ML20247F302
| ML20247F302 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 12/09/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20247F042 | List:
|
| References | |
| FOIA-89-2, FOIA-89-A-7 NUDOCS 8905300045 | |
| Download: ML20247F302 (40) | |
Text
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BEFORE THE 2
NUCLEAR REGULATORY COMMISSION l
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.In the Matter of:-
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INVESTIGATIVE INTERVIEW
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7 Region V Field Office of Investigations g
Nuclear Regulatory Commission 1440 Maria Lane 9
Walnut Creek, California to 11 An investigative interview of MICHAEL CILLIS 12 was conducted this date, commencing at 10:00 a.m.
13 PRESENT; ROBERT MARSH, Director and, RONALD A MEEKS, Senior Investigator g
Field Office of Investigations 37 Nuclear Regulatory Commission, Region V 18 19 20 21 22 23
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CONTENTS WITNESS:
PAGE 2
MICHAEL CILLIS 3
Examination by Representatives of NRC 3
5 6
7 8
9 10 11 EXHIBITS j
12 (None) j3 14 i
15 16 17 18 19 1
20 21 22 23 24 1
25 O
e
1-i 13 1
P R.Q g E E_ p I N_ p_ E 2
10:00 a.m.
L, 3
MR. MEEKS:
This is an interview of Mike 4
Cillis;
- and, in that regard, Mr.
Cillis is a senior L
5 radiation specialist for the Nuclea r Regulatory Commission' l
6 in Region V.
It concerns Mr. Cillis's. review of a December 7
2, 1986 response to a July 18, 1986 request of SMUD for-
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information concerning their radiological effluents program.
g 9
Present at this interview are Mike Cillis; as well as myself, Ronald A Meeks, Senior Investigator, of the.
to it Regions V Field Office of investigations; Robert Marsh, the 12 Director of Region V Field Office of Investigations.
As agreed upon, this interview is b'ein g 13 reported by Jim Higgins.
i, Mike, if you win raise your righthand, I win 15 swear you in.
16 37 Whereupon, 18 MICHAEL CILLIS i,
was caned as a witness by and on behalf of the Commission po and was examined and testified as fonows:
21 EXAMINATION 22 BY REPRESENTATIVES OF NRC, OFFICE OF INVESTIGATION:
23 Q
What.I would like to do first, is just review the Office of Investigations, July 18,- 1986, request and get 24 from you your general impression on their response to each 25 t
1 l
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i k
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i of those questions that we asked of SMUD.
There are seven i
2 in number on that July 18, 1986 request.
As we have already 3
identified, their response was transmitted with a memorandum dated December 2,1986.
l The first question in our Office of 5
Investigation, July 18, request was:
)
6 "From the issuance of Rancho Seco's operating 7
license to present, identify the water sources from e
outsid e the sta tio n's boundary for all ' of Rancho Seco's water systems, including those systems utilized 10 si or necessary for the generation of power, as well as those systems utiliz ed or necessary for other plant 12 operations."
i3 Now, Mike, you reviewed their response, why don't you make some general observations about SMUD's 15 response to question number 1?
16 A
O v e r all,
'I thought that the response was i7 commensurate with the questions that were asked.
- However, 33 it was not as descriptive as the question implies.
They did 39 trace the water into the plant.
They concentrated on the 20 water for contamination control.
However, they did not make 21 a distinction on the utiliz ation of the systems that were 22 identified in their response to question 1.
However, I 23 would assume that the licensee was under the impression that 24 information was available to the NRC through other sources, 25 O
I
5 i
such as:
the upgraded safety analysis report which is 2
contained here in the Region.
3 So, ove rall, I thought the licensee responded 4
- to question 1, but you have to wade through it.
5 0
Questions No. 2 states:
6
" Identify what radioactive materials and other 7
contaminants are present in Rancho S e c o 's water-e system, including those systems utilized or necessary 9
for the generation of. power, as well as the systems 10 utilized or necessary for other plant operations."
ii A
The response for that, as to question number 12 2, by the licensee, I felt was adequate.
Q Number 3:
33 "From the issuances of Rancho Seco's operating-3, license to the present, describe the pathways of the 15 station's water systems at their points of origin 16 17 within the plant, to their point.s of release outside is the station's boundary?
Also, describe the release of e f flu e nts pathways from the station's boundary to 39 their ultimate destinations?"
20 21 A
I would say that the license e 's response do not provide the d e tail that I was e x p e c tin g.
I was 22 expecting more organization and clarity in their response to 23 the question itself.
It assumes that the reviewers are 24 knowledgeable of the systems.
And, in my viewpoint, I think 25 i
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6 i
they avoided the answering of the question in the degree 2
that we were expecting.
3 Q
Question No. 4 states:
"From the issuance of Rancho Seco's operating 5
license to present, provide a detailed Iccount of how, and at what inte rvals, r a dio a ctive ma te rials are 6
id e ntified and released from the sta tio n 's water 7
systems for each--
g THE WITNESS:
May we go off the record?
9 MR. MARSH:
Off the record.
10 ii (Discussion off the record.,)
MR. MARSH:
On the record.
12 i
BY MR. MEEKS:
13 i
Q Number 4 states:
i,
"...fr each testing processes, identify and 15 Provide the operational requirements for conducting 16 sue.h. tests."
l 37 I had id e n tifie d the first part of the i-ig questions already.
j, 4
4 A
Okay.
