ML20055E311
| ML20055E311 | |
| Person / Time | |
|---|---|
| Site: | San Onofre, Rancho Seco  |
| Issue date: | 07/27/1988 |
| From: | Blume M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | White R FRIEDMAN, COLLARD & POSWALL |
| Shared Package | |
| ML20055C206 | List:
|
| References | |
| NUDOCS 9007110286 | |
| Download: ML20055E311 (16) | |
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UNITED STAT 88
[
m NUCLEAR REGULATORY COMMISSION s:
nam 0N V wee MARIA LAwt. sutra tw i
WALNUT CREEK CALIFORNIA e4006 5385 July 27, 1988 l
R. Parker White Es Friedman, Collard & quire Poswall
)
7750 College Town Drive, Suite 300 Sacramento, Ca 95826 (by next-day de' live'y) r
SUBJECT:
Brace v. Sacramento Municipal Utility 1
UTTUTcI TriTTToMiTa Tuperior court "or Sacramento County, Case No. 337598)
Dear Mr. White:
l This letter confirms my conversation this morning with your secretary, Ms. Elizabeth Gibbons, concerning the subpoena 2
issued on July 18, 1988.for the July 29, 1988 appearance of Mr. Greg Yuhas of.thisioffice.
Based on that. conversation, it is my understanding that at i
this time you do not intend to cal 1~ Mr. Yuhas to appear at i
the above-referenced trial, and that if you should need to do so at a11ater date, you will contact _me to discuss the Nuclear. Regulatory Commission's requirements concerning such l
an a)pearance.
For your. convenience, I am enclosing a copy of tie Commission's regulations on the subject, o
l 10 CFR 9.200, et seq.
Based on our understanding, we will;not at this-time file a motion to quash the subpoena.
Thank'you for your cooperation on this matter.
Should you l
need to contact me, you can reach me at (415) 943-3737.
l;.
Yours truly, ha.-
l Michael B. B1'ume Regional Attorney i
Enclosure a/s cc:
Clerk, Superior-Court bcc Neil Jensen. 000 Greg_Yuhas, RV e
S 9007110286 90062 PDR. ADOCK 05000 O P
F iC
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- L. 9.*'l08(c)
PART 9 o PUBUC RECDRDS
'any meetir. closed f[m)'For purposes of this subpert the i
- (c)In the ease ol b
froin whero discovery is or will be l, the Secretary of ter ' employee of the NRC** includes all sought, areas of inautry, length of pursuant to 6 0.10 the Comtniasion. ' spon the advloe of I NRC personnel as that term a defined in time away from duty involved. and the General Counsel and af ter consul
- E l 9.3 of this part. includmg NRC identification of documents to be used in each deposition, t here appropriata.
tation with the Cc mrnission, shall de* a contractors.
I, transcript or inLn. '~
(c) The General Counsel w!!! notify termine which, if 1,ny, pertions of the
, electronic recordin
- l utes and which, if any, items of infor*
(c) This subpart is intended to pro-the employee and such other persons,
- mation withheld pursuant to l 9.106(c) vide instructions regarding the inter.
u circumstances may warrant, of his i
I or her decision on the matter' contain informaticn ahich should be nal operations of the NRC and is not ah withheld pursuant to I 9.104, 'n the intended, and does not, and may not, 4 p.203 Procedure e here response to R event that a requent for the recording, be telled upon to create any right or demand le required prior to receiving transcript, or rn nutes la received benefit. Substantive or procedural, en-g,,g,,,gg,,,,
within the period 4 uring which the re.
forceable at law by a party against the cording, transcripi, or rninutes must NRC.
If a responte to the demand is re.
t ed, unde pararraph (b) of 6 9.201 Prodvetion or diectosure prohibit
- fh ener C unse rec ve1 a ed unless approsed by appropriate U.S. attorney or NRC attorney desis.
