ML20247F341
| ML20247F341 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 03/25/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20247F042 | List:
|
| References | |
| FOIA-89-2, FOIA-89-A-7 NUDOCS 8905300056 | |
| Download: ML20247F341 (68) | |
Text
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y
-4 e
1 BEFORE THE 2
UNITED STATES S
NUCLEAR REGULATORY COM!ilSSION 4
PEGION V 5
6 In the !!atter of:
)
)
7 INVESTIGATIVE INTERVIEW
)
DOCKET NO:
NONE
)
3 (CLOSED MEETING)
)
9 Sunrise Sheraton Hotel 11211 Point East Drive Rancho Cordova, California to 13 Wednesday, March 25,.1987
~
12 13 An investigative interview was conducted with 14 LEE KEIL!!AN, commencing at 9:00 a.m.
15 PRESENT:
16 ROBERT MARSil Field Office Director 17 Office of Investigations, Region V Nuclear Regulatory Commission 18 19 20 21 u
28 24 25 N
y x
S x
x 5 010 EXHIBIT 2c) 8905300056 090516 FRIEDMA89-A-7 PDR Page g
of Q]
-Pages
2
'd 1
CONTENTS 2
WITNESS PAGE 3
Lee Keihnan 4
Examination by Mr. Marsh 3
5 6
7 8
9-10 11
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12 13 j
14 15 16 17 18 19 20 21 22 SS 24 25 l
1 I
c -
3
.s -
I EEEEEEE1EEE 9:00 a.m.
2 3
Whereupon, LEE R.
KEIL!iAN 4
was called as a witness herein, and, having first be' en duly 5
6 sworn, was examined and testified as follows:
7 MR. MARSH:
This is an interview of Lee R.
3 Keilman, an employee of the Sacramento Municipal Utility 9
District.
The time is approximately 9:00 a.m.
The nature of the investigation has been explained to Mr. Keilman.
10 Present during the interview is the court 11 12 stenographer, and the interview is being conducted by
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13 Robert G. fiarsh, Field Office Director, Office of Investigation, Nuclear Regulatory Commission, Region V.
14 EXAMINATION 15
'6 BY MR. MARSH:
Mr. Keilman, I'd like to ask you at this time, 17 O
has anyone offered you any reward, or coerced you in any 18 19 way to proceed in this interview?
20 A
No, sir.
21 Q
Are you here voluntarily?
22 A
Yes, sir.
I'd like to advise you that under a voluntary 23 0
submittal to this. interview, if you wish to stop the inter-24 view at any tine, it is your right, and I encourage you to 25 F
4 1
exercise it if you care not to answer any questions.
2 Mr. Keilman, can you explain to me, please, 3
what your current position is with the Sacramento Municipal 4
Utility District, and from this time forward,"We'll use the 5
S-y;-U-D acronym, called SMUD in place of Sacramento Municipa l 6
Utility District.
7 A
My current position with SMUD is that I'm 8
the Director of the Central California Power Agency No. 1, 9
which is made up of three utilities that being Modesto 10 Irrigation District, the City of Santa Clara, and SMUD, and 11 our business function is to develop electrical power
~
12 producing plants in the Geysers.
15 We are presently constructing two 65 megawatt i
{,
l 14 geothermal units.
The Geysers are located north and east 15 of Santa Rosa by about 40 miles.
My job is to do all the 16 administrative, design, construction, start-up of these 17 facilities.
18 O
Okay.
When did you assume your current 19 position?
20 A
In March 1,
'86.
21 0
Can you give us a background history on your 22 employment with SMUD, and the general dates as to when you 23 had those positions?
24 A
I first started to work for SMUD in 1968, 'and 25 I was a Supervising Mechanical Engineer, worked on the desig ra 8
a
S 1
of Rancho Seco, on all of the mechanical systems.
Later on 2
I became, 1974, the Resident Engineer in charge of construc-3 tion, completion of the plant, held that position til 1978, 4
at which time I moved from the Rancho Seco site location to 5
SMUD's headquarters and worked on alternative' generation 6
sources, as well as Rancho Seco until 1983 when I was 7
appointed the manager of nuclear engineering for Rancho Seco.
8 I left that position to take the position of Director of 9
CCPA in March of '86.
10 Q
So from -- do you have an approximate month 11 in '83 when you assumed the Manager of Nuclear Operations?
12 A
Huclear Engineering?
~
13 0
Nuclear Engineering.
r A-14 A
It's either April or May.
15 O
So from the time of April or May,1983, until 16 March of ' 86, you were generally responsible for the 17 nuclear engineering activities at Rancho Seco?
18 A
Yes, sir.
19 0
Who did you report to in that capacity?
20 A
I reported to Ron Rodriguez, the Assistant 21 General Manager of Nuclear.
22 0
can you explain to us the organization that 23 you had beneath you in the structure?
24 A
The table of organization was basically one 25 of a design team made up of the four disciplines with a I
6 1
principal project engineer in charge of the four disciplines 2
O Who was that?
3 A
That was John McCulligan.
Beneath that, 4
there were four supervising engineers, the civil engineer 5
was Val Louis; the instrument and control eng'ineer was 6
Jerry Willians; the electrical engineer was Bob Daniels; 7
and the mechanical engineer was Dave Abbott.
8 I was also responsible for the construction --
9 modification / construction work and Jim Jerkovich was the 10 resident engineer who worked for me.
Also, Roger Powers 11 in charge of the -- the Supervisor of Nuclear in charge of
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12 nuclear fuels worked for me at that time.
In addition to 13 him, Bob Dieterich sho was Supervising Nuclear Engineer who
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14 was in charge of licensing.
L 15 0
As I explained, the nature of this investiga-16 tion pertains to the release of radioactive effluence from 17 the Rancho Seco site.
Can you tell me which of the super-18 visors, engineers that you've just listed, had some 1
19 responsibility as far as monitoring the releases of 20 effluence, or examining or testing for radioa'ctive presence, 21 or constructing the modifications of moving the water about l
22 the plant?
23 A
I don't understand that question.
You need 24 to take that in pieces so I can get ahold of it, because 25 I've been --
i l
i 4
I l
b e
7
/
1 O
Okay.
Who would have been -- under that n
2 organization that you mentioned, who would have been res-A ponsible for the monitoring of any radioactive. releases?
4 A
No one in nuclear engineering was directly 5
responsible for s.he monitoring of liquid effluence from.the 6
plant.
In ' 83, Btb Dieterien cnd below him, Ed Bradley 7
were responsible for filing the required reports with 8
various agencies.
9 Q
Who would have been responsible for, in 10 the organization you've described, testing for any radio-t 11 active nuclides in the effluence?
~
12 A
None oi the people that worked for me were la hands-on testing people.
14 Q
That testing process was in another --
15 A
Done by Nuclear Operations.
16 Q
Okay.
So those folks would not have worked 17 for you?
18 A
They did not work for me,:.no.
19 Q
The modifications of the plant to move any*
20 effluence around from one tank to another, or from one 21 operation to another, who would have been responsible for-22 that?
23 A
If it was a permanent modification, permanent 24 piping, I would be responsible, as versus if it was merely 25 hoses, or plastic pipe, and some of the other temporary
'e
_.s l
8 1
l l
1 l
I connections, those would have been the responsibility of j
2 Nuclear Operations.
3 Q
Oka~y.
Can you describe to us, please, what 4
the difference between permanent would be versus temporary?
]
5 A
Permanent, any permanent piping would be --
6 go through the normal engineering process of detailed 7
design, review by second level engineer, and entered in the 4
8 configuration control system that's used on the plant.
9 O
And temporary would be?
10 A
Temporary piping, and hoses, and plastic pipe 11 are not shown on the configuration control at Rancho Seco.
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12 O
So if there were temporary pipes installed, 13 or a tenporary modification of some sort, your organization
{.'
14 would not be responsible for implementing it or constructing 15 it?
16 A
Yes, r.ir, that's right.
17 Q
Are you aware of a modification to, move water 18 from the demineralized reactor coolant storage tank to the.
19 regenerate holdup tanks?
20 A
I don't have that much detailed knowledge 21 about the plant.
22 O
If such a modification was created, and used 23 from the 1970's time frame until the 1986 time frame, would 24 that be considered a temporary modification, or a permanent 25 structure?
9-I A
- My guess would be, if it's shown<en the 2
drawings, we treated it as a permanent installation,'and 3
it should have gotten all of the review.
If not, it would 4
have had some kind of tagging system that would have told 5
- operators - that it was temporary.
6 O
Ok ay.
So if it's not permanent, well, then, 7
it should be tagged so that the operators would readily 3
identify it as temporary?
9 A
Yes, sir.
10 Q
can you describe dais tagging process?
. 11 A
No, sir, I don't have detailed knowledge of 12 that.
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13 0
You mentioned one of the people was a civil
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A' 14
' engineer that was responsible to you.
15 A
val Louis.
16 Q
Val Louis.
Can you describe to us what his 17 responsibilities would be in constructing or taking down.
18 of any structure, or modification of pipihg, if it fel1~
19 within your organization's responsibility?
20 A
The discipline split would be on piping 21 systems, all the piping and all the support for that is 22 done by the supervising mechanical engineer, and Dave 23 Abbott.would have had that responsibility.
