ML20055D683
| ML20055D683 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/29/1986 |
| From: | Meeks R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20055C226 | List:
|
| References | |
| FOIA-90-76 NUDOCS 9007090287 | |
| Download: ML20055D683 (37) | |
Text
{{#Wiki_filter:j# UNITE D $T ATE $ + E. NUCLEAR REGULATORY COMMISSION s; E OFFICE OF INVtSTIGATioNS FitLD OFFICE, RtGtON V ? / 1460 MARIA LANE. SUITE 210 WALNUT CREEK. CALIFORNIA M6K December 29, 1986 MEMORANDUM TO: 05-86-010 FROP: Ronald A. Meeks, Senior Investicator b Office of Investigations Field Dffice, Region V
SUBJECT:
UPGRADE ON INQlllRY TO INVESTIGATION The Sacramento Municipal litility District (SMUD) responded On December 2, 1986 to a July 10,1986 01:RV request for infomation of Rancho Seco's liquid F;f'luents prograr.. A revin: of the response by OI:RY indicates a need to broeden the scope e' this case, Consequently, this inquiry is upgraded to f s 1 invest 40ation b-80-010, cc: J. SinclM r. 01:HO I I l l t ( ,y',,
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SUMMARY
OF INTERVIEW TRANSCRIPT WITH GREGORY P. YUHAS Date Interviewed: January 15, 1987 Date of Summary: January 21, 1987 Gregory P. YUHAS, the NRC Region V Chief of the Nilities Radiological Protection Section, was interviewed by Office of Invesdations Senior Investigator Ronald A. Meeks, regarding Yuhas' knowledge of the Sacramento Municipal Utility District's (SMUD) management and operations of the liquid effluent release at the Rancho Seco Nuclear Generating Station (Rancho Seco). Specifically, YDHAS was interviewed concerning the inspection he conducted of the effluents program at Rancho Seco which was recorded in his June 6, 1986, Inspection Report, number 50-312/86-15 The information listed below is a summary of the interview transcript. Procedures Concernino Liquid Effluents 1. Rancho Seco Technical Specification 4.21.1 requires all radioactive peaks identified in the analysis for radioactivity to be reported in the Semi-annual. Effluent Reports (pp 36-37). 2. Technical Specification Table 4.21-1 requires the Reactor Holdup Tanks (RHUT) to have samples removed for composite analysis for all releases. SMUD only removed samples for composite analysis when the RHUT showed radioactivity (pp 42,57-58). 3. Releases of water are authorized when the system's storage tanks are at capacity if there is compliance with Technical Specification requirements on concentration and dose limits (p 50). 4 procedure AP305-13, Rev.16 - Environmental Releases of Liquid Radio-activity, Section 3.1, gives Rancho Seco's plant operations the authority to release effluents (p 51), a. Sampling of the Demineralized Reactor Coolant Storage Tank (DRCST) water is required before transfer to RHUT (p 52), b. Sample analysis of water in the DRCST before transfer and dilution of the water in the RHUT maintains the integrity of detecting radionuclide peaks in the DRCST water (p 57). Management of the Liquid Effluents Program l 1. Officials involved in the review of the bases of Technical Specification 4.21.1 used check sheets to assure that the word "not" in the second sentence of the opening paragraph of the bases was not removed. The insertion and maintaining of the word "not" in the bases of this Technical Specification indicated that SMUD officials did not intend for Rancho Seco to be in compliance with the dose objectives of 10 CFR 50, g.p oto o7F
't Appendix 1. The bases of Technical Specification 4.21.1 originated in the 1976 - 1978 time f rame (pp 3-8). 2. Ed BRADLEY, SMUD's Supervising Health Physicist, identified to his supervisors in early 1985 the fact that Rancho Seco's Technical Specification 3.17.2, ceiling for a lower limit of detection value (LLD) of SE-7 was not sufficient for Rancho Seco to *ssure compliance with the dose objectives of 10 CFR 50, Appendix I (pp 10-11). 3. SMUD's Executives, Ronald J. RODRIGUEZ, the then Assistant General Manager, Nuclear; Roger POWERS, the Managcr of Nuclear Engineering and George COWARD, the Rancho Seco Plant Operations Manager, did not inform, in 1985, the Radiation Protection and Chemistry Managers that Rancho Seco's Technical Specification LLD values were not s'.'ficient to assure compliance with Appendix ! dose objectives (pp 9-17). 4 Af ter BRADLEY identified in writing the LLD issue in his draft LLD Report in October 1985 and his subsequent December 16, 1985 memo to POWERS concerning compliance with 10 CFR 50, Apper.Jix I, RODRIGUEZ discussed the issue with COWARD. COWARD then, in a discussion with KELLIE, the Radiation Protection Superintendent, concluded that the Technical Specification LLD value at Rancho Seco was sufficient (pp 37-38). 5. Steve MANOFSKY, a Senior Chemist and Radiation Assistant, and KELLIE did not concur with the composite sampling data conducted by Controls for Environmental Protection (CEP) for 1985 Consequently, BRADLEY was not furnished with the CEP data which would have allowed him to conduct the appropriate Appendix I dose calculations for 1985 and which would have reflected possible non-compliance with Appendix I (p 40). Rancho Seco Plant Confiourations 1. Repeated heatups in a short period of time in the primary system causes the system to reject large volumes of water as does system leaks and flushes (p24), 2. From June 12-16, there were daily releases from the DRCST to the RHUT Tanks. The releases for these days total 80,000 gallons. Total release from DRCST to the RHUTs in 1985 total 787,500 gallons (pp26-27). 3. With the Rancho Seco steam generator tube leaks, the excess water in the secondary system is recycled through the Radwaste Treatment System causing the condensates to become contaminated and the Radwaste processing and storage system to become overloaded (pp 49-50). Effluent Reports to the NRC 1. The Effluent Report of September 26, 1986, does not show the peaks identified in releases 85-98, 85-99 and 85-110 because a lower counting time precluded the identification of peaks prevalent in the longer i counting times (pp 3-6). l l 5-86-010 2 l n
