ML20247F438
| ML20247F438 | |
| 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 8905300082 | |
| Download: ML20247F438 (33) | |
Text
.
r 4
l l
I BEFORE THE 2
UNITED STATES 3
NUCLEAR REGULATORY COMMISSION 4
REGION V 5
6 In the Matter of:
)
)
7 INVESTIGATIVE INTERVIEW
)
DOCKET NO:
NONE
)
8 (CLOSED MEETING)
)
9 Sunrise Sheraton Hotel 11211 Point East Drive 10 Rancho Cordova, California Il
- Tuesday, March 24, 1987 12 An investigative interview was conducted with 13 STEPHEN C. MANOFSKY, commencing at 1:10 p.m.
14 PRESENT:
15 OWEN C. SHACKLETON, Jr.
16 Senior Investigator Office of Investigations, Region V 17 Nuclear Regulatory Commission 18 19 20 11
=
25 24 25 o
8905300082 090516 (l
I PDR FOIA FRIEDMA89-A-7 PDR JAMES W.NWOINs XFIBIT H
= =
mn - - a
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2 1
CONTENTS 2
WITNESS PAGE I
3 Stephen C. Manofsky 4
Examination by Mr. Shackelton
'3 5
6 7
8 9
10 EXHIBITS II (None) 12 13 e
14 15 16 17 18 19 20 21 22 23 24 25
_mm________
3-1 P3Qgggpiggg 2
1:10 p.m.
1 3
MR. SHACKLETON:
For the record this is an l
4 interview of Mr. Stephen C. Manofsky, who is employed by 5
the Sacramento Municipal Utility District, which.we'll 6
commonly refer to either as SMUD or as the district.
7 This interview is taking place at the Sheraton 8
Sunshine Hotel and Towers in Rancho Cordova, California.
9 Present to conduct this interview is myself, to Owen C. Shackelton, Jr.
I'm a Senior Investigator with the 11 Of fice of Investigations, Field Of fice of Region V of the 12 U. S. Nuclear Regulatory Commission.
13 As agreed, this interview is being transcribed e
14 by a court reporter, Ms. Mirna Choy, from Higgins and 15 Associates.
16 Now, Mr. Manofsky, if you'd please stand.
17 STEPHEN C. MANOFSKY 18 was called as a witness herein, and, having first been duly 19 sworn, was examined and testified as follows:
20 MR. SHACKLETON:
Thank you.
Please be seated.
21 EXAMINATION 22 BY MR. SHACKLETON:
23 Q
Mr. Manofsky, for the record would you please give your work background with the district, how long you'vo 24 25 been with the district, the positions you've held and where t
4 1
you're working today.
2 A
Okay.
I started with the district about six 3
and a half years ago.
I held the position as a chem rad 4
assistant for approximately I guess about three and a half 5
years, almost four years, and then I went to Nuclear 6
Training Department for about three months or two months 7
and then went back to the. Chem Kad Department as a super-8 visor, senior chem rad assistant, and I held that position 9
up until now.
I'm acting chem quality supervisor, which to started in September or october of this last year.
I had 11 held that position but I was transferred all the way over to 12 chemistry from when we split the group.
I didn' t get split 13 all the way until that time.
14 Q
h ank you.
Now the subject of this interview 15 today is to discuss in some depth the radiological effluent 16 program at the Rancho Seco Nuclear Generating Station where 17 Mr. Manofsky is employed.
18 Steve, before we went on the recording, I gave you a document to read which is commonly referred to as the 19 20 Special Report No. 84-07.
his document was signed by Mr.
23 R. J. Rodriguez, R-o-6-r-i-g-u-e-z, who at that time was 22 the Executive Director Nuc.1. ear for the dis trict and the 23 document is dated Septemb.3r 27,19 84, and my initial questions, Steve, will be relating to this document and I'll 24 25 place it here for your reference.
i a
5 l
3 A
okay.-
2 Q
Is this the first time you've ever seen this 3
document to your recall?
4 A
I may have possibly seen it before.
I don't.--
r 5
I.have not read it through like I did this one.
g Q
Um-h uh.'
Were you in any way to your recollection involved in the writing of this document?
7 g
A h.
g Q
-Have you heard of this document being dis-cussed on the site?
10 A.
Not as 84-0 7, no.
No, not really.
We had gg discussed not discharging any gamma emitter down the creek 32 and took steps to take care of that, at least anything above 33 34 LL -- or, yeah, above IID.
15 Q
All right and when we're talking about the creek, we' re talking about Clay Creek on this site?
gg 17 A
Yes.
13 Q
Is that correct?
