IR 05000369/1989036

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Insp Repts 50-369/89-36 & 50-370/89-36 on 891023-27. Violations Noted.Major Areas Inspected:Effluent Measurement QC & Confirmatory Measurements Including Review of Count Room Procedures,Instrument QC & Count Room Staffing
ML19332E093
Person / Time
Site: McGuire, Mcguire  
Issue date: 11/24/1989
From: Adamovitz S, Decker T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19332E088 List:
References
50-369-89-36, 50-370-89-36, NUDOCS 8912060223
Download: ML19332E093 (15)


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NUCLEAR HEGULATORY COMMISSION

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REGION 11 g

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101 inCARIETT A STRE ET, N.W.

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ATL # ETA, GEORGI A 180323

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WN 2 71989, w

. Report Nos.:

50-369/89-36 and 50-370/89-36 Licensee: Duke Power Company 42C South Church Street Charlotte, NC 28242 Docket Nos.:

50-369 and 50-370 License Nos.:

NPF-9 and NPF-17 Facility Name:

McGuire 1 and 2 Inspection Conducted: October 23-27, 1989 c/[bf Inspector:J nw<2 2 <* O'

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S. S. Adamovitz

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Date Signed

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Accompanying Personnel:

T. R. Volk Approved by:

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. /7 v// / #f T. R. Decker, Chief Date Signed Radiological Effluents and Chemistry Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards SUMMARY Scope:

This routine, unannounced inspection was conducted in the areas of effluent measurement quality control and confirmatory measurements including review of count room procedures, instrument quality control, and count room stwffing; and comparison of radiological verification results between the licensee and the NRC laboratory facilities.

The inspection also includea a special, review of the incident concerning offsite transport of sanitary sewage sludge.

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Results:

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i The ' licensee's count room performed well in the confirmatory measurements-inspection with 89 percent of the licensee's measurements within 10 percent of NRC values (Paragraph 6).

Sanitary sewage sludge containing low levels of radioactive materials was

' accidentally removed from Duke property.

Since the itcensee had identified

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this problem and committed to appropriate corrective actions, a non-cited l

violation (NCV) was is, sued (Paragraph 7).

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REPORT DETAILS

1.

Persons Contacted Licensee Employees

  • S. Adams, Supervisor, Ccrporate Communicetions
  • N. Atherton, Production Specialist III, Compliance

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G. Barker, Supervising Scientist, Chemistry

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'M. Birch, Technical System Manager

  • J. Boyle, Superintendent Integrated Scheduling (Acting Station Manager)

C. Brown, Scientist, Chemistry

  • B. Byrum, Supervising Scientist, Radiation Protection
  • G. Cryton, Manager, Safety Review Group V. Dame, Radiation Protection Specialist
  • L. Epps, Radiation Protection Specialist
  • J. Foster, Radiation Protection Manager
  • G. Gilbert, Superintendent Technical Services
  • W. Haller, Manager, Nuclear Production Department
  • G. Johnson, Scientist, Radiation Protection
  • R.

Isenhour, Jr., Verification Specialist II

  • C, Lan, Supervising Scientist Radiation Protection
  • S. LeRoy, Production Specialist II, Regulatory Compliance

"T. Mathews, Managar, Desiga Office

  • R. Michael, Chemistry Manager
  • D. Phillips, Environmental Compliance Coordinator
  • H. Sloan, Scientist, Radiation Protection R. Smith, Associate Scientist, Radiation Protection
  • B. Travis, Superintendent Operations
  • 1. Warren. Support Engineer, Regulatory Compliance

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NRC Resident Inspectors

  • T. Cooper
  • K. Van Doorn

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  • Attended exit interview I

2.

Audits (84750)

The inspector reviewed portions of the audits:

NP-88-04(MC) " Health Physics, Environmental', and ODCM Activities," conducted February 15, 1988 to March 10, 1988; and NP-89-06(MC).

" Health Physics, Radwaste,

Environmental, and Quality Assurance Activities," conducted February IS,

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1989 to March 15, 1989. The audits were examined for review of count room activities and had identified several improvement items. These items were

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adequately reviewed and acted upon in a timely manner.

No violations or deviations were identified.

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3.

