ML20055D919
| ML20055D919 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 04/14/1989 |
| From: | Marsh R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Miller R AFFILIATION NOT ASSIGNED |
| Shared Package | |
| ML20055C226 | List:
|
| References | |
| FOIA-90-76 NUDOCS 9007100149 | |
| Download: ML20055D919 (1) | |
Text
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April 14, 1989 Mr. Roger I. Miller V 0 ear Mr. Miller:
Per your request, your investigative interview is enclssed.
Sincerely, 4
Robert G. Marsh, Director Office of Investigations Field Office, Region Y
Enclosure:
As stated Distribution:
5-86 010 Reading Information in IM in accordance viilh I, ik:cd dI
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tKLE00M OF lflFORMATlotl ACT REQUEST Donnie H. Grimsley, Director M"fD=%
Division of Freedom of Information and Publication Services Offices of Administration and W* h Resources Management UNITED STATES NUCLEAR REGULATORY COMMISSION Washington, D.C.
20555 Re:
Freedom of Information Act Request
Dear Mr. Grimsley:
As you will recall, on November 3, 1988, a Freedom of Information Act request was made on behalf of persons living within the vicinity of the Rancho Seco Nuclear Power Plant with respect to the United States Attorney's criminal investigation of Sa'cramento Municipal Utilities District employees following the discharge of radioactive liquid waste water at the plant.
A portion of this FOIA request was referred to the Nuclear Regulatory Commission.
See your FOIA number 89-2.
The NRC has previously produced those records it supplied to the U.S. Attorney's Office as part of the U.S. Attorney's investigation into possible criminal indictments against SMUD employees.
I am now initiating a separate request on behalf of persons living within the vicinity of the Rancho Seco Nuclear Power Plant for further NRC documents.
L
-Pursuant to Title 5, U.S.C. Section 552, request is hereby.
made for any and all documents, letters, interviews, statements, and any other tangible things or effects regarding the Nuclear Regulatory Commission's investigation of liquid radioactive discharges from the Rancho Seco Nuclear Power Plant leading up to the determination to impose regulatory penalties upon the Sacramento Municipal Utilities District in'or about Januat=f, 1989.
Request is further made for any and all documents, letters, interviews, statements, and any other tangible things or effects regarding the discharge of radioactive liquid effluent from the SW
- 7
~
Page 2 of 2 Donnie H. Grimsley, Director February 14, 1990 Rancho Seco Nuclear Power Plant following the assessment of penalties by the NRC against SMUD in or about January, 1989, i
Application is also hereby made for waiver of fees in l
connection with this request on the ground that the information i
primarily benefits the general public.
In addition, many of the people upon whose behalf this FOIA request is made, are persons l
who have qualified for in forma pauperts protections under California law.
A response to this request is to be provided within twenty days pursuant to applicable Federal law.
Very truly yours, FRIEDMAN, CQ RD & POSWALL 4
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BARRY ERMAN BAZ:rh 1
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a SACRAMENTO MUNICIPAL UTILITY DISTRICT 6201 s Street. Po Bom 15830. sac ntp CA 958521830.1916 452 3211 AN ELi CTRIC SYSTEM SERVI 1 Jill 11p A 1,,OF CALIFORNI A lir,".~,.
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' January 5, 1987 Robert G. Marsh Office of Investigation Region V U. S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek CA 94596
Dear Mr. Marsh:
The enclosed revisions provide edditional clarification of our December 2, 1986 response to your liquid effluent inquiry. This matter was discussed with Mr. Ron Meeks on December 22, 1986.
Thankcyou for your consideration.
Sincerely,
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. Ward
. Deputy General Manager, Nuclear 1
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RANCHO SECO NUCLEAR GENERATING STATION ^ 1444o Twin Cities Road, Herald, CA 95638 9799;(209) 333-2935 D-D -Cl O EMM
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Table 3 - Chemicals Intentionally Added to Water Systems and the Maior
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System in which it Occurs.
1.
Lithium Hydroxide Reactor Coolant 3.
Sodium Hydroxide Regeneration (Ion Exchange)
System 4.