,e r l 2. Special Report 84-07 dated September 27, 1984, indicated that the steam generator tube leaks dealt with a flow path involving exclusively the l contamination of the secondary ~ system resulting in trace quantities of isotopes released to the environment. Inspection Report 86-15 reveals that 84-07 did not include the illegal flow paths concerning the primary-l system that were in existence at the time of 84-07 (pp 45-48). 3. - Based on Rancho Seco's commitments and short and long term operational plans contained in 84-07, NRR decided that a variance for continued operation was not necessary with respect to excessive radioactive liquid effluents releases for the years 1981,1983and1984(p64). 4 The Semi-annual Radioactive Effluent Report for the first half of 1985 indicates compliance with the dose objectives of Appendix I, as called forinReport84-07(pp64-65). 5. Contrary to the information in 84-07, the operations personnel required to implement a good deal of the measures to assure greater focus on compliance with Rancho Seco's Technical Specifications, were not aware L of Special Report 84-07 or its contents requiring their increase in i performance and attention to liquid effluents releases (p 65), 6. Any indication of non-compliance to provisions of 84-07 would indicate a breakdown in the management of the liquid effluents program, requiring: I a. NRR to revisit the variance issue as it relates to the competence L and.integrityofmanagement(pp65). b. A Technical Specification change which would delay pending startup in the fall of 1985 and possibly require public hearings on an l issue that had already received increased media attention and had resulted in legal suits against SMUD (pp 66-67), c.- Possible physical construction to implement the short and long term provisions of 84-07 requiring expenditure of additional financial manpower and time expenditures resources, i.e., the construction of evaporator ponds -(pp 67-68).
- 7. -
In 1985, BRADLEY informed POWERS and RODRIGUEZ that Rancho Seco's LLD requirements were not sufficient to assure compliance with the dose objectives of Appendix I, thus contrasting directly with the commitments previously offered by RODRIGUEZ in 84-07 (pp 65-66)-. 5-86-010 3
y ~ 1 ^ SACRAMEliTO MUlilCIPAL UTILITY DISTRICT OFFICE MEMORANDUM January 5, 1987 To: Ray Ashley. DAT E: Greg Cranston ~. JEW B7-003 l. Y# gh .p- 'FROM: oh E'. Ward ONGOING OI INVESTIGATIONS I SUBJECT; 9 Ron Meeks (OI) called today to ask these questions: 1. Have we received the OI letter asking for more information on the liquid effluent question?. 2. When will they receive this additional information? 3. When will our two investigations or the ,CRTS/ Cable routing question be completed? NArig ACTION Ray Ashley Plchse provide ne with an answer to 1&2 above. Greg Cranston Provide me with an answer to #3 as regards to.the NED Investigation. ' Jerry Langer Provide me with an answer to $3 as regards to the Security . investigation. Due date for all answers is January 15. cc: K. Perkins-G. Coward B. Croley -R. Moore v 4 I ( =--H..OlO-02(c.
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SUMMARY
OF INTERVIEW TRANSCRIPT WITH GREGORY P YUHAS Date Interviewed: . January 20, 1987 Date of Summary: February 3, 1987 Gregory P. YUHAS, the NRC Region V Chief of the Facilities Radiological Protection Section, was interviewed by Office of Investigations' Senior Investigator, Ronald A. Meeks, relevant to his knowledge on the Sacramento Municipal Utility District's (SMUD) Management and Operations of the Liquid Effluents Release Program at the Rancho Seco Nuclear Generating Station (RanchoSeco). Specifically, YUHAS was interviewed concerning the inspection he conducted of the effluents program at Rancho Seco which was recorded in his June 6, 1986, Inspection Report No. 50-312/86-15. The information listed below is a summary of the interview transcript. Procedures Concerning liquid Effluents 1. On December 7,1982, a temporary change to procedure A-29, Waste Water Disposal System, was implemented allowing radioactive water to be pumped from the Demineralized Reactor Coolant Storage Tank (DRCST) to Reactor Holdup Tank A or B (RHUT) (pp 5-7). 2. Technical Specification 6.8.3 explains who has responsibility on procedure changes and requirements for review of the procedure changes by the Plant Review Committee (PRC) (pp 6, 10), 3. A temporary change to Procedure A-10 on January 6,1986, which involved in the transfer of water from the DRCST to the RHUT did not receive a PRC review contrary to Technical Specification 6.8.3 (pp 8-14). 4 Technical Specification 6.9.3 - Monthly Reports - requires per 10 CFR 50.59b, Reports of Facility Changes Involving 50.59 Safety Evaluations (pp19-20). 5. COLOMB0 stated in the NRC June 20, 1986, Enforcement Conference that he was not aware that Rancho Seco Technical Specification Lower Limits of Detection (LLD) would not assure compliance with 10 CFR 50, Appendix I, Dose Objectives, with respect to the word "not" and the bases of Technical Specification 4.21-1 (p 31). 6. Rancho Seco officials admitted that the word "not" in the Technical Specification Table Bases 4.21-1 was inserted because Rancho Seco was not designed to meet the dose objectives of 10 CFR 50, Appendix I (p 32). Manaoement of the liquid Effluents Program 1. COLOMB0 signed off on the 50.59 screening sheet on the Temporary Change to Procedure A-10 indicating that the PRC was not required to review the 5-86-010 1 %% cno-07'l