Procedures (84750)

The inspector reviewed selected portions of the following procedures related to count room activities:

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HP/0/B/1001/11

" Calibration and Quality Assurance of the Automatic

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GM's," October 6, 1989.

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HP/0/B/1001/17, " Calibration and Quality Assurance for Tennelec Alpha / Beta Counting Systems," August 31, 1989.

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HP/0/B/1001/20. " Calibration, Quality Assuranec, and Parameter' Set-up

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for Beckman LS-5800 Series Liquid Scintillation System,"

September 19, 1989.

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HP/0/B/1001/24, " Quality Assurance for ND 9900 Gamma-Ray Spectroscopy

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System," October 6, 1989.

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Radiation Protection Manual (RPM), < Section 7, Radiation Protection

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Administrative Policy. 7.14 "ETQS Interpretation of Standards,"

Revision 8, February 28, 1989.

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RPM, Section 12, " Counting Room and Fixed Instrumentation Operation."

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(1)' 12.2 Operation of Automatic and Manual GM Counting Systems, Revision 10, September 11, 1989.

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(2) 12.3 Operation of. the Tennelec LB 5100 Series II Automatic Alpha / Beta Counting System, Revision 7, August 21, 1988.

(3) 12.8 Quality Assurance and Sample Traceability, Revision 24, June 5, 1989.

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(4) 12.12 Operation of the Beckman LS-5800 Series Liquid Scintillation Counter, Revision 6, August 18, 1989.

(5) _ 12.13 MCA System Hardware and Maintenance, Revision 4, April 18, 1986.

(6) 12.18 Operation of the ND 9900 Gamma Spectroscopy System -

Genie, Revision 5, August 29, 1989.

The procedures. appeared to have been written and approved in accordance i

with Technical Specficiation (TS) requirements.

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No violations or deviations were identified.

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Records (84750)

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The inspector reviewed selected portions of the following records:

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Equipment History Logs. 1988-1989

'(1) Tennelec GM Counters MCHPS-26437 and MCHPS-26341.

(2) Tennelec Alpha / Beta Counting Systems MCHPS-26012 and-l

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MCHPS-26668.

(3) -Beckman Scintillation Counters MCHPS-26470 and MCHPS-26552.

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h (4) Ortec High Purity Germanium Systems' MCHPS-26537, MCHPS-26669,

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MCHPS-26471 and MCHPS-26404.

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Daily Performance and Background Checks, August - October 1989.

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(1) Tennelec Alpha / Beta Counting Systems MCHPS-26012 - alpha only.

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MCHPS-26668 - alpha only.

'(2) Beckman Scintillation Counter MCHPS-26470 and MCHPS-26552.

(3) Ortec High Purity Germanium Systems MCHPS-26537, Detector A; s

MCHPS-26669, Detector B; MCHPS-26471, Detector C; and MCHPS-26404, Detector D.

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Monthly Interlaboratory Crosscheck Results January 1988 - August 1989 for.the following geometries:

(1) Gamma in water, 3.5 liter Marinelli (2) Alpah/ Beta smear-(3) Charcoal cartridge - I-131

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(4) Two inch filter - mixed gamma (5) H-3 in water (6) Body burden analysis - Co-60, Mn-54

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Monthly Intralaboratory Crosschecks. May - September 1989 for the following:

(1) Liquid radioisotopes for the following geometries:

14cc vial 50 mi bottle 1000 mi bottle

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1000 ml Marinelli 3500 ml Marinelli (2) Gross alpha measurements for the automatic GM counters.

(3) H-3 in the Beckman liquid scintillation counters.

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(4) Pu-239 in the Tennelec Alpha / Beta counters.