19 A
Yes.
20 Q
Do you recall going back tc the period of this 21 document was put out, in September of 1984, did you do any 22 work.or any analysis work for the input into this document 23 regarding, as you said, controlling the release of gamma 24 emitters into the environment?
I think that the only thing I' may have done 25 A
e
6 d0d JEE!
involved with this was write up an AP 22 af ter I did the bil$
y Al calculations, based on the ef fluents releases at that point 2
in time with the ODCM calculations.
But as f ar as the 3
4 document goes, no.
I didn't do anything with that.
Some of these numbers don' t look ' kike the same 5
6 numbers either.
So, I think that the dose report may have 7
come out of the downtown health physics section.
3 Q
All right, thank you, Steve.
Steve, please y
refer to page 2.
10 A
Okay.
33 Q
On Special Report 84-07 and the last sentence in paragraph 3.
12 A
Okay.
yg e
14 Q
And it states something to the effect that the 15 steam generator tube leaks were considered the major source 16 of contamination for the secondary system.
17 A
- That's true.
13 Q
For the record could you give us what other gp sources that you can think of that could be contaminants 20 for the secondary system?
21 A
For the secondary system?
22 Q
Yeah, are there any others?
23 A
No, act that I know of.
24 Q
Okay.
25 A
None that I'm aware of.
l f
m L-_-_-____________
7 3
Q So to your knowledge, tube leaks are the Primary ant. sole source that you know of for leaks into the 2
3 s econdary ?
4 A
Yes, for leaks into the secondary.
That's --
5 well, there is a possibility of getting gases into the j
g secondary, thinking about it.
We had had that happen one time and that was f rom the reactor building and it was throut 7
the vacuum lines going back to the condenser.
3 Q
But in relation --
A Vacuum leaks and --
10 yy Q
Excuse me, go ahead.
A Well that was, like I said, that's gases.
12 That would not be cesium, iodine, that type of thing.
Maybe g3 a little bit of iodine but not enough.to be really measurabic 14 15 Q
Now the reference that we' re making here is 16 Primary, you know, just to liquids.
17 A
Um-huh.
Yes, that's the only place I know 13 of that --
3, Q
Did you have -- as you read that document and have more familiarization with it now, is there anything 20 that looks -- that you can associate with some research 21 22 work you may have done to go into the document?
23 A
Not really, other than the initial calculation and I'm even sure that 'that was part of this.
See, it was 24 25 recognize'd about that time and I think that the downtown l
B people that were involved in doing dose cals were also look i 1
2 ing at this problem.
I didn' t really get involved in any 3
of the detailed dose calculations.
l 4
Q Steve, daere was a report 84-15.
I think it 5
was dated sometime in June of 19 86, that was wr'itten by 6
Greg Yuhas, Y-u-h-a-s.
7 A
Okay.
3 Q
From our Regional Office in Walnut Creek and at the time that that report.was issued did you have -- was y
it passed around so that you had an opportunity to read it to 11 and its contents?
12 A-I don't remember reading Greg Yuhas's report.
13 Q
But are you familiar with it?
14 A
I was in the interview.
I was in the exit interview and everything else involved' with -- I think if 15 16 it's the same one.
Because he came in and, you know, he was 17 just kind of nasty at that one point in time.
Is Q
Therefore, you're f amiliar with his concerns 19 that he identified in that inspection?
20 A
Yes in some ways.
I'm --
21 Q
Well, let's --
22 A
I had some other concerns.
Because we weren'G aware that -
are you talking specifically on the LLD issue?
23 24 Q
Well, let me get into the question and it'll 15 be more specific.
"M a
r 9
1 A
okay.
2 Q
The question is, do you know the reason why 3
the district didn't report the modification which allowed 4
the water to be trans ferred from the demineralized reactor 5
cooling storage tank, which we commonly refer ho as a g
DRCST.
7 A
Demin, DRCST or Demin RC Storage Tank.
3 Q
Yes.
p A
TE 61, yeah, I'm real familiar with the tank.
10 Q
To the regenerate holdup tank or the RHUT?
33 A
I was not aware that it had not been reported.
I was -- we were treating it as a normal discharge with our 12 13 procedures.
So, I'm really not aware of what went on that 14 way.
15 Q
Steve, are --
is A
I can't give you anything.
Go ahead.
17 Q
Steve, are you familiar with the requirements that the Commission imposes on a licensee, like the distric@
13 19 for your FSAR7 20 A
To do the 50.59 report and --
21 Q
Well, when you make a modification in the 22
- plant, 23 A
You do a 50 --
24 Q
-- it's to be included in the FSAR.
