ML20055D715

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Forwards Info Requested During 870325 Interview & 870331 Telcon
ML20055D715
Person / Time
Site: Rancho Seco
Issue date: 03/31/1987
From: Canter H
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To: Meeks R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20055C226 List:
References
FOIA-90-76 NUDOCS 9007090327
Download: ML20055D715 (28)
v • d • e


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{ ( SMU-SACRAMENTO MUNICIPAL UTILITY DISTRICT P. O. Box 16830. Sectamento CA 95852 1830.19 G14 h[2'.3211 AN ELECTRIC SYSTEM SERVING THE HE4QT OF CALIFORNIA

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March 31, 1987 l

l US' Nuclear Reguletory Comm'ission Attention: Mr. Ron Meeks 1450 Maria Lane, Suite 210 Walr.ut Creek, CA 94596 m

Dea r Ron,

' Per our interview at 2:00 p.m. on Wednesday, March 25, 1987, and per our j

phone, discussion on March 31, 1987 at 3:00 p.m., I've enclosed three sheets of information you requested.

I Sheet.one.and two indicate that my dealings with' Region V were with Harry North mainly.

Sheet three documents a time in my notes when I wrote something about the transfer line from the DWRCST to the RHUT.

The note on the' margin said " call Harry or. Mike". My notes don't make it clear that I actually did call Harry or' Mike, however,.

If you 'have any further questions, I'm sure you know how to reach me.

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Harvey L. Canter i

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SUMMARY

OF INTERVIEW TRANSCRIPT WITH L

GEORGE A. COWARD DATE INTERVIEWED: 3/24/87 DATE OF

SUMMARY

?/31/87 01:RY CASE NUMBER: 5-86-010 1

George A. COWARD, an Engineer for the Sacramento Municipal Utility District (SMUD) and former Rancho Seco Nuclear Generating Station (Rancho Seco) Plant Manager, was interviewed by Office of Investigations Field Office, Region V, Senior Investigators Ronald A. Meeks and Owen C. Shackleton Jr., regarding COWARD's knowiedge of SMUD's management and operations of the Rancho Seco Liquid Effluents Program. The information listed below is a sumary of the L

interview transcript.

Procedures Concerning liquid Effluents The DRCST was analyzed on a regular basis to determine radioactivity but there was no individual sampling of the DRCST tank before overy transfer to the RHUT (pp 24-25).

Short tern corrective action item VII meant that water in the RHUT, which contained radioactivity or gamma peaks was not to be released to the retention basin.

If the analysis showed that there were no gamma emitters, the analysis was called LLD and the water was released to the environment.

Instructions were given to the Chemistry and Radiation and Operations Managers not to release water that had gamma emitters. Water containing gama emitters would be sent back to the Miscellaneous Waste System and processed. The source of this instruction was the Plant Manager. Pierre OUBRE (pp 26-28).

Manaoement of the Liquid Effluents' Program On or about September 1984 there were numerous management meetings concerning the generation of radioactive waste because of the Steam Generator Tube Leaks l

l at Rancho Seco. COWARD's primary interface concerning Special Report 84-07 was his supervisor, Pierre OUBRE (p 6).

Resources from all of the SMUD organizations were involved in the input of Special Report 84-07 including RODRIGUEZ, OUBRE, MILLER, and the Nuclear Engineering Staff (pp 7-8).

When a RHUT radioactive analysis precluded release from the RHUT to the environment, the water would be pumped to the reactor coolant basement.

The Rancho Seco Operations Manager would then decide on the disposition of that water from the RHUT. The Operations division was supervised by Dan COMSTOCK in 1984 and Bill SPENCER in '985 (pp 12-15).

COWARD acknowledged that cianging the analysis count times on samples from the RHUT changed the LLD for the sample (p 35).

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W In'1986, SMUD put into place a real time tracking system to determine on a release by release basis the amount of radioactivity being(put into the i

environment as it related to 10 CFR 50, Appendix I Limits p 39).

The lowering of the analysis count time was a public relations move because of 'he comitment by SMUD not to release any radioactivity to the environment.

In reality, there is radioactivity in any holding tank. However, in this situation, the lowering of the count time met Rancho Seco's Technical Specification LLD, thus allowing SMUD to make releases of water with no indications of gamma peaks and therefore, a non radioactive release. COWARD authorized KELLIE to lower the RHUT samples analysis count time (pp 40-41).

COWARD did not discuss the authorization or practice of lowering the count time with OUBRE or RODRIGUEZ because these individuals were not at their office on the day that COWARD and KELLIE discussed the basis for lowering the count time.

COWARD felt that the fact the lower count time met the Lower Limit of Detection Technical Specification did not require notification to OUBRE or RODRIGUEE (pp 41-42).

With the issuance of BRADLEY's October 29 memorandum on the LLD issue, as l

well as the Lawrence Livermore National Laboratory's (LLNL) findings of radioactivity in sediment beds downstream from the Rancho Seco release point, SHUD management began to focus on the LLD issue. Management meetings were conducted in an effort to tighten up the procedures on releasing water containing radioactivity off site.

COWARD indicated that KELLIE and BRADLEY would have the specifics with respect to how the actual process was made more effective so that off site releases would not contain radioactivity. COWARD l

stated this refocus on the management and operations of liquid effluent l

releases was made in conjunction with BRADLEY's memo in October 1985 and before the NRC inspection on~ Rancho Seco's liquid effluents' program in April /May 1986. Some of the actions taken were to install portable demineralizers allowing more water to be sent back to the Miscellaneous Waste l

System from the RHUTS, the implementation of throw away demineralizers used in the secondary water clean up systen, and changing the dilution flow rate of water being released to the environment (pp 52-56).