MC ofMmL nated for the purpose shall appear to) If at some 1 6ter time the Com' No employee of the NRJ,, shall,in re*
with the employee of the NRC upon missien determinei that there is no sponse to a demand of a court or other whom the demand has been made, and further justification for withhoklint judicial or quul judicial authority, shall furnish the court (r other au.
arry tranactlpt, recording or other item produce any materini contained in the thority t'ith a copy of the regulations of information frcen the public shich flies of the NRC or disclose, through contained in this subpart and inform has previously been withheld, then testimony or other means, kny infor.
the court or other authority that the such information i hall be made avail.
mation relating to material contained demand hu been, or la belnt-as the ablo in the f!!es of the NRC, or disclose any a 1 9.199 Report to Ccnrreen-information or produce any insterial 3 case may be, referred for the prompt to he on ens egard g he C to mp y of al d t ooI C
8 i
i g mission,a compilante with the Govern-clk1 status without prior approval of the court or authority te stay the i
r the General Courtsel of NRC.
E demand pending receipt of the re-
= ment in the Bunst ine Act, including a quested instructions. In the event that
' tabulation of the t >tal number of open g g.203 Procedure la the event of a an immediate demand for production meetings, the totsi number of closed d, mend for prodvetion or discloeure, or disclosure is made in circumstances meetings, the reuins for closing such = (a) Prior to or simultaneous with a which would preclude the proper des.
meetings and a de,cription of any titl* I demand upon an employee of the NRC Ignation or appearance of a U.S. or gation brought trainst the Commis. E for the production of material or the NRC attorney on the eroployee's alon pursuant to the Government in a disclosure of information described in behalf, the employee shall respectful.
the Sunshine Act< including any cost ' l 9.200, the party seeking production ly request the demanding authority assessed against he Commission in 2 or disclosure must serve the General for sufficient time to obtain advice of such litigation (* hether or not paid by Counsel of the NRC with an affidavit counsel
- the Commissiont,
or statement as described in para-graphs (b) (1) and (2) of this section.
0 9.264 Procedure in the esent of an ad.
Whenever a demand is made upon an
,erse ruling.
~
Subpert D-Productlen er Disclosure employee of the NRC for the produc-In Response le Subpeones or D.,
tion of material or the disclosure of in.
If the court or other judicial or enende of Ceurts er Other Authorl*
fortnation described in i 9.200, that quaal. judicial authority declines to employee shall immediately not!fy the stay the effect of the demand in re-N" General Counsel. If the demand is sponse to a request made in accord-f 9.200 Scope of subpart, made upon a regio tal NRC ernployee, ance with ( 9.203 pending receipt of in-that employee shall immediately structions, or if the court or other au.
(a) This subpart r,ets forth the pro-nottfy the Regional Counsel who, in thority rules that the demand must be cedures to be followed when a subpoe-turn, shall immediately request in-compiled with irrespective of instrue.
g na, order, or other demand (herein.
structions from the Oeneral Counsel.
tions not to produce the material or i
, after referred to as a ' demand ) for (bX1)If oral testimony is sought by disclose the Information sought, the
- the production of NRC records or dis
- the demand, a summary of the testi.
employee upon whom the demand has g closure of NRC information, including mony desired must be furnished to the been made shall respectfully decline to g testimony regarding such records, is General Counsel by a detalled affida*
comply with the demand, citing these issued by a court or other judielal or vit or,if that is not feasible, a detailed regulations and United 3fales em reL quast judicial authority in a proceed
- statement by the party seeking the Touhy v. Ropen. 340 U.S. 462 (1951).
ing, excluding Federn) grand jury pro-testimony or the party's attorney, ceedings, to which the NRC is not a This requirement may be walved by
~
party, Information and documents the General Counsel in appropriate subject to this subpart include:
circumstances.
Appenda A l removed) 50 FR $0283 (1) Any material contained in the (2) The General Counsel may re-files of the NRC; quest a plan from the party seekink, (2) Any information relating to rna.
discovery of all demands then reason-terial contained in the files of the ably foreseeable, including but not
- NRC, limited to, names of all NRC personnel i
9 15 December 31,1987
.. ~
SACRAMENTO MUNICIPAL UTILITY DISTRICT OFFICE MEMORA400M CCF 88-568/SWM to:
Distribution Datt:
August 29, 1988 Propwed tw:
Pa'ted MuVphy Reviewed tw:
- Y 48 Approved tw/
Eric"Yoch im SUSJECt SECONDARY SIDE WATER MANAGEICNT Attached is an update (88-11) of the secondary water data currently trended by Chemistry and the Effluents and Water Management Project.
The last issue was August 8.
This data is for information only.
Included is a brief summary which defines each parameter and indicates how the data was collected and reduced.
Upcoming editions will gradually expand to cover primary side water management and its impact on affluents as well.
