ML20055E315
| ML20055E315 | |
| Person / Time | |
|---|---|
| Site: | San Onofre, Rancho Seco  |
| Issue date: | 10/11/1988 |
| From: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20055C206 | List:
|
| References | |
| EA-86-110, NUDOCS 9007110289 | |
| Download: ML20055E315 (17) | |
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EMORANDUM FOR:
J. B. Martin, Regional Administrator Region Y 4
FROM:
James Lieberman, Director
.I Office of Enforcement J
SUBJECT:
EA 86-110 RANCHO SECO RADICACTIVE EFFLUENT DISCHARGE Now that D0J has declined prosecution on this matter the staff needs to j
formulate a final position.on the enforcement issue.
The enclosed draft i
enforcement action is essentially the same as the one your staff proposed some months ago.
Please have your staff review the draf t and provide any comments to Jim Luehman at 492-3280. As in all enforcement cases involving i
01 investigations timeliness of enforcement is a real consideration.
- However, given that at the time your office proposed the original action a significant length of time had already sassed since the violations occurred and corrective actions had been taken by t1e licensee, I do not see that the situation has changed much since then.
Therefore I do not see any overriding reasons why the basic proposal should be changed now.
Also enclosed is a draft Commission paper on this sub, ject.
The paper represents what I think is an accurate sumary of the discussion held between our offices, j
OGC, and NRR in late 1987. Again please have your staff provide Jim Luehman any comments on the paper.
Finally since extensive staff discussions have already taken place we should be able to move fairly quickly to forward the staff's position to the Comission for considerstion and thereby minimize the l
further lack of timeliness associated with this matter.
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James Lieberman, Director Office of Enforcement L
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D. Crutchfield, NRR L. Chandler, OGC P
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The Commissioners From:
Victor Stello, Jr.
f Executive Director for Operations
Subject:
Proposed Notice of Violation and Proposed Imposition of i
Civil Penalty concerning compliance with 10 CFR Part 50, Appendix ! by Sacramento Municipal Utility District (EA86-110) purpose:
To present and explain to the Commission the staff's view relative to the issues discussed in the report which, in part, differ with the 01 conclusions.
Discussion:
During the period of April I to May 23, 1987 an NRC radiation protection specialist from NRC Region V conducted a special unannounced inspection at Rancho Seco to review the Sacramento Municipal Utility District's management' of radioactive materials released in effluents during 1985. The inspection which is documented in NRC Inspection Report No.- 50-312/86-15, identified a number of apparent violations concerning the licensee's improper implementation and control of the plant's u
radioactive effluents program.
These violations resulted in radioactive effluent releases such that during calendar year 1985, a member of the public could have received a total body dose in excess of the Technical specification limit of 3 mrem. The dose calculated for 1985 using the licensee's Offsite. Dose Calculation Manual was approximately 3.9 mrem.
The technical issues discussed in the report were the subject of ongoing dialo ue between the licensee and Region V and they were large resolved within a few months after the inspection.
No en orcement action was taken by the staff based on the possibility that the violations were committed knowingly and willfully by SMUD managers and employees (corporateandplant).
The matter was then referred to 01 by the Region in a memorandum dated June 13, 1986.
Contact:
James Lieberman, OE x20741 L
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The Consissioners-Investigation Report 5-86-010 was issued by 01 on October 16, 1
1987 and concluded that the evidence and testimony collected during the investigation demonstrated that "the entire chain of command from the SMUD Assistant General Manager, Nuclear, through the Rancho Seco Operations Manager, j
Nuclear Engineers Plant Managers, and Radiation Protection 1
Supervisors participated in or had knowicdge of the repetitive creation of false records and made false reports j
to the NRC on recurring occasions." By another memorandum also dated October 16, 1987 01 forwareil the investigation i
report to the staff for review. The memorandum stated that a copy of the investigation report had been provided to the Department of Justice for prosecutional review. */
q Upon completion of the staff's review of the O! report it l
was concluded that willful violations of the requirements may have occurred.