i 11 .o t i i procedure change. This is contrary to the requirements of Technical Specification 6.8.3 (pp 8-19). 2. Fred KELLY and Carl STEPHENSON told YUHAS that weekly surveillances of the DRCST tank were not conducted as required by Technical Specification 3.17.3, which assures 10 curie limits (pp 20-22). 3. The I&E circular 80-18, dated August 22, 1980, concerning 10 CFR 50.59, Safety Evaluations for Changes to Radioactive Waste Treatment Systems requires licensee's to obtain Commission approval if the 50.59 Safety Evaluation indicates a departure from the evaluation criteria presented in I&E 80-18 (pp 23-25). 4 The plant superintendent at Rancho Seco is responsible for transfer of water from the DRCST to the RHUT. The Radiation Protection and Chemistry Group is responsible for sampling the DRCST water and determining the amount of water involved in the transfer and transferring their data to Corporate Health Physics. Corporate Health Physics then determines compliance with the.various environmental technical specifications (pp 25-26). 5. Roger MILLER was the Chemistry and Radiation Protection Superintendent 'during the first hal.f of 1985. At the time of the inspection of 86-15, MILLER was the Acting Chemistry Supervisor (p 29). 6. . Fred KELLIE and Steve MANOFSKY told YUHAS that as long as the water sample analysis met Rancho Seco's-Technical Specification on LLD, then the counting time could be altered. KELLIE and PANOFSKY passed the same instruction on to the chemist who conducted the analysis of water samples (pp37-38). 7. Bill WILSON also related to the chemist that it was OK to alter the countingtime(p42). Effluent Reports to the NRC 1. 8RADLEY, POWERS, C0 WARD and KELLIE were all aware that-Rancho Seco's LLD would not assure compliance with Technical Specification 3.17.2 dose objectives when the Semi-Annual Effluent Releast Report of March 30,1986, was issued (pp 26-27). 2. KELLIE and MAN 0FSKY were aware that radioactive peaks were identified in analysis for radioactivity of the RHUTs but that these peaks were not reported in a Semi-Annual Effluent Release Repret of March 30, 1986. This is contrary to the requirements of footnote c of Technical Specification Table 4.21.1 (pp 26-27). 3. KELLIE and MAN 0FSKY were in receipt of the CEP data (p 26). 4. KELLIE reviewed the Semi-Annual Effluent Report of Septemb6r 1985 which reported that there were no detectable fission or activation products. This is contrary to KELLIE's knowledge that there were identifiable peaks detected-(p 28). 5-86-010 2
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SUMMARY
OF INTERVIEW TRANSCRIPT WITH EDWARD W. BRADLEY Date Interviewed: January 26, 1987 Date of Summary: February 4, 1987 OI:RV Case Number: 5-86-010 Edward W. BRADLEY, the Supervising Health Physicist for the Sacramento Municipal Utility District (SMUD), was interviewed by Office of Investigations' Senior Investigator, Ronald A. Meeks, regarding BRADLEY's knowledge of SMUD's management and operations of the Liquid Effluents Release Program at the Rancho Seco Nuclear Generating Station (Rancho Seco). Specifically, BRADLEY was interviewed concerning his December 16, 1985, memorandum concerning Rancho Seco's radioactive source term definition and Rancho Seco's Technical Specificatier, on the Lower Limits of Detection (LLD). ihe information listed below is a summary of the interview transcript. Procedures Concerning Liquid Effluents 1. The 10 CFR 50, Appendix I dose objectives are the calculated values of radiological exposure off site. These calculations are depended upon the environmentel values described in the Offsite Dose Calculation Manual (ODCM) which are subject to change in accordance with the Annual Land Use Census and the information gathered in the Environmental Program (pp 47-48). 2. After the issuance of NRC Inspection Report 50-312/86-15, BRADLEY was told that the temporary modification from the DRCST to the RHUT did not need a 50.59 cvaluation because the modification was done under temporary procedure change (pp 61-62). 3. No one from Health Physics is on the Plant Review Comittee (p 65). Itanagement of the liquid Effluents Program 1. BRADLEY informed his supervisor Roger POWERS in January 1985 that Rancho Seco's Technical Specification LLD might not assure compliance with Technical Specification 3.17.2. BRADLEY told POWERS he was going to study this issue and POWERS indicated he did not want BRADLEY to do such because it might expose a deficiency in the effluents program (pp 4-8 and 12). 2. Lee KEILMAN, the Manager of Nuclear Engineering for SMUD in 1984, reduced BRADLEY's staff in early 1984 With the increased emphasis and focus on effluents and effluent reporting to NRC in 1984, BRADLEY.'s staff did not increase (pp 11-12). 3. In July 1985, BRADLEY submitted a draft LLD study to POWERS. Several months passed with no definitive word from POWERS other than various coments about the report itself. Therefore, on October 29, 1985, s-% cto-010
+ BRADLEY sent the draft LLD study to KAPLIN, KELLIE, BROWN, and COLOMB0 in order to derive some definitive action on the matter (pp 14-17). 4. BRADLEY told RODRIGUEZ that he would hold up publishing the draft LLD study until after the high point vent break issue was resolved and RODRIGUEZ concurred with this. The high soint vent break matter resolution was delayed so BRADLEY issued iis October 29, 1985, draft LLD study (pp 17-19). 5. In 1984, BRADLEY pointed out calculational errors concerning the conversation of effluent curies to off site dose which directly related to information published in the Semi-Annual Reports to NRC (p 21). 6.. KEILMAN directed Don MARTIN to review BRADLEY's work on the calculational errors and also hired contractors from Bechtel, Stone and Webster,- Babcock and Wilcox to also review the same. All confirmed BRADLEY's work-(p 22). 7. After the calculation error issue BRADLEY's jeb classification was downgraded KEILMAN told BRADLEY his moral and ethical standards were possibly too high. KEILMAN suggested to BRADLEY that he needed to compromise his standards if he were to remain employed by SMUD (p 22). 8. In late December 1985, BRADLEY informed POWERS that KELLIE had been altering the counting times on the analysis of water in the RHUT. This information was passed on to KELLIE's supervisor, COWAxu, through KEILMAN and RODRIGUEZ. COWARD and KELLIE discussed the. issue and decided that as long as the LLD was within the Technical Specification, then altering of the counting time could be made. RODRIGUEZ and POWERS concurred with this stance (pp 24-28). 9. COLOMB0 told BRADLEY that the word "not" was inserted into the bases of Technical Specification 4.21.1 to show that Rancho Seco could not meet Appendix I dose objectives (pp 30-32). 10. In late December 1985, KE'. LIE justified to COWARD the alteration of counting time by means of the procedure change that was conducted in early 1985 which supported the alteration. This was also supported by RODRIGUEZ and POWER in late December 1985 (pp 33-45).
