ML20247F115
| ML20247F115 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 10/16/1987 |
| From: | Hayes B, Marsh R NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20247F042 | List:
|
| References | |
| FOIA-89-2, FOIA-89-A-7 5-86-010, 5-86-10, NUDOCS 8905300006 | |
| Download: ML20247F115 (55) | |
Text
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United States / !
Nuclear Regulatory Commission id;y;',,/
N Report of Investigation Rancho Seco Nuclear Generating Station Material False Statement, Conspiracy to
. Conceal the Presence of Radioactive Nuclides in Liquid Effluents Released to the Environment,
- and Violations of 10 CFR 50 Requirements to j
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Limit Radioactivity Exposure to as Low as Reasonably Achievab e (ALARAD Office of Investigations Reported by 01: RV
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Title:
RANCHO SECO NUCLEAR GENERATING STATION MATERIAL FALSE STATEMENT, CONSPIRACY TO CONCEAL THE PRESENCE OF RADI0 ACTIVE NUCLIDES IN LIQUID EFFLUENTS RELEASED TO THE ENVIRONMENT, AND VIOLATIONS OF 10 CFR 50 REQUIREMENTS TO LIMIT RADIOACTIVITY EXPOSURE TO AS LOW AS REASONABLY ACHIEVABLE (ALARA)
Licensee: Case Number: 5-86-010 Sacramento Municipal Utility District Report Date: October 16, 1987 P.O. Box 15830 Sacramento, California 95813 Control Office: 01:RY Docket No.: 50-312 Status: Closed Reported by: Approved by:
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Robert G. Marsh, Director Robert G. itarsh Director Office of Investigations
. Office of Investigations ;
Field Office, Region V Field Office, Region V Approve y:
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IMin T. Hayes, DiretVf Office of Investigal ns Participating Personnel: L Michael CILLIS, NRC Region V, Health Physicist Philip Joukoff, Office of Investigations, Region V, Investigator Ronald A. Meeks, Office of Investigations, Region V, Investigator Owen C. Shackleton Jr., Office of Investigations, Region V Investigator l
WARNING - ;
The attached document / report has not been reviewed pursuant to l 10 CFR %2.790(a) exemptions nor has any exempt material been deleted.
Do not disseminate or discuss its contents outside NRC. Treat as l
"0FFICIAL USE ONLY." ,
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SYNOPSIS This investigation was initiated on June 13, 1986, based on a Request for Investigation from the Regional Administrator, NRC, Region V. The purposes of this investigation were to: '-
- 1) Determine if the Sacramento Municipal Utility District (SMUD) officials responsible for managing the Rancho Seco Nuclear Generating' Station (RANCHO SECO) had made material false statements to the NRC concerning releases of radioactive liquid effluents during calendar year 1985.
- 2) Determine if SMUD managers and employees conspired to conceal plant design modifications and operations, and manipulated chemistry and testing records in such a way that radioactive releases would not be detected or known by the NRC and public.
- 3) Detennine if SMUD managers and employees conspired to conceal radioactive releases that exceeded Federal Regulations 10 CFR 50, Appendix I requirements and violate the As Low As Reasonably Achievable (ALARA) regulatory intent.
The investigation included extensive reviews of the RANCHO SECO Operating License DPR-54 and Techaical Specifications, Final and Updated Safety Analysis
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Reports, plant design and operations records, and required reports to the NRC; as well as extensive interviews of SMUD, RANCHO SECO, and NRC officials.
The findings were that on September 27, 1984, SMUD, Assistant General Manager",
Nuclear, reported in Special Report 84-07 to the NRC that RANCHO SECO had violated radiation limits in releases of radioactive liquid effluents to the environment. SMUD acknowledged the violation and degree of radioactive
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contamination, however, did not request a variance in their NRC license. The
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cause of the radioactive releases was identified as resulting from an anomalous condition of steam generator tube leaks which had allowed radioactive water from the primary or steam generation system to infiltrate the secondary or reactor coolant system and then was released from RANCHO SEC0 via the regenerant holdup tanks (RHUTs). Reportedly, the conditions resulting in the off site releases of radioactive water had been corrected and a series of specific corrective actions that had been taken and were planned were presented to the NRC.
The NRC licensing officials relied on the infonnation contained in Special Report 84-07 and allowed SMUD to restart RANCHO SECO without a variance to the NRC license.
Special Report 84-07 specifically identified the pathway for radioactive water that was released to the environment had been the result of steam generator tube leaks. In April 1986.;while conducting an NRC unannounced inspection, NRC Inspectors discovered the existence of.a, design and; operation modification to RANCHO SECO which created e separate and distinct pathway for radioactive water to be pumped directly from the demineralized reactor coolant storage tank (DRCST) to the RHUTs and released off site. This modification had been used regularly prior to September 1984 and Special Report 84-07 and continued to be used regularly during 1985 when over 750,000 gallons of radioactive
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4I water were diverted from the DRCST to the RHUTs. The modification, which was j called temporaryA existed for several years and was never examined by the SMUD j Plant Review Comittee (PRC) or the SMUD Management Safety Review Comittee i (MSRC). A review pursuant to MRC requirements of 10 CFR Part 50.59 was not: {
performed and the change to the design and operation and the procedures for )
operation of the plant were not reported as required to the NRC. INRC officials -
stated that had the modification been known at the time of deciding the issue (
related to a need for licensing variance, the NRC actions may have been j different regarding authorization to restart RANCHO SECO. !
The Inspection identified apparent violations of NRC Regulations and the RANCHO SECO Operating License as follows:
- Failure to develop procedures to implement 10 CFR 50, Appendix I criteria.
- Failure to report the results of radioactivity measured in liquid effluents
- Failure to comply with RANCHO SECO Technical Specification 3.17.2 liquid effluent dose limits for 1985
- Failure to perform safety evaluations required by 10 CFR 50.59
- Failure to establish, implement, and maintain procedures required by RANCHO SECO Technica Specification 6.8.
The inspection found that radioactive liquid effluents had been released from RANCHO SECO ia 1985 in excess of the allowable limits of 10 CFR 50, Appendix I criteria. .
Beginning in March 1985, Chemistry / Radiation Techhfcfans were instructed to ~ #
reduce the counting time,for the prescribed test for radioactive nuclides .
present in the RHUTs prior to release of water from RANCHO SECO. The count time was an essential factor in the equation for determination if radioactive nuclides exceeded the dose limits for allowable releases. Also, water was piped in from off site to dilute the water:in tne RHUTs prior to performing
- the tests.
In 1985, of ly recorded! releases oril/69 wefe'r.ade using <thCprescribed3 counting timeo The counting times were reduced when radioactive nuclides*were ;
detected using the prescribed counting time. SMUD had comitted not to release radioactivity, therefore, the method of detection was altered in order to create a record that no radiation existed in the liquid effluent releases.
These reported acts of creating false records were the result of directions from the RANCHO SECO Plant Manager, a Radiation Protection Superintendent, and i two Chemistry / Radiation Supervisors. Also, the investigation revealed that as early as the sumer of 1985, the nature of the tests for radiation in the Lower Limits of Detection (LLD) was suspected of being inadequate. Due to the concerns raised about the LLD, Lawrence Livermore National Laboratory (Livermore Lab) and Oakridge National Laboratory were contracted to study off site radiation exposures. The findings indicated that radioactive nuclides were present downstream in greater quantities then should have been relative to calculations from recorded liquid effluent releases. Even with these i findings SMUD and RANCHO SECO officials continued to count for shortened times to avoid detection and documentation of radiation levels in liquid effluent releases. -
Case No. 5-86-010 2
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. NRC. officials responsible for monitoring the health physics of RANCHO SECO )
declared that there had been numerous violations of nuclear regulations and l believed that the SMUD and RANCHO SECO officials had been intentionally 2 deceptive in Special Report 84-07 and that subsequent reports that radiation released in liquid effluents had not exceeded regulatory limits was false.
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ACCOUNTABILITY The following portions of this Report of Investigation (Case No. 5-86-010) will not be included in the material placed in the Public Document Room. They consist of pages 5 through 55. -
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m TABLE OF CONTENTS Page SYNOPSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 ACCOUNTABILITY . . . . . . . . . . . . . . . . . . . . . . . . .. .. 5 APPLICABLE REGULATIONS . . . . . . . . . . . . . . . . . . . . . . . 9 DETAILS OF INVESTIGATION . . . . . . . . . . . . . . . . . . . . . . 11 Purpose of Investigation ................... 11 Background . . . . . . . ................... 11 History and Organization of SMUD and Rancho Seco ....... 12 Review of NRC and EPA Regulations and the NRC License No. DPR-54 . . ................... 13 SMUD Special Report 84-07 and the Commitment to Adhere to the ALARA Provisions of 10 CFR 50, Appendix I . . . . . . . . 17 NRC's Response to SMUD Special Report 84-07 . . . . . . . . . . 18 Interview of Gus C. LAINAS, Division of Licensing, NRR, NRC . . 18 Interview of Edward M. BRADLEY, Supervising Health
. Physicist, RANCHO SECO ................... 19
- Review of NRC Inspection Report 50-312/86-15 ......... 20 .
Interview of Gregory P. YUHAS, Chief Facilities Radiological .
- Protection Section, NRC, Region V . . . . . . . . . . . . . . 26 Office of Investigations' Request for Information from SMUD Concerning Operations and Management of RANCHO SECO Liquid Effluent Program . . . . . . . . . . . . . . . . . . . 28 SMUD's Response to the Office of Investigations' Request for
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29 I nf o rma ti on . . . . . . . . . . . . . . . . . . . . . . . . .
Interview of Michael CILLIS, Senior Radiation Specialist, NRC, Region V . . . . . . . . . . . . . . . . . . . . . . . . 29 Office of Investigations' Request to SMUD for Additional ,
Information . . . . . . . . . . . . . . . . . . . . . . . . . 29 I SMUD's Response to Request for Additional Information . . . . . 30 Technical Review of SMUD's Response for Additional Information . . . . . . . . . . . . . . . . . . . . . . . . . 30 Interview of Lee. R. KEILMAN, Former Manager of Nuclear Engineering, RANCHO SECO .................. 30 ;
Interview of Roger L. POWERS, SMUD Supervisory Nuclear i Engineer . . . . . . . ................... 32 l Interview of David R. MIXA, former RANCHO SECO i Chemical / Radiation Technician . . . . . . . . . . . . . . . . 33 Interviews of RANCHO SECO Chemical / Radiation Technicians ... 34 Interview of William A. WILSG3, SMUD Acting Chemistry Operation Supervisor . ................... 35 Interview of Stephen C. MANOFSKY, RANCHO SECO Chemistry Supervisor . . . . . . ................... 37 Interview of Roger I. MILLER, SMUD Chemistry / Radiation Protection Superintendent . . . . . . . . . . . . . . . . . . 38
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TABLE OF CONTENTS (Cont.)
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l Interview of Fred W. KELLIE, SMUD Radiation Protection .
Superintendent . . . . . . . . . . . . . . . . . . . . . ' . . 39 Interview of George A. COWARD, RANCHO SECO Plant Manager ... 41 Interview of Pierre OUBRE, SMUD Acting Assistant General Manager of Engineering and Opecstions . . . . . . . . . . . . 43 Interview of Ronald J. RODRIGUEZ, SMUD Assistant General Manager, Nuclear ...................... 44 Interview of Ronald W. COLOMBO, RANCHO SECO Regulatory Compliance Superintendent . . . . . . . . . . . . . . . . . . 46 Review of RANCHO SECO Semi Annual Effluent Release Reports for 1985 .......................... 48 W111 fulness / Intent Section . . ................ 49 Investigator's Conclusions . . ................ 50 Status of Investigation . . . . . . . . . . . . . . . . . . . . 50 LIST OF EXHIBITS . . . . . . . . . . . . . . . . . . . . . . . . . . 51 LIST OF ACRONYMS . . . . . . . . . . . . . . . . . . . . . . . . . . 55 p
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APPLICABLE REGULATIONS 10 CFR 50.34(a)a: Design Objectives for Nuclear Power Reactor Equipment to Contrc,1 Releases of I,adioactive Material in Effluents 10 CFR 50.36(a): Technical Specifications on Effluents from Nuclear Power Reactors 10 CFR 50 Design Objectives for Release of P.edioactive Material in Appendix I: Liquid Effluents 10 CFR 50.71: Requirements to Maintain Records and Update the Final Safety Analysis Report 10 CFR 50.59: Requirements for Determining Unreviewed Safety Questions 10 CFR 20.106(g): NRC Implementation of EPA Regulation relevant to 40 CFR 190 " Environmental Radiation Protection Standard for Nuclear Power Operations."
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9 DETAILS OF INVESTIGATION Purpose of Investigation This investigation was initiated on June 13, 1986, based on a R'eq'uest for Investigation from J.B. MARTIN, Regional Administrator, NRC, Region V (EXHIBIT 1). The purposes of this investigation were to:
- 1) Determine if Sacramento Municipal Utility District (SMUD) officials responsible for managing the Rancho Seco Nuclear Generating Station (RANCHO SECO) had made material false statements to the NRC concerning releases of radioactive liquid effluents during calendar year 1985.
- 2) Determine if SMUD managers and employees conspired to conceal plant design modifications and operations, and manipulated chemistry and testing records in such a way that radioactive releases would not be detected or known by the NRC and public.
- 3) Determine if SMUD managers and employees conspired to conceal radioactive releases that exceeded Federal Regulations 10 CFR 50, Appendix I requirements and violate the As Low As Reasonably Schievable (ALARA) regulatory intent.
Background
On June 6, 1986, NRC, Region V, issued NRC Inspection Report No. 50-312/86-15,
. The Inspection was performed by Greg P. YUHAS, Chief Facilities Radiological Protection Section, NRC Region V, at RANCHO SECO during the Period of April 1, to May 23, 1986. The inspection was a special, unannounced inspection to review the management of radioactive materials released in liquid effluents during 1985. The review resulted in identification of apparent violations involving failure to develop procedures to implement 10 CFR 50, Appendix I, criteria; failure to report the results of radioactivity measured in liquid effluents; failure to comply with RANCHO SEC0's Technical Specification 3.17.2 liquid effluent dose limits; failure to perform safety evaluations required by 10 CFR 50.59; and failure to establish, implement, and maintain procedures required by Technical Specification 6.8.
No enforcement action was taken by the NRC based on the possibility that the violations were committed knowingly and willfully by SMUD and RANCHO SECO managers and employees. The matter was then referred to the NRC Office of Investigations.
This investigation, which was performed during the period of June 13, 1986, to September 30, 1987, consisted of reviews of NRC and Environmental Protection Agency (EPA) regulations; the organization and history of SMUD and RANCHO I SECO, the NRC Operating License No. DPR-54, Final Safety Analysis Report (FSAR), and Technical Specifications for the operation of RANCHO SEC0; review of RANCHO SEC0 re:ords; and interviews of SMUD, RANCHO SECO, and NRC officials.