Ammonium Hydroxide Feedwater 5.
Hydrazine Feedwater, CCW and NSCW
- 6. -
Morphaline Component Cooling Water -
Nuclear Service Cooling Water 7.
Sulfuric Acid Circulating Waterj Regeneration (Ion Exchange) System 8.
Alum-Clarifier 9.
Sodium Hypochlorite Nuclear Service Spray Ponds 10.
Chlorine Circulating Water, Sewage Effluent 11.
Nitrite-Borax Mixture Chilled and Heating Water System >
12.
Ambitrol Diesel Generators Coo ing' Water i
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MMIUP gTORM POtaOM i
I-RECENERATION __
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MATER 8083fH SYSTEM CANAL WATER i
9r REGENERANT STOMM N TA8en ORA 5
-' I RETENT m
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am CONDENSATE DEMINERALIZERS
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II REGENERATION U Y OttuteON MAD $ELVlLLE sump CREEK Ak I.
COOLING TOWER DRIFT "DOllNG==.
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FIGURE 1 WATER SYSTEM FLOW DIAGRAM (SIMPLIFIED) i 9
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t TABLE 1 WASTE WATER INPUTS TO THE RETENTION BASIN AREA A.
Various Drains / Backwashes 1.
Backwash from reservoir supply line filter.
2.
Drain from cooling towers.
3.
Circulating canal overflow.
4.
Overflow from nuclear service spray ponds.
5.
Backwash from nuclear service spray ponds.
6.
Area drain from chemical storage tanks.
7.
Drain from auxiliary boiler area.
8.
Drain from hydrochlorite tank.
9.
Backwash from service water filters.
10.
Blowdown from cooling waters, 11.
Drain desludge and overflow from clarifier.
12.
Drain from service water pumps.
13.
Overflow and drain from condensate storage tank.
14.
Sewage treatment system.
15.
Turbine deck drains.
16.
Transformer area drains.
B.
Sumps - Detailed Inputs Presented in Table 2 1.
Polishing Demineralizer Sump.
2.
Condenser Pit Sump.
9b 12/23/86
l' Both modifications installed a temporary line of ' PVC -
(Schedule 80) piping to the RHUTs.
Prior to use after 1985, the temporary piping was hydrotested, barrier taped and-radiation area posted.
The tanks were drained via the temporary piping pursuant to an abnormal operating procedure 6
with required walkdowns every one-half of an hour. Prior to 1985, this evolution was not controlled by formal procedure.
The concentration of tritium in the DRCST and the NWHUT was ~5 MPC (1 MPC = 3E-3 uCi/ml). 10 CFR 20.106 and Appendix B to 10 CFR 20 limit releases off-site to 1 MPC.
The water transferred to the RHUTs was sufficiently diluted prior to release-off-site to assure the 1 MPC limit would not be violated.
These temporary modifications were changes to the facility as described in the USAR- (Reference 1).
Because the changes were only temporary, the USAR was not updated to reflect the temporary system operation.
The temporary modification of transferring DRCST water to the RHUTs is being incorporated to becomo a permanent modification to the plant.
12/23/86
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USAR SECTION DESCRIPTION OF CHANGE REASON FOR CHANGE operating the to minimize the miscellaneous water environmental impact of evaporator.
liquid waste processing.
- 11. ~. 1 Paragraph added describing The District conducted compliance of Rancho seco a review to ensure that Design Shielding with the Rancho Seco design NUREG-0737, Item II.B.2.
shielding complies with the guidelines of NUREG-0737, Item II.B.2.
Table 11.3-2 Addition of three channel Formerly, it was only 11.3-7 process radiation monitor possible to monitor atmosphere.
the air in the reactor building or the air downstream of the HEPA and the purge duct.
The three additional channels monitor make i
it possible to monitor the air in the reactor building.
Table 11.3-2 Range of waste gas surge The range of the 11.3-10 tank monitor changed.
monitor was formerly inadequate to measure the discharge from the waste gas surge tank (V-650).
Table 11.3-2 Polisher domineralizer The polisher domin-11.3-10 area sump monitor R15020 eralizer sump is moved to-waste we.ter upstream of the discharge.
regenerator holdup tanks, which are the release point for waste water.