- 11. When RODRIGUEZ etal accepted KELLIE's explanation of the alteration of counting time, there was no further action by management to pursue BRADLEY's LLD issue (pp 44-45).
- 12. With respect to Item 4 in BRADLEY's December 16, 1985, memo concerning other possible sources of radioactivity contributing to recorded activity in the retention basin, POWERS told BRADLEY that there was no need to study this issue because past studies were adequate on this matter and there was no need to go back and reevaluate the issue (pp 57-58).
Rancho Seco Plant Configuration Rancho Seco has done a safety evaluation for permanent modification allowing transfer of water from the DRCST to the RHUT. The safety evaluation was 5-86-010 2
deficient in that data on nuclides other then tritium were not considered or identified in the safety evaluation. The evaluation was also deficient in that it reported that the 10 curie tank limit would be in compliance with 10 CFR 50, Appendix I when in fact the 10 curie refers to 10 CFR 20. BRADLEY wrote an onsite description report on these deficiencies and the evaluation in December 1986 and a reevaluation is being done on the safety analysis (pp 62-64). Effluent Reports to the NRC Through SMUD's analysis of the CEP data, the issued Special Report 86-08 was issued in June 1986 stating that Rancho Seco had exceeded 10 CFR Appendix I limits in 1985 as pointed out in NRC Inspection Report 86-15 (pp 46-47). Lawrence Livermore National Laboratory (LLNL) Effluents etelease Analysis 1. A 1985 LLNL analysis of Rancho Seco water released to the environment indicated that there was too much radiocesium in the stream pathway for the amount of residual radiocesium analyzed in the sediments of the streart bed which had been quantified at an earlier date (p 54). 2. The 1.LNL Analysis contradicted Rancho Seco Semi Annual Report of negative releases (p 155). 3. During the week of October 14, 1985, BRADLEY, because of LLNL's conclusions on the offsite effluent stream pathways had samples taken from the RHUTs and the retentie basis for LLNL analysis. That analysis showed activity of mancane n 54, cobalt 60 and Cesium 134 and 137. This fact served as the b is for BRADLEY's December 16, 1985, memo to POWERS (pp 54-55). American Nuclear Insurers (ANI) Audit of Rancho Seco's Effluents Proaram ANI's March 25-26, 1986, audit of Rancho Seco's Liquid Effluents, ODCM, Technical Specifications, Radiological and Environmental Monitoring Program and Management Controls and Control Procedures, reached the same conclusion as BRADLEY concernine Rancho Seco's LLD's, (pp 52-53). 5-86-010 3
p. ^ i l' it! a r E I h BRIEFING FOR MR HAYES ON THE SACRAMENTO MUNICIPAL E UTILITY DISTRICT'S RANCHO SECO NUCLEAR GENERATING STATION LIQUID EFFLUENTS PROGRAM E 01:RV Case 5-86-010 February 26, 1987 K ~ F M m m B -m
. ;r The; Rancho Seco Nuclear Genercting Station: Liquid:r.ffluents Program Introduction THE SMUD LIQUID EFFLUENTS PROGRAM MANAGEYddT ORGANIZATION TliE NRC REGULATORY REQUIREMENTS Details
Background
Rancho Seco Radiological and Environmental Technical Specifications-Modification to Rancho Seco's Primary Water System Alteration of Rancho Seco's Radionuclide Analysis Counting Time The Insufficiency of Rancho Seco's Lower Limits of Detection Technical Specification SMUD's acknowledgement of Effluent Release Program Errors. Summation-
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=. NRC REGULATORY REQUIREMENTS sv.h 10 CFR 96e Technical Specifications required demonstrating adherence to 10 CFR 20.106 and 10 CFR 50 Appendix.I-limits. - Semi Annual Effluent Reports are required reporting the amount of liquid effluents released to the environment - All information which allows NRC to estimate the maximum annual radiation doses shall be reported in the semi annual reports. 10 CFR 20.106 The EPA standard.for Nuclear Plant Operations - 40 CFR-190/ annual dose of less than 25 mrem to an individual-shall not be exceeded by effluent releases to the public. If the cause of the excess releases is temporary and corrective action has been taken, a variance for continued operation can be granted by NRC. 10 CFR 50 Appendix ! Requires the estimated annual dose from radioactive material released in liquid effluents not to exceed 3 mrem to the body and 10 mrem to any organ. - The licensee is required to establish a surveillance and monitoring program in order to provide data on liquid releases. - The licensee is required to identify changes in the unrestricted areas in order to permit modifications to the monitoring programs that estimate doses to individuals 10 CFR 20.405 Requires licensee to file a report to the Region within" 30 days if releases of radionuclides are in excess of the EPA standard of 40 CFR 190. - The report should describe the cause of the excess releases and corrective action taken and - the extent of exposure to the. individual. 10 CFR 50.71 Requires the licensee to annually update the Final Safety Analysis Report so that the NRC is aware of changes made to the facility. 10.CFR 50.59 Requires the licensee to make a safety evaluation for proposed changes to the facility as described in the Final Safety Analysis Report when the change involves an unreviewed safety question.