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L (5): Gaseous radioisotopes for the following geometrics:

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95cc gas bomb 4400cc gas Marinelli o

Particulate filter

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Charcoal cartridge-(6) Crud filter for reactor coolant j

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Efficiency Calibration Data (1989)for the Gamma Spectroscopy Systems

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including the following geometries:

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(1) MCHPS-26537, Detector A

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4400cc gas Marinelli

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i 95cc gas bomb at 3, 6, and 12cm 50 mi liquid bottle at 0, and 3cm

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l 1000 m1 liquid bottle at Ocm

3500 m1 liquid Marinelli -

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!T (2)' MCHPS-26669, Detector B

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Particulate filter at 0 and 3cm

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Charcoal cartridge at 0 and 3cm

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Crud filter at Ocm 14 m1 liquid vial at 0, 3, and 6cm o

1000 ml liquid bottle at Ocm

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(3) MCHPS-26471, Detector C

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Particulate filter 3 and 6 cm 95cc gas bomb.at 12cm

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L 14 m1_ liquid vial at 3cm 50 m1 bottle at 12cm

1000 m1 bottle at 3cm (4) 'MCHPS-26404, Detector D-Particulate filter at 6cm

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95cc gas bomb at 6 and 12cm

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4400cc gas Marinelli

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50 mi at 3 and 6cm 1000 mi bottle at 3cm

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1000 mi liquid Marinelli 3500 ml liquid Marinelli

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The inspector noted that current efficiency calibrations for the _ gamma

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spectroscopy systems were compared to previously determined efficiencies.

Evaluations were performed for differences greater than 10 oorcent for

liquid geometries and 15 percent for gaseous geometries.

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No violations or deviations were identified.

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5.

Quality Assurance Program (84750)

The inspector ' reviewed the licensee's quality assurance program for the

. count room using the guidance contained in Regulatory Guide 4.15 (Quality r

Assurance for Radiological Monitoring Programs (Normal Operations) -

y-Effluent Streams and the Environment -- February 1989)).

L The licensee's organizational structure as it related to the management

and operation of the count room was defined in the site's Radiation L

Protection Manual,Section VII, Radiation Protection Administrative F

Policy. The duties and responsibilities of the various positions were listed and the Employee. Training and Qualification Task list was also included, i'

The qualifications of individuals involved in radiological sampling and

counting activities were specified and documented. The inspector reviewed

Training and Qualification Guides relating to operation of the various count room instrumentation which included:

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Task RP-23 " Operation of MCA/ Germanium Detector" Rev.10, August 29, i

1989.

Task RP-201 " Operation of Body Burden Analysis System "Rev. 7, July 27,1989.

Task HP-203 " Operation of Tennelec LB5100 Series II Gas Flow Proportional Counter" Rev. 7, November 21, 1988.

Task RP-205 " Operation of Beckman LS5800 Liquid Scintillation Systems" Rev. 9, August 18, 1989.

Task RP-209 " Restoration of Power to Countroom Equipment" Rev. 8, May 1, 1989.

The tasks referenced station procedures and specified operations to be

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successfully completed for qualification.

The inspector also reviewed lesson plans for continuing training in count room activities which included instrument trouble shooting, software evaluatiory, data' review and identification of abnormal sample results.

In addition to classroom

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-training, the employee was required to work 10 weeks in the count room and pass a performance evaluation by senior technical staff, The licensee's training program was accredited by INPO.

Currently, daily staffing for the count room included two full-time Radiation Protection (RP) Specialists, two shift technicians who were assigned on a rotating basis, and an RP Scientist for management and overview responsibilities.

A total-of 21 shift personnel and 3 RP Specialists were currently qualified as count room technicians. Four RP personnel were also qualified to perform instrument calibrations..

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The inspector verif ied that written procedures were prepared, reviewed,

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and app *cved for countroom activities according to plant administrative requirements.

The inspector reviewed procedures relating instrument calibration end eseration, data review, report generation, sample traceability, and instrument troubleshooting.

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t The ' licensee had the abilitt to track and control various samples by means of sample record sheets which included assignment of a priority rating for

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immedi tte or delayed analyses.

Quality control records fcr counting systems included the results of measurements of radioactive check sources.

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calibration sources, and hekgrounds.

Daily or shift QC logs were

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maintained and kept next to the appropriate counting system.

The inspector noted that all records reviewed were well organized and easily accessible.

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The licensee's count room quality control program included the use of NBS traceable reference standards to determine counting efficiencies for specific radionuclides and to determine counting efficiency as a function

of gamma-ray energy for gamma instrumentation.

Daily performance checks and background of counting systems were performed and the results of these measurements were recorded in logs and plotted on control charts.

The lictnsee tracked the measurements to ensure that the measured values were

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within "three-sigma" control limits, and the control limits were revised quarterly.