25 A
okay.
To do a 50.59 to see if there's any O
0
10 i
1 safety implications.
Yes, I am f amiliar with that kind of E
1 2
O Did this ever cone to your mind wh'en this 3
kEC piping was installed, that maybe it ought to be reported 4
to the Commission?
5 A
No end I'll tell you why.
6 Q
Please.
7 A
Because I wasn't involved in any of the 3
engineering and I thought that stuff was taken care of.
I y
had -- it never even dawned on us.
10 Q
SEike, did you hear any of your supervision or v1 any other members of management that occupy positions above 12 you, discuss this modification and withholding the informa-13 tion from the Commission?
r 14 A
No.
15 Q
To whom do you report, Steve?
14 A
Right now I report to Eric Yochheim.
I 17 reported before to Fred Kellie.
13 Q
Would you spell Mr. Yochheim's last name 19 please ?
20 A
Y-o-c-h-h-e-i-m.
But he's only been here 21 since October I think.
Maybe af ter that, of this last year.
22 Q
And prior to that time you reported to fir.
13 Fred Kellie?
l 24 A
Yes.
25 Q
K-e-1-1-i-e.
l 9
- - - - - _ - - - - - _ - _ - _ - ~ - - - - - - - -
t 111 9
I 1
A And Roger Miller.
Roger Miller I report --
2 well, I was the guy that -- one guy had one arm and one guy 3
had the other.
4 Q
Steve, going back in your recollection, and i
5 with all -- I know with all the events that have happened at 6
Rancho Seco that it's hard to separate all the different 7
issues and pick the time frames, but if you can to the best 3
you recall, back in 19 85, --
9 A
Okay.
10 Q
- - -- there were some activities that caused 11 787,500 gallons of water to be released from the DRCST to-12 the environment through the RHUT.
Do you recall what the 13 circumstances were, behind that large release?
.r 14 A
We were periodically releasing to lower our
- 15 water volume.
Mainly because a lot of the water went back 16 to the primary to be processed and then discharged as 17 tritiated water.
It was treated so that we didn' t release 18 as much radioactivity as we would have if we would have just 19 sent the water on down.
20 Q
Steve, if I can recall correctly, you folks 21 had a large long-time outage at that time, didn't you in '851 22 A
Yeah.
23 Q
Could that -- could you expound upon what 24 happens during an outage to accumulate a lot of water, what 25 activities take place?
--_a_-___.___-_
__________-_m.
0 12 0
1 A
Ye ah.
Probably the steam generators going 2
onto wet lay-up and then the subsequent draining down of the 3
We went up and went right back down againo 4
That's -- but I don' t remember discharging an awful lot of 5
water in '85.
We did not discharge a lot of water.
The 6
water out of the Demin RC storage tank probably came from 7
steam generator water and the feed and condensate system 3
that had to be processed through.
9 Q
Steve, in your capacity as a supervisor, did 10 you have any management responsibilities to overlook or 11 supervise water being transferred from the DRCST to the RHUT 12 tanks?
13 A
other than we do the analysis on it af ter it's 14 done, no I wasn't involved in saying how much water went 15 where.
That's taken care of I think further on in --
16 psobably up in the operations.
17 Q
Steve, for the record, when you say you did 18 analysis, would you explain when you do it and what you do?
19 A
Every time they do a regen holdup tank for a 20 release, they do a gamma scan and a tritium on that analysis 21
-- or on that particular tank to quantify anything that's l
12 in the tank.
13 Q
Do you participate in any of the analysis 24 activity that apparently, transpires before water is release 6 15 from the RHUT tanks to the retention ponds?
9 w-m_-
__m___-__
e 13 I
g A
Yes.
2 O
And what is the purpose of those analyses?
3 A
Just to determine whether they're a radio-4 active release or whether they're not.
Actually all of them j-5 are treated as radioactive now I think, from a sampling 6
standpoint.
I don't think, to be honest, it's probably not 7
necessary sometimes but that's whet's being done now.
3 Q
Steve, the next question refers back to y
Special Report 84-07.
I'm going -- for the record, I' m to
-c 10 it's brief, just read it, and I'll give it to you to study 13 in case you have any question.
12 A
Okay.
33 Q
Action 7, which is one page 3 of the attach-14 ments to the report:
The district has initiated a policy that all 15 releases will be controlled such that technical specification 16 17 3.17.2 limits will not be exceeded.
All sampling of the 13 RHUTs and releases of liquids will be based on this 19 objective.
The chemistry and radiation protection personne8 20 responsible for evaluating the releases, have been instructo 21 concerning these objectives.