.e, 1 i .q[ A RANCHO SECO LIQUID EFFLUENTS PROGRAM
Background
March / April 1984: SMUD's ODCM found to be in error by a factor of 25, impacting on effluent releases since 1980. May 1984: SMUD filed a Special Report with the NRC based on the ODCM error. The report indicated: The maximum calculated dose for 1983 for all pathways was 108 mrem. A WBC of an individual living in the effluent pathway for the 1st quarter of 1984 was 12 mrem, thus the limits of 40 CFR 190 were not exceeded. The cause of the radioactive-releases was due.o a d primary to secondary steam generator tube leaf. Region V requests NRR to confirm SMUD's May 1984 report in order to determine whether a variance for cor.tinued operation is necessary. In July, Region V disclosed that the= irrigated food pathway parameter was not included in the calculations for the data in the SMUD May report. SMUD did not inform NRC that the land use parameter was omitted. July 1984: The Rancho Seco RETS are implemented. September 1984: NRR reports that the SMUD May report data does not support SMUD's assumptions. NRR states that 10 CFR 50, Appendix I dose objectives and the 40 CFR 190 limits have been exceeded, and there is no apparent justification for granting a variance for continued operation. SMUD issues Special Report 84-07 for the first eight months of 1984, stating that SMUD had exceeded 40 CFR 190 limits with calculated annual doses from liquid effluert being 185 mrem to the body and 253 mrem to the organ. The source of the problem, the primary to secondary steam generator tube leaks, had been resolved, and the pathway of the releases to the environment was through the RHUTS via the secondary system.
-- Near term corrective action included instructions to the Chemistry and Radiation Protection managers to sample the RHUT and control the releases so that they were in conformance with Appendix I, Tech Spec limit *. Rancho Seco was limiting their discharges so that 10 CFR 50, Appendix I limits were not to be exceeded and a variance for continued operation would not be necessary. November 1984: NRR notifies SMUD that a variance for continued operation is not needed because of SMUD's commitments in the September 1984 Special Report 84-07 not to exceed the limits of 40 CFR 190 and because the near term corrective actions that had been implemented. Fall 1984: Pierre OUBRE, SMUD's Plant Manager for Rancho Seco, makes a public statement that the plant will not make any liquid releases containing radioactivity. April /May 1986: Region V Inspection Report 86/15 indicates that the radioactivity released in Rancho Seco's liquid effluents in 1985 violated Appendix I Tech Spec dose objectives. Rancho Seco's Radioloaical and Environmental Technical Specifications May 1979: Rancho Seco's draft RETS was sent to NRR with the word "not" in the bases of the Tech Spec 4.21.1. Insertion of the word not indicates that the levels of radioactive materials in bodies of water outside the site will "not" result in exposure within the design objectives of 10 CFR 50, Appendix 1. The word not was inserted because Rancho Seco was a dry site and the design of the plant exceeded the ALAP,A Appendix I provisions designed to comply with Appendix I. July 1984: Rancho Seco's RETS became' effective with the word not remaining in the bases of Tech Spec 4.21.1. g dificetion to Rancho Seco's Primary Water System Inspection Report 86/15 revealed that from December 1982 to March 1986, a modification from the Class I DRCST, in the form of a PVC pipe and hose to the RHUT, allowed water to be transferred from the primary system via the DRCST tn the RHUT, for release to the environment. The modification was not reported in FSAR updates, as required, showing a different routing of the primary water and its release to the environment. 5-86-010 2
l.. i No safety evaluation was conducted on the modification. With the release of primary water to the environment, the DRCST should have been sampled for radioactivity. Water from the DRCST was transferred to the RHUT, where it was diluted with service system water before sample water was taken for analysis. The modification conflicts with the information reported in the September 1984 Special Report 84-07 regarding the source of liquid effluents, the implemented short term corrective action to control, through sampling and management, the release of radioactive effluents and the commitment not to exceed the 10 CFR 50, Appendix I dose objectives. KELLIE and MANOFSKY stated they were neither aware of Special Report 84-07 nor the conynitment required of them to control liquid effluents so that releases would not exceed the Appendix I dose objectives. COWARD, the Reactor Operators and KELLIE had direct responsibilities over the control o P pr'imary and secondary water. The information on the modification was obtained by happenstance by -Region V. Alteration of Rancho Seco's Radionuclide Analysis Counting Time In early 1985, Chemistry and Radiation Technicians were