ML20247F469
| ML20247F469 | |
| 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 8905300089 | |
| Download: ML20247F469 (139) | |
Text
_ _ - - _ _ _ _ _ - _ _ _ _
f 7
,i
'l BEFORE THE 2
UNITED STATES 8
NUCLEAR REGULATORY COMMISSION 4
REGION V 5
6 In the Matter of:
)
)
7 INVESTIGATIVE INTERVIEW
)
DOCKET NO:
NONE
)
8 (CLOSED MEETING)
)
.9
'10 Sunrise Sheraton Hotel 11211' Point East Drive Il Rancho Cordova, California 12
- Tuesday, March 24, 1987 i-18 L
I4 An investigative interview was conducted with 15 FRED W. KELLIE, commencing at 7:00 a.m.
16 PRESENT:
17 ROBERT G. MARSH Field Office Director i
18 Office of Investigations i
Region V q
19 Nuclear Regulatory Commission J
4 20 RONALD MEEKS Investigator
' ~
21 Office of Investigations Region V 22.
Nuclear Regulatory Commission i
kh ALSO PRESENT:
Ik OWEN C. SHACKLETON PHILIP V. JOUKOFF
(
15 g
\\
89053000B9 890516 PDR FOIA FRIEDMA89-A-7 PDR 5
86-010 EXHIBIT m
Aukw t
amm i
2 I
CONTENTS 2
WITNESS PAGE 4
j 5
Fred W. Kellie 4
4 1
)
.5 7
8 9
10 II 12 l
II EXHIBITS
[None) g4 15 15 17 18 19 20 21 22 28 24
~
II e
==
3 r
i taaszsninsS 7:00 a.m.
l 2
3 ME. MEEKS:
On the record.
4 For the record, this is an interview of Fred th 5
Kellie, who is employed by the Sacramento Municipal Utility 6
District at the Rancho Seco Nuclear Generating Station.
The 7
location of this interview if Rancho Cordova.
3 Present at this interview are myself, Ronald Ac 9
Meeks, Investigator with the NRC Office of Investigation; as 10 well as Robert Marsh, the Field Offict Director of the Regios
' ll V Field Office for the Office of Investigations.
Also preseg at this interview are Investigators Owen Shackleton and 12 13 Phil Joukoff of NRC's Office of Investigations.
And, as
.e
%/
14 agreed upon, Mr. Joukoff and Mr. Shackleton are sitting in 15 on this interview.
And, Fred, you have no objections to 16 them being present here?
17 MR. KELLIE:
No.
If I do I will let you know 18 as we go with the interview.
19 HR. MEEKS:
As agreed, this interview is being
- 20 transcribed by Court Reporter James Higgins.
21 The subject matter of this interview concerns 12 the Liquid Effluent P.rogram at the Rar.cho Seco Station.
23 Frad, if you will stand and raise your right 24 hand I will swear you in.
25
///
m ww--
mx__- - - - -. - - -- - - - - ---.--____ - - - - -
i 4
1 Whereupon, 2
FRED W. KELLIE 3
was called as a witness herein, an'd, having first been duly 4
sworn, was examined and testified as follows:
5 EXAMINATION 6
BY'MR. MEEKS:
7 Q
Fred, we want to start off talking about a a
report, Special Report 84-07, that was sent to Mr. Martin, 9
the Administrator in Region V.
It is dated September 27,.
10 1984 and concerns the Liquid Effluents Program.
13 (The document was proffered to the. witness.)
12 First of all, are you familiar with that report 13 in any way whatsoever?
14 (Witness examines the document.)
15 A
To the best of my knowledge I am not familiar 16 with this report.
17 Q
Okay, this report was sent to Mr. Martin from 18 Mr. Ronald Rodriguez, who at the time was the Executive 19 Director,,N.uclear, of the Sacramento Municipal Utility 20 District.
Then you had no involvement in the development of 11 the information in this Special Report 84-077 22 A
No, I did not.
j-23 Q
Special Report 84-07 was sent to NRC to report d
24 that during the first eight months of 1984 they had calculate L
25-doses in excess of the Appendix I lbnits, the 10 CFR 50 i
l I
1 5
1 3
-Appendix I limits.
They had stated that the reason for that 2
primarily was the steam generator tube leaks, Mr. Rodriguez i
3.
in this report.
And they gave near term corrective actions 4
which would bring, you know, the plant into compliance.
5 Fred, I forgot to -- what we nordially do at 6
the start of the interview is to get your cu'rrent position 7
and what position you had over the past.
8 A
Okay.
p Q
So why don't we, before we continue on here 10 with 84-07, why don't we just -- what is your current 11 position?
It A
Okay, my current position is Radiation 13 Protection Superintendent.
And as such I am not responsible f
- However, L'
14 for the sampling and analysis of plant effluents.
15 I am still responsible for the dose calculations and for 16 providing that information to the Health Physics, Support 17 and Environmental Procedures Group, which does the final 18 dose calculation.
19 At the time of this letter I was the -- the 10 titles may not be exactly right here but they are on record, the correct titles -- I was the Assistant Chem Rad Protectio 9 21 22 Supervisor.
It could have been " Superintendent" at that 18 time, they changed titles in there.
But it was the same 24 job. 'At'that position I was more or less at a working level 15 taking care of and responsible for the day by day actions and t
o
_____m___-__.____
6 1
all of the chemistry, radiochemistry, counting room, radia-2 tion protection, environmental, the whole working level 3
responsibility at that time. And I worked at that time for 4
Roger Miller, who retired then in June of 1985, who was the 5
Chemistry and Radiation Protection Superintendent.
6 Q
Who do you report to now?
7 A
I report now to John McCulligan, who is the 3
Assistant Manager, Nuclear Plant.
9 Q
Okay.
to A
I have had in the last year six different 11 people that I reported to in the last year.
So a lot of 12 changes have been taking place.
13 Q
Okay, when Mr. Miller left as the Chemistry 14 and Radiation Protection Superintendent who took his place?
15 A
I took his place.
In May of 1985 I was 16 upgraded while he was still there.
Because he was leaving, 17 he was retiring. And when he left in the end of June of 1985 18 then I was -- I had all the responsibility.