24 O
Do you know if he had any activities regarding 25 the modification that I described?
s 4
F._._.__._____.__
_m.___
I 10 1
A No, sir, I have no_ knowledge of that.
2 Q
If he would have had responsibilities or 3
' activities in that, would you have expected to know of it?
4-A
.Yes, sir.
At one time, it would have had to 5
have been put in our to-do list of items and 't ere would
.6 have been a budget for it, and I would have somewhere -- if 7
it happened after '83, between '83 and '86, I-would have 8
signed something saying -- authorizing the work to be done.
9 But so much work was done, that I do not have detailed to knowledge of all the changes that was made at Rancho Seco.
11 Q.
Okay.
So it's possible that that would have 12 been a project, but you just can't remember?
IS A
Yes.
' {T.-
14 Q
But would you describe to us the type of 15 record that would exist if it was, in fact, a project?
16 A
There should be an engineer!.ng change notice 17 which gets various approvals.
It is judged to be a safety 18 related, or non-safety related change.
If it's safety 19 related, then it goes to;the Plant Review Committee to 20 assess the impact on the plant.
If not, it doesn't.
The 21 engineer then does whatever design details, and d6 sign 12 calculations are necessary, and he puts together an 23 engineering ' change notice package including all the drawing 24 change notices, and then that work would be either issued 15 to construction forces with a work request, or to the 1
i
________.______._____.________.m
11
\\
1 nuclear operations forces with the same type of work request
{
2 O
Are there conpany policies and procedures 3
that lay out that operation as you described it?
4 A
There are detailed configuration can change j
5 proce dure, it's called' Engineering Change Procedure #1, and 6
it has all the details of how any modification change is 7
made to the plant.
8 Q
Those are permanent modifications?
9 A
Yes, sir.
10 Q
Are you aware of any similar engineering 11 change procedure for temporary modifications?
~
12 A
I am not aware of any formalized procedures 13 to be used for temporary changes.
L#
14 0
It would seem to me that in an industrial 15 complex plant like a nuclear generating station, that it 16 would be important to coordinate any temporary modifications 17 with the engineering operation to ensure that th y were not 9
18 interfering with the proper function of the permanent 19 design operation of the plant.
20 Is there anything that you're aware of like 21 that at Rancho Seco?
22 A
I'm not aware of any review that's done for 23 temporary hookups of piping systems.
24 Q
So to the best of your knowledge, the opera-
)
15 tions branch, or activities could install any number of e
9
12 I
temporary modifications to the plant that would have no 2
knowledge of the engineering function?
1 A
They use a work request system which defines 4
the work that they are going to do.
Whether that gets an 5
engineering -- an operational engineer review or not, I'm 6
not sure.
But it doesn't get any design engineer review.
7 Q
From a professional engineering standpoint, 8
does this seem like a good practice to have temporary 9
modifications involving the piping and flow of offluence in 10 the plant without the coordination of the engineering staff?
11 A
I'm not sure how it's handled at other plants, 12 and I'm not sure how the nuclear operations folks handle
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18 temporary changes.
A lot of temporary changes are just to f, s b'
14 drain various systems for maintenance., and other short-term 15 temporary connections, which I feel would not need the 16 design engineer review, because they return the system to 17 the as-built conditions before startup.
18 Q
Okay.
You've cited some examples where you 19 can imagine that it didn't need coordination.
There must 20 be some more examples that you could cite that would be 21 imperative that there be coordination.
22 A
It's quite possible that there would have 25 been more professional to have a review of temporary 24 connections.
25 O
Because it is possible that they could have 4
13 I
nn impact on the as-built operational design of the plant.
2 A
Yes, sir.
3 O
Is it possible also that these temporary 4
modifications could, in f act, change a permanent desinn, 5
engineering design 6f the plant for a temporary period of 6
time?
7 A
In my view, that would depend on the operating 3
procedures, and whether operating procedures allowed the use 9
of the temporary facilities during the normal plant power 10 operations.
11 Q
So if the plant was in power operation, and 12 a temporary modification was installed, it is possible that 13 it could have an impact on the designed operation of the 14 plant?
15 A
Yes, sir.
16 Q
Who -- what organization within Rancho Seco 17 or SMUD would be responsible to make that determination?
IS A
The Nuclear Operations Department that it installed the temporary facilities.
20 Q
And who would they have to coordinate with 21 in order to make that determination?
Wouldn't it be with l
22 one of your engineering group?
23
.A No.
We would not -- the design engineers 24 would not necessarily get involved in temporary changes.
1 25 Q
Well, then, how would the operations Branch L_____
_ _ _.. _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _. _. _ _ _. _ _ _ _ _ _. _ _ _ _ _ _.. _. _ _ _ _ _ _. _ _ _ _ _. _ _ _ _ _. _ _ = _ _ _ _ _
l 14 j
1 know whether they had interfered with the proper design and 2
f unction of the plant if they didn't coordinate with the 3
design engineers?
4 A
Their engineers would have to make that 5
determination, and by their', I mein the Nuclear Operations 6
Department also had registered professional engineers-7 working for them.
8 O
Okay.
You mentioned that in 1974 to 1978 9
that you were the TSsident engineer at Rancho Seco.
Are 10 you f amiliar during that period of time of the modification 11 that I described earlier of moving effluents from the
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12 demineralized reactor coolant storage tank to the regenerate 13 holdup tanks?
C-14 A
No, sir, I don't know the systems well enough 15 to even remember what that move is, physically.
16 Q
If there was a transfer of effluence from 17 the primary system, or the contaminated system within the 18 plant of water to the secondary system, would that be a 19
-- considered a significant transfer of water from an 20 engineering standpoint?
Not concerning yourself with the 21 amounts or the volumes, but just the concept of creating a 12 pathway from the primary to the secondary system?
13
.A That would be contrary to the design criteria 24 of the plant to prevent that from happening.
15 Q
It would be the intent of the design of the E
h
15 I
plant to keep that from happening?
2 A
Yes, sir.
3 Q
So if the demineralized reactor coolant 4
storage tank is a storage facility for radioactive water 5
that is chemically clean, intending for it to'be reutilized 6
in the primary loop, the -- what you're saying then is the 7
design of the plant was intended to preclude that water 8
f rom being moved into the secondary system?
9 A
Yes, sir.
Secondary system water would be 10 made up from the condensate situation, I think.
I 11 O
okay.
Is there any -- to your knowledge, was 12 there any design of the plant to allow release of water la f rom the primary system into the environment?
14 A
of course, that happens when there's a tube 15 leak in the steam generator.
16 0
okay, but that would be an anomalous condition 17 I'm talking about if everything is working as designed.
18 A
Okay.
Is there any piping systems that take 19 water from primary coolant storage tanks and put it into.
20 any of the regen holdup tanks and I can't answer that, I 21 don't know whether there is or not.
22 Q
But you're not aware of any?
23
.A I'm now aware of any.
24 Q
Because of the design of the plant intending 25 to preclude that, would that seem like that would be t
a G
[
16 i
p 1
something that you would generally be aware of if that L
2 existed?
3 A
Yes, we should have processed that through 4
a normal drawing change design review, Plant Review 5
' Committee, maybe even to the Management Safet'y Review
)
1 6
Committee.
Il 7
O So during your tenure at Rancho Seco, you're a
not aware of any of that -- anything of that nature happening?
9 A
I don't remember.
10 Q
In September of 1984, there was a report 11 submitted to the NRC that essentially stated that the 12 Rancho Seco plant did not need a variance from their
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13 operating license to continue operating because of the 14 steam generation tube leaks, and essentially that memo, If or report stated many short and long-term corrective actions 16 that had been implemented, and were going to be implemented 17 to preclude the release of radioactive nuclides to the 18 environment.
19 Are you aware of that report?
It is entitled, 20
- Report No. 84-07" di ted September 27th,1984.
21 A
I'm sure I've read it.
I don't remember all 12 the details of it.
23
-Q And when did you first become aware of this 24 memo or report?
15 A
I can't answer that as far as date goes.
4
L 17 1
O Was it generally back prior to September '84 1
1 2
when it was being put together?
l l
3 A
Again, I didn't work on putting it together, 4
so I can' t answer that.
5 O
Okay.
Well, generally, when do you believe 6
you became. conscious of this report?
1 7
A All reports like that would have oeen routed a
for me to look at, or might have even been routed via my 9
signature.
10 Q
Okay.
So generally, if Rodriguez wur. signing 11 off on a report to the Nuclear Regulatory Commission 12 describing conditions that pertained to the steam generation
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13 tube leaks, and the controlling of those leaks and the
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14 corrective action associated with those, that would fall 15 under your area of cognizance?
16 A
The way our system worked, we would have 17 gotten a copy of it for information, if nothing else.
18 O
Okay.
What about if there had been commit-19 ments to the NRC that certain things were going to be 20 accomplished with -- av permanent changes.
Would that 21 have been sonething that you could have consulted on?
22 A
Somewhere in that time frane we did formalize 3
s i
13 1 a system to take commitments and put them on a comnitment 24 tracking system.
Prior to that, those kind of commitments 15 were done by the licensing engineer, Bob Dieterich.