However, given the complex nature of the technical issues and the information collected by 01, the staff is unable to conclude that:
(1)thechangingof i
the sample count times discussed in the O! report was not due to.a misunderstanding of the requirements rather than a willful attempt to cover-up the discharge of radioactive material and (2) the temporary modification that cross-connected the primary and secondary water storage systems did not exist because of inadequate design review rather than a willful attempt to use this temporary system to discharge radioactive material. Additionally, given the
'j fragmented nature of the lines of responsibility for-oversight of the programs it may be that:
(1)theplant staff did not know of or at least did not fully understand the concerns.of the corporate health physicist who first raised the issues concerning 10 CFR Part 50, Appendix I L
requirementsand(2)managerswithinthelicensee's corporate organization did not follow-up that individual's L
concerns because of their lack of understanding of the l
technical issues and because they received assurances from their staffs that there was no significant problem. For these reasons, the staff concluded that there was not sufficient evidence to find that by a preponderance of o
the evidence, willful violations occurred.
Further investigation might conclusively prove the case for willful violations but, the staff sees the investment of further resources as unnecessary given the total restru-*uring of the licensee's organization that has taken place since the time of the violations.
Nevertheless, the staff was not satisfied with the performance of SMUD personnel. During the staff's review
- / The Department of Justice declined prosecution in a letter dated September 23, l
1988.
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The Commissioners 1 of the O! report it became apparent that at_ a minimum certain managers and supervisors at SMUD who may have had
-continuing-responsibilities in the licensee's programs to
. control and monitor radioptive effluents were either not technically qualified to be involved in such activities or-had been at least negl.igent in administering the programs, Therefore, in a. letter dated December 23, 1987, the staff.
requested,pursuartto10CFR50.54(f),thatthelicensee q
provide additional information concernfog the basis for the utility's confidence in the personnel administering the-
' radiological effluents programs, The licensee responded to o
the staff's request in a letter dated-January. 25, 1988, 4
thatconcludedbystating"thosepersonnel[previously involved in programs to control radioactive effluents] are
.o either no longer employed at Rancho Seco or will be- -
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reassigned e'br to startup to positions in which they A
will hau tw Mne management responsibilities "
1 Recomendation:
The staff.;;6 ends to issue the Notice of Violation and
-Proposed Imposition of Civil Penalty for the violation
'ofrequirementsgoverning(theRanchoSecoradioactive s
liquid d fluent-programs Enclosure.2) two weeks from the p
date of. this paper, unless the Comission directs otherwise.
Coordination:.
OGC has no legal objection to this paper,
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P Victor Stello, Jr.
p Executive Director for Operations -
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Enclosures:
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Inspection Report 3 i
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Draft Notice of Violation 3
and Proposed' Imposition of-Civil Penalty Ia
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Docket No. '50-312
. EA 86-110'
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Sacramento Municipal. Utility District 1
Rancho Seco Nuclear Generating Station i
ATTN:
G. Carl Andognini l
Chief Executive Officer Nuclear a
14440 Twin Cities Road d
Hearld, California 95638-9799 Gentlemen:
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SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY-
"i (INSPECTION REPORT NO.
50-312/86-15)
This refers to aLspecial NRC inspection conducted at Rancho Seco by members of the NRC staff-during the period of April'1, 1986 through May 15, 1986, of y
activities authorized by NRC License No. DPR-54. The subject inspection 1
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0 report was transmitted to you by separate correspondence-dated June 6,1986, j
An enforcement conference related to the inspection findings was held at the RegionLV office on June:20,-1986, with members of the. District staff.
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. on the results of-this-_ inspection and discussionsiduring the enforcement conference, it appears that certain of tyour' licensed activities were not, conducted in full compliance with NRC requirements, j
Thel apparent violations set forth in the enclosed Notice of Violation and i
- Proposed Imposition of Cive Penalty (Notice) demonstrate a failure of the District to implement'its technical specification requirements to preclude -
1 release'of-liquid' effluents.containing radioactivity in amounts exceeding the_-
dose criteria set.forth in 10 CFR 50, Appendix I; evaluate changes-to the
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facility as required by 10 CFR 50.59; maintain and implement procedures and e
report the release of radioactive material in-effluents as prescribed in the
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-facility Technical Specifications. These apparent violstions and inspection findings'present a picture of how the District'during 1985, in spite of R
commitments made in the, letter; dated' September 24, 1984, accomplished only the~ minimum that was perceived as required and ended up with a very inaccurate n
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. record of radioactive releases made during 1985.