I had no 19 assistant during that period of time so I had a lot of 20 responsibility and a lot of work was going on. And I had that 21 until he actually came back again to take over as chemistry 12 Superintendent, like, in January or February of 1986.
13 Q
Okay, and then --
24 A
And then at that point I was then Radiation 15 Protection Superintendent and had responsibility in the f
7 1
Radiation Protection area and had no more responsibility 2
in the Chemistry or the Counting Room area.
3 Q
Okay.
4 So you were the Chemistry and Radiation 5
Protection Superintendent from May of 1985 until the first 6
part of 1986?
7 A
That's correct.
8 Q
When was it in 1986, again?
9 A
January, February of 1986.
It's on the recorde i
10 Q
And then Mr. Miller came back --
11 A
Yes, he was back --
l 1
12 Q
-- as Chemistry Supervisor?
la A
Chemistry Superintendent.
4' 14 O
And you retained the responsibilities of the 15 Radiation Protection --
16 A
That's correct.
17 Q
-- group Superintendent?
1 18 A
Correct.
l l'
Q When you were the Chemistry and Radiation 20 Protection Superintendent who did you report to?
I 21 A
I was reporting to the operations Manager.
12 Q
And who was that?
13 A
That was -- we just got a new one here, I got 24 to think for a second.
15 (Pause.)
9
j 8
I Why don't you stop that thing for a second.
2 Because you really -- I should -- I have had so many bosses l
(
5 in the last year.
I've been gone a week, too.
When I i
4 think about it as we go through here I'll tell you.
l 5
Q Steve Rediker was the --
4 A
Steve Rediker.
7 Q
-- Plant Superintendent, wasn't he?
8 A
No,SteveRedikeristheonewhoIwasreporti%
9 to as the Operations Manager.
10 Q
Okay.
II A
It was Steve Rediker.
George Coward was the 12 Plant Superintendent at the time.
13 Q
Okay, so that was the chain of command to 14 the Plant Manager?
15 A
Yes, right.
16 And there was at one time in there -- and I'm 17 not sure exactly of the dates -- but I stopped reporting to 18
-- but I believe this was sometime in 1986, when I stopped 19 reporting to Steve Rediker and then I started reporting 20 directly to George Coward.
21 Q
As the Radiation Protection Superintendent?
22 A
Correct.
13 O
Okay.
24 A
And the Chemistry Superintendent continued to 15 report to the operations Manager.
e m
---.--____-._____._____________m_
9 v
3 Q-So getting back to Report 84-07, -you say you 2
had no involvement in the development of the information.in j
g this report?
4 A
No, I did not.
5 Q
Have you ever seen this report before?
~
6 A
I saw it after Greg Yuhas came and was doing 7
his investigation, that's when he showed us this report. :
4 8
Q Okay, you are referring.to the inspection he' 9
did on the Effluents Program last year --
i 10 A
Right, right.
11 Q
-- in April and May of 19867 12 A
That's correct.
33 THE REPORTER:
Excuse me, Mr. Meeks.
Mr. Kell 6 14 please wait until he is finished with the question, please.
15 THE WITNESS:' I'm, sorry.
16 MR. MEEKS:
I think it was the other way 17 around, I was cutting in on him.
18 THE WITNESS:
Yeah, I'm sorry --
19 MR. MEEKS:
I'll wait until you finish ta.lking-20 and then if you wait for me --
21 THE WITNESS:
I have to work on that.
.22 MR. MEEKS:
I do, too.
We don't go through 28 these every day.
24 BY MR. MEEKS:
25 Q
So that was the first time that you saw Specia8 b
c b__-__m__.m__.
u_
____,_o_.__.__.-.
__-am._
10 1
Report 84-077 2
A That is correct.
3 Q
This contains information about the Chemistry 4
and Radiological Programs, which you supervised at that. time.
5 A
Well, okay, that's correct.
I was from the 6
working level standpoint supervising that.
'But Roger Miller 7
was still there at that time.
3 Q
Okay, do you know if your department through.
9 Roger Miller was tasked to furnish information input into 10 this? ~
11 A
I can't answer that.
i don't know.
12 Q
What has been your involvement in Special 13 Report 84-07-in review of the information in that report 14 since it was brought to your attention by Mr. Yuhas?
15 A
oth'er^than just, you know, it was in the 16 report. And he showed it to us when he was here. And there-17 has been, you know, no other involvement that I can think of.
18 Q
Fred, in the report on page 2, the last para-19 graph on this page -- we'll let you read that report.
20 (Witness examines the document.)
21 A
Okay.
22 Q
Are you aware of any individuals that had 23 responsibility for input into this report?
At any time did 24 you become aware of any individuals?
15 A
No.
i 1
-.-__-a---__s.--_- - -. - - _ _ _ _ _ _. _ _ _ - - - _
i al i
t,,
[
t Q
This paragraph right here that you just l
2 finished reading, it refers to the. pathway of contaminated l
l 3
water from the steam generator tube leaks to the environment.l 4
Do I understand that this system includes all the secondary 5
systems?
4 A
(No response.)
7 Q
In there anything in this paragraph which you would understand to include the routing of the pathway to the l 8
9 environment through the primary or the Rad Waste or Miscellaq 10 neous Waste System?
11 A
Well, this is true, you know, strictly from th0 12 secondary system.
The pathway from getting contaminated 13 liquid in the secondary system, this would generally be the 14 pathway,'yes.
15 Q
okay.
16 Now, Mr. Yuhas in his Inspection Report 17
. reported a modification between the Demineralized Reactor 18 Coolant Storage Tank to the Regenerate Holdup Tanks.
Why 19 wasn't that information reported in here as part of -- well, 20 let me ask you dais:
Was that a pathway of liquids to the 21 environment also?
22 A
Yes.
13 Q
Okay.
24 (Pause.)
15 A
And there's, you know, also other -- as Greg it
___m.m
12 l'
well aware and I'm sure you people are -- there are some 2
storm drains that, if there happened to be a leak in that 3
area and it was a leak from the secondary system which 4
contained any small amount of radioactivity that that could 5
be a pathway outside also throu' h tte retentios' basins.
g 6
Q Okay.
