminants in

plant cooling systems, which contribute to corrosion of reactor vessel and plant piping

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systems. Specifically, the inspector reviewed the trends of impurities in the reactor i coolant, feedwater, and condensate during 1998 and reviewed the mitigation of corrosion in the circulating water system and closed cooling systems. The inspector also verified the licensee's implementation of Plant Chemistry Procedure (PCP) (Revision 14), " Water Chemistry Guidelines." Observations and Findings l The inspector observed that the licensee maintained a high level of commitment to minimizing corrosive impurities in reactor water. Procedure PCP 1.9 contained administrative action levels at concentrations of impurities that were consistent with current industry guidance. Along with the minimization of chemicalimpurities, the licensee maintained hydrogen injection into the reactor feedwater to reduce the electrochemical corrosion potential (ECP) of the reactor coolant system and to reduce the potentia! for intergranular stress corrosion cracking (IGSCC). The inspector noted that the licensee maintained a consistent level of injection and monitored the ECP to validate its effectiveness. As described in NRC Inspection Report No. 50-331/97008 (DRS), the licensee also continued to implement a noble metal chemical addition l program, which introduced a layer of noble metals onto the system surfaces. This

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process reduced the ECP of the system and the quantity of hydrogen injection necessary to inhibit IGSCC. Both the reduced hydrogen injection rate and the injection of zinc oxide had a positive effect on radiation levels and radioactive source term at the facilit The inspector reviewed the licensee's chemistry trends for January through July of 1998 and noted that the level of impurities in the reactor coolant system were maintained at a minimum. For example, the concentration of sulfate and chloride in the reactor coolant system were generally below the licensee's analytical detection capabilities (i.e.,1 part per billion (ppb)). Feedwater iron concentrations ranged from 0.5 ppb to 2 ppb, which was consistent with industry performance. The licensee also used additives to minimize the corrosion of the circulating water and closed cooling water systems. Based on sample specimen evaluations, the inspector also observed progress in these area The chemistry organization also performed reviews of water chemistry parameters at all levels of the organization (i.e., from the chemistry technician to the chemistry supervisor) to ensure that adverse trends were identifie l

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However, on June 30,1998, the licensee identified a problem with the circulating water sulfuric acid addition system. As designed, the system automatically adjusted the acidity of the circulating water to a pH bcnd of 7.5 to 8.2 (via sulfuric acid addition).

based on the indications of one-of-two in-line pH instruments. Only tl.e selected instrument provided indication in the control room and control of the acid addition pumps; the other instrument provided local ind; cation and did not have a controlling function. On June 30,1998, a member of the chemistry staff noticed a discrepancy beNveen the local i'1dications of the two instruments (i.e., pH indications of 7.3 vs 2 5).

The operations staff secured the acid feed pumps, and the chemistry staff obtained a grab sample and measured a pH of about 2.90. As a result of a plugged in-line pH instrument, the acid addition system improperly reduced the pH of the circulating water system to about 2.5. During the course of the day, a circulating water intrusion was also detected in the reactor coolant system. Consequently, the level of sulfates in the reactor coolant increased to about 10 ppb (maximum), which exceeded the licensee's administrative action level. As river water normally diluted the circulating water system, the pH of the circulating water was neutralized, and the reactor water cleanup system reduced the level of sulfates in the reactor water. On July 1,1998, the pH in the circulating water system was in the optimal range, and the reactor water sulfate level was below the administrative action level. Based on the short period of time of the {

excursion and the analysis of metal coupons in the circulating water system, the )

licensee concluded that the effect of the excursion on the circulating water system was minimal. In addition, the !icensee did not otsserve any other indications of in!sakage of circulating water into the reactor coolant system. However, the licensee planned to implement corrective actions to prevent future problems with the acid addition system, including routine flushing of the instrument lines and providing alarm capabilities for both instruments in the control room, Conclusica The staff's control of plant water chemistry was effective in reducing corrosive impurities in the reactor coolant system. Measured values of chloride and sulfates were routinely below the licensee's limit of detection. Additionally, the licensee continued to demonstrate a strong commitment to advanced technologies (e.g., noble metal chemical l addition, hydrogen water chemistry, and zine addition). The chemistry staff closely monitored and evaluated enemistry parameters and evaluated excursion R1.2 Radiological Environmental Monitorina Proaram (REMP) Insoection Score (IP 84750)

j The inspector reviewed the implementation of the radiological environmental monitoring program (REMP). Specifically, the inspector reviewed the 1996 and 1997 Annual Radiological Environmental Reports, observed sample collection activities, and reviewed the calibration and operability of instrumentation. The inspector also reviewed the l following procedures and their ! implementation:

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ESP 4.3.1.1 (Revision 18), " Airborne Particulate and lodine Sampling;"

ESP 4.3.1.3.A (Revision 9), " Surface Water Sampling;" and HPP M 10.42 (Revision 0), * Calibration of Eberline RAS-1/ RAP-1 Low Volume Air Sampler."

b. Observations and Findinas The insnector reviewed the 1996 and 1997 annual reports and found the reports to be well written and to contain the information required by the Offsite Dose Assessment Manual (ODAM). Within the reports, the licensee documented sampling anomalies and corrective actions for those anomalies. The inspector noted that no measurable radioactivity above background (i.e., natural background and fallout) was detected in the environmental samples, with the exception of sediment samples from the licensee's sewage effluent canal (onsite). In 1996 and 1997, the licensee detected cobalt-60 in the range of 0.15 to 0.25 picocuries per gram (pCi/g)in these samples. However, the licensee did not fully evaluate these results in the context of previous sample results and plant operations. Although these concentrations did not exceed any reporting levels and did not indicate a public health and safety concern, the inspechr noted that the body of the report did not explain the origin of the cobalt-60 and that the report summary suggested that only background radioactivity was detected. At the time of this inspection, the chemistry staff reviewed historical REMP data and found consistent results through about 1990. Based on these observations, the licensee initiated an action request to fully evaluate the sample results and planned to ensure that futura annual reports properly documented and explained these sample result The inspector also observed the collection of environmental air filters (air particulate and charcoal cartridges). The inspector noted that the instrumentation was operable and was acceptably maintained. During these observations, the inspector noted tnat the technician demonstrated an acceptable level of knowledge concerning the air sampling instrumentation and the procedure requirements. The technician also demonstrated good analytical techniques in removing and replacing sample media and performed a l inleakage test to ensure that the sample train was properly seale l The licensee properly calibrated the air pumps and regulators used in the collection of environmental samples. Based on the current calibration data, the inspector noted that i air regulator accuracy was stable. As required by procedure, the air sampling systems were calibrated to ensure that the systems produced a sample flow of 1 cubic foot per minute (* 10 percent). However, the inspector ncied a problem in the calibration l procedure, HPP 3110.42. Step 7.3.5 of the procedure required that the field rotameter l be cdjusted to within i 10 percent of the standard rotameter. The metrology team I

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leader indicated that the newer rotameter models could not be adjusted and that a procedure change was being processed to account for the lack of adjustment capability, i Although this did not result in a deleterious effect on the calibrations, the metrology team leader acknowledged that a temporary change should have been processed to more

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immediately address the inconsistency, so that ongoing calibrations could be performed without any problem ;

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. Conclusions The REMP was properly implemented in accordance with the ODAM and program procedures. Air sampling equipment was properly calibrated, and the REMP technician demonstrated good analytical techniques. With the exception of minor amounts of cobalt-60 detected in the sewage discharge canal sediments, the REMP sample results were consistent with normal background. However, the licensee had not fully evaluated the sewage discharge canal sediment results, and the 1996 and 1997 annual reports did not thoroughly explain the source of the cobalt-60 nor its relationship to previous sample results. An action request was initiated to fully evaluate the sample result R2 Status of RP&C Facilities and Equipment R2.1 Quality Control of Chemistry Instruments l Insoection Scoce (IP 84750)

The inspector reviewed the licensee's quality control (QC) program for laboratory and in- l line chemistry instrumentation including instrument control charts and calibrations, interlaboratory and intralaboratory sample analyses, and control of chemistry standards and reagents. The inspector also discussed laboratory practices with the chemistry staff and verified the licensee's implementation of the following procedures:

PCP 1.2 (Revision 10), "DAEC Chemistry Quality Control Program;"

PCP 1.3 (Revision 6), " Analysis of Chemistry Quality Control Samples;"

PCP 1.4 (Revision 5)," Chemical Equipment Calibration Program;"

PCP 4.6 (Revision 10), "lon Chromatography -- Anions;"

PCP 4.9 (Revision 6), " Metals Analysis -- Atomic Absorption;"

PCP 4.31(Revision 0),"lon Chromatography - Anions;"

PCP 6.1 (Revision 4), " General Considerations for Counting Radioactive Samples and Recording Results;"

PCP 6.4 (Revision 2), " Detector Efficiency of Counting Systems;"

PCP 6.5 (Revision 6), " Counting Room Statistics;"

PCP 7.2 (Revision 6), " Nuclear Data Spectroscopy Systems Calibration;" and l PCP 7.4 (Revision 5), " Nuclear Measurements Corporation Proportional Counter." Observations and Findinas -

The chemistry staff implemented a QC program that was consistent with industry guidance and NRC Regulatory Guides 1.21 and 4.15. The staff performed duplicate samples, instrument calibrations, efficiency tests, and performance tests at the frequency described in the above procedures. The instrument performance tests were graphically trenced to identify any biases in system performance (i.e., non-statistical performance). Routinely, the performance tests were performed daily or at the beginning of each shift, as applicable. In accordance with the applicable procedures,

! the chemistry staff also performed required actions when performance test results exceeded action levels (i.e., i 3 standard deviations from a mean/ prepared

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concentration). However, the inspector noted that the licensee's procedures and practices did not address the review of previous analytical results if an unsatisfactory performance test result was obtained. Since the chemistry staff did not specifically perform an instrument performance test following an analysis sequence, an

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unacceptable routine result could potentially indicate an instrument performance problem applicable to the previous analysis sequence. Although the inspector did not identify any specific data problems, the chemistry staff acknowledged the inspector's observations and planned to evaluate the laboratory practice. The inspector also reviewed instrument notebooks and noted that the chemistry staff properly documented the results of data reviews and pror.erly performed evaluations of biases in performance trend With the exception of the ion chromatograph (IC), the inspector found the instrument <

performance test data to dernonstrate statistical variations about the mean valu However, the IC analysis for chlorides (both laboratory and in-line instruments)

demonstrated a high degree of variability and resulted in frequent performance test failures. The inspector reviewed the IC analyses and noted that the analytical methods did not provide a clear separation between the elution of water and chloride. The instrumentation allowed for an integration of the peak associated with chloride; however, the lack of separation may have introduced some additional variation into the analysi The chemistry staff also attributed high biases (i.e., results greater than the expected concentration) with the normal potential for contamination of the performance test standards. Although the data did not indicate a significant problem with analytical results, the chemistry staff planned to further evaluate the analytical method and the potential for chemical contamination of the sample The chemistry staff implemented interlaboratory and intrataboratory analysis programs to ensure that accuracy of instruments and technicians, respt.ctively. In these programs, the chemistry staff analyzed samples prepared by a vendor laboratory and by a member of the chemistry staff. The chemistry staff performed the analysis required by procedure PCP 1.3 and performed corrective actions for results which were not in agreement. The staff's performance in these programs was very good, as evidenced by the good agreement between the laboratory results and the known concentrations /

activities. The inspector noted a minor, conservative bias in the noble gas radiochemical analysis, but the licensee's results were well within the acceptance criteria. Based on discussions with the chemistry staff, the inspector also noted that the l in-line IC was not used to perform any of these analyses; however, the in-line IC was the routine instrument for analyzing reactor coolant. Although procedure PCP 1.3 did not define the required instrumentation for sample analyses, the licensee acknowledged the inspectors observations and planned to evaluate the analysis of these samples on this instrument in the future, c. Conclusions j The chemistry staff properly implemented an analytical and radiochemistry instrument QC program that was consistent with industry and NRC guidance. Generally, QC results indicated that instruments were performing with a good degree of accuracy and

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precision. However, the inspector noted a high degree of vcriance in chloride analysis via the IC, which the licensee was evaluatin R2.2 Maintenance and Quality Control of Meteorological Monitorina Instrumentation