This action, coupled with 22 action 9, will provide a second level of control beyond the 23 other near-term actions specified herein.
Are you f amiliar with this procedure or policy 24 25 that was established?
14 o
1 A
Stated that way, not as -- I'd have to look at 2
l 3
O All right.
I have it here and for the record 4
I'm making available to Steve technical specifications that 1
5 were obtained from the -district and let's see, this is
{
6 3.17.1.
It must be farther on down.
Here it is, dose.
7 A
Okay.
Yes, I'm f amiliar with this.
3 Q
The next question relating to that, Steve, that 9
we'd like to have your feelings on, states, explain the to policy mentioned as action number 7, of the near-term 11 correction action, Special Report 84-07, that was initiated 12 which controlled releases so that technical specification 13 limits would not be exceeded, f
14 A
All of our releases were to be below the LLD 15 levels mentioned in the tech specs, which were later found 16 to be too high, which was completely unknown to us at the 17 time.
We thought we were complying with this by meeting all 18 those lower limits of detection.
19 Q
Steve, when did you find out that you were not 20 in compliance?
11 A
Towards the end of 1985 when Greg Yuhas came 12 in and did another special inspection.
13 Q
Steve, did you have any responsibilities on 24 carrying out the work to assure that action number 7 was 15 implemented in conjunction with the commitment made in t
-.-_---------------.---_u----..__.-~_---___a_
1.
l 15 3
Special Report 84-07?
2 A
I ha;1 to sign for releases but this actual 3
statement, looking at the tech specs, we were looking at a 4
limit that was too high to meet this and that's where the z
5 mistake happened and it was a mistake, too.
Nobody was 6
aware.
What we had read the tech specs as saying, that thosC 7
levels should be adequate to meet any Appendix I dose 3
eriteria.
p Q
I'm going to go now Steve back to the Special 10 Report and this time to action item number 8 and I will read 53 it and then I'll make it available for you to review.
12 he district has implemented a program that 13 permits the PDS, -- and I have to look at that acronym.
/
14 A
Polishing domin sump.
15 Q
okay.
m at's a polishing domineralizer sump.
16 A
Yes.
17 Q
Okay.
Or RHUTs to be processed back to the 18 rad waste system to provide a reduction in the amount of 19 activity released.
This option can be exercised at the 20 option of the chemistry and radiation protection personnel.
21 This method, coupled with dilution of the liquids, will help 22 insure that any liquid waste released meet the objectives of 23 this program.-
24 A
That was -- okay.
You ask your question.
25 Q
okay.
Can you explain for us so that -- for P
m e
^.---__-__-m____.m.._
16 g
the' record, what you folks understand is meant by the dilution of the liquids?
2 3
A From what I understood -- any liquid waste 4
released meet the -- what we did and from what I understand 5
this to say, what ended up happening was radioactive releases 6
that had quite a bit of gamma emitting activity in them, 7
transferred back to the black box, that's the rad waste 3
system, and the water was processed.
It went out to the Domin RC, storage tank and then out to the regen holdup tanks 9
30 to be released.
What that did was it took the gamma emitters gg way down and the water dilution was to meet our 10 CFR 20 specs for our tritium going out and what we did was they
- 12 33 put water into the RHUTs from the Domin RC stoage tank.
e Diluted that up so that the tritium concentrations were 14 lower, so that we could get it out the back without exceeding 15 16 any 10 CFR 20 limits.
17 Q
All right, thank you.
13 A
Um-huh.
19 Q
Steve, the next question relates, the basis 20 and technical specification 3.17.1 limiting conditions for 21 operations and technical specification 4.21.1, surveillance 22 standards, state that the specifications do not assure Can 23 compliance with 10 CFR 50 Appendix I dose objectives.
24 you explain why these technical specifications cannot assure '
15 compliance with the dose objectives of 10 CFR 50 Appendix I? -
+=
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i
'4 17 i
i j
1 A
Ho.
That -- we were always under the 2
impression that we did meet Appendix I dose commitments i
3 by meeting the LLDs in that statement.
That was -- I re-i 4
read that three times and I still thought that we were still T
5 meeting Appendix I.
1 6
Q Was it after Yuhas made his special inspection 7
that --
3 A
Yes.
p Q
-- you were made aware of it?
l I
10 A
That's right but I had read it over before and
. - 11 I had always thought we were meeting Appendix I.
Stat's 13 what was --
13 Q
Was that common knowledge amongst all your 14 Peers and colleagues?
15 A
Yeah, we thought we were meeting Appendix I.