20 In reviewing the licensees response to number i
21 4, they referred to the references -- there is an abundance 22 f references that they provided us.
I did conduct a 23 j
cursory review of the references.
However, I do have some 2,
i additional information that I need before my review will be I
25 0
1 i
i
7 1
completed in that area, and we will' save those questions for 2
later.
3 Q
Okay.
4 Number 5 states:
~5 "From the issuance of Ranch Se o's operating 6
license. to present, provide a d etaile d account of all planned and unplanned modifications to the 7
e approved - final safety analysis report-in the program to identify released radioactive. materials from the 10 station's - systems.
Provide the reason why each ii modification occurred."
A
.In essence, I have the same responses I just 12 gave for number 4.
However, ir addition to that, I felt the-33 response lacked the detail as to when and how; and, "as' well, i,
it did not provide the supporting document for some of these 15 unplanned modifications that were made.
16 17
- And, there again, I have some additional is questions with respect to this item, and we will get to that.
later.
i, 20 Q
So you plan to expand on that, as we get into observations?
21 A
As we go.
.22 Q
Okay.
23 Questions 6 states:
24 "For those planned and unplanned releases made 25 I
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other than as described in the FSAR, from the issuance 2
of Rancho Seco's operating license to present, provide 3
a description of each release pathway; the volumes of liquid for each release, their radioactive source, and 4
5 method of determining the source for each release; the amount of radioactivity identified per release; and 6
if, and how the NRC was notified of each release."
7 A
Here again, I have a similar answer as I gave g
to question number 4 and 5.
I also want to add that I felt the response was incomplete, in that:
they did not trace a 10 ij source back to the origin of the releases as was expected by the. question that was asked.
However, I do have some 12 additional questions in this area that I will cover later, 33 too.
3, 0
okay.
15 And the last question, number 7, states:
16 "For those planned and unplanned releases made jy other than as described in the FSAR, from the issuance ig of Rancho Seco's operating license to present, provide i,
an analysis which shows all possible pathways to the 20 environment, and their radiological consequences, of 21 all possible failure modes."
22 A
I felt the licensee responded to that; but, 23 1
there again, there are an abundance of references that are 24 involved in the review.
And seven was one of the areas that 25 l
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I provided the least amount of resources to.
Because we, I 2
had prior knowledge in that area, and I felt the other areas 3
needed more concentration.
4 So, ove rall, I felt their response to seven 5
was adequate.
MR. MARSH:
We will go off the record for a 6
second.
7 (Discussion off the record.)
g 9
MR. MARSH:
On the record.
BY MR. MARSH:
10 ii O
- Mike, b a sic ally, are you tellin g us,
- now, 12 that, from your analysis of SMUD's response on December 2, clearly responses to the a
ey were, r were n 13 questions related to tracking the radioactive effluents from y
their Demineralized Reactor Coolant Storage Tank and their 15 Miscellaneous Waste Holdup Tank and their releases to the 16 environment?
37 A
I would say no.
They picked it up from their 18 releases made directly from the Regenerative Holdup Tank and ig the environment.
They did not provide us any details of the 20 21 spe cific releases that were made from the Demineralized Reactor Coola nt Storage Tank, or from the Miscellaneous 22 Waste Holdup Tank to the Regenerative Holdup Tank.
And that 23 i
is one of the questions that I have to go back and ask for 24 this additional information.
25 S
_-._____-_______--A
10 i
Q.
Were they responsive in identifying the actual 2
nature or. source of the contaminants that were contained in 3
these temporary tanks?
A Yes; but not to the actual concentrations.
4 3
And the reason for that is:
the question d'id not ask for that information.
6 MR. MARSH:
Okay.
7 8
M MR.,MEEKS :
O Why don't we, Mike, just go to your specific 9
obs e rva tions and material which you feel needs to be l
in 33 provided in order to complete your review of this matter?
A Okay.
12 Q
We can take them, the qu estions, we will go 33 j,
through our July 18, seven questions, or the seven questions c ntained in our July 18, memo.
We will go through them in 15 sequence and you can comment in depth on each one of those.
16 A
Why don't I take them one at a time, starting 17 is with questions number 1 and 27 I don't have any additional requests in that area.
3, However, with respect to question number 3,
20 the information that they provided us in reference 6--
21 L22 MR. MARSH:
Off the record.
(Discussion off the record.)
23 MR. MARSH:
On the record.
24 i____________.__.__
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1 THE WITNESS:
-- was-incomplete.
2 BY MR. MEEKS:
3 Q
Let me identify for the record, in reference 5 4
when we talked about -- in the discourse of this discussion 5
when we talk about the references, those are th references 6
that were included along with their response to our seven l
7 questions.
In reference 6 there happens to be Appendix I 8
evaluation report for the Rancho Seco Nuclear Generating 9
Station.and it is dated June 1, 1976.
10 A
I stated that reference 6 was incomplete.
Just l-2-6 through 2-9 and page 2-11 were missing.
I would suggest 11 12 that we obtain this material from the licensee.
13 C
Any other observations at this time on question 14 number three?
i 15 A
Mo other observations at this time on question 16 number three.
17 MR. MARSH:
Do we know what those are, what those 18 pertain to?
Are they relevant?
I 19 THE UITNESS:
Yes, they describe the systecs.
I 1
20.