Waste water may reach the tanks downstream of the polisher demin sump.
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SACRAMENTO MUNICIPAL UTILITY DISTRICT C P. O. Box 15830. Sacramento CA 95852.MDMW) 452<3211 AN ELECTRIC SYSTEM SERVING I;HC HEART OF CALIFORNIA 91 GCI -9 A O 140 OCT 0 81987 i
GCA 87-483 x
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i U. S.. Nuclear Regulatory Commission L
Attn:
J. B. Martin, Regional Administrator Halnut Creek,.CA 94596 n.
E3 DOCKET NO. 50-312 E,,T 2 p
RANCHO SECO NUCLEAR GENERATING STATION p
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LICENSE NO. DPR-54 re REVISED RESPONSE TO APPARENT VIOLATIONS IDENTIFIED IN NRC INSPECTION REPORT _,,
JL NO. 86 >
Dear Mr..Hartin:
?'
y By letter dated July 3,1986, the Sacramento Municipal Utility District i
provided specific responses to the-apparent violations relative to'the-control
'or releases of liquids from the Rancho Seco site identified in NRC Inspection Report No.'DPR 54 86-15.
Subsequent to the implementation of the commitments documented in July 3,1986 response, the District initiated alternativa controls for ensuring' compliance with the dose limitations specified in 10 CFR 50. Appendix I.
The new L
procedural controls have been presented to the NRC and the concepts-for procedural control are embodied in Proposed Amendment No. 155, which was y
transmitted to the NRC on June 30, 1987.
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RhNCHO SECO NUCLEAR GENERATING STATION 1444o Twin Cities Road. Herald. CA 95638 9799;(209) 333 2935
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<i; GCA 87-483 l.i.
J.B. Martin '
Recognizing the improvements which have been made at Rancho Seco in ensuring compliance with the offsite dose guidelines of 10 CFR 50, Appendix I', the.
District hereby modifies the July 3,1986 response to apparent violations identified in NRC Inspection Report No. 50-312/86-15.
.This revised response replaces our previous response in its entirety.
Sincere.ly,
./'
//.,,)dy.' i.%kwas J.
Gf Carl Andoghini Chief Executive Officer,
. Nuclear Attachment cc w/atch:
G. Kalman, NRC, Bethesda (2)
A. D'Angelo NRC, Rancho Seco 1
F. J. Miraglia, NRC, Bethesda
ATTACHMENT REVISED RESPONSE TO APPARENT VIOLATIONS IDENTIFIED IN NRC INSFECTION REPORT NO. 50-312/86-15 ADoarent Violation. 86-15-01:
(Summary reprinted in part from NRC Inspection Report 86-15)
"As of April 1, 1986, since the Radiation Protection-Superintendent apparently believed that the LLD values presented in T.S. Table 4.21-1.
were adequate to meet Appendix I, no other appropriate monitoring program had been established to provide data on quantities of radioactive material released in liquid effluents to assure the dose criteria of Appendix I were met.
Failure to establish appropriate surveillance and monitoring procedures represents an apparent violation of 10 CFR 50, Appendix I".
l l
District Resoonse Procedures have been revised to require a minimum count time of 4000 seconds l
for all samples of RHUT A & B releases to the environment.
Procedure AP.305-13, Environmental Releases of Liquid Radioactivity, has been revised to provide better documentation on quantities of radioactive material b
released in liquid effluent.
The changes include:
1 sampling and analysis of every RHUT A & B volume transferred to the retention basins composite of all RHUT A & B volumes transferred to the retention basins l -
placing a complete set of documentation for each RHUT A & B release to the retention basin in a folder for routing and signature approval I
Retaining a copy of the complete set of documentation while the original is being routed for signature specifying a screening analysis of batch volumes of liquid. transferred l
to the RHUT A & B from only primary systems and liquid radioactive treatment systems.
This requirement for pre-transfer sampling and analysis will be superseded by the Technical Specifications once L
Proposed Amendment No. 155 is approved by the NRC, L
Proposed Amendment No.155 to the Rancho Seco Technical Specifications L
corrects discrepancies between LL0s for 10 CFR 20 and 10 CFR 50, Appendix I compliance.
