ML20247F418
| ML20247F418 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 03/24/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20247F042 | List:
|
| References | |
| FOIA-89-2, FOIA-89-A-7 NUDOCS 8905300079 | |
| Download: ML20247F418 (90) | |
Text
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i 1
BEFORE THE l-2 UNITED STATES 3
NUCLEAR REGULA'10RY COMMISSION 4
REGION V 5
6 In the Matter of:
)
)
7 INVESTIGATIVE INTERVIEW
)
DOCKET NO:
NONE I
8 (CLOSED MEETING)
)
9 Sunrise Sheraton Hotel 11211 Point East Drive 10 Rancho Cordova, California 11 Tuesday,-
March 24, 1987 12 13 An investigative interview was conduct,ed with 14 UILLIAM A. WILSON, commencing at 1:12 p.m.
15 PRESENT:
16 PHILIP V. JOUKOFF Investigator 17 office of Investigations, Region V Nuclear Regulatory Commission 18 19 20 21 Information in thiS TeCord was deleted 12 In z:
ce nith th Freedom of Information f
23 F0iA -- J e f/- 2
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2 l
1 CONTE!)TS 2
WITNESS PAGE 3
William A.
Wilnon 4
Examination by Mr. Joukoff 3
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 23 l
1' 24 i
25 i
i I
3 l
5 1a9CEEeIn2S 2
1:12 p.re.
3 MR. JOUKOTF:
The date is March 24th, 1987.
4 The time is 1:.'2 p.m.
For the record, this is an interview 5
of William Albert Wilson, W-i-1-s-o-n, who is emoloyed by I
6' the Sacramento Municipal Utility District at the Rancho l
7 Seco Nuclear Generating Station.
3 The location of this interview is the j
i 9
Sheraton Sunrise Hotel and Towers, Rancho Cordova, California 10 As agreed, this' interview is being transcribed by Court 11 Reporter Harry Attmore.
The subject matter of this l
12 interview concerns the Radiological T.ffluent Program at the ;
i 13 Rancho Seco Nuclear Generating Station.
14 Mr. Wilson, please stand and raise your richt i 15 hand.
16
'Whereupon, 17 WILLIAM ALBERT WILSON 18 was called as a witness herein, and, having first been duly 19 sworn, was examined and testified as follows:
20 EXAMINATION 21 BY MR. JOUKOFF:
22 0
For the record, Mr. Wilson, could you please 23 state your full name?
24 A
William Albert Wilson.
15 0
And y our da te of birth?
t
- mmar6mmeses e
swat m
W------_-_-.
___x.
1 4
~
l 1
A ll l
2 O
By whom are you employed?
3 A
Sacramento Municipal Utilities District.
4 Q
And as an employee of S!!UD, can we call i:
L 5
SMUD?
6 A
Yes.
7 0
Where is your work location?
3 A
The Rancho Seco Nuclear Generating Station.
9 Q
And at the Rancho Seco ' Nuclear Generating.
to Station, what position do you occupy?
))
A.
Presently, I'm the acting chemistry operation 12 s upe rvisor.
13 0
And for how. long have you held that position?
14 A
Approximately one year.
15 0
And prior to holding that position, did you 16 act in another capacity at Rancho Seco?-
17 A
Ye s.
Previous to that, I was classified as a la senior chemistry radiation assistant.
19 0
And for approximately how long were you in 20 that job classification?
21 A
For about seven years.
22 0
And how long, totally, have you worked for 23 SMUD at Rancho Seco?
24 A
Almost 15 years.
1 25 0
Prior to my asking you the last series of j
i
)
1 i
I 4
/-
l
5 1
ques tions, I placed you under oath.
Was that done with-2 your consent?
[
3 A
Yes.
4 O
And this interview, is it being held at your lq 5
consent?
I 6
A Yes.
i 7
Q I would like to show you a copy of a document 8
dated September 27th, 1984, and it is on the SMUD letterhead 9
and it's to John B. Martin, who is the Regional Administra-10 tor of Region V of the Nuclear Regulatory Commission and' 11 it's signed by R. J. Rodriguez, Executive Director, Nuclear 12 for SMUD.
Could you take a look-at this document and 13 f amiliarize yourself with it?
14 A
Yes.
15 (Pause to examine document.,
16 A
I'm a slow reader.
17 Q
He actually might be able to shorten the I
18 p roce ss.
11 ave you ever seen that document before?
il 19 A
.I'm trying to remember.
The -- generally a j
i 20 lot of paperwork that we sometimes don't get to see.
j l
21 O
Let me just ask you, were you -- can you 22 recall being involved in the development of information for 25 this report?
q 1
24 A
I may have been, if it has to do with the 1
25 tube leak which I just saw.
6 1
Q Okay.
Well,.why don't we let you go ahead a..d 2
finish reviewing the document, then, perhaps you can 3
remember if you had any involvement in preparing this 4
. document, or preparing information for -that document.
5 A
All right.
6 (Pause to examine document.)
7 A
I probably helped generate some of the raw a
data, okay.
9 O
Ok ay.
1
'10 A
This is the end result.
11 O
Have you ever seen that document before in 12 the final form as it is now for any reason?
13 A
Not that I can recall.
14 O
Okay.
That document is commonly referred to1 15 as special Report No. 84-07, and why it goes by that nane,.
16 I'm not sure.
Would it bother you if I called it Report 17 84-07?
1 18 A
No.
l 19 0
Okay.
Do you recall interfacing with anybody 20 to obtain information.that was used in the preparation of Il 21 that report?
22 A
Well, it would be under the -- our groue at i
!l 25 the time which was Chemistry Rad Protection.
!I I1 24 0
Okay.
But other than a general recollection,
j 25 can you renenber talking to any particular individuals, i
I e
I J
~
7-]
p.
1 or interf acing with any particular individuals in order to:
2 gather. information about that report?
f I
3 A
Well, it would be my supervisor at the, tire,-
L 4
because he would ask'me'for certain.information.
j i
5 0
And who was your supervisor at the time? '
6
'A Tred Kellie.
'7 0
Fred Kellie?'
8 A
He's -- at that time, I think he was'the 9
assistant. Chem Rad Supervisor.
i i
10 Q
Okay.
How about any -- can you recall any-4
'll specifics at all about what information you might have 12 supplied to him, or any activities that you might have gone'l-
\\
13 and gathered information, done research, or anything like 14 that?
15 A
You've got to realize, this is almost two and 16 a half years ago.
17 0
Yeah, no, I understand that time-has elapsed 18 since that report was written.
19 A
Well, some of these near-term corrective I
20
' actions, you know, they bring back a memory that, yeah, i
21 that they were being addressed.
12 O
So near-term what?
23 A
I'm sorry, in the document, it says near-term i
24 corrective actions in' response, and I remember they were 25 doing something about that.
Prior to that, you know, I've
]
4 l
~
.1 9
L
.I 1
asked for, you' know, different things, over the course of 2
the history of the. plant that things be done, and this 3
final form, I don't recall.
~
4 O
You basically don't recall?
5 A
No.
i I
I 6
O Okay.
Can you recall when -- f rom what tire 7
frame you gathered information for that report, or.is.that 8
also vague?
9 A
Well, go back to your dates, or this. document'p 10 dates, I should say, I ' m sorry.
Well, it would have to be 11 previous to this letter is all I can say, you know.
12 O
You don' t have any specific recollection then?
13 A
No, no.
14 O
Okay, thank you.
Can you reca11'specifica11y, 15
.what information you developed, reviewed or analyzed with 16 respect to the input for this report?
17 A
Oh, part of our function is to analyze water 18 samples, whether it be normal routine operation, or leaks-,
19 you know, and we deterndne leak rates, and that would-be the 20 kind of data that we 'd have to --
21 Q
Okay.
And in reference to leak rates, are you 12 talking about steam generator leak rates?
13 A
Yes.
14 0
Ok ay.
So you think generally you w'ere involved 25 in calculating steam generator leak' rates?
t
9 1
A Or reviewing the. data.
2
-Q or reviewing the data.
But specifically,.ycu 3
can't remember what it was.
4 A
Well, I used to do it, you know.
5 Q
Okay.
All right.
Are you aware of any other 6
SMUD officials, enployees that were involved in the 7
preparation of this report, who they were?
8 A
Well, I'm sure -- well, this is my own 9
opinion, but I'm sure a lot of people reviewed that document 10 you know, that's --
11 O
I'm talking about, you know, who is responsibl.
12 for input to create this document?
13 A
Well, Fred Kellie would be one.
14 0
Fred Kellie would be one.
Anybody else that 15 you can think of?
16 A
Well, maybe at the time, Roger Miller, but 17 I think he retired, you know.
I want to say June of '85, 18 but -- I don't know if he was involved with it.
He probably.
19 was.
20 Q
Okay.
Referring back to the report again, 21 the last sentence in paragraph 3 of this report, states 1
12 that the " Steam generator tube leaks were considered the 23 major source of contamination for the secondary system. "
24 A
Okay, I would agree with it.
25 0
Okay.
What were the other sources of F
L--____-_____________-______-__-___-___-____-___
____-_______A
c7_
[
' 10 -
i 1
contamination for. the secondary system?
2 A
Well, initially itJwas the tube leaks, and 3
then after the stopped it, the leak per.se, you know, we 4
shut down the' system, the residual activities,that was in 5
the contaminated system now was a source.
6 Q
!!ow about any other -- are there any other 7
external sources, other than the tube leaks that would L
8 cause contamination, radiological contamination in'the ll l
9.
secondary. system that you're' aware'of?
t-10 A
No, no.
4-11 Q
So basically, it would have to come directly 12 or indirectly from the steam generator. tubes?
13 A
From the -- right.-
14 0
Okay.
During 1985, can you recall if there 15 was contamination in the secondary system at Rancho Seco?
16 A
Oh, I'm sure - there was, there's a little bit '
17 right now, it's residual, so --
18 0
Okay.-
19 A
And we did have a -- what we call a weeper, a 20 real small, almost negligible tube leak, almost -- well 21 actually, it was.almost undetectable, but we. knew it'was-12 there.
23 0
Okay. - What was d,one in 1985 to eliminate the 24
- sources of ' radioactive contamination in the secondary 25 system?
If you can' t answer that specifically, what is f
f
_.al_-.__--__._L_.__....-
l 1:
1 typically done to attempt to minimize the radiological 2
contamination in the secondary system?
3 A
Typically we try and clean it up.
You know, 4
we have a polisher system, resin domineralizers that we 5
can recycle-water through it to clean it up.
6 Q
And these demineralizers, these are resin L
7 beds, is that correct?
8 A
Yes, resin beds.
9 Q
And what type of contamination can these 10 resin beds remove, what radio isotopes are they capable of 11 removing from the secondary system?
12 A
The majority, except for tritium.
13 0
So of the radioactive isotopes present in the 14 secondary system, by pulling the water through these resin 15 beds, you would expect to remove everything but tritium to 16 some extent?
17 A
Yeah, and I forgot, you have fission gaser 18 that are not too good f or that either.
i 19 Q
Okay.
I'd like to again refer to this same 20 report, Special Report 84-07, and I'd like to ask you to 21 read the last paragraph on the second page, if you could, 22 it begins "The p ath that... "
23 A
Okay.
24 (Pause while reading. )
25 0
Okay.
Were you responsible for the original j
1
--__._2__________-_-.__
T2 1
input of the information contained in the paragraph that 2
you just read?
3 A
I don't think so.
I may have been' asked, but 4
everybody-chat is out there is' aware of the flow path.
5 o
You don't recall directly giving that input, 6
so is this basically generally known knowledge is what is 7
stated in that paragraph?
3 A
It's generally know, yes.
9 0
so you can't really. identify one individual l
10 who might have given that input to this special report?
11 A
No.
12 O
Okay.
I understand at Rancho Seco that there 13 are a series of tanks'that are used to store radiologically 14 contaminated water, is'that correct?
