ML20247F338
| ML20247F338 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/15/1987 |
| From: | Cillis M NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | Marsh R NRC OFFICE OF INVESTIGATIONS (OI) |
| Shared Package | |
| ML20247F042 | List:
|
| References | |
| FOIA-89-2, FOIA-89-A-7 NUDOCS 8905300054 | |
| Download: ML20247F338 (11) | |
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MEMORANDUM FOR: Robert G. Marsh, Director Office of Investigations Field Office, Region V FROM: Mike Cillis, NRC Region V, Senior Radiation S'pecialist. .
, Facilities Radiological Protection Section p Civ: 7EM
SUBJECT:
OFFICE OF INVESTIGATIONS INQUIRY, ALLEGATION REQUEST NO. RFI-RV-86-010 The following documents / records were reviewed in conjunction with the Office of Investigations' inquiry related to the management of Rancho Seco's liquid effluent program. The review was conducted at Rancho Seco during the week of April 13-17, 1987, and in the Region V office on April 23-24, 1987.
References:
a) Management Safety Review Committee meeting and agenda minutes for the period of January 1983 through June 1986. M b) Chemical / Radiation Logs (Hot Lab) for the period of January 1984 through.
June 1986.
c) Selected Daily Lab Reports (i.e., Enclosure 4.1 of Procedure AP-306-VIII-13 " Lower Limit of Detection Count Time Determination") for the period of January 1984 through June 1986.
d) Rancho Seco Procedure AP-1, " Responsibilities and Authorities", Rev 15, dated 4/12/85.
e) Completed Liquid Effluent Release Permits for the period of January 1984 through June 1986. The permits are identified in Procedure AP-305-13,
" Environmental Releases of Liquid Radioactivity."
f) Region V Inspection Reports 50-312/86-15, dated June 6,1985 'and 50-312/87-05 of March 20, 1987.
g) IE Circular 80-18, "10 CFR 50.59 Safety ' Evaluations for Changes to Radioactive Waste Treatment Systems."
h) SMUD Memoranda:
- 1) P.JR 86-124, dated March 3'1, 1986 - This memo identified that SMUD decided not to pursue the construction of evaporation ponds.
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- 2) RJR '84-425 of September 27, 1984, identified as Special Report 84-07 This memo includes a licensee commitment for limiting liquid waste discharges so that 10 CFR Part 50, Appendix I limits will not be exceeded. An attachment to the memo includes SMUC's near term and long term corrective actions. .*
3)- RWC 87-200, dated March 20, 1987 This memo provides SMUD commitments to meet Appendix I guidelines. ,
- 4) RJR 84-176, dated May 14, 1984 This memo provides a discussion on the May 4, 1984 meeting between NRC and the NRC (I BELIEVE SMUD IS TO BE INSERTED IN LIEU OF THE SECOND NRC).
- 1) Region V Inspection Report 50-312/86-23, dated July 18, 1986. This document documents the NRC Enforcement Conference held with SMUD on June 20, 1986. The report includes SMUD's actions associated with the findings provided in Inspection Report 50-312/86-15.
j) SMUD Memorandum RJR 84-274, dated July 13, 1984. This memo identified several things; for example:
- SMUD's comitment to provide a proposed means to lower offsite releases anel a schedule for implementing that option.
- ' possible construction of evaporation ponds.
maintaining discharges consistent with the ALARA concept.
k) SMUD Memorandum JEW 86-087, dated June 5, 1987, Special Report 86-08.
- 1) Region V Special Inspection Report 50-312/84-06, dated May 31, 1984 m) SMUD Memorandum RJR 85-0, dated January 30, 1985. This memo was issued as a refinement to the District's transmittal letter dated May 14, 1984.
Attachment A, page A-1 identifies SMUD's plans for improving their environmental monitoring program and also states that changes were implemented to significantly reduce the radioactive liquid effluents.
n) Memorandum RJR 85-170, dated March 29, 1985. This is the 1984 Annual Radiological Report.
o) Miscellaneous NRC documents related to the subject matter, p) Review of correspondence files for Mr. R.J. Rodrigue7, P. Oubre, R. Colombo, R. Miller, R. Powers, L. Keilman, E. Bradley and F. Kellie.
In addition to the above, discussions were held with various members of the licensee's staff. The discussions were related to the subject matter identified herein.
Also reviewed was Region V allegation File RV-86-A-0048.
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EXH M- - 01 Ll Pages Page J
. . s Observations and/or comments resulting from the review conducted during the period of April 13-24,1987 are included as' Attachment A.