The proposed specifications provide Lower Limits of Detection sufficient to assure that environmental releases of plant effluents are maintained within all applicable regulatory limits.
(...
Accarent Violation. 86-15-03: (Summary reprinted in part from NRC Inspection Report 86-15)
.s
" Failure to report positive results for Cs-137 activity which was identified and measured on June 4, 6 and 17,1985, in liquid effluent releases 85-98, 85-99 and 85-110 in the Semiannual Radioactive Effluent Release Report dated September 26, 1985, is considered an apparent violation of T.S. 4.21."
District Resoonse:
Procedures have been revised to better identify and report quantities of radioactive material in liquid effluent discharged to the environment.
The District submittal, Special Report 86-08 dated June 5, 1986 (JEH 86-087),
provided an estimate of the quantity of radioactive material 'n liquid effluent discharged to the environment during 1985.
This information was included in the January - June 1986 Semiannual Radioactive Effluent Release Report (JEH 86-375), dated August 28, 1986.
Aoparent Violation. 86-15-05: (Summarized from NRC Inspection Report 86-15)
~
"The estimated quantity of radioactive material in liquid effluents discharged to the environment in 1985 appears to result in a calculated dose that is an apparent violation of T.S. 3.17.2.
It is reasonable to expect that no real member of the public actually received a dose greater than this value as a result of the liquid releases made during 1985."
District Resoonse:
In the District transmittal to the NRC dated June 5, 1986 (JEH 86-085), Special Report 86-08, the District acknowledges that the best estimate of the radio-active material in-liquid effluent discharged to the environment in-1985 resulted in a calculated dose to the maximum hypothetically exposed individual that was in excess of the values specified in T.S. 3.17.2, Liquid Effluents, Dose.-
Procedures have been revised to include the RHUT composite sample analysis results into the 30 day dose projection calculations. These projections ensure that offsite doses do not exceed the requirements of 10 CFR 50, Appendix I.
The 1985 Annual Radiological Environmental Operating Report included an environmental assessment and estimated a maximum potential exposure of 2 mrem to a member of the public during 1985. -
Apoarent Violation bb-15-07:
(Reprinted from the NRC Inspection Report 86-15)
"The installation of a piping system specifically intended to transfer 3
water from the liquid radioactive treatment system to the RHUTs for release to the environment without first performing a safety evaluation is considered an apparent violation of 10 CFR 50.59."
. District Resoonse:
The temporary piping in question was removed in April 1986 and its re-installation would not be allowed without proper 10 CFR 50.59 evaluations in accordance with procedures which are currently in effect.
At the time the temporary piping was installed, the AP.26, Abnormal Tag Procedure. pertained only to electrical equipment, not to mechanical.
It was, therefore, necessary to use the temporary change provisions of AP.2, Review, Approval and Maintenance of Procedures, which at the time did not require a 50.59 determination for all' temporary changes to procedures and temporary modifications to plant systems.
Accarent Violation. 86-15-09: Apparent Violation of T.S. 6.8 (reprinted in part from NRC Inspection Report 86-15)
" Based on review of the Procedural Change Approval Form and discussions with the Principle Regulatory Compliance Engineer, it appears that on January 6,1986, a temporary change to Procedure A.10. Demineralized Reactor Coolant Storage System, was approved and implemented which allowed piping water from T-621 to T950 A and B for offsite release without review by the Plant Review Committee (PRC).
From January 6, 1986 to March 6, 1986, the licensee estimates that about 350,000 gallons of water were transferred.
In addition, the inspector noted that AP.2, Revision 21, Review. Acoroval and Maintenance of Procedures, had not been developed consistent with this T.S. in that it does not require temporary changes to be reviewed by the PRC.
The Principle Regulatory Compliance Engineer informed the inspector on May 21, 1986, that this issue had been previously addressed by the PRC and that they believe the previous NRC Senior Resident had agreed that the review of non intent changes to procedures could be delegated to a Group Supervisor, reviewed by the PRC Chairman and approved by the Plant Superintendent. The inspector commented that if T.S. 6.8.3.c were revised, their technique would be considered acceptable.