16 We had no idea we weren't.
Otherwise we wouldn' t be here.
17 Q
Steve, you know Ed Bradley at the site?
18 A
Yes.
19 Q
And this next question relates to Mr. Bradley.
20 Ed Bradley issued a draft, lower limits of detection study,
~
21 on October 29, 1985.
Are you familiar with that study?
Do 22 you remember this?
23 A
Yes.
I'm not real f ami!iar with it but I do 24 know the way he laid it out at first, it wasn' t even plausib3e 25 because of the way he stated the things.
From what I saw I
e
1@
I they were talking about lower all the different isotopes.
He had no isotope specific stuff and what he said was, as 2
3 I remember, that if we were at LLD for all these isotopes 4
during our releases, we'd go over Appendix I.
But doing 5
business that way is not really possible or plausible 6
because some of the isotopes are a lot harder to analyze for, 7
yet aren't even present when some of the other isotopes 3
might be.
Like ceriums in our plant is much more prevalent i
than any of the other ones.
So in that respect what he said in October of 10 11 19 85 still didn' t make sense.
12 Q
Were you involved, Steve, with any follow-up actions taken to try and comply with some of Steve's 33 14 recommendations?
15 A
You mean some of Ed's recommendations?
16 Q
Or Ed, pardon me.
17 A
What we did was we started compositing more 13 samples, the nonradioactive with the radioactive, and sending those off for more analysis and gamma scans so that we could 19 20 reach a lower LLD.
But by then -- by.that point in time the 21 majerity of the releases had already happened and it was 12 kind of like too late.
Plus that draf t kind of went away and we didn' t 13 24 see it af ter that and we had started instituting a tighter 15
-- tighter controls as I remember.
Meaning Fred Kellie and e
4
19 c.
I the chem rad group.
2 O
So there was some response to Bradley's 3
findings?
4 A
Yes but it was like I said, the majority of 5
all the releases had already happened and we didn' t really 6
get involved in too many more radioactive releases af ter 7
that.
3 Q
There as you reflected, as we've talked about ~
9 what.has happened in the past, there were some changes made 10 af ter Yuhas pointed out his findings relating to the LLD, Il and this next question relates, it says why were instructions 13 given to lower the counting times on analysis of REUT samples ?
13 A
That was to meat -- it was to meet the LLD.
r 14 Basically at the point in time that that was given we were 15 trying to lower our counting times.
We were still meeting 16 all the LLDs.
17 Q
Can you raccll, Steve, who in your management 18 chain authorized a lowering of the counting time on the
(
19 analysis of the REUT samples?
20 A
Fred Kellie.
Il Q
Was there any explanations given when this 12 order came out?
15 A
I don' t recall all the -- I don't recall ell 24 the details on that.
As I remember it was discussed and, everybody was under the impression we werS meeting all our 15 l
l
-u-.w-----
20 1
Appendix I criteria and everything else.
It was -- well, 2
what else can I say?
3 O
The next question is a little bit repetitious 4
but it's important here to get your feelings and your 5
experience.
When the LLD issue of Bradley,came to your 6
attention, what did you do to possibly assist in the lowerin{
7 of the count time on the analysis of R-H-U-T samples, RHUT 3
samples, together with the LLD issue so they would not impacq 9
on Rancho Seco's ability to cunform to the 10 CFR 50 to Appendix I dose objective limits?
11 A
They never came together.
All that discussion 12 came af ter and by that point in time we were back to 13 counting at normal time, normal counting time.
f 14 This LLD issue actually surfaced well after 15 that had happened.
16 Q
Steve, I have another document here.
I don't 17 know whether you've ever had an opportunity to see it and 18 for the record I am now making available to Mr. Manofsky a 19 telephone record on a form from the district between a 20 telephone conversation of Mr. Fred Kellie and Greg Yuhas.
21 Have you ever seen that document before, Stevo~
22 A
I can't recall whether I have or not.
I 23 remember 'this,being discussed.
But --
24 Q
And what -- the subject we're talking here --
I think it was discussed later' on.
I see whas 25 A
+
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l
\\>
21 1
i i
1 it is.
2 Q
This telepho.m conversation relates to reportir g 3
identifiable peaks.
Was there any meeting held by your 4
supervision with your staff to change their reporting as a l
5 result of this?
I I
6 A
Well, it's always been the -- what am I trying
)
l 7
to say, that -- we've always recorf.ad or reported the 3
positive peaks when they show up on the gamma scan, regard-p less of whether they're lower than LLD or not.
10 Q
Thank you.