I e
.m__
18 L
1 1
Q Can you describe this commitment tracking 2
system of how that would operate?.
3 A
It's a computer-based system, and where there' s 4
a commitment to the NRC that we'll put in a demineralized,-
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5 or we'll change some electrical circuitry, or add new 6
pumps, or et cetera, that's listed on the tracking system.
7 It tells a brief description of the work or task to be done, 8
gives a date of when it's to be done, and it.. lists the 9
responsible person to get it done.
10 Q
Okay.
So if something -- tell ne again when 11 this commitment ' tracking system was implemented?
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12 A
Sometime in '84.
13 Q
Okay.
So if something was on the commitment-14 tracking system, it had all of the necessary tools within 15 it to ensure that the project was accomplished, or at least 16 monitored on its progress?
17 A
Yes, sir.
18 O
If something was committed to, but did not 19 show up in the tracking system, how would the SMUD organiza-20 tion know that it needed to be accomplished?
21 A
It would just be by sheer luck that the 22 licensing engineer or someone had passed on to someone that 23 it was a job'to be done.
24 Q
So generally speaking, then, if they intended 25 to do the job, it should have gone in the commitment
(
^
19
+
I tracking system?
2
'A Yes, sir.
5 Q
And if they didn't show up in the commitment 4
tracking system, it's likely that it could have slipped 5
by and never been secomplished?
q 6
A That's right.
7 Q
Are you aware of any attempt to preclude 8
putting commitments into the commitment tracking system?
9 A
No, the -- any person within the nuclear 10 organization can add an item to that commitment tracking Il system.
12 Q
Who could take them out?'
18 A
The three designated persons in the tr.acking A
14 system. - There was a tracking system in 1984, and that's li been revised since then, so all of my previous statements 16 do not relate to the current usage of tracking systems 17 that they had.
-18 Q
Okay.
But in 1984, that was the system that 19 was in place to manage commitments?
20 A
That's right.
21 O
I would like to show you at this time the 22 Report 84-07 and have you examine it, and tell ne if you 18 are - -if yo6 can recall when you first became knowledgeable 24 of this report.
We can go off the tape.
15 (Off record to review document.)
________-m
l ilman.
20 L
1 1
Q Now that you've reviewed this Special Report 2
No. 84-07, Mr. Keilman can you recall any involvement that 3
you may have had in the development of that Report?
4 A
I certainly had an input in the evap pond, to 5
evap ponds to evaporate liquid ef fluence from holding ponds 6
on the site that was for sure one of the design engineering 7
construction assignments.
8 Q
So would that commitment have gone into the 9
commitment tracking system?
10 A
Yes, sir.
11 Q
Are you aware of whether that did in fact go 12 into the commitment tracking system?
13 A
Yes, it did.
- (
14 0
Do you know what the disposition was of that?
15 A
We did preliminary design of that and prepared 16 an environmental impact report for that.
We held hearings 17 on the installation of evap ponds in the -- around the local 18 area, both in Galt and in Harold, and we subsequently 19 abandoned the installation of the evap ponds.
20 Q
In that process, who did you interface with 21 in generating your input to that report?
12 A
The person that did the work on the evap ponds 23 was Val Louis.
24 0
Val Louis was the --
15 A
He's a supervising civil engineer.
l m______________m_.__.._
?.:
21 q
I Q
What.about as far as briefing Mr. Rodriguez?.
2 A
We in the nuclear organization'in ' B4, we had S
' meetings almost daily.
So as.far as me briefing him,'more 4-than' likely Val Louis briefed him in the meetings.
5 Q'
.okay.
So whenever the 'long-term corrective 6
actions were' stated to include the evaporative ponds, at 7
.that point in time SMUD did not know if it was even feasible 8
to do that?.
9 A
Yes sir, thats right.
10 Q
And when it says the district intends to design
'and construct two eight-acre evaporation ponds at Rancho 11
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12 seco, that you did not know in fact if you could 'do that?
15 Whenever it was stated that the district intends to, in fact 14
. you didn't know if it was even possible to do that?
15-A That's right.
We knew that 'we would have to 16 have an environmental impact statement approved before we 17 could start construction.
. 18 Q
And then whenever that the district will draw 19 upon the experience of other utilities who use. evaporative 20
. ponds, but that it wasn't that you had not fully developed 21 the scientific design criteria yet.
But in any case, the 22 evaporative ponds will contain the following design features.
25 This was certiainly a representation that you intended to do 24 this work.
25 A
Yes and we developed a lot of that design i
0 t
.e
22 l.
l I
criteria from the work done at the Palo Verde Nuclear Power 2
Station.
j g
So there was an example of where evaporative 4
Ponds had been constructed.
5 Q
Well was this somewhat misleading to say that 6
you intend to do something and be as specific as what this 7
represents whenever it is not yet known whether it's even g
possible to do it?
A The language and definition of intent we used 10 frequently and a lot of times we'd make design statements yy that we intend to design and construct something and we do 12 not include the proviso of assuming we can get approval gg from all of the governmental agencies, NRC included.
14 Q
But you state that you intend to accomplish 15 something, wouldn't that carry with it to the person acting 16 upon that representation, that all of those necessary tasks 17 would have been accomplished?
33 A
No, sir.
Because it takes months and sometimen 39 years to get approval of design modifications.
20 Q
How long in fact had the steam generation 21 tube leaks been, existing?
22 A
In fact -
23
.Q
. Since October '84?
24 A
MY. recollection was we first experienced tube 25 generator leaks in 1980 or thereabouts.
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m_._.__
_w
23 P-1 Q
So the problem that's being addressed in this 2
Special Report 84-07 had been a known issue for,at least 3
three or four years at the time that this corrective action 4
was represented?
l 5
A Yes, sir.
6 0
Would it be possible that the recipients of 7
this record, report, would have assumed that since the 3
problem,had been known for three or four years prior to dhis 9
proposed intended corrective action, that all of that hone-10 work would have been accomplished?.
11 A
You need to break that question down for me 12 in smaller pieces, if you would.
13 Q
If the SMUD organization represents that they
(
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14 intend to take corrective action on a problem that's been 15 known for three or four years, wouldn't it be logical to 16 assume that the recipients of that report of intent would 17 believe that the necessary background work and homework and 18 preliminary or prerequisite tasks would have been accomplish-19 ed already?
20 A
I can't speak for what the understanding of 21 the recipient would be.
We did do preliminary work on the 22 use of evap ponds.
We had no way of knowing whether or not 23 it woul.d be approved.
24 Q
So if you had no way of knowing whe'ther it'd 25 be approved or not, isn't it in fact somewhat misleading to e
i '5.
24 I
state that you intend to design and construct two specifical ly 2.
mentioned eight-acre evaporation ponds and that, in any case 3
those evaporation ponds will contain specific design 4
features that are listed, there's approximately eight 5
specific design features that they would contain?
6 A
It's somewhat misleading in that we should 7
have said, providing we could get NRC approval and all other 3
necessary construction permit approvals.
9 Q
Did anyone at any time explain before this 10 memo went out that it was possible that you couldn' t do --
11 that SMUD cou3 8 not accomplish that?
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12 A
No one said that we couldn't accomplish it.
13 It was a matter of how long would it take to do it.
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14 O
Do you know approximately when that commitment
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15 went into the commitment tracking system?
16 A
It would have went in at the same time that 17 that letter went out.
Because an engineer named, Rob 15 Roehler in the licensing department took allit6e NRC 19 correspondence and put them in the commitment tracking 20 system.
Robert Roehler is the engineer's name.
21 REPORTER:
How do you spell the last name?
j 12 THE WITNESS:
R-o-e-h-1-e-r.
13
' REPORTER:
Thank you.
l 24 BY MR. MARSH:
25 Q
Do you know that it was determined that that l
l l
t l
l
._____________-_____-a
IL6 25
+
3 commitment could not be accomplished?
2 A
The district's decision to not go forward on 3
the evap ponds was made af ter I was out of the nuclear 4
organization.
5 Q
So you're saying that commitmen$ was not 6
decided upon, that it would not done until after March of 7
'867 g
A Yes sir, that's my recollection.
p Q
Well that would be 19 months af ter the commit-10 ment had been communicated.
Would there be any annotations 33 or documentation in the commitment tracking system to show 12 ' progress on that commitment?
13 A
Yes.
They would show the -- how late it was
(*f
(
14 and, in fact, I don't have knowledge that it's not still on 15 there.
16 Q
So although you can' t remember the specific 17 dates of your involvement, youaresurebhsedon,thecentent 13 of this Special Report 84-07 that you -- your organization 19 was involved prior to its submittal?
20 A
Yes sir.
We put together the information 21 on the evap ponds.
22 0
Is there any other information contained in 25 this report that you would have submitted from your 24 organization?
15 A
None of the to do items looked like they were 4
7 26 I
nuclear engineering tasks.
3 2
O What other officials were responsible for 3
input to that ort that you have knowledge of?
4 A
By our procedure, Ron Columbo, the compliance 5
engineer would for sure have input or would h' ave written 6
the letter.
7 0
What about the Plant Manager or the Nuclear 3
Operations Department?
9 A
Pierre Oubre would have seen the letter 10 before it went to Rodriguez would be the typical operating 11 procedure, whether Pierre has seen it or not, I couldn't 12 say.