7 A
But generally that last paragraph covers the 8
situation if you have activity in the secondary system and 9
you were regenerating the polisher resins and you had 10 leakage from the condensate pumps, which you do, they.have Il a continual leak off of those, and any other leaks that you 12 may have out of the secondary system would go into the 18 condensate pit sump, over to the Polishing Demin Sump, then 14 to the Regenerate' Holdup Tank, where they would be neutrali-15 zed, analyzed and then released to the retention basis and -
18 then recirced and analyzed again and then diluted to insure 17 you meet 10 CFR 20 before you go outside.
'18 Q
Okay.
38 Also on page 2 here, the last sentence in 20 paragraph 3, this sentence right here.
I'll just read it.
Il "The tube was subsequently stabilized and plugged.
This 12 action may eliminate the major source of secondary system 13 contamination which led to exceeding the above-stated limits.
14 And they are referring to the Appendix I lbnits.
So it 15 states that the steam generator tube leaks were the major e
13 1
source of contamination.
2 What were the other sources of contamination i
l i;
3 for the secondary system?
l-4 A
That's it.
f 5
Q Okay, so --
6 A
The primary -- on a nuclear re' actor, or on 7
an operating power plant such as Rancho Seco, all of the 3
activity comes from one place, it comes from the reactor.
p so if you have a leak from the primary system into the 10 secondary system then that's where that activity will come Il from.
And even though you may stop the leak completely there -
12 may still be some residual activity left in the secondary 13.
system for some time afterwards.
14 Q
Okay, so you would read that sentence as 15 being -
"This may eliminate the major source..." -- that 16 would be more complete according to what you've told me:
17 "This action may eliminate the major and only source of 18 secondary system contamination"?
19 A
Right.
20 Q
Okay.
11 A
That may get -- you know, but I think they 12 were speculatively at that time.
I'm not sure if they knew 13 for sure that would completely stop all the leaks, I don't 24 know.
15 Q
When you say "they" who most likely would be m
_e
_________-________--_m--
I 14 l
1 the individuals responsible for the information in this 1
l i
2 report?
l 1
l 3
A You know, to be honest with you I really 4
don't know.
I don't know who -- where they even got their I
5 information for these things.
Because they didn't ask me.
6 I mean, I was not asked and I did not provide any informa-7 tion to this report.
So I don't know who was doing that, 8
maybe Ron Columbo, I don't know.
9 Q
Okay.
10 MR. MARSH:
I would like to ask a question 11 here, Ron.
12 MR. MEEKS:
Sure.
13 BY MR. MARSH:
14 Q
Mr. Kellie, are you aware'of any other sources 15 of contamination into the secondary system other than the 16 tube leaks?
17 A
No.
18 BY MR. dEEKS:
19 Q
Fred, were you ever involved in any efforts to 20 point out -- you know, any discussions with fellow workers 21 at the plant and any managers or supervisors -- to point out 12 the fact that that modification that we referred to from the 13 Demineralized Reactor Coolant Storage Tank allowing water 24 to be transferred from'that tank, the DRCST tank -- have you 25 ever hear'd it referred to as a Doctor CST?
l e
f 15 1
A Yes.
2 Q
From the Dr. CST tank to the Regenerative 3
Holdup Tanks, or the RHUTs, were you ever involved in any 4
discussions where it was pointed out that this modification !
5 should be made known to the NRC?
6 A
No.
7 0
okay.
3 A
Because, you know, the first -- I don't think c 9
the first I heard, you know, that there was going to be no 10 radioactive releases, okay, and that was in October of 1984.
11 And the way that came to people _like myself was that it just 12
-- you know, we had been doing radioactive releases, taking 13 the samples, calculating, and determining what the activity r
And my boss, Roger Miller, just said there were no su 14 was.
15 more radioactive releases.
And I said, "Well, what does 16 that mean?"
And he said, "Well, there's just no more
-17 radioactive releases."
And I said, "Well, what about 18 tritium?"
The tritium question was never -- it was made, 19 at least the information given to me was that it didn't 20 really -- it was only from radioactive releases that 21 contained gamma emitting isotopes and that if it was just 22 pure tritium then it was not applicable.
23 Because we knew -- at least I knew at that 24 time, is that, you know, if they said no radioactive 15 releases and they meant completely no radioactive releases
~
6
l 16 1
that would have included tritium.
But the information that
)
2 was given to me was, no, it didn't include tritium.
3 Q
Okay.
4 A
And so, therefore, you know, you could l
5 release from the Demineralized RC Storage Tank, 6
Q So this was in October of 1984 that Roger' 7
Miller told you --
8 A
Yes.
9 Q
-- that there would be no radioactive releases 10 of gamma emitting isotopes?
11 A
Right.
12 Q
What are the --
13 A
And that wasn't even clear necessarily what 14 that meant, at least to me.
15 Q
Did you ask him what he, referred to when he 16 said gamma emitting isotopes?
17 A
I can't remember.
Is Q
Okay, what would be the principal gamma 19 emitting isotopes that would be released from Rancho Seco?
20 A
Primarily that depends on how long you have 21 been operating and depends on how long you've shut down. But, 22 you know, if you've been shut down for a while it's 23 Cesium 134 and 137.
But you could have had cobalt 58, you 24 could have Iodine 131, you could have Manganese 54, you 25 could have other isotopes other than what we just have right e
=
_-__m____
9
17 1
now, Cesium 134 and 137.
2 Q
Do I understand that the Cesium 134 and 137 3
are more prevalent during an outage --
l 4
A After you've been shut down for a long time, 5
that's correct.
6 Q
Okay, and the other nuclides that you mentione(
7 are also prevalent during --
3 A
Could be prevalent after --
9 Q
After you've been operating?
10 A
Right.
11 Q
Would Cesium 134 and 137 also be prevalent 12 during operation?
13 A
Yes.
14 Q
But the other nuclides tend to -- their 15 presence tends to be diminished without it?
16 A
Right.
17 Q
Who would have been doing those calculations?
Is A
Ih 84?
I'm n6t..sure.. I think it was probably 19 Ed Bradley's group at that time.
20 Q
In 19847 21 A
Yes.
12 Q
And in 19857 13 A
Ed Bradley's group.
24 0
Okay, you mentioned that this was relatively 15 a new process to you?
h-_-_-____._____m______
18 1
A Well, yes.