Data for the last three months has so far been entered into a data base manager; it will be distributed once some software anomolies are resolved.
Hiahliahts:
o The total volume of radioactive liquid affluent released through the RHUTS is holding at 72 percent of the value projected for this time in the year (20 Mgals annually per.
basis of TS 4.21.2).
o As of August 22, the dose to the most restrictive offsite individual (adult whole body) was 0.684 mrem, roughly 35 percent of the annual Appendix I limit prorated for this date.
Two Condensate Polishers were changed during the last three o
weeks.
However, because the sluice water was directed to the Spent Regen Tanks, no activity spikes were observed in the RNUTs.
This helps substantiate the hypothesis that the Polisher sluice water contributes the large majority of the liquid affluent source term.
PO-2 was-responsible for a very slight increase in offsite o
dose.
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t Distribution 2
CCF 88-568/SWM Discussient Graph 1 of the current total volume of liquid effluent (9.2-Mgals). indicates that the rate of waste water generation is holding constant at 28 gpa (72 percent of that assumed in the i
basis of TS 4.21.2).
i Graph 2 show the waste generation rate on a per tank basis.
The scatter in this data is exaggerated because of the
{
calculation method (see sheet attached).
The range for.the last eight RHUTs was 22 to 42 gpm with an average of. 32 gpa.
Generally the gradual trend toward a smaller generation rate following the startup was not sustained because of Hotwell draindowns and DRCST transfers.
During the last three weeks, draindowns, occurred on 8/6, 8/10, and 8/15.
DRCST to - RMUT J
transfers took place on 8/2 and 8/16 for a total of about 120,000 gallons so far this year.
i.
Per Graph ;3, roughly 68 percent of the water released through L
the Retention Basins comes from the RNUTs.
The rest (4.3' i
Mgals so far this year) comes from effluent diverts due to Mi
[
radiation, conductivity, or Hi/Lo pH alarms.
The majority of i
i this water results from manual diverts prior release of the~C i
RHUT performed by the operators to preclude auto divert due to the. exceptionally high conductivity in C RNUT.
The "RMUT fraction" has held constant at 68 percent for all of 1988.
As shown in Graph 4 the total plant effluent flow rate as measured by FR95108 averages 8930 gpm so far this year..This value. is higher than the minimum annual average flow rate of 8500 gpm (basis of TS 4.21.2) and is trending upward.
This is
)
good since tho' dose from releases goes down as the dilution goes up.
The reason for the unusually high rate in May is not known specifically.
However, this was the first full month' of operation of the flow recorder after it had been raranged from 0-10,000 to 0-30,000 gpa.
Taking credit for flows over-10,000 gpa would not account for the large difference, but there was.
some maintenance done on the ranging mechanism as well.
The cesium activity in Graph 5 fa; RNUTs 88-75 through 82 stayed at the exceptionally low levels characteristic of the shutdown.
During the last three weeks, two polishers were exchanged (see discussion below).
For these sluice E
evolutions, the Polishing Domin Sump was temporarily directed to the Spent Regen Tanks, and no significant increase in RHUT activity occurred.
This helps confirm the hypothesis that.the Polisher sluice water contr:.butes almost all of the activity to the plant effluent.
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Distribution 3
CCF 88-568/SWM
'As of August 22, the dose to the most restrictive offsite individual (adult whole body) plotted in Graph 6 was 0.684
- mRea, roughly 35 percent of the annual Appendix I limit prorated for this date.
While.our standing is excellent, the RCS activity will increase as we ascend in power, and the degree of steam generator tube integrity at higher power
)
levels is not known, i
Per Graph 7 the cumulative volume of makeup water (DMW) so far this year is 11.60 Mgals; this corresponds to an average rate of 34.3 gpm which has remained stable during power operation.
As plotted in Graph 8,
the volume of water associated with regenerating the Makeup Domineralizers is holding at roughly 1
30 percent of throughput.
This value is much higher than the
)
ameunt anticipated by the vendor (5.2%).
Note that if this' water.(presently 3.41 Mgals) were directed to the A and B RNUT j
instead of C RHUT, the cumulative volume of radioactive water 1
released would be 97 percent of the 20 Mgals " limit" for this point in the year.
In Graph 9, the number of makeup system cation regenerations is consistent with the manufacturer's recommendations.