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The inspector reviewed the operability of the meteorological instrumentation located in the meteorology tower. Specifically, the inspector reviewed trends of instrument performance, instrument calibration records, and preventive maintenance survFlances;

. discussed instrument performance with a member of the chemistry staff; and pt.rformed a walk-down of the meteorological tower and instrumentation. The inspector also verified that the licensee had properly implemented the following procedures:

1.MIT-C012-01 (Revision 13), "Climatronics Meteorological Equipment;" and PCP 1.2 (Revision 10), "DAEC Chemistry Quality Control Program." Observations and Findinas The licensee maintained a meteorological tower to provide weather information for the purpose of offsite dose projections and emergency response actions. The -

meteorological tower consisted of instrumentation to measure the wind speed, wind direction, temperature, dew point, and precipitation. Dual instrumentation was available at each level (10 meters (m) and 50 m) on the tower. On a weekly basis, a member of the chemistry depertment performed weekly validation tests to determine the operability of the meteorological tower. Based on the results of these weekly tests, the availability (i.e., recoverable data hours) for meteorological tower instrumentation (i.e., for wind l speed, wind direction, and temperature indication) was generally greater than 95 l percent._ in cases when the availability was less than 95 percent, the chemist ensured that corrective actions were taken. For 1996 and 1997, the inspector noted that the annual availability of the instrumentation was also greater than 95 percen The inspector observed the condition of the meteorological tower and did not identify l any significant maintenance issues. However, the inspector noted that the primary data L recorder in the control room had been inoperable since January 5,- 1995. Although the

recorder was inoperable, the plant computer system provided data recording and i display for the plant staff, including the control room. System engineering i

representatives indicated that a design modification was in progress to completely

- modify the data transfer system so that it would communicate with a new chart recorde The system engineers indicated that the testing had been completed and that the design package would be ready for installation in November of 1998. The engineers

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acknowledged that the recorder had t:een inoperable for an excessive duration and

! attributed the delay to a lack of priority.

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The licensee properly calibrated and tested the meteorological towerinstrumentation, as required by the above procedures. At a 6 month frequency, the licensee performed a calibration of each of the instruments or returned the instruments to a vendor for i

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calibration. The inspector reviewed the previous calibration data (performed on May 14, 1998) and did not identify any problems. In addition, the inspector reviewed the bi-

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performed; however, the licensee had difficulties locating certain testing data. In addition, the inspector noted rather large variations in the comparison of some .

redundant instrumentation. For example, on June 5,1998, two redundant wind direction sensors differed by over 70 degrees. The instrument and controls supervisor attributed the variation to the low wind speed and the delay between instrument measurement l However, the individual acknowledged that the applicable procedure did not provide objective criteria to compare the redundant sensors and planned to review the guidance j in the procedure and to revise, if applicabl Conclusions i

The chemistry staff performed good monitoring of system operability for the meteorological tower. The calibrations and surveillance for the meteorological tower were properly performed and the licensee properly maintained the monitoring instrumentation. Although the control room chart recorder had been out of service for over 3.5 years, the plant computer system provided equivalent data recording and display for the control roo R4 Staff Knowledge and Performance in RP&C J

R Chemistrv Samoling Observations i Insoection Scoce (IP 84750)

The inspector observed chemistry technicians obtaining offgas and reactor coolant j samples and performing associated chemical analyses. The inspector verified that the technicians properly implemented the fc!)owing procedures:

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PCP 2.1 (Revision 4), " Plant Chemistry Sampling Program Guidelines;"

PCP 2.2 (Revision 0)," Collection of Liquid Grab Samples from Sample Stations and Local Sample Points;"

PCP 2.6 (Revision 4), "Offgas Retreatment and Posttreatment Sampling;" ,

PCP 2.13 (Revision 9), " Reactor Water Sampling;" )

STP 3.4.6-01 (Revision 0)," Reactor Coolant lodine Activity;" and STP NS770101 (Revision 0)," Reactor Coolant Chloride lon and Conductivity Analysis." Observations and Findinas The inspector observed two chemistry technicians obtaining samples from the offgas and reactor coolant system. The technicians demonstrated effective analytical techniques and procedure adherence. The inspector noted that both technicians