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Inter-and intralaboratory crosschecks were also included in the licensee's QC rrogram. Monthly interlaboratory crosscheck samples were provided by the Duke Power General Office and the licensee used the NRC c-iteria for comparisons of the analytical measurements.

Intralaboratory crosschecks were performed monthly and consisted of a series of samples counted on all available detectors.

No violations or deviations were identified.

6.

Confirmatory Measurements (84750)

During the inspection, reactor coolant and selected liquid and gaseuus samples were sampled by the licensee and analyzed for i sot'opic concentration: using the licensee's gamma spectroscopy systems and the NRC Region 11 mobile laboratory.

The purpose of these comparative measurements was to verify the licensee's capability to accurately measure gamma emitting radienuclide concentrations in various plant systems and i

l effluent streams. Comparisons were made using the licensee's Genie gamma spectroscopy systems (4 out of 4 operational). Sample types and counting

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geometries incluced the following:

reactor coolant system sample - 50ml

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bottle; liquid waste tank - 1000ml Marinelli; and waste gas decay tank -

100cc gas bomb. Spiked charcoal cartridge and particulate filter samples were provided in lieu of licensee samples which did not have sufficient activity for comparisons.

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Compardsons of licensee and NRC results are listed in Attachment I with the acceptance criteria listed in Attachment 2.

Results were in agreement

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for all compared radionuclides in all geometries. The licensee's count

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room performed well-during the irspection with 89 percent of 'the licensee's measuremer.ts within 10 percent of the NRC values, No violations or deviations were identified.

7.

Sanitary Sludge (93702)

On Tuesday, October 24, 1989, the inspector was informed by the licensee of the accidental removal cf dewatered sanitary sewage sludge containing low levels of radioactivity from Duke Power property.

The sludge was removed by vendor personnel and taken to a privately owned landfill which

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was not authorized to receive sanitary sewage or radioactive materials.

t The inspector and licensee discussed the possible cause and the series of

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events which led to the incident.

Typically, on an annual basis, the licensee contracted with a vendor to process the accumulated sludge from the bottom of the sewage treatment syst em.

The licensee would first sample and count the sludge for radioactive materials.

Processing consisted of the addition of a flocculant, sludge dewatering, and a final addition of lime.

The processed sludge would then be taken by vendor personnel to the McGuire onsite landfarming area for final deposition. McGuire had obtained the necessary state permits for the landfarm and had successfully performed disposal operations during 1987 and 1988.

The following sequence of events was obtained from anformation provided by the licensee:

Sequence of events:

October 9, 1989 Vendor arrived onsite at McGuire (Monday)

October 11, 1989 Vendor began processing sludge (Wednesday)

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October 16, 1989 Vendor completed sludge processing and left the (Monday)

site. Two dumpsters remained at McGuire - one held approximately 15 cubic yards (11 tons) of processed sludge and the other dumpster was empty.

The filled dumpster was lined, covered by a tarpaulen and held on

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the owner controlled property.

The vendor indicated that a subcontractor would remove the empty dumpster.

October 17, 1989 McGuire Radiation Protection (RP) personnel performed

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a release survey of the processing equipment and the l

filled dumpster.

Reported radiation levels were 3 to 6 microR/hr (background levels).

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i October 18, 1989 The subcontractor contacted McGuire to obtain a (Wednesday)

purchase order (PO) number for removal of the empty dumpster. McGuire personnel provided the PO number

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s and requested the name of a contact in order to make

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l arrangements for transport of the filled dumpster to l

the McGuire landfill. A contact name was provided by

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the subcontractor.

L October 20, 1989 The subcontractor mistakenly removed the half full

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(Friday)

dumpster from the McGuire site and transported it to a prfvate landfill.

Licensee representatives indicated that the driver's papers specified removal of the empty dumpster.

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October 23, 1989 McGuire personnel discovered that the half full (Monday afternoon) dumpster was missing from licensee property.

The NRC resident inspector was informed.

October 24, 1989 State personnel and the RII inspector were informed (Tuesday)

of the incident. McGuire RP personnel were dispatched to the private landfill to assess the situation. A meeting was held onsite with the State, NRC and Duke Power personnel to provide information.