instructed by KELLIE, MANOFSKY and WILSON to lower the analysis counting time from-2000 to 1000 seconds' to. preclude detecting peaks of radioactivity. - -If radioactive peaks were detected. the RHUT water could not be released because of SMUD's commitment not to release to the environment liquid effluents containing radioactivity. i I; One of the first occurrences of the lowered counting time occurred in March 1985. MIXA notified a Reactor Operator in the Control Room that peaks had been identified and that the water could not be released, i-Shortly thereafter, KELLIE instructed MIXA to recount at 1000 seconds - and release the water if no peaks were identified. The CRPT's felt uncomfortable lowering the counting time because they were reporting to the Reactor Operators that there was no radioactivity L, when they knew otherwise. The CRPT's were told by KELLIE, MANOFSKY and WILSON that NRC was aware of the count time alteration and as long as Rancho Seco's LLD's were met, the counting time could be lowered. In June 1985, KELLIE was told by YUHAS that any peaks, including those below the plant's LLD, had to be reported in the Semi Annual Effluent Report. L 5-86-010 3
t,- In December 1985, BRADLEY was-told by MIXA that the counting times were being altered. BRADLEY informs-POWERS and RODRIGUEZ. As a result, COWARD consults with KELLIE and then states that as long as the counting time is within Rancho Seco's LLD, it can be lowered. In March 1986, BRADLEY informed NRR, as an aside, about the alteration of counting time. This information led to the initiation of Inspection 86/15. The Insufficiency of Rancho Seco's Lower Limits of Detection Technical Specification In January 1985. BRADLEY realized that Rancho Seco's Technical Specification requiring a LLD capability of SE-7 did not assure compliance with Appendix I dose objectives because the plant is a dry site and has no river or ocean dilution capability. POWERS and RODRIGUEZ are informed by BRADLEY about the LLD issue in January 1985. POWERS does not want BRADLEY to study the matter because it might expose deficiencies in the effluent program. RODRIGUEZ agreed with BRADLEY's suggestion to not publish his LLD study until after startup and resolution of the high point vent brake. The study was furnished to POWERS in July 1985, and he disagreed with .BRADLEY's assertion.that Rancho Seco's LLD was insufficient for compliance with Appendix I dose objectives. POWERS takes no further-action on the matter. COLOMB0 and KELLIE were not aware of the LLD issue until after BRADLEY issued his draft study in October 1985. SMUD's 1985 Semi Annual Report of September 1985, reported no releases of radioactivity in liquid effluents. The report stated that extensive work and a concerted effort had been extended to comply with Appendix I dose objectives. In December 1985, BRADLEY informed YUHAS that LLNL's downstream pathway analysis detected cesium 4 concentrations that are unusually high for a plant with no radioactive liquid releases. BRADLEY also informed YUHAS about the insufficiency of Rancho Seco's LLD. In December 1985, Region V informed NRR that Rancho Seco's LLD cannot assure compliance with Appendix I limits. SMUD's 1985 Semi Annual Report of March 1986 reported no releases of radioactivity in liquid effluents. 1 5-86-010 4
i SMUD's Acknowledgement of Effluent Release Procram Errors In April 1986, NRR informed SMUD that the staff assessment of the contamination of the-environment of liquid releases for the years 1980-1984 was significant but that the ORNL whole body count analysis indicated that the 40 CFR 190 lirit was not exceeded. NRR also informed that they were reviewing SMUD's radiological effluent program to determine if SMUD management practices are adequate to insure compliance with 10 CFR 50, Appendix ! and 40 CFR 190. In June 1986, SMUD's Special Report 86-08 acknowledges that the 1985 annual dose objective of Appendix I was exceeded due to strict reliance 'l on Rancho Seco's LLD values and tb? release of liquid effluents in quantities not contemplated. 1 In July 1986, SMUD acknowledged violations contained in Inspection l Report 86/15 regarding monitoring procedures, modifications without 10 CFR 50.59 reviews, the alteration.of counting times and not reporting j detected radionuclide peaks. j 1 { l l i 5-86-010 5