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performed the evolutions with the applicable procedures in-hand and properly implemented the applicable requirements. Consistent with procedures PCP 2.1,2.2, and 2.6, the technicians purged the sample lines to ensure a representative sample was

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obtained and were aware of the purge times and their basis. In the case of the reactor coolant sample, the technician pre-rinsed the sample container to reduce the potential for cross contaminatio During the reactor coolant sample, the chemistry technician compared the value of the in-line conductivity instrument to a temporary instrument. Although the initial comparison was satisfactory, the technician noted that the two instruments did not compare favorably after the reactor coolant grab sample was obtained. The inspector noted that the technician responded in a conservative manner and discussed the anomaly with his supervisor. After allowing some additional time for stabilization of the temporary instrument, the values were in agreemen The technicians demonstrated good radiological practices, with some minor exception The inspector noted that both technicians used a survey instrument to monitor dose rates in the area. The technicians also properly donned applicable protective clothing to reduce the potential for the spread of contamination. Although the technician surveyed the offgas sample, no dose rate measurement was made of the reactor coolant sampl The licensee indicated that a radiation detector in the area would identify abnormally high radiation levels but planned to review the survey practice. Prior to a contamination survey, the technician also placed a copy of the procedure used within the contaminated area on the step-off-pad. Although the technician requested RP support to survey his equipment and the procedure, the placement of the procedure on the step-off-pad could have potentially resulted in the spread of contamination. The RP manager acknowledged the inspector's observations and indicated that the plant was reviewing the use of procedures in contaminated areas and the respective handling of those procedures. The RP manager also indicated that the staff planned to decontaminate and release the reactor coolant sampling area, which would reduce encumbrances to the chemistry technician c. Conclusions During routine chemistry sampling, chemistry technicians demonstrated excellent analytical practices and procedure adherence. When anomalies were experienced, technicians acted in a conservative manner and requested assistance from chemistry i supervision. However, the inspector identified some minor problems concerning -

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R7 Quality Assurance in RP&C Activities 1 The inspector reviewed assessments of the chemistry program and REMP which had ,

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been performed by the quality assurance organization and the chemistry departmen The audits were thorough, and the licensee provided a broad view of performance in these programs. In particular, the chemistry /RP organization performed a comprehensive review of the chemistry program on a biennial basis, which provided a good assessment on chemistry performance. In addition, the chemistry department i conducted quarterly reviews of the chemistry QC program, which provided a thorough assessment of instrument performance, the status of control charts, and intertaboratory/

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intralaboratory analysis program results. The inspector noted that audit findings were generally positive; however, areas in need of improvement were well documented. For example, identified problems in the area of chemical controls were being reviewed by the departmen R8 Miscellaneous RP&C lssues R (Closed) Unresolved item No. 50-331/97008-03: As a result of inadequate heat tracing of sample lines, the licensee was unable to obtain a representative containment atmosphere sample via the post accident sampling system (PASS) for iodine quantification. Based on the lack of regulatory basis for the capability, the licensee planned to revise the Updated Final Safety Analysis Report (UFSAR) to delete the referenced capabilit On May 11,1998, the licensee completed UFSAR Change No. 98-66. The licensee evaluated the gaseous iodine capability and determined that revising Section 12.3.4. to delete the reference to heat tracing to prevent the " loss of iodine in the sample lines" did not result in an unreviewed safety question. Since the licensee did not rely on PASS gaseous iodine quantification for core damage assessment or emergency response decisions, the licensee concluded that the deletion of the capability would not effect accident mitigation or the margin of safety. In addition, the licensee reviewed commitments to the NRC, which did not include any commitment for this capability. This item is close R8.2 (Closed) Insoection Follow-uo item No. 50-331/98007-02: The licensee planned to review the posting of the reactor building and to evaluate the adequacy of posting the entire building as a radiation area. The licensee performed "DAEC Technical Basis Document #4 - Radiation Area Posting," which compared the licensee's current practices to NRC regulations, Regulatory Guides, Information Notices, and Health Physics Positions. Based on this evaluation, the licensee concluded that the reactor building postings met the above regulatory guidance. In particular, the licensee noted that the postings addressed access to overhead areas, which contained radiation area However, the RP staff also initiated some improvements to better alert workers to discrete radiation areas. Specifically, the licensee posted discrete radiation areas with floor level, painted posting to alert workers to hazards in those areas. The inspector reviewed the postings and concluded that the additional floor markings provided sufficient warning to workers. This item is close R8.3 (Closed) Violation No. 50-331/98007-07: The chemistry staff failed to perform PASS training as required by procedures, resultag in three chemistry technicians who exceeded the biennial training required by procedure PCP 1.2 (Revision 9), "DAEC Chemistry Quality Control Program." The licensee attributed the violation to inadequate tracking of training requirements. During this inspection, the inspector verified that the licensee had completed the following corrective actions:

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. the chemistry staff suspended the qualification of the three chemistry technicians for the PASS;

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a the training department incorporated PASS training requirements into the plant training / qualification program, so that PASS training dates would be formally tracked; and

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the chemistry staff and/or training staff observed training to ensure that technicians properly performed the surveillanc The inspector reviewed the training documentation and did not identify any problem . The training records properly reflected the chemistry records, and the training records called for a 2 year re-training, as required by procedure PCP 1.2. In addition, the chemistry staff reviewed other training and did not identify any other re-qualification tracking systems, which needed to be revised / corrected. This item is close V. Management Meetings X1 Exit Meeting Summary On August 7,1998, the inspector presented the inspection results to licensee managemen The licensee acknowledged the findings presented. The licensee also discussed RP improvement initiatives and results of field observations. 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 l l

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PARTIAL LIST OF PERSONS CONTACTED l Licerisee l J. Franz Vice President-Nuclear l

S. Funk Radiological Engineer- Chemistry

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R. Hite Radiation Protection Manager D. Jantosik Quality Assurance Manager l L. Kriege Chemistry Supervisor f B. Lewis Chemistry

' R. Lewis Chemistry Foreman D. May Maintenance Process Support Supervisor l B. McVicker Chemistry Foreman R. Murrel Licensing R. Perry Health Physics Supervisor K. Putnam Licensing Supervisor B. Richmond Health Physics Supervisor D. Schebler Quality Assurance G. Van Middlesworth Plant Manager T. Vine Radwaste Supervisor D. Wilson Assistant Vice President i K. Young Manager, Nuclear Training l INSPECTION PROCEDURES USED IP 83750: Occupational Radiation Exposure l IP 84750: Radioactive Waste Treatment and Effluent and Environmental Monitoring IP 92904: Follow-up Plant Support

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ITEMS OPENED, CLOSED, AND DISCUSSED Opened Non Closed 50-331/97013-03 URI Capability to determine airborne iodine concentration in ,

vital areas under accident conditions (Section R8.1). j 50-331/98007-02 IFl Radiological postings within the reactor building (Section R8.2). j i

50-331/98007-07 VIO Failure to ensure PASS qualifications of chemistry {

technicians (Section R8.3). 1 Discussed l

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! LIST OF ACRONYMS USED CFR Code of Federal Regulations DRS Division of Reactor Safety i ECP Electrochemical Corrosion Potential HPP Health Physics Procedure IC lon Chromatograph '

IFl Inspection Follow-up item l IGSCC Intergranular Stress Corrosion Cracking

! IP Inspection Procedure NRC Nuclear Regulatory Commission ODAM Offsite Dose Assessment Manual PASS Post Accident Sampling System PPB Parts Per Billion OC Quality Control REMP Radiological Environmental Monitoring Program RP Radiation Protection RP&C Radiological Protection and Chemistry TS Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved item VIO Violation

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DOCUMENTS REVIEWED Form 103 (Revision 3), " Conductivity Cell Checks," dated 7/7/98,6/9/98, 5/19/98,4/17/98, 3/10/98,2/27/98, and 1/26/9 Form 108 (Revision 0), " Duplicate Samples," dated 7/14/98,6/16/98, 5/19/98,4/16/98,3/17/98, 2/17/98, and 1/20/9 l.MIT-C012-01 (Revision 13), "Climatronics Meteorological Equipment," Section A - l Meteorological Equipment Bi-Weekly inspections, dated 7/29/98,7/7/98,6/5/98,5/14/98, .