On October 24, 1989, the licensee dispatched Radiation Protection (RP)

personnel to the private landfill to attempt to determine the exact location of the sludge and perform surveys.

The RP personnel indicated that the sludge had since been covered with other debris and that the location could not be identified.

Radiation surveys were not performed since release surveys of the dumpster showed only background levels of radiation.

The inspector reviewed isotopic analyses of the pre-processed sludge performed August 8, 1989, The analyses showed concentrations of 1.6E-7 uC1/ce, Co-60; 4.3E-8 uC1/ce, Cs-137; and 5.4E-8 uCi/cc Co-58. The licensee calculated that a total of 2.6 microcuries of radioactive material was present in the processed sludge and that the estimated dose to the general public was less than 0.4 mrem / year. The inspector informed licensee management that failure to prevent unauthorized removal of licensed materials from the place of storage was an apparent violation of 10 CFR 20,207.

The inspector and licensee discussed corc'ctive measures to prevent recurrence of the incident and toured the onsite sewage treatment area and the initial holdup pond (IHP) of the routine water treatment facility.

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Proposed corrective actions included the construction of vehicle barriers to the sanitary sewage pand and the IHP to prevent removal of equipment during dewatering and to attach an informational sign during sludge processing specifying the reason that the vehicle barrier was locked.

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During the exit meeting conducted October 27, 1989, the inspector requetted that a firm date be established for the installation of the

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vehicle barriers; that sludge not be processed until the barriers had been installed; and that an informational sign be posted during processing.

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Acting Station Manager, Mr. J. Boyle, committed to a completion date of c

January 31, 1990 for these actions.

Since the licensee had-identified i

this problem and committed to appropriate corrective actions, a

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licensee-identified noncited violation (NCV) would be identified.

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criteria specified in Section V.G.1 of the NRC Enforcement Policy were

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satisfied (NCV 50-369; 310/89-36-01). Additionally no response would be required since the licensee had committed to corrective actions with a

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timely due date.

On October 27, 1989, subsequent to the exit meeting, licensee personnel informed the RII inspector that the subcontractor had excavated the sludge and v;as holding it at the private landfill.

The subcontractor had

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apparently performed this excavation on their own initiative and the

action was not prompted by Duke Power or the State of North Carolina. The subcontractor had removed the original 11 tons of sludge plus an

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additional five-tons of other debris collected by the removal process.

The subcontractor was holding the sludge at the private landfill until a

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decision could be reached for disposal.

On October 30, 1989, the RII ins ctor contacted the licensee for further information. The State had granted the subcontractor a variance to allow disposal of the slightly radioactively contaminated sanitary sewage sludge at the private landfill.

The subcontractor planned to return the sludge to the landfill.

One NCV was issued.

8.

Exit Interview The. inspection scope and results were summarized on October 27, 1989, with those persons indicated in paragraph 1.

The inspector described the areas inspected and discussed in detail the inspection results listed below.

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Proprietary information is not contained in this report.

Dissenting comments were not received from the licensee. The licensee's count room l-performed well in the confirmatory measurements inspection with 89 percent l

of the licensee's measurements within 10 percent of NRC values

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(Paragraph 6).

Court rooms quality assurance was clearly defined-(Paragraph 5), and records and procedures were easily accessible and

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complete (Paragraphs 3 and 4).

L Sanitary sewage sludge containing low levels of radioactive material was accidentally removed from Duke property.

Since the licensee had i

identified this problem and committed to appropriate corrective action, a o

NCV was issued (Paragraph 7).

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ATTACHMENT 1-

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NRC-LICENSEE SAMPLE COMPARISON EVALUATIONS AT THE MCGUIRE NUCLE 4R POWER PLANT SAMPLE ISOTOPE LICENSEE CONCENTRATIONS RESOLU T 109'

RATIO COMPARISON ~

CONCENTRATIONS NRC 1.

Reactor Coolant Kr-85m 1.03E-2 1.0210.01E-2 102 1.01

. Agreement -

50ml Bottle Kr-87 1.83C-2 1.8510.03E-2

0.99 Ag reement McCulre Kr-88 2.51E-2 2.4910.03E-2

1.01 Ag reement Detector A Xe-133 9.19E-2 8.9110.02E-2

. >200 1.03 Agreement.