13 O
All right.
Now, in that report, as you
(
14 reviewed it, do you notice that the principal pathway that 15 is described for radioactive nuclides to get into the 16 secondary system, and were being raleased, had been 17 released from the envirotutent, wsa fraie LI.e uteluit ganara-18 tion tube leaks, and in that regard, that fell under your 19 organizational responsibility to be aware of that design.
20 imperfection, or operating imperfection.
21 A
No, sir, not directly.
We would not have an 12 input on the water chemistry in the plant, and tube leakage 23 from the steam generators, that's a Nuclear Operations 24 responsibility.
25 O
So the pathway of radioactive nuclides going l'
27 1
- from the primary system into the regenerate holdup tanks 2
would not be within your area of responsibility?
8 A
We would only knot about it by -- would have 4
only known about it in that ti-s frame we're t,alking about, 5.
by reading some report.
6 Q
Okay.
But you were aware of those leahs?
7 A
Yes, sir,-I was aware that we had steam l
8-generator tubu leaks,.
9 0
Can you describe the nature of those leaks, 10 how much leakage there was, and generally in layman's terms, 11 what was happening?
la A
My knowledge of the tube. leakage is that the 18 tubes were experiencing pinhole cracks of some hind that
,f A
14 fit the tube support plate in the steam generators..
15 Q
And what was the result of those cracks and 16 pinholes and leaks?
17 A
Whenever the leak got to the limit,, tech spec 18 limit, or before, I'm not sure what the limit was set at, 19 some tenth of a gallon per minute, or some such leak, we I
10 would shut down and fix steam generator tubes, tube leaks.
21 Q
All right.
But as far as the leak itself, 22 were was that leak going to, what was tVa result of the' leak 18 itself?
Steam generator tube leaks, provided'the 24 A
1 25 primary system is at its operating pressure, would cause l
i
- J.A
-28 I
primary. fluid to -leak into the. steam system, then the stean 2
- sys tem' would ' carry - to the -- through the turbine, to the
-3 condenser, and the radioactive isotopes would be picked up 4
by the polishing demineralizers.
3 Q
So, in effect, what you're saying is - that
'6 the radioactive water of the reactor coolant loop was 7
interf acing directly with the steam loop because of the-3 leaks?
p' A
Yes, sir.
3 10 0
And it was -- the steam generation loop, or 33; the steam loop was then contaminated.
Was there -- was 12' this an anomalous condition to the design of the plant?
~
1 33 A
We had always. known there would be-tube.
I leaks,.all shell and tube type heat exchangers experienced 34 15' tube leaks.
i gg Q
okay.
So although the plant wasn't designed-17' this way, you anticipated this pioblem.
Dc you know w11at is the anticipated corrective action to this problem was?
Was 19-there a contingency plan?
20 A
I can't remember what the design criteria 21-called for in the event of excessive steam generator' tube 22 3eaks.
23
.O can you recall approximately what the volume 24 of leakage was?
15 A
It's in the tenths of gallons per minute.
l 1
9
29 j
1 Q
Did it ever get more severe than that?
2 A
Not to my knowledge.
3 O
Was it ever necessary to shut the plant down 4
because of the leakage?
5 A
From hearsay, I have heard that we shut the 6
plant down because of tube leaks.
7 O
But during your tenure, that was not the case?
8
,A I don't remcmber whether it happened during 9
the '83 '86 time frame or not.
10 0
Mell, it seens like as the Manager of Nuclear 11 Engineering at the nuclear plant, if you had to shut down 12 for an anomalous condition to the designed operating function
~
13 of the plant, you would know directly rather than by 14 hearsay.
15 A
Not so, not the way we operated when I uns 16 the manager of Nuclear Engineering.
i7 0
Who would --
18 A
I got no calls at home in the middle of the 19 night telling me that they were shutting the plant down..
20 I had no responsibilities for the operation o'f the plant.
21 O
Who was responsible for that?
12 A
Pierre Oubre.
23
.O In the Special Report 84-07, there is no 24 mention of another major pathway of effluence to bc 15 released from the plant, other than the steam generator
30 I
tube leaks.
The-modificatici. that I described of moving-I..
2 water from the demineralized reactor coolant storage tank 3
to the regenerate holdup tanks was a major pathway of flow 4
of effluence.
5 Do you feel that from an engine'ering standpoin t:
6 that that was a pathway that should have been reported?
7 A
It would depend on the quality of the water 3
in that demineralized holdup tank, because the plant is e
equipped with evaporators and demineralizers to process 10
, water and it's my understanding that most of the isotopes-11 would be removed before they would be put into the.
'12 demineralized tank.
13 Q
But in a circumstance where you are saying
(
14
- that you will not have any radioactive releases to not 15 mention a pathway directly from a -- the primary loop to
- 16 the release point, would be a significant omission from an 17 engineering standpoint.
'Is A
From the start of -design of the plant, we 7
19 have acknowledged that tritium would be released from the 20 plant via liquid effluence.
21 Q
And how was that going to be accomplished?
12 A
When we got steam generator tube leaks, there 23 would be --
24 Q
Now, we're talking about releasing the tritius 25 How -- if you designed the plant knowing that you were t
i e
L 31 4
1 going to release tritium, well, then, you knew you were 2
going to have sone point of collection of that triatiated 8
water, but you didn' t design the plant to have tube leaks, 4
so we're talking about 6.wo different things here.
5 How were you going to release tritium to the 6
environment?
7 A
In answer to that, I can only tell you that 8
in the plant design stages a' study for tritium' release was 9
made.
10 Q
Do you recall the pathway that that was to 11 take?
12 A'
No, sir.
~
13 Q
If it was part of the intended design of the
(
14 plant to releast tritium, then it would have been 15 appropriately a permanent pathway in the design.
16 A
I don't have any comment on that.
17 Q
Well, wouldn't that be appropriate?
From the 18 way you described the intent of the program before., it 19 would seem like if your intent was to have a pathway of 20 releasing tritiated water to the environment, it must have 21 been part of your design.
12 A
That's possible.
I do not remember how the la pathway was engineered into the plant.
I'm only making the 1
24 statement that in the early 1970's, a' tritium study was 1
'5 made for Rancho Seco.
2
_______________._________.______m__________
32 4-a' 1
O And you don't know what the conclusions or.
2.
results of that study were?
j 8
A I don' t remember what they were.
4 O
Can you identify that study-for.the.racord?
5 A
The study was done by -- through the nuclear--
6 Supervising Nuclear Engineer, ' his name is Robert Wilson.
7 O
Can you pinpoint a specific name or date that.
8 we should look for that: report under?
9 A'
The title I do not recall exactly.- It would to have in it, I believe a study on tritium release, and the 11 tine frane would' be guessing, 70 to 72 type time frame.
12 O
In Paragraph 3 on Page 2 of the Special Report
~
13 84-07, the last sentence generally states that the~ steam C
generator tube leaks were considered the major source of 14 15 contamination for the secondary system..What were the
- 16 other sources of contamination to the secondary system?-
17 A-I don't have any knowledge of that.
18 0
If there was an alternate pathway, as I've 19 described to you, would that be a source?
p 10 A
Right, that would potentially place primary 21 system fluids in the regen holdup tank.
22 O
The evaporative ponds that you described, 28 what system, the primary or secondary, would those ponds
' 24 have assisted in removing the radioactive nuclide?-
25 A
They were be'ing designed only to process water 1
,5+
!.1^
33 4
1 out of 'che regen holdup tanks which the ef fluent that goes 2
in the regen holdup tank is a result of regenerating the 3
polishing denineralizers, and we could also take liquid 4
from the retention basins which are on the out, fall of the 5
plant.
6 O
So basically, the regenerate holdup tanks, 7
and then down to the retention ponds could have been 8
reprocessed back up through the evaporative ponds was the 9
plan?
10
.A Yes, sir, and that would be implemented if Il there was contamination found in those ponds.
~
12 O
Or points of measurement.
13 A
Yes.
F 1
L 14 O
So clearly, the intent was not to release 15 radioactive nuclides to the environment, based on what was 16 represented as corrective actions?
17 A
The intent was to use the evap pon$s for 18 release of isotopes that we could measure in the regen 19 holdup tanks.
20 0
So it would be reprocessed up through the 21 evaporative ponds so that those isotopes would not be 22 released to the environment?
23 JL Yes, sir.
24 O
Since the evaporative ponds were not 25 constructed from September '84 to spring of '06 time frame, l
I 6
i 34-I what would have been the meth J aology of removing those 2
nuclides that would have been found during that period of 3
time?.
4 A
The only removal cycle I know about is that 5
they put in temporary facilities for using throw-away resins 6
that -- out of the polishing demineralizers.
7 O
So that would mean that water would have to 8
be taken from the regenerate holdup tanks and moved back 9
into the demineralizing process?
10 A
Well, that's not the way I understand it.
Whatever isotopes were collected on the resins in the 11
~
12 condensate polishing demineralizers, rather than regenerate 13 the resins and develop isotopes in the regen holdup tank, 14 we would simply take the resins out and not regenerate them 15 and throw them away, and put in new resin.
16 O
Those resins are located in the regenerate 17 holdup tanks?
la A
No, they're in the condensate polishing 19 demineralizers.