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l History and Organization of SMUD and RANCHO SECO 1
RANCHO SECO, a 914 megawatt rated nuclear power generating station, first i became commercially operable in April 1975 under provisions of NRC License DPR-54. The plant is on a 2,500 acre site, 25 miles southeast of Sacramento and is an integral part of the electric power generation faciliti'es owned and operated by SMUD. SMUD began construction of RANCHO SECO in 1968 with an initial cost of approximately $342 million. The actual construction cost was increased by $300 million due to facility modifications. In addition to RANCHO SECO, Upper American SMUD River owns Project and aoperates (UARP), seven geothermal planthydroelectric SMUDGE 0), a p(hnts known as the combustion turbine and polar photovolatic facility (SMUDPV). All facilities combined, SMUD's aggregate electric power generating capacity is 1,695 megawatts.
SMUD was formed in 1923 under provisions of tiie Municipal Utility District Act approved by the California State Legislature in 1921. SMUD is headquartered in Sacramento, the State Capitol of California, and has a service area of about 898 square miles which includes the principal parts of Sacramento County and a small portion of Placer County. SMUD has over 390,000 customers and operating revenues of about $350 million. Although organized in 1923, SMUD did not comence electric operations until January 1,1947, and has provided all electric service within its service area since that date. The sole activity of SMUD has been the generation, transmission, and distribution of electric energy.
SMUD is governed by a board of five directors, elected by voting ward for staggered four-year terms. The Board of Directors (the Board) appoints a ,
General Manager who is responsible for SMUD operations. The Board also .
appoints Assistant General Managers and their assistants who serve at the Board's pleasure. During the period relevant to this investigation, the members of the Board and key managers were as follows:
Name Occupation Term Expires Ann L. TAYLOR, President Businesswoman 12/31/88 Cortus T. K0CHLER, Vice President Educator 12/31/88 Clifford R. WILCOX Agribusinessman 12/31/86 John T. KEHOE Business Executive 12/31/88 Paul W. CARR Business Executive 12/31/86 General Manager: Dewey K.K. LOWE was appointed General Manager in September 1985. LOWE was preceded by John J. MATTIMOE who was the General Manager from November 1982 until August 1985. LOWE resigned from SMUD in June 1986.
Assistant General Manager, Nuclear: Ronald J. RODRIGUEZ was appointed as Assistant General Manager, Nuclear on March 22, 1985. He had served as Executive Director, Nuclear from February 1983 until March 1985. RODRIGUEZ was responsible for the nuclear organization within SMUD which included Nuclear Operations, Nuclear Engineering, Nuclear Licensing and Quality.
RODRIGUEZ had worked for SMUD since 1968 in several capacities including Manager of Nuclear Operations, Plant Superintendent, and Assistant Superintendent for Operations. -
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SMUD received its power requirements from electricity generated by the UARP, ;
RANCHO SECO, SMUDGE 0 #1, SMUDPV, and Combustion Turbine. Also electricity was purchased from the U.S. Department of Energy Western Power Administration (Western), the Camp Fare West Hydroelectric Project, and non-firm energy purchases from eight Pacific Northwest utilities. SMUD also had a Power Sale, Exchange, and Integration Contract with Pacific Gas and Electric tompany (PG&E).
For calendar year 1985, SMUD experienced a net operating loss of $9,156,000.
That was the first time in SMUD's history that a net loss had been experienced.
The loss was principally caused by a combination of circumstances related to RANCHO SECO operations. During 1985, RANCHO SECO achieved only 26 percent of the annual electric power generation capacity factor. Historically, RANCHO SECO had achieved an annual average of 47 percent of capacity. Annual capacity factors for the years 1981 through 1984 were 35, 44, 39, and 51 percents respectively. The low factors were reportedly due to steam generator tube leaks, feedwater header damages, extensive systems modifications, and NRC directed inspections and modifications. SMUD calculated the production cost
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of energy from RANCHO SECO for 1984 as 28 mills per kilowatt-hour. However, the comparable costs for 1985 were about 71 mills per kilowatt-hour. Those poor perfomance conditions were further aggravated by the fact that SMUD was forced to purchase $94,327,000 of electric power from outside sources in order
, to meet their customer demands. This represented an increased operating expense of $62 million over 1984 and $76 million over 1983 for purchased
- power. Coupled with the fact that only $50.9 million of surplus power was sold in 1985 relative to $102.3 million in 1984, RANCHO SECO was responsible for nearly all the SMUD 1985 net operating loss.
Review of NRC and epa Regulations and the NRC License No. DPR-54 On August 16, 1974, the Atomic Energy Comission issued Facility Operating License Number DPR-54 to SMUD, owner and operator of RANCHO SECO. Pursuant to the license, the RANCHO SECO facility consisting of a pressurized water reactor and associated equipment, was authorized to operate as described in the FSAR and in accordance with 10 CFR, Parts 20 and 50 and RANCHO SECO's Technical Specifications.
Pressurized water reactors are distinguished by the existence of a primary system, which heats water through energy from nuclear reactions, and the secondary system, which generates steam by circulating water through steam generator tubes heated by water from the primary system. The primary and secondary systems maintain their individual and separate integrity so the secondary system does not become contaminated with radioactive isotopes from the primary system.
Review of Atomic Energy Act and NRC Regulations Concerning Technical Specifications:
"Section 182a, of the Atomic Energy Act of 1954, as amended (42 U.S.C.
2232), mandates the inclusion of Technical Specifications in licenses for the operation of production and utilization facilities. The Act requires that Technical Specifications include information of the amount, kind, and source of special nuclear material, the place of use, and the specific
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characteristics of the facility. That section also indicates that Technical Specifications should contain such infonnation as the Comission may by rule deem necessary to enable it to find that the utilization of special nuclear material will be in accord with the comon defense and will provide adequate protection of public health and safety. Finally, that section requires Technical Specifications to be made'a part of any license issued."
10 CFR 50.36, ' Technical Specifications,' implements section 182a, of the Atomic Energy Act and was promulgated by the Comission on December 17, 1968.
This rule delineates requirements for determining the contents of Technical Specifications. Technical Specifications set forth the specific characteristics of the facility and the conditions for its operation that are required to provide adequate protection to the health and safety of the public. Specifically, 10 CFR 50.36 requires that:
"Each license authorizing operation of a production or utilization facility of a type described in 550.21 or 550.22 will include Technical Specifications. The Technical Specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to 550.34. The Comission may
- include such additional Technical Specifications as the Comission finds appropriate.
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" Technical MRC approv'a, l..." Specifications'cannot be cMenged by?lfeensees'witho -
"The purpose of Techr.ical Specifications is to impose those conditions o'r limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an imediate threat to the public health and safety by establishing those conditions of operations which cannot be changed without prior Comission approval and
- by identifying those features which are of controlling importance to safety."
10 CFR 50.36a " Technical Specifications of Effluents from Nuclear Power Reactors" states as follows:
"(a)In order to keep releases of radioactive materials to unrestricted areas during normal reactor operations, including expected operational occurrences, as low as is reasonably achievable, each license authorizing operation of a nuclear power reactor will include technical specifications that, in addition to requiring compliance with applicable provisions of $20.106 of this chapter, require-
"(1) That operating procedures developed pursuant to 650.34a(c) for the control of effluents be established and followed and that equipment
! installed in the radioactive waste system, pursuant to $50.34(a) be maintained and used.
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"(2) Each licensee shall submit a report to the Comission within 60 days after January 1 and July 1 of each year, that specifies the quantity of each of the principal radionuclides released to unrestricted areas in liquid and in gaseous effluents during the previous six months of Case No. 5-86-010 14
operation, including any other infomation as may be required by the Commission to estimate maximum potential annual _ radiation doses to the public resulting from effluent releases. The report must be submitted as specified in 650.4. If quantities of radioactive materials released during the reporting period are significantly above design objectives, the report must cover this specifically (emphasis added). Oh the basis of these reports and any additional infomation the Commission may obtain from the licensee or others, the Commission may require the licensee to take action as the Commission deems appropriate. .
- "(b)ln establishing and implementing the operating procedures described u in paragraph (a) of this section, the licensee shall be guided by the following considerations: Experience with the design, construction and operation of nuclear power reactors indicates that compliance with the technical specifications described in this section will keep average annual releases of radioactive material in effluents at small percentages of the limits specified in $20.106 of this chapter and in the operating license. At the same time, the licensee is permitted the flexibility of operation, compatible with considerations of health and safety, to assure that the public is provided a dependable source of power even under unusual operating conditions which may temporarily result in releases higher than such small percentages, but still within the limits specified in $20.106 of this chapter and the operating license. It is expected that in using this operational flexibility under unusual operating conditions, the licensee will exert his best efforts to keep levels of radioactive material in effluents as low as is reasonably achievable" (emphasis added). ,
10 CFR Part 20.106(g) requires RANCHO SECO to comply with EPA regulation
" Environmental Radiation Protection Standard for Nuclear 40 CFR Part 190 Power Operations." 40 CFR Part 190.1-(a) requires that radiation from nuclear power fuel cycle operations shall not exceed, on an annual basis, 25 millirems (mrem) to the whole body, 75 mrem to the thyroid and 25 mrem to any other organ, of any member of the public as the result of exposures to planned discharges of radioactive materials to the general environment. There are, however, provisions for 40 CFR 190.11 standards to be exceeded if:
- 1) NRC, who has the authority to regulate nuclear power fuel cycle operations, has granted a variance based upon its determination that a temporary and unusual operating condition exists;
- 2) Continued operation is in the public interest; and
- 3) Information is promptly made a matter of public record delineating the nature of unusual operating conditions, the degree to which the operation ;
is expected to result in levels in excess of the standards, the basis of {
the variance,.and the schedule for achieving conformance with the {
standards.
40 CFR 190 defines radiation as any alpha, beta, gama or X-ray; neutrons; and high energy electrons, protons or other atomic particles... Radioactive material j is defined as any material which spontaneously emits radiation. # General l
environment means the total terrestrial, atmospheric and aquatic environments outside the boundary or area of ,the licensee control of a nuclear power fuel j
cycle operation, i
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EPA considers 10 CFR 50, Appendix I as a basis for realistic implementation of the 40 CFR 190 standards for a single reactor unit. 10 CFR 50, Appendix I contains the numerical guides for design objectives and limiting conditions for nuclear power fuel cycle operations to meet the criterion ALARA for radioactive material in nuclear power reactor effluent releases to the environment. The 40 CFR 190 EPA standard is measured in terms'of;real or actual dose to the public while NRC's Appendix I limits deal with a ,
hypothetical or calculated exposure modes. ,
10 CFR 50, Appendix I, Section II A requires the total quantity of all radioactive material to be released annually from liquid effluent pathways not to exceed an estimated annual dose of 3 mrem to the total body and 10 mrem to any organ. Section IV B-2 requires the licensee to establish an appropriate surveillance and monitoring program to provide data on measurable levels of radiation and radioactive materials in the environment in order to evaluate the relationship between quantities of radioactive material released in effluents and resultant radiation doses to individuals from principal pathways of exposure.
The RANCHO SEC0 Radiological Environmental Technical Specification (RETS) 3.25 implements the 40 CFR 190 requirements. RETS 3.17.2 im e requirements of 10 CFR 50, Appendix I at RANCHO SEC0/ plements the 10 CFR 50.36 a(a)(2), " Technical Specification On Effluents From Nuclear Power Reactors," requires licensees to submit semi-annual reports to NRC specifying -
the quantity of the radionuclides released to the environment in liquid effluents, and information which may be required by the Comission which ,
allows the NRC to estimate the maximum potential annual radiation dose. In -
addition, if releases for the reporting period are significantly above the design objectives, then the report shall cover this condition specifically.
INVESTIGATOR'S NOTE: The above sections demonstrate the intent of the 1 Atomic Energy Act and EPA and NRC regulations to have the licensee report releases of radioactivity to the environment; and that the NRC relies on these reports to estimate annual radiation doses.
RANCHO SECO Safety Analysis Report: 10 CFR 50.34, " Nuclear Power Reactors Design Objectives for Equipment to Control Releases of Radioactive Material In Effluents," requires RANCHO SECO to describe the equipment and process for controlling releases of radioactive materials to the environment. As required by the NRC Operating License, RANCHO SECO's Spdate(rFAnal, Safety 4 Analysis Report (UFSAR) Section 11.1, " Radioactive Waste Handling" states:
"The radioactive waste disposal system provide for the controlled handling and disposal of liquid, gaseous, and solid wastes. The
[ primary, secondary, and associated] systems are designed to ensure that plant personnel and the general public are protected against excessive exposure to radiation from wastes, in accord with limits defined in 10 CFR 20, 10 CFR 50, and 40 CFR 190. The systems are j designed to minimize discharge of radioactive liquids, gases, and i solids of station origin to the surrounding environment.
"... The only liquid discharge pathway of potentially contaminated -
water is via the regenerate holdup tanks or RHUTs, which can receive Case No. 5-86-010 16 I
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water from regeneration of resins on the secondary side, or from miscellaneous secondary sumps and equipment drains. The event of a primary to secondary leak, would be the only pathway contaminated liquids would be released to the environment (emphasis added). All liquid radioactive releases from the plant are made through.the RHUT to the retention basins. Releases beyond the site boundary tre.made from the retention basins. All_RHUT releases to the retentio6' basins are sampled, analyzed, and monitored. There are no design direct connections from the primary system's radioactive liquid ,
radwaste treatment equipment to the RHUTs" (emphasis added)
"With the exception of wastes released from the regenerate holdup tanks, the Rancho Seco Nuclear Generating Station is. designed not to release any' liquid effluents containing radioactivity of plant origin to the environment during normal. plant operation. .The possibility of radioactivity of plant origin being inadvertently discharged in the plant liquid effluents is extremely unlikely, since multiple barriers must be breached and monitoring systems are provided" (emphasis added). "In the event of abnormal plant operation, radioactivity concentrations in the plant effluent will still be within the limits established by 10 CFR 20,10 CFR 50, and 40 CFR 190."
SMUD Special Report 84-07 and the Commitment to Adhere to the ALARA
- Provisions of 10 CFR 50, Appendix I On September 27, 1984, Ronald J. RODRIGUEZ, SMUD, Executive Director, Nuclear;
- sent "Special Report 84-07" to J.B. MARTIN, Regional Administrator, NRC, Region V (EXHIBIT 2). In Special Report 84-07, RODRIGUEZ informed the NRC
~
that the calculated radiological exposure from liquid effluent releases to the maximum exposed individual in the environment from January 1, 1984, through
- - August 31, 1984, exceeded the limits of 40 CFR 190. RODRIGUEZ reported the calculated radiological exposures to be 185 mrem to the maximum adult body and 302 mrem liver exposure to a maximum exposed child liver.