4/23/98, and 2/28/9 l 1.MIT-C012-01 (Revision 13), "Climatronics Meteorological Equipment," Section C --

Climatronics Met Tower Sensors Calibration, dated 5/14/9 Health Physics Calibration Data Sheet (Revision Ok (Instrument No. ) (Dated)

EAS 45 8/3/98,2/9/98, and 11/4/97 EAS 46 5/18/98,2/3/98, and 10/6/97 EAS 47 5/11/98,11/11/97, and 5/6/97 EAS 48 5/3/98,11/11/97, and 8/5/97 EAS 49 8/3/98,2/9/98, and 10/29/97 EAS 50 8/3/98,2/18/98, and 11/4/97 EAS 51 8/3/98,2/9/98, and 5/18/98 EAS 52 8/3/98,2/9/98, and 10/29/97 EAS 53 5/3/98,11/4/97, and 7/29/97 EAS 54 5/11/98,2/3/98, and 8/5/97 EAS 55 5/11/98,2/3/98, and 8/11/97 EAS56 5/3/98,1/20/98, and 11/4/97 EAS 57 5/3/98,10/29/97, and 5/6/97 EAS 58 5/11/98,2/3/98, and 8/11/97 EAS 59 5/11/98,2/3/98, and 8/11/97 EAS 60 5/5/98,11/4/97, and 8/5/97 EAS 61 2/9/98,10/29/97, and 5/27/97 Plant Procedures:

ESP 4.3.1.1 (Revision 18),"Airbome Particulate and lodine Sampling;"

ESP 4.3.1.3.A (Revision 9), " Surface Water Sampling;"

1.MIT-C012-01 (Revision 13), "Climatronics Meteorological Equipment;"

HPP 3110.42 (Revision 0)," Calibration of Eberline RAS-1/ RAP-1 Low Volume Air Sampler;"

PCP 1.2 (Revision 10), "DAEC Chemistry Quality Control Program;"

PCP 1.3 (Revision 6)," Analysis of Chemistry Quality Control Samples;"

PCP 1.4 (Revision 5), " Chemical Equipment Calibration Program;"

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O PCP 1.9 (Revision 14), " Water Chemistry Guidelines;"

PCP 2.1 (Revision 4), " Plant Chemistry Sampling Program Guidelines;"

PCP 2.2 (Revision 0), " Collection of Liquid Grab Samples from Sample Stations and Local Sample Points;"

PCP 2.6 (Revision 4), "Offgas Retreatment and Posttreatment Sampling;"

PCP 2.13 (Revision 9), " Reactor Water Sampling;"

PCP 4.6 (Revision 10), "lon Chromatography - Anions;"

PCP 4.9 (Revision 6)," Metals Analysis - Atomic Absorption;"

PCP 4.31(Revision 0), "lon Chromatography - Anions; '

PCP 6.1 (Revision 4), " General Considerations for Counting Radioactive Samples and Recording Results;"

PCP 6.4 (Revision 2), " Detector Efficiency of Counting Systems;"

PCP 6.5 (Revision 6), " Counting Room Statistics;"

PCP 7.2 (Revision 6)," Nuclear Data Spectroscopy Systems Calibration;"

PCP 7.4 (Revision 5)," Nuclear Measurements Corporation Proportional Counter;"

STP 3.4.6-01 (Revision 0), " Reactor Coolant lodine Activity;" and STP NS770101 (Revision 0)," Reactor Coolant Chloride lon and Conductivity Analysis."

Regulatory Guide 1.21 (Revision 1), " Measuring, Evaluating, and Reporting Radioactivity in j Solid Wastes and Releases of Radioactive Materialin Liquid and Gaseous Effluents From Light-Water-Cooled Nuclear Power Plants," dated June 197 Regulatory Guide 4.15 (Revision 1), "Ouality Assuruce for Radiological Monitoring Programs (Normal Operation)- Effluent Streams and the Environment," dated February 197 Safety Evaluation Form No.98-050, dated May 7,199 UFSAR Change Request initiation, Change No. 98-66, dated May 11,199 l l

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