Xe-135 1.00E-1 1.07t0.002E-1

>200 0.93 Ag reement Os-134 1.50E-3 1.4810.05E-3

1.01 Ag reement Cs-137 1.63E-3 1.6210.05E-3

1.01

- Agreement Cs-138 6.89E-2 7.2510.20E-2,

0.95 Agreement Reactor Coolant Kr-85m 9.95E-3 1.02iO.01E-2 102 0.98 Ag reement 50ml Bottle K r-87 1.86E-2 1.8510.030-2

1.01 Agreement McGuire K r-88 2.38E-2 2.49fo.03E-2

0.96 Ag reement Detector D Xe-133 8.75E-2 P.9110.02E-2

>200 0.98 Ag reement Xe-135

'9.83E-2 1.0710.002E-1

>200 0.92 Agreement Cs-134 1.43E-3 1.4.810.05E-3

0.97 Ag reement Cs-137 1.66E-3 1.6210.05E-3

1.02 Ag reement Cs-138 6.91E-2 7.2510.20E-2

0.95 Ag reement Reactor Coolant Kr-85M 1.01E-2 1.0210.01E-2 102 0.99 Agreement 50ml Dottle K r-87 1.75E-2 1.85io.03E-2

0.95 Ag reement McGuire Kr-88 2.45E-2 2.49i0.03E-2

0.98 Ag reement Detector C Xe-133 8.61E-2 8.9110.02E-2

>200 0.97 Agreement Xe-135 1.01E-1 1.0710.002E-1

>200 0.94 Ag reement Cs-134 1. 4 f4 E-3 '

1.4810.0$E-3

0.97 Agreement CS-137 1.68E-3 1.6210.05E-3

1.04

. Agreement Cs-138 7.93E-2 7.25io.20E-2

1.09 Ag reement ideactor Coolant Kr-85M 1.OOE-2 1.02iO.01E-2 102 0.98 Agreement 50ml Bottle K r-8 7 1.66E-2 1.8510.03E-2

0.90 Agreement McGuire Kr-88 2.41E-2 2.49io.03E-2

0.97 Agreement Detector D Xe-133 8.35E-2 8.9110.02E-2

>200 0.94 Ag reement Xe-135 9.95E-1 1.07to.002E-1

>200 0.93 Ag reemen t.

Cs-134 1.54E-3 1.4810.05E-3

1.04 Ag reement Cs-137 1.73E-3 1.6210.05E-3

1.07 Agreement Cs-138 8.56E-2 7.2510.20E-2

1.18 Agreement

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P 2r.Ws2t3 Monitar Cr-51 5.58E-5 5.5810.36E-5.

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Agreement'

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18 i te r Ma rine i I i_ Co-58 ~

2.53E-5 2.5010.08E-5

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Mn-54

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1.39E-4-1.3510.01E-4 135 1.03

- Ag reement /

McGuire,

Co-60.

2.44E-4 2.4710.02E-4

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Ag reement

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Detector A Zr-95 8.99E-6-1.1010.10E-5

0.82 Agreement-Ag-110m 2.00E-5 1.83fD.06E-5

1.09-Ag reement Co-57-1.69E-6 1.9010.26E-6-7'

.0.89 Agreement Nb-95 2.18E-5 2.3210.08E-5'

29-0.94 Ag reement Sb-125 1.82E-5 1.7910.13E-5__

1.02

, Agreement -

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Waste Monitor C r-51 5.35E-5

.5.5810.36E-5-

0.96,

Agreement Tank B Mn-54 2.34E-5 2.30iO.08E-5

1.02.

Agreement

.11 i te r Ma ri ne l l i Co-58 1.39E-4 1.3510.0fE-4-135 1.03

- Agreement McGuire Co-60 2.45E-4 2.4710.02E-4 124 0.99 Agreement Detector B Z r-95 9.48E-6 1.10io.10E-5-

0.86 Agreement Ag-110m 2.05E-5 1.8310.06E-5

1.12.