INVESTIGATOR.'5. . NOTE: As previously stated, the EPA standard of 40 CFR 190 requires actual radiation exposure not to exceed 25 mrem on an annual basis.- SMUD contracted with Lawrence Livennore Nationat-tatmratory (Livermere Lab) to determine what the actual radiation exposure was .
relative to the calculated exposures referred to in 84-07. EPA considers the NRC regulated ALARA provisions of 10 CFR 50, Appendix I as a sufficient basis for adherence to 40 CFR 190. Appendix I, as stated above, limits the annual calculated radiological exposure to an individual in the environment to 3 mrem to the body and 10 mrem to any organ.
RODRIGUEZ reported the cause of the excessive exposure rates was a continuous leak in the steam generator tubes. The date of the origin of the leak was traced back to on or about September 17, 1983, and continued until August 31, 1984, at which time RANCHO SECO was shut down and the leaking tube was reportedly identified and plugged.
. In Special Report 84-07, RODRIGUEZ reported the pathway of the radioactive liquid effluent to the general public was by means of the contamination of the .
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l RANCHO SEC0 secondary system from the primary system, as a result of the tube
-leaks. RODRIGUEZ pointed out that after neutralizing and sampling the RHUTs, the water was transferred to the retention basin. When the basin became full, the water was released to the environment. RODRIGUEZ also stated that the results of the RHUT sampling were used to determine the total rel. ease activity for each radioactive isotope (emphasis added).
Even though 40 CFR 190 limits had been exceeded for 1984, RODRIGUEZ stated in Special Report 84-07 that an NRC variance for continued operation, as required by 40 CFR 190, was not required at that time because the cause of exceeding 40 CFR 190, the steam generator tube leaks, had been corrected; that the near term corrective actions to assure compliance with 10 CFR 50, Appendix I ha r been implemented; and the design of RANCHO SECO was such that liquid radioactive discharges should not be required.
NRC Response to SMUD Special Report 84-07 Gus C. LAINAS, Assistant Director for Operating Reactors, Division of Licensing, NRC Office of Nuclear Reactor Regulation (NRR), signed a letter dated November 15, 1984 (EXHIBIT 3) which was sent to RODRIGUEZ in response to Special Report 84-07. Because of the corrective actions that had been reportedly implemented by RODRIGUEZ and RODRIGUEZ's commitment not to exceed the 40 CFR 190 and 10 CFR 50 Appendix I limits, LAINAS, acting for the NRC, concurred with RODRIGUEZ's assertion in Special Report 84-07 that a variance -
in accordance with 40 CFR 190 was not needed.
Interview of LAINAS, Division of Licensing, NRR, NRC <
- On February 25, 1987, LAINAS was interviewed. He provided a signed sworn written statement (EXHIBIT 4) that in summary stated as follows: l
.= He had relied on the information submitted by RODRIGUEZ in Special Report j 84-07 in making his decision that a variance to the NRC License No. DPR-54 was i not necessary. If the information provided by RODRIGUEZ was not accurate, the NRC's conclusions relative to the need for a variance may have been different.
Interview of Edward M. BRADLEY, Supervising Health Physicist, RANCHO SECO On January 26, 1987, BRADLEY, Supervising Health Physicist, RANCHO SECO, was )
interviewed under oath. The transcript of BRADLEY's interview (EXHIBIT 5) is l i
summarized as follows:
l In January 1985, BRADLEY, while attending a health physics symposium, became aware that the RANCHO SECO Technical Specification for Lower Limits of '
Detection (LLD) might not be sufficient to assure that the radioactivity released in liquid effluents was within the limits of the ALARA provisions of 10 CFR 50, Appendix 1. This was due to the configuration of RANCHO SECO as a dry site nuclear power operation; in that the liquid eff,luents released to the environment were ret diluted by the rivers, lakes, oceans, or other large bodies of water. BRADLEY's discovery about the sufficiency of RANCHO SECO's Technical Specification LLD was discussed in January 1985 with his supervisor, -
Roger POWERS, a Supervising Nuclear Engineer.
Case No. 5-86-010 18
1 1
BRADLEY wanted to conduct a study on the issue but POWERS instructed BRADLEY to study the issue only to the extent that it did not impede on other assigned work projects. Even though the LLD issue, if substantiated by BRADLEY's study, could have reflected negatively on SMUD's ability to adhere to the comitment to the NRC in Special Report S4-07, POWERS felt it was.more important to comit resources to issues that would reflect positively on the degree of radioactivity being released in RANCHO SECO's liquid effluents.
For RANCHO SECO, LLD was a predictive estimate representing the capability of a measuring system to detect the smallest positive value concentration of radioactivity in a sample approximately 95 percent of the time. The RANCHO SECO Technical Specification on LLD's requires a system with the measuring capabi}itytodetectpositivevaluesofradioactivityatconcentrationlevels of SE- microcuries per milliliter (uti/ml).
BRADLEY completed his study on the LLD matter and issued a preliminary report to POWERS in July 1985. The report indicated, in fact, that RANCHO SECO's Technical Specification LLD was not sufficient to assure compliance with 10 CFR 50, Appendix I limits. BRADLEY stated that POWERS reviewed the report, disagreed with its contents, and took no action on the LLC' issue. In discussions with both POWERS and RODRIGUEZ, BRADLEY had a difficult time obtaining a comitment from them on the LLD issue because of reactor restart issues that were being considered in 1985. BRADLEY stated he suggested to both POWERS and RODRIGUEZ that he hold up distributing his draft report on the
. LLD issue until after the restart of RANCHO SECO. BRADLEY explained that he suggested this delay thinking that after restart POWERS and RODRIGUEZ would be able to dedicate the appropriate time and attention to the LLD issue. -
- BRADLEY's draft LLD study was also sent to Ronald COLOMBO, RANCHO SECO Regulatory Compliance Superintendent, and Fred KELLIE, RANCHO SECO Chemistry and Raiffation Protection Superintendent. BRADLEY stated he never received a
.- reply to his request for feedback from COLOMBO and KELLIE on the LLD issue.
In early December 1985, as a result of Livermore Lab detecting radioactivity in the RHUTs, BRADLEY requested from POWERS an analysis for gama emitting radioisotopes based on monthly RHUTs composite samples of water being released to the environment. Controls for Environmental Pollution (CEP), a private firm under contract to SMUD, conducted analyses of composite RHUTs' samples.
Such composite analyses would indicate, on a monthly basis, the amount of radioisotopes in the RHUTs. The CEP analyses was important to BRADLEY for two reasons. One reason was his concern that the RANCHO SECO LLD Technical Specification was inadequate; and the second reason was the fact that the Livermore Lab RHUTs analyses indicated the presence of Cesium 137 at levels contrary to the SMUD Semi Annual Effluent Release Report of September 1985.
As a result of delays in obtaining the CEP analysis, BRADLEY wrote a December 16, 1985, memorandum to POWERS (EXHIBIT 6) criticizing SMUD's manage-ment of the liquid effluents release program. In the memorandum, BRADLEY also warned POWERS that if SMUD management did not take aggressive action to correct apparent NRC violations for radioactivity releas'ed in liquid effluents, the regulatory posture of NRC could become quite severe. As a result of BRADLEY's memorandum, POWERS wrote a letter (EXHIBIT 7) through RODRIGUEZ,
, directing KELLIE to conduct the analysis of the composite samples for 1985.
In December 198F, in conjunction with requesting the analysis of the composite j sampling, BPnLSY learned from David MIXA, a former Chemistry Radiation and Protect W lrca .ician at RANCHO SECO, that KELLIE had directed the Chemistry and Radiation Protection Technicians to lower the counting time on analyses of i RHUTs batch liquid samples when the standard 2000 second count time indicated l the presence of Cesium 137. At the time of this conversation wittj BRADLEY, j j
MIXA was working on infomation programs at SMUD headquarters in downtown Sacramento. BRADLEY stated he reported this information to RODRIGUEZ through POWERS. As a result, RODRIGUEZ requested KELLIE's supervisor, George C0 WARD, the RANCHO SECO Plant Manager, to look into the lower count time. C0 WARD reportedly determined as long as the RHUTs batch analyses was conducted at a LLD lower than RANCHO SECO's Technical Specification LLD, then the lowering of the analysis count time was authorized.
BRADLEY stated that when COWARD reported his view on allowing the lowering of the count time, any interest that SMUD management might have had in pursuing BRADLEY's LLD issue seemed to dissipate. However, the CEP analysis of composite RHUT samples for 1985 indicated that RANCHO SECO had exceeded Appendix I limits. In a June 5, 1986, Special Report Number 86-08 to URC (EXHIBIT 8), John WARD, Acting Assistant General Manager Nuclear, acknowledged the violation of RANCHO SECO's Technical Specification / Appendix I limits, and that SMUD's Semi Annual Effluent Release Reports for 1985 were in error
- because the SMUD management relied too heavily on RANCHO SECO's Technical Specification LLD.
Review of NRC Inspection Report 50-312/86-15 .
During the period from April 1, 1986, to May 15, 1986, YUHAS, supra, performe~d a special unannounced inspection at RANCHO SECO. The purpose of the inspection
~
was to evaluate the SMUD management of radioactive materials released in liquid effluents from RANCHO SECO during 1985. The inspection results were documented in NRC Region V Inspection Report No. 50-312/86-15 (EXHIBIT 9).
The Inspection identified apparent violations of HRC Regulations and the RANCHO SECO Operating License as follows:
- Failure to develop procedures to implement 10 CFR 50, Appendix I criteria.
- Failure to report the results of radioactivity measured in liquid l
effluents
- Failure to comply with RANCHO SECO Technical Specification 3.17.2 liquid effluent dose limits for 1985
- Failure to perfom safety evaluations required by 10 CFR 50.59
- Failure to establish, implement, and maintain procedures required by RANCHO SECO Technical Specification 6.6.
In summary, the inspection found that radioactive liquid effluents had been released from RANCHO SECO in 1985 in excess of the allowable limits of 10 CFR 50, Appendix I criteria.
RANCHO SECO's Chemistry / Radiation Technicians advised the NRC Inspector that they had been instructed by their Supervisor, KELLIE, that when conducting required chemistry tests prior to release of liquid effluents and the standard 2000 second count time showed the presence of identifiable peaks in radioactive Case No. 5-86-010 20 _
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nuclides, they were to reduce the counting time to only 1000 seconds. If the shorter count did not show the presence of identifiable peaks of radiation, they were to release the liquid effluents. Some of the technicians did not believe this was proper but did as they were told. Records reviewed by the NRC Inspector showed that on June 4, 1985, the counting time had been reduced to reflect no identifiable radiation and 150,767 gallons of water'containing radioactive nuclides were transferred from the B RHUT to the retention basin for release from RANCHO SECO. A review of the Chemistry / Radiation Logs indicated that counting times were specifically reduced from 2000 seconds on June 6 June 16, and June 17, 1985, and that for the remainder of 1985 of the 111 samples analyzed, only 69 were counted for 2000 seconds.
INVESTIGATOR'S NOTE: The investigation disclosed an internal SMUD memorandum (EXHIBIT 10) in the RANCHO SECO files that showed on June 6,/
1985, KELLIE telephonically contacted YUHAS to resolve the meaning or interpretation of RANCHO SECO Technical Specification requiring the reporting of any detected radiation in liquid effluent releases. The memorandum records KELLIE's understanding of the resolution as follows:
If a nuclide is below minimal required LLD but is a positive value, it must be recorded and reported. This memorandum bearing KELLIE's initials clearly demonstrates his understanding of the NRC's requirement and intent of the Technical Specifications. Distribution of copies of the memorandum is shown as being sent to the following RANCHO SECO and SMUD officials:
R. COLOMB0 R.J. RODRIGUEZ G. COWARD A. SCHWIEGER ~
R. DIETERICH B. SPENCER L. KEILMAN ADMIN Files QA Files
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J. MCCOLL1GAN R. MILLER 4th Floor Files R.P. OUBRE The continued practice of shortened counting time by Chemistry / Radiation Technicians after the June 6, 1985, telephone conversations and memorandum, /
demonstrates a willful intent to create a Chemistry / Radiation record that appears to be in compliance with NRC criteria when in fact a false record concerning releases of radioactive liquid effluents was created.
The Inspection also cited the SMUD Semiannual Radioactive Effluent Release Report which was required by NRC License Condition in Technical Specification 6.9.2.3. This semi annual report which was submitted to the NRC on September 26, 1985, stated that there had been 199 batch releases of liquid effluents from RHUTs from January through June 1985, and that no releases containing detectable fissionable or activation products were made during that /
period.
l It was also discovered during the inspection that a physical modification of the plant design and operation had occurred. The modification was contrary to the design of the plant, which called for segregation between the primary system (radioactive) and the secondary system (non-radioactive). The modification consisted of plastic pipes and fire hoses allowing the moveme.nt of water from the liquid radioactive waste treatinent, demineralized reactor I ewdAE4%a2 21 3
)
coolant storage tank (DRCST) (an element of the primary system), to the RHUTs (an element of the secondary system). The RHUTs are the designed point of release of liquid effluents from the RANCHO SECO site into Clay Creek which flows into the Sacramento River and other California waterways, and subsequently, used to irrigate agricultural lands. There was n.o record that the modification had received a safety analysis review as require 3 by 10 CFR 50.59.
Based on the discovery of the modification to the plant, which created an unreported pathway for radioactive water to be released from the plant, the NRC Inspector concluded that the pathway and cause of releases of radioactive liquid effluents as described in SMUD Special Report 84-07 dated September 27, 1984, was not correct. The following is presented verbatim from the NRC Inspection Report No. 50-312/86-15:
"A. ... Based on this inspection, it appears that the cause and pathway were not entirely correct. Specifically, beginning in 1983, the licensee initiated a procedure which allowed the frequent transfer of water recovered from the liquid radioactive waste treatment systems to the RHUTs for release to the environment.
/ "10 CFR 50.59(a)(1) reads:
'The holder of a license authorizing operation of a production or utilization facility may (i) make chances in the facility as describedinthesafetyanalysisreport,(ii)makechangesin the procedures as described in the safety analysis report, and, (iii) conduct tests or experiments not described in the safety .
analysis report, without prior Comission 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 the following infomation in Section 11.,
Radioactive Waste and Radiation protection, that:
"The liquid waste systems are designed to permit plant operation without discharging radioactive liquids to the environment under normal operating conditions. The boric acid concentrator and miscellaneous waste evaporator can each process waste liquids in excess of the maximum expected waste generation rates. The coolant waste receiver and holdup tanks are sized to store one reactor coolant system volume of waste during an evaporator outage or during maintenance.
"The coolant waste system is a closed loop water system with the recovered water and boric acid stored onsite for reuse.