15 A
There's a lot of different tanks.
16 0
Okay.
One of these tanks is called the l
17
' demineralized reactor coolant' storage tank, is that correct?
18 A
Yes.
19 0
And there's also another tank that's called 20 the generate holdup tank, or there's actually two of.those, 21 I understand.
22 A
One's the regenerate holdup tank.
I 23 Q
Regenerate holdup tank?
24 A
Yes.
25 0
Okay.
Would it bother you if I called the Lj
1 1
1 first one the DRCST, and the second one the RHUT tanks?
l
- t i
2 A
No.
t!l I 3 3
0 You'd still be familiar with what I'm.talkinc i{
4 about?
j I:
)
L 5
A That's the acronym we use.
]
--4 6
0 Okay.
In reference to the DRCST tank, can 7
you tell me what the purpose is of that tank?
L
'8 A
That is a' holdup tank for makeup water to the 9
primary system.
{
10 Q-And how does water cone to be in that tank?
11 A
We have what we call our effluent rad waste I
12 system, and the miscellaneous liquid rad waste system, and.
I 13 we process water through evaporators to clean it up, one 14 recovers boric acid, the other one just makes distilled 15 water, and that's a storage tank for the distilled water 16 out of the evaporators.
17 0
So consequently, the source of water that 18 eventually winds up in the DRCST tank comes. -- it comes I
19 from where, the reactor building?
]
20 A
No, the reactor coolant system, and our -- I 21 call it the drain system, the dirty ' water system in the 1
l 22 controlled area.
23 Q
How about the -- you have let's say floor 24 drains in the --
29 A
That's the miscellaneous liquid rad waste
.1 system.
2 O
And that's not the sane as the --
3-A Effluent rad waste system, no, that's primary 4
water, clean water, chemically clean.
5 Q
Chemically clean water.
So if you werento.
6 spill some water -- if the plant were to for some reason 7
spill sone water on the floor in the reactor building, where 8
would that water go to?
9 A
It would end up in the miscellaneous liquid i
10 rad waste system in the storage tank in the building.
11 Q
And that's a dif ferent tank than the DRCST-12 ta nk ?
IS A
Yes.
14 0
Okay.
How about the regenerate holdup tanks?-
15 What water is stored in those tanks?
16 A
That comes from the leakage, or water processir 17 in the secondary side of the plant, not the controlled area.
18 Q
And is water in those tanks, is it radioactive' 19 A
It has been.
20 0
There are times when it is?
21 A
Yes, and at times we pump it back to the 12 miscellaneous liquid rad waste system.
28 0
The miscellaneous rad waste system?
14 A
It 's the -- well, okay, one more tinne 25 0
okay.
Ij
15-
-l 1
A We have two systens for processing water in 2
the controlled area.
i 3
0 Okay.
4 A
Coolant rad waste is'from the racker systems.
5 0
okay.
6 A
And the miscellaneous liquid rad waste is.a i
7 dirty water type system, sumps, drains, floor drains, and l
8 stuff like that.
9 0
What happens to that water?
10 A
That water is processed, distilled, deionized 11 and sent out to the DRCST, or there's another tank that's 12 a miscellaneous water holdup tank, they're both about the
.i i
13 same quality of water.
14 0
Okay.
What's the size of the DRCST tank, 15 gallonage?
16 A
It's capacity is 450,000 gallons.
17 0
And how about the two RHUT tanks, what ' are 18 their capacities?
19 A
A-1 is roughly 100,000 and the B is roughly 20 200,000 gallons.
21 0
Now, water that is maintained in the DRCST-l 22 tank, is it routinely sent for any reason to the nHUT tanks?
23 A
I wouldn't say that as a matter of routine, 1
24 but yes, it has been.
25 0
It has been done in the past?
._a
16 1
A Yes.
2 Q
And by what mechanism'is water transferred-3 from the DRCST tank to the RHUT tanks?
4 A
They put in a tenporary pump and piping and 5
transfer it.
6 O
And what was the reason for them to do all 7
this, to move water from the DRCST tanks over to the-RHUT 4
tanks?
9 A
Okay.
They was running out of room.
10 0
Okay.
11 A
'It was filling up due to excess water 12 generation.
13 0
Okay.
And what caused that excess water 14 generation, do you know?
15 A
Well, part of it was from the tube links, and-16' we would put a lot of secondary water back through the 17 system, and we'd call what we have a black box, it's water 18 inventory, and what we put in, we should use, and it's 19 generating more than what we could use, so we had to 20 discard some water.
21 C
So what you' re telling me is that somehow 12 some of the water that was on the secondary side got back-23 around to the DRCST tank, is that correct?
24 A
Yes.
25 Q
So water is pumped from the RHUT tanks at 1
_h___mu____m
___.,___m__..
17 1
times back around and goes.through the evaporators, is that 2
correct, and then winds up in the DRCST tank?
3 A
Ye ah.
4 0
Okay.
Why would that procedure. occur?
5 A
Well, for one thing, the water was probably 6
too hot radioactivity-wise to discharge downstream,;the 7
effluent system.
8 0
So by putting the water through the evaporator '
9.
it lowers its radioactivity, is that correct?
10 A
Yes.
11 0
The radioactivity of the water?
12 A
Yes.
13 Q
okay.
14 A
We've also put it back to'our secondary 15 system and run it through our polishing demineralizers.
16 Q
So this is taking water out of the RHUT tanks 17 and putting it through the polishing demineralizers, and 18 poing back in the RHUT tanks ' again?
19 A
Well, cleaning up the radioactivity in that 20 respect.
21 Q
Okay.
22 A
But we've only done Unat once, I think..
23 0
Is that -- can that be done by existing piping' 24 in the plant?
25 A
No, I don't think so.
F
__________.m_
i 18 L.
l.'
1 0
So the times when it was done, was it a i
2 special --
1 I
3 A
On a temporary system.
l 4
O A temporary system had to be installed to do 5
that.
'And when the water was moved from the DRCST tank 6
to the RHUT tanks, was that done by a temporary modification?
7 A
Yes..
3 O
And do you know who it was that directed 9
that that modification be made to the plant?
10 A
As an individual, no.
11 0
Do you know whether or not a modification of 12 a plant like that must be reported to the Nuclear 13 Regulatory Commission?
14 A
I know certain things have to have 50.59 15 reviews, you know, safety reviews.
16 0
okay.
Do you know if that modification had a 17 50.59 review?
13 A
No, I don't know.
After the reports, I don't 19 think it was, but at the time it was done, no, I didn't know 20 Q
Okay Do you know what the reason was for 21 not reporting that modification to the NRC?
12 A
No.
23 0
Do you know what the reason was for not 24 reporting to the NRC that water was being transferred from 25 the DRCST tank to the RHUT tanks?
- - _ - - - - - - ~ _ _ _ _ _. _. _ - - - _ _ _ _ _ _ _ _ _ - _ _. _. _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _,
'19 i
i 1
A No.
2.
O Were you at any time involved in any effor:s 3
at Rancho Seco to notify the NRC concerning the modification 4
involving the DRCST tank and the RHUT tanks?
3 f
5 A
No.
i 6
0 You never brought it to anybody's attentien 7
that this should be reported to the NRC?
8 A
No.
9 0
Your bosses, your supervisors, higher manage-10 ment in SMUD?.Well, did the thought ever cross your mind 11 that it should be reported to the NRC?
12 A.
No, I'm-in a different. flow path, you know.
13 0
Okay.
So that basically the reporting some-14 thing like that to the NRC would not necessarily be
.l.
i
'15 something that you would be involved with, then?
16 A
No, that's a licensing aspect, or a rate 17 compliance, and I'm not really involved with that.
18 Q
That's not in the purview of the type of work 19 you do, is that correct?
20 A
No.
21 0
That is correct?
22 A
That is correct.
28.
O okay.
In 1985, approximately 787,500 gallons 24 of water were. released from the DRCST tank to the environ-1 25,
ment via the RHUT tanks.
Are you aware what activities l
I L_=-_--_-_-________-__-_-____-___--_____--_-__-_-__-______-__-___-________-_____________________---__-
20 I
caused that. release to occur?
2 A
Other than what I've previously mentioned, l
1 3
just an excess accumulation of water.
4 0
And by' an excess accumulation of, water, that 5
means that the DRCST tank just had too much water in it,
.i 6
and something had to be done with the water, is that
~7 correct?
8 A
Yes.
9 0
And was that water then transferred to the
'10 RHUT tanks via a temporary modification?
11 A
Yes.
12-0 And from the RHUT tanks, how is the water 13 from those tanks released to the environment?
14 A
We empty them.into a retention basin, which-15 is another holdup pond.
16 0
okay.
This is an open-air pond rather'than 17 a tank, is that correct?
18 A
Yes.
19 0
And then from that basin, where does the 20 water go?
21 A.
To the plant effluent, to the environment.
22 O
Does it g'o dovn a creek of sone type?
l L
23 A
A creek, yes.
24 Q
Okay.
Is that commonly known as Clay Creek,.
25 is that correct, or do you know?
.__m.__m_______
____________m
- 21 1
A well, we used to call it no name creek and 2
it went into Clay Creek.
3 0
And it went'into Clay Creek.
And eventually 4
the water wound up in Clay Creek?
5 A
Hadselville Creek and --
6 0
But it eventually wound up in some creek near 7
the plant, is that correct?
8 A
Yes.
9 0
were you involved in that activity at all in 4
10 the transferring of water from the DRCST tank, to the REUT 11 tanks, and then the release to the basins, and then even-12 tually out to a creek near the site?
13 A
Ye s.
14 0
And what was your involvement in that 15 activity?
16 A
Well, we would sample the DRCST, look at its I
17 tritium concentration, and then we would recommend the 18 amount of water to be transferred to the regen holdup tank 19 for dilution, and then we would resample the regen holdup 20 tank to make sure we wouldn' t exceed 10 CFR 20 tritium 4
i 21 limits and then we would treat it from that.
fl 12 0
Were you yourself involved in the sampling 23 of the DRCST tank for tritium levels?
I, 14 A
- was the supervisor, or.e of the supervisors, !
i, 35 yes.
s
---.----.s
- e n
l 1
0 And was that routinely done before water'was 2
transferred to the RHUT tank that you or your people' would 3
sample it for tritium levels, was that a routine --
t 4
A Not as a routine.
It was a scheduled sanele 1
5 on a routine basis, you know, we would look at the chemistry 6
of the tank, and we'd do a tritium activity on it also.
7 0
Was this done on some type of a time basis, 8
once a day, once a week, once a month?
9 A
Well, I -- we would do it like once a week, 10 but. I think some of the samples, don't quote me, you were 11 anyway, on a monthly basis, okay.
12 0
okay.
But you did -- when water was to be 13 transferred f rom the DRCST tank to the RHUT tank, would you
^
14 go out and take a special monitoring of the DRCST tank just 15 for that transfer?
16 A
No, no.
17 0
Okay.
So basically, it was a routine monitor-18 ing that was going on?
)9 A
Right.
20 0
And what type of monitoring would you do at 21 the RHUT tanks, you were, or you-directed -- I presume 22 you dt.rected your subordinates to go do the --
13 A
WL11, when it's p.roceduralized, but we would 24 sample the reger, hold tank fer ehemical constituents, plus 25 tritium and ganuta activity.
_____m- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ -. _. _ _ _ - _ _. _ _ _ _ _ _ _
w 23-i j.
1 0
And was there.some type.of a requirement.tha't 2
the water had te meet prior to being released?
3 A
Yes.
4 O
And what was that requirement?
5 A
The requirement for whichever one you want 'to f
6 talk about?
7 Q
Well, you.can tell me about both ' of them.
8 A
Well, we had to meet our tech specs.
9 0
That's what I'm asking, what are the tech
'I 10 specs.