Af ter this information was 11 discussed amongst your staf f, were there any special -- you 12 said you've always reported these peaks even though they're 13 lower than the LLD.
14 A
Yeah, us ually.
15 Q
so there I would assume from what you're 16 saying, it was not problem then for you or your staff?
17 A
No, not really.
13 Q
No change had to be made.
Steve, we're going 19 to go back and at this time refer to specification 4.21.1.
20 Is it on that document?
21 A
I think it's on this one.
Yeah, right here.
12 The table?
23 Q
Yes, I think it is.
24 A
Ok ay.
25 Q
Let me give you the question here and we'll go
22-1 back and look at the table.
l l
2 A
Okay.
S'
'Q How did you reconcile instructions to the 4
chemistry and radiation protection technicians to lower the l
5 RHUT sample analysis count time, when technical specification l
6 4.21.1, footnote C --
7 A
I don't see C.
S Q
Let's see, is the footnote present on that 9
document?
I think it is.
10 A
Okay.
11 Q
Gives instructions to report all ' identifiable 12 peaks of radioactivity made during the sample analysis.
Did Il you discuss this, Steve, with any of your people?
14 A
I think the standard was still to go back and 15 go ahead and report.
These. numbers have always been discussed.
16 "lhe five times ten and the minus seven.
17 Q
So that really, to your recollection, there 18 isn' t anything new there --
19 A
No.
20 Q
-- to what you were doing?
21 A
No.
22 Q
Fine.
'Ihank you.
Going back again, Steve, 23 into October '19 85, the Lawrence Livermore National Laboratory 24 was out and doing some work at the site and they reported 15 detecting cesium 137 in downstream sediment at levels that e
m
-__._.__--_---.-_m
23 1
were not previously anticipated, due to the f act that no -
2 releases of radioactive products had been reported.
3 What action did you witners or participate in?
4 A
We didn't --
5 O
Did you have anything to do with the results of 6
that?
7 A
We didn' t get the results back until af ter 3
October of 19 85 from what I remember.
This had all pretty 9
much come to a head in that time f rame.
It may have even 10 been later than that, that we actually saw them.
What they It was that they had reached an equilibrium which was close --
12 as I remember it was close to no discharge.
What it didn' t 13 do was it had not built up and, hey, you' re right.
Af far 14 as discharges go, we probably were discharging some radio-15 active material.
But it was below the LLD and not detected 16 on the gamma scans.
We now count -- to make an example of 17 this, we were counting for 2,000 seconds.
We could meet 18 LLDs with 1,000 seconds usually.
Sometimes we would count 19 for 1,000 seconds and meet LLDs.
Now to meet the criteria 20 that we need to meet, we are counting for 4,000 seconds 21 and sometimes 6,000 seconds, depending upon what the back-22 greemd is in the samples.
And what was never given to us before were the 23 24 numbers that we actually had to reach.
We were always --
25 we may have been discharging radioactive material, but it e
l, 24 i
1 wasn't detectable and it was below the LLD limits.
2 Q
Your statement answers my next question which 3
was, what action was taken af ter all this information was 4
made available?
And what you' re telling me ther) is that you 5
folks changed your criteria and raised your, count time.
6 A
Yes.
7 0
To give you a more indepth analysis.
8 A
Oh, yeah.
In fact,'I still couldn't tell you 9
that we are not discharging radioactive material because 10 that'would really be kind of a lie.
We're kind of stuck
- 11 with it.
There's some around.
We've had problems lately 12 that we' re getting counted -- we're having to account for 13 stuf f that's been there from bomb tests and Chernoble.
14 You'know, we're on the jagged edge now, so to speak.
15 Q
What was the reason for not taking composite 16 samples for controls for environmental protection?
I mean J
17 there was a contractor.
Are you familiar with them,. they' re 18 on the site?
I guess they do work for you folks.
CEP.
19 A
They're not on site.
CEl you just send off i
)
l 20 samples there.
Let me go back over the question. l' 21 Q-Yeah, okay.
22 What was the reason for not taking composite samples for i
23 CEP analysis 'from the RHUT for all RHUT releases?
24 A
That's not a true s+,atement. -Me trave always 25 composited the results.
But we do ganna scans before -- some t
e an
_m_____m_
_m_ _ _ _ _ _ _ _ _ _. - _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.. _ - _ _ _ - _ _ - _ _ _.. _ _ _ - _ _ _ _ _ _ _ _ _ _.. _ _ -. - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _. _ _ _
25 e
1 of the deposits were not available because they had been 2
used up to do subsequent gamma scans af ter the fact.