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We' have received and. reviewed your July 3,1986 and October 8,1987 letters j
describing your corrective ections in response to the inspection findings. We also acknowledge your continuing. efforts to improve your performance in the 1
area of radioactive effluents,as well as many other areas since the plant was shutdown.- As the two letters referenced above limited themselves largely to corrective actions of a technical and programmatic nature, by a letter dated
_ December 23, 1987 the NRC sent you a request for information under the provisions of 10'CFR 50.54(f) asking for your assessment of the management and personnel considerations surrounding the inspection findings. Your evaluation of those areas was provided in'a: letter dated January 25, 1988 which has been reviewed A
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Sacramento Municipal
-2 Utility District by the NRC staff. Notwithstanding all the information you have provided concerning those issues as well as the relative age of the violations ~ involved, the continuing nature of the violations is seen as especially significant by 1
the NRC.
To emphasize the'importance of establishing and adhering to approved procedures,.
I performing safety evaluations and to avoid unnecessary releases of radiation to the environment, I have been authorized, after consultation with the Director, Office of-Enforcement and the Deputy Executive Director for Regional Operations,.
to issue the enclosed Notice in the amount of $100,000 as set forth in the enclosed Notice.
In accordance with the " General Statement of Policy and
.ProcedureforNRCEnforcementActions,"10CFRPart2,AppendixC(1988),the violations described in the enclosed Notice have been collectively classified as a Severity Level III problem.
The base value of a civil penalty for a 1
Severity Level III problem is $50,000. The escalation and mitigation factors
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in the Enforcement Policy were considered and based on your past performance-and significant breakdown in the management controls for radioactive effluents an adjustment of 100% has been deemed appropriate.
You are required to respond to this~1etter and should follow the instructions
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specified in the enclosed Notice when preparing your response.
In your y
_ response, you should document the specific' actions taken and any additional 1
actions you plan to prevent recurrence.. After reviewing your response to i
this Notice, including'your proposed corrective actions, the NRC will determine whether further NRC enforcement action is necessary to ensure
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compliance with NRC regulatory requirements, i
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," Part 2 L
Title 10, Code of Federal Regulations, a copy of this letter and the j
enclosure will be placed in the NRC's Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
L Sincerely, L.
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lz John B. Martin L
Regional Administrator a
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Enclosure:
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Proposed Imposition of Civil Penalty ec w/ encl:
J. Vinquist, SMUD K. A. Meyer, SMUD State of California
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b yo NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Sacramento Municipal Utility District Docket No.
50-312 Rancho Seco Nuclear Generating Station License No. DPR-54 EA 86-110 During an NRC inspection conducted during the period April 1, 1986 through May 15, 1986, violations of NRC requirements involving control of radioactive effluents were identified.
In accordance with the " General Statement of Policy and Procedures-for Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the Nuclear Regulatory Commission proposes to impose a civil penalty) pursuant to Section 234 of the Atomic Energy Act of 1954, as amended ("Act", 42 U.S.C.
-2282, PL 96-295, and 10 CFR 2.205. The violations and associated civil penalty are set forth below:
A.
10 CFR 50, Appendix 1. Section lY B reads:
"_The licensee shall establish an appropriate surveillance and nonitoring program ~to:
1.
Provide data on quantities radioactive material released in liquid and gaseous effluents to assure that the provisions of paragraph A of this section are met:"
Contrary to the above requirement, as of April 1,1986, an adequate surveillance program was not established to provide data on quantities of radioactive material released in liquid effluents to assure that the provisions of paragraph A of 10 CFR Part 50, Appendix I were met.
B.-
10CFRPart50.59(a)(1),inpart.. reads:
"The' holder of a license authorizing operation of a production or utilization facility may (1) make changes in the facility as described in the safety analysis report, (ii) make changes in the procedures as.
described in the safety analysis report, and (iii) conduct tests or experiments not described in the safety ' analysis report, without prior Commission approval, unless the proposed change, test or experiment involves.a change in the technical specifications incorporated in the license or an unreviewed safety question."