Observations / comments resulting from the review of material requested in the 01 request of December 24, 1986, are provided as Attachment B.
Enclosures:
Attachment A - Comments resulting from 4/13-17/87 visit.
Attachment B - Comments resulting from review of data provided to' 01 request of 12/24/86 cc: R. Meeks, 01:RV t
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ATTACHMENT A OBSERVATIONS / COMMENTS a) The information contained in Region Inspection Report 50-312/86-15 of June 6, 1986 (ref. (f)) above, was confirmed during the visit of 4/13-24/87. The information presents an accurate description of the licensee's management of the liquid effluent release program. The Inspection Report alone may suffice to substantiate the allegation identified in Region V Allegation file #RV-86-A-0048.
b) The followino comment can be made about the review of SMUD memorandum identified under references (h), (i), (j), (k), (m) and (n).
In simple terms, they appear to provide mainly just lip service by solely addressing the issues being pursued at the time they were prepared. For instance: several of the memoranda commits SMUD to maintaining releases consistent with the ALARA program. The question arises as to how would you expect this to be accomplished, by increasing the volumes, m3nipulating the LLD values or by adjusting the counting times. Perscnnel in key positions on the MSRC and PRC review and approve procedures before they are issued for implementation. One such procedure is the Offsite Dose Calculation Manual , AP-310. The methodology ( . . . the the ODCM7??) for calculating the dose is a function of the total volume and total radioactivity released. Personnel from the SMUD Chemistry and Radiation Protection staff and also plant management personnel approved the procedure and should have been aware.of what was occurring by adjusting the counting times and increasing the volume of liquids released from DRCST.
I could not find any evidence of correspondence assigning the SMUD staff responsibility for implementing the corrective actions identified in reference h(2).
Reference (k) states that immediate actions were taken to control l compliance with the numerical guides for design objectives of 10 CFR l Part 50, Appendix I. I question the term "immediate" considering the fact that Mr. Bradley officially notified his management of the LLD problem in October 1985 and the review of Liquid Waste Release Permits for the first 2-2i months of 1986 revealed samples were still counted for 1,000 seconds.
It is not clear what actions were taken by SMUD management to reduce the radioactive liquid effluents (see item (m)) and to maintain discharges consistent with the ALARA concept (see reference (j)).
Reduction is not achieved by increasing the volume of liquids (i.e.,
DRCST) and decreasing the LLD (i.e., by decreasing the sample counting time). The review did not indicate any evidence of changes to operational procedures to significantly reduce the radioactive liquid effluents as was committed in reference (m).
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e Most Rancho Seco staff members responsible for assuring releases were within T.S. 3.17.1 limits do not remember receiving the instructions concerning T.S. Section 3.17.2 limits objectives near term corrective action number VII of attachment to reference h(2) made a comitment to provide such instructions. Mr. Kellie stated on April 27, 1987 that he and most of his staff had not seen the letter until it was shown to him by Mr. Yuhas in 1986 and that. he and his staff had not received any instructions related to the actions described in the letter. Mr. Kellie could not ' state whether Mr. R. Miller had seen or received a copy of the letter.
Reference h(2) was included as an attachment to reference (m).
Reference '(n) was reviewed by SMUD management at both the site and corporate levels. Everyone should have been aware of SMUD's commitments in Special Report 87-04 (e.g., reference h(2)).
c) .See Attachment B, 0uestion 11. The same question arose during the reviews conducted during the period of April 13-24, 1987 I feel it is an important question. Based on the visit of 4/13-24/87. A review of reference (d) revealed that the Chemistry and Radiation Protection Superintendent has responsibility for the Environmental Monitoring
. Program. This means that Roger Miller had responsibility for the program through June 1985, at which time Mr. F. Kellie assumed control. With recent changes in SMUD's staffing of the Chemistry and Radiation Protection area, the question becomas more important. The absence of SMUD's technical support staffing at the corporate level and at the site has been identified as a constant problem since July 1984. Informa' tion related to weaknesses with the organization, ' staffing and corporate support of site activi;ies has been identified in several Region V Inspection Reports. The most recent report is 50-312/87-05.
Based on the current requirements in AP-1, it woulu appear that no one has been technically in charge of the Environmental Monitoring Program since the Chemistry Superintendent reported in September 1986. This is not consistent with SMUD's commitments made in reference (i) and (m).
Both documents provided SMUD's commitments for improving the Radiological Environmental Monitoring Program to assure future compliance with 10 CFR 50, Appendix 1.