- However, anion and mixed bed resin - regenerations are more frequent mainly because the present conductivity ~ specification
)
is considerably lower than the design basis for the equipment.
As shown-in Graph 10, the last Polishers changed out-(B and F) both had run times of 102 days.
This exceeds the desired minimum duration of service for this -resin (90 days).
Generally, runs should be limited to a hundred days or so to stagger the changeouts; this provents the operational difficulty associated with having multiple polishers " break"'
simultaneously.
Secondary plant chemistry is excellent.
Graph 11 has some inaccuracies in date (x-axis).
However, it-shows qualitatively that the DRC5T water level went down by two feet on 8/2 and again on 8/16 as a result of transfers to the RHUTs.
This increase on 8/5 came from the RC holdup tank in preparation for operation of the Boric Acid Concentrator (BAC).
Operation of the Miscellaneous Waste Evaporator (MWE) 8/9 through 8/12 caused the second increase.
On 8/23 and 8/24 there transfers of DRCST water to the Spent Fuel Pool.
Graph 12 illustrates the reactor power history.
As noted above, there was a small increase in offsite dose following the PO-2 outage.
This occurred because only three Polishers were in service rather than the full compliment of eight at 80 percent power or greater.
Note that a larger variety of isotopes were observed at this time.
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CCF 88-568/SWM I
Please contact me if you have programmatic concerns on this i
issues specific questions regarding the preparation of the data should be directed to Peter Murphy at extension 4578.
Attachments:
Parameter Definition Sheets Graphs 1-12 Distribution:
J. Firlit B. croley D. Xeuter J. Shetler J. Vinquist B. Xemper
- 8. Redeker C. Rowland A. Fraser T. Tucker e
D. Tipton i
Shift Supervisors (6)
OTAs (6)
F. Xellie D. Gardiner G. Larson B. Wilson i
M. Leinwander M. Sullivan G. Ruszala J. Atwell t
u X. Sqibbs i
R. McAndrew L
-R. Mannheimer i
R. Huebner S. Melancon l
i
i SECONDARY WATER MANAGEMENT Trended Parameters 1.
RHUT Discharges The cumulative total of waste water radioactive and nonradioactive) released to the Retention Basins from(both the Regenerative Holdup Tanks (T 950 A and B).
The main sources of water to these tanks are the Condensate Polishing Area Sump (PDS), the Condenser Pit l
Sump (CPS) via PDS, Aux Boiler Blowdown, the Makeup Domineralizer sump when C RHUT is isolated, transfers from the Domineralized Reactor Coolant Storage Tank (DRCST, T 621), and some Tank Farm storm drains.
The data comes from
-the Liquid Discharge Permits (LWR) index presently maintained by Radiation Protection.
The projected volume is a linear interpolation of the 20 million annual release volume assumed in developing Lower Limits of Detection (LLDs) in Tech Spec 4.21.
2.
Liquid Waste Generation Rate -
Average flow rate of waste water entering the RHUTs (T 950 A and B).
The rate is calculated by dividing the volume of the RHUT. at isolation by its duration of service.
The volume comes from the LWR index, and the length of time the tank was in service comes from the Water Operator Logs.
The horizontal line at 38 gpm represents an average generation rate' corresponding to an annual waste water volume of 20 million gallons used in the Tech Spec 4.21 basis.
- 3. Retention Basins
- The cumulative volume of water discharged to Clay Creek through the Retention Basins as taken from the Liquid Effluent Log (LEL).
The volume is estimated based on difference in basin level.
The volume is larger that the - RHUT volume because the Basins also receive diversions from the nonradioactive plant effluent when out of specification on chemistry or radiation.
4.
Total Plant Effluent
- The average flow rate of the total plant effluent.
The total volume released per month is taken from Chemistry data l
based on the totalizer attached to FR 95108 which is divided by the number l
of minutes in the months to obtain the rate.
This is compared to the l
average flow in the basis for TS 4.21.2.
5..
Cesium 137 Released in Liquid Effluent -- The cumulative amount of Cs-137 activity (uC1) released from the RHUTs (T 950 A and B) as indicated from the Release Permit data.
The projected is the amount of Cs-137 which would reach the Appendix ! dose commitment of 3 mrem at the end of the year.
This includes the contribution of other isotopes assuming they are present in their historic mix.
L 6.
Adult Whole Body Dose --
The adult whole body is the most restrictive offsite receptor from the liquid pathway.