The updated FSAR submitted July 22, 1982 and subsequent amendments through July, 1985 provide information in Section 11. Radioactive Waste and Radiation Protection that:
"During normal plant operations, the Rancho Seco Nuclear Generating Station is designed not to release any liquid effluents containing radioactivity of plant origin to the environment. All potentially radioactive wastes are processed by degasification, filtration, demineralization, and/or evaporation to remove radioactive and nonradioactive components.
Radioactivity removed by these processes is retained within the filter cartridges and exchange resins and concentrated evaporated bottoms for offsite disposal in drums by an NRC-licensed disposal contractor."
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' Notice-of Violation: '
Contrary to the above requirement, from January 1983 through' March 13, 1986, procedures and temporary system modifications were implemented and radioactive water was pumped from the Demineralized Reactor Coolant Storage ' sank (T-621) through a temporary conduit.to either Regeneration 3
Hold-up (T-950 A or B) and ultimately released to the environment and no evaluation was performed to determine if a change in the Techn! cal Specifications was required or if an unreviewed safety question was 1
involved.
C.
Technical Specification 4.21., Liquid Effluents, requires:in part that:
"The radioactivity content of each batch of radioactive liquid waste to be discharged shall be determined prior to release _by sampling and analysis in accordance with Table 4.21-1..." Table 4.21-1 requires in
. part that each batch waster release tank be sampled prior to release and analyzed for Cs-134 and Cs-137.
Footnote (c) of Table 4.21-1 reads in-part:
"Other peaks which are measurable and identifiable, together with the listed nulcides,_shall be identified and reported."
Technical Specification 6.9.2.3, Semiannual Radioactive Effluent Release R oort,. reads in part 6.9.2.3.1:
"The radioactive effluent release: reports shall include a summary of the quantities'of radioactive liquid and gaseous effluents and solid waste released from the unit as outlined in Regulatory Guide 1.21,
' Measuring Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Redioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants,' with data summarized on a ' quarterly basis, following the format of Appendix B thereof."
Regulatory Guide 1.21 reads in Paragraph B.2: -
"In'many cases the criteria-for sensitivity of effluent measurements.
have been modified to reflect ns low as practicable dose considera -
tions'in the offsite environs; 1.e., the sensitivity of effluent measurements should be sufficient to detect concentrations which,-
when dispersed in the offsite environs, would result in a dose to individuals of a small fraction of natural background radiation."
and Paragraph C.10
The sensitivity limits given for radioactivity analyses in Appendix A.of.this guide are based on the potential significance in the environment of the quantities of radioactive materials released.
For some radionuclides, lower detection limits than those given herein may be readily a:hievable and when measurements below the stated sensitivity limits are attained, the results should be recorded and reported."
Contrary to the above requirement, on June 4,1985 isotopic analysis of a' batch of radioactive liquid waste (B RHUT 85-98), identified measurable concentrations of Cs-137 (2.33 E-7 4.9 E-8 uCi/ml) which were not identi-fied or reported on the Rancho Seco Radioactive Liquid Waste Release Permit p.t..,
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Notice of Violation 85-98orintheSemiannualEffluentReleaseReport(RJR85-491)forthe'
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' period January 1 through June 30, 1985. Analyses of releases on June 6, 1985(85-99)~andJune 17.1985(85-110) also found measurable concentra-tions of Cs-137 which were identified but not reported.
D.
Technical Specification 3.17.2., Dose, reads:
"The dose or dose commitment to a member of the pubile from radioactive materials in liquid effluents
. released beyond the r.ite boundary shall be limited:...
P "b..During any calendar year to 3 mrem to the total body and to 10 mrem to any organ."
Contrary to the above requirement, during calendar year-1985, radioactive materials in liquid effluents were released such that a member of the public could have received a total body dose -in excess of 3 mrem when
-calculated in accordance with the methods described in the Technical Specifications.
The dose calculated for 1985 using the-licensee's Offsite Dose Calculation Manual was approximately 3.9 mrem.
Technical Specification 6.8, " Procedures," reads in part that, " Written E.
procedures shall be established, implemented and. maintained covering the
' activities referenced below:
- a. The applicable procedures recomend -in Appendix :' A' of Regulatory Guide 1.33, November 1972." Regulatory Guide 1.33, November 1972, recomends in G., " Procedure for Control of Radio-activity (For Limiting Materials Released to Environment and Limiting Personnel Exposure) " that procedures be developed for liquid radioactive waste systems-including discharging of effluents.