AP-1 does not identify the responsibilities for Mr. Keilman's group which includes R. Powers and E. Bradley. Mr. Bradley informed me, although he had job related responsibilities, he did not have any direct authority that went along with his responsibilities.
In conclusion, one can state that SMUD management was aware of problems resu? ting from the steam generator tube leaks starting in 1980 through 1985 and yet they failed to assure that the liquid effluent release 4 program was properly managed and controlled in accordance with the license and their commitments to the NRC.
d) The review of reference (b) and (c) revealed the following trend related to the manipulation of counting times.
- 3000 second counting times were used for counting 1984 samples.
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j 1000 - 2000 second counting times were used for counting samples ;
between March 1985 through December 1985. For some reason, most of l the samples counted in October 1985 were 2000 second counts. '
i Several log entries were noted in the " hot lab" log notes df I transfers f rom DRCST to the RHUT's. An entry made on 8/17/84 )
indicates 30,000 gallons were transferred from the DRCST to the "B" i RHUT. The gama scan showed the following: . I go - 2.68E-7 5.97E-8 131 CS - 6.34E-7 7.4E-8 137 1 - 2.32E-7 6.23E-8 Cs - 1.23E-6 1.02E7 Most of the gama checks performed in 1984 showed positive gama peaks. The count times were generally 3000 seconds.
A Hot Lab report for 7/13/85 has the following notation:
"B RHUT 8-san No 8 peaks 1000-second et Met all LLD's per Bill Wilson per Tech Spec's Tritium (MC1/ml) 3.72E-6" Gamma scans of DRCST (Tank T-621) is not normally conducted'whenever the tank is sampled. Counting times of DRCST sampling also rahged between 1000-3000 seconds for the few times that gamma scans were performed.
937]26/gyg)gagey,g6EM4.bE GUT cTUhMu# A eYt2g sggggg ggggd scan showed no 8 peaks.
A 2000 second count of DRCST (Tenk T-621) on 2/4/86 at 1015 hours0.0117 days <br />0.282 hours <br />0.00168 weeks <br />3.862075e-4 months <br /> showed a gama peak of 9.63E-8 3.26E-8. A subsequent recount of the sample at 1450 hours0.0168 days <br />0.403 hours <br />0.0024 weeks <br />5.51725e-4 months <br /> for 1000 second showed no 8 peaks.
An entry made on the 6/22/85 hot lab originally indicated gamma peak in the "B" RHUT as follows:
134 2370 : f:kbE:$i8:$$$23 The above values were lined out and a 'new gamma scan was performed.
The new gamma scan report no 8 peaks were present. This same practice'was noted at'several other occasions between the period of 1985 - June 1986.
An entry on a Hot Lab report dated 11/14/84 disclosed that a 1000 second count time was used to assess the "B" RHUT contents.
The inspector verified the accuracy of the data discussed in Inspection Report 50-312/86-15 with re'pect s to manipulation of the LLD by adjusting the count times. It appears that the 1000 second count time was EXHIBIT e L m wa_curm
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indiscriminately used for the period commencing on March 20, 1985 end ending on or about March 1986, e) The review of reference (a) (e.g., MSRC meeting minutes) did not disclose any direct discussions in the reports that were related to changing of count time times, the LLD, changes made to DRCST, increased volumes of releases cade from the period of January 1984 through June 1986. The-review also disclosed the following: ,
The problem Mr. Bradley identified in October of 1985 with the LLD's.
and counting times were not discussed at the MSRC meetings even though Mr. Bradley, R. Powers or L. Keilman periodically attend the MSRC meetings. I feel the discovery was important enough to warrant
! an MSRC di.mcussion..
Mr. Kellie attended more MSRC meetings than did R. Miller. You can count on one hand the No. of times Mr. Miller attended between 1983 through June 1985.
No one from the Chemistry and Radiation Protection staff is a member of the MSRC.
In. conclusion, I find it strange that more information wasn't available
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in the MSRC meeting minutes on this subject, f) An attempt was made to determine whether the NRC staff was informed of the changes made to DRCST for transferring liquids from DRCST to the A or B RHUTs'. No records related to this matter could be found or produced by.
the licensee's staff.
g) A search of the correspondence files maintained at the Ranch 9 Seco Docteent Control Center was made for the following individuals listed in item (p) to determine what, if any, discussions related _to the control-and management of liquid effluent releases were documented.