Agreement Co-57 1.36E-6 1.9010.26E-6-7 0.72 Ag reement Nb-95 2.33E-5 2.3210.08E-5

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Agreement-Sb-125 1.82E-3 S.7910.13E-5

1.02 Ag reement waste Monitor Cr-51 5.65E-5 5.5810.36E-5

1.01 Ag reement Tank B Mn-54 2.50E-5 2.3010.08E-5 29-1.09 Agreement 18 i te r Ma r i ne l l i Co-58 1.40E-4 1.3510.01E-4 135 1.04

. Agreement McCulre Co-60 2.49E-4 2.47io.02E-4 124-1.01 Agreement Detector C Z r-95 1.06E-5 1.10io.10E-5-

0.96 Ag reement Ag-110m 2.t6E-5 1.8310.06E-5

1.18 Agreement Co-57 1.30E-6 1.90f0.26E-6

0.68 Ag reement Nb-95 2.36E-5 2.3210.08E-5

1.02 Agreement Sb-125 1.83E-5 1.7910.13E-5

'1.02 Ag reement Waste Monitor C r-51 5.91E-5 5.58to.36E-5 16 '

1 06 Agreement Tank B Mn-54 2.40E-5 2.3010.08E-5

1.04 Agreement 11 i te r Ma rinel I i Co-58 1.38E-4 1.3510.01E-4 135 1.02 Agreement McGuire Co-60 2.40E-4 2.4710.02E-4 124 0.97

. Agreement Detector D Z r-95 1.03E-5 1.1010.10E-5

0.94 Agreement Ag-110m 2.02E-5 1.8310.06E-5

1.10-Ag reement 1.f7E-6 1.9010.26E-6

0.77 Ag reement Co-57 t

Nb-95 2.25E-5 2.3210.08E-5

0.97 Ag reement Sb-125 1.85E-5 1.7910.13E-5

1.03 Agreement-3.

Waste Gas K r-85m 6.81E-3 6.9210.12E-3

0.98 Agreement Decay Tank K r-87 1.72E-3 1.3110.13E-3

1.31 Agreement 100cc Gas Bomb Kr-88 8.36E-3 7.9010.28E-3

-1.06 Agreement McGuire Xe-133m 2.30E-2 2.1910.05E-2 47s 1.05 Agreement Oetector A Xe-133 1.13E0 1.2710.001E0

>200 0.89 Agreement Xe-135 9.92E-2 1.03fo.002E-1

>200 0.95 Agreement

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1.07 Aghtement Detector D Xe-133 1.20E0 1.2710.001EO

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0.98 Ag reement NRC Spike Co-57 1.54E-3 1.4610.06E-3

1.05 Ag reement LQ 014D Y-88 8. 85 E-4 8.38i1.19E-4

1.06 Ag reement hcGuire Cs-137 4.11E-2 3.9210.04E-2

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ATTACHMENT 2

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CRITERIA FOR COMPARISONS OF ANALYTICAL MEASUREMENTS

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This enclosure provides criteria for the comparison of results of analytical

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radioactivity measurements.

These criteria are based on empi rical.

relationships' which combine-prior experience in comparing radioactivity analyses, the measurement of the statistically random process of radioactive

'

emission, and the accuracy needs of this program.

In these criteria, the " Comparison Ratio limits"1 denoting agreement or-disagreement between licensee and NRC results are variable. This variability

.is. a function-of the ration of the NRC's analytical value relative to its associated statistical and analytical uncertainty, referred to in this program.

-as " Resolution"8 For comparison purposes, ratio between the licensee's analytical value and the LNRC's analytical value is computed for each radionuclide present. in a given sample. -The computer ratios are then evaluated for-agreement or disagreement F

based ' on. " Resolution."

The corresponding values for " Resolution" and the

" Comparison Ratio Limits" are listed in the tabic below.

Ratio values which are either above or below the " Comparison Ratio Limits" are considered to be in disagreement, while ratio values within-or encompassed by the " Comparison Ration Limits" are considered to be in agreement.

.

TABLE NRC Confirmatory Measurements Acceptance Criteria Resolution vs. Comparison Ratio Limits

,

Comparison Ratio Limits:

Resolution for Agreement

<4 0.4 - 2.5 4-7 0.5 - 2.0 8 - 15 0.6 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.60 - 1.25

-

-

>200 0.85 - 1.18 2 Comparison Ratio = License Value NRC Reference Value 2 Resolution = NRC Reference Value Associated Uncertainty