20 0
So if you detected nuclides at the regenerate 21 holdup tanks during a chemistry test, what would you have to 22 do with that water to remove those nuclides?
23 A
You would have -- the water would have to be 24 put back into the radioactive storage tanks, would be one 25 way of doing it, or I believe they installed a small side I
1
35 I
stream-demineralized, again, using throw-away resins for 2.
cleaning up a regen holGap tank prior to releasing it.
3 Q
okay.
So these were the alternate methods 4
of cleanin y up the nuclides until the evaporative ponds 5
could be instelled, or constructed?
6 A
Yes, sir.
7 Q
I'd like for you to read the last paragraph 3
on page,'2 of Special Report 84-07 and tell me if you were 9
responsible, or your organization was responsible in any to way for the information contained in that paragraph?
11 A
This paragraph tight here?
~
12 O
Yes.
13 A
Page 2.
s' 14 (Pause while reading. )
15 A
f(y answer is that paragraph could have been 16 written by any member of the engineers that work in the 11 nuclear organization.
I did not write it.
18 O
So you don't know who did?
1 19 A
That's right, I don!t remember who wrote it.
(
20 0
You know what the reason was for not 21 reporting the modification that I described to you in this 22 special report where they were moving water from the 23 demineralized reactor coolant storage tanks to the regenerate 1
24 holdup tanks?
j 25 A
I have no knowledge of whether they reported l
0 e
..__________..__.__.._________.___m_.___
L 36 l
1 it or not.
2 O
Well, clearly not in this report.
Do you have 3
any knowledge of why it is not in that report?
4 A
I do not have any knowledge of why it was in 5
the report.
6 0
Did you take any actions to point out that 7
there was a modification involving the moving of water from a
the demineralized reactor coolant storage tanks to the 9
regenerate holdup tanks?
10 A
To my knowledge, I made no statements like 11 that.
~
12 0
In 1985, there were approximately 787,500 13 gallons of water released from the demineralized reactor Ll 14 coolant storage tank to the environment-via the regenerate 15 holdup tanks.
Can you comment on what was the cause for 16 that large volume of water being moved, needed to be moved?
17 A
I have no knowledge of that.
is Q
Did you implement any management controls 19 or processes within your side of the responsibilities at-20 Rancho Seco to assure that water transferred from the 21 demineralized reactor coolant storage tanks to the 22 regenerate holdup tanks was properly sampled for radio-23 activity?
24 A
I have no knowledge of that.
25 0
Action #7 in that report which states, "The i
t e
37 1
District has initiated a policy that all releases will be 2
controlled such that Technical Specification 3.17.2 limits 3
will not be exceeded.
All sampling of the RHUTs and 4
releases of liquids will be based on this objective.
The 5
chemistry and radiation protection personnel ' responsible 6
for evaluating the releases have been instructed concerning 7
these objectives.
This action, coupled with Action #9 will 8
provide a second level of control beyond the other near-term 9
actions specified herein."
10 Are you aware of any responsibilities that 11 your organization had in complying with that action?
12 A
The only possible tie would be through the 13 ALARA program.
s-14 0
okay.
Can you describe what that would be, 15 then?
16 A
That ALARA program is to hold exposures as 17 low as reasonably possible, and we did have in nuclear 18 engineering the ALARA responsibility for reviewing certain 19 aspects of radiation control, but I have no personal 20 knowledge of that.
21 O
Whenever there is a responsibility as you 12 described, who would be responsible for reporting to you 23 that that release had been made of radioactive nuclides?
24 A
We would not -- typically the Manager of 25 Nuclear Engineering would not even see reports like that.
in 1
Those releases are signed by plant operating personnel, and
]
2.
the only knowledge we would have is the year-end reports 3
that we summed up everything and submitted that to Mr. Ed 4
Bradley.
5 Q
okay.
So during the course of normal business,
6 the. operations side would be responsible for collecting and 7
maintaining any records of releases, and you would be a j
8 collection point of all of those bits of data to then make 9
your annual report.
10 A
Yes, sir.
11 Q
Can you describe what the purpose of this
~
12 annual report is?
la A
It's a licensing requirement is all that I e
14 know.
15 Q
And within that licensing requirement, the 16 report is addressed to and directed to the Nuclear 17 Regulatory Commission?
18 A
Yes, sir.
19 Q
Is there any section in that report that 20 calls for documentation of any radioactive releases to the 21 environment?
12 A
Yes.
We're required"to document any liquid 23 effluents or' gaseous effluents.
24 Q
Are you in that process certifying that you 15 have complied with the ALARA requirements?
l l
l
_ l..o...
J
. ~.
39 1
A I think we are only certifying that we've 2
complied with technical spec requirements.
3 Q
Were you aware at any time that you'were not 4
' within the technical. specs that you have indicated you were 5
reporting to?
6 A
Any violation of the tech specs would be put 7
on a licensing event report, and sent in, and I would see-3 that and ultimately get a copy of all those.
i 9
O Did'you ever receive a licensing event report 10 that indicated that you were not in compliance with 11 specifications concerning release of --
~
12 A
Tech spec limits for liquid effluent releases?
13 Q
Right.
14 A
I don't remember that.
15 Q
Action 48 of Report 84-07 in the near-term 16 correction actions states that the processing of water from 17 the polishing demineralized sumpc,.PDS, and the RHUTs to 18 the rad waste system, coupled with the dilution of the i
L l
19 liquids will help ' ensure compliance with the limits of 20 radioactivity released in liquid effluence.
Can you explain 21 what is meant by dilution of the liquids in that regard?
12 A
No, sir.
13
.Q The basis in Technical Specification 3.17.1 24 limiting conditions for operations and Tech,nical Specifica-25 tion 4.21.1 surveillance standards, stkte that the i
9
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40 I
specifications do not assure compliance with 10 CFR 50, 2
Appendix I, dose objectives.
Can you explain why these 8
technical specifications cannot assure compliance with the 4
dose objectives of 10 CFR 50, Appendix I?
5 A
No, I cannot explain that.
6 O
Are you aware of any discussions, or concerns 7
ever raised about the Rancho Seco technical specification 8
in that regard?
9 A
I'm sure it was talked about at a Management 10 Safety Review Committee meeting about the release levels, 11 whether it was Appendix I or the AIARA release, or whether 12 it was the EPA release number, and there was discussion 18 about there being at least tto limits, maybe even there's a 14 third one.
15 Q
You mentioned earlier that Ed Bradley worked 16 for you.
Could you describe fcr us again what his capacity 17 was?
18 A
Ed Bradley worked -- in 1983, when I first 19 assumed the position of the Manager of Nuclear Engineering, 20 Ed Bradley worked for Bob Dieterich, the then Supervising 21 Licensing Engineer.
Some time in 1985, they transferred i
22 Ed Bradley and the ALARA group over to report to Roger 13 Powers, the Supervisor of Nuclear Engineering.
24 0
In the early part of 1985, did Ed Bradley 25 discuss with you the possibility that Rancho Seco's
[
j i
41 x
1 technical specifications on lower lindts of detection was
'I 2
not sufficient to assure compliance with the dose objectives 3
4 A
Yes, he talked to me about problems.
5 0
What was your response?
6 A
Tell me what to do about it.
7 Q
What specifically did he tell you were the 8
problems, and what he felt was the appropriate action?
9 A
I don't recall him coming back with specific 10 design changes that we should make.
11 0
Could you describe the problem that he
~
12 alluded to?
13 A
The problem, as I recall, was in the C
14 calculational things that we had done, how we were 15 administering the procedures.
16 0
Did he have any specific concerns about the 17 releases of radioactivity were greater than what,was being 18 calculated?
j i
19 A
Yes, he did.
20 0
Did this cause you to take any specific action?
21 A
Well, sometime shortly after that, or around
{
12 that tine, we actually did the next step thing, going to 13 Ashley, look'ing in the environment, and got water sanples, 24 soil samp,les and fish -
got some fish, other animals and 25 measured them for actual radioactive isotope uptake by
)
)
i A
42 I
{
1 animal.
2 O
Was this something that you did independently 3
within your operation or responsibilities?
4 A
It was a collective decision.
5 0
Who did you. discuss that with a[ far as
'l 6
making that collective decision?
7 A
It was discussed at the Management Safety 3
Review Committee which is made up of 10 of S!:UD's top 9
management people in the nuclear organization.
10 Q
And tell me who those people would be, to the 11 best of your recollection?
12 A
Ron Rodriguez is the Chairnan.
Alternate 13 Chairman was Andy Schwieger who was at that time Manager 14 of Quality Assurance.
John Sullivan was Technical Sngineer 15 off of the Quality Assurance staff.
Myself in Nuclear 16 Engineering.
John McCulligan, Bob Dieterich.
On the 17 Operating side was Pierre Oubre, George Coward, and Ron 18 Colun6o and the AGM,.that's Assistant General Manager of 19 Engineering Del Raasch, R-a-a-s-c-h.
20 Q
Do you recall approximately whe'n that 21 Management Safety Review Committee met that this information 22 was brought to their attention?
23 A
I do not remember, but we were meeting at 24 least every two weeks in that time frame lof early ' 85.