"The miscellaneous liquid radwaste system, through the use of the miscellaneous water holdup tank and the shipment of concentrated wastes offsite by an NRC-licensed contractor, ,
allows normal operation without requiring the discharge of liquids from the system. The entire liquid waste processing 22 Case No. 5-86-010
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l system is contained within the Auxiliary Building. Therefore, J any leaks will be retained within the building, collected in the sumps, and reprocessed through the miscellaneous liquids j radwaste system. l "All vents, drains, and secondary flow paths in the liquid radwaste system are shown in Figures 11.1-4 and 11.1-5. The system is designed so that no liquid radwaste will be released to the environment" (empnasis added). ]
"Section 11.1.2.2.2., Miscellaneous Liquid Radwaste System, reads:
'In addition, spent regenerant wastes from the polishing demineralizers can be processed if they contain radioactivity as the result of operation with a small steam generater tube leak.'
" Based on review of licensee records, it appears that on December 7, M-sv 1982, was a temporary implemented change which to Procedure allowed radioactiveA.29, water"toWaste Watericom be pumped Disposal the System," ,
Demineralized Reactor Coolant Storage Tank (T-621) through a temporary D conduit to either Regeneration Hold-up Tank (T-950 A or B) for ultimate release to the environment and the Principle Regulatory Compliance Engineer was unable to provide any indication that an evaluation had been performed to determine if a change in the Technical Specification was
- required or if an unreviewed safety question was involved. The temporary change expired on January 7, 1983, and was re-established on February 8, 1983, and then expired on March 30, 1983. :
"Again, on January 6, 1986, a temporary change to Procedure A.10,
' Demineralized Reactor Coolant Storage System,' was implemented which allowed radioactive water to be pumped from T-621 through a plastic pipe
~
- to' either T-950 A or B for ultimate release offsite and the Principle Regulatory Compliance Engineer was unable to provide any indication that an evaluation had been performed to determine if a change to Technical Specification was required or an unreviewed safety question was involved.
"From January 1983 through March 13, 1986, the licensee routinely transferred liquid through various conduits including firehose and '
plastic pipe from T-621 located within the tank farm to either T-950 A or B which are located in an uncontrolled area such that failure of the temporary conduit might have resulted in an uncontrolled release of radioactive material to the surface waters.
"On May 15, 1986, the inspector physically observed that the plastic pipe which had been connected to T-621 drain line had been removed leaving the exposed open pipe in close proximity to the tank. The licensee representative stated that tne temporary pump which had been installed in the system had a flow rate of 166 gallons per minute.
" Technical Specification 3.17.3, Licuid Holdup Tanks, limits the quantity l of radioactive material which can be contained in the RHUTs and outside /
, temporary storage tanks to 10 Curies. Technical Specification 4.21-3 contains the following comment: ,
' j
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' Tanks included in this specification are those outdoor tanks that are not surrounded by liners, dikes, or walls capable of holding the tank contents and that do not have tank overflows and surrounding area drains connected to the liquid radwaste treatment system.'
"Theconnectionofanon-qualityclasstemporarypipingsy'stimiwithno automatic isolation capability, to T '621 raised the question as to whether the licensee had performed the weekly surveillance on T-621 to l determine that the activity was less than the 10 Curie limi,t while the temporary system was in operation. The licensee indicated that the
< surveillance had not been performed. The inspector attempted to review the accident analysis for failure of either T-621 or the Borated Water Storage Tank (450,000 gallon) since both are outdoors, not surrounded by liners, dikes, or walls capable of holding their contents, and the licensee does not perform the weekly surveillance. Neither the FSAR nor the . licensee presented a safety analysis which would bound these tanks failures. This matter has been brought to the attention of NRR (50-312/86-15-06).
"The installation of piping system specifically intended to transfer water from the liquid radioactive treatment system to the RHUTs for release to the environment without first performing a safety evaluation se is considered an apparent violation of 10 CFR 50.59 (50-312/86-15-07)
(emphasis added).
"10 CFR 50.71(e) requires in part that each person licensed to operate a nuclear power reactor shall annually update the final safety analysis -
report (FSAR) to assure that the information included in the FSAR contains .
( the latest material developed. The update must be submitted to the NRC -
and shall contain all the changes necessary to reflect information and analyses submitted to the Commission by the licensee or prepared by t N
.~
licensee pursuant to Commission requirement since the submission of the original FSAR or, as appropriate, the last updated FSAR.
" Based on discussions with licensee representatives and review of records, including Control Room Logs, it appears that the licensee has discharged liquid radioactive effluents from T-621 to the RHUTs for release to the environment from early 1983 through March 13, 1986 and did not update the
~
- FSAR to reflect this infonnation. This represents an example of failure to comply with 10 CFR 50.71(e) (emphasis added).
"B. Procedures "1. Technical Specification 6.8, ' Procedures,' reads in part that,
' Written ~ procedures shall be established, implemented and maintained covering the activities referenced below: a. The applicable procedures recommended in Appendix 'A' of Regulatory Guide 1.33, November 1972.' Regulatory Guide 1.33, November 1972, recommends in G., ' Procedure for Control of Radioactivity (For Limiting Materials Released to Environment and Limiting Personnel Exposure),' that procedures be developed for liquid radioactive waste systems including discharging of effluents. ,
t Case No. 5-86-010 24 -
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" Based on discussfuns with licensee. representatives and review of ,
records, it appears that from March 30, 1983, to January 6, 1986, no procedure was maintained which controlled the transfer of radioactively contaminated water from the Demineralized Reactor Coolant Storage Tank (T-621) to the Regenerate 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 l and released to the environment. j
" Based on review of the Control Room Logs for March 1986 and docun,ent control records, it appears that.on March 6.1986, the temporary change to Procedure A.10 " Demineralized Reactor Coolant Storage System," which authorized transfer of water from T-621 to T-950 A f and B was not maintained-in that the procedure expired and a transfer of 6,000 gallons was made to T-950 A on March 10, 1986, and 15,000 gallons were transferred to T-950 B on March 13, 1986.
"2. Technical Specification 6.8.3 reads: ' Temporary changes to procedures of 6.8.1 above may be made provided:
'a. The intent of the original procedure is not altered.
'b. The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor . Operator's
. License on the unit affected.
'c. The change is documented, reviewed by the PRC [ Plant Review .
. . Comittee) and approved by the Plant Superintendent within seven (7) days of implementation.'
" 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.n0 W Demineralized Reactor Coolant Storage-System,' was approved and' implemented which allowed pumping water from T-621 to T-950 A and B for offsite release without review by the Plant Review Committee (PAC). From January 6 ,
1986, to March 6,1986, the Itcenseerestimates.that about:350,000 gallons of water were transferred "In addition, the inspector noted that AP.2 Revision 21, Review, Approval and Maintenance of Procedures, had not been developed consistent with this Technical Specification in that it does not require temporary changes to be reviewed by the PRC. The Principle Regulatory Compliance:
Engineer infomed the. inspector on Mayc21,1986; that.this issue had been '[
previously addressed by the PRC and that they believed 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 Chainnan and approved by the Plant Superintendent. The inspector commented that if Technical Specification 6.8.3.c. sere revised, their technique would be considered acceptable. In any case, the inspector i considered the revision ~to A.10 to be an-intent: change.in view of the FSAR information.- ,
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" Failure to implement and maintain procedures is considered an apparent violation of Technical Specification 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 ~pr ovided in IE Circular No. 80-18: 10 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 y sampling of T-621 prior to transfer such that compliance with Technical 1 Specification 3.17.2 could have been achieved."
Interview of Gregory P. YUHAS, Chief, Facilities Radiological Protection Section, NRC, Eegion V On January 9,d5, and 20, 1987, YUHAS was interviewed and provided detailed information concerning the NRC Inspection No. 50-312/86-15 (EXHIBITS 11, 12, and-13). The information provided by YUHAS is summarized as follows:
From initial startup of RANCHO SECO to the early 1980's, liquid radioactive wastes were shipped offsite to other facilities for disposal. The offsite shipments of the radioactive water were stopped and RANCHO SECO constructed an vc evaporator to handle the disposal of water from the radwaste system. The evaporator never.. functioned properlyc periodicanycreating problems-that, resulted in the release of contaminated water. .
YUHAS explained that in early May 1984, Region V was infonned by SMUD of the ,
i possibility that RANCHO SECO might have exceeded the EPA standard which limit's .
the dose to any real member of the public to less than 25 mrems per year.
RANCHO SEC0's Technical Specifications up to that time allowed the plant to release quantities of radioactive material in liquid effluents of concentrations less than the 10 CFR 20 Appendix B limits, provided the total
' amount released did not exceed 10 Curies per quarter or 20 Curies in 12 consecutive months. If more than 2.5 Curies were released in a quarter, the licensee was required to submit a special report to describe what actions they would take to limit future release to the 5 mrem design objective of RANCHO
{
SECO's Technical Specification. Considering the site specific nature of RANCHO SECO's liquid effluent pathway (a dry site), a release of 2 Curies l
l could have easily exceeded the EPA standard of 25 mrem to a real person.
YUHAS stated that in conjunction with a May 1984, Region V inspection, SMUD issued a Special Report on May 14, 1984, indicating that RANCHO SECO exceeded the dose objectives values for 1981, 1983, and 1984 for a hypothetical adult '
exposed to the liquid pathway. However, SMUD stated they had not exceeded the EPA requirement.
YUHAS stated RANCHO SECO implemented their Technical Specification 3.17.2 requiring compliance with 10 CFR 50, Appendix I dose objectives in July 1984.
Appendix I dose objectives and ALARA criteria intended to keep the licensee {
well within the EPA limitations. Thirty days after the Appendix I Technical {
Specification implementation, an analysis of RANCHO SECO's effluent releases {
revealed that RANCHO SECO was in violation of the specification. Consequently, !
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Case No. 5-86-010 26 -
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. i SMUD issued Special Report 84-07, dated September 27, 1984, stating they were instituting provisions and procedures which would keep RANCHO SECO in compliance with Technical Specification 3.17.2.
YUHAS explained that in connection with the 1984 focus on SMUD's liquid effluent releases, NRR contracted with the Oakridge National La'boratory to I assist in determining if the actual man pathway limits of 40 CFR 190 were l exceeded. YUHAS also related that SMUD hired the Livermore Lab to study the l same issue. According to YUHAS both the Oakridge Lab (contracted by NRC) and i the Livermore Lab (contracted by SMUD) confimed the presence of radioactive ,
]
nuclides in the environment resulting from releases from RANCHO SECO.
YUHAS stated that the findings in Inspection Report 86-15 concerning temporary modificatierr to the DRCST T-621 revealed that the infomation in Special Report 84-07 was not correct. Special Report 84-07 described the steam generator tube leaks and the pathways relevant to the generator tube leaks ,
which concerned a secondary system pathway involving water storage in the !
RHUTs. YUHAS stated that Inspection Report 86-15 found that the temporary modification to the DRCST created a pathway which allowed discharges of liquid radioactive waste to the RHUTs and then release to the environment from 1983 to 1986.
YUHAS stated that the reason for transferring water.from the.DRCST to the RHUTs was not only because of tube leaks, but also because of actual plant
- operations. He explained that because of the large volume of water resulting from plant startups and repair of the steam generator tube leaks, radioactive water had to be disposed of. Also,, reactor trips resulting in frequent
.heatups of the reactor. coolant systems would cause~ rejection of' water and result in excess radioactive water.
During telephone calls on November 22 and November 26, 1985, between him and
- BRADLEY, YUHAS learned that the on-site RANCHO SECO LLD capabilities might not be sufficient to detect if RANCHO SECO was exceeding Appendix I dose objectives. YUHAS explained that Livermore Lab analyses of samples of RHUTs water had detected radioactivity at LLDs well below RANCHO SEC0's LLDs. YUHAS stated that BRADLEY told him in these telephone calls that he (BRADLEY) had informed RODRIGUEZ, POWERS, and SMUD's attorney (name unknown) about the LLD issue. As a result of these conversations, YUHAS requested that BRADLEY conduct an analysis on the activity detected by the Livermore Lab.
YUHAS stated he was notified by BRADLEY on December 5,1985, that the Livermore Lab analysis had detected radioactivity off site. As a result of this information, YUHAS wrote a letter to Frank MIRAGLIA, NRC Headquarters, dated December 12, 1985, infoming NRR that RANCHO SEC0's LLD was not sufficient to assure RANCHO SECO compliance with their own Technical Specifications and Appendix I requirements.
YUHAS stated that NRR, after reviewing the RANCHO SECO LLD/ Appendix I issue, had a March / April 1986 meeting with SMUD representatives. On March 21, 1986, George KALMAN, NRR Project Manager for RANCHO SECO, told Frank WENSLAWSKI, YUHAS' supervisor, that KALMAN had been informed by BRADLEY that RANCHO SEC0
- technicians had altered the LLD counting time to allow the release of liquid effluents to the environment. Upon learning this information, YUHAS telephoned BRADLEY and was infomed that David MIXA, had altered the counting time.
~
_ _ - - _ _ mm mm a
. i l
YUHAS subsequently telephoned MIXA and was informed about the details of the change in the counting time, which occurred while MIXA was conducting an analysis on RHUT water samples. YUHAS related that a record of his conversation with MIXA and relevant followup information is included in YUHAS' April 7,1986, memorandum to the RANCHO SECO Docket File concerning liquid effluent Technical Specification 4.21.1. -
In Inspection Report 86-15, YUHAS reported that a followup inspection performed by SMUD concerning Special Report 84-07, had not detected concentrations of fission or activation products in their effluent releases from RANCHO SECO in 1985. SMUD also reported that RANCHO SECO had no, releases of detectable radioactivity in RANCHO SECO's Semi Annual Effluent Radioactive Release Report dated September 26, 1985. YUHAS stated that the failure to detect radioactivity in the effluent releases was due to RANCHO SECO diluting water l transferred from the DRCST to the RHUTs prior to sampling; and when j radioactivity peaks were detected after dilution, a second analysis was )
conducted using a lower counting time, thereby concealing the earlier detection j of any radioactive peaks and allowing for release of the. water This practice in,.effect created; a record showing that no rad,ioadtMty was' Veleased when in fact it had been, ,
Office of Investigations' Request for Information from SMUD Concerning
- Operations and Management of RANCHO SECO Liquid Effluent Program On July 18, 1986, Robert G. Marsh, Director, NRC, Office of Investigations '
~
Field Office, Region V, requested the following information from John WARD, the newly appointed Deputy General Manager, Nuclear, SMUD (EXHIBIT 14). The request was preceded by a meeting between Marsh and WARD where WARD advised ,
that all the events under investigation preceded his employment with SMUD and he pledged full cooperation with the NRC Investigation of this matter. Marsh specifically requested official SMUD answers to the following questions:
"1. From the issuance of RANCHO SEC0's operating license to present, identify the water sources, from outside the Station's boundary, for all of RANCHO SEC0's water systems, including those systems utilized or necessary for the generation of power as well as those systems utilized or necessary for other plant operations.