Data is taken form the LEL.
7.
Plant Makeup Water --
The total volume of water passing through both treins of the Makeup Domineralizers.
Data is taken from the Water Tour and Inspection forms completed by the Watershack operators.
Specifically, the difference in totalizer readings is used.
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C RHUT
- The cumulativ6 total water volume discharged offsite through f
the C RHUT.
This parameter indicates the volume of waste water produced by regenerating the Makeup Demins.
It also included waste water associated with the conductivit The volumes come from the Water Operator Logs.y meters in that train.If no number was given, a tank lev (approximately 86,000 gallons) was assumed.
This method does underestimate the regeneration wastes because the M/V Deimin sump is lined up to the other RHUTs when C RHUT is isolated prior to release.
The historical average value comes from a conservative estimation of the water saved = by constructing the C RHUT.
The-calculation.
EP-CRHUT, estimated the number of regenerations by dividing the total flow through each domin and dividing by the estimated throughput before regeneration.
The amount of waste water produced with each regeneration was estimated from
. i the-Cochrane Vendor procedures.
The volume of conductivity cell waste was obtained by direct measurement of the flow rate and assuming cc.itinuous operation.
The projected value is alta derived from the Cochrane manua* which states
)
that the amount of waste water produced during retienerations is approximately 5.2 percent of the throughput.
This line on tie graph is 5.2 percent of throughput as indicated from graph 4.
]
- 9. Makeup Domineralizers Shows the number of regenerations for each -
domin so far in 1988.
The data is taken from the Water Operator Logs.
- 10. Polisher Rosin Replacement -- Data is taken from the Watershack Operator Logs.
The parameter is an indicator of secondary plant water chemistry and provides a basis for estimating the contribution of polisher sluice water to the RHUTs (1 transfer requires roughly 3,000 gpm),
- 11. DRCST Water level -- Data taken from Operations crimary side water inventory sheets.
This parameter may be a precursor to DRCST transfers to the RHUTs for release offsite (primary inventory reduction).
12.
Reactor Power History -- Taken from Chemistry Lab Logs.
NOTE:
Monday was used as the start and end of the week except for DRCST level (Friday).
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t 1 ~ raitA e w.4 ~ \\ TOTAL PLANT EFFLUENT 1988 11000 5 MONTHY RVG suss Lu1 10000 ll l, h gg L ' y weas e 1.p' y.. ::. _ Mi!!N .!!j.sf v ano g .lb E $lI j !"8000 ! J L!s? {}. l!j . gggg i 8 ~ ! JL li e l g 3 m., S /000 i L:.2 ' AS6 -sgy u. i l
- -2. m.f i
ih[!i! .. Mi ' '~"- 6000 1 h b ;!i l g! i JRN FEB MFR FFR 14W JUN JUL CEM DRTR TIME _ 2..
'N n, 1 CESIUM-137 RELEASED c CUMULRTIVE TOTAL 1988 i 8000 O ACTURL a fFPEN]IX ' I 1 7000 L i i. u i 6000 n l i u 5000 2 t u (M ~ ~ i l F 3000 u t i x [ .-r o c o-o o o o o-o l 2(XX] / o i 1000 o-o *_o -o-o
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/ Ou-60-o-o4 o o o oO:oxr "" - i 0 4 8 12 16 20 24 28 32 t+ttCilVE REUST 22 TIE (WEEKS) I Jm lyes e Afa i maw u naw ,m LM i L .._._,..,,,,,m._,, _.. _ ~. _..., _..... _.,.. _...
624M & l ~ ADULT WHOLE BODY DOSE RESULTING FROM LIQUID EFFLUENTS i (CUMULATIVE 1988) , 2.5 l o RELERSED a FFPENJIX I i 2.0 .a r r i n l E 1.5 3 a: l z j v i-u; 8 1.0 i o c/o 0.5 0.0c 0 6 -- O 1 >** 2 ** 3 w -4
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7 8"' 8 4**- 9 LEL Oftti,II'WE FEUST 22) TIE (MNTHS) i 1 i I
i. ddLAfw 7 ~ PLANT MAKEUP WATER ~ CUMULRTIVE VOLUME IN 1988 i 16 o o HISTERICFL C 1985) 14 1 i l t i m ACTUAL (CATION) i 12 m.m i m m J 10
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