In any case, the inspector considered the revision to A.10 to be an intent change in view of the FSAR information.
Failure to implement and maintain procedures is considered an apparent violation to T.S 6.8.
The establishment, implementation, and maintenance of procedures is a management function.
It is the inspector's conclusion that the proper establishment of these procedures considering the guidance provided in IE Circular No. 80-18:
'O CFR 50.59, Safety Evaluations for Changes to Radioactive Waste Treatment Systems, could have resulted in recognition of the need to perform a 50.59 review, update the FSAR, and assure proper sampling of T-621 prior to transfer such that compliance with T.S. 3.17.2 could have been achieved." !
9-Q1ttrict Resoonse:
l,i The District has reevaluated the guidance in IE Circular No. 80-18.
Procedure AP.2 and T.S. 6.8 have been reviewed in light of the above discussion and revised as necessary.
The approval process of having the PRC Chairman screen procedures was discussed with the NRC in 1984 and found appropriate according to the Technical' Specification requirements.
Training has reviewed the guidance in IE Circular No. 80-18, AP.2, and T.S. 6.8, and current training modules pertaining to 50.59 determinations.
Improvements to the 50.59 training have been made as necessary and training has been provided to District staff performing 50.59 determinations.
Should there be any questions regarding this revision of the District's response to the apparent violations, please contact Ron Colombo at (916) 452-3211, extension 4236.
- of UNITED STATES 6
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- U OFFICE OF INVESTioATioNS FIElo OFFICE. REoloN V b q,,,*
WA N T CREEK ANFo NIA 596 November 27, 1967 Mr. Thomas Flynn Assistant U.S. Attorney 650 Capitol Mall, 3305 Sacramento, California 95814
Reference:
U.S. NRC Case File 5-86-010 Rancho Seco Nuclear Generating Station
Dear Mr. Flynn:
Enclosed is a copy of a memorandum submitted to me from the NRC official for administering the health and safety aspects of the NRC License at Rancho Seco.
.It is self-explanatory and should be factored into your analysis of the subject investigation.
I hope the tour of Rancho Seco was helpful as well as interesting. Do not hesitate to call me if there-is any thing I can assist with during your revieni of the case file.
Sincerely,
.AOM Robert G. Marsh, Director Office of Investigations g
Field Office, Region V
Enclosure:
As stated RfM7fMfQd
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r November 27, 1987 Mr. Thomas Flynn Assistant U.S. Attorney 650 Capitol Mall, 3305 Sacramento, California 95814
Reference:
U.S. NRC Case File 5-86-010 Rancho Seco Nuclear Generating Station
Dear Mr. Flynn:
Enclosed is a copy of a memorandum submitted to me from the NRC official for
- administering the health and safety aspects of the NRC License at Rancho Seco.
It is self-explanatory and should-be factored into your analysis of the subject investigation.
I hope the tour of Rancho Seco was helpful as well as interesting. Do not hesitate to call,me if there is.any thing I can assist with during your review of the case file.
Sincerely, Robert G. Marsh, Director Office of Investigations Field Office, Region V
Enclosure:
As stated Distribution:
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J W SMUD SACRAMENTO MUNICIPAL UTILITY Di&TRICT C P. o. Box 15830. Sec,emento CA 95852 1830.(916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEART OF CAltFORNIA January 25, 1988 GCA 88-018 U. S. Nuclear Regulatory Commission Region V, Office of Inspection and Enforcement 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 ATTENTION:
Mr. J. B. Martin, Regional Administrator DOCKET No. 50-312 RANCHO SECO NUCLEAR GENERATING STATION LICENSE NO. DPR-54 SUIL7ECT:
Response to Reference (1)
REFERENCES:
(1)
Letter, dated December 23, 1987, from John B. Martin, Regional Administrator, to G.
Carl Andognini (2)
Letter, dated July 3, 1986, from John E. Ward, Assistant General Manager, Nuclear (Acting), to J. B. Martin, Regional Administrator (3)
Letter, dated October 8, 1987, from G.