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r ACRN0YMS SMUD - The Sacramento Municipal Utility District ALARA - As Low As Reasonably Achievable MREM - Millirem - a Thousandths of a Rem, expressed in rates per hour or per year. A chest x-ray is equal to about 20 mrem per hour; cosmic rays equal about 45 mrem per year. LLD - The lower limit of detection capability of radioactive material analysis. The LLD is influenced directly by the volume of water sampled, the analysis counting time and the sophistication of the detection equipment. WBC - Whole Body Count of r?dioactivity in a person using radionuclide detection equipment. RETS - The Radiological Environmental Technical Specifications FSAR - The Final Safety Analysis Report describing the nuclear plants facility, and the operational mode and safety parameters of the facility. ODCM - The Rancho Seco Offsite Dose Calculation Manual.-the procedural guide for determining the radioactivity in effluent releases. DRCST - The Demeneralized Reactor Coolant Storage Tank of the Rancho Seco radioactive waste treatment system. .RHUT - The Regenerate Holdup Tank, a water storage tank of the Rancho Seco secondary water system SCRA - Senior Chemist Radiation Assistant CRPT - Chemistry and Radiation Protection Technician LLNL - The Lawrence Livermore Nations) Laboratory "RNL ' - The Oak Ridge National Laboratory r
s l- : ' g. 'y s BRIEFING FOR MR. HAYES ON THE SACRAMENTO MUNICIPAL UTILITY DISTRICT'S RANCHO SECO NUCLEAR GENERATING STATION LIQUID EFFLUENTS PROGRAM OI:RV Case 5-86-010 February 26, 1987
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e L. The Rancho Seco Nuclear Generating Station Liquid Effluents Program u Introduction s THE SMUD LIQUID EFFLUENTS PROGRAM MANAGEMENT ORGANIZATION THE NRC REGULATORY REQUIREMENTS Details
Background
Rancho Seco Radiological and Environmental Technical Specifications Modification to Rancho Seco's Primary Water System Alteration of Rancho Seco's Radionuclide. Analysis Counting Time The Insufficiency of Rancho Seco's Lower Limits of Detection Technical Specification SMUD's acknowledgement of Effluent Release Program Errors. Summation 0
.= NRC REGULATORY REQUIREMENTS So 36ct_ - 10 CFR Sfnr Technical Specifications required demonstrating adherence to 10 CFR 20.106 and 10 CFR 50 Appendix I limits. - Semi Annual Effluent Reports are required reporting the amount of liquid effluents released to the environment - All information which allows NRC to estimate the maximum annual radiation doses shall be reported in the semi annual reports. 10 CFR 20.106 The EPA standard for Nuclear Plant Operations - 40 CFR 190/ annual dose of less than 25 mrem to en individual-shall not be exceeded by effluen_t releases to the public.J Tf the cause of the excess-releases is I temporary and corrective action has been taken, a 7 ~ lvarianceforcontinuedoperationcanbegrantedby{ 10 CFR 50 Appendix.I Requires the estimated annual dose from radioactive material released in liquid effluents not to exceed 3 mrem to the body and 10 mrem to any organ. - The licensee is required to establish a surveillance and monitoring program in order to provide data on liquid releases. - The licensee is required to identify changes in the unrestricted areas in order to permit modifications to the monitoring programs that estimate doses to individuals 10 CFR 20.405 Requires licensee to file a report to the Region within, 30 days if releases of radionuclides are in excess' of the EPA standard of 40 CFR 190.. - The report should describe the cause of the excess releases and corrective action taken and - the extent of exposure to the individual. 10 CFR 50.71 Requires the licensee to annually update the Final Safety Analysis Report so that the NRC is aware of changes made to the facility. 10 CFR 50.59 Requires the licensee to make a safety evaluation for proposed changes to the facility as described in the Final Safety Analysis Report when the change involves an unreviewed safety question.
.3 RANCHO SECO LIQUID EFFLVI.NTS PROGRAM
Background
March / April 1984: SMUD's ODCM found_to be in error by a factor of 25, impacting on effluent releases since 1980. May 1984: SMUD filed a Special Report with the NRC based on the ODCM error.- The report indicated: The maximum calculated dose for 1983 for all pathways was 108 mrem. A WBC of an individual living in the effluent pathway for the 1st quarter of 1984 was 12 mrem, thus the limits of 40 CFR 190 were not exceeded. The cause of the radioactive releases was due to a primary to secondary steam generator tube leak. Region V requests NRR to confirm SMUD's May 1984 report in order to determine whether a variance for continued operation is necessary. In July, Region V disclosed that the irrigated food pathway parameter was not included in the calculations for the data in the SMUD'May report. SMUD did not inform NRC that the land use oerameter was omitted. July 1984: The Rancho Seco RETS are implemented. September 1964: NRR reports that the SMUD May report data does not =- support SMUD's assumptions. - NRR states that 10 CFR FC, AppeMix I dose objectives and the 40 LFR 190 limits havc hen exceeded, and there is no apparent justification for granting a variance for continued operation. SMun issues Special Report 84-07 for the first eight. months of 1984, stating that SMUD had exceeded 40 CFR 190 limits with calculated annual doses from liquid _efficent being 185 mrem to the body and 253 mrem to the organ. The source of the problem, the primary to secondary steam generator tube leaks, had been resolved, and the pathway of the releases to the environmer* as through the RHUTS via the secondary system.