See, before that time, you know, 2
we had been clearing radioactive releases, you know, just 3
right along.
Then all of a sudden they said no, no more.
4 And there wasno explanation either to us why that was being 5
done, no guidelines, it was not -- you know, it just came 6
down that way.
7 Q
Why don't you explain the process of how a
the releases were made before your instructions from Roger 9
Miller.
You mentioned you just made the releases, there 10 was a process you went through --
11 A
The same thing.
You.know, this applies here 12 and you are doing the analysis and doing the dose evaluation 13
-- well, let's see, 84 -- yes, you were doing the dose 14 evaluations, you know, prior to release, and having the 15 total curie content for each release and you had all that 16 documented.
And then you would give that information to the 17 environmental group who would then do the actual dose la calculation and then, you know, you would just continue to 19 do releases that way.
And then you would release it to the 20 retention basin where you would do another complete evalua--
21 tion to insure that you comply with 10 CFR 20 at your 22 environmental release point and it would be, you know, all 23 documented.
And that's how we were doing it.
24 That's exactly how we did it even when they 25 said no more releases when we were doing releases that t
m
1 19 I
i 1
contained radioactive tritium.
]
2 Q
Okay.
1 3
Let's go back and why don't you kind of lead
~4 me through a little bit more. You might have assumed that S
I know more than I actually do.
6 A
Okay.
7 Q
And for the record I would just like to get j
8 a kind of a step by step process of what you did.
9 What are the causes or the reasons for.
10 releasing liquid effluents from the site?
II A
Okay, the reason you have to release liquid 12 effluents -- we're talking radioactive liquid effluents or 13 are we talking just liquid effluents in general?
14 Q
Let's say radioactive liquid effluents.
15 A
okay.
The reason you would have to release i
16 is, one, if you had a primary to secondary leak.
17 Q
And when you refer to primary to secondary 18 leak --
19 A
This is water that is radioactive from the 20 primary system that is then under high pressure, 2000 11 pounds or so, which will then migrate into the lower pressurc 12 system, which is the secondary system, at the order of 900 13 pounds, and that water then will mix with water that is 24 supposedly cleaned water,, or non-radioactive, as'long as you 25 have the tube leak.
And then that water, if you have any e
I 20 1
1 leakage from the system or if you were regenerating the 2
polisher resin. Because the secondary condensate liquid 3
goes through the polishers,.the polishers are resin; resin 4
will remove the radioactivity.
5 Now, if you take and regenerate that resin and
\\
6 you use caustic lye and you use sulfuric acid and you 7
regenerate that then that radioactivity comes out, that 8
waste then goes into the Polishing Demin Sump, then from 9
the Polishing Demin Sump to the Regen Holdup Tank.
- Okay, 10 so that water now contains some of the radioactivity that 11 was from the primary to the secondary, removed from the 12 resin, you regenerated the resin, and then it was placed -
II back into the -- it ended up into the Regen Holdup Tank.
14 0
okay, and then from the REUT, or the Regen 15 Holdup Tank, it was delivered to the basin?
16 A
Retentior. Basins.
17 Q
Retention Basins?
Is A
Right.
l 19 Q
Where then it was released to the environment?
20 A
correct.
21 Q
Okay, now, in this process that you have just 22 explained to us why don't you continue and explain what the 23 sampling. process is at every point that you just mentioned?
24 A
Okay.
And I wasn't directly involved in them 25 so, you know, I may not have all the details.
But basically e
i u
1 1
21 1
first of ~ all from a water quality standpoint you have to 2
meet the California Water Quality Control Board standpoint.
]
3 So, therefore, the water first was analyzed to insure it.is-4 neutral from the standpoing of pH, the pH had to be a range j
5 from 6.5 to 8.5.
You had'to insure that the h'ydrazine was I
6
' neutralized.and we neutralized the hydrazine with hydrogen 7
peroxide.
8 Once the sample was within the correct pH 9
range -- and it had been recirculating all the time because 10 you have a big propeller in there, just a big propeller to 11 move the water around to recirculate it.
12 Q
What area of the tank are you talking about?
13 A
.The Regen Holdup Tank.
14 Q
Okay.
15 A
I'm just talking strictly Regen Holdup Tank.
16 Then & sample.would be taken and a gamma scan using the 17 gamma spectroscopy system, jelly-type system, would be used 18 to determine the activity for gamma emitting nuclide.s.
And 19 at that thne we were using 2000 seconds.
There would be a l
20 sample taken for tritium using the liquid scintillation.
11 There would also be a gross beta sample, and at that time 12 we were using the gross beta results to insure that the 13 Strontium 89 and 90 was witin the tech spec lower level of 24 detection.
15 Then each isotope as it is -- if it was a f
8
l l
22 1
l 1
positive then that isotope would be the total curie amount 1
2 based on a concentration, microcuries per cc, of that l
3 isotope times the total ces that you released from the tank E
4 only that was in the tank at the time.
Then you would have
)
5 a total microcurie.
You would also know what the MPC was I
l 6
for that particular isotope so you would kn'ow how much 7
dilution that you would have to make once it was in the a
retention basin.
9 Q
When you say MPC what are you referring to?
10 A
Maximum Permissable Concentration.
These are 11 the 10 CFR 20 values, limits that you need to meet.
Those 12 were met at the rel, ease from the retention basin. You wanted 13 to determine what it was in the Regen Holdup Tank to_give 14 you an idea of -- see, if it was too high -- see, when we 15 originally were doing these things we were looking at -- from 16 an operational standpoint we couldn't really tolerate much 4
17 more than, say, 20 to 30 MPCs of th irotope in the Regen 18 Holdup Tank.
You know, we're going back now, we're going 19 back to where we were releasing regenerate waste that 20 contained, you know, some amount of radioactivity.
We're 21 beyond Appendix I levels.
12 See, when you start talking MPCs you're 23 talking,way beyond Appendix.I.
But you couldn't tolerate 24 having a real high MPC value in the Regen Holdup Tank and 25 then dump that to the retention basin because you've only 1
23' 1
got about a factor of three dilution in the retention basin.l 2
And you could only take about a factor of ten reduction as l
3 it came from the retention basin out to the plant effluent.