MR. MARSH:
Let us get that on the record, that 21 you believe those are important because they describe,the 22 systems?
l 23 THE WITNESS:
The reason we feel that they are 24 important is we feel that they describe the systems that we 25 had., requested information on.
a 1
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BY MR. MEEKS:
2 Q-You mean Demineralized React'or Coolant Storage 3
Tank and Miscellaneous Waste Holdup Tank --
4 MR. MARSH:
Off the record.
5 (Discussion off the record.)
6 MR. MARSH:
On the record.
7 THE IIITNESS:
With respect to question number 8
four, there are some observations that were made in any 9
observations made under question number four that also apply 10 to question number six.
There is some additional information 11 that I..ould need to complete my review of the original request 12 that was made to the licensee.
And I will proceed and take 13 these one at a time, provide the sampling analysis results 14 obtained from the completion of procedure AP-306, entitled 15 Sampling Points Analysis Required, Frequency and Specification 16 Levels for the period January, 1980 to current date, and 17 restrict the data to the following:
18 I.
Derivative of 3-3, entitled Component Cooling 19 Uater; 3E9, entitled Demineralized Storage Tank Filter 20 Outlet, RC-13; 3-E-10, entitled Demineralized RC Storage 21 Tank; 3-F-6, entitled Miscellaneous Water Holdup Tank 22 (T-9 9 3) ; e.n'd 3-F-7, entitled Miscellaneous Waste Tank 23 (T-667).
24 BY MR. MEEKS:
25 Q
Kike, I didn't understand, what was the first i
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1 1
one again, could you read that first one again?
2 A
3-D-3.
3 Q
The Component Cooling Water?
4 A
The Component Cooling Water.
5 Q
Okay.
6 A
With respect to Item 4 above, provide detailed 7
information to indicate if all samples were obtained and a
reasons for any missed samples.
9 Q
Now, when you make reference to Item 4 above, to you are talking about your personal notes?
,11 A
My personal notes.
12 Q
Which happens to be item four of your personal 13 notes?
14 A
night.
15 Q
Can we get a copy of those afterwards, a copy 16 of your personal notes?
17 A
Yes.
18 Q
With respect to item three.above, provide the 19 sampling requirements and results of any sampling that was 20 conducted prior to, during and after drainage of the tanks, 21 that was prior to, during and after drainage of any of the tanks?
22 A
That is correct.
23 Q
Okay.
24 A
Reference 21, Data for the period of 5/26/77 to 25 5/21/81 was not included in Reference 21.
It is recuested that 3
L-14 1
the missing data be provided.
2 Q
Okay.
3 Now, let me refer to what Reference.21 has.
4 Reference 21 says, "The computer compilation of release permit 5
data, October 14, 1974 through October 28, 1986.'"
6 11R. MARSH :
Off the record.
7 (Discussion off the record.)
8 MR. MARSH:
On the record.
9 THE WITNESS:
With respect to Region V Inspection 10 Report 50-312/S615, it was included as part of the review.
11 There is some additional information that I would like to 12 receive from either the NRC, if it is available, or from the 13 licensee.
14 DY MR. MEEKS:
15 Q
Mike, could you just identify what that 16 Inspection Report that you have referred to related to?
17 A
This was an inspection report conducted by the 18 Chief of the Facilities Radiological Protection Section in 19 Region V, Mr. Greg Yuhas, whom I worked for.
And this report 20 provides a detailed assessment of the licensee's liquid waste 21 management program.
22 Q
Thank you.
23 A
To continue on, the additional information -- I 24 mm just going to refer to page number and line number.
So 25 star. ting on page six, fourth paragraph, starting with the
9 15 1
first'line --
2 Q
This is of the Inspection Report, now?
3 A
Of the Inspection Report.
4 Q
Okay.
5',
A Starting with the first line:
"For the 6
Regulatory Compliance Supervisor-the following information is 7
requested.. The licensee staff, having knowledge of the reason 8'
for the basis" - _you know what I am referring to there?
9 O
The basis of the technical specifications?
10 A
The technical specification.
11 Q
Understood.
12 A
I am referring to the -- not the ones included 13 prior to the issuance of the technical specifications.
14 Q
okay.
15 A
And any supporting documents associated with 16-who may have had knowledge in this area of the liceniee's 17 staff, who may have had knowledge in this area.
18 Q
of that particular compilation of that section 19 of the technical specification?
20 A
That's correct.
21 Q
Do you rccall, Mike, the exact reference of that 22 technical specification?
23 A
I don't have a copy of the technical specifica-24 tion around here.
If I am not mistaken, it is Section 317.2 25 of the technical specifications.
l-l*
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1 0
Section 317.2?
2 A
I do have a copy of the Inspection Report if you 3
want me to verify it.
4
'O That won't be necessary.
5 A
The second part of the request, still referring 6
to this Inspection Report, on page six, paragraph line number 7
one, providing a copy of the December 16, 1985 memorandum 8
referenced in that paragraph and also include the distribution 9
list that was associated with that memorandum.
10 0
Okay.
11 A
Also related to the Inspection Report on page 12 nine, third paragraph, last sentence, starting with the words, 13 "The Radiation, Protection Superintendent, SCRA," I wculd like 14 to obtain a copy of the draft cop'y of the LLD study reports 15 and the distribution that was made of the report.