i. ) l Near term corrective action included instructionf, to -i the Chemistry and Radiation Protection managers to i sample the RHUT and control the releases so that they were in conformance with Apper. dix I, Tech Spec limits. Rancho Seco was limiting their discharges so that 10 CFR 50, Appendix I limits were not to be-exceeded and a variance for continued operation would not be ~ 'i necessary. . November 1984: NRR notifies SMUD that a variance for continued operation is not needed because of SMUD's commitments in the September 1984 Special Report 84-07 not 'to exceed the limits of 40 CFR 190 and because the near term corrective actions that had been implemented. I Fall 1984: Pierre OUBRE, SMUD's Plant Manager for Rancho Seco, makes a public statement that the plant will not make any liquid releases containing radioactivity. April /May 1986: Region V Inspection Report 86/15 indicates that the radioactivity released in Rancho Seco's liquid effluents in 1985 violated Appendix I Tech Spec dose objectives. i Rancho Seco's Radiological and Environmental Technical Specificat'ons May 1979: Rancho Seco's draft RETS was sent to NRR with the word "not" in the bases of the Tech Spec 4.21.1. Insertion of l the word not indicates that the levels of radioactive materials in bodies of water outside the site wi.ll "not" result in exposure within the design objectives of 10 CFR 50, Appendix 1. The_ word not was inserted because Rancho Seco was a dry site and the design of the plant exceeded the ALARA Appendix I provisions designed to tl comply with Appendix I. July 1984: Rancho Seco's RETS became effective with the word not remaining in the bases of Tech Spec 4.21.1. l Modification to Rancho Seco's Primary Water System inspection Report 86/15 revealed that from December 1982 to March 1986, a modification from the Class I DRCST, in the form of a PVC pipe and hose to the RHUT, allmed water to be trarsferred from the primary system via the DRCST to the RHUT, for release to the environment. The modification was not reported in FSAR updates, as required, showing a different routing of the primary water and its release to the environment. 5-86-010 2 i_
c i No safety evaluation was conducted on the modification. With the release of primary water to the environment, the DRCST should have been sampled for radioactivity. Water from the DRCST was transferred to De RHUT, where it was diluted with service system water before sample water was taken for analysis. The modification conflicts with the information reported in the September 1984 Spe:ial Report 84-07 regarding the source of liquid effluents, the implemented short term corrective action to control, through sampling and management, the release of radioactive effluents and the Commitment not to exceed the 10 CFR 50, Appendix I dose objectives. KELLIE and MANOFSKY stated they were neither aware of Special Report 84-07 nor the cortnitment required of them to control liquid effluents so that releases would not exceed the Appendix I dose objectives. COWARD, the Reactor Operators and KELLIE had direct responsibilities over the control of primary and secondary water. The information on the modification was obtained by happenstance by Region V. t Alteration of Rancho Seco's Radionuclide Analysis Counting Tin In early 1985. Chemistry and Radiation Technicians were instructed by KELLIE, MANOFSKY and WILSON to lower the analysis counting time from 2000 to 1000-seconds to preclude detecting peaks of radioactivity. If radioactive peaks we'e detected, the RHUT water could not be released because of SMUD's commitment not to release to the environment liquid effluents containing radioactivity. = One of the first occurrences of the lowered counting time occurred in March 1985. MIXA notified a Reactor Operator in the Control Room that peaks had been identified and that the water could not be released. Shortly thereafter, KELLIE instructed MIXA to recount at 1000 seconds and release the water if no peaks were identified. The CRPT's felt uncomfortable lowering the counting time because they were reporting to the Reactor Operators that there was no radioactivity when they knew otherwise. The CRPT's were told by KELLIE, MANOFSKY and WILSON that NRC was aware of the count time alteration and as long as Rancho Seco's LLD's were met, the counting time could be lowered. In June 1985, KELLIE was told by YUHAS that any peaks, including those below the plant's LLD, had to be reported in the Semi Annual Effluent Report. 3-86-010 3
e, /' In December 1085. BRADLEY was told by MIXA that the counting times were being altered. BRADLEY inforns POWERS and RODRIGUEZ. As a result, COWARD consults with KELLIE and then states that as long as the Counting time is within Rancho Seco's LLD, it can be lowered. In March 1986, BRADLEY informed NRR, as an aside, about the alteration of counting time. This information led to the initiation of Inspection 86/15. The insufficiency of Rancho Seco's Lower Limits of Detection Technical Specification In January 1985, BRADLEY realized that Rancho Seco's Technical Specification reouiring a LLD capability of SE-7 did not assure compliance with Appendix ! dose objectives because the plant is a dry site and has no river or ocean dilution capability. POWERS and RODRIGUEZ are informed by BRADLEY about the LLD issue in January 1985. POWERS does not want BRADLEY to study the matter because it might expose deficiencies in the effluent program. RODRIGUEZ agreed with BRADLEY's suggestion to not publish his LLD study until after startup and resolution of the high point vent brake. l The study was furnished to POWERS in July 1985, and he disagreed with BRADLEY's assertion that Rancho Seco's LLD was insufficient for compliance with Appendix ! dose objectives. POWERS takes no further action on the matter. COLOMB0 and KELLIE were not aware of the LLD issue until after BRADLEY issued his draft study in October 1985. 1 SMUD's 1985 Semi Annual Report of September 1985, reported no releases of radioactivity in l' quid effluents. The report stated that extensive work and a concerted :ffort had been extended to comply with Appendix !, w dose objectivos. In December W85, BRADLEY informed YUHAS that LLNL's downstream pathway l annlysis detected cesium at concentrations that are unusually high for a plant with no radioactive liquid releases. BRADLEY also informed YUHAS L abcut the insufficioney of Rancho Seco's LLD. In December 1985, Region V informed NRR that Rancho Seco's LLD cannot assure compliance with Appendix ! limits. 1 SMUD$s 1985 Semi Annual Perort of March 1986 reported no releases of p radioactivity in liquid effluents. i 1 5 86-010 4 )
T ? l SMllD's Acknowledgement of Effluent Release Program Errors In April 1986, NRR informed SMUD that the staff assessment of the contamination of the environment of liquid releases for the years 1980-1984 was significant but that the ORNL whole body count analysis indicated that the 40 CFR 190 limit was not exceeded. NRR also informed that they were reviewing SMUD's radiological effluent program to determine if SMUD management practices are adequate to insure compliance with 10 CFR 50, Appendix ! and 40 CFR 190. In June 1986, SMUD's Special Report 86-08 acknowledges that the 1985 annual dose objective of Appendix 1 was exceeded due to strict reliance on Rancho Seco's LLD values and the release of liquid effluents in quantities not contemplated. In July 1986, SMUD acknowledged violations contained in Inspection Report 86/15 regarding monitoring procedures, modifications without 10 CFR 50.59 reviews, the alteration of counting times and not reporting detected radionuclide peaks. w 5-86-010 5
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