T'e : correspondence files for Mr. E. Bradley, R. Miller, R. Powers
. Keilman were extremely small. Mr. Millei s files were ai.a smaller than would be expected when compared to Mr. Kellie. This is more surprising if you consider that Mr. Miller held the position that Mr. Kellie is currently holding at least ten times longer than Mr. Kellie.
- Mr. Miller's correspondence files revealed that he was involved with ;
the negotiations of the Radiological Environmental Technical Specifications (RETS) prior to their issue on July 20, 1984 Discussions with Mr. R. Columbo disclosed that Mr. Miller had to be present when the term "not" was discussed in Section 3.17.1 of the T.S. Mr. Columbo added that Mr. Miller should have been aware of the reason why the term was used.
The inspector concluded that the Rancho Seco Document Control Center (DCC) may not have all of the personal correspondence that has been written by the involved individuals. Discussions with Mr. R. Columbo on 4/24/87 disclosed a lot of his personal correspondence has not been FB" n am 7 A 1d Pam I
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t turned over to Rancho Seco's DCC. The inspector also concluded that the correspondence files for Messrs. Rodriguez, Bradley, Powers and Keilman may be located at SMUD's corporate office or have not been turned over to DCC by the involved individuals. ,
h) The 1984 annual radiological report issued as reference (n) on March 29, 1985 includes an attachment describing Rancho Seco's Radwaste Processing System. The system description provided indica,tes that liquids in the Miscellaneous Liquid Radwaste System are pumped to:
(1) DRCST as makeup, (2) are recycled to the Miscellaneous Waste Tank or (3) are pumped to the Miscellaneous water holdup tank for reuse in selected plant applications. I found this portion of the report deceiving since the DRCST had been modified as early as 1983 throughout early 1986 (see item (d) above) to transfer liquids over to the A&B RHUT for subsequent release to the environment. A question arises as to why the report didn't identify the change that was made to DRCST. This is not consistent with other licensee memoranda referenced herein which states programs consistent with the ALARA concept would be initiated to reduce radioactive liquid effluents and also that steps would be taken to make improvements to the District's radiological environmental monitoring program (see reference (m)).
- 1) Reference (e) requires a review of the data be made by the Chemistry and Radiation Protection Superintendent or by his Assistant Superintendent.
Of several hundred copies reviewed, I noted five percent had not received any review and the remaining had been reviewed by the Assistant Super-intendent (e.g. F. Kellie). None that I examined had been reviewed by the Superintendent (e.g., R. Miller). I found this interesting since Mr. Miller was technically responsible for the environmental monitoring program. One can only assume that Mr. Kellie informed Mr. Miller of any abnormal results and/or conditions?
Conclusion I do not believe the licensee's actions were commensurate with 10 CFR Part 50, Appendix I or with the previous commitments referenced herein. Let's suppose that the licensee's staff did not understand the LLD concept es indicated in Inspection Report 50-312/86-15. Then you have to ask yourself if the licensee's actions were timely and consistent with their previous commitments for maintaining releases and activity consistent with the ALARA concept.
First of all, Mr. Bradley suspected that there was a problem which he verbally discussed with his supervision early in 1985 and which he subsequently documented on October 29, 1985. What did the licensee do? Did they notify the NRC? Were any changes made in the way they managed their liquid effluent release program via DRCST7 The review conducted by Mr. Yuhas, Mr. Meeks and I indicate every~ thing continued on as usual until Mr. Yuhas' visit in 1986. The question is why?
Especially if you consider the licensee's comitme.nts to limit discharges within Appendix I limits and for improving the environmental monitoring program. Was the licensee more interested in reducing the volume of liquid offluent inventory? The bottom line is did they need Mr. Yuhas to identify their errors before they took any action. Why wasn't the action more timely?
As previously stated, even without understanding the LLD concept, it must be M
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pointed out that most of the individuals involved reviewed and approved the ODCM and certainly should have had an understanding of the dose model which is contingent on volume and total activity released. Masking out the positive gamma peaks did not eliminate the radioactivity. Even a Chem / Rad Technician is and was smart enough to recognize what was happening. -*
Additionally, it must be recognized that the changes made to DRCST was not consistently with what was being reported to the Region in SMUD correspondence dating back to July 1984. I found this to be very deceiving in that the correspondence provides an entirely different picture than what was identified in Inspection Report 50-312/86-15. I find it very difficult to believe that the only reason why a 10 CFR 50.59 safety evaluation was not performed was because it was considered to be a temporary change when you consider that they received IE Circular 80- reminding them to perform such evaluations. Also, needing to be consider is the licensee's organization responsible for the Environmental Monito .ig organization must be taken into account. You must ask who was responsible for assuming that a viable organization was in place to manage the program. Fir. ally, why weren't the MSRC Quality Assurance audits effective in identifying the problem? Especially when you consider the Technical Specifications, Section 6.5.2.8 requires annual audits to encompass the radiological environmental monitoring program.