COWARD stated RODRIGUEZ was aware of the Livermore Lab's findings in t

October 1985 and supported the actions that corrected the situation (p 56).

COWARD acknowledged that technically diluting the RHUT which already contained water from the DRCST, reduced the likelihood of detecting radioactivity (p 67).

COWARD acknowledged the temporary modification allowing water to be transferred from the DRCST to the RHUT's should have been incorporated into the plant design system as a permanent structure (p 71).

Rancho Seco Plant Configuration The modification allowing water being transferred from the DRCST tank to the RHUT tanks was necessary in order to make room for more water in the DRCST.

The plant was not designed to deal with these excess water build ups in the DRCST tank (pp 10-12,20).

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Water processed through the Miscellaneous Waste System was usually considered clean water except for the presence of tritium. This water was used for decontamination. Water in the DRCST tank was usually processed through the boric acid concentrator evaporator before being put in the DRCST (pp 16-17),

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The draining of the fuel transfer canal several times in 1985 to repair a Reactor Coolant Pump created an excess amount of water in the Rancho Seco water inventory (p 23).

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SUMMARY

OF INTERVIEW TRANSCRIPT WITH FRED W. KELLIE DATE INTERVIEWED:

3/24/87 DATE OF-

SUMMARY

3/31/87 OI:RY CASE NUMBER: 5-86-010 Fred W. KELLIE, the Radiation Protection Superintendent for the Sacramento Municipel Utility District (SMUD) at the Rancho Seco Nuclear Generating Station, was interviewed by Robert G. Marsh, Director, Office of Investigations Field Office, Region V and Ronald A. Meeks, Office of Investigations Field Office, Region V Senior Investigator.

KELLIE was-interviewed relative to his knowledge of SMUD's management and operations of the Liquid Effluents Release Program at Rancho Seco. The information listed below is a summary of the transcript of that interview.

-Procedures Concerning Liquid Effluents It was KELLIE's opinion that everyone connected with the modification allowing water to be transferred from the Demineralized Reactor Coolant Storage Tank (DRCST) to the Regenerate Holdup Tank (RHUT) believed that modification to be legal (p 67).

KELLIE stated if analysis of water in the reactor basement indicated the presence of gross beta contamination, then the water was sent to the DRCST and not put into the Miscellaneous Waste Hoidup Tank (MWHUT).

KELLIE explained that water in the MWHUT was used for decontamination and thus, could not contain gross beta activity.

VELLIE related thet if gross beta activity was present you would also have gamma emitters present but the detection of g(amna emitting radioisotopes depends on the length of the counting time pp 78-79).

Management of the Liquid Effluents' Procram In October 1984, KELLIE's Supervisor, Roger MILLER, told KELLIE that there would be no more releases of radioactivity in liquid effluents from Rancho Seco.

KELLIE stated no other explanation accompanied MILLER's statement other than releases containing tritium in liquid effluents are allowed.

KELLIE interpreted MILLER's statement about releases of tritium in liquid effluents to mean that water from the DRCST, which contained tritium, could be released to the environment (pp 15-18,50).

After implementation of the Radiological and Environmental Technical Specifications (RETS), detection of radioactivity in the RHUT, required the water from the RHUT to be returned to the MWHUT for deionization. The deionization process caused a delay in reducing the water inventory from Rancho Seco because water from either the 100,000 or 200,000 gallon RHUT had to be channeled into the 30,000 gallon capacity MWHUT (p 29).

KELLIE recalls a meeting he and others had with Plant Manager, Pierre OUBRE, in 1981 concerning the DRCST modification.

That meeting was held in conjunction with the steam generator tube leaks that occurred.

KELLIE does h

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i not recall anyone mentioning the necessity to report the modification to NRC in that meeting (pp 69-70).

In 1981, OUBRE directed KELLIE to draw up procedures to standardize the DRCST modification.

OUBRE's direction to KELLIE was made after the first steam generator tube leak was corrected in 1981.

KELLIE made recomendations on how to standardize the removal of water from the DRCST but not all of his recommendations were accepted. Consequently he never followed through on the directions to draw up procedures for the DRCST modification (pp 73-75).

KELLIE, before releasing the DRCST water to the RHUT, took water samples for tritium analysis.

No gamma emitting analysis was conducted on these DRCST samples (p 77).

KELLIE explained that when time restraints required water in the RHUT to be released as soon as possible he would use the plant service water for dilution of the RHUT. The dilution was to assure that tritium in the RHUT was released within the specified limits of Maximum Permissible Concentration (MPC).

KELLIE stated there was no procedure for a dilution factor for gross beta and gama emitters until 1986 when NRC pointed out the necessity for such a procedure.

KELLIE also explained that DRCST water transferred to the RHUT could become more contaminated by diluting the RHUT with contaminated water from the secondary system (pp 83-87, 130-131).

KELLIE was not informed in any way whatsoever of the Technical Specification Lower Limits of Detection (LLD) issue raised by BRADLEY until October 1985 (pp 87-88).

KELLIE stated had it been shown to him that the amounts of cesium 137 being L

released in 1985 would have caused the plant to exceed the Appendix I limits l

because Rancho Seco's Technical Specification LLD could not assure compliance with the Appendix I limit, KELLIE would have stopped all releases (p 94).