4 So if you had to dilute any more than ten to one from the 5
retention basin in order to meet the MPC requirements then 1
6 that would operationally just take too long to release the 7
basin arulyou would end up getting stuck with another basin 8
filled up before you had that basin empty.
9 And operationally you wouldn't want to do that 10 because then you could have water running out on the ground Il somewhere and that was not -- you know, from 'aus operational 12 standpoint..So you had to keep that MPC, level low in'the 13 Regen Holdup Tanks, in the order of something less th,an
\\
14 20'or 30 so that when you released it down to the retention-15 basin it would be in the order.of ten or so, so you would 16 have a dilution of something less than 10 to 1 in order to l
17-release it offsite.
18 Q
Okay.
19 What was the action that caused water to be 20 transferred to the RHUT?
Is that --
21 A
Just --
12 Q
Whether you have generator tube leaks or not 13 you automatically get --
24 A
That's right.
25 Q
-- the water going to the RHUT7
24 1-A See, before 1981, I.mean, we were always doing 2
Regen Holdup Tank releases, you know.
3 Q
Uh-huh.
4 A
It was until we had a primary to secondary 5
leak is when we then started doing radioactive liquid
~
8 effluent releases from the RHUTs.
I l
7 Q
Uh-huh.
i 8
A Prior to that time we were not doing radio-9 active releases from the RHUTs, they were all non-radioactive 10 releases.
Q Prior to what time?
11 11 A
Prior to the first tube leak in 1981.
13 Q
Steam generator tube leaks?
d 14
'A From tube leaka, right.
15 Q
Now, do we understand that it's your impression 16 or your knowledge that there is no other source of contami-17 nation for the secondary system other than the steam genera-18 ter tube leaks?
19 A
Well, if there is I'm sure not aware of it.
20 Q
-Okay.
II A
I'm not, aware of it.
No, not that I'm aware of.
22 Q
So in the process'of the secondary -- the 23 processing of the secondary water you come up with excess 24 water that needs to be. released, that excess water goes to 25 the RHUTs, and then it's released?
.o
o i
25 1
A Well, see, you~ have -- as the plant operates 2
you lose on the order of -- and the operators can give you 3
better numbers -- but depending on -- see, any of the 4
regeneration from the Makeup Demineralizers, wh,ich are non-
'1 5
radioactive, all that water, all the regenerate waste from 6
that goes into the RHUTs.
Okay, along with any regeneration 7
.that you had for the Polishing Demins, that went'in.. And 8
you're taling -- I can't give you exact numbers, but to 9
regenerate.a'one polisher -- I don't know an exact number, 10 but we're talking about large volumes of water to. regenerate II one. full. bed.
12 Because there is a separation of the resin, 18 there is a regeneration of one and the rinses from that, L
14 then there's a regeneration of the other and the rinses _from 1
15 that, then you put them back together and you rinse them 16 again.
1 I?
Q Okay.
18 A
So there is a considerable amount of water.
19 And at the time, too, a lot of the operators were not real 20 efficient in minimizing the am.mt of liquid that was being 21 used in these regeneration processes.
And in addition to 12 that, any leaks that you would have in the secondary -- and 25 there were leaks.
When you operate a big water plant -- and 1
}
24 that's all those nuclear plants are, are water plants and y
15 they're moving water around in circles -- valves leak, there i 1
l t
26 1
is a continuous leak out of the condensate pumps, there is 2
continuous leakage from that.
3 So you have continuous leakage into the sumps 4
which ultimately end up into the Regen Holdup Tank.
5 0
Okay, so as you had these steam generator tube 6
leaks and that dirtied up the system --
7 A
Right.
S Q
-- so the water going in there was dirty, 9
contained radioactivity?
10 A
Right.
11 Q
And I understand from your explanation that 12 you sampled, you did your various sampling that you had to 13 do at the RHUT tank?
14 A
Yes.
15 Q
And then a dilution came when you transferred 1
16 the water from the RHUT to the --
17 A
No, the dilution really didn't come until --
18 there was inherent dilution -- and there could have been times 1
I l
l' when we may have diluted some of the water in the Regen 20 Holdup Tank.
21 Q
Okay.
12 A
You know, there are so many things that have 23 happened overthe years, I can't say exactly.
But inherently 24 there is some dilution of the water in the Regen Holdup 15 Tank just from the standpoint that from regenerating the l
l
'ea-e uil
27 1
dsminaralizers, the Makeup Drmineralizers,.which are not 2
radioactive in any way.
So any water you had from the 5
regeneration, the regenerate chemicals, from the flushes, 4
from the rinses on that system went into the Regen Holdup.
1 5
Tank and would have a tendency to dilute that.'
6 BY MR. MAh; '
l 7
Q Mr. Kellie, am I correct in what I'm under-a standing, that all of this process that you're describing 9
is part of your normal operating procedures within the 10 secondary system?
11
'A Yes, that's correct.
12 MR. MARSH:
Okay.
13 BY MR. MEEKS:
14 Q
So you would do the sampling but you're' talking 15 about the retention basin had a capacity dilution factor of 16 ten to --
17 A
Well, you.could --
18 Q
-- a factor of ten?
. 19 A
well, you could get -- see, your Regenerative 20 Tanks are, A_ke, 100,000 or 200,000.
Il Q
Just in even numbers, okay.
12 A
A is 100,000 gallons and B is 200,000 gallons.
23 Q
okay.
24 A
' If you released a tank that had 100,000 gallonc 25 in it and it went to the retention basin, which has approxi-4 i
e
__-.____.____-__m.-___.__._
28-
'l-mately 400,000 on the average, you could have about three 2
to one or four,~okay?
And then from going from the retention 8
basin to offsite -- the pump is, like, a 3000 gallon a 4
minute pump but you can throttle that-down to as low as 5
100 gpm coming out of the retention basin.
6 So you could have 100 gpm/comr, out --'or 7
1000 gpm coming out, which is a reasonable amount.
But it 8
could go down to as low as 100.
But you start thinking of 9
100 gallons a minute and you've got a 400,000 gallon tank 10 you start figuring out how many minutes that is,.how many 31 hours3.587963e-4 days <br />0.00861 hours <br />5.125661e-5 weeks <br />1.17955e-5 months <br /> it is, and you're looking at some considerable amount 12 of time before you could get one out.