16 With respect to the information asked for under question number nine, I want to clarify that. The distribution 17 18 list that I am looking for is all internal and external 19 distribution of the three reports that are requested.
20 0
Okay.
21 A
Additional information that is being requested 22 is a detailed explanation for the LLD, or Lower Limit of 23 Detection, values of liquid eff.'.uents given in the 1984, 24 1985 and 1936 semi-annual Effluent Release Report that I 25 referenced in the Region V Inspection Report 50-312/8615.
On
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page nine, middle of the page, starting with the sentence, E
2 The licensee's semi-annual Effluent where the LLD reference established what the purpose of ushering compliance with 3
4 10 CFR, Part 50, Appendix I.
5 0
Okay, I've got a' question for you'on that, Mike.
6 In other words, you are asking for more information than was 7
contained in the 84, 85 and 86 semi-annual Effluent Release a
Reports?
9 A
Yes.
10 Q
And it has to do with the LLD, LLD being an 11 acronym for Louer Limits of Trotection?
12 A
That is correct.
13 I'm interested.in finding out if those were 14 actual values established by the licensee for that period 15 of time and also if they controlled their releases to those-16 LLDs that vere established.
The second part of the request 17 that I would like to make is the LLD -- or another tern 18 referred to is MDA, or Minimum Detectable Activity -- values 19 that were used for the periods prior to the implementation of 20 the radiological environmental monitoring program technical 21 specifications.
22 And I am talking about the period of time prior 23 to July, 1984, and that is when the radiological environmental 24 monitoring program became effective.
25 Q
So you are interested in the LLDs, or as they
i 18
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1 were referred to before, the 1984 radiological environmental 2
monitoring program, MDAs, you want those values?
3 A'
That's right.
4 0
What is the specific time period?
5 A
That would be from the origin of the plant up 6
until the effective bnplementation of the radiological 7
environmental monitoring program, which went into effect on 8
July 20, 1984.
9 Q
Okay.
to I think you had one item, didn't you, Mike, that 11 referred solely to response number four?
12 A
That's correct.
13 0
Okay.
14 A
Procedure number MEG 303, entitled Site 15 Radioactive Water Inventory, was provided to us as one of the 16 references.In reviewing the procedure there is some useful 17 data that I.. feel would be necessary for us to obtain.
And I 18 would like to obtain the data that was collected for the period 19 of January of 1980 to the current date.
And the information 20 should also include an explanation for missed samples.
And 21 the information should also include the exact measurement as 22 to what the number represents in gallons.
l 23 Q
Do the se refer to the tanks that you have 24 previously mentio'ned before this?
25 A
Yes, these include the Demineralized Reactor I
19
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Coolant Storage Tank and the Miscellaneous-Waste Holdup Tank, 2
plus the Regenerative' Holdup Tanks and some other tanks. I 3
mean, what the procedure does is it keeps the water inventory of'what is in the tanks and by knowing what is in the tanks-4 5
and looking at the release permits it appears that we can use 6
that'information in our review.
7 Mith respect to question number five, there is.
8 some additional information that I need in the way of.
9 procedures that were referenced in the documents that were 10 provided to us in the July 18 request.
And I will read off the procedure number and"the title.
And I would also like the 11 12 information to provide us with any copies or revisions that 13 may have-been in existence between the period 1982 to the 14 current date.
16 The: procedures are as follows:
A-10, entitled 16 Demineralized Reactor Coolant Storage System.
17 MR. MARSH:
Off the record.
18 (Discussion off the record.)
19 MR. MARSH: On the record.
20 THE WITNZSS:
I have additional procedures.
1 21 A-17, entitled Miscellaneous Liquid Rad Waste System; A-28, 22 Miscellaneous Water Systems, Plant Operations Manual procedures l 23 that are related to A-10, A-17 and A-28; and also any temporary; proceduresastotransferringliquidinfluencedfromthe 24 25 Demineralized Reactor Coolant Storage Tank and the Miscellaneous
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1 Waste Holdup Tank to the Regenerative Holdup Tank.
2 Also related to question number five, here is 3
an additional request for more.information: Provide a detailed 4
account of the on-plant modifications for the partial' drainage 5
of the Demineralized Reactor Coolant Storage Tank and the 6
Miscellaneous Waste Holdup Tank to the Degenerative Holdup 7
Tank and include all supporting' documents and data, such as 8
engineering change notices, work requests, non-conformance 9
reports and procedures; provide the dates that the modifications to were in effect.
11 BY'MR. MEEKS:
12 O
Mike, I want to ask you a couple of questions 13 here.
You had asked for procedures concerning the Demineralized
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14 Reactor Coolant Storage Tank, the Miscellaneous Water Systems 15 and the Liquid Rad Waste System as well as the plant operation-l 16-manual for those procedures and any temporary procedures.
And 17 in the sense that in our question four we ask for them to 1
18 provide the operation requirements or the procedures for 19 conducting any plant or on-plant modifications we can also 20 state that these kind of dovetail together in that sense, in 21 responding to the questions fo6r.and five and their response 22 to questions four and five?
23 A
well; getting back to my initial observations, j
24 this is the kind of information that I felt was lacking in the.,. licensee's response to the questions.
I think I discussed 25
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I this earlier,'that I would refer to it later.
And I felt that
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2 this.information should have been provided as part of the 3
original package that was requested pursuant to the July 18 4
request that was made.