KELLIE's review of BRADLEY's draft study on the LLD issue indicated concern about the validity of the study (pp 97-100).

KELLIE stated he made the decision to lower the count time on the analysis of RHUT samples (p 109).

KELLIE understood that counting the RHUT samples for a shorter time period would reduce the ability to identify positive peaks of radioactivity. KELLIE discussed this fact with his supervisor, George C0 WARD, in relation to the KELLIE/YUHAS telephone call on this subject on June 6, 1985.

KELLIE wanted direction from C0 WARD on whether the lowering of the counting time was legal (pp 117-119).

The reporting of the June 6, 1985, telephone conversation between KELLIE and YUHAS was a standard practice at Rancho Seco and the distribution for such records-of telephone conversation was normal.

The fact that KELLIE doubted the validity of BRADLEY's LLD issue caused KELLIE to not take any action to determine if the lowering of the analysis count time was effected by the LLD issue. It was not until after the NRC inspection by Greg YUHAS in April /May 1986 that BRADLEY's LLD issue was confirmed as being valid (p 122).

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.i KELLIE did not discuss with his senior chemist and radiation assistants the-contents of the June 6 telephone conversation with YUHAS because KELLIE had already received instructions from MILLER not to release any radioactivity in

-liquid effluents (pp 123-124).

KELLIE did not change the process of how the RHUT's were diluted and sampled after he was instructed by MILLER in October 1984 not to make any radioactive releases (p 132).

Rancho Seco Plant Configuration The design of Rancho Seco's primary water system did not allow for water to be removed from the primary system in the quantities that were generated by the steam generator tube leaks.

In addition, the normal leakage from the secondary system into the Reactor Building Sump under. normal opera'ing conditions created an increase in the water inventory of the DRCST (pp ?S-45).

Water in the DRCST is chemically clean although it contains radioactive isotopes.

This water serves as makeup water for the Reactor Coolant System (p 45).

Part of the reason that 787,500 gallons of water had to be released in 1985 was due to the high point vent break which occurred in June / July 1985.

The high point vent break caused a shut down which necessitated the use of borated water.

With startup, the borated water needed dilution and that dilution required significant amounts of water makeup (pp 54-55).-

Water shipped off site was water from the Miscellaneous Waste System.

The i

off site shipment stopped in the late 1970's because the regulatory requirements were changed to prohibit such shipments (pp 64-65).

With even minor amounts of steam generator tube leaks during plant operation there is continual input of radioactive contamination into the secondary system {p 91).

j Effluent Reports to the NRC KELLIE had no involvement in the formulation and input of information contained in Special Report 84-07 dated September 27, 1984. At the time of that report KELLIE was Rancho Seco's Assistant Chemical Radiation Protection Superintendent, reporting to Roger MILLER, the Rancho Seco Chemistry Radiation Protection Superintendent (pp 4-6, 9-10).

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SUMMARY

OF INTERVIEW TRANSCRIPT WITH i

ROGER I. MILLER DATE INTERVIEWED:

3/24/E7 DATE OF

SUMMARY

4/1/87 Roger 1. MILLER, the former Rancho Seco Nuclear Generating Station (Rancho Seco) Chemistry and Radiation Protection Superintendent for the Sacramento Municipal Utility District (SMUD) until his retirement in June 1985, was interviewed by Office of Investigations Senior Investigator, Ronald A. Meeks regarding MILLER's knowledge of SMUD's management and operations of the Liquid Effluents Release Program at Rancho Seco. The information listed below is a sumary of the interview transcript.

Procedures Concerning liquit' Effluents MILLER indicated that analysis sampling is required when there is any movement of water between tankage at Rancho Seco (p 8).

The DRCST was sampled for the presence of tritium before the release of the water from the tank to the RHUT. MILLER acknowledged that a procedure should have been implemented directing the sampling of the DRCST for gamma emitters (pp19-20).

MILLER stated that in mid-1985, NRC indicated to SMUD management to start sampling water in the DRCST before it entered the RHUT (p 28).

Management of the Liquid Effluents' Program MILLER was the SMUD manager responsible for Near Term Corrective Action No. 7 in Special Report 84-07. MILLER stated that the policy of Action Item No. 7 was not to exceed the limits of Technical Specification of 3.17.2.

MILLER stated _ that he did not recall any specific actions that were implemented to assure compliance with the Commitment and Action Item No, 7.

Near Term Correction Action VIII gave the Chemistry and Radiation Protection Group responsibility to send water to the Miscellaneous Waste System if it contained radioactivity (p 36).

MILLER acknowledged that he was aware of the practice of lowering the l

analysis sample count time.

MILLER stated the reason for lowering the count time was to -speed up the release of water to the environment. MILLER stated that the practice of lowering the analysis sample count time was proceduralized (pp 41-42).

i l

l Regarding the June 6, 1985, telephone conversation between KELLIE and NRC's Greg YUHAS, MILLER stated that his interpretation of that telecon indicated that KELLIE was instructed to report identified peaks when obtained in the sample analysis. MILLER stated that a generalized direction was given to the L

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Chemistry and Radiation Protection personnel that sample analysis which had measurable amounts of radioactivity was reportable. MILLER stated this was a generalized direction that had always existed for the Chemistry and Radiation Protection personnel (pp 42-44).

Rancho Seco Plant Configuration MILLER explained that the Operations Division had a difficult problem with excess water inventory build ups due to the fact that Rancho Seco was designed to be a dry site. This situation created a management and operations effort to limit the amount of water in Rancho Seco's inventory that contained radioactivity in order to keep the plant functioning (pp21-22).