Ib So reasonably about 1000 gallons is reasonable 14 for releasing from the retention basin.
So if you had 1000 15 gallons a minute c'oming out and you could only dilute up 16 to the total going offsite is 10,000 gallors, okay?
So --
17 now, I'm talking about meeting 10 CFR 20 limits, now.
I'm 18 not even -- you know, this is not even now what we know as l'
far as the 10 CFR 50 Appendix I.
We're just talking to meet 20 10 CFR 20.
And if you have 1000 coming out and you have 21 10,000 gym -- that's the max you can have going off -- then 22 you have about one to ten dilution.
23 Q
Okay.
24 Now, in October of 1984 Roger Miller told you U
there would be no more radioactive releases?
9 e
29 1
A Right.
2 Q
So what changed?
Now, you've explained the 5
procees.
How was the process run after that?
4 A
We were doing exactly the same thing as far 5
as sampling every tank.
We were counting the samples, 6
50,000 seconds at the time.
We were counting for tritium, 7
we were looking at any -- and doing gross betas also.
And 8
then if we had any tritium we would consider the radioactive 9
ralease and, you know, it would be the same process of 10 dilution and everything if there was tritium.
11 But if there was any gamma activity, any 12 positive peak, then at that point we would have to, one --
13 and this is where, you know, in some of the cases what we
~
14 had to do and we were not -- you know,. at the time, we would 15 try such things as we got some demineralizers from Diablo 16 to put between the Regen Holdup Tar.ks to run the liquid 17 through to try to get it down to a low Appendix I level.
18 Now we're talking Appendix I levels.
19 So really we didn't have the system necessary 10 to properly deal witti the water.
Because any time we had ang 11 positive peaks then we had to put it downstairs.
Okay, eveg 22 time we put it downstairs -- meaning into the Miscellaneous 13 Waste System -- then we would have to process that water.
24 Okay, so we're talking, you know, 100,000 gallons, 200,000 15 gallons at a shot to go into a 30,000 gallon tank, which t
e
-m___-
30 1
took a number of times to fill.
So operationally -- and all 2
of these were through te!..porary PVC piping basically back 3
to the Polishing Demin Sump and then the Polishing Demin 4
Sump, we have the necessary hardware and piping to pump it L
5 to the Spent Regenerant Tanks, which are in our Miscellaneous 6
Liquid Rad Waste System.
7 And then that water, which was then'really 8
very low radioactivity, you know, compared to what the 9
radioactivity is in the Miscellaneous Rad Waste System, 10 you would process that water. And then the distillate of 11 that,.when you evaporated this water off, the distillate 12 from that would be comparatively clean water and would be 15 demineralized, with the exception that there would still be 14 tr'itium there.
Because the domineralizers have no effect 15 on tritium.
16 So that water then would be transferred to the 17 DRCST Tank...The DRCST Tank is a 450,000 gallon tank. How-38 ever, it doesn't take very much arithmetic to start figuring I?
out we were doing -- I can't give exact numbers -- but we 20 were probably doing a Regen Holdup Tank release a day, or 21 at least every other day.
If you were putting all of that 12 back downstairs it doesn't take long to figure out you're 13 going to get a Demin RC Storage Tank filled full of deminer-24 alized tritiated water.
And that's exactly what happened.
15 Q
Okay, so let me just make sure I understand
~
e I
31 l
1 that, understand the process as it was after October of 1984.
2 When you detected radioactivity thenyou say you transferred 3
the water back to the Polishing Demineralized --
1 4
A Yes, it went to the Polishing Demineralized 5
Sump.
4 Q
Okay, let me give it back to you to make sure 1
7 I understand.
8 A
Okay.
9 Q
it went back to the Polishing Demineralized 10 Sump.
And from there you sent it to the Spent Regenerant 11 Holdup Tank?
12 A
Spent Regenerant Tanks.
II.
Q Spent Regenerant Tanks, all right.
14 This is in the secondary system?
15 A
No, this is the Miscellaneous Liquid Rad 16 Waste System now.
17 Q
Okay, but the Polisher Demineralized Sump, 18 that's in the secondary system?
19 A
Part of the secondary system, yes, 20 Q
Okay.
21 A
Actually, that's called the Clean Drain 22 Systam.
23 Q
And to transfer it to the -- that's called the 24 PDS, the Polishing Demineralized Sump?
25 A
Yes.
e
32 y
Q To send it to that sump you had to set up --
A' Temporary piping.
2-3 Q
-- temporary piping?
4 A
Ye8-5 Q
PVC piping?
g A
Yes.
7 Q
Okay, to transfer that water.
Whe'n was that 3
piping first established?
- p A
I don't know.
10 -
Q When did you first become aware that that 33 piping existed to send the water back to the PDS?
A I can't give you an exact date.
I mean, it 12 was some time after October of 1984.
gg 34 Q
Okay.
15 A
'Because, you know, when we had the activity 16 there we had to send it'back over here, had to sand it back 17 to the Polishing Demin Sump,.back to the Spent Regen Tanks.
13 Q
Now, from the PDS you already had existing to lines and valves set up to send it to the Miscellaneous 20 Rad Waste --
21 A
Yes, that was the -- the original design of 12 the plant was such that -- and I think the engineers were as a little naive at this -- was that if you had a primary-24 secondary leak then all you would do is take all of your 15 water from the Polishing Damin Sumps and put it into the I
\\
_-_-----________________,___,m_._,_
l 33 1
Spent Regen Tanks and process it.
But.I think they were a 2
little naive in that they didn't realize how many gallons l
1 3
of the water that you ended up with in a regeneration of I
4 one of those Polishing Demins.
5 They were looking at things at the time'the 6
plant was built of meeting 10 CFR 20.
They'were never ever 7
looking at meeting 10 CFR 50.
The plant was never'ever 8
built to meet 10 CFR 50 A-pendix I values. And that whole 9
system was designed both to. insure you could meet 10 CFR 20 10 limits.
II MR. MARSH: I have a question.
12 BY MR. MARSH:
IS Q
I'm confused somewhat.
How are we getting so 14 much water?