"2. Identify what radioactive materials and other contaminants are present in RANCHO SECO's water systems including those systems utilized or necessary for the generation of power as well as those system utilized or necessary for other plant operations.
"3. From the issuance of RANCHO SECO's operating license to present, describe the pathways of the Station's water systems at their points of origin within the plant to their points of release outside the Station's boundary. Also describe the released effluents pathways from the Station's boundary to their ultimate destinations.
"4. From the issuance of RANCHO SECO's operating license to present, provide a detailed account of how and at what intervals radioactive materials are identified and released from the Station's water systems. For each 4
Case No. 5-86-010 28 -
. . j testing process identified, provide the operational requirements for conducting such test.
"5. .From the issuance of RANCHO SECO's operating license to present, provide.
a detailed account of all planned and unplanned modifications to the approved Final Safety Analysis Report (FSAR) program'to identify and release radioactive materials from the stations systems. Provide the reason why each modification occurred.
"6. For those. planned and unplanned releases made other than as' described in the FSAR, from the issuance of RANCHO SECO's operating license to present, provide a description of each release pathway, the volume of 14. quid for each release, the radioactive source and method of determining the source for each release, the amount of radioactivity identified per release and if and how the NRC was notified of each release.
"7. For those planned and unplanned releases made other than as-described in the FSAR, from the issuance of RANCHO SECO's operating license to present, provide an analysis which shows all possible pathways to the environment and the radiological consequences of all possible failures modes.
SMUD's Response to the Office of Investigations' Request for Information On December 2,1986, WARD submitted a letter to Marsh providing SMUD's response
~
to the July 18, 1986 request. The SMUD response is attached (EXHIBIT 15).
.p The attachments to the SMUD response are not appended to this report.-
i However, they are maintained in the Office of Investigations Field Office at ~,
Region V.
Interview of Michael CILLIS, Senior Radiation Specialist, NRC, Region V
'# On December 9,1986, CILLIS, Senior Radiation Specialist, NRC, Region V, was interviewed concerning his review of the SMUD response to the NRC Office of Investigations' questions (EXHIBIT 16). Mr. CILLIS stated that in general, SMUD was responsive to the questions except where the question requested specific information concerning releases of radioactive liquid effluents. In those instances, the answers were incomplete, vague, or failed to contain the requested detail in order to make a comprehensive answer. CILLIS could not make a valid technical review without obtaining additional information.
CILLIS was requested to identify additional information that would be required in order to make a complete technical review.
Office of Investigations' Request to SMUD for Additional Infonnation AfterreviewingthESMUDresponsetotheOfficeofInvestigations'requestfor information, supra, it was determined that clarification and additional information was needed. On December 24, 1986, a letter requesting additional information was sent to SMUD (EXHIBIT 17). <
_ __ h h l-@@-010_ __ 29 -
m . 1 SMUD's Response to Request for Additional Information On February 19, 1987, WARD submitted the SMUD response to_the Office of Investigations' request dated December 24, 1986. The transmittal letter and explanation of the response is attached (EXHIBIT 18). The supporting documents to the SMUD response are not attached to this Report Vf-Investigation, however, they are being retained in the Office of Investigations Field Office at Region V.
Technical Review of SMUD's Response for Additional Information During the period April 13 to April 24, 1987 CILLIS perfonned a technical review of the infonnation that SMUD submitted in response to the Office of Investigations' requests of July 18, 1986, and December 24, 1986. CILLIS prepared a report of his analysis which is attached (EXHIBIT 19). In summary, CILLIS concluded as follows:
SMUD management actions were not commensurate with requirements of 10 CFR Part 50, Appendix I or with the commitments of SMUD Special Report 84-07. To mask the presence of positive gamma radiation peaks did not eliminate the radioactivity. CILLIS believed it was "very deceiving" for SMUD not to report 2 the modification allowing water to be pumped from the DRCST to the RHUTs in 7
Special Report 84-07.
Interview of Lee R. KEILMAN, Former Manager of Nuclear Engineering, RANCHO SECO ,
On March 25, 1987, KEILMAN, Director, SMUD Central California Power Agency No.1, was interviewed concerning releases of radioactive effluent from RANCHO SECO (EXHIBIT 20).
KEILMAN has been employed by SMUD continually from 1968 to the present.
During the period from May 1983 to March 1986, he was the Manager of Nuclear Engineering for RANCHO SECO. In that position he was responsible for managing all nuclear engineering activities at RANCHO SECO through a project engineer i and several subordinate engineering supervisors. t KEILMAN reported to RODRIGUEZ, Assistant General Manager, Nuclear. Also under KEILMAN's direction was Roger POWERS, Supervisor of Nuclear Fuels, and )
Bob DIETERICH, Supervisory Nuclear Engineer in Charge of Licensing. l KEILMAN explained that the Nuclear Engineering Division did not have responsibility for monitoring liquid effluents or releases of radioactive effluents from RANCHO SECO nor would the temporary modification used to move
- radioacti'/e water from the DRCST to the RHUTs fall under his responsibility.
All of those activities were the responsibility of Pierre OUBRE, Manager of l
Nuclear Operations.
- l
[
Had the modification been a permanent installation, there would have been f l
required detailed designs, reviews by record level engineers, and the t
I modification would have been included in the configuration control system. A temporary modification ~would require a red tag but that would have been the 30 Case No. 5-86-010
9 responsibility of the operations staff of the plant. KEILMAN stated there was no established process for coordinating a temporary modification made by operations with nuclear engineering. He also stated that it was possible that it would be more professional to have such an engineering review because temporary modifications could result in the permanent change in the design or i
operation of the plant. The modification of moving radioactive-Water from the l
DRCST to the RHUT was in fact a modification that changed the design of the l plant. The plant was not intended to move radioactive water to the secondary i system and then released to the environment. Any such changes or modifications such as that should have been processed through a design review, the PRC, and the Management Safety Review Comittee (MSRC).
KEILMAN was knowledgeable of Report 84-07 but claimed he did not have responsibility for that report. However, SMUD comitments made to the NRC should have been entered into the computerized comitment. tracking system.
If SMUD intended to accomplish the tasks, they would have to be placed in the commitment tracking system or they would probably not get done. KEILMAN believed the comitment to build evaporating ponds as stated in Report 84-07 was entered into the comitment tracking system but ponds were never constructed. KEILMAN acknowledged that although the evaporation ponds n -
~
represented as corrective actions that would be accomplished, SMUD had no actual knowledge if the ponds could be constructed because none of the preliminary design work or environmental studies had been done. The statement that SMUD intended to construct the ponds as was specifically spelled out was
- misleading because permits and approvals had not been obtained.
Some time in the early part of 1985, BRADLEY reported to KEILMAN that the calculations for the LLD were in error and were not sufficient to assure compliance with radioactive dose objectives of 10 CFR 50 Appendix I. BRADLEY was specifically concerned that the radioactive releases were greater than the calculations would indicate. The MSRC, which was composed of ten of the SPUD top management officials within the nuclear organization, met about every two weeks, and the releases of radioactivity, as calculated by BRADLEY, were discussed on several occasions in 1985. MSRC meeting minutes should document the discussions. KEILMAN believed that POWERS and BRADLEY made a presentation to the MSRC on that specific topic and a plan of action which included performing off site downstream samples was initiated. KEILMAN recalled that all of these actions occurred prior to the sumer of 1985.
KEILMAN could not recall any discussions about releases from the DRCST but if water was being released from the DRCST through the RHUTs, it would be logical to check that process as a pathway for radioactivity being released. POWERS was assigned responsibility for collecting all the data for offsite dose calculations. KEILMAN believed POWERS composed some reports but the primary report was made by Dr. NOSKIN of the Livermore Lab.
KEILMAN advised that BRADLEY's calculations were confirmed prior to the actions by Livermore Lab in the summer of 1985. He could offer no explanation for why BRADLEY's findings that were confirmed by the sumer of 1985, were not reported until October 29, 1985, except that the findings may have needed checking. KEILMAN claimed not to have given any instructions that would have way3ed BRADLEY's report to be held up until after the plant had restarted.
Case No. 5-86-010 31
KEILMAN believed that a Licensee Event Report (LER) was filed in early 1985 by COLOMBO concerning the dose calculations problems surfaced by BRADLEY. That was part of the plan of action that POWERS was responsible for implementing.
KEILMAN claimed that although he had no direct knowledge of anyone reducing the count time to 1000 seconds for detecting radiation prior t6 release, late in 1985 he heard that that had happened.
He believed that KELLIE and MILLER would have been knowledgeable of BRADLEY's calculations because they all had worked together on the problem. Also, BRADLEY had been responsible for collecting the information for the annual report and should have reflected that radioactive effluents had been released beyond certain levels.
KEILMAN explained that MIXA had come to him and expressed concerns about being instructed to lower the count time from 2000 to 1000 seconds. MIXA was afraid that such action was wrong. ' KEILMAN claimed he told MIXA not to worry, someone else would resolve that problem and he was a technician doing his job as he was instructed. KEILMAN explained that he believed KELLIE was responsible for instructing MIXA to shorten the counting time when checking for radioactivity. KEILMAN stated that he never made any correlation between the findings that the dose calculation were in error as presented by BRADLEY, the finding of radioactivity downstream by the Livermore Lab, and the lowering
- of the chemistry count times for detecting radioactive releases. However, KEILMAN admitted that if radioactive peaks were detected and not reported that ~'
it would be contrary to the documented interpretation between YUHAS and KELLIE concerning reporting detected radioactive nuclides. KEILMAN explained that .
the most effective time to detect radioactivity *;;ould be prior to diluting thi RHUTs because after dilution, it is more difficult to detect.
Interview of Roger L. POWERS, SMUD Supervisory Nuclear Engineer On March 25, 1987, POWERS was interviewed regarding his knowledge of SMUD's J management and operations of the Liquid Effluents Release Program at RANCHO SECO (EXHIBIT 21).
POWERS was BRADLEY's supervisor and was aware of a study performed by BRADLEY concerning the LLO issue. That 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 allowed for the reporting of problems and adhering to the license of Technical Specifications. POWERS stated the fact BRADLEY took no action through Administrative Procedure No. 22 was an indication to POWERS that no further management action needed to be devoted to BRADLEY's concern.
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 reasonable fraction of the i 3 mrem limits of 10 CFR, Appendix 1. BRADLEY wanted that reasonable fraction to be reduced but POWERS did not> concur.
Case No. 5-86-010 32 -
t POWERS became 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 lower count time.. POWERS i recalled that George COWARD, SMUD Engineer, was also involved in'this j conversation with RODRIGUEZ and him (POWERS) concerning the composite sample 1 analysis and the direction to KELLIE to run the composite analysis. 1 POWERS detemined, based on reviews of the draft LLD study performed in the summer of 1985 by MILLER and KELLIE, that BRADLEY's concern on the LLD issue.
was not significant. POWERS stated that he did not have any conversations with KEILMAN, his supervisor, concerning BRADLEY's LLD issue. 'I In December 1985, SMUD management decided to move forward on the LLD issue and determine what the issue implied through the CEP analysis.
POWERS stated he did not remember any discussion with BRADLEY to withhold or delay the issuance of BRADLEY's draft LLD study until resolution of a high point vent break issue and/or the restart of the plant. POWERS stated if in
< fact the issuance of BRADLEY's draft LLD study was held up, it could have been due to the legal suits against SMUD at that time.
Interview of David R. MIXA, Former RANCHO SECO Chemical / Radiation Technician
~
- On January 26, 1987, MIXA, Contract Analyst for Nuclear Support Services,
" SMUD, was interviewed regarding his knowledge of the alteration of counting e
- times on analysis for radioactivity in water contained in the RHUTs at RANCHO SECO (EXHIBIT 22). From April 1984 to October 1985, MIXA was a Chemical and Radiation Protection Technician at RANCHO SECO.
-- He recalled that when he started work in 1984, there were instructions on the bulletin board in the Chemistry Lab regarding the counting time for detection of radiation. He stated the Canberra Computer Program was implemented in the first part of 1985, and the program was established with a count time of 3000 seconds. It was later believed that RANCHO SECO could meet the LLD with a 2000 second count time so the time was reduced to 2000 seconds.
There were no fomal written procedures or documented instructions concerning the 2000 second count but information was written on the bulletin board in the Chemistry Lab directing the technicians to use a 2000 second count time in their testing activities.
On March 20, 1985, MIXA, while testing water of the RHUTS, detected radioactivity using the 2000 seconds count time. He believed that might have been the catalyst for instituting a lower 1000 second count. MIXA made the activity entry into the radiation log book and reported to the Control Room Operator that the RHUT water could not be released becau.se of the indication of radioactivity. After reporting the peak to the Control Room, MIXA weiif contacted by KELLIE who inquired about the activity. MIXA recalled that the water was backed up in the plant and the tanks were at capacity. KELLIE instructed MIXA to redo the analysis on the RHUTs using a counting time of 1500 seconds and if no peaks were identified, then proceed with the release.
O i __ m_ _ _ b
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According to MIXA, KELL 1E's reason for directing the lower count time was the need to release the water. .A copy of the March 20, 1985, Chemical / Radiation' Log is attached (EXHIBIT 23)J MIXA felt uncomfortable in lowering the counting time to 1500 seconds and then reporting to the Control Room that there was no activity when in fact he knew there was radioactivity. It was MIXA's understanding that the reduction in the count time was done so that SMUD could maintain their public commitment of not releasing any radioactive isotopes to the environment.
MIXA stated that he felt the pressure from the Control Room Operators was sometimes excessive in that the Control Room Operators were anxious to have the water released as soon as possible. At times, for example, a Control Room Operator would contact MIXA during the middle of his analysis inquiring if it appeared the water would be able to be released. MIXA recalled specifically talking with Al FRAZIER, a Control Room Operator, several times concerning the release of water in conjunction with MIXA's analysis.
MIXA explained that when radioactivity peaks were identified at a 2000 second count, it would be discounted and a second count was run at 1000 seconds. If peaks were still identified within the 1000 second count, then the water was returned back to the system. If the second count was negative regarding detected peaks, a third count of 1000 seconds was conducted and any positive
% indications caused the water to be sent back and any negative indications allowed the water to be released. MIXA stated that he always notified the Control Room of identified activity during 2000 second counts.
MIXA explained that the detection equipment. was very: sensitive. and any, change 3 such as replacing the RHUT 1.iners.or. receiving wa~ter ~from the~ secondary systems sumps could have caused indications of highen,radioactiv.ity?
Interviews of RANCHO SECO Chemical / Radiation Technicians On January 26, 1987, four Chemistry / Radiation Technicians were individually interviewed concerning their knowledge of releases of radioactive liquid effluents from RANCHO SECO.