Carl Andognini, Chief Executive Officer, Nuclear, to J. B. Martin, Regional Administrator (4)
Inspection Report No. 50-312/86-15, dated June 6, 1986
Dear Mr. Martin:
This letter is submitted in response to the request for information contained in Reference (1).
Specifically, Reference (1) requests that, in addition to the description of corrective actions taken and to be taken pursuant to References (2) and (3),
I provide:
(i) my " assessment of the management and personnel considerations surrounding the inspection findings" set forth in Reference (4) (the " Inspection Report"), and (ii) my " views on, and the basis thereof, whether (I) have full faith and confidence in the present management personnel who were, or may have been, involved in these matters such that similar performance is precluded in the future."
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- 862/6biaW (y RANCHO SECO NUCLEAR GENERATING STATION D 14440 Twin Cities Road, Herald, CA 95638 9799;(209) 333 2935
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Mr. John B. Martin January 25, 1988 GCA 88-018 After careful review of the findings in'the~ Inspection Report and the subsequent investigations conducted by the Rancho Seco organization respecting such findings, I have concluded that the findings resulted directly from the exercise of poor judgment by some managerial personnel primarily as a result of:
(i) a lack of knowledge and understanding of the complex art of measuring radioactivity of liquid samples, (ii) failure in communications, (iii) ambiguous provisions of the technical specifications, (iv) inadequate work procedures, (v) inadequate administrative procedures respecting changes in the plant and the conduct of radioactivity analyses and the review of such changes, (vi) inadequate training, and (vii) the absence.of quality assurance audits and controls (the Quality Assurance Department-responsibilities have recently been defined in this area).- These causes collectively precluded the focus by management and others on attention to detail.
The' foregoing assessment is stated intentionally in generalities in light of the ongoing investigations respecting these matters.
Suffice it~to say, that I believe the corrective action described in-Reference (3) and the changes made over-the past year in the I
Rancho Seco organization, personnel, procedures, and culture give assurance that recurrencelof the poor performance cited in the Inspection Report will be precluded.
With respect to "present management personnel who were, or may have been, involved in these matters", I can report that those personnel are either no longer employed at Rancho Seco or will be reassigned, prior to restart, to positions in which they have no line-management responsibilities.
Sincerely,
,4(.
G Ca An gnini Chief Executive Officer, Nuclear Sworn to and subscribed before me this s26' day of January, 1988.
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Notary Public u
omcat sua cc:
Dr. Thomas Murley
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NUCLEAR REGULATORY COMMISSION
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j OFFICE OF INVESTIG ATioNs FIELD OFFICE, REGloN V WALNUT CREEK, CA Fo NIA 5%
l Februa ry 17, 1988 MEMORANDUM FOR:
Gregory P. Yuhas, Chief Facilities Fadiological Protection, Region V FROM:
Robert G. Marsh, Director Office of lovestigati.ons Field Office, Region V
SUBJECT:
MEETING WITH ASSISTANT U.S. ATTORNEYS This is to confirm with you the meeting with Assistant U.S. Attorneys.
Tom Flynn and Janet Gnidstein to discuss information on Rancho Seco Nuclear Generating Station's release of radina tive effluents.
This meeting is schedule for Friday, February 26, 1988, 9:00am at the U.S. NRC Region V
- office, fk
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Robert G. !!arsh, Director Office of Investigations Field Office, Region V w
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February 17, 1988 MEl'ORANDUI'i FOR:
Gregory P. Yubac, Chief Facilities Fadiological Protection, Region V FROM:
Robert G. Marsh, Director Office of Investigations Field Office, Region V
SUBJECT:
MEETING WITH ASSISTANT U.S. ATTORNEYS
-This is to confirm with you the meeting with Assistant U.S.- Attorneys, Tom Flynn and Janet Goldstein to discuss information on Rancho Seco Nuclear Generating Station's release of radioactive effluents. This meeting is schedule for Fridey, February 2f>, 1988, 9:00am at the U.S. NRC Region V office.
M Robert G. Marsh, Director Office of Investigations Field Office, Region V Distribution
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