11 A.
Technical specifications, and at the time 12 you know, it was 5 E minus 7 microcuries per cc sensitivity.
13 0
Okay.
You got that, microcuries per ce?
1
-14 A
11111, cc.
15 0
Okay.
So it. was five times ten to the minus 16 severth microcuries per cc?
17 A
Yes, or mill.
18 0
Or mill, okay.
And that was the requirement 19 for what, or the tech spec for what?
20 A
Gamma activity.
It O
In which tank?
)
\\
22 A
P.elease to the environment.
23 O
Okay.
So if you had that concentration or 24 lower, you could release, is that correct?
25 A
tJo, I didn't say that.
f I
24 1
0 Okay.
2 A
We have to also report any observable actitit'.
3 vould be an easy way to say it.
4 0
Okay.
Well, why don't you explain to me what 5
you would have to meet to do a release, in order to 6
release to the environment?
7 A
Chemically, or radioactive-wise?
8 0
Radioactive-wise first.
9 A
Okay.
We would sample the tank.
We would 10 run a tritium analysis, and a -- what we call a gamma scan, 11 it's a radio isotopic analysis on the water, okay.
And 12 then we review the data, and if it met the sensitivity 13 requirements, we'd report that.
14 0
What sensitivity requirement are we talking 15 about?
4 16 A
Well, we're talking environmental release of 1
17 the technical specifications, five, ten minus seventh, I
}
18 microcuries per mil.
i 19 0
Okay.
So that would be for tritium, right?
20 A
No, that's fvor the gamma activity.
21 0
That's for gamma activity?
12 A
Right.
23 0
Okay.
And is there a separate test that was 24 done for tritium, or does that test include -- the test you 25 just quoted include tritium?
l
25 i
1 A
No, it's a different analysis,'it's a liquid 2
similation analysis.
3 0
.And after you did that anlaysis, I presune you 4
came up with a number, is that correct?
5 A
Yes.
6 O
And what are the units of that number?
7 A
It's microcuries per mil.
8 Q
It's microcuries per mil also.
And what is 9
the tech spec requirement for release?
10 A
If I'm not mistaken, it's one times ten minus 11 five microcuries per mil.
12 Q
Okay.
All right.
Now, how about in the DRCST-13 tank, you monitored that tank periodically also?
14 A
Yes.
15 Q
And is there any technical specification as
-16 to what the radioactivity ceiling is for water in that tank?l 1
17 A
No.
i 18 O
So water in there can be highly radioactive 19 without causing any technical specification violation?
20 A
By our present tech specs, that's right.
{
21 Q
And was that also the case in the 1984 and 12 1985 time frame?
23 A
The water in that tank was never really high, 24 if you want to term the word high, you know, it had tritium 25 in it, but very little of anything else.
l i
i a_____-________.
26-1.
Q Okay.
What management controls do you-2 utilize to assure that water transferred from the DRCST I'
to the RHUT tanks was procerly sampled for radioactivity?
4 A
would you please try and clarify that, or 5
repeat it anyway.
6 0
Did you utilize any management controls as a 7
supervisor to assure that water which was transferred from 8
the DRCST tank to the RHUT tanks was properly sampled for 9
radioactivity?
10 A
The DRCST was sampled.
11 0
But the water was sampled.
Okay.
12 A
Other than on our routine analysis, or maybe 13 a random sample to see what was there, but --
14 0
Okay.
That gets back into the question I 15 asked. earlier, was it normal for you to sample that water, 16 just specifically to pung it to the RHUT tanks?
17 A
No, it's not normal.
II Q
Okay.
Explain to me what happens when you 19 pump water from the DRCST tanks to the RHUT tanks, okay, 20 the incoming water has some amount of radioactivity, which 21 I presume varies, is that correct, the amount of radio-l l
12 activity varies?
23 A
Yeah, it varies.
24 Q
And by what process is that radioactivity-25 lowered to the five times ten to the minus seventh value?
f
27 1
A Well, typically, we dealt with tritium, and 2
that's what we dealt with.
3 0
And how would you go about lowering ~the 4
concentration if it was too high?
!!ow would y,ou make the l'
5 water relcasable?
6 A
Excuse me.
Typically we would have an empty 7
regenerate holding tank and transfer 10,000 gallons of 8
tritia water over and fill it with plant waste.
9 Q
So the method of making the water acceptable 10 for release was to dilute it with other water?
l 11 A
Sure.
[
12 Q
Referring to Special Report 84-07 that we've 13 discussed be fore, and there are some action items here 14 that are attached to the report, okay, in the near-term i
15 corrective actions, there is action item number seven, 16 would you take a look at that please?
17 A
All right.
Okay.
18 0
okay.
Could you read that action item into 19 the record for me please?
l 20 A
Sure.
" Administrative policy to control Il releases such that monthly calculated dose is under 12 technical specifications 3.17. 2 to limits. "
23 0
What does that statement mean to you?
14 A
I'd have to see what 3.17.2'is.
25 0
I think I have it here.
L 2E 1
A-Convenient.
2 0
3.17.
3 A
2.
4 0
2.
The re is 3.17.2.
5 A
Okay.
6 Q
Let the record reflect that Mr. Wilson is 7
reviewing the pertinent techn.ical specification.
8 (Pause to review document. )
9 A
Okay.
10 Q
so what does action item seven mean to you
-11 now that you've reviewed that?
12 A
It means that we're not supposed to dose the 13 public with liquid ef fluents.
14 0
Which means that you're not supposed to 15 release any radioactive liquid effluents, is that'what it
-16 means?
17 A
It doesn't say that.
18 Q
Okay.
What does it say, then, can you 19 clarify that?
20 A
It says you will restrict liquid effluent
]
l' 21 releases, that you will not exceed those limits.
I think 12 it says that, anyway.
Well, you won't exceed released 23 limits, right.
24 Q
Okay.
Which release limits are you not to 25 exceed?
-a
l 29 1
1 A
Well, from the site.
)
-2 O
No, I mean the value, is there some value
+
3 assigned to that.in micro -
whatever --
4 A
It's in millirems, yes, it's one and a half 5
for total body, and five milliren to any organ for any.
6 given gallon to a quart.
7 0
one and a half to'a total body?
8 A
one and'a half millirem to a total body.
9 Q
How does that statement there intertie to 10 the releases coming from the RHUT tank, can you explain 11 that?
12 A
The regen holdup tank is considered the 13 release - point f rom that side.
14 Q
So consequently, is this policy stating that 15 the releases will be controlled such that you will 'not 16 exceed certain millirem readings, wt..le-body and dose rates, 17 is that what that is telling us?
18 A
It inplies that, yes.
19 Q
Do you know what actions were taken such 20 that action item number seven was complied with?
Was any 21 special action taken to make sure that this occurred as i
12 stated?
L f
23 A
At that time frame, it was only after the fact:.
i 24 0
What do you mean by that?
25 A
Well, we would submit all of our analysis to l l
..L_L__-____-_-_.-____
j 30 l
I 1
a different group and they would re-'iew it and come up with 2
a dose calculation.
A O
And by doing that, and they came out with a l
4 dose calculation, then is that what you mean byEafter the i:
5 f act, that it was calculated af ter the f act, that you 6
wouldn't know when you were doing the releases what was 7
going to transpire?
8 A
Right, yes.
9 (Off the record for interruption at door.)
10 0
okay.
So consequently, just so I understand 11 this for myself, because I'm trying to understand this, the 12 action plan set forth there in item number seven was J
13 basically sonething that was not controlled by management 14 as it was ongoing, it was sonething that was calculated at 15 a later point in time, is that correct?
16 A
Well, it was ongoing, because that is done l
17 monthly.
18 0
Oh, so consequently, this dose calculation 19 is done on a monthly basis, so you know every 30 days how 20 close you are to let's say exceeding whatever limits are
]
21 set there, is that true?
J 12 A
I didn't say I knew, I said it was done.
23 0
okay.
Somebody in the Sacramento Municipal-Uti'ity District knows, is that correct, from the dose rater 24 J
25 A
I would hope so, yes.
j 1
1
31 1
O Okay.
Do you happen to know who that '
1 H
2 individual would be?
3' A
At'the time it'was Ed Bradley, our environ-4 mental person.
5 0
That was the responsibilities of'his position,.
6 is that correct?
i 7
A Yes.
To my knowledge, anyway.
3 0
To the best of your knowledge.
9 A
Yes.
to O
To the best of your knowledge, were the 11 technical specifications set forth in action item number 12 seven there, were they ever exceeded?
13 A
At this time, not that I'm aware of, no.
14 0
Not that you' re aware of.
How about a 15 subsequent time?
l 1.
Yeah, they -- we were told that we could have j.,
16 A
i 17 exceeded them, or -- I'm not definite on that.
.13 0
What knowledge do you have about exceeding.
19 them, was that somebody told you that that had occurred, 20 or possibly had occurred, or --
21 A
Yeah, it was possibly that it had occurred, 22 which is why this is here.
23 0
By this, you mean this interview, is that 24 correct?
2$
A Yes.
_ _ ~ _. _ _. _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _. _ _ _
12 1
Q And what knowledge do you have, can you 2
explain to me about that exceeding of the limit?
1 L
3 A
I wasn't that much involved with it, but 4
fall of '85 we were told that we could have a,possible 5'
dose, you know, exceeding the dose, that's when we were j
6 first aware of it, that's my knowledge, anyway, of it.
7 O
So that you were told by whom, can you recall?
8 A
It would be a guess, you know, but I don't 9
know, I don't remember if Ed Bradley told me or not.
It
_10 was just there.
11 Q
Okay.
Somebody, possibly Ed Bradley, okay,.
12 told you that --
13 A
I won't swear to Ed Bradley, 14 Q
Okay.
Well, that's what I said, possibly 15 Ed Bradley told you that the dose rates as set forth in 16 technical speci fications had.possibly been exceeded, is 17 that correct?
18 A
Well, more than likely, it was probably 19 Fred Kellie.
20 0
Okay.
Fred Kellie.
Okay.
So let's just
. 2.
21 say that somebody told you that they would possibly exceed 22 it, is that the terminology that was used?
23 A
That was what.was said.
24 Q
And --
4 A
But I didn't see anything in writing.
33 1
0 Did that cause you any alarm when you found 2
that out, or --
's A
Yeah, it bothered me, we have tech specs to 4
meet, and we weren't aware of what's going on, that's sort l
5 of hard to deal with.
6 0
And were you told why the tech specs were 7
possibly exceeded, is it explained to you as to what could 8
have. transpired to -- you know, to cause this to occur?
9 A
Well, from what I can recall, the computer 10 codes that we're using weren' t up to snuff, if you'll.
11 accept that, there was some questions about the computer 12 they were using, the code they were using.
Then it was 13 also said that a few people were changing the code that I 14 was unaware of.
15 0
What do you mean by changing the code?
16 A
Well, they were making entries.
I don't know 17 the full extent of that.
It's just that we had student i
3 18 engineers that would enter the data on the computer code, 19 but somebody said that they were changing a few of the 20 idoscyncracies of the machine or I don't know how you'd 21 want to call it, but that's what I was -- you know, it 12 could be rumor too, but that's what I was told.
l 23 0
Well, what kind of data would they be 24 changing?
25 A
That I don't know.
All they were supposed to
F 34 o
I do was enter the data.
2 Q
And' what kind of data is this? ~
3 A
It's the sample analysis results.
4 0
That's done by your group?
5 A
Yes.
6 0
And that' would lxa what, the entering of some 7
values?
3 A
Yeah, the activities that were involved with 9-the regen holdup tank samples.
}
10 0
okay.
So a sample would be taken of the RHUT 11 tank and would be analyzed, and it would produce a certaini 12 numerical answer, is that correct?
13 A
Yes.
.l 14 O
And that that numerical answer would then be I
15 placed into some type of a computer program?
f 16 A
Right.