5 BY MR. MARSH:
6 Q
So you feel that the questions were clear'enough 7
to support them providing these type of proeddures and so forth 8
in their response?
9 A
Yes, I felt it was.
I understood it that way to myself.
11 MR. MARSH:
Thank you.
12 THE WITNESS:
With respect again to question 13 number five, I want to fill in the group with a little history 14 regarding any unplanned modifications that are made to systems.
15 A Region V inspection conducted in 1980 at Trojan indicated 16 that some modifications were made to Rad Maste systems without going through an appropriate 5059 safety evaluation review.
As 17 18 a result of that inspection an IE circular was issued to all 19 licensees and the circular number was 00-18.
The title of it 20 was "10 CFR Part 50, 59, Safety Evaluations for changes to 21 radioactive waste treatment systems."
L 22 I would like to get some information from the
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l 23 licensee as to when they -- wall, let me back track.
The 24 in5crmation I would like to get from the licensee is, if they 25 received it, when it was received and what actions resulted e
_A.
22 i
t' from their receipt of this document.
2 MR. MARSH:
What you are saying is that by 3
making these releases without a plan'they may be in violation
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4 of the NRC circular?
5 THE WITNESS:
What I am saying is'that by making
- 6 these modifications to the Demineralized Reactor Coolant 7
Storage Tank and to the Miscellaneous Waste Holdup Tank may a
have been.' contrary to the information provided in this IE 9
circular, and especially to 10 CFR 5059.
10 BY MR. MARSH:
11 Q.
Which requires that'all unreviewed safety 12 questions be assessed by the licensee?
13
'A Before any such changes are made.-
14 Q
Changes mean modifications?
15 A
Modifications, right.
16 Q
So what you are saying is that if they made 17' modifications to the Rad Waste Treatment System, which the 18 Demineralized Reactor Coolant Storage Tank is a part of, 19 without notification and analysis they would be in violation 20 of the 10 CFR 5151?
21 MR. !!EEKS :
5059.
22 THE WITNESS:
They don't have to make a notifica-23 tion.
All they have to do is make an assessment pursuant to 5059 and then they are allowed to make a modification provided 24 25 that no changes to the technical specifications are required.
l
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1 And this is written into the requirement itself.
It is the 2
purpose of making the review, is hat if they make a modifica-3 tio to the system then it requires a technical specification 4
change, but then they have to go through the appropriate 5
changes of the NRC to get those changes before -- and the 6
approvals -- before-the change can be made.
7 However, there are -- the regulation does allow a
the licensee to make these modifications -- and I don't want 9
to inake a distinction, because there is no distinction between 10 temporary -- any modification has to go through an appropriate If th'e licen'see decides to make these' changes 11 5059 review.
12 and they do -- I mean modifications -- and they do not involve 13 a need to modify the tech specs then they are authorized to 14 do it, provided it goes through an appropriate assessment to 15 identify any unanswered or unresolved safety questions.
16 BY MR. MARSH:
17 Q
Would it be your opinion that the Demineralized 18 Reactor Coolant Storage Tank in the release of effluents from 19 that to the environment would have required a technical 20 review or would have had a technical impact and required an 21 NRC review?
22 A
I personally am not in the position to make that 23 decision.
I don't think so, considering the volumes of liquid 24 involved.
The Demineralized Reactor Coolant Storage Holdup 25 Storage Tank contains about 450,000 gallons of effluents.
That e
24 l
1 is a lot more than effluents to be released and was considered 2
under the original design of that system.
As a matter of fact, 3
if you review the updated final safety evaluation report, and 4
even the reference six that I talked about earlier, and'even 5
some of the correspondence that the licensee pro ided to us 6
in response to this July 18 request, they identify that the 7
systems were not. designed to be released to the environment.
8 Q
So by the fact.that they had a system designed 9
not to release to the environment, yet they modified the 10 system and did have a release to the environment, would you 11 consider that being of the nature that should have been 12 notified and reviewed by the NRC, or possibly should?
13 A
Possibly.
At least they should have communicated 14 with the NRC of their intention to do so.
15 Q
Okay.
16 A
That's all I have with respect to question 17 number five.
18 With respect to question number six. I just 19 discussed under item four.
However, there is another item 20 I want to bring up with respect to this question.
Well, cancel 21 that last request.
I already covered that under the last 22 question.
23 BY MR. MEEKS:
24 Q
You mean question number,four?
25 A
I mean in response to question number four.
a 25 1
Q Okay.-
2 A
With respect to question number seven, there is 3
additional information that I would like to obtain.
But before 4
I get to the request I would like to fill you in on a'little 5
history.
6 The licensee's tech specs dated 3/84, and even 7
the subsequent tech specs that were modified in 1984, only,.
8 required fish samples to be obtained from the site reservoir 9
which is upstream from any releases that are made.
- However, 10 in 1980 when the licensee started to experience some primary to secondary leakage, and as a result of the primary to 11 12 secondary leakage releases were made to the environment via s
13 Clay Creek, which is 180 degrees opposite of the reservoir, 14 it is to the' west of the plant.
15 And from my own personal knowledge, where the 16 discharges are made to Clay Creek that is inhabited by fish, 17 and large quantities of fish.
You can see them from the-bank, 18 as a matter of fact.
lE BY MR. MARSH:
20 Q
Should I take my fly rod up there?