MILLER explained that the Rancho Seco plant does not have the clean up capabilitytoremoveyadioactivitythroughtheirwaterprocessbelowthe levels of 10'6 to 10~ concentrations (p53),

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SUMMARY

OF INTERVIEW TRANSCRIPT WITH ROGER L. POWERS DATE INTERVIEWED:

3/25/87 DATE OF

SUMMARY

4/2/87 OI:RY CASE NUMBER: 5-86-010 Roger L. POWERS, the Supervisor of Nuclear Engineering for Nuclear Fuel Management for the Sacramento Municipal Utility District (SMUD), was interviewed by Office of Investigations Senior Investigator, Ronald A. Meeks regarding POWERS' knowledge of SMUD's management and operatior.s of the Liquid Effluents Release Program at the Rancho Seco Nuclear Generating Station (Rancho Seco).

The information listed below is a sumary of the interview transcript.

Management of the Liquid Effluents' Procram POWERS explained that BRADLEY, before he brought up the LLD issue at Rancho Seco, wanted to work on a situation involving difficult to detect isotopes I

per an EPRI report. POWERS, as BRADLEY's supervisor, discouraged BRADLEY's L

desire to work on this issue because it was counter productive.

POWERS explained that BRADLEY then turned his attention on the LLD issue and his study indicated that there might be a problem with Rancho Seco's Technical Specification on LLD assuring compliance with Appendix I Limits.

POWERS took no action on BRADLEY's LLD study stating that if BRADLEY was concerned that the Technical Specification LLD would be violated, he could have used Administrative Procedure No. 22 which allows for the reporting of problems and adhering to the license of Technical Specifications. POWERS stated the fact BRADLEY took no actinn through Administrative Procedure No. %2, was an indication to POWERS that no further management action needed to be devoted to BRADLEY's concern (pp 19-22).

POWERS interpreted BRADLEY's LLD study as follows:

If all releases had activity just below Technical Specification LLD, then the annual release of radioactivity and liquid effluents could equal a reasonab'le fraction of the three mrem limit of 10 CFR, Appendix I.

BRADLEY wanted that reasonable fraction to be reduced but POWERS did not concur (p 24).

POWERS becane aware in December 1985 of the lowering of the sample analysis count time through BRADLEY. POWERS, at RODRIGUEZ's direction, called KELLIE in December 1985, and asked KELLIE to run composite sample analysis to determine what fraction of the calculated dose could be attributed to the undetected amount of radioactivity due to the *ower count time. POWERS recalled that C0 WARD was also involved in this conversation with RODRIGUEZ and POWERS concerning the composite sample analysis and the direction to KELLIE to run the composite analysis (pp 26,33-34).

POWERS determined, based on MILLER, BRAUN, and KELLIE's review of the draft LLD study in he summer of 1985, that the latter three did not think that

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BRADLEY's concern on the LLD issue was significant.

POWERS stated that he did not have any conversations with his supervisor, Lee KEILMAN, concerning BRADLEY's LLD issue (pp 29-31).

In December 1985, SMUD management decided to move forward on the LLD issue and determine what the issue im Pollution (CEP) analysis-(p 34) plied through the Controls for Environmental i

j POWERS stated he did not remember any discussion with BRADLEY to withhold the issuance of BRADLEY's draft LLD study until resolution of a high point vent break issue and/or restart. POWERS stated if in fact the issuance of BRADLEY's draft LLD study was held up, it could have been due to the legal i

suits against SMUD at that time (pp 37-38).

POWERS does not recall any specific meetings with his Supervisor, KEILMAN, or the Executive Director for Nuclear, Ron RODRIGUEZ as it related to POWERS' views that the Offsite Dose Calculation Manual was highly conservative and j

1 BRADLEY's LLD issue that the Rancho Seco Technical Specification might not assure compliance with Appendix I Limits (p 49).

Lawrence Livermore National Laboratory (LLNL) Effluents Release Analysis i

In conjunction with amounts of radioactivity re)orted in Special Report i

84-07, LLNL was contracted by SMUD to resolve tie concern as it related to I

the calculated doses reported in 84-07 and what the conditions of radio-i activity were in the environment (p 10).

POWERS felt that the Offsite Dose Calculation Manual model (ODCM) was high1 conservative because of the figures in Special Report 84-07 (i.e.,185 n'remf, and the fact-that the Livermore whole body count of maximally exposed individuals indicated an exposure in the low 20 mrems.

POWERS also explained that the whole body count of individuals who stated they congested large amounts of fish were negative (pp 39-41,45).

POWEP,S stated that he does not recall Dr. NOSKIN of the Livermore Laboratory recommending any specific action after the Lab's October 1985 findings of increased activity in downstream sediment (p 51).

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SUMMARY

OF INTERVIEW TRANSCRIPT-WITH RONALD WAYNE COLOMBO DATE INTERVIEWED: 4/3/87 DATE OF

SUMMARY

4/9/87 i

OI:RY CASE NUMBER: 5-86-010 i

Ronald W. COLOMBO, the Regulatory Compliance Superintendent for the Sacramento Municipal Utility District's (SMUD) Rancho Seco Nuclear _ Generating Station (Rancho Seco), was interviewed by Robert G. Marsh, Director Office of l

Investigations Field Office, Region V and Ronald A. Meeks. Senior l

Investigator, Office of Investigations Field Office, Region V.