That along -- and with the tank 17 volures, discharge volumes of the water going up the back.
18 Q
And that would then do some type of a 19 calculation, I pres ume.
I 20 A
Yes.
21 O
And would give an answer.
And what was the 22 meaning of that answer?
23 A
It's a dose attributed to that result.
l 24 0,
Okay.
So therefore, the answer that comes 25 out is in the units for the answer are rems or millirems.
i
__.-__-.______m_._--___
35 i
1:
'I 1
A Millirems more than likely.
i l
io 2
O Yes.
Okay.
So you heard that there were 13 some student engineers that ware manipulating --
4 A
Well,.I'm not saying it was rumored, you know.
5 Q.
Well, rumor, there was rumor that they were 6
what, manipulating the numbers being inputted, or the 7
calculational techniques, or what?
8 A
I don't know.
I don't think they could 9
manipulate the. numbers they were given by us, okay.
10 Q
But these people were acting in the capacity 11 of dati entry people?
12 A
Yes.
13' O
They were not acting in the capacity of 14 people that came up with the numbers, individuals that 15 got the original number?
16 A
Which number?
17 Q
The test result number.
18 A
No, the test results we did.
19 0
Okay.
You did, so they were not -- you and 20 your people created a -- did a test and got a final number, 21 and then you gave that number to somebody else that then I
22 inputted that into a computer system.
23 A
Yes.
24 Q
Okay.
So to the best of your knowledge, 25 nobody altered or changed the number that your people
36~
I I
1 created, you or'your subordinates created?
2 A
.Not that uas submitted for this, no.
1 3
O So the only problem that could have occurred, i i
4 then, was basically the way the data was. inputted, rather 5'
than the data 1itself, is that correct?
6 A
That's a possibility.
7 0
Well, the' point I'm trying to get to ' --
8 A
Like I say, it was rumors.
9 0
That's what I mean.
I understand that,.but 10 I'm trying to get to what the rumor was about.
Do you have 11 any reason to believe that the numbers generated'by you 12 or your subordinates were later altered for any reason?
13 A
Ch, no.
14 0
Okay.
So you have no suspicions that your 15 data was altered?
16 A
No.
17 0
Okay.
Did you have any responsibilities to 18 assure that Action Item #7 was implemented in conjunction 19 with the commitment made in Special Report 84-07?
20 A
No.
21 0
You didn't have any responsibilities in those 22 areas?
l i
23 A
Well, I'm sure if we had a procedure that 24 dictated what we should do, but that was my resp onsibility.
25 o
Okay.
Can you recall having any responsibility-J 1
r 37 1
involving making sure that Action Iten. #7 was implemented
.)
o 2
correctly?
1 J
3 A
No.
,l 4
0 You can't remember that?
5 A
I didn't -- not that I'm aware.of.
i 6
0 Okay.
That same report, 84-07, could you 7
please read Action Item # 87 8
A Okay.
9 Q
Let the record reflect that Mr. Wilson is 10 reviewing the document in question.
11 A
Processing of the PDS or the RHUT back to the 12 rad waste system in case activity is too high to release.
i 13 O
The PDS?
14 A
Is the polishing domineralizer sump.
15 0
Thank you.
So consequention, Action 8 of the 16 near-term corrective actions of the Report 84-07 states 17 that the processing of water from the PDS and RHUTs to the 18 rad waste sys tem, coupled with the dilution of the ' liquids 19 will help ensure compliance with the limits of radioactivity 4
20 released in the liquid effluents.
Is that basically, is 21 that what it says?
22 A
Where are you reading that?
23 0
Well, we're just summarizing it is what 24 we're saying.
25 A
Yes, yes.
I I
l
30 1
0 Okay.
Can you explain to me what is meant 2
by dilution of the liquids, what did that term mean?
3 A
In respect to this #8?
4 0
Ye ah, in respect to #8.
5 A
I don't think it applies, if I pump it back 6
the rad waste system, I'm processing it in-plant, I'm not 7
diluting that activity, I'm processing that activity in a 8
different system.
I mean, it is diluted in that system.
9 O
Let's go to a different page here.
Okay, this 10 explains the action items a little bit better, okay.
This is page 3 of the attachment to Special Report 84-07.
Can' 11 12 you read Action #8 there, it states a little bit more.
13 A
Okay.
Action #8, the district has -- no, 14 tha t 's #7.
"The district has implemented a program that 15 permits the PDS or RHUTs to be processed back to the rad 16 waste system to provide a reduction in the amount of 17 activity released.
This option can be exercised at the 18 option of the chemistry and rad protection personnel.
This 1
19 method, coupled with dilution of the liquids will help 20 ensure that any liquid waste released meets'the objective 21 of the program."
Okay.
22 O
Now that we have the statement dilution of 25 the liquids, what does that terminology mean to you?
24 A
In the context of that statement, I don't 25 know, because it doesn't apply, you know.
L___n____.__________.__
[
39 i
1 0
Well, where do you'think dilution of the 2
liquids would apply.in the plant?
3 A
Typically after the water is processed, it 4 -
goes back out to -the DRCST and then if'we transfer it to 5-the regen holdup tank then it's diluted.
6 O
And what is the purpose of the dilution?
7 A
So you won't exceed 10 CFR 20 release' limits._ l the-purpose of the dilution is l 8
0 okay.
So that i
9 to lower the concentration of radioactivity,-is that 10 basically true?
11 A
'Yes.
12
'O Okay.
A little while ago you reviewed 13 Technical Specification 3.17.1.
14 A
2.
15 0
2, okay.
Could you review 3.17.1 for me 16 please?
17 A
Sure.
'18 0
And after that, you'll find attached to this 19 same document that I have here, Technical Specification
.i i
1 20 4.21.1 if you could take a look at those please?
21 A
All right.
22 0
Let the record reflect that Mr. Wilson is 23 reviewing the documents in question.
24
.(Pause to review documents. )
25 Q
Now that you've reviewed those two technical 1
_=_:_______-____
40 L
1 specifications, is it true that those technical specifica-2' tions state that the specifications do not assure' compliance 3
with 10 CFR 50, Appendix I, dose objectives?
4-A They do not assure it?
5 0
They do not assure.
6 A
Well, it states here, that you know,Lwill not 7
resolve exposures with the design objectives of 10 CFR 50 8
to an individual, and 10 CFR 20 to the population.
9 0
I'm talking about 10 CFR 50, Appendix I, is 10 that mentioned there?
11 A
No.
Yes,'it is.
Yes, it is.
A design 12 objective of Appendix I, 10 CFR 50 is mentioned.
13 O
And what does it say about it?
14' A
It says that this limitation provides 15 additional assurance that the levels of radioactive 16 materials in the bodies of water outside the site will not 17 result in exposures within that limit, as long as we meet 18 10 CFR 20.
19 O
So the refore, is it your opinion that these 20 technical specifications assure compliance with the dose 21 objectives of 10 CFR 50, Appendix I?
12 A
That's what it says to me.
l4 13 0
Well, I just read it.
24 A
Okay.
In approximately October of 1985, and 15 specifically October 29th of 1985, Ed Bradley issued a a
l i
41 1
draft lower limits of detection study.
Are you familiar 2
with that document at all?
3 A
Not really.
4 O
The information that I have is that the draft 5
study indicated that Rancho' Seco's technical specification 6
on lower limits of detection,. commonly - known as LLD --
7 A
Okay.
8 0
-- was not sufficient to assure compliance 9
with the dose objectives of 10 CFR 50, Appendix I.
Can 10 you recall Ed Bradley doing such a draft report?
11 A
I know that he did one.
12 0
You know that he did one.
Did you ever 13 review that draft report?
14 A
No.
15 O
Did you ever _ review the final report that 16 was issued later on?
17 A
Not that I recall, no.
18 Q
Not that you recall.-
Did you take any action 19 concerning Bradley's concern about the LLDs?
20 A
I didn't, no.
21 0
Do you know of anybody who did take any actic:
22 concerning those concerns that Bradley had?
23 A
We were concerned, yes, because of that 24 report, but at that time, I didn't take any action myself..
25 0
so the draf t report written by Bradley did nc '
1.
__________.______._._______a
42 1-result'of you changing the mode of operation of you or your 2
subordinates, is that correct?
3 A
It did from the f ac t that we had to look at 4
what we could do to lower those LLD's.
5 0
Yeah, but I'm talking about October of 1985 6
now, did you take'any action around October of 1985 i
7 concerning what Bradley did, his work, or was that action 8
taken at some later point in time?
l 9
A I think it was taken at a later point in time.!
10 0
And can you recall what action was taken at l
l 11 a later point in time, and at what point in time that i
12 action was taken?
13 A
Specific time frames, I can't answer it, but i
14 we had to look at what our system capabilities were to
[
15 see if we could reduce that LLD.
16 Q
And by reduce the LLD, you mean that you want 17 to make the LLD lower, or more sensitive?
18 A
More sensitive, yes.
i 19 0
Okay.
And so at some point in time that you 20 can't recall --
21 A
Well, it had to be in the general time frame, 22 but --
23 O'
Well, in -- let's just say in the general i
24 time frame of October 1985, you were involved in taking some 25 action to lower the LLD value, is that correct?
l
- r l
l 43 i
1 A
To see what our system capabilities were, yes.
2 Q
And what were the results of your doing that?
'3 A
It would be very difficult to do with wha:
4 equipment we had.
I mean, we looked at differ,ent techniques, 5
you know, increasing count times,-we looked at larger 6
samples, but that obf uscates everything because it doesn't L
7 do you much-good beyond a certain size, and.we looked at 8
the chenical separati ons.
I 9
Q.
So at the time that Bradley's report was 10 issued, or his concerns came forth, whatever you'd like 11 to call it, what was your LLD.at that time,-can you recall?.
12 A
well, that would depend on the length of timej j.-
13
_you counted the sample, particularly the method of five c.
14 times ten minus seventh, tech spec limit.
15 0
And that was using what count time?
16 A
Either one or 2,000 seconds.
i 17 0
Was the re a point in - time when you we re using t 18 the count time of 2,000 seconds in doing your work?
19 A
Yes.
20 0
And at some other point in time, later on, 21 did you change that to 1,000 second count time, or was it 12 changed?
23 A
It was changed to the 1,000 seconds, yeah.
24 O
Do you recall why the count time was changed?
25 A
A leaded question, I could hardly know the
___._____m._._-_
m______._-_-_
.m
F 44 l
1 1
answer.
I' m sorry.
Initially it was chanced because we 2
could meet the tech spec LLD of Le minus seventh, 1,000 l
3 seconds.
4 THE REPORTER:
What's that term, five minus i
5 e.--
6~
THE WITNESS:
I'm sorry, five times ten minus 7
seventh.
I 8
BY MR. JOUKOFF:
9 O
So consequently, although at one point in to time you were using a 2,000 second count time to obtain an 11 LLD of five times ten to the.minus seventh, it is.your 12 opinion that that same LLD value could be maintained even 13
'though the count time was-changed to 1,000 seconds?
14 A
Yes.
15 0
And you still maintain that today, that that's; 16 true?
17 A
Yes.
18 O
So along the sane lines, did you direct that' 19 the count time be changed from 2,000 seconds to 1,000 20 seconds?
21 A
I don't think I did.
You know, there's a l
22 lot of people out there, you know.
23 0
Well, let's go back, to the best of your 24 recollection, did you --
25 A
okay.
To the best of my recollection, no I I
1-E_________
t 45 1
did not direct that.
2 0
To the best of your recollection, who 'did 3
direct'it?
4 A
Well, Fred Kellie.
5 0
And why do you.think Mr. Kellie would change-6 the count time?
f 7
A Because we could neet the same count, or.same-3 LLD, okay.
p Q
While counting for a shorter period of time to A
While counting for a shorter period of' time 11 and comply with 10 CFR 20.