3 I,
from what I understand, well from all the 4
data that we have, we had all the composite samples we were 5
required to take and they were sent off and analyzed.
I 5
don' t think that that's a good statement.
7 Q
'The statement may not be correct.
Steve, do
-3 you know why of the CEP composite analysis documents are 9
missing?
10 A
No.
1 13 Q
Were you aware of that at all?
12 A
No.
They should be readily available from 13
'CEP.
14 Q
APParently this question relates to a search 15 for the documents at Rancho Seco.
Where are they maintained n
la on the site?
Are they maintained on the site?
17 A ~
They're probably down in the environmental 18 area now, since that's been taken out.
But I don' t -- I 19 think that all the information that needs to be available is 4
20 available.- I think the confusion that lies in that is they 21 had a -- we had said we would get the analysis or gamma l
I 22 spec analysis done on the~ composite and some of those 18 composite samples were not available to CEP because the 24 sample had been used up and that might clarify some things.
25 I don' t know.
That just doesn' t ring right.
26 v
~l 1
Q Before taking a sample analysis, why was the 2
RHUT diluted with service water af ter transfer of DRCST 3
water to the RHUT?
4 A
Just to get it ready to ship down, to the base' c 5
to the basin.
It was actually a dilution that was taking 6
place to -- we knew how much tritium we had.
We knew what 7
we had to dilute it to, so we just diluted it, and then 8
analyzed it, since that's our primary point of discharge.
9 Q
Do you know who authorized the dilution of the 10 RHUT containing DRCST water before taking the analysis Il sample?
~
12 A'
It's pretty much a standard way to operate of 13 any -- as far as I know, they would do this at any plant.
14 Q
- What effect did diluting the RHUT before taking 15 a sample have on the Wbility to detect radioactivity in the 16 DRCST water that was transferred to the RHUT?
17 A
Well, it would dilute the sample.
18 Q
Do you know who is responsible for collecting 19 and maintaing records of water transferred from the DRCST 20 to the RHUT?
21 A
No.
We weren't keeping track of that.
I 22 think operations was keeping track of that.
They did the 18 transfers, then the dilution, and then called us for the 24 samples.
We at any one given point in time would not know 15 when they were transferring water.
l l
l
[
~
27
~ +
g Q
Have you ever heard from working with persons in operations or in other parts of the plant why'but a few 2
3 of these records were kept?
l 4
A No.
I've never had any discussions with them. '
5 Q
Apparently our findings were there were very 4
few of the records available.
7 A
I think that the reason for that was probably.
3 our primary discharge point was the a -- our region holdup 9
tank.
I don't think it was looked at as important but I 10 don't know.
c gg Q
Were you involved in any discussions regarding whether or not the modification had allowed the transfer of 12 water from the DRCST to the RHUT should be made known' to the 33 r
14 NRC?
15 A
No.
I was never involved in any discussions 16 on it.
17 Q
Steve, you worked out at the site you said for is approximately six and a half years.
39 A
Um-h uh.
20 Q
Do you know how water was disposed -- radio-21 active water was disposed of before the construction of the 12 DRCST and RHUT systems?
23 A
^ I thought -- wait, the RHUTs, from what I 14 understand -- to answer that question, no.
From what I 25 understand the DRCST is part of the plant.
It's been e
m.--
--______-m__--_______m__-___
_____.u__
28 I
designed that way.
3 Q
How about the RHUTs?
3 A
The RHUTs from what I understand are part of 4
the plant also.
They are not temporary tanks.
5 Q
They may be referring here to the modification 6
that --
7 A
Oh, you mean --
3 Q
-- took place when over the years --
9 A
You mean the --
10 Q
-- that were on the PVC lines.
11 A
The PVC lines.
12 Q
What did they do before the PVC lines?
13 A
What do you mean?
Oh, they'll hydro the PVC 14' lines and then they hook them up but I was never involved 15 in any of the engineering or any of that.
So I --
16 Q
I think what we're getting to here is in the 17 early years of the plant before they had tube leaks and the 18 problems with --
19 A
Okay.
20 Q
-- an overabundance of water they --
21 A
I know that they did transfer once.
They 22
' trammferred from the Domin RC storage tanks.
But I don't 23 know how they' did it and I was not there when that happened.
24 Q
Have you been there when they have had of f-25 site shipments?
I m
29 1
A You mean liquids?
2 Q
Liquid.
3 A
No.
I was never there when they did liquid 4
shipments.
5 Q
Do you know, Steve, why the of f-site shipments 6
of radioactive water stopped?