COLOMBO was interviewed regarding his knowledge of SMUD's management and operation: of the Liquid Effluents Release Program at Rancho Seco. The information listed i

below is a summary of the interview transcript.

Procedures Concerning Liquid Effluents In 1986, SMUD was issued a violation by NRC because a Temporary Modification concerning rework on a shed in the drum storage area-did not go through the Rancho Seco Plant Review Committee (PRC) and receive the proper 50.59 safety j

evaluation (p 44).

If a temporary modification procedure was used for more than 30 days, then it was a violation of the procedure governing temporary modifications and consequently, a violation of SMUD's license.

COLOMB0 felt that knowledge of any violation of the procedure governing temporary modifications should be subject to an occurrence description report which would be channelled to COLOMBO,'who had responsibility for such depositions (pp 67-68,136-138).

Manacement of the Liquid Effluents' Prooram COLOMB0 was responsible for coordinating all input into Special Report 84-07.

Pierre OUBRE, the Plant Manager was responsible for report 84-07 and it was OUBRE who took the report to Ronald J. RODRIGUEZ, the Executive Director, Nuclear, for RODRIGUEZ's signature (p 7).

Arshad ALVI of the Nuclear Engineering Organization, was responsible for the information concerning the pathway of liquid releases to the environment.

In a meeting prior to the issuance of Special Report 84-07, Pierre OUBRE assigned KIELMAN, POWERS, and ALVI certain responsibilities for the Near Term Corrective Actions. Also present at that meeting was Fred KELLIE, Roger MILLER, and Dean C0liSTOCK (pp 11, 13-14, 59).

COLOMBO recalls that BRADLEY, between the time that BRADLEY discussed exceeding Appendix I Limits with COLOMBO, which was after July 1984, and the first meeting on Special Report 84-07 with Pierre OUBRE, commented to COLOMBO that POWERS did not believe in BRADLEY's figures. COLOMBO senses that the chain of command for resolving this matter was not functioning as it should (p 26).

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t COLOMBO stated that OUBRE issued an assignment sheet for corrective action items responsibility on Special Report 84-07 (p 28).

It was COLOMB0's opinion that all modifications, whether temporary or permanent, should go through the PRC to assure that the modification was within the bounds of Rancho Seco's license (pp 34-36).

COLOMBO, who is chairman of the PRC since its inception in 1972, objected to a 1975 Temporary Modification at Rancho Seco. COLOMBO did not recall exactly the nature of the modification but that it was under the guidance of Bob WICHERT. COLOMBO complained to Pierre OUBRE because that modification did not go through the PRC. OUBRE took the stance that there was no need for the modification to have a PRC review and accompanying safety analysis because the change was temporary (pp 37-41).

Over a period of approximately 10 years, COLOMBO spoke to Pierre OUBRE on approximately three occasions about the need for temporary modifications to receive a safety analysis review by the PRC. The modification between the DRCST and the RHUT was one of the Temporary Modifications discussed by COLOMBO with OUBRE.

It was COLOMB0's opinion that a 50-59 Safety Review should be conducted on the DRCST modification due to the fact th6t a pipe could break and radioactive water could be released to the environment.

OUBRE's reply to COLOMB0's stance on this matter was the fact that a man was stationed at the DRCST control valve at any time during a transfer of water fron the DRCST to the RHUT. OUBRE also explained that the activity in the DRCST was below the allowable Technical Specification Limit. OUBRE also explained that plastic or Polysheeting around the PVC pipe would capture the water in the. event of a pipe break. COLOMB0 stated that his conversation with OUBRE on the DRCST rrodification was around December 1982 or January 1983 (pp 45-46, 53, 61).

The DRCST modification was explained to the PRC by Operations Supervisor Don BLATCHLY (p 63).

COLOMBO stated the pathway of the DRCST modification should have been reported in Special Report 84-07 because the pathway added radioactivity to the system that releases liquid effluents to the environnent (pp 64-65).

COLOMBO stated that a few months after the issuance of Special Report 84-07, Pierre OUBRE, in a staff meeting, stated if water was below Rancho Seco's Technical Specification LLD, then it was non radioactive (p 69).

COLOMB0 stated he did not have the authority to cause action to be taken to enforce Rancho Seco's Technical Specification. Such enforcement i

responsibility was with the Operations Superintendent and his managers (p 75).

COLOMBO stated the PRC and the Management Safety Review Committee (MSRC) reviewed the insertion of-the word "not" in the basis of the Radiological Environmental Tech Spec (pp 76-80).

When BRADLEY issued his draft LLD study in October 1985, COLOMB0 requested input from BRADLEY on what the tech spec LLD should be. COLOMB0 stated that question had not been answered to date.

However, COLOMB0 recalled that the 5-86-010 2

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MSRC did review the LLD issue at some point in time in 1985 (pp 90-99).

COLOMBO explained that the counting time on the sample analysis of the RHUT was lowered to a LLD within the Technical S)ecification LLD thus allowino the lower counting time analysis to be within tie definition of non-radioactive releases. COLOMBO, in retrospect, did not agree with lowering the sarple analysis count time and could not defend the position of lowering th9 count time. COLOMBO stated that the commitment made in 84-07 not to release effluents containing radioactivity put Rancho Seco and SMUD managerv.nt in a bind, thus a redefinition of radioactivity had to be made (pp 99, 1J3-104, 112-113).