21 A
Yes, if you enjoy Black Bass.
22 Q
So these game fish would be included in that 23 waterway?
24 A
Right.
25 And to the best of my knowledge the licensee f
I
26 1-started to take some fish samples at Clay Creek in 1984.
2 However,'I.would like to verify this by asking for additional 3
information to find out whether or not any samples were taken 4
there, meaning Clay Creek, during the' periods pri,or to 1984.
5
.BY MR. MEEKS:
6 Q
That is tied in, Mike, to the primary to.
I 7
secondary steam tube' generator leaks'and the fact that they 8
had to make releases to'the environment.
Is that what I 9
understood from your explanation?
10 A
Well, what is tied in is that in reviewing the
.11 data, specifically reference 21, which provides all of the 12
-releases, there is an indication that some radioactivity, 13.
although it was below Part 20 release limits, the releases 14 did. occur anyway, indicating to me that any environmental 15 monitoring program that is properly managed would have picked 16 up.the need to start looking at all of the possible release 17 pathways besides just the water and the sediment.
And that 18
-would include any game, such as fish and any' fowl or anything i
19 of that nature.
20 It is my understanding that Lawrence Livermore, 21 who was contacted by the licensee to sample Clay Creek, 22 started their sampling program sometime in 1984.
But I would 23 like to verify that.
24 O
Do you know the fact that -- did you state the 25 fact that their steam generator leaks were first identified in
____.________m_.____
L 27 I
1980?!
j l
2-A In 1980.
3 Q
And because of those leaks then the excess water 4
had.to be released from the system, is that a true statement?
A That is correct.
S 6
Q Then your concern is from 1980 to 1984 -- the 7
latter date was when they first started sampling the fish --
a you wanted to know what their attitude posture was from 1980 g
to 1984?
10 A
And there was another reason for that request, it too.
If,you go back to'the reference s2.x, which is the Appendix I evaluation report dated 1976, it recognizes that 12 13 any releases from the plant are made via an unnamed creek, 14 which actually is Clay Creek.
And I feel the licensee should-have been aware of that.
And for that particular reason, you 15 16 know, it would make just good common sense to include an 17 adequate environmental monitoring program based on the l
l 18 problems that you experienced at the plant.
l-19 And one of the problems was the amount of radio-l 20 activity that had to be released because of the primary to 21 secondary leakage.
22 Q
Let me ask you another question along these lines.
You mentioned that there was a point in time when the Lawrence 73 24 Livermore Laboratory was contracted to sample for Ranch Seco?
25 A
That's correct.
f i
I
28 1
Q Which included fish sampling?
2 A
That's right.
3-Q And when was that?
4 A
In 1984.
i
~
5 Q
Were those -- was that data inclu ed in.their 6
responses?
7 A
Yes, that data has been included in their e
responses,'and I had reviewed that data before they supplied 'it 9
to us pursuant to your July 18 request.
to I would like to conclude with a couple of
. 11 general observations.
As you know, for any good program it 12 requires that you have an active quality assurance and audit
. 13 group.
And I would like to obtain any copies of licensee's
- 14' audits, either internal or frm external sources, that are 15 related to this topic.
16 I would like to'also have supporting documenta-tion along with that of any corrective actions that were taken 17-18 in response to any. identified deficiencies.
And in particular i
19 I am looking for any audits and surveillance that the licensee 20 conducted out of their radir' agical environinental monitoring program, especially as it relates to the release of any 21 22 liquids from their plant.
23 Q
What is the time period that you are interested 24 in for those?
25 A
The time period I am interested in is going back i
1 Mc 0
4 29
{
1 from 1980 to the current date.
2 BY MR. MARSH:
3 Q
Mike, you said that any good program would have 4
an internal audit and inspection program.
To yov knowledge 5
is there any requirement in a licensing document or an NRC 6
regulatory process that calls for the licensee to have an 7
internal control program, internal audit?
8 A
Yes, this is defined in the licensee's technical 9
specifications under administrative controls, Section 6.
10 0
So in fact they are required to have an internal 11 review program?
12 A
That's correct.,
13 Q
Do you know if that intern &l program is intended v
14 to review this particular topical. area?
15 A
I believe it is, but I am n>>t sure to what 16 depth such reviews are required to be performed.
17 Q
Okay.
18 A
This.last item is a request for some information.
O And the reason for it, I think, should be quite obvious after 20 I ask for it.
What I am looking for is from the plant origia 21 to the present for the licensee to provide a description of 22 their radiological environmental monitoring program organiza-23 tion, to include names of individuals and their responsibilities
(
24 And the reason for that request -- like I said, it should be j
25 obvious -- I would like to know of find out what the organizatic f
i I
f I
i 1
30 1
consisted of when the plan was first organized, compared to l
2 where they are at today; year by year would be preferable.
I 3
guess the reason for that request is to determine.did.they 4
have adequate staff to. implement the management controls over 5
the liquid s.*w n effluents.
6 O
Mike, are you concerned with the corporate as 7
well as the Rancho'Seco site effluent management program a
l
'8
' organization?
9 A
Yes, that's right.
10 MR. MARSH:.Off the record.
11 (Discussion off the record.)
12 MR. MARSH:
On the record.
13 BY MR. MARSH:
14 Q
Mike, in your explanation of your analysis you 15 have basically listed quite a shopping list of additional 16 information that you feel would be helpful and necessary to 17 make a more thorough analysis of their response.