7 A
I think because, this is only conjecture on 3
my part, but you're not allowed to ship radioactive liquids 9
anymore in large quantity like that and I think that's why 10 it stopped.
v 11 Q
Steve before you came over for this interview, 12 did anyone in your management from the district ask you to 13 furnish them a 1sumraary of your interview today?
14 A
Yes.
15 Q
And who was that please?
16 A
He asked if I would mind being debriefed, to 17 put it that way, and it was Mr. Ashley.
18 Q
And Mr. Ashley's job title at the site?
y 19 A
I think he is regulatory compliance.
He just 20 wanted a summary of what we -- what was asked and that.
21 Q
Has this request in anyway influenced your 22 answers or --
23 A
No.
24 0
-- your participation in this interview?
15 A
No.
In fact if it would, I' d have been down e
g-30 l
l g
here with a pen and write.
I ' told him I' d do my best, but l
3 no.
3 Q
Steve, have I or any other representative from 4
the Nuclear Regulatory Commission threatened you in any 5
manner or offered you rewards in return for your appearance-g and your testimony here today?
7 A
No.
g Q
And you've done this on your own free will?
9 A
Yes, I have.
10 O
steve, on behalf of the Commission I want to 33 thank you for your participation here.
Is there any -- are 12 there any comments or remarks that you would like to make for the record at this time in relation to this investigation 33 r
14 involving the radiological effluent program at the site?
15 A
Well, I don't think on this whole thing no one 16 was intent on conuniting any criminal acts or becoming 17 negligent on this.
We always -looked at it from the public 18 standpoint.
There was no intent on anyone's point I don' t 19 think.
20 Q
Did you ever have anyone over you in 21 responsibility request or direct that you omit information 22 from your reports in --
23 A
No.
24 Q
-- relation to gamma emitters and releases 15 of effluents from the site?
31 1
A' No, not in that regards.
No.
We had some 2
regen holdup tanks that were recounted but never to really 3
omit anything from a report when we had the hard copy, no.
4 Q
Why were they recounted?
l 5
A So that they could be considered nonradio-6 active.
7 Q
And --
8 A
But we were still meeting LLD on it and I was 9
asked to do that.
10 Q
And how was this done, Steve?
What was --
11 A
Just by recounting, reanalyzing the same 12 sample.
13 Q
Did you use a different time for count?
f 14 A
Yeah, we used a different time for count.
15 Q
What was the original count time?
l l
16 A
I think the original count time was two or 17 three thousand seconds.
18 Q
And then what time did you use on the second 19 analysis?
20 A
I don't remember.
21 Q
How long ago was this, Steve?
22 A
This was quite a while ago.
13 Q
- When you say quite a while, what are we talking 14 about, a year ago, two years?
25 A
Probably two years ago I would imagine and it i
m 04
.-___m.m._____--_.._-___._________m.___.____.___
32' l
l 3
all hinged on that seven or five times ten and the amount of L 1
2 seven number.
3-0 And who directed you to do this?
4 A
I think that was Fred.
5 Q
When you say Fred, Fred Kellie?
6 A
Yes.
7 Q
Anything else that you can think of that sh' ulf o
3 be brought to our attention?
9 A
No.
I wouldn't even consider that really 10 important.
gg Q
You don't feel that under the -- knowing with 12 your technical knowledge that there was any real safety 33 significance to that decision?
r 14 A-No.
15 Q
Are you comfortable, Steve, presently the way gg you're able to operate as a professional in your field, 17 that you're able to do your work honestly and forthright 13 without any --
19 A
Yes.
20 Q
-- coverup and doing your job properly?
21 A
Yeah.
In fact I'm happier with my job now 22 that I'm not doing 50 million things, than I have ever been 23 before.
It's actually we're seeing some changes made.
So -c 14 Q
Any other comments, Steve?
15 A
No.
MR. SHACKLETON:
At this time we'll close this interview with Mr. Manofsky.
Thank you.
(Concluded 2:00 pj e
m-
...g_
~
NU k' AGE NUMiit This i.s to cartify that tho attached pr cocdings b3foro tho UNITED S*.'ATES NUCLEAR REGtTLATORY COMMISSION in the matter of:
.JG: GF PROCEEDING:
INVESTIGATIVE INTERVIEW (CLOSED)
~
DOCKET NO.
NONE p
r
- PLACE :
Ranch 6 Cordova, California
'DATE:
24 March 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory c-4 ssion.
5
(:
(Sic:).
(TTPED)
/
MIRNA CHOY f
Official Reporter Reporter's Affiliation Jim Higgins and Associates EXFIBIT C
2 e
.. m
_ _ _ _ _ _ _ _ _ _ -