The MSRC considered the LLNL findings on radioactivity in downstream sediment beds, together with BRADLEY's LLD issue in 1985. COLOMB0 recall', being present at two of these MSRC meetings (p 126).

Rancho Seco Plant Configuration The design of the Rancho Seco plant does not allow, under normal operations, for radioactivity to be released off site. However, with Steam Generator Tube Leaks and the modification which allowed water to be transferred from the DRCST to the RHUT in 1985 and 1986 a pathway was created for radioactive water to be released off site.

COLOMBO stated that the modification was a change to the design of the plant (pp 29-31).

If the modification allowing water to be transferred from the DRCST to the RHUT was not made, then the water would have to remain in the tanks until new storage tanks were constructed. This process would be expensive and time consuming (pp 31-34).

During 1985, continual heat up and cool downs during outages took water from the operations of the plant system causing the tankage to approach the storage capacity at Rancho Seco (p 71).

Effluent Reports to the NRC BRADLEY's calculations on releases of radioactivity contained in liquid effluents put into the environment, subsequent to the implementation of the Radiological Environmental Technical Specification in July 1984, caused the needs for Special Report 84-07 (p 19).

COLOMBO stated that a variance was not needed at the time of the issuance of-Special Report 84-07 because the actions were taken to assure compliance with the recently implemented RETS. COLOMBO explained that the RETS are Appendixes to NRC's license (pp 23-2S).

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SUMMARY

OF INTERVIEW TRANSCRIPT WITH RONALD J. RODRIGUEZ DATE INTERVIEWED: 4/7/87 DATE OF

SUMMARY

4/10/87 OI:RY CASE NUMBER: 5-86-010 Ronald J. RODRIGUEZ, the former Assistant General Manager Nuclear, for the Sacramento Municipal Utility District (SMUD) was interviewed by Robert G. Marsh, Director, Office of Investigations Field Office, Region V and Ronald A. Meeks, Senior Investigator, Office of Investigations Field Office, Region V, regarding RODRIGUEZ's management of SMUD's operatiens of the Liquid Effluents Release Program at the Rancho Seco Nuclear Generating Station (Rancho Seco). The information listed below is a summary of the interview transcript.

Henagement of the Liquid Effluents' Program RODRIGUEZ stated he recalled BRADLEY discussing the LLD issue in terms if all samples were just below Rancho Seco's Tech Spec LLD, then the Technical Specification might be exceeded. RODRIGUEZ did not recall when BRADLEY's explanation or the LLD issue took place. RODRIGUEZ recalled that BRADLEY wanted the CEP data analyzed to determine just what the activity of the releases were in relation to Rancho Seco's Technical Specification (pp 15-17).

RODRIGUEZ stated that BRADLEY explained to RODRIGUEZ that KELLIE had been requested to do a CEP analysis by BRADLEY but that KELLIE did not take any action on this request.

As a result, RODRIGUEZ directed C0 WARD to assure that the CEP analysis was conducted (p 18).

RODRIGUEZ stated that he did not recall any conversations with BRADLEY to hold up the issuance of BRADLEY's draft LLD study until after resolution of a hich point vent break and/or restart (pp 25-27).

RODRIGUEZ did not recall what specific action was taken to assure compliance with the Short Term Corrective Action Item VII of Special Report 84-07 (pp 30-31).

RODRIGUEZ recalled talking to COWARD about the loWring of the sample analysis count time. COWARD had told RODRIGUEZ that the issue was not a problem.

RODRIGUEZ explained that it was C0 WARD's responsibility to assure that the decision to lower the sample analysis count time was proper (pp 32 and 70).

RODRIGUEZ did not recall any specifics concerning KELLIE's June 6, 1985, telephone conversation with NRC's Greg YUHAS. Upon reviewing the record of that telephone conversation, RODRIGUEZ stated that he understood the instructions given by YUHAS clarified the issue on whether detectable peaks should be reported when iden:ified (pp 34-36).

RODRIGUEZ stated he held the 10BRE, COWARD, MILLER, AND KELLIE responsible s-u-os 0 -O*\\ 0

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. to cor.' elate the LLNL findings, comitments made in 84-07 and BRADLEY's LLD issue. RODRIGUEZ stated it was wrong that no one in the organization correlated the LLNL findings, the commitments in 84-07, BRADLEY's LLD issue with the lowering of the sample analysis count time (pp 47-48,72).

RODRIGUEZ did not recall if the issue of "not" being inserted in the basis of

'the Radiological Environmental Tech Specs was brought to his attention.

RODRIGUEZ stated that this item would have been reviewed by the Management Safety Review Committee (pp 52-54).

Rancho Seco Plant Configuration The DRCST modification a M owed the Rancho Seco plant to release excess water which existed since the early 1980's. RODRIGUEZ recalled that the modification was p;obably terminated when the problem of cesium contamination surfaced in conjunction with the Livermore Lab studies (pp 36-38).

RODRIGUEZ could not explain why the DRCST modification was not updated in Rancho Seco's Updated Safety Analysis Report (USAR) because the modification-was a change in the design of the plant. RODRIGUEZ acknowledged that although the modification wcs considered temporary, it existed over a lengthy time.

RODRIGUEZ explained that Robert DIETREICH, the Supervising Nuclear Engineer for Licensing Matters was responsible for updating the USARs. RODRIGUEZ was not aware how the USAR updates were accomplished or the degree of attention that DIETREICH gave to such matters. RODRIGUEZ explained that in mid-1985 DIETREICH reported directly to RODRIGUEZ (pp 38-41).