Wayne HAMPTON, Pamela HOWARD, and Mark LEINWANDER each stated that the counting time for detecting the presence of radioactive nuclides had been reduced from 2000 seconds to 1000 seconds. The reason for this was that the capacities of the RHUTs had been reached ard unless the test showed no radioactivity, the i water could not be released; therefore, the counting time changed as the need !
to release water changed.
l Walter PARTRIDGE reported that he and MANOFSKY had performed samples at 1000 seconds and believed the LLD was met.
Reports of Interviews for HAMPTON, HOWARD, LEINWANDER, and PARTRIDGE are attached (EXHIBITS 24, 25, 26, and 27). -
t Case No. 5-86-010 34
6 Interview of William A. WILSON, SMUD Acting Chemistry Operation Supervisor On March 24, 1987 WILSON, SMUD Acting Chemistry Operations Supervisor at RANCHO SECO, was interviewed regarding his knowledge of the liquid effluents release program at RANCHO SECO (EXHIBIT 28). .I WILSON was questioned regarding his knowledge of SMUD's Special Report 84-07 and he advised that he probably helped generate some of the " raw data" that was used in that report, however, he did not recall seeing the report in its final form. WILSON added that he may have talked with his Supervisor, KELLIE, regarding the data in the report but he could not specifically recall. WILSON advised that KELLIE was the individual responsible to provide input to create the report and added that possibly another SMUD employee, Roger MILLER, may also have been involved.
WILSON was questioned regarding sources of radiological contamination in the secondary system of RANCHO SECO, and he stated that steam generator tube leaks were the only major source. WILSON stated that he knew of no other sources of contamination. WILSON stated that during 1985 he could recall there being a "little bit" of radiological contamination in the secondary system, however, e this contamination was "almost undetectable." In reference to eliminating
- radiological contamination in the secondary system WILSON stated that typically the method utilized to remove the contamination was to recycle the water through the resin demineralizers which were capable of removing the majority of radioisotopes from the water with the exception of tritium and n some fission gases. ,
WILSON was questioned regarding his knowledge of the DRCST and the RHUTs and he stated that he was familiar with both of these tanks and their functions.
WILSON advised that routinely, water maintained in the DRCST was not pumped to the RHUTs, however, in the past that had been done on some occasions via a temporary pump and piping system. WILSON added that the reason to move water from the DRCST to the RHUTs was because the DRCST was full to capacity.
WILSON added that the reason for the maximum amount of water in the DRCST was due, in part, from secondary system water in the RHUTs being transferred to '
the DRCST in order to! remove the radioactivity from the secondary system water. Putting the water through the evaporators associated with the DRCST piping lowered the radioactivity of the water. WILSON stated that he could recall moving water from the RHUTs to the DRCST in order to remove the radioactivity from the water on only one occasion and that when this was done, the water was then returned to the RHUTs via a temporary piping system.
WILSON was questioned as to his knowledge of who directed that the temporary piping modification be made and he stated that he did not know who authorized the modification. WILSON advised that he did not know if such a temporary modification was required to be reported to the NRC and he did not know whether a report was filed with the NRC regarding the modification nor was he aware of any reason for the modification not being reported to the NRC.
WILSON added that he was not involved in any effort at RANCHO SECO to notify the NRC concerning the temporary piping modification nor did he advise any of his superiors regarding whether or not a report should have been filed with the NRC regarding the temporary modification. WILSON advised that his job position, however, was not such that he was involved in making reports to the l
, NRC.
I
.I WILSON stated that he wa's aware that in 1985, approximately 780,500 gallonsof water from the DRCST was released to the environment via the RHUTs due to an-excess accumulation of water in the DRCST. WILSON advised that the water transfer between the tanks was made via the temporary modification after which the water was emptied into an open air retention basin and then to a creek, the name of which he (WILSON) was not aware. WILSON stated tha't he was involved in the above noted transfer of water, in that individuals under his supervision took samples of the water of the DRCST for tritium concentration and made recommendations regarding the amount of water to be transferred from the DRCST to the RHUTs for dilution. WILSON added that after dilution, individuals under his supervision would resample the water of the RHUTs to l ensure that the limits set forth in 10 CFR 20 for tritium were not exceeded.
WILSON advised that the sampling of the DRCST was done on a periodic basis and that no special monitoring of the DRCST was done for the express purpose of transferring water to the RHUTs. WILSON added that in reference to the samples taken at the RHUTs, his subordinates would sample the tanks for 1
" chemical constituents, plus tritium and gamma activity." WILSON stated that thereasonforthismonitoringwastoinsure}hatthewaterbeingreleaseddid not exceed the technical specification of 5E~ microcuries per cc sensitivity.
WILSON explained that in order to make a water release to the environment from l the plant, both a tritium analysis and a gama scan were performed of the water and if the appropriate sensitivity requirements were met, then the release was made. WILSON added that tt activity required a sensitivity of SE~je technicalper microcuries specification cc and that for th gama tritiumanalysisrequiredatechnicalspecificationsensitivityofIE~g ,
microcuries per cc.
WILSON was questioned regarding the near term corrective actions listed in .
Special Report 84-07, and specifically, the " administrative policy to control releases such that monthly calculated doses were under technical specification limits." WILSON stated that this near tem corrective action meant that liquid effluent releases from the plant would not exceed one and one half mrem total body and five mrem to any organ. WILSON explained that in reference to Action Item No. 7 his organization would submit their analyses to a different group located at RANCHO SECO that would review the analyses and "come up with a dose calculation." WILSON stated that these post release calculations were done on a monthly basis, however, his (WILSON's) group did not review dose calculations as this was done by BRADLEY, an individual in a different group at RANCHO SECO.
WILSON was questioned regarding the LLD draft report written by BRADLEY during October 1985. WILSON stated that he was not familiar with that document as he could not recall reviewing either the draft or final report. WILSON advised that he did not take any action concerning BRADLEY's concerns regarding LLDs although he (WILSON) recalled being concerned about the information in the report and recalled that his group "had to look at what we could do to lower the LLDs." WILSON stated that the LLD was affected by the " count time" which was the length of time a sample was counted. WILSON added that at one point in time, a count time of 2000 seconds was used and that subsequently, this count time was changed to 1000 seconds. WILSON stated that to the best of his recollection, KELLIE, his supervisor, was the individual who directed that the count time be changed from 2000 seconds to 1000 seconds. WILSON added that achieving the LLD, which he claimed was not changed by changing the counting time, brought RANCHO SECO in conformance with the requirements of 10 CFR 20 Case No. 5-86-010 36
and also 10 CFR 50, Appendix I. WILSON averted that in his interpretation, the meeting of those requirements of 10 CFR 20 was all that was required and as long as those requirements were met, he (WILSON) was doing nothing wrcng WILSON stated that ';he original count time of 2000 Teconds was contair.ed in written procedures and that after the count time was changed to 1000 seconds, the procedures were not changed to reflect the new count time. '4ILSON agreed
! that as a consequence of that action, the procedures which required a counting time of 2000 seconds were violated when only counting for 1000 seconds. WILSON stated that he had no knowledge if KELLIE's supervisor, COWARD, directed the count time be reduced to 1000 seconds.
WILSON admitted that the changing of the count time from 2000 seconds to 1000 seconds did eliminate some positive readings from occurring which should have been reported pursuant to the Technical Specifications, and thus not reporting these resdings was a violation of the Technical Specifications.
WILSON was questioned regarding the finding of Cesium 137 in downstream sediment in a creek near RANCHO SECO. WILSON stated that in his opinion, certain plant life and dirt collect and concentrate radioactivity and that accumulation, in conjunction with the use of more sensitive equipment by the
- Livermore Lab, detected the radioactive material. WILSON stated that in his opinion, the lowering of the count time was not involved with the unexpected radioactivity detected downstream from the RANCHO SECO plant. WILSON added that he was sure that the LLD issue raised by BRADLEY in that the limits set by 10 CFR, Appendix I, had been exceeded was involved in the finding of
~
Cesium 137 downstream from the RANCHO SEC0 plant.
v #
Interview of Stephen C. MANOFSKY, RANCHO SECO Chemistry Supervisor On March 24, 1987, MANOFSKY, Acting Chemical Quality Supervisor, RANCHO SECO, was interviewed regarding his knowledge of SMUD'c management and operations of the liquid effluent release program at RANCHO SECO (EXHIBIT 29). The interview of MANOFSKY is summarized as follows:
MANOFSKY was aware of Special Report 84-07 before this interview, but he was not involved in the preparation of the report.
Upon reviewing the report, MANOFSKY stated that some of the numbers in the report did not look like the same numbers he had reported. He, therefore, thought that the dose report may have been provided by the health physics section of SMUD headquarters in Sacramento.
To his knowledge, steam generator tube leaks were the only source of liquid contamination for the secondary system, however, he was familiar with the DRCST. He was not aware that SMUD had not reported to the NRC the modification which allowed the water to be transferred from the DRCST to the RHUTs.
He was not involved in the engineering modification for the plastic pipes erected between the DRCST and the RHUiS, and neither his supervisor nor any member of SMUD management discussed the modification with him.
In 1985, RANCHO SECO was in a long-time outage. RANCHO SECO periodically released water to lower their water volume. That was caused because a lot of a
Case No. 5-86-010 37 _
?
l
~
l the water was returned to the primary system to be reprocessed, and then was discharged as treated wate.. It was treated so that they would not release as much radioactivity as they wculd have if they had just released the water as i t came t' .n .
Accordig :.o MANOFSKY. KELLIE authorized the lowering of the counting time on l I
the analysis of the RHUT samples.
MANOFSKY participated in the analysis activity before water was released from the RHUTs to the retention ponds. All of the releases were to be below the LLD which were later found to be too high, which was completely unknown to him at the time. He thought they were complying with this by meeting all the LLDs. He did not know they were not in compliance on their effluent releases until the end of 1985 when YUHAS conducted a special inspection.
MANOFSKY was familiar with the draft report issued by BRADLEY on the LLD on October 29, 1985. The way BRADLEY first presented the data, MANOFSKY believed the procedure was not plausible because of the way BRADLEY omitted specific information on the isotopes. However, in response to BRADLEY's recommendations, RANCHO SECO started compositing more samples, the
-. non-radioactive with the radioactive, and sending those off for more analysis e and gama scans so that they could reach a lower LLD. By that point in time, however, the majority of the releases had already occurred.
As he remembers, the lowering of the counting times were discussed and.,
everybody was under the impression they were meeting all the Appendix I criteria. MAN 0FSKY believed they have always recorded or reported the positive peaks when they showed up on the gamma scan, regardless of whether they were -
lower than the LLD. To meet the criteria for proper detection of radioactivity, RANCHO SECO was now counting for 4000 seconds and sometimes
- 6000 seconds, depending upon what the background was in the samples.
- In essence, MANOFSKY stated that they changed their criteria and lowered or raised their count time depending on the desire to detect radioactivity.
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.
He was never involved in any discussions regarding whether or not the modification that had allowed the transfer of water from the DRCST to the RHUT should be made known to the NRC.
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.
Interview of Roger I. MILLER, SMUD Chemistry / Radiation Protection Superintendent ,
On March 24, 1987 MILLER, SMUD, Chemistry / Radiation Protection Superintendent (Retired June 1985), was interviewed regarding management and operations of the Liquid Effluents Release Program at RANCHO SECO (EXHIBIT 30). A sumary of information provided by MILLER is as follows: ,
Case No. 5-86-010 38
MILLER believed that an analysis was required when there was any movement of water between tankage at RANCHO SECO. 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.
MILLER explained that he was the SMUD manager responsible for Near Term Correction Action No. 7 in Special Report 84-07. The intent of Action Item No. 7 was to not exceed the limits of Technical Specification 3.17.2. He did not recall any specific actions that were im with the Consnitment in Action Item No. 7. ] plemented to assure compliance MILLER acknowledged that he was aware of the practice of lowering the RHUT sample count times, and stated the reason for lowering the count time was to speed up the release of water from the overflowing tanks.
Regarding the June 6, 1985, telephone conversation between KELLIE and NRC's YUHAS, MILLER stated that his interpretation of that telecon indicated that l KELLIE was instructed to report identified peaks when obtained in the sample l analysis. MILLER stated that a generalized direction was given to the Chemistry and Radiation Protection personnel that sample analysis which had measurable amounts of radioactivity was reportable. MILLER stated this was a direction that had e1 ways existed for the Chemistry and Radiation Protection personnel.
MILLER explained that the Operations Division had a difficult problem with exces's water inventory build ups due to the fact that RANCHO SECO was designed
. as a dry site. This situation created a management and operations problem to'-
'J limit the amount of water in RANCHO SECO's inventory that contained
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radioactivity in order to keep the plant functioning.
Interview of Fred W. KELLIE, SMUD Radiation Protection Superintendent On March 24, 1987 KELLIE, SMUD, Radiation Protection Superintendent, was interviewed regarding his knowledge of SMUD's management and operations of the Liquid Effluents Release Program at RANCHO SECO (EXHIBIT 31). The information listed below is a summary of the transcript of that interview:
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 shutdown which necessitated the use of borated water. With startup, the borated water needed dilution which required significant amounts of water makeup.
Water from the miscellaneous waste system had at one time been shipped off site. The off site shipment stopped in the late 1970's because the regulatory requirements were changed to prohibit such shipments.
It was KELLIE's opinion that everyone connected with the. modification allowing water to be transferred from the DRCST to the RHUT believed that modification to be legal. In October 1984. KELLIE's Supervisor, MILLER, told KELLIE that there would be no more releases of radioactivity in liquid effluents from Case No. 5-86-010 39
RANCHO SECO. KELLIE stated no explanation accompanied MILLER's statement
- other than that releases containing tritium in liquid effluents were 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. ,;
After implementation of the RETS, detection of radioactivity in the RHUT required the water from the RHUT to be returned to the miscellaneous waste holdup tank (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 channelled into the 30,000 gallon capacity MWHUT.
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 MWHUT. KELLIE explained that water in the MWHUT was used for decontamination and thus could not contain gross beta activity. KELLIE i related that if gross beta activity was present, there would also be gama emitters present; but the detectiog of..gamum emitting,radteisotopes depends on the langth of the counti g time b; KELLIE recalled a meeting he and others had with'PTant Manager OUBRE;"l1n 1988
- concerning the DRCST modificationOThat meeting was held in conjunction with the steam generator tube leaks, and KELLIE did not recall anyone mant.ioning g the. necessity to repoct, tha.modificad$bn to NRC in' that meeting. ' ."
In 1981, OUBRE directed KELLIE to draw up precedures.to ~ standardize the DRCSTl '
modification. OUBRE's direction to KELLIE was made after the first steam generator tube leak was corrected in 1981. KELLIE made recommendations on how to standardize the removal of water from the DRCST but not aU.of his recommendations were accepted. Consequently, he never followedJthrough on the directions to draw up procedures for the DSGST, modification.<
KELLIE, before releasing the DRCST water to the RHUT, took water samples for tritium analysis. No gama emitting analysis was conducted on these DRCST samples.