Now, the 18 additional analysis that is necessary, is it accurate for me 18 to state that this information would be necessary for a more 20 complete and accurate assessment of the volume and nature of 21 the effluents that were actually released?
22 A
Not necessarily so.
I am trying to -- the reason 23 for the request is also to fill in the mitsing gaps that I 24 feel are necessary to make a thorough review and be fair to 25 both the NRC and the licensee as well.
I 1
l l
~
31 1
Q-Can you explain why there was a need to store 2
the radioactive effluents in the Demineralized Reactor Coolant 3
Storage Tank from your analysis or your knowledge of their 4
operation?
5 A
Well, that information is provided in the 6
updated safety and analysis report.
The systems description 7
and than its use is described in the updated safety analysis e
report. This is required for routine plant operations.
9 However, they extended that when they made the on-plant to modification to drain it down to the Regenerative Holdup Tank.
11 It is just an abundance of water that they got from the, 12 primary to secondary leakage and they did not have any place 13 to put..it.
14 Q
So the recent rule of the effluents,in the 15 Demineralized Tank was because of leaks in the primary and-16 secondary reactor loops?
ii A
That's correct.
18 0
okay.
19 A
And if I'm not mistaken, they even discuss that 20 in their response to it.
21 MR. MEEKS:
Just a little comment on this.
It is the degree of their response that Mike hasn't been satisfied 22 23 with.
MR. MARSH; I understand that.
24 2s f f f.,
t
+
'^~
e E.
32 1
BY MR.' MARSH:
2 Q
Did SMUD make any commitments to the NRC on how 3
the effluents creating the need.for the Demineralized Reactor 4
Coolant ~ Storage Tank were to be met?
5 A
Th'eir commitments, yes, are ma'de in the updated 6
safety analysis, report.
7 Q
And was that final, do you know?
8 A
I believe their updated report-is dated 1982.
I 9
might be' wrong.
And their commitments are also in the final to safety analysis report that was pre-1982.
11 Q
Do you know if they had any commitment or plan 12 to release or:not release radioactive effluents-into the 13 environment in that report?
14 A
No, it says'there that those aru'self-contained 15 systems,.not intended for release to the environment.
16 Q
And that is -- strike that.
r7 A-And that is also contained in the reference 6, 18 which is the Append (.x I evaluation report that was completed
- 19 in 1976.
20 Q
So in 1982 the SMUD organization committed to the 21 NRC that they were not going to release radioactive effluents 22 to the environment and in your analysis.of their submittal 23. and response to our questions they acknowledged that they 24 intended not to be releasing radioactive effluents?
25 A
That's correct.
And if I'am not mistaken, there l I
m '
l I
I
33-1-
is a special report that is referenced in Inspection Report 2
5312/8615.
I believe the licensee's special report number 3-8407, where they made an additional commitment.that they were 4
going to maintain their releases within Appendix,I guidelines.
5 But.you can easily review the inspection report and weed out 6
the material.
I seem to recall reading that.
7 Q
Mike, from your assessment of both the inspection 8
report performed by Greg Yuhas that you referred to and your 9
analysis of the submittal by SMUD to the questions posed to 10 them by the Office of Investigations is it your conclusion 11 that radioactive effluents were in fact released to the 12.
environment?
13 A
Yes.
The licensee admits that in their r'e' port made to 14 15'
-- in Greg Yuhas' inspection report plus in their semi-annual 16 effluent release reports that were made since 1984.
17 Q
Okay, so there were reports made to the NRC --
18 A
That's correct.
19 Q
-- from SMUD during the period in which radio-20 active effluents were released?
21 A
That's right.
l 22 But I want to clarify that.
All of those 23 releases were still below 10 CFR Part 20 limits.
24 Q
Were'they reported?
25 A
They were reported.
However, they were in some l
i
'34 1
instances considered to be above the guidelines of'10 CFR' 2
Part 50, Appendix I, and in one instance'there was some, concern 3
as'to whether they were consistent with the EPA guidelines.
4 I
4 Q
Was SMUD required to report the impact on the
.l 5
environment?
6 A
Yes, they were.
And they did in their reports 7
to the Region V office.
1 1
8 Q'
Were you able to determine from your analysis 9
on how many occasions there were releases made to the.
10 environment by draining the Demineralized Reactor Coolant
, 11 Storage Tank?
12' A
No, that information was not supplied to us.
And 13
.that.is one of the requests that were made as part of my 14 review, for that type of additional information.
And I might' 15 want to clarify that, too.
16 I am not sure that, based on our visit to the 17 licensee on December 2, as to whether they are going to be.
j 18 able to supply us with that information.
I thought'that they 19 indicated that they did not maintain records of the dates and 20 quantities of those releases that were made from the 21 Demineralized Reactor Coolant Storage Tank and the Miscellaneous 22 Waste Holdup Tank.
Q From your analysis were there any HRC regulations
]
23 24 or licensee conditions violated when the releases were made?
25 A
I believe that those are pretty well captured by i
-___-_-_-___________-____________.----__--_-_-__-_____A
35
.. ' ~
1 Mr. Yuhas' inspection report, 5312/8615.
2 O
So to your knowledge'itLis the position of'the 3
NRC through its previous inspection that there'were violations?
4 A
Yes.