Effluent Reports to the NRC RODRIGUEZ stated that Special Report 84-07 indicated a variance for continued operations under 40 CFR 190 was not needed because 84-07 explained what actions had already been implemented. RODRIGUEZ further explained this view was supported by NRC's Greg YUHAS in meetings with NRC concerning Rancho Seco exceeding their radiological and environmental Tech Specs. RODRIGUEZ recalls YUHAS stating in these meetings that Rancho Seco had already taken the corrective actions thus SMUD only needed to inform NRC officially of what actions had been taken as it related to whether a variance was needed (pp 7-11).

RODRIGUEZ stated the DRCST modification was a pathway for allowing liquid-effluent releases containing radioactivity to be released to the environment and as such, should have been reported in Special Report 84-07 (pp 42-44).

Lawrence Livermore National Laboratory (LLNL) Effluents Release Analysis RODRIGUEZ does not recall what action he took, if any, regarding the LLNL October 1985 findings on analysis of the downstream creek bed sediment.

o However, RODRIGUEZ did recall that the issue was discussed and considered L

(p 46).

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SUMMARY

OF INTERVIEW TRANSCRIPT OF STEPHEfi C. MANOFSKY DATE INTERVIEWED: 3/24/87 DATE OF

SUMMARY

5/5/87 01:RV CASE NUMBER: 5-86-010 Stephen C. MANOFSKY, presently the Acting Chemical Quality Supervisor for the Sacramento Municipal Utility District (SMUD) at the Rancho Seco huclear Generating Station (Rancho Seco), was interviewed by Office of Investigations' Senior Investigator, Owen C. ShacH eton Jr., regarding MAN 0FSKY's knowledge of SMUD's management and operations of the Liquid Effluents Release Program at Rancho Seco.

MAtl0FSKY has been employed by SMUD for approximately 6j years.

He held the position as a Chemical Radiation Assistert for almost four years.

Then he was made e supervisor in the Chemical Pediation repartnent.

The infornation listed below is a surnary of his interview transcript.

Er.ecial Report ho. 64-07 1.

MAN 0FSKY saw Special Report No. 84-07 before this interview, but he did not read it through.

He was not in anyway involved-in the writing of this report (p 5).

2; He does not recall discussing this document on the site. They l

had discussed not discharging any gamma emitter down Clay Creek

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and took steps to take care of that, at least anything above the Lowest Level of Detection (LLD) (p 5).

l 3.

The only work he did that may have been involved with Special Frrer+ ik. Fa-C1 was write up an Administrative Procedure 22 (fr;. r#t e.. he did thc doco celcula+ione. ha s cri er tre effluert 3.swces?

i

-t releases et that peint in time with the Off Site Dose Q1r W rior (DDU;).

4 Some of the numbers in the report do not look like the same numbers he had worked on.

He, therefore, thinks that the dose report may have come out of the downtown health physics section (p 6).

Contanination of the Secondary System 1.

To his knowledge, steam cenerator tube leaks were the only source of liquid contamination for the secondary system (p 6).

Modification of the Demineralized Reactor Coolant Storage Tank 1,

He wet real familiar with the Demineralized Reactor Coolant Storaos Tank (DDCST).

He was not aware the District had not reprirted to the NRC the modification which allowed the water to be transferred from the DRCST to the RHUTs (p 9),

2.

He was n M involved in any of the engineering for the PVC lines between the DRCST and the RHllTs. He thought all of the notifications to the NRC was taken care of (p 10).

3.

hone of his suDerVision or any members of the District's management discussed this modification and withholding this information from the Comission (p 10).

l 4.

Back in 1985, they were in a long-time outage. They were periodically releasing water to lower their water volume. This was caused because a lot of the water went back to the primary l

to be processed and then discharged as tritated water.

It was traete se thet tt ey did not release as much radioactivity as

+nnu (;C r t;vn i< thre would have just released the water es

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MA':0F5fY es not involved in saving how nuch water beine

.ranr#crrce 'rm the DFIST to the PPU' tents went where.

He-thinks that decision was probably made by operations (p 12).

6.

He has participated in the analysis activity that transpires" before water is released from the RHUTs to the retention ponds (pp 12-13).

7.

All of their releases were to be below the Lowest level of i

Detection (LLD) mentioned in the tech' specs, which were later found to be too high, which was completely unknown to them at the tir>e, They thought they were complying with this by maetine all those lower linits of detection (p 14).

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He did not know they were not in compliance on their effluent releases ur.til the end of 1985 wher 2 9g YUHAS came in and did f

another s rec 51 inspection (p 14).

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C.

He had to sinn for releases. They were looking at a limit that wEs too high to neet the tech specs. That is where the mistake happened. They had read the tech specs as saying those levels

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should be adeouate to meet any Appendix 1 dose criteria (p 15).

10. They were always under the impression that

.y did meet Appendiy. I dose commitments by meeting the LLD's in Technical Specifications 3.17.1 and 4.21.1 (pp 16-17).

11. He was familiar with the draft issued by Ed BRADLEY on the lower limits of detection on October 29, 1985.

He stated the t-way BRADLEY first laid it out, his procedure was not even plausible because of the way he omitted specific information on the isotopes (pp 17-18).

1 ir rne r~ o 7.0 BP A DL E V ' t recorrenc'ations, thev s tarted er r ;

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nonreir--*',vc H*L the rarir -

i activt, and sending those off for mora analycis and garra scans l

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50 ti!? they could reach a lower -LLD.