12 0
Is there some activity that occurred that 13 resulted in the count time being changed, or why would the 14 count time change at that point in time?
15 A
Well, I know we were processing water, you 16 know regen holdup tanks and whatever else.
17 Q
But you were always doing that, weren't you?
13 A
Well, yeah, we always process water.
19 Q
Okay.
So, since you were processing water, 20 and you have processed water for a long time, why would, at 21 that point in time, Mr. Kellie decide to change the count 12 time?
23 A
I'm trying to think of a way to answer it.
24 0
Well, just --
25 A
I know -- but see, I wasn't involved with it
46 I
that much.
I nean, I was aware of it, even though I'm 2
supposed to be aware of it, other things were happening too, 3
but I heard that there was background fluctuations, there 4
was activity in the water, okay, and we were,- he counted-5 it for 1,000 seconds-and --
6
.THE REPORTER:
Deco unt?
7 THE WITNESS:
I'm sorry, the water, he counted.
8 it for 1,000 seconds, and then what activity was there 9
initially was not there the second time.
10 BY MR. JOUKOTF:
11 0
So consequently, did you observe him counting 12 the water for 1,000 seconds or --
13 A'
Oh, no, he doesn't.
14 0
Or did he tell you he counted it?-
'15 A
No.
He's my boss, he doesn't count the 16
' water, okay.
17 0
Did he direct that somebody count the water 18 for 1,000 seconds, rather than 2,000 seconds?
l-19 A
Yes.
i 20 0
And who did he direct to do that?
21 A
well, the lab techs, of course.
22 Q
Do you know specifically which lab _ tech?
23 A
No.
24 0
Or just one of the lab techs?
25 A
No, I don't know which one.
L__
47-
-- I
.O Okay.
So onetof the lab techs 2-A Yeah.
3 0
And those lab techs were under.his directien, 4
is that correct?
5-A well, they were under my direction too.
6 O.
So consequently the. chain of command, so to 7
speak, would be the lab techs reported to you and then you 8
reported to Kellie, is that correct?
9 A
Yes.
q 10 0
So being in that chain, you know that Kellie 11 had one of the lab techs count for 1,000. seconds instead 12 of 2,000 seconds?
13 A
Well, I wasn't a physical witness, you know, 14 I was just aware that it had happened.
15 0
okay.
You were' aware that that had happened.
-16 And after that was done, Mr. Kellie directed that the count 17 time be changed from 2,000 seconds to 1,000 seconds, is thatL.
18 correct?
19 A
Yeah.
Of course, I was involved with it too, j
20 I rean, I'm not evading the issue.
21 O
Okay.
Well, how were you involved in it too?
22 A
well, like I say, I'm one of the supervisors, 23 you know.
24 0
Ye ah, but so f ar, I haven't heard you being 25 involved.
All I've heard is Kellie told one of the lab
V 4B I,
1 techs to count for 1,000 instead of 2,000, end then later 2
on, you heard that it was changed to 1,0007 I-A.
Well, I was there, not physically, but I was 4
on the premise s, and we talked about what we were doing, 5
and we ' re not ' exceeding 10 CFR 20, you know, and that's I
6 our doctrine, you know.
7 0
How about 10.CFR 50, Appendix I?
j 8
A That I didn't think about.
9 0
was there some reason that you didn't think 10 about that?
11 A
No, not really, it wasn't there.
12 0
I beg your pardon?
13 A
It wasn't there, you know, I-go with the tech 14 specs, 10 CFR 20, you know, that's what'we live by.
I know 15 10 CFR 50 is in there, but it says if I meet 10 CFR 20, I'm 16 okay.
17 0
So your reading of the tech specs if you can 18 meet the requirements of 10 CFR 20, that you're also meeting 19 the requirements of 10 CFR 50, Appendix I, is that your 20 interpretation?
21 A
yeah.
12 O
That was your interpretation at that point in 25 time?
24 A
.yes, 25 0
And is that still your interpretation today?
s 49' 1
1 A
Not now.
I
+
2 O
What.is your interpretation now?
{
3 A
We have to meet 10 CFR 50.
l.
4 O
Appendix I?-
I 5
A Appendix I.
}
6 Q
And what's the difference between those two l
l 7
standards?
8 A
One is a release limit, MPC calculation.
9 Q
And which one is that?
10 A
11 O
And MCP means what?
12 A
Maximum permissible concentration, and 13 Appendix I, 10 CFR 50, is dose to the individual and the 14 public.
i 15 0
Why was it that in 1985 you weren't aware i
16 that there was a difference between these two standards, 17' although SMUD was committed to both of them?
18 A
Well, as I nentioned earlier, we weren't 19 involved with the dose calculations.
Okay.
My forte, if 20 you want to call it, was sampling and releasing water 21 within the limits of 10 CFR 20.
12 O
And what procedures, or directions were you 23 given to do these water releases?
14 A
By administrative procedures.
25 0
And those administrative procedures were what?
E
50 1
Tell me, what this --
2 A
Ch, I'm sorry, it's samoling of the systems 8
and releasing of the system.
4 0
Okay.' But that's done to some t,ype of a 5
standard, is that' correct?
I mean, you have to work to 6
something, something tells you how to do this, that 7
activity, doesn't it, sore written document tells you how 8
to do that activity, does.it not?
9 A
Our procedures.
10 0
Okay.
And what did your procedures tell you II, were allowable releases?
14 A
MPC calculations.
II O
Which tie s to --
14 A
15 0
Okay.
And so therefore,.if I'm to understand
- 16 this correctly, at - that. point in time, the 1985 time frame, 17 your procedures told you to meet 10 CFR Part 20, and were 10 they -- were the procedures quiet on Appendix I requirement.
19 A
Yes.
20 0
so to the best of your recollection, Appendix 21 I requirements were not in the procedures, is that correct?
22 What I'm trying to get to is why --
28 A
They weren't addressed in the procedures we 24 used to release.
25 0
That's exactly what I'm getting to.
I mean O
e f?
51 1
as the supervisor in charge of this release of water going 3
2 off-site, what caused your employer, SMUD, to.be committed 3
to 10 CFR 50, Appendix I, and you and your subordinates 4
doi- " 'he work, why were they not aware of that?
Why~were 5
you working to 10 CFR Part 20?
j 6
A I can't give you a good answer.
I know that
- 7 after a release, you know, we would send the data to the l
3 environmental group, and they would do the dose calculations.
i 9
I'm well aware of that, you know, that's just flow path of to information.
i gg Q
If I aanted.to review the procedures that you' r
worked to when you did these releases, okay, where would I 12 33 find those?
Are those in a technical specification, or 14 are they --
15 A
No, they're in the administrative procedures 16 for our group.
17 Q
So let me just recap what we just discussed, 13 so that I have it clear.
In the October 1985 time frame, 19 you were working to sone administrative procedures that 20 were written down on paper, and that you and your group 21
. worked to those procedures, and followed them, is that 22 correct?
23
.A Yes.
24 Q
And those procedures told you and your 25 subordinates how to release water such that you were in
"-"---a-- - --_--___.___ _ _ _ _ _ _ _ _ _____ ___
52 1
L 1
compliance with 10 CFR Part 20, is that correct?
2 A
Yes.
f L
3-Q However, to the best of your recollection, i
4 you can't remember seeing 10 CFR, Appendix I, Part 50, i
}.
~
5
. Appendix I in those procedures?
l
^
t 6
A That's true.
f 7
O And so consequently, the procedures you'used 8
spoke to MPC, is that what you call it?
Maximum permissible 9
concentration?
10 A
Yes.
4 It O
Rather than to dose rates?
12 A
Yes.
13 0
okay.
And so consequently in the October, 14 1985 time f rame, you took no management actions involving 15 Bradley's concerns, is that correct?
16 A
It's difficult when you're not a manager.
17 O
Okay.
Well, as a supervisor, you didn't 18 take any supervisory action or change --
19 A
Well, I didn't know what the outcome was 20 going to be so I just have to wait.
t 21 Q
Okay.
And then Mr. Kellie at some point in.
12 time had the count time changed from 2,000 seconds to 23 1,000 seconds, and you said that he had one of the labora-24 tory assistances, what did you call them, was that what-15 you called them, a lab assistant or a lab tech?
l l
l
l-l.
L 53 i-I 1
A A lab tech.
l 2
Q A lab tech, that he had one of the lab techs 3
count a cample --
4 A
Well, like I. say, I wasn ' t the re, so --
this is to the best of you$-knowledge?
5 O.
But 6
A Yes.
7 O
To the best of your knowledge?
8 A
Yes.
9 0
Mr. Kellie had a lab tech count a sample for 10 1,000 seconds instead of 2,000 seconds, and that resulted I
1 11 in what difference?
You said there was something about --
12 A
Well, when you're talking with low levels i
13 of activity, background fluctuations, sometimes you'll see 14 an isotope, sometimes you won' t.
Okay.
15 0
And counting at 2,000 seconds, they saw l
16 something in there, in the results, and that by counting l
17 it to 1,000 seconds, instead of 2,000 seconds, they no 18 longer saw that, is that -- whatever it was they saw, is 19 that correct?
20 A
Yes.
II O
So consequently, Kellie had -- did Kellie 12 direct you to have your laboratory technicians change the.
23 count time to 1,000 seconds?
14 A
Well, like I said, we discussed meeting 10 15 CFR 20.
I
_.__m____
a____.______._.
54 l.
1 1
Q You and Kellie discussed'that?
+
L 2
A Well, you know, that goes -- my interpretation-3 as long as I met 10 CFR 20, I was doing nothing wrong.
4 0
Okay.
5 A
Okay.
And that's what we based it on, or 6
I based it on too, I had to satisfy myself.
7 O
Do you recall having a discussion with Kellie,
8 about changing the count time from 2,000 seconds to 1,000 9
seconds?
10 A
well, I know we talked about it.
11 Q
And af ter you talked about it, you concluded that the changing of the count time would not result in 12 13 a changing of the LLD, is that correct?
14 A
That's true.
15 0
And so consequently, aftcr you had discussions 16 he had discussions, af ter some discussions occurred, whateve 17 they may have been, he directed the count time was changed 18 from 2,000 seconds to 1,000 seconds, is that true?
19 A
Yeah.
20 0
And as a result of that, were any procedures 21 changed to change the count time from 2,000 seconds to 22 1,000 seconds?
23
.A I thought they were.
24 O
So consequently, the original count time of 25 2,000 seconds was proceduralized?
h-----------__m___._._._.________.__
55 l
1 A
Yes.
2 0
It was.
3 A
Well, I was under the impression it was just 4
a matter of habit, this is recent, not at that, time,.we 5
f ound one procedure that had.2,000 seconds in. it.
6 0
So consequently, that procedure would have r
7 to be enanged in order to count for 1,000 seconds instead j
L of 2,000 seconds, is that correct?
9 A
Yes.
10 0
Do you know if that procedure was changed?
11 A
No, it wasn' t.
12 0
You know it was?
13 A
No, it was not.
14 0
No, it was not changed.
15 A
Like I said, recently.
i 16 0
Okay.
Recently being when?
{
l 17 A
Within the past month or two.
18 0
Within the past month or two it was changed, 19 but back in --
20 A
Well, it's changed, but not to 1,000 seconds.
You've got to realize, this happened a long time ago, and i
21 22 this is now, we changed it to 4,000 now.
Oh, so it was 2,000 until sometime in late 23 0
i l
24 1986, early 1987, and then it was changed to 4,000, is that 25 correct?
.l t
s
H 1
A
- Well,
'87.
2 O
Okay, it was done in 1987?
3 A
Well, by administrative decree, we were 4
counting everything for 4,000, but now we're revamping all 5
our procedures, and that's being addressed in that now.
6 Q
Okay.
But prior to it-being changed in 1987, 7
what did the procedure read,- count for 2,000 seconds?
8 A
Yes.