25 O
Do you have any notes or personal logs that mm.._ _ _ _. _. _ _ _ ___
i H
1*.
43 1
indicate that you did, in fact, inform them of this-2 condition?
3 A
There are minutes approved, meeting minutes 4
for every fianagement Safety Review Committee meeting.
f I did not take any personal notes.
6 o.
Du you recall seeing minutes that did 7
reflect the representation that you made?
8 A
The representation made probably by either j
9 Ed Bradley or Roger Powers, or both.
10 0
Okay.
So Bradley, or Powers, or both made the presentation?
11
~
12 A
Yes, sir.
13 Q
And you believed this was shortly after 14 Bradley brought it to your attention first in early 19857 15 A
The timing of when we finally mobilized for 16 action, I'm not sure, but it was sometime in -- I'm sure
)
17 it was before the summer of ' 85 when we collected the fish 18 samples.
19 0
Do you recall any of the discussion at that 20 meeting where anyone said -- well, you described that it 21 was a collective decision to do the things that you 12 described you did as far as collecting the fish, and 23 sampling downstream, and so forth.
Were there any internal
.24 actions that were going to be taken to ' find..out where these 25 effluents could be coming from?
I
44 e
l 1
and that was Roger Powers.
l 2
O Do you know if he made a report, or a staff 3
study that was made available to anyone on his findings?
4 A
The reports were made, several reports from I
5 Dr. Noskin of the Lawrence Livermore Laboratory.
j l
6 THE REPORTER:
Spell it for the record?
7 THE WITNESS:
N-o-s-k-i-n.
1 8
BY MR. MARSH:
'3 9
Q Now, Mr. Bradley brought this condition to l
1 10 your attention in the early part of 1985,, but he did not 11 issue a draft report until October 29th, 1985, and in that
~
12 draft study indicated that Rancho Seco's technical 13 specifications on lower limits of detection was not w-14 sufficient to assure compliance with the dose objectives 15 of 10 CFR 50, Appendix I, which is the same thing that he 16 related to you in th'e early part of ' 85.
17 Can you describe to us why there w4s such a 18 delay in identifying the problem and then reporting it?
19 A
My only knowledge is that there was a 20 question about the use of formulas and dilution factors 21 and rechecking data and rechecking calculations to be sure 22 that we knew what we were talking about.
23 0
Do you know if those checking of the 24 calculations and factors proved Mr. Bradley to be correct?
25 A
I think they did prove that we had made t
e 0
45 y
'o I
calculations in error.
2 Q
Do you recall approximately when those 3
confirmations were made?
1 4
A It had to be in that early ' 85 tire frame.
5 Q
Prior to all of the decided upon actions?
6 Or you mentioned that it was certainly that you had 7
assigned Powers to head up the actions that were described 8
as being -- taking place prior to the summer of ' 85.
Are 9
you saying also that Bradley's calculations were generally 10 confirmed prior to that, or about that same time?
11 A
About that same time.
~
12 O
So several months prior to October 29th.
13 A
Yes, sir.
J 14 Q
Is there any -- can you shed any light on 15 why there would be such a long lag time between the reported 16 anomaly, the confirmation of the anomaly and the actual 17 documentation in the draft study report?
18 A
My only knowledge is that the formulations, 19 and the computer work that was done needed to be checked' 20 and double-checked, and it wasn't a straightforward problem.
21 0
Did you at any time give Bradley instructions 22 to hold up on publishing that?
23
.A No, sir.
.24 O
Are you aware of anyone else giving him 25 instructions to that effect?
I I
a G
_m_-______________
46
,j' 1
A No, sir.
L 2
0 Are you aware of anyone, including yourself, 3
that may have taken action to preclude Mr. Bradley from 4
having the resources or necessary time to put that report 5
toge ther?
l l
6 A
Would you restate that please?
7 0
Are you aware of anyone, including yourself, 3
that precluded Mr. Bradley from having the necessary 9
resources,or tine to put that report together?
10 A
Mr. Bradley had limited resources to put 11 the report together, but in zy feeling, ample manhours to 12 do it.
13 0
At any time did you become concerned with the
('
slowness of putting this report together and identif'ying 14 15 the problem?
16 A
No, sir.
17 0
Are you aware of the october 29th, 1985 time 18 f rame in relationship to a shutdown of the plant prior to 19 that, and the restart of the plant?
20 A
I don't remember all that operating history 21 in 1985, no.
12 O
Am I correct in stating that once the 23 information had been brought to the knowledge of the
.24 Management Safety Review Committee, and Mr. Powers was 25 assigned as the responsible action party pertaining to that 6
'47 I
subject matter, that you had no further responsibilities 2
to head up the actions of making Mr. Bradley's concerns 3
known by anyone else?
4 A
Mr. Bradley worked for Roger Powers at that 5
time.
6 Q.
So you felt it was -- had the -- high enough 7
visibility to Powers who was responsible for the project?
8 A
And we went to the top mind in the country 9
for help on that.
10 Q
And that was?
11 A-Dr. Noskin.
12 O
Dr. Noskin.
What position was -- what job
~
q 13 did Powers have at that time frane?
14 A
He was a Supervising Nuclear Engineer Iauld 15 have been his title.
16 O
So he worked directly for you?
17 A
Yes.
18 Q
Now, the folks that you've described as j
19 being knowledgeable of this condition on the operations 20 side, Oubre, Coward, Columbo, and Raasch, is that correct?
21 A
No, Del Raasch would probably not have, he's 22 not in the nuclear organization at all, he was non-nuclear.
23
.Q Okay.
But he was in the committee?
- 24 A
Right.
25 O
So he had knowledge, but he wasn't on the i
E
i 48 e
1 operations side?
2 A
Right.
3 Q
So Oubre, Coward and Columbo would have been 4
the folks on the operation side having knowledge?
5 A
And Rodriguez coming from the operating side, 6
a former plant superintendent.
7 Q
Okay.
Did Oubre, Coward or Columbo, or 8
Rodriguez indicate that they were going to do anything 9
internally' to try to track down where these effluents could to be coming from, or control it more tightly?
11 A
Well, they talked about a lot of thinas, such
~
12 as fixing steam generators, putting in plugs, talked about 13 the condensate drainage that was bypassing the polishing 14 demineralizers, 15 O
Did anyone raise the point that because in 16 September, 1984, just prior to this, there had been a 17 commitment to NRC not to release radioactivity tQ#<p 18 environment and just a few months later, you're discovering 19 that you are releasing nuclides beyond the tech spec --
20 beyond the lower levels of detection, and the requirements l
21 of 10 CFR 50, Appendix I.
Did anyone raise that as a l
22 concern?
23
.A They had a lot of talk at that time about 24 the 3 millirem versus the 25 millirem and what was the real 25 limit.
l e
ao 1
0 So you were discussing what the real limit 2.
was, but wasn't anyone discussing the idea that you'd made 3
a commitment that you weren't going to release any?
4 A
I can't answer that question.
5 Q
Was there any discussion that this mattbr
[.
6 needed to be reported to the NRC?
7 A
I think it had already been reported to the 8
NRC.
9 0
How do you think that?
I 10 A
In the form of a licensing event report.
11 Q
When. do you believe that took place?
~
12 A
Sometine there in early '85, 13 0
Who would have been responsible for filing i
14 a licensing event report?
15 A
Ron Columbo.
16 O
So you fee 1 ~ that a licensing event report -in 17 early ' 85, based on Bradley's findings --
a 18 A
That we had made' errors in calculations, yeah.
19 0
Was -- you believe that was made?
I 20 A
Either in the form of L-A-R or in the form of i
21 a letter telling Region V that there were calculational 12 errors.
23
.O ras that part of the plan that was set in
.24 motion?
15 A
I believe so.
l
50 4
1 Q
So the minutes of that Safety Review Committee 2
should probably reflect that they were going to do that?
3 A
Yes, sir.
And I don't want to infer that 4
there's just one set of Management Safety Review Committee 5
meetings that would relate to this.
There are probably 6
several.
7 O
The same people generally involved.
8 A
Those are the people that serve on there, yes.
9
':ou can't have a meeting without six of them there.
10 Are you going to go much longer?
I'd like 11 to take a pee break.
~
12 O
Oh, yeah, let's take a break.
13 (Brief recess. )
r bd 14 O
Are you aware of any instructions given to I
15 the chemistry personnel to lower the counting limits on the 16 analysis of regenerate holdup tank effluence?
17 A
By hearsay I'd heard that this had occurred.
18 Q
Do you rech11 when you heard this?
19 A
In late '85, I believe.
20 Q
Are you aware of Mr. Kellie or Mr. Miller 21 having been informed of Mr. Bradley's findings?
4 22 A
It would be hearsay, but they all worked 23 together on the day-to-day data for putting together the 24 annual report comes via Roger Miller to Ed Bradley.
25 O
So, what you're describing is that Roger i
4
_____.m_________
M1 4
1 Miller would be supplying information to Bradley and then 1
2 Bradley would be putting together the annual report?
I 3
A Yes, sir.
4 Q
Does Bradley have anything to do with the i
5 semi-annual reports?
6 A
I'm not sure.
7 Q
When does Bradley start collecting his s
information for the annual report?
9 A
I can ' t answe r that.