By that point in time, the rajority nf the releeses had already happened (p 18).

13 Fred l'ELLIE authorized a lowering of.the counting time on the analysis of the RHUT samples.

They were still meeting all the i

LLDs (p 19).

14 As he remembers the lowering of the counting times was' discussed and everybody was under the ' impression they were meeting all the Appendix I criteria and everything else (pp 19-20).

15.

They have always recorded or reported the positive peaks when they showed up on the gamma scan, regardless of whether they're lower than the LLD or not (p 21),

i 16.

Tc meet the criteria, they are now counting for 4000 seconds

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ene somtires 6000 seconds, dapending upon what the background l

1; in the semples (p 2M.

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What w?s never given to them before were the numbers that they actually had to reach. They may have been discharging radio-l active material, but it wasn't detectable and it was below the

. 1 LLD linits (p 24).

l 18.

Ir essence, what they did was change their criteria and raised their count time (p 24).

19.

He did not know who was responsible for collecting and maintaining records of water transferred from the DRCST to the RHUT. He thought operations was keeping track of that (p 26).

4 l

20.

He was never involved in any discussions regarding whether or l

not the modification that had allowed the transfer of water

'rv '.he DD

+hr DuMT Should be made known to the NRC c,

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21, in closirg he stated he did not think, on this whole subject of discharging effluents, that anyone was intent on committing any crir.inal acts or becoming negligent on this procedure.

They alweys looked at it f rom the public standpoint (p 30).

22. He never had anyone in his supervision request or direct him to omit information from his reports regarding gamma emitters and releases of effluents from the site,

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1 Re orted by:

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,y h M.'

.e Owen C. Shackleton Jr.

f Senior Investigator Office of Investioctions Fiele Office, Pcgion V f

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SUMMARY

OF INTERVIEW TRANSCRIPT l

OF HARRY L. CANTER s

Date Interviewed: 3/25/87 Date of Summary:

5/11/87 OI:RV Case Number: 5-86-010 On March 25, 1987, Harry L. CANTER, the former Senior Resident NRC Inspector at Rancho Seco was interviewed by Investigator Philip V. Joukoff, regarding I

CANTER's knowledge of liquid effluent releases and transfers at Rancho Seco during the time period that he was the Senior NRC Resident inspector at the site.

CANTER advised that he was currently employed by SMUD and that prior to being employed by SMUD, he was employed by the Nuclear Regulatory Comission.

CANTER advised that whil,e a member of the NRC, he was assigned as a Senior Resident Inspector at Rancho Seco from July 1979 through January 1984 CANTER was questioned regarding his knowledge a temporary piping modification that was installed to move water from the DRCST tank to the RHUT tanks.

CANTER stated that he could recall that for a number of years there was a PVC temporary piping going between the two tanks in question.

CANTER stated that he could not recall exactly when this temporary modification was put in place, however, he could recall " tripping over that thing for a number of years."

CANTER added that the modification was "more or less" the standard of transferring water.

CANTER recalled that there was a tremendous amount of discussion among the SMUD personnel at meeting which CANTER attended regarding the temporary piping modification and that a number of discussions with the NRC were held regarding the modification in question.

CANTER added that NRC inspectors from the Region V office also came to Rancho Seco and discussed the modification.

CANTER added that he knew that the NRC knew that the modification existed, however, he was not exactly certain of when he first became aware of the modification.

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CANTER advised that he could not recall what the requirements were for SMUD officials to notify the NRC of the modification.

CANTER recalled that he notified Harry NORTH'of the RV NRC office about the piping modification, and to the best of his knowledge, this occurred in the early 1980's, however, CANTER.was unable to tell exactly when he made this notification.

CANTER averred that NORTH took some action regarding the modification, but CANTER could.not recall what that action.

CANTER recalled that at some point in time, possibly during a exit interview with the licensee, that the subject of the modification was brought up, however, CANTER could not recall when this

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occurred.

CANTER stated that he could not specifically remember the reason for the modification and added that for some reason SMUD had to transfer a large quantity of water from the DRCST tank to off site and that such transfer would have to go through the RHUT tanks as they are the path that water takes to be released off site.

CANTER added that the reason for the release could have been in conjunction with the steam generator tube leaks.

CANTER was questioned regarding any conversation he had with Ron COLUMBO, SMUD, concerning a review of this modification and CANTER stated that he could not recall any details of any such meeting.

CANTER added that his recollection was that the modification was discussed in the Plant Review Committee and the Management Safety Review Comittee meetings and CANTER knew there was discussions about funding to install a permanent piping system from the DRCST to the RHUT tanks. CANTER recalled that funding this permanent installation had a lot to do with the delay in putting permanent piping in.

CANTER stated that he considered the PVC piping system that was installed at the plant to be a temporary system. CANTER added that he felt that the piping system was installed as a consequence of steam generator tube leaks.

CANTER stated that while he was at Rancho Seco, the other NRC Inspector at the site was a Jack O'BRIEN and that O'BRIEN also was aware of the temporary piping modification as was CANTER's supervisor, Tolbert YOUNG.

CANTER added that another NRC employee, Jerry ZWETZIG may also have known about the modification. CANTER advised that it would have been normal for him to refer i

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a matter like this temporary modification to Harry NORTH, as he was the principal health physics inspector at the plant. CANTER advised that he did not have the authority while at Rancho Seco te authorize a modification such as the piping system ~ involved in this case.

i l-Prepared by:

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