5 And that is up for review within the NRC.
And 6
I.might add that the response to the.last question, the 7
licensee has responded in part to Mr. Yuhas' inspection 8
acknowledging those violations.
9 MR. MEEKS:
While we are on the same subject let to me ask a couple of other matters that I want to expand on.
, 11 EY MR. MEEKS:
12 Q-We have talked about the quantity of water and 13 the amount of radioactivity that could be contained in the 14 Demineralized Reactor Coolant Storage Tank as well as.the 15 Miscellaneous Waste Holdup Tank.- You just stated, Mike, that 16 the licensee has acknowledged that possibly they won't be able 17 to identify the origin of that, of the radioactivity in those 18 tanks.
19 However, if I understand from the information 20 that you have requested here that you would like to receive, 21 there are procedures that, one, document how much --
22 A
In the tanks.
23 0
-- how much is in the tanks and the sample of 24 the' radioactivity in those tanks.
And those are recorded at 25 periodic intervals?
l 36 1
A That is correct.
2 BY MR. MARSH:
3 Q
Are those requirements on them to those?
A Some are and some are not.
As a m,atter of fact, 5
they use some words in their procedures as desirably -- it's 6
one of the words that they use -- for taking some of those 7
samples.
8 Q
To your knowledge from your analysis are there 8
procedures that had to be implemented in order to release the 10 effluents from the Demineralized Reactor Coolant Storage Tank?
- 11 A
Yes.
12 0
or was it possibly an accident?
13 A
Well, --
l' Q
I'll repeat the questions.
15 Were there procedures that had to be implemented 16 in order to release the effluents from tihe Demineralized 17 I
Reactor Coolant Storage Tank, or was it possibly an accident?
18 A
Well, it certainly wasn't an accident.
The 18 licensee in their response to us said that ch-plant modifica-20 tions were made.
However, during the actual transfers they 21 man it with personnel who patrolled it at half-hour intervals.
22 So apparently, although they did not provide us with the 23 procedures that were used, apparently they must have had some 24 procedure in effect at the time the transfers were made.
25 O
So from your analysis it is clearly an orchestrated
_m___________._
k 37 t
' l planned operat/f.d. to drain these tanks?
2
-A That's correct.
3
.Q Can you tell me how it was discovered that-the 4
releases were in fact made, not necessarily from,your. analysis 5
of their input but from Yuhas' inspection report?
Did the 6
NRC discover that the conditions were a certain way. contrary 7
to the way it was led to believe in reports?
8.
A
,I don't feel I en in a position to answer that.
9 Probably Mr. Yuhas would be the appropriate person to ask.
10 Because I think there was n' combination of being informed by 11 the licensee and then our own inspection effort probably 12 identified it.
13 Q
To your knowledge was there any attempt to 14 conceal the amount of radioactivity or the volume of effluents 15 released?
16 A
Not to my k'nowledge.
It is just the way in 17 which the menace, the effluents that were released that I have 18 some questions about.
19 Q
Are you aware of any chemical tests that were 20 performed during the release of the effluents?
21 A
Not personally.
But in reviewing their procedurest i
22 they are required to conduct tests for chemicals and radio-23 activity.
However, that information was not supplied to us.
So 24 I am not aware of what those concentrations were or what they 25 nay h. ave been.
I i
I l
i
9 38 L
1
-Q To your knowledge was there any. negative impact 2'
on the environment by the release of radioactive effluents?-
3-A I don't think I am ina position to answer that.
4 Q
Whenever the Demineralized Reactor; Coolant 5
Storage Tanks were designated as the receptacle for the leakage 6
from the primary and. secondary systems do you know what the 7
licensee's plan was on handling those effluents, managing s
those effluents and disposal of those effluents?
9 A
No.
to Q
Can you tell us where it would be the most
. 11 effective place to look for that information?
12 A
It would picbably be best to go and ask for 13 that'as additional information.
14-0 By --
15 A
A part of which we are doing.
16 Q
A part of which you are requesting?
17 A
Yes.
18 MR. MARSH:
That's all the questions I have.
19 MR. MEEKS:
I don't have any further questions.
20 Mike, do you have any additional areas that you 21 wouldl.like to cover?
22 THE WITNESS:
No, not at this time.
I may have 23 some additional comments p~ending,the review of the additional 24 information that I requested.
25 MR. MEEKS:
Thank you very much.
This session
\\
t e
--_---____a__
--__._________.__-___a___
r.,.
39 1'
is concluded.
2 Hihereupon,.at 12:00 p.m.,.the interview was 3~
concluded.)
4-5 6
7 8
9 10 11 12 13 0
14 15 16 17 18 19 20
-21 22 23 24 25 h
~
{-
t3 cortify that-tha ottachcd procandinga baf 4--
c.
TES NUCLEAR REGO'LATORY COM!!ISSION in the matt et
' PROCEEDING:
INVESTIGATIVE INTERVIEW (CLOSEQ MEE1
!O.
~
NONE WALNUT CREEK, CALIFORNIA, DECEMBER 9,.'1986 s horein appears, and that this is the original L.k;fhhYhk f "if'-lN
.heEcof for the file of the United States Nuclear
~
- cmmiasion.
' ff; I
j, JSLqt
,Nl W$ W,*
(TYPfD) (JAPES W. HIGGINf Official 'eporter R
Reporter's Affiliation e
6 0
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