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The bottom line with respect to this matter is summarized in Attachment B under Request #11 and I feel that Inspection Report 50-312/86-15 captures this rather well. 4 1
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ATTACHMENT B COMMENTS TO SMUD LETTER INVOLVING AN 01 INVESTIGATION l
Request #1 Reference (6) provides a discussion on SMUD's evaluation for assuring compliance l with 10 CFR 20 and 10 CFR 50, Appendix I. Reference (6), which is entitled as j
" Appendix I Evaluation Report," was signed by SMUD Management on j November 26, 1976. Mr. J.J. Mattimoe, " Assistant General Manager and Chief Engineer" signed the report, j
Section 2.0, " Design Description of Liquid and Gaseous Waste Handling System" provides a good description of the radwaste systems and of its performance objectives which states:
"2.1.1.1 Perfonnance Objectives The radioactive liquid waste handling systems provide controlled handling, processing and disposal of liquid wastes. The systems are designed to ensure that plant personnel and the general public are protected against excessive exposure to radiation from wastes, in accordance with limits defined in 10 CFR 20 and guidelines of 10 CFR 50, Appendix I.
The systems minimize or preclude discharge to the surrounding environment of radioactive liquids of station origin. Liquids containing radio-activity of plant origin are not discharged to the environment as a result of normal operation, but are processed and held for reuse or for shipment offsite by a licensed contractor. Under unusual onts or abnonnal
- operating conditions radioactive liquid releases n.ay occur consistent with the requirements of the technical specifications."
Paragraph 2.1.1.3 states that " Makeup to the primary system ir from the demineralized reactor coolant storage tank-(DRCST). Paragraph 2.1.2.1 ,
states: I
" Condensate from the evaporator is processed tnrough deborating ion exchangers, to remove traces of boric acid that may have been carried from the evaporator, and are pumped to DRCST." It should be noted that Figure 2.2-1 does not show a flow path going from DRCST to the Regenerant Holdup tanks.
It appears from the above that SMUD management was aware of radwaste handling system design for assuring compliance with both 10 CFR Part 20 and 20 CFR Part 50, Appendix 1. Any changes to the system would have required a 10 CFR, Part 50.59 safety evaluation. Item (g) was issued to all licensee's in 1980 as a reminder to perform 50.59 safety evaluations. SMUD management should have been aware that any deviations would have resulted in noncompliance with 10 CFR Part ., Appendix I,
, Request #2/ Request #4 SMUD management became aware of the modification made to DRCST and miscellaneous L4 < 1d Radwaste System with the issuance of a Temporary Change made to precedure
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- Demineralized Reactor Coolant Storage System." The changes were signed b2 tN plant review committee chairman and the plant superintendent.
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- f Request #8 Considering the volumes of liquid releases performed in 1980,-1981, 1982, 1983, 1984, 1985 and 1986, did anyone from SMUD attempt to perform a calculation to determine whether compliance with Appendix I, as committed to'in Reference 6,
.could be' achieved assuming all releases were performed at the prescribed LLD value of SE-7 u Ci/ml?
Request #9 -
Why was sampling of fish from Clay Creek delayed until 1984. Records showed detectable activity being released from the basin as early as 19807 What prompted the 1984 sampling?
Request #10 Although internal audits identified major deficiencies with the REMP - none were effective in. identifying the findings identified in Region V Inspection Report 50-312/86-15 'Why?
-Request #11(SeeItemC, Attachments)
' ' It' is. still not clear as' to who has responsibility for the REMP. AP.1 indicates it is under the cognizance of the Chemistry and Radiation Protection Super-intendent. However, Enclosure 3 shows a corporate HP Support and Environmental group. Based on. recent inspections, it is my understanding that the later group has responsibility for REMP.
General Observation Overall,. it appears that SMUD made certain that the management of radwaste -
liquid effluent releases were in compliance with 10 CFR Part 20; but failed to assure that they maintained compliance with 10 CFR Part 50, Appendix I and 40 CFR Part 190 as was previously' committed. It appears that no real effort was made by SMUD management to assure compliance with the later two regulations because based on the infonnation provided, the records show that SMUD management approved-the temporary changes to radwaste liquid processing system. It does not appear like there was any real attempt to mitigate the releases.
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