10 Q
When does he file the annual report?
11 A
At the end of the year, he has 90 days, I 12 think, to get it in.
13 Q
So basically the collection of data may not r(
14 begin until January of '86 to make that '85 annual r'eport?
15 A
That's quite possible.
16 Q
So that the ' 85 annual report should have 17 reflected some form of data concerning the Bradley 18 calculations and the response to them, if there were 19 effluent releases beyond certain levels?
10 A
Yes, I believe that's true.
21 Q
Do you know if that report did contain that 12 information?
23 A
I cannot remember.
. 24 O
Do you recall who gave the authorization to-15 reduce the count time?
f e
0
52 s
1 A
I have no knowledge of that.
2 O
Are you -aware that in June 1985, Mr. Kellie 3
had a telephone conversation with Greg Yuhas, health i
4 physicist at Region V, NRC, regarding deportability of 5
identifiable peaks of radioactivity and sample analysis.
6 A
I might have got a copy of that.
I get 7
telecons, or would at times get telecons, but I don't a
remember that.
9 0
I'm going to show you a documentation of a 10 telephone conversation between Mr. Kellie and Mr. Yuhas 11 dated June 6th,1985, in which your name appears as having 12 received a copy.
Would you examine this and tell ne if 13 you recall this memo?
14 (Pause to examine document. )
15 A
I Probably still don't understand what the 16 telephone conversation was about.
17 Q
Do you recognize the memo as having seen it 18 before?
19 A
Since my name's on it, I would assume I've-20 seen it.
21 Q
But you don't have any recollection of it?
22 A
It's not one of the topics that I would 25 particularly not.
We see in those days, probably 100 of 2<4 those a week.
25 O
Do you have any reason to wonder why you i
l 53 I
i 1
would be on distribution for such a memo as this?
l 2
A I think routinely I was on distribution for I
3 all telecons between SMUD personnel and NRC.
4 O
So it's standard operating proce,dures to 5
create such a memorandum when there's communication between j
l l
6 SMUD officials and NRC officials?
7 A
It's a procedural requirement.
8 Q
Having knowledge of Bradley's concerns and 9
calculations, and that they were validated through a 10 process, did you do anything to express concern about 11 lowering the count time on the analysis of the effluence
~
12 in the regenerate holdup tanks?
13 A
I have no recollection of coupling those C-14 for sure.
15 Q
Are you aware of anyone else expressing 16 concern in that regard?
17 A
I know f rom secondhand information,that there 18 was a lot of discussion about changing the count time.
19 O
Do you recall who was involved in those I
20 discussions?
21 A
For sure, Bradley, Roger Powers and Dave 12 Micsa, M-i-s-a, I think is the name. -- no, that's not the 23 right spellihg.
24 Q
We'll find the spelling, Dave Micsa?
25 A
Yeah.
1 4
c 94 4
1 O
What was his position?
'2 A
He was rad chem technician out there who 3
was actually taking sanples from the regen holdup tank 4
for discharging, or for providing the discharge re'1 ease 5
form, and then the reason ne talked to me, because he 6
later come in and worked in the cost engineering group for 7
me.
8 O
Micsa did?
9 A
Yeah.
10 0
What was his concerns?
11 A
His concern, only that there had been a
~
12 change in this from 2,000 seconds to 1,000 seconds, and 13 he didn't understand the total implications of that.
l s-14 0
Did he have some concerns or reservations 15 about doing that that he expressed?
16 A
He expressed some concern that he night have 17 done something wrong, or been told to do something wrong, 18 yes.
19 Q
What did you tell him in that regard?
20 A
I told him that, you know, that's an instru-21 mentation type of thing and it would be resolved, and that 12 we were working on it, or somebody was working on it, that 23 he shouldn't be concerned, he was a technician, told to do 24 his job.
25 Q
Who was working on that problem as Miesa j
e i=
55 I
had described?
2.
A Fred Kellie.
3 0
Do you know what Kellie's findings were?
4 A
I do not know the outcome of that, whether 5
it was good, bad, or indifferent to lower the count rate.
6 0
What was the occasion of Micsa being reassigned 7
over to your group?
8 A
It was a promotional opportunity.
9 0
Was this after he had raised the concerns?
10 A
No, no, this -- when he raised the concern, i
11 he was already located downtown in Plaza 50, totally away
~
12 from the Rancho Seco plant site.
13 0
Are you aware of any discussions or plan
- 14 existed to -- for Mr. Bradley to withhold issuing of the 15 final study that he had done until such time as Rancho 16 seco was back on-line?
17 A
I have no such knowledge of that.
\\
18 0
I remind you that you are under oath.
19 A
Yes, sir, I still have no knowledge of Mr.-
20 Bradley being told, ordered, or otherwise to withhold any 21 kind of report.
22 O
Are you aware of him voluntarily suggesting 23 that?
24 A
He might have suggested all kinds of things.
25 I have no -- I can only say I did not order Nr. Bradley to f
m___. _ _ _ _ _ _. _._ _. _. -
56 C
I hold any report, or any information.
2 O
Are you aware of'any discussions concerning 3
that matter?
4 A
I am not aware of any discussions even if 5
we talked about such a thing.
6 O
Concerning the nemorandum that came to you 7
pertaining to the interpretation by Yuhas that the -- any 8
detected nuclides should be reported, do you recall taking 9
any action. pertaining to that?
10 A
No, sir, I took no action.
11 Q
Did you at any time express concern that
~
12 lowering the count time could impact adversely on commitments 13 of Special Report 84-077
(~
b-14 A
I made no comments on the count time.
15 0
When Mr. Micsa expressed his concerns to you, 16 did you document any of these concerns and route them to 17 anyone?
\\
18 A
No, sir.
It was given on a personal basis, 19 not -. he didn't want anything documented, or-didn't ask-20 for my help, or anything else.
21 o
All right.
Can you describe your relationship 22 with Mr. Micsa that would cause him to come to you with 25 this concern?
. 24 A
Merely that he had worked out of Rancho Seco 25 and was now coming into a new job,. and he wanted to share
^{
e
57 o
I things with ne at times.
2 O
You and Mr. Miesa live generally in the same 3
community?
l 4
A Not that I know of.
i 5
0 In October of 1985, Lawrence Livermore 6
Laboratory reported detecting Cesium 137 in downstream 7
sediment.
Are you aware of this report?
8 A
If that's the Lawrence Livermore report on 9
Hadesville Creek samples.
10 0
Was this part of the exercise ' implemented i
11 based on Mr. Bradley's concerns?
12 A
Collecting water samples and soil sampics i
~
13 was a part of the whole program that Roger Powers laid out, 14 really.
15 0
Based on Bradley's concerns?
16 A
Based on Bradley's concerns.
17 Q
Did you take any action at that - tine in regard s 18 to Bradley's findings in the Livernere Lab findings in 19 October of '85?
20 A
We did additional work on collecting, I i
21 believe even some cattle samples for cattle that was in the We set up also an ongoing program that where you 12 area.
13 would catch 'diff erent seasons of the year, we would catch
.24 liquid samples and measure them.
15 0
It sounds to me that generally the actions i
58 1
~ 1 that-were-decided upon'were all to neasure the impact or 2
result of any releases.
What kind of' actions were being 3
taken to identify the source of the.nuclides and preveat 4
-them from being released?
5 A
The only actions I know of was to review 6
what might be done to the steam generators to improve their 7
integrity, such as a Layne Blocking Bar, we looked at that, 8-I remember, we looked at the water industry, took another 9
look to see if there was something amiss in the water 10 industry,.and the reason we went to look at the actual 11 environment of the soil samples, water samoles, and animal
~
12 life was everything else was theoretical as f ar as what i
13 impact isotopes might have on the animal life.
c.
sv 14 Q
Well, I'm not indicating that that's not a 15 wise policy to check those things, but it would seem to 16 me that if you've got the evidence of a problem that's 17 potentially being caused'by some condition within your l
18 plant, it seens like the major thrust would be to isolate 19 the cause, or the root cause of that problem, and I haven't 20 heard any description of any elaborate efforts that were 21 made to do that.
12 A
If that's a question, I agree, we did what 23 we could with the resources we had.
.24 O
Did you ever correlate Mr. Bradley's concerns, 25 the findings of the radioactivity downstrean, and the lowering
(
59
-.1 1
of the count times as being related in.any way?
l 2
A No, sir, never related those in my own mind.
8 O
Are you aware of anyone else making such -a 4
correlation, or hypothesizing that possibly that was a
^
5 contributing factor.
i 6
A-No, that was secondhand information that the-7 people were concerned that count time had -- would allow 8
release of radioactivity higher than reported.
9 Q
Who was making that concern?
10 A
It was coming from mid-valley,. but not 11 directly.
-12 Q
Uould your organization be' responsible in any la way for documenting, or taking composite samples to la 14 submitted to the contractor controls for environmental 15 protection, you know, CEP?
16 A
Those samples, 'and' that contract was 17 administered by Roger Miller of the Nuclear Operations.
18 Q
Did your organization. have any responsibility 19 for that operation at all?
20 A
To my knowledge, we did not.
21 Q
Would you be awarit of any of the deliverables 22 or documentation that was requi: red under that contract?
28 A
No, sir.