15 JL Just in the normal process of -- see, until' 16 they stopped regenerating the Polishing Demineralizers all 17 the inputs into the Regen Holdup Tanks are the -- and I 18 can't give you exact ' numbers how much we get -- but you have 19 actually six domineralizers, you have two cations, two 20 anions, and two mixed bed domineralizers on the Makeup Water 11 System.
Well, each of those have to be regenerated at some 22 frequency and they have to be rinsed.
And all of that 18 regenerant waste and water goes into the same Polishing 14 Demin Sump and goes over to the Regen Holdup Tanks.
15 MR. MEEKS:
Let me stop you right there, Fred.
34 1
BY MR. MEEKS:
2 Q
So to regenerate all of those beds you're 3
talking about you have to bring water in for each of those 4
regeneration. processes?
5 A
Exactly.
6 0
You bring in new water into th'e system?
7 A
That's right.
8 Q
You're sending it and regenerating those 9
resins and that's dirtying the water up?
10 A
That's right.
, II Q
Okay.
12 A
This is clean -- when we say -- this is la dirtying the water up from a chemical standpoint.
14 Q
Chemical standpoint.
15 A
Not from a radioactive standpoint.
With the 16 Makeup Demineralizers.
17 Q
Right.
okay, now add to that you have none polisher 18 A
19 beds that are doing the same process and even there in some 20 cases you use more water.
And depending on the frequency ofregenerationofthosethingsthenyouendedupaddingall 21 22 this water.
Now, the polishers, if there was any rate of 13 radioactivity --
24 Q
From a tube leak?
25 A
From a tube leak.
See, the resin does not o
35 I
discriminate whether or not it is a cobalt particle that 2
is soluble that is radioactivity and a cobalt particle that ;
5 may be soluble that is not radioactive.
It will remove all 4
cobalts, it will remove all iodine, or at least, you know 5
all -- what is all.
6 But anyway, this material, then concentrates 7
just.as if chemicals, you know, from your -- if you have a 3
water softener in your house it concentrates the chemicals
. 9 that are in the water.
Okay, the calciums and that sort 10 of thing.
That's what the resin does.
And so when you 11 then regenerate it you hit it with some chemical -- like, 12 for a softener you hit it with sodium chloride.
13 Okay, with a Polisher Demineralized you would 14 hit it with caustic sodium hydroxide or sulfuric acid,'
- 15' depending on which resin.
So all of this then would remove 16 all the bad-actors, okay, and then leave it with supposedly 17 clean resin. Then you would mix all of this back together, 18 rinse it off and then sample it to make sure you had all 19 the regenerant chemicals removed.
But all of this process 20 then takes a lot of water.
That water goes through the 21 Regenerant Holdup Tank.
22 BY MR. MARSH:
13 Q
How much water was actually being regenerated 24 through the steam tube leaks?
25 A
Well, you know, the numbers -- you know, the e
I e
e w
36 I
first tube leak we had was something on the order of 60 2
gallons a minute.
That's a little bit of a misnomer because 3
you don't sit there and operate for very long.
I mean, 60 4
gallons a minute you got to come down quick because the 5
limit is one gallon a minute from the primary system.
6 So consequently you have to stop operating and 7
shut down.
Now, here is what happened to us on the first 8
tube leak, however, is that --
BY MR. MEEKS:
10 Q
What time are we talking about?
II A
January of 1981.
12 Q
Okay.
33 A
And that first tube leak we had a situation 14 where it actually filled up the steam lines with water 15 that was of a concentration because of the operation of the 18 secondary system, if you steam down, if you had radioactivity II coming into the steam generator, okay, liquid, radioactive 18 liquid, if that steams down then what happens to the radio-I' activity there?
It concentrates.
In fact, we had activity 20 that was approaching, and in some cases was a little higher, 21 than it was in the reactor coolant system in the secondary 22 system.
23 0
You're referring to the first leak?
24 A
The first leak, right.
That was our, worst leak that we've ever had, by the way.
But then -- so in our
37 I
first' tube leak also we were not -- you know, this was the 2
first time it ever happened to us -- we did not necessarily
)
3 know what the most efficient method was of cleaning this up.
1 4
You know, run the demineralizers?
We hesitated,to run the 5
demineralizers because we didn't know what the radioactivity l
6 levels would be if we took all of this material and ran it i
7 through our demineralizers, we didn't.know what the radiation 4
levels would be, we just didn't know that sort of thing.
9 And we opted to drain all these systems down.
10 We released what we could and we went back to the criteria.
II If the MPCs were too high we couldn't release it'offsite.
12 So that water, then, was put back downstairs.
13 BY MR. MARSH:
14 Q
When you say " downstairs" what does that mean?
15 A
Okay, I'm sorry.
Back to the Polishing 1,6 Demin Sump, back to the Spent Regen Tanks, and then processed 17 through the Miscellaneous Liquid Rad Waste System.
18 Q
okay.
19 A
And then, again, all of that distillate 20 would go and fill up the Demis RC Storage Tank and then you 21 would have to release from that to get that water out of there.
22 Q
So you would need to release from there when 13 the Demineralized -- DRCST, is that what you call it?
24 A
Right.
15 Q
When it would get full then you would have to j
e
._________._____--________-m_
38 l
1 move that water someplace?
l 2
A That's correct.
You had no other place to mov 3
it.
4 Q
How was the plant designed te move that water 4
5 out?
6 A
It was never designed.
It was never in any 7
design to -- I mean, that wasn't.
Not that I'm aware of, 8
at least.
I didn't have any part of designing that plant.
9 You know, I mean, I think at the time people looked at it 10 and said, "Well, we know we could move water from here to 11 there by using this method."
And, you know, people looked 12 at it and felt it was okay to do that.
And then that just 13 continued.
14 0
'They needed to remove the water from the DRCST 15 then probably back in 1981, would that be right?
16 A
There was times even before that.
We removed 17 water from the DRCST before 1981. See, any time you had a 18 leak in the secondary system.
For instance, we had steam 19 leaks and we had leaks of feedwater in the reactor coolant 20 system, okay?
We're talking in the reactor building, now.
21 So here you have water that is from the secondary that is not 12 contaminated, not radioactive, but it's leaking now into the 13 sump, into the reactor building.
24 Tha,t water now mixes with water that's leaked U
from the Reactor Coolant System.