1.
Contrary to the above requirement, from' March 30, 1983 to January 6, 1986,-and from March.6,-1986'through March 30, 1986, no procedureL was maintained which controlled the transfer of radioactively con--
taminated water from the Demineralized Reactor Coolant Storage Tank (T-621) to the Regenerated Hold-Up Tanks (T-950 A and B) for ultimate release to the environment. During 1985' about 787,500 gallons were transferred from T-621 to T-950 A and B and released:to=the environment.
2.
Technical Specification 6.8.3 reads:
" Temporary changes to procedures of 6.8.1 above may be-made provided:
6 a.
The intent of the original procedure is not altered...
b.
The change is documented, reviewed by the PRC nd approved by the Plant Superintendent within seven-(7) e of implementation."
7 Contrary to the above requirement, on January 6,1986 a temporary change to Procedure A.10, " Demineralized Reactor Coolant Storage System" was approved and implemented whichtallowed
) umping waster from T-621 to T-950 A and B for offsite release wit 1out review by the Plant Review Comitment (PRC).
From January 6,1986 to March 6, 1986 the licensee estimates that about 350,000 gallons water were transferred.
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The above violations, A, B, C, D, and E, have been categorized in theaggregateasaSeverityLevelIllproblem(SupplementsIandIV).
Civil Penalty - $100,000 - assessed equally among the violations.
Pursuant to the provisions of 10 CFR 2.201, Sacramento Municipal Utility-District (licensee) is hereby required to submit a written statement or iexplanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory
,y Commission, within 30 days of the date of this Notice. This reply should be b;
clearly marked as a " Reply (1) admission or denial of the alleged violation, to a Notice of Violation" and should include for each alleged violation:
(2) the reasons for the violation if admitted (3) the corrective steps-that-have been taken and the results achieved, (4),the corrective step that will be taken to avoid further violations, and (5) the date when full compliance will be achieved.- If an adequate reply is not received within the time s)ecified-in this Notice, an Order may be issued to show cause why the license siould not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration maybe given to extending the response time for good cause shown.
Under the authority of Section 182 of the Act,'42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response required above under 10 CFR
'2.201,-the~11consee may pay the civil penalty by letter to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to the Treasurer of the United States in the amount of the civil penalty proposed above. or the the cumulative amount of the civil penalties if more than one civil penalty is proposed, or may protest
-imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. -Should the licensee fail to answer within the time specified, an Order imposing.the civil penalty will be issued. Should the licensee elect-to file an-answer in accordance with 10 CFR 2.205 protesting the civil genalty, in whole or in part, such answer should be clearly marked as'an Answer to a Notice of Violation" and may:
(1) deny the' violation listed in this Notice in whole or in part (2)demonstrateextenuatingcircumstances, (3)_showerrorinthisNotice,or{4)show-otherreasonswhythepenaltyshould-not be imposed.
In addition to protesting the civil penalty, such answer may-request remission or mitigation of the penalty.
In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1988), should be addressed, f
Any written answer in accordance with 10 CFR 2.205 should be set forth separately-from the statenant or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of, the 10 CFR 2.201 reply by specific reference L
-(e.g.,citingpageandparagraphnumbers)toavoidrepetition. The attention of the licensee is directed to the other provisions of 10 CFR 2.205, regarding
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the procedures for imposing a civil penalty.
Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may
'be referred to the Attorney General, and the penalty, unless compromised,
-remitted or mitigated, may be collected by civil action pursuant to Section 234c to the Act, 42 U.S.C. 2282c.
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Notice'of-Violation ~
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-The responses to the Director,' Office of Enforcement, noted above Reply to a Notice of Violation, letter with payment of civil penalty, and Answer to a 1
-Notice of Violation should be addressed to: Director,' Office of Enforcement,-
. U.S. Nuclear Regulatory Commission,' ATTN:
Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission Region V..1450 Maria Lane, Suite 210, Walnut Creek, California and a. copy.to the NRC Senior Resident inspector, Anthony J. D'Angelo.. Rancho Seco.
FOR THE NUCLEAR REGULATORY COMMISSION i
1 John 8. Martin Regional Administrator Dated at Walnut-Creek,-California this day-of October 1988.
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