KELLIE explained that when s tine.restraintsi. required water in the RHUT to b&
released as soon as possible, he would use the plant ~ service water for di10 tion of the RHUT. The dilution was to assure that tritium in the RHUT was released within the specified limits of Maximum Permissible Concentration. KELLIE stated there was no procedure for a dilution factor for gross beta and gama emittars 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.
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 Case No. 5-86-010 40
f a
s direction from COWARD as to whether lowering the counting tir. was legal. I KELLIE stated he made the decision to lower the count time on the analysis of RHUT samples.
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 conversations was normal. The fact that KELLIE doubted the validity of BRADLEY's LLD issue caused KELLIE to take no action to determine if the lowering of the analysis count time was affected 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 confimed as being valid.
KELLIE did not discuss with his Senior Chemist and Radiation Assistants the contents of the June 6 telephone conversation with YUHAS because KELLIE hada already received instructions from MILLER not to release any radioactivity in liquid effluents:
KELLIE did not change the process on how the RHUTs were diluted and sampled afte~ he was instructed by MILLER in October 1984 not to make any radioactive releases.
KELLIE acknowledged that he understood that 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 nomal leakage from the secondary system into the
,- reactor building sump under normal operating conditions created an increase in the water inventory of the DRCST. .-
Water in the DRCST is chemically clean although it contains radioactive isotopes. This water serves as makeup water for the reactor coolant system (primary system).
.- KELLIE claimed to have had no involvement in the fomulation and input of infomation 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 MILLER, the RANCHO SECO Chemistry Radiation Protection Superintendent.
l Interview of George A. COWARD, RANCHO SECO Plant Manager On March 24, 1987, COWARD, SMUD Engineer, and fomer RANCHO SECO Plant Manager, was interviewed regarding his knowledge of SMUD's management and operations of the RANCHO SECO Liquid Effluents Program (EXHIBIT 32). The information listed below is a sumary of the interview transcript.
In approximately September 1934, there were numerous management meetings concerning the generation of radioactive waste because of the steam generator tube leaks at RANCHO SECO. C0 WARD's primary interface c.oncerning Special Report 84-07 was his wrvisor, Pierre OUBRE. 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.
Case No. 5-86-010 41
I I
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. 4 l
l The draining of the fuel transfer canal several times in 1985 t'o reiiair a reactor coolant pump created an excess amount of water in the RANCHO SEC0 water inventory.
The DRCST was analyzed on a regular basis to determine the leveis of radioactive tritium but there was no individual sampling of the DRCST before every transfer to the RHUT.
The lowering of the analysis count time was a public relations move because of the commitment 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 gama peaks and, therefore, a non radioactive release. COWARD m
authorized KELLIE to lower the RHUT samples analysis count time.)
COWARD did not discuss the authorization or practice of lowering the countm time with OUBRE or RODRIGUEZ because these individuals were not at their office on the day that C0 WARD and KELLIE discussed the basis for lowering the count time. COWARD felt that the fact the lower count time met the LLD _
Technical Specification did not require notification tot OUBRE or RODRIGUEZ.
When an 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.
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COWARD acknowledged that changing-theoase4ysis:ceunth*:imasuon.. samples frontthe RHUT changed the LLD for the sampTe.*
With the issuance of BRADLEY's October 29 memorandum on the LLD issue, as well as the Livermore Lab's findings of radioactivity in sediment beds downstream from the RANCHO SECO release point, SMUD management began to focus on the LLD issue. Management meetings were conducted in an effort to tighten up the j 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 stated this refocus on the management and operations of liquid effluent releeses was made in conjunction with BRADLEY's !
memorandum 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 system from the RHUTS, the implementation of throw away demineralizers used in the secondary water clean up system, and changing the dilution flow rate of water being released to the environment.
COWARD stated RODRIGUEZ was aware of the Livermore Lab's finding in October 1985 and supported the actions that corrected the situation. COWARD Case No. 5-86-010 42
I o l
't 1
acknowledged that technically diluting the RHUT which already contained water l from the DRCST, reduced the likelihood off detecting radioactivity. ;
i COWARD acknowledged the temporary modification allowing water to be transferred from the DRCST to the RHUTs should have been incorporated into'"the plant design system as a permanent structure.
Short Term Corrective Action Item VII in Special Report 84-07 meant that water 4 in the RHUT, which contained radioactivity or gama peaks, was not to be j released to the retention basim If the analysis showed that there were no I
. gama emitters, the analysis was called LLD and the water was released to the environment. Instructions were given to the Chemistry and Radiation and *
~
Operations Manager not to release water that had gama' emitters. Water containing gama emitters would be sent back to the Miscellaneous Waste Syst'em and processed. The source of this instruction was the Plant Manager, OUBRE.
Interview of Pierre OUBRE, SMUD Acting Assistant General Manager of Engineering and Operations On March 24, 1987, OUBRE, SMUD Acting Assistant General Manager of Engineering and Operations, was interviewed regarding his knowledge of the management of RANCHO SEC0's Liquid Effluents Program. The transcription of the interview is
- . attached (EXHIBIT 33), and is sumarized as follows
During the period from 1978 to 1983, OUBRE held the position of Plant Superintendent and from 1983 to August 1985, he was the Manager of Nuclear a Operations for the RANCHO SECO Nuclear Power Generating Station, a SMUD .
facility. In those positions, OUBRE was responsible for the operation of
- RANCHO SECO. COWARD had assumed the position of Plant Superintendent when OUBRE was promoted to manager of Nuclear Operations and OUBRE managed the plant through COWARD. ,
The Radiation Protection Chemistry Division, under the supervision of MILLER and the Plant Superintendent, would have been responsible for controlling effluents and the releases of effluents from RANCHO SECO. KELLIE was the Supervisory Chemist responsible for supervising the daily operations of the Radiation Protection Chemistry Division during the 1984 time period. In 1985 KELLIE was promoted to Superintendent when MILLER retired.
OUBRE was ft.miliar with Special Report 84-0? concerning the comitments of SMUD not to make any radioactive releases from RANCHO SECO and, therefore, would not require a variance to the NRC Operating License.
He stated the comitment to the NRC was a topic of general discussion at the weekly Friday morning staff meetings held by the Executive Director for Nuclear, RODRIGUEZ. All the top level managers from RANCHO SECO would attend which generally included: KEILMAN, Andy SCHWIEGER, Bob DIETERICH, as well as himself. Prior to submittal to the NRC, Special Report 84-07 was composed !"'
the Engineering Department and coordinated through COLOMB0 who was responsible l
for communications with the NRC. The pathway of effluents that were described in Special Report 84-07 would have been under the operational control of OUBRE and any effluent pathway information that was not correctly represented in the l
report should have been addressed by OUBRE's organization. The report would
/
Case No. 5-86-010 43 _
I have then been sent back to the Engineering Department for their coordination with COLOMBO and final signature by RODRIGUEZ. .
1 OUBRE acknowledged being aware of the modification to the operation of the_. !
plant wherein water contained in the DRCST could be moved to the.BHUT. OUBRE l could not say whether the modification was ever formally reported to the NRC l t%t he believed the NRC Resident Inspector had been aware of the modification. i OUBRE stated that during the early operating days of RANCHO SECO water that .
now went to the DRCST had been disposed of by shipping to a disposal site in {
Galveston, Texas. However, after that process was no longer available, the effluents were moved via the modification to the RHUTs and then released to the environment. OUBRE further explained that prior to the comitment to NRC' in Special Report 84-07, as long as the effluents were diluted sufficiently d :
that the concentration of nuclides was below the requirements, the release was .
ok. But after Report 84-07, if radioactive nuclides were detected, the water should not have been released. Further, that when testing for lower levels of radioactivity, to reduce the time of the test would reduce the ability to detect radioactive contamination. Therefore, if the counting time was shortened, SMUD would be less vigilant rather than more vigilant as represented
. in the SMUD Report 84-07. Also, the interpretation documented based on a ;
June 6, 1985, telecon between KELLIE and YUHAS would indicate that any detected 7 peaks in nuclides must be reported. To reduce the count time during testing ~
would reduce the ability to detect nuclide peaks. Dilution of water prior to] '
testing would also reduce the ability to detect radioactive peaks.')
OUBRE stated that RANCHO SECO was not designed to release radioactive water -
and this was only done after the process of shipping the radioactive water to ,
a disposal cite was stopped. He also stated that the pathway of . radioactivity to the environment coming from the DRCST should have beenifep6rtid'to the NRC.~
, OUBRE advised that he did not know until about 60 days before this interview that KELLIE had shortened the count time for chemistry tests for release of radioactive effluents. OUBRE further explained that prior to Special Report 84-07, if a nuclide was above the LLD and the tank was diluted, the nuclide could then be below the LLD, and would go unreported. After the Report 84-07 in September 1984, to dilute the RHUT water down to an acceptt.:e reading of radioactivity and then release it would be inappropriate becLuse the commitment would not allow radioactive releases. OUBRE stated he was unaware of making any releases of radioactive effluents, however, if the tests were manipulated by shortening the count time or diluting prior to testing, otherwise reportable releases would not have been reported and that would have made him very mad.
Interview of Ronald J. RODRIGUEZ, SMUD Assistant General Manacer, Nuclear On April 7, 1987, RODRIGUEZ, SMUD's former Assistant General Manager, was interviewed regarding the management of SMUD's operation of the Liquid Effluents Release Program at RANCHO SECO. The information listed below is a sumary of the interview transcript (EXHIBIT 34):
RODRIGUEZ stated he recalled BRADLEY discussing the LLD issue in terms that if all samples were just below RANCHO SECO's Technical Specification LLD, then the Technical Specification might be exceeded. RODRIGUEZ did not recall when
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Case No. 5-86-010 44
o BRADLEY's explanation on the LLD issue took place. RODRIGUEZ recalled that BRADLEY wanted the CEP data analyzed to detemine just what the activity of the releases were in relation to RANCHO SECO's Technical Specification.
{
RODRIGUEZ stated that BRADLEY explained to him (RODRIGUEZ) that.KELLIE hadt )
been requested to do a CEP analysis by BRADLEY but that KELLIE 'did not take i
any action on this request. As a result, RODRIGUEZ directed COWARD to assure that the CEP analysis was conducted. . ,
l RODRIGUEZ stated that he did not recall any conversations with BRADLEY to hold 4
. up the issuance of BRADLEY's draft LLD study until after resolution of a high point vent break and/or restart of the plant.
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. j RODRIGUEZ recalled' talking to C0 WARD about lowering the sample analysis count-time. COWARD had told RODRIGUEZ that the issue was not a problem. RODRIGUEI; explained that it was COWARD's responsibility tolassure that the decision to lower the sample analysis count time was proper. D i -RODRIGUEZ did not recall any specifics concerning KELLIE's June 6, 1985, telephone conversation with NRC's 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 identified.
RODRIGUEZ stated he held OUBRE, COWARD, MILLER, and KELLIE responsible to correlate the Livemore Lab findings, commitments made in 84-07, and BRADLEY's LLD issue. RODRIGUEZ stated it was wrong that no one in the organization correlated the Livermore Lab findings, the commitments in 84-07, and BRADLEY's
-- LLD issue with the lowering of the sample analysis count time.
RODRIGUEZ could not explain why the DRCST modification was not updated in >
RANCHO SECO's UFSAR because the modification was a change in the design of the plant. RODRIGUEZ acknowledged that although the modification was considered temporary, it existed over a lengthy time. RODRIGUEZ explained that DIETERICH, the Supervising NuclearEngineer for Licensing Matters; was responsible for updating the UFSARs. @DRIGUEZ was not aware how the UFSAR updates were accomplished or the degree of attention that DIETERICH gave to such matters. ,
RODRIGUEZ explained that in mid-1985 DIETERICH reported directly to RODRIGUEZ. (
RODRIGUEZ stated that Special Report 84-07 indicated a variance for continued operation 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 YUHAS in meetings with NRC concerning RANCHO SECO exceeding their radiological and environmental Technical Specifications. RODRIGUEZ
' recalled 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 they related to whether a variance was needed.
Case No. 5-86-010 45
i 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.
RODRIGUEZ did not recall what action he took, if any, regarding the Livemore Lab's October 1985 findings on analysis of the downstream creek bed sediment.
However, RODRIGUEZ did recall that the issue was discussed and considered.
Interview with Ronald W. COLOMBO, RANCHO SECO Regulatory Compliance Superintendent On April 3, 1987, COLOMBO, RANCHO SECO Regulatory Cbmpliance Superintendent, was interviewed regarding his knowledge of SMUD's management and operation of the Liquid Effluents Release Program at RANCHO SECO (EXHIBIT 35). The infor-mation listed below is a summary of the interview transcript:
The design of the RANCHO SECO plant does not allow, under nomal 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. COLOMB0 stated that the modification was a change to the design of the plant,
~
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. ,
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.
It was COLOMB0's opinion that all modifications, whether temporary or permanent, should go through the PRC.tcLassure that the modification was within the -
bounds of RANCHO SECO's: license.
COLOMBO, who is chairman of the PRC since its inception in 1972, objected to the Temporary Modification at RANCHO SECO. COLOMB0 complained to OUBRE because the modification did not go through the PRC. OUBREtookthestange, that there was no need for the modification.to have a PRC reyies and; ,"
accompanying safety analysis because the change was. temporary.
Over a peried4fn, Approximately,10, years. COLQM603 g)Mydskyhgg,3pokgn, to a OUBREonapproximata17thheoccasiopEsbouLthe., peed.fortemporarymodi,,
cations 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 COLOMB0 with OUBRE. It was COLOMB0's opinion that a 50-59 Safety Review should have been conducted on the DRCST modification due to the fact that 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 from the DRCST to the RHUT. OUBRE also explained that the activity in the Case No. 5-86-010 46 h _ -__-_
1 4
? .
)
e I 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. COLOMBO stated that his first conversation with OUBRE on the DRCST modification was around December 1982 or January 1983.
COLOMB0 stated the pathway of the DRCST modification should have teen reported in Special Report 84-07 because the pathway added radioactivity to the system that releases liquid effluents to the environment.
COLOMB0 stated that a few months after the issuance of Special Report 84-07, OUBRE, in a staff meeting, stated if water was below RANCHO SECO's Technical Specification LLD, then it was non radioactive.
COLOM80 stated that OUBRE issued an assignment sheet _ for corrective action items responsibility on Special Report 84-07.
COLOMB0 was responsible for coordinating all input into Special Report 84-07.
OUBRE, the Plant Manager, was responsible for Report 84-07 and it was OUBRE who took the report to RODRIGUEZ, the Executive Director, Nuclear, for RODRIGUEZ's signature.