9 0
And that procedure goes back how f ar in time, 10 do you know?
11 A
I would say a long time.
12 0
Okay.
Does it at least go l>ack to the 13 beginning of 1985?
14 A
Yes.
15 0
So consequently, in '1985, to the best of your 16 knowledge, the procedure stated to count for 2,000 seconds, 17 is that correct?
18 A
Yes.
19 0
And during that same time frame, laboratory 20 technicians under your supervision were counting for 1,000 21 seconds, is that correct?
12 A
Yeah.
You must realize that 'there's a lot of 23 P rocedures.
24 Q
Oh, no, I realize that, I'm just trying to 15 get the --
t
- - - ~ - - - _ _ -. - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
57 1
1 A
I know.
6 2
0 You have to understand that I have to get i
3 these facts, okay.
4 A
Yes, I'm aware of that.
I 5
0 And I understand there are a lot of proceduresj, I
6 and I just have to know if that happened or not, and did it 7
happen?
3 A
To the best of my knowledge, that's what' 9
happened.
10 0
And to the best of your knowledge, this.was 11 done at Kellie's direction, is that correct?
12-A Yes.
I 13 0
okay.
14 A
But you have my concurrence, too, because of 15 what we discussed with 10 CFR 20.
16 0
Well, I -- okay.
We can add that to the l
17 record, that you concurred in changing the count times, j
18 because in your opinion, the LLD was not changed by changing, 19 the count time, is that correct?
2)
A Tha t's true.
21 0
okay.
Do you know if any members of i
Kellie?
Who 12 supervision and/or management higher than Mr.
13 was Mr. Kellie's direct boss?
14 A
At that time, I'm pretty sure it was George 15 Coward.
58 i
.1 O
At that time it was George Coward.
2 A
Yes.
3 O
Do you know if George Coward directed that 4
.the count time be changed?
5 A
Not that I know of.
6 Q
Do you know if Mr. Coward was even involved 7
in the discussions regarding count time?
8 A
Not that I'm aware of.
9 MR. JOUKOFF:
The time is now 2:35, we'll be 10 going off the record for a break.
11 (Brief recess.)
.3 12 MR. JOUKOFF:
The time is now 2:45 p.m.,
13 we'll be going back on the record after having a break.
14 BY fir. JOUKOFF:
can you recall when the LLD issue l
~
l 15 0
Mr. Wilson, 16 raised by Bradley came to your attention?
17 A
Around October of '85.
18 Q
To the best of your knowledge?
19 A
To the best of my knowledge.
20 0
At that point in. time, did you take any 21 action to assure that the lowering of the count time un 22 the RHUT samples, together with the LLD issue would not 23 impact on Rancho Seco's ability to conform to 10 CFR 50, 24
. Appendix I requirements?
15 A
Not 10 CFR 50, no.
" - - - _ _ - -. ~. _ _. - _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _, _
P 59 t
1 Q
And is that because you were under the 2
impression that you were working to 10 CFR 20?
3 A
Yeah.
We made sure that our system would mee.
4 the five tines ten minus seventh LLD limit, te,ch spec.
5 0
And did Bradley's issues coming forth in 6
October '85, did that cause you to change any of your.
7 operation, or did you feel that your operation was in 8
compliance with --
9 A
I changed the operation.
10 0
It didn't cause you to do anything dif ferent?
11 A
No, not that I can recall.
12 Q
Okay.
Are you familiar with a name -- a 13 gentleman by the name of Greg Yuhas?
14 A
Yes.
15 0
He's a member of the Nuclear Regulatory 16 Commission?
17 A
Region V, yes.
18 0
You know who Mr. Yuhas is?
19 A
Yes.
20 0
Are you familiar with a conversation that Mr.
21 Yuhas and Mr. Kellie had regarding the identifying --.or 22 identification of peaks of radioactivity to assure that 23 such peaks in a sample we,re reported?
Do you have any 1
1 l
24 idea what I'm talking about?
l 25 A
Not really.
E I
o
m.
60 t
1 MR. JOUKOFF:
The time is now 2:48.
We'll be 2
going off the record so I can obtain a document.
3 (Off the record.)
4 MR. JOUKOFF:
The time is now 2:56 p.m.,
5 we'll be going back on the record.
6 BY MR. JOUKOFF:
7 o
Mr. Wilson, I'd like to show you a telephone 3
conversation record between a Mr. Fred Kellie, and Greg 9
Yuhas of the t. lear Regulatory Commission.
Could you 10 review this document please?
+
11 A
Okay.
12 (Pause to review dccunent. )
13 A
Okay.
14 Q
Do you know what this telephone record 15 pertains to?
16 A
I've got a good indication, yes.
17 Q
And what would that be?
18 A
That activity was seen in-the regen holdup 19 tanks and wasn't reported.
20 0
And does that also mean that Mr. Yuhas gave 21 Mr. Kellie some type of direction about reporting, and the 22 deportability of certain samples, and what was being seen 13 when those samples were being analyzed?
24 A
Well, I talked to Mr. Yuhas too.
25 0
And what do you recall about this incident F
l-61 l
1
'with Mr. Yuhas?
2 A
He asked me if -.you know, we sarpled the 3
regen. holdup tank, and saw activity, we changed.the count 4
times and everything for those, yeah, we changed the count 5
times, but.under the auspices of 10 CFR 20, if.I met that, 6
I was doing nothing wrong.
7 0
Okay.
8 A
That's what I told him,.anyway.
9 Q
Okay.
And this telephone conversation I'm 10 reading from, it says, 'under resolution reached, if a nuclid-11 is below minimally. required LLD, five e to the minus seven,.
12 but is a positive value, it must be recorded and reported.
13 A
Okay.
14 Q
What does that sentence mean?
15 A
That means if we saw an isotope of less than 16 that value, we've got to report it on our annual report.
17 O
So just so that I understand this correctly, the requirement that you had to meet was five e to the.minus 18 19 seven, is that correct?
20 A
Yes.
21 Q
However, my understanding is that your instru-22 mentation was nore sensitive than five e to the minus sever..
23 A
Yes.
And under certain circumstances, is that 24 Q
25 correct?
62 1
A Yes.
2 Q
And consequently, at times, you could read a 3
value that was lower than five e to the minus seven, but 4
would not reach the sensitivity of your instrumentation, is 5
that correct?
6 A
Not really, you're -- let me paraphrase it a i
7 little bit.
I 8
Q Okay.
That would be fine.
9 A
Okay.
The machine would see less than five 1
10 times ten to the minus seventh.
11 Q
Right.
12 A
But typically, it reported a value of LLD of 13 less than five e minus seven, if that's an answer.
I don't 14 know if we're connecting or not.
15 0
I'm not sure that we are either.
If a particular sample that you ran had a concentration, or 16 17 whatever you would like to call it, of less than five e to 18 the minus seven --
19 A
All right.
q I
then it was releasable, is that correct?
j 20 0
i 23 Or it --
22 A
Well, it was releasable, yes.
1 23 Q
Okay.
It met the requirements, the NRC 24 requirements, isn't that true?
It met the NRC requirements i
l 25 for release if the sample was five e to the minus seven or f
1 o
~~
M
m_ _ _ _ _._ _ _, _ _ _, _ _ _ _ _ _ _ _ _ _ _ _ _
4 63 I'
I less.
2 A
Or it could be more.
3 0
And if it was more, then what would.haopen?
4 A
We'd still recort it.
He're not-connecting.
5 0
Okay.
Why don't you explain to ne how this 6
works, then maybe we'll connect.
7 A
Okay.
We analyze a' sample.
8 Q
Okay.
9 A
Okay, and if there's nothing there, we call 10 it LLD, another terminology is minimum detectable activity, Il MDA, okay.
If the reports generated that it's at LLD or 12 MDA, at less that five e minus seven, then it isn't there.
13 Now, you can analyze a sample and have it less than,five e 14 minus seven, but it would be a positive value, not MDA LLD.
15 Okay, then you report that too.
16 O
Is that what this document is talking about?
17 A
Yes.
18 o
Okay.
So as I understand it, Mr. Yuhas told 19 Mr. Kellie that if you had a positive value --
20 A
Okay.
21 0
Although it was below five e minus seven, you 22 were to report it anyway.
23
'A Yes, right.
24 Q
Is that correct?
And as a result of this 25 telephone conversation log, okay, did you see this I
Am-----------a----xa.---
a
lL 64 c
1 Particular document, or were the contents of this document-
~
discussed with you in approximately June 6th, 1985, when 2
3 this telephone conversation occurred?
4 A
Well, it's always been that case.
5 0
It's always been that case.
6 A
I think it's. referenced in the tech specs.
7 O
So to the best of your knowledge, what Mr.
Yuhas told Mr. Kellie.was the way that you had always 3
9
_ operated, is that correct?
to' A
Unless we could attribute an isotope to a 11 background activity or something, yeah.
12 0
okay.
So did this document here, or the results of this telephone conversation, did this in any.
13 14 way cause you to change the method of operation of yourself 15 or your subordinates?
16 A
No.
17 0
Okay.
After this particular telephone 13 conversation occurred, -- let me rephrase that.
When this 19 telephone conversation occurred, can you recall what count 20 time you were using to run RHUT samples?
21 A
Probably 1,000 seconds.-
12 Q
Okay.
Probably 1,000 seconds?
23
.A Well, that was June of '86, and by that--- I 24 don't know, probably 2,000, but I don't know, it's --
15 0
okay.
So you' re final answer is you're not "h"~""A--------_m._m_______
65 l
1
.sure what was --
2 A
Well, yeah, I don't know.
3 0
You don' t know, okay.
)
4 A
But as a venture, I would say 1,000, and
)
5 after that 2,000, but --
6 Q
Do you think that the -- a lower count time, 7
okay, of 1,000 seconds versus 2,000 seconds, do you think 8
that that impacts adversely on the commitments made in 9
Special Report 84-07?
10 A
I'd have to see which commitments.
11 0
Let me give you Report 84-07 again.
12 A
Okay.
These are the near-term commitment --
13 near-term corrective actions you're referring to?
14 0
Yeah, I would just -- I would just say that 15 you have both near-term and long-term commitments made in 16 there, and my question is, does lowera,J the count time 17 adversely affect those commitments?
18 A
As long as the commitments were five e minus 19 seven sensitivity, it doesn't affect them.
20 0
It doesn't affect them?
21 A
No.
22 (Pause) 23 A
Unless you're referring to Item #7 which is 24 calculated dose under tech specs, and it's been determined
~
25 that sensitivity-wise, we have to meet a lower sensitivity
-m_ _ _ _ _ _ _..__ _ _______._. _ _ _
m
66 k
1 to meet those dose commitments.
2 O
Yeah, but dose commitments speak to Appendix 3
I of 10 CFR 50.
4 A
Yes.
5 0
Why don't we move on.
So at some point in 6
time, in approximately October of 1985, radiation protectic..'
7 technicians were using a lowered count time of 1,000 ' seconds,.
8 is that correct, in order to do the analysis of the RHUT 9
water?
10 A
If I recall correctly, at that time, we 11 changed our count time on our computer itself, okay, so it 12 would -- it's an automatic function, even though it didn't 13 work too well.
14 Q
But you were counting for 1,000 seconds?
15 A
Yes.
16 0
okay.
And during that sane point in time, 17 technical specification 421.1, which I have a copy of,
- 18 421 -- tech spec 421.1 Footnote C was in effect at that point in time, and I'd like to show you 421.1 and have you 19 20 look at it, and also, will you please read Footnote C, whi:P 21 is also included?
22 A
okay.
23 0
You can review as much of that document as you feel you need in order to f amiliarize yourself with it.
24 25 Let the record reflect that Mr. Wilson is reviewing the F
m._______
67' I
technical specification in question.
2 (Of f the record to. review document. )
3 0
And in reference to Footnote C of that 4
technical specification, what does that footnote say?