O Have you been inforned, or are you knowledge-i
.24 25 able that certain documents on t:he analysis performed by l{
e M
.g 60 1
CEP are missing from the SMUD records?'
2 A'
I have.no knowledge of that.
3 Q
Are you aware of the impact of diluting the f
4 regenerate holdup tanks with service water on the test and 5
sampling process?
6 A
I have no knowledge of that.
We practiced 7
that.
There's some provisions for adding dilution to the 3
regen holdup tanks.
9 Q
The question is, are you aware of the impact 10 of diluting the holdup tanks with service water on the Il testing process?
12 A
As an engineer, my training would tell me
~
18 that would lower readings.
' ('.
Tw '*
14 '
Q Are you aware of any activities'that may have 15 been brought to your attention, or that you were aware of 16 in some form, where radioactive readings would be obtained 17 and then the regenerate holdup tanks would be diluted 18 further, and then readings taken again so that the readings i
19 would be below a certain threshold?
I 20 A
I have no knowledge of that.
There would be 21 a procedure that would tell how to collect samples and --
12 of the release permit should have all the information on j
13 how much dilution water was added.
.24 Q
okay.
So if you, in your testing process, 15 detected nuclides, well, then, it would be necessary to i
e
61 I
dilute it to a certain degree before it could be released?
2 A
That sounds like that's the practical way 3
it would work, yes, sir.
4 O
Are you aware of that being generally the 5
way it was suppored to work?
6 A
I have no knowledge of how they actually 7
did it, I never did it, and that's a Nuclear Operations 8
operation, not Nuclear Engineering.
9 Q
Okay.
If that process was taking place to 10 where a nuclide was detected in some form, and then the 11 regenerate hoidup tanks were diluted, and then the total 12 volume was then released to the environment, according to 13 the memorandum of a telephone conversation, and between r
s' 14 Yuhas and Kellie, would it be appropriate to document the i
15 fact that a peak was detected, or the nuclide was detected?
16 A
Yes, that would seem that that would be in 17 order.
18 O
Would you say that if 'it is in fact not 19 being done, that it is contrary to the interpretation by-
]
20 the NRC?
21 A
It appears to be, yes.
22 O
So the way you understand the system, the 23 dilution would come prior -- or af ter the test had been
.24 taken to detect the nuclide?
15 A
well, let me explain, in the regen holdup tank,
l r
f
6 2__
a o
I there's also dilution added to balance the pH of the liquid 2
effluent in the regen holdup tank, so water is added for 3
more than just one reason.
4 0
okay.
But it would be appropriate to take 5
an -- do an analysis of water moved from the demineralized 6
reactor coolant storage tanks into -- strike that question.
7 When water is moved from the demineralized a
reactor coolant storage tank to the regenerate holdup 9
tanks, the test samples should be taken at that time, prior 10 to diluting the RHUTs.
11 A
I can only answer in that my engineering
~
12 knowledge of how that should work is that the regen holdup 13 tanks are released on a batch basis, and the sample should e,
w/
14 be taken at the time of release, and after the water's been 15 properly mixed.
16 Q
If the commitment is, however, to not release 17 radioactive nuclides, is it possible that diluting that 18 volume of water would then bring the detectability --
19 make it more difficult to detect the ' radioactive nuclide?
20 A
I think that's a correct engineering statement.
11 O
So if the intent was to notirelease radio-22 activity to the environment through the release of ef fluence,
23 the most likely time to detect the radioactivity would be 24 prior to dilution.
25 A
Yes, sir.
4
61 1
O concerning the modification that was made to 2
move water from the demineralized reactor coolant storage 3
tank to the regenerate holdup tanks, who would be 4
responsible for collecting and maintaining records of 5
that modification?
6 A
It would be in the Nuclear Operations 7
Department and candidates for doing that would have been 8
Fred Kellie in charge of water chemistry and health physics, 9
or possibly the operators.
10 0
Who would be responsible for collecting and maintaining records of actual transfers of water from one 11
~
12 tank to the other?
13 A
And again, I think that -- I don't know the 14 plant operations that well, but those are the two candidate 15 groups for maintaining those records, for sure, Nuclear 16 Engineering would never see those records and not be 17 involved with moving water around the plant.
.5 18 Q
Were you ever involved in any discussions 19 regarding whether the modification, as I've described, i
20 should be reported to the Nuclear Regulatory Commission
)
1 l
21 or not?
22 A
I was never involved in those discussions.
13
.O Are you aware of those discussions taking 24 place?
1 4
25 A
No, s ir.
5 J
64 o
I (Pause) 2 A
My qualification on that 'last one would be 3
that typically, temporary modifications of the plant are 4
not reported to the NRC.
5 0
Are you aware of a certain point in time in 6
the 1970's time frame of shipping radioactive water off X
7 of the Rancho Seco site for disposal?
8 A
Yes, sir, we shipped water from sometime in 9
mid-70's til sometime in -- close to 1980.
10 0
Do you recall the nature of that water that 11 was being disposed of?
~
12 A
It was low level radioactive liquid, water.
15 The readings, I don't recall ever seeing the readings, 14 but --
j-15 Q
Wasn't that, in fact, the method of disposing 16 of radioactive water in the design of the plant that we 17 talked about early on in the interview?
18 A
Yes, sir, we hauled water as part of plant i
19 design, that or drum it.
We had a drumming station.
20 0
Do you recall the reason for stopping the 21 shipments of radioactive water?
12 A
I did not participate in that decision.
23 Q
Do you know who did?
24 A
I could only assume it was the then Plant 15 Manager, Ron Rodriguez.
4 m
o 65 a
1 Q
Do you recall where the water was being 2
collected for this disposal process?
3 A
Only in one of the miscellaneous rad waste 4
tanks would be my only knowledge, and the true,k backed in 5
nekt to the auxillary building, and we had a station there 6
for filling the truck.
l 7
0 Was any water ever taken from the demineralized 8
reactor coolant storage tank for this process?
9 A
I can' t answer that.
10 Q
Do you have any further information pertaining 11 to the nature of this investigation that would be relevant 11 that you would like to add at this time?
~
IS A
No.
C.
14 Q
As a citizen, living in a community near the 15 plant, are you concerned in any way that radioactivity --
16 radioactive effluence have been released into the water 17 systems and have not been reported for proper analysis and 18 control?
19 A
I believe that adequate work has been done-10 in monitoring the liquids in Hadesville Creek, Consumnes 11 River and through the Galt Irrigation District, which it 12 is real close to where I live, where they distribute water, 13 and I am comfortable with the results of all of the
. 14 Lawrence Livermore Laboratory work showing that the levels 15 of reactivity are barely measurable.
e e
wh__-._.__.mm_____.___._____..__._____________m.___m_.
_________________.___m.____.,__..___.___._.__..__.,__.m
66 e
1 0
Do you believe that the plant procedures as 2
you know them are adequate to -- in the design of the 8
plant, and the operation of the plant, is adequate to 4
protect the citizenry living in your communitp?
5 A
I think as they presently exist, they ' ve been 6
improved on, and I think that that problem has been solved.
7 O
If there was manipulation of the counting 8
time and the chemistry testing processes back in the 1984-85 9
time frane. that disguised the nature of the effluent release s, 10 would that be considered an acceptable practice to you as 11 a citizen living in the community?
12 A
I do not know the end result of changing 13 count rates, or changing procedures, but I've always
(.
L#
14 supported that we do things on the safe side, whether 15 lowering the count improved the accuracy, or lessened it, I 16 do not know the results of all that.
But I did spend 17 enough time with Dr. Noshkin to feel comfortable.in the 18 work that he had done, feeling safe living in Galt.
19 Q
Has any S!!UD official, or manager, or 20 supervisor given any instruction to you that you should 21 provide information f rom this interview to them?
22 A
Yes.
We were told to first tell the Manager 13 of Licensing that we have been asked to come for an inter-l
.24 view, and secondly, would we jot down or telephone him the 15 major points of -- or nighlights of the interview.
l f
67 I
1 1
0 Do you feel intimidated in any way, or a 2
pressure on you to comply with that?
8 A
Yes, I'll call him and tell him in general 4
what we talked about.
5 MR. MARSH; That concludes the interview at 6
this time.
Let the record show it is 11:36 a.m., March 7
25th.
Thank you again for coming down.
8 MR. KIELMAN:
Sure, Rob, thank you.
9 (Whereupon the interview was concluded at 11:36 a.m.)
10
--oCo--
11
~
11 Il r
L 14 15 16 17 18 19 30 21 12 33
. 24 25 i
a
O is to cOrtify that th3 ottach0d proc 3Odinga b3foro thO ITdITED STATES NUCLEAR REGULATORY CCMMISSION in the matter of:
E OF PROCEEDING:
INVESTIGATIVE INTERVIEW (CLOSED)
DOCKET NO.
NONE
", PIACE :
Rancho Cordova, California "DATE:
25 March 1987 were held as harmin appears, and that this is the original transcript thereof for the file of the United States Nuclear kegulatory C 4=sion.
r.
(Sicit).
MIRNA CHOY d
Official Reporter Reporter's Affiliation Jim Higgins and Associates
~
1 l
t
(
EXHIBIT e
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re z %!# _M l
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