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, OUBRE assigned KEILMAN, POWERS, and ALVI certain responsibilities for the Near Term Corrective Actions. Also present at that meeting was KELLIE, MILLER, and Dean COMSTOCK. ,
4 If a temporary modification procedure was used for more than 30 days, then it' was a violation of the procedure governing temporary modifications and
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consequently, a violation of SMUD's license.
- COLOMB0 explained that the counting time on the sample analysis of the RHUT was lowered to a LLD within tile Technical Specification LLD thus allowing the lower counting time analysis to be within the definition of non-radioactive releases. COLOMBO, in retrospect, did not agree with lowering the sample analysis count time and could not defend the position of lowering the count time. COLOMBO stated that the connitment mad? in 84-07 not to release
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effluents containing radioac.tivity put RANCHQ $ECO and SMUD management in a bind, thus a redefinition of radioactivity had to be~ made.-
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 need for Special Report 84-07.
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. COLOMB0 explained that the RETS are Appendixes to NRC's license.
COLOMBO recalled that BRADLEY, between the time that BRADLEY discussed exceeding Appendix I Limits with him (COLOMBO), which was after July 1984, and the first meeting on Special Report 84-07 with OUBRE, comented to him (COLOMBO) that ,
l a
Case No. 5-86-010 47 -
b POWERS did not believe in his (BRADLEY's) figures. COLOMB0 sensed that the chain of command for resolving this matter was not functioning as it should.
The MSRC considered the Livermore Lab findings on radioactivity in downstream sediment beds, together with BRADLEY's LLD issue in 1985. COLOMB0 recalled ~-
being present at two of these MSRC meetings.
When BRADLEY issued his draft LLD study in October 1985, COLOMBO requested input from BRADLEY on what the Technical Specification LLD should be. COLOMB0 stated that question had not been answered to date. However, COLOMBO recalled that the MSRC did review the LLD issue at some point in 1985.
COLOMB0 stated he did not have the authority to cause action to be taken to enforce RANCHO SECO's Technical Specification. Such enforcement responsibility rested with the Operations Superintendent and his managers.
Review of RANCHO SECO Semi Annual Effluent Release Reports for 1985 On September 26, 1985, and March 3, 1985, RODRIGUEZ, SMUD Assistant General Manager, Nuclear, submitted to the NRC the RANCHO SECO Semi Annual Effluent
- Release Report for January 1, through June 30, 1985, and July 1 through December 31, 1985, respectively. The reports were required pursuant to
- Technical Specification 6.9.2.3 and 10 CFR 50.36a(a)(2). The transmittal
- letters and Executive Sumaries are attached (EXHIBITS 36 and 37). The transmittal letter for the September 1985 Report specifically states
- -
"During the operational phase of this report period a primary to secondary leak has continued at approximately 0.07 gpm, or less. The radioactivity entered the secondary system has resulted in an increase in gases ve.nted
^
> from the Auxiliary Building Exhaust. As a consequence of this leat, the District is continuinc to pursue an active program for reduction of
- licuid releases in orcer to reduce exposure to the public via this pathway ,(emphasis added).
... Aithough not part of this report, environmental samples of mud and silt, algae, and fish downstream all showed radioactivity of plant origin. A program of definition of the environmental pathways by sampling and analysis by the Lawrence Livermore Laboratories, Biomedical and Environmental Sciences Division is continuing. Results of the environmental monitoring program will be included in the annual report."
The Executive 3umary of the September 1985 Report states in part as follows:
"... In 1984, the dose calculations indicated that 10CFR50, Appendix I guidelines values for the liquid effluent pathways had been exceeded. In 1985, the District continued an extensive environmental monitoring program. In. order to further reduce offsite exposures, a liquid effluent reduction program has further reduced offsite exposures, a liquid effluent reduction program was implemented in October, 1984.- This reduction program has meant that o.ffsite liquid releases.in 1985 have brought RANCHO SECO liquid effluent '
releases within the 10CFR50 Appendix I design objectives.'
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Case No. 5-86-010 48
1 "First and Second Quarter effluent results indicate that all effluent pathways are less than the regulatory limits."
The Executive Summary for the March 1986 Report specifically states:
"The radiological liquid effluent control program that begab in October 1984 has continued during this report period. Normal liquid effluent releases of radionuclides other than tritium continue to be below the limits of detection required by Technical Specification 4.21."
The full Reports as submitted by SMUD are retained in the Office of Investigations' Region V Field Office.
The 1985 Annual Radiological Environmental Operations Report, dated May 27, 1986, did not address liquid effluent releases.
Willfulness / Intent Section Beginning about 1982, RANCHO SECO started experiencing a buildup of radioactive waste water. The waste was a result of many conditions principally associated with steam generator tube leaks. Previously, RANCHO SECO had disposed of excess radioactive waste water through shipping to off site locations.
However, this method of disposal was precluded by regulatory actions which resulted in the need to process radioactive waste water through disposal resins. This process was much more expensive but was not a major concern
,* because the closed loop design of RANCHO SECO technically did not generate -
radioactive waste water in such volumes that created a disposal problem.
However, problems of excess radioactive waste water associated with the steam generator tube leaks eventually exceeded the capability of RANCHO SECO to
-- process the water through resins. Also, the secondary system water which was designed not to be radioactive had become contaminated with radiation from the primary system. The requirement to reprocess the secondary water which was stored in two RHUTs having a combined volume of 300,000 gallons through the MWHUT, which had a volume of 30,000 gallons, was causing all the tanks to be filled to capacity.
Rather than incur the expense of properly disposing of the water, SMUD and RANCHO SECO managers changed the design of RANCHO SECO in such a way that allowed water to be moved directly from the primary system, DRCST, to the secondary system, RHUTs, and then released to the environment. This modification, although used regularly for over four years, was done as a so called temporary change and none of the required reviews were accomplished and the changes were never reported to the NRC as required. The releases of radioactive water to the environment resulted in radioactive contamination of the aquatic life, irrigated crops, pasture fed animals, and ultimately the ingestion of rr.dioactively contaminated food stuffs by humans in the downstream l vicinity of RANCHO SECO. .
SMUD and RANCHO SECO managers recognized that the releases of water to the environment were radioactive and,did not comply with Technical Specifications or the comitments of Special Report 84-07. Consequently, the testing process was changed, which consisted of testing for shortened periods when radiation ;
Case No. 5-86-010 49
o i
- l was detected, resulting in the creation of a false record that no identifiable '
radiation was present in the releases of water from RANCHO SECO. Also, water l was added to the RHUTs prior to testing to further dilute the mixture. These I practices of dilution and shortened counting times in effect disguised the fact that RANCHO SECO was releasing radioactive nuclides in liquid effluents.
The actions to modify the design of RANCHO SECO and to disguise the presence
, of radiation in liquid effluent releases were willful violations of NRC Licensing Conditior.s, and were intentionally deceptive in the failure to .
report the modification as a major pathway for radiation to be released from l the plant. The records that were created which were knowingly false, were .
then used to fonnulate required semiannual reports to NRC that no releases of L radioactive liquid effluents exceeded the regulatory limits.
The actions by SMUD we e willful and intentionally concealed radioactive releases to the envir .nent from the NRC and the public by false records and reports. While crea w n che false records and submitting the false reports to the NRC, SMUD was avoiding the operating costs that would have been experienced through proper radioactive waste disposal. SMUD officials were motivated to control or reduce operating costs in 1985 because of experiencing, in 1985, the first financial loss in SMUD's history. The entire loss, amounting to over $9 million, was attributable to problems with RANCHO SECO not operating and forcing SMUD to purchase electricity in order to meet customer demands.
Had the NRC known the true conditions and degree of releases of radioactive waste being released to the environment, the NRC may not have allowed the ,
restart of RANCHO SECO without the correction of the conditions contributing ,~
to releases of radioactive liquid effluents, or, at a minimum, increased surveillance to protect against releases in excess of regulatory limits. .
It is believed that the intent of SMUD management was to deceive the NRC anC'l public that RANCHO SECO was not experiencing design and operating problems
~
until such time that the plant had been allowed to restart and the necessary corrective actions could then have been undertaken while. PANCHO .S.EC0 was in,,
operation (sellin d.taking corrective. actions ',
while shut down (g electricity), ratherpurchasingelectricity)
Investigator's Conclusions Evidence and testimony collected during this investigation demonstrates that the entire chain of command from the SMUD Assistant General Manager, Nuclear, i through the RANCHO SECO Operations Manager, Nuclear Engineers, Plant Managers, and Radiation Protection Supervisors participated in or had knowledge of the repetitive creation of false records and made false reports to the NRC on recurring occasions. SMUD officials, through their actions, attempted to avoid certain costs of operations by improperly disposing of radioactive waste )
which caused releases of liquid effluents in excess of ALARA to the )
l environment.
l Status of Investigation
! This investigation is closed.
1 50 Case No. 5-86-010 _
d c
n, LIST OF EXHIBITS EXHIBIT NUMBER DESCRIPTION a
1 Request for Investigation RFI-RV-86-010 from J.B. MARTIN, I Regional Administrator, to R.G. Marsh, Director Office of Investigations Field Office Region V, dated June 13, 1986 2 Special Report 84-07 from Ronald J. RODRIGUE2, SMUD Executive Director, Nuclear, to J.B. MARTIN, NRC Regional Administrator, Region V, dated September 27, 1984 3 Letter from Gus C. LAINAS, NRC, to R.J. RODRIGUEZ, SMUD,
Subject:
RANCHO SECO NUCLEAR GENERATING STATION - CALCULATED DOSES IN EXCESS OF 10 CFR 20.406(c) and 40 CFR 190, dated November 15, 1984 4 Sworn Statement of Gus C. LAINAS, dated February 25, 1987 1 5 Investigative Interview of Edward M. BRADLEY, dated January 26, 1987
~
6 Memorandum from BRADLEY to POWERS,
Subject:
' APPENDIX I, - SOURCE TERM DEFINITION, dated December 16, 1985 r
- 7 Letter from POWERS through COWARD to KELLIE,
Subject:
CEP COUNTING OF COMPOSITE MONTHLY SAMPLES, dated December 31, 1985
~
8 Special Report 86-08, PRELIMINARY L,'fULATED DOSE TO THE PUBLIC EXCEEDING THE NUMERICAL DESIGN OBJECTIVES OF.10 CFR 50, APPENDIX I, from John E. WARD, SMUD Assistant General Manager, Nuclear, to J.B. MARTIN, NRC Regional Administrator, Region V, dated May 9, 1986 9 NRC Inspection Report 50-312/86-15, dated June 6, 1986 10 SMUD Internal Memorandum, telephone contact of KELLIE with YUHAS, dated June 6, 1986 l 11 Report of interview with Gregory P. YUHAS, dated January 9, 1987 12 Investigative Interview of Gregory P. YUHAS, dated l January 15, 1987 13 Investigative Interview of Gregory P. YUHAS, dated January 20, 1987 Case No. 5-86-010 51 _ !
o n
EXHIBIT j NUMBER DESCRIPTION 14 Letter from MARSH, Director, Office of Investigations Field Office, Region V, to WARD, SMUD Assistant General tianager, Nuclear, regarding Request for Information, dated.
> July 18, 1986 l 15 Letter from WARD, SMUD Deputy General Manager, Nuclear to MARSH, Director, Office of Investigations Field Office, Region V,
Subject:
OFFICE OF INVESTIGATIONS INQUIRY, dated 1 December 2, 1986 16 Investigative Interview of Michael CILLIS, dated December 9, 1986 17 Letter from MEEKS, Senior Investigator, Office of Investigations Field Office, Region V, to WARD, SMUD Deputy General Manager, Nuclear, Request for Additional Information, dated December 24, 1986 18 Letter from WARD to MARSH, Response to Request for Additional
- Information of December 24, 1986, dated February 19, 1987 ,
19 Memorandum for Marsh, Director, Office of Investigations Field c 13f# ice, Region V, from CILLIS, Senior Radiation Specialist, Paci11 ties Radiological Protection Section, Region V, -
Subject:
01 INQUIRY, ALLEGATION REQUEST NO. RFI-RV-86-010 -
dated July 15, 1987 20 Investigative Interview of Lee R. KEILMAN, dated March 25, 1987
~
21 Investigative Interview of Roger L. POWERS, dated March 25, 1987 22 Report of Interview with David R. MIXA, dated January 26, 1987 23 Chemical / Radiation Log dated March 20, 1985 24 Report of Interview with Wayne M HAMPTON, dated January 26, 1987 25 Report of Interview with Pamela R. HOWARD, dated January 26, 1987 26 Report of Interview with Mark P. LEINWANDER, dated January 26, 1987 27 Report of Interview with Walter F. PARTRIDGE, dated January 26, 1987 1 28 Investigative Interview of William A. WILSON, dated ,
March 24, 1987
~
Case No. 5-86-010 52
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- c. .
A EXHIBIT NUMBER DESCRIPTION i
Investigative Interview of Stephen C. MANOFSKY, dated j 29 March 24, 1987 {
30 Investigative Interview of Roger I. MILLER, dated i March 24, 1987 31 Investigative Interview of Fred W. KELLIE, dated March 24, 1987 l 32 Investigative Interview of George A. COWARD, dated March 24, 1987 33 Investigative Interview of Pierre OUBRE, dated March 24, 1987 34 Investigative Interview of Ronal.d J. RODRIGUEZ, dated April 7, 1987 .
35 Investigative Interview of Ronald Wayne COLOMBO, dated April 3, 1987 ;
36 Letter from R.J. RODRIGUEZ to J.B. MARTIN,
Subject:
SEMIANNUAL EFFLUENT RELEASE REPORT, dated September 26, 1985 37 Letter from R.J. RODRIGUEZ to J.B. MARTIN,
Subject:
RANCHO I
SECO SEMIANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT, dated .
c -
March 3, 1986 a
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Case No. 5-86-010 54 -
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'# LIST OF ACRONYMS q c s ACRONYM TITLE >
ALARA As Low As Reasonably Achievable ..
CEP Controls for Environmental Pollution -
DRCST Demineralized Reactor Coolant Storage Tank EPA Environmental Protection Agency FSAR Final Safety Analysis Report
!.ER Licensee Event Report LLD Lower Limit of Detection Millirem mrem MSRC Management Safety Review Committee MWHUT Miscellaneous Waste Holdup Tank NRR Nuclear Reactor Regulation PG&E Pacific Gas & Electric Company PRC Plant Review Comittee RANCHO SECO Rancho Seco Nuclear Generating Station RETS Radiological Environmental Technical Specification RHUTS Regenerant Holdup Tanks SMUD Sacramento Municipal Utility District SMUDGE 0 SMUD Geothermal Plant SMUDPV SMUD Polar Photovolatic Facility UARP Upper American River Project UFSAR Updated Final Safety Analysis Report
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'. Case No. 5-86-010 55
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