5 A
It says other peaks which are measurable and.
6 identifiable, together with a list of nuclides shall be 7
identified and reported.
8 0
okay.
And do you find that to be in contra-9 diction with the count time that was being used in that
[
10 the changing of the count time changed the number of -- I 11 believe you called them, what, positive readings that were 12 obtained?
13 A
It's in conflict, yes.
14 0
It is in conflict in your opinion?
15 A
Yes.
16 0
And --
17 A
But as I stated earlier, you know, some peaks 18 could be background.
19 0
Did you give any instructions to your 20 chendstry and radiation protection technicians regarding how 21 to reconcile this conflict?
12 A
I recall one instance where we discussed the 23 count time and the contribution of background to a sample.
1 24 O
So basically, is it your opinion that those 25 positive readings you were obtaining were background
68 1
attributable in all cases?
2 A
No, I'm not saying in all cases, but I'm 3
saying it could have been, yes.
4 Q
But the fact that the reducing of the count 5
time did, in fact, eliminate some of these positive 6
' readings from occurring, and only some of them were 7
attributable, in your opinion, to background--
3 A
Yes.
9 Q
-- then the rest of them -- not reporting the to rest of them was in direct conflict to tha technical 11 specifications, isn't that correct?
12 A
Yes.
13 O
And did you realize that at that point in 14 time?
15 A
Possibly.
It's difficult to answer.
You know 16 a lot of things were happening, so --
17 0
Well, let us say that you were aware that 13 you were violating your own tech specs, doesn't that cause 19 you concern when you or your superiors have yourself and 20 those people that you supervise violating your own technical 21-specifications?
{
I 12 A
Yeah, it causes a lot of concern.
23 Q
So do you recall being concerned at that 24 point in time about this?
25 A
Not really, I mean, you know, I questioned it, L
i
3 69 1
that's all the way back to 10 CFR 20, you know, count tine
+
2 limits 'and everything else.
3 O
okay.
Well, I still have to reconcile my i
4 question with you.
l1 il 5
A I know, I'm aware of that but --
I \\
6 Q
Okay.
What was going on at that point intime;1 l
7 that now, you know, you' re realizing that you're violating 8
your own tech specs, I mean, you know, as -- that your 9
subordinates are doing it.
10 A
Yeah, I know, I know.
11 O
And one of your superiors directed it.
Did 12 you take any action on that at all?
j i
13 A
Other than discussing, you know, we were, you know, within tech specs by reducing the count time.
14 15 Q
But you were violating tech specs by not I
16 making these reports of those positive peaks which you've 17 now eliminated, some of which are not attributable to l
18 background.
19 A
I' m aware of that now.
20 0
Were you aware of that then?
21 A
If I was, I didn't -- I wasn't that concerned.
22 I don't know why, of course, I was involved in a lot of 23 other things too, so it's difficult.
Did Mr. Kellie direct you to violate these 24 0
25 technical specifications?
2 l
L 70-1 A
No, no.
2 O
Did any other nenber of SMUD management 3
direct you to violate these technical specifications?
4 A
No.
5 Q
Did you ever bring to Mr. Kellie's attention 6
that you were in violation'of technical specifications 7
because of your activities and the way that you were doing g-a the sampling?
9 A
'Not as I recall.
10 Q
Did you ever bring it to the attention of 31 any other member of SMUD management that the way that you 12 were sampling was in violation of the technical specifica-13
.tions?
14 A
No.
15 Q
So basically, you knew it, but you didn't do 16 anything about it?
I would like you to phrase it in your 17 own terms.
13.
A I know, I can't, because I was here and-19 there, I was involved with a different system, you know, 20 almost f ull-tine, you know.
I was aware that, ye ah, we' re 21 changing the count times.
12 O
And you were aware that-that was in violation of the technical specification because you were eliminating 23 24 some positive values?
15 A
Yeah.
Well, ye ah, that one, that's part of
)
1 L
4 1
1 L
1 our tech specs, you know, I can't evade that.
l 2
0 okay.
And what do you feel was the reason 3
that you didn't do anything about it, you were'too busy --
4
- A Well, that, and like I stated earlier, as long as we counted the sample, we met our LLD' sensitivities.
5 6
0 You felt that was more important than this 7
particular part of the technical specifications?
3 A
Well, I didn't think we was doing anything 9
wrong.
I mean, I met the intent of what was written in 10 our tech specs.
1 e
11 O
In one area.
12 A
In one area.
13 Q
And you were violating them in another area.
14 A
Apparently.
15 0
But did you know that at that point in time 16 when you were doing it, did you know that you were --
i 17 A
Well, I'm sure I was aware of it, but it's 1
18 hard to answer.
19 O'
So basically, it didn't prompt you to take 20 any action?
j 21 A
No.
22 0
okay.
In approximately October of 1985, the Lawrence Livermore National Laboratory, do you know who 23 j
24 they are?
1 25 A
Yes.
72' 3
1 O
Reported detecting Cesium 137 in downstream 2
sediment near the Rancho Seco Nuclear Generating Station.
3 A
Okay.
4 O
At levels'not anticipated due to the fact that,
5 no releases of radioactive products had.been reported, are 6
you following me so far?
l 7
A Yes.
a 8
0 What action did you take to. assure that the i
9 LLD issue raised by Bradley was not the cause of activity-
{
10 being detected by LLNL?
11 A
I didn't take any action.
12' O
You didn' t take any action?
13 A
Mo.
14 Q
Do you recall LLNL coming out with this findin 15 regarding the Cesium 137 downstream of the plant?
16 A
Yeah, but I never reviewed their report.
,i j l 17 Q
How did you cone to know about it?
Did Mr.
l 18 Kellie tell you about it, or --
19 A
Group knowledge.
20 Q
Just group knowledge.
I 21 A
Yeah.
12 Q
Do you have any idea what caused those
!i 23 radioactive products to be found by LLNL downstream of the l'
24 plant?
l!
~
25 A
I have my own opinion.
I a
I l
73 1
Q And what are those?
2 A
Well, you could have activity in the system 3
and not detect it, but by, you know, our equipment or 4
whatever, but certain plant. life, dirt, whatever will 5
collect and concentrate with that activity, algae is 6
one, will concentrate activity, so it will accumulate it, 7
and they use a lot more sensitive equipment than we use to-l 8
detect activity.
9 Q
So is there -- does algae commonly grow in 10 the RUUT tanks?
11 A
No, no, no, in the environment.
12 Q
oh, so that the -- they're a potential that 13 the algae attracted or caught Cesium 137 as it was going 14 by'in the liquid effluent, that's one of the potentials 15 you considered?
16 A
Yes.
17 O
Are there any other opinions that you have 18 regarding how they got that reading?
19 A
Not really, unless it was in the dirt, you 20 know, that would -- it's a soluable species, but it will, 21 you know, like it's attracted bionically, I guess, to dirt 12 or. algae, or whatever you want to call it.
13
.Q You mean by dirt, you mean common dirt?
14 A
Dirt, mud, dirt.
25 0
If that were the case, wouldn't we expect to l
l E_ _
I L
74.
dM I
find-it all over in the dirt in the creekbed?
2 A
We did previous before the plant ever started,'
t i lI 3
from all the fallouts.
l 4
0 Okay.
So did the LLNL report cause you any l
l 5
great amount of concern, or -- let's back up, I know you 6
stated you didn't review the report, but you had general f
1 7
knowledge'of the report.
8 A
Yes.
9 0
Did the general knowledge that you had of the.
10 report cause you any great concern?
11 A
Other than the fact, like you already stated, 12 where in the hell it was coming from.
13 0
Did you view it as being a radiological 1 hazard' 14 to the public?
15 A
No.
16 0
And it didn't prompt you to think about i
changing any of the activities that you were involved with j
17 18 at Rancho Seco, the sampling techniques, or the count times,:
19 or anything like that?
20 A
Well, my sampling techniques and count times 21 were adequate, you know.
12 O
Okay.
In your opinion, was the lowering of 25 the count time in any way involved with the unexpected 24 radioactivity being detected by LLNL downstream of the 25 plant?
u___.----_----
75 1
A No.
Of course, the facts point the opposite 2
way now, but at that time, no.
3 O
Do.you think that the LLD issue raised ~by 4
Bradley had anything to do with the unexpected radioactivity-,
5 being detected downstream of the plant by LLNL?
6 A
As an end result, yes.
7 0
I beg your pardon?
3 A
As an end result, yes.
9 Q
But that's in today's time of f rame.
I'm to talking about in the time frare of when the general 11 knowledge came to you.
12 A
Well, I'm not that familiar with his report, 13 but he says because of our LLa situation, you know, we 14 could possibly have exceeded Appendix I in 10 CFR 50.
I'm 15 sure that's attributed to that.
16 0
Okay.
Did you take any action as a result of 17 the LLD concerns raised by Bradley during the time frame 18 that they were raised?
19
- A Well, if I recall correctly, he raised them 20 a long time before we were told about them, months.
21 O
Has he -- before you were told about them?
12 A
Ye ah.
23 Q
Do you have any idea of when you were told 24 about them?
25 A
In that general area of October, or the fall
_____-m_
-...__.________-._._.___.m.___________.____._-.___--_
___-___._-._._____m_m._._
__._.________-_____________-_______-_-a
76 l
1 of '85.
1 2
0 And he raised the concerns prior to that, 3
that they became knowledgeable to you.in the f all of 1985 i
l 4
to'the best of your recollection, is that correct?
5 A
night.
f I
6 0
So -when ' you did - become aware of then, though, !
7 you didn't change any of the sampling techniques, or in 8
any way change things than the way you were doing your 9
sampling an analysis?
10 A
Other than what I referenced earlier, we had 11 to start looking at a lower LLD limit for activity.
12 0
And by a lower LLD limit, you mean what?
13 A
Decreasing the. sensitivity -- I'm sorry, 14 increasing the sensitivity.
I i
15 0
Increasing the sensitivity which is a lowerine!
16 of the number?
17 A
Right.
0 Are you f amiliar with a company by the name 18 19 of Controls for Environmental Protection?
-20 A
Yes, they're our environmental contractor.
21 Q
And as your environmental contractor, what is 12 it that they do at the plant?
23 A
We send them samples for a third party 24 unbiased count.
25 0
And where do the samples come from that they
77 1
are sent, I mean, which specific systems and/or tanks?
2 A
Well, we send them composite samples from l
3 the regen holdup tanks, and we send them animal vegetation 4
and milk, air samples.
5 Q
Is this done on a routine basis?
6 A
Yes.
7 O
And the samples that are taken,' who takes a
them, you or your subordinates?
9 A
The techs.
10 0
The techs that work unde.r you take those 11 sanples?
12 A
The liquid samples.
13 0
The liquid samples.
14 A
Yes.
15 0
And you mentioned earlier the word composite 16 sanples.
17 A
Yes.
13 O
And can you explain to me what a composite 19 sample is?
20 A
That's where we combine the proportional 21 aucunts of regen holdup tank releases into a common 22 cdntainer, that's a composite.
23
-Q Does that typically involve the use of what's 24 known as an aliquot?
25 A
An aliquot sample, yes..
1-8 l
1 O
And the samples that you -- or you as SMUD 2
gave to Controls for Environmental Protection, these samples I
l 3
were composite samples, and what I'm talking about is the 1
4 RHUT releases?
5 A
Yes.
6 0
You made up composite samples of the RHUT 7
releases and gave them to Controls for Environmental 8
Protection for a third party analysis, is that true?
9 A
Yes.
10 0
And was that always done,'you always gave 11 them composite samples?
12 A
On radioactive releases, yes.
13 0
So that to the best of your knowledge,,they 14 were always provided with the composite samples?
15 A
To the best of my knowledge, yes.
16 0
Okay.
And is Controls for Environmental 17 Protection, can I call them CEP?
18 A
Yes.
19 0
would you feel comfortable with that?
Does 20 CEP get any documents along with these samples, any type 21 of documentation, are they provided with any type of f
i 12 documentation that you're aware of?
i I'
23 A
Well,, I'm not involved with that part of the 24 program, but they would get a dated sample, okay, they 25 would say the regen holdup tank composite, but as for any I
l l
79' 1
others, I don't know.
2 O
And the' analysis that is'done by CEP, how 3
was that analysis reported to you, to SMUD?
Do you know?
I 4
A It's in a report they sent us on,the resulte 5
.of their analysis.
C 0
Do you routinely see those reports?
7 A
No.
8 0
Have you ever seen them?
9 A
Yes.
10 Q
Are you aware that some of the CEP composite-11 analysis documents are now missing?
12 A'
No.
13 Q.
Are you aware that they have ever been missingt 14 A
No.
15 0
Okay.
Before taking a sample analysis, why 16 was the RHUT diluted with service water after transfer of 17 the DRCST water to the RCuf?
18 A
Reduced tritium concentration.
19 0
Is it typical that you would put service i
20 water into the RHUT tanks?
21 A
Not really.
12 Q
My understanding is that the typical way that l 23 you would get water in the RHUT '. Ar&, other than that
\\
i 24 transferred from the DRCST tank would be through normal plant operation, through leaks in the secondary system, and 25 t
i
80 h
I things.like that.
2 A
Yes, yes.
3 0
So consequently, the putting of service water 4
in there just creates more water that you have to deal 5
with, isn't that true?
6
.A Yeah, but it's going to be discharged, and 7
it's just water.
8 Q
So to the best of your knowledge, the only 9
reason to put, service water in the RHUT tank is in order 10 to dilute the tritium levels?
11 A
Yes.
12 O
And you would do that prior to sampling,-is 13 that correct, you put service water in there, dilute the-14 water that came in from the DRCST tank, and then take a 15 sample for analysis, is that correct?
16 A
After everything is done, yes, we take a 17
. sample.
18 0
Is the dilution of RHUI water containing 19 DRCST water a normal operation, is it normal to dilute the 20 water in the RHUT tanks after water's come in from the 21 DRCST tanks?
12 A
It happens both ways, we could have a batch 23 of water in there, and put that DRCST water in there, or 24 vice versa.
25 Q
But either way, it's a normal operation for i
i Al i
~
l' the DRCST water to get diluted in the RHUT tanks, is that i
2 correct?
3 A
Right.
4 O
And who authorizes that to be do,ne?
5 A
well, it's a recommendation from the chemistry 6
group, and we' re looking at MPC's of tritium, you know, 7
there's nothing wrong with dilution of that, I don't think.
8 Q
So that would be a normal operation of the 9
plant, is that correct, to do that?
10 A
It's not normal, because we don' t routinely, 11 you know, put over the DRCST to the RHUT, that's not an.
12 everyday occurrence.
13 Q
Okay.
But in the times that you do do that, 14 okay, it would be normal to dilute the RHUT water af ter 15 you put DRCST water in there?
I mean, DRCST water becomes 16 RHUT water, is that correct?
17 A
Oh, yes.
18 0
Okay, I mean it's in the tank, it's now RHUT 19 water.
20 A
That's right.
21 O
It would be normal'to in some way dilute that 22 water?
23 A
Yes.
24 0
Okay.
And does that take a specific 25 authorization of any individual of the plant, or is it
Pr' I
normal procedure to dilute it?'
2 A
It was normal procedure.
3 0
3o it wouldn't take an authorization from 4
Mr. Kellie, or from you, or from some other supervisor to 5
dilute it?
6 A
We would probably tell them to dilute it, whe..
7 you transfer so much water, then you fill up the tank, j
g Q
Okay.
Butasnormaloperation,it'snotas-k f
9 nothing special about it?
l 10 A
tio, not that I'm aware of.
33 0
Okay.
What effect did diluting the-RHUT water before taking a sample have on the ability to detect 12 radioactivity in the DRCST water that was transferred, to the 33 14 RHUT7 15 A
What effect?
16 0
Yeah, what effect?
17 A
It's rather obvious, if there was any there, 13 it's going to be diluted too.
19 Q
So basically, the ability to detect radio-20 activity would that ability go down because there's less 21 radioactivity there?
22 A
Yes.
L 23 0
And that's why you do dilution, is that 24 correct?
For the tritium mainly, ye's, but I don't see L
25 A
83.i I
.1 nothing wrong with doing that.
2 O
Okay.
Do you know who was responsible for.
3 collecting and maintaining the recordt of water transfers 4
from DRCST tank to the RHUT tanks?
5 A
Of collecting --
6 0
Yeah, who was responsible for collectino and 7
maintaining records of those water transfers?
l 3
A During this time frame?
f 9
0 Yes.
During any time frame that you know of?,
i 10 A
Th3 records of transfe of DRCST to RHUT.
iI' 11 Q
If you were to -- if the SMUD plant, Rancho' 12 Seco were to transfer water from the DRCST tank to the 13 RHUT tank, who would be responsible for collecting and 14 maintaining records that on such and such a day, a certain 15 gallonage of water was transferred from this tank to. that 16 tank?
f i
17 A
I dcn't think there were any.
I mean, we took' 18 a -- we didn't, per se, the operations takes a level i
19 reading everyday, or every eight hours, or whatever, but--
By a level reading, you mean how much water is' 20 0
21 in a certain tank?
l 12 A
The DRCST, yes.
23
.Q Okay.
You monitor how much water is in the 24 DRCST tank?
25 A
Yes.
1 1
es 1 H
j s
Ib h
-j 1
0 On an eight -- basica11yfa once per shift j
2 basis?
3 A
Well, at least once a day.
4 0
At least once.a day, okay.
But other than J
5 that, did anybody collect and maintain records when you 6
would transfer X number of gallons from the DRCST tank to j
7 the RHUT tank?
8 A
If they did it wasn't very formal,.okay, it 9
was neither here nor there, that I'm aware of.
10 0
So you're not really' aware of transfer 11
. records being formally maintained by the utility, or by l
i, 12 anybody at the plant?
- j 13 A
No.
In fact, when I had to research all the. l 14 data, I really had to dig, you know, to look at levels of j
15 transfers.
16 0
And what kind of records did you dig through?
17 A
Well, mainly tank level, you know, it's all 18 on days recorded.
19 0'
So at some point in time, you had to go do 20 some working regarding what, the transfer of water between 21 the tanks?
l l
22 A
How much water.
23 0
How much water was transferred between the 24 tanks?
I I
25
'A Yeah.
l
85; h
1 Q
You had to research that?
2 A
Yes.
3 Q
When was that?
4=
A Af te r Mr. Yuhas came out.
5 0
Okay.
After Mr. Yuhas' inspection at 6
. Rancho Seco?
7-A Yes.
.I'm trying to recall if we wrote it on 8'
the-release forms,' but I don' t recall, I'm sorry.
9 O
And when you did that particular work, that 10 research, you used the water level indications that.were 11 written down on approximately 'a daily basis?
12 A
I'm quite sure I did.
13 Q
You' don't recall seeing any other records?.
14 A
Well, that's what I'm saying, I'm trying ---
15 I don't remember, you knew.
16 O
Seeing'any such records?
17' A
Well, they may have been there.
18 Q
But you don't. recall them?
19 A
Ye ah.
I'm trying.
20 0
Apparently we, we being the NRC, have found 21 that all but a few of the records on the transfer of water '
22 f rom the DRCST tank to the REUT tank were not kept or 23 maintained, so apparently there's some records, but very 24 few.
Do you know why that ' type of situation would exist?
25 A
I don't know why it had to be?
I mean, l
d
86 i
i 1
there's nothing that says I have to do that.
1 n
2 O
well, I'm not talking just about you --
l 3
A No, I'm saying.just the transfer of --
4 0
I'm talking about the --
l 5
A My release point is the' regen holdup tank, 6
it's not the DRCST, you know.
7 O
I' m not a sking -- ye ah, I'm not asking you 8
about you specifically --
\\
9 A
No, I'm saying that's -- no.
10 Q
You being the entire SMUD organization at 11 Rancho Seco, I me an, do you have any --
12 A
I can't answer that.
13 0
Okay.
You don't have any knowledge of why-14 sone of those records are not available?
15 A
No.
16 O
Getting back to the temporary modifications 17 that were made to move water from the DRCST tank to the 18 RHUT tank, were you ever involved in any discussions
[
regarding whether or not that modification, even though it 19 20 was temporary, should be made known to the NRC?
I 11 A
No.
l 22 O
Did you ever hear anybody else making any l
conversations regarding whether it should be reported to l
23 i
24 the NRC7 25 A
No.
p 4
4
l 87 l.-
l1 1.
O
~It is my' understanding that at one point in 2
time the Rancho Seco facility shipped radioactive water' j
3 off-site.
4 A
Yes.
5 0
And it is my understanding that the water 6
which was shipped off-site came from the evaporators that 7
were in the DRCST system in --
l 8
A Yes.
9 Q
I mean, the water before it went to the DRCST 10 tank.
11 A
Yes.
12 O
And that running the water through the la evaporators. led to a concentrated amount of water, which 14 is called -- I can't remember what the terminology is.
15 A
Called liquid concentrates, bottoms. -
16 0
Yeah, liquid concentrates, okay.
Why were 17 those shipments stopped, do you have any idea?
18 A
Yeah, the disposal sites wouldn't accept the m.
19 O
And that's the only reason that they were 20 stopped?
21 A
In the liquid form, yes.
22 0
In the liquid form.
And do you recall when
.4 25 those of f-site shipments were stopped?
24 A
Late '70's.
25 0
Late '70's?
i
-=
'g t !
I 1
A Maybe
'80.
2 0
-You can't recall specifically?
3 A
Not dates, but I was involved with that too..
4 0
I beg your pardon?
5' A
I was involved with those too.
6 0
You were involved with those too?
7 A
Oh, yes.
8 0
okay.
Has-any SMUD official, manager, or 9
supervisor given any indication that they want you to j
10 furnish a summary to them of your interview today?
11 A
It was brought up, yes.
I 12 O
And by whom?
13 A
Ray Ashley.
14 0
And what did Mr. Ashley ask you to do?
15 A
To summarize what happens.
16 0
In a written form?
17 A
As best as possible, yes.
18 0
As best as possible in a written form?
19 A
Yes.
20 0
And after you do that, to whom are you l
21 supposed to give this information?
22 A
To the same.
25 0
To Mr. Ashley?
I 24 A
Right.
i s
25 0
And have any other members of SMUD approached li
89 1
you.and discussed this same type of activity?
2 A
No.
3 Q.
Mr. Wilson, have I or any other-NRC represen-4 tative here threatened you in any raanner, or offered-you 5
any rewards in return.for this statement?
6 A
Jo.
7 0
Have you given this statement freely md 8
voluntarily?
9 A
Yes.
10 0
Is there anything further you care to add for 11 the record?
-12 A
No.
13 MR. JOUKOFF:
Thank you very much for your 14-cooperation and coming in to be interviewed today.
The 15 time is now 3:39 and we'll be going off the record.
16 (Whereupon the interview was concluded at 3:39 p.m.)
17
--o0o--
18 19 20 21 22 23 24 25 P
3
Thic is to cortify that tho attach d procacdings' bsforo the
~
1NITED STATES NUCLEAR REGULATORY COMMISSION in the matter of:
4 OF PROCEEDING:
INVESTIGATIVE INTERVIEW ' (CLOSED)
. DOCKET NO.
NOt4E PIACE :
RancRo Cordova, California DATE:
2f March 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
l'h /
(Sicrt).
[
(TYPED) p HARRY ATTMORE official Reporter Reporter's Affiliation Jim Higgins and Associates i
1 l
l l
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d t
EXHIBIT 2
90
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