Now, this goes into the c
m__-__
39 1
Miscellaneous Liquid Rad Waste System also, it's processed, 2
now it's tritiated also.
So you started out with feedwater 3
that was clean feedwater radioactivewise, mixed with water 4
that is coming from leakage from the reactor bui,lding into 5
the sumps, goes to the Spent Regen Tanks, then it's 6
proecessed and now you end up with tritiated water.
7 There were times before 1981 that we had 8
released Water from the Demin RC Storage Tanks.
Q So basically any time that you have secondary 19 system water that loses its integrity of being isolate'd in 11 that closed system of secondary, which is intended not to 11 be radiated --
13 A
Right.
14 Q-
-- any time it loses its integrity and mixes 15 with the primary system water in some way it then gets 16 radioactive as well because it's mixed with the primary IT system.
And because of that then all of that water then has 38 to be dealt with as rad waste and then goes through your l'
system on the rad waste as it was designed?
10 A
That's correct.
II Q
And then it eventually finds its way into the 12 DRCST Tank?
II A
From the Miscellaneous Liquid Rad Waste System as you process it through the evaporator the distillate or 14 15 the evaporative liquid is then -- actually, you know, goes
L e
40~
l from steam back to a liquid and then that liquid is processed 2
through demineralizers and then goes to the Demin RC Storage I
Tank.
That's correct.
4 Q
Okay.
5 A
But now we're talking -- if you 2-I want to 6
make it clear that there are two things that' can happen. One 7
is that you can have a leak that goes from the primary 8
system directly to the secondary system.
9 MR. MEEKS:
Steam generator tube leaks.
10 THE WITNESS:
Tube' leaks.
Il MR. MARSH:
Okay.
12 THE WITNESS: That then can contaminate your 18 whole secondary system. So now if I have a leak out in the 14 secondary I have to deal with that as being a potential 15 radioactive contaminated leak, okay?
16 Now, the other way that I can be affected is I?
that I can have a leak in the secondary system, either steam 18 or feedwater, that leaks in a controlled area.
For instance, I?
like, in the reactor building.
Then that water, which is 20 not radioactive, now leaks to the floor, gets into the 21' sumps mixed with water that is radioactive that you have 22 from normal leakage, goes back to the spent Regen Tanks and 23 is processed.
Those are the two primary methods.
24 But, see, now in that case I could still have 25 a leak in the secondary and not be a problem to.me as long e
41 1
as I didn't have that tube leak, that primary to secondary l
2 leak.
3 BY MR. MEEKS:
4 Q
When it leaks out of the secondary system it 5
goes into the drains and those drains take it to the sumps i
6 which are reactor -- they are controlled sumps because they 7
are sumps for the reactor --
8 A
That's correct.
j 9
Q
-- the primary system?
10 A
That's correct, if you're talking about the 11 reactor building now...
]
12 Q
Leaks from the secondary system 18 A
In the reactor building.
14 Q
-- in the reactor building?
15 A
Exactly.
16 BY MR. MARSH:
17 Q
So basically both of those methods that you 18 described,'then, based on your plant design and your 19 mechanisms for handling it would both be handled through 29 the Rad Waste process?
}
21 A
The leak from the secondary into the contain-12 ment building sumps would be handled totally through the 15 Miscellaneous Liquid Rad Waste System, correct.
24 BY MR. MEEKS:
15 Q
When the water goes through that system that's f
i e
e
~ 42 1
a clean-up system, is that what you're telling us?
The 2
processing is a clean-up system?
3 A
Yes.
' 4 0
You referred to it as being processed.
5 A
Yes.
6 Now, you have two Rad Waste systems.
One is 7
called the Coolant Rad Waste Syster and in some plants they 8
call them Boron Recovery Systems.
That's any water from --
9 that we let down from the Reactor Coolant System, is.
10 processed through an evaporator that looks exactly like the 11 Miscellaneous Liquid Rad Waste Evaporator.
But then the 12 bottoms are actually concentrated boric acid and we recover la that boric acid.
14 Now, you still get distillate from that.
That 15 distillate also goes to the'Domin RC Storage Tank.
Now, the 16 Miscellaneous Liquid Rad Waste System processed mostly 17 floor drains.
We do have some demineralizers and when we 18 transfer those demineralizers we get water that we use in l
l' the transfer process.
So it processes all that water, water 20 from the labs, from sampling reactor coolant or primary 21 systems,'.that water goes into the Miscellaneous Rad Waste 22 System.
And then if you had any leakage from the secondary l
18 system into the containment building or into the auxiliary 24 building, and in some cases from the auxiliary steam system, 15 which is nor ordinarily a radioactive system.
That water e
.----_._m
43 1
could also then go into the drains and then add to the total J 2
gallons that you have in the Miscellaneous Liquid Rad Waste 3
System.
4 We call the Miscellaneous Rad Waste System
)
5 black boxes.
And the reason for that is because you only 6
have a finite amount of storage capacity there.
Anything 7
that you put into that what you want to try to do is reuse 8
the water that you make there and you don't want to put I
water in there from anything that's not radioactive.
But 10 when you have these situations where you have a feed line II leak or you have a leak cf steam, a bad leak of steam, in 12 the reactor building then you do end up getting non-radio-13 active water mixed with radioactive water.
14 Now, this puts more water into the black box II than you can actually handle. So, therefore, you have to be 16 able to have some mechanism to rid yourself of this water.
17 Otherwise,'you know, the tanks go full and you hav6 no II place to put it.
II Q
And that deposit is in the DRCST Tank?
20 A
Right.
I Q
So if I understand this right -- ar.d I think II 22 I do, based on your explanation -- any time you have secon-23 dary leaks, like you explained, or tube leaks of the steam 24 generators, it ' overtaxes the capacity of the system?
U Of the Rad Waste System and also the storage A
4
44 I
capacity for the Demin RC Storage Tank.
2 Q
That's what I was referring to.
3 A
Right.
4 Q
That 450,000 gallon tank --
5 A
Right.
6 0
-- when you have leaks in it it's almost a 7
foregone conclusion, if I understand your explanation 8
right, that you're going to exceed that capacity and you 9
have to release water?
10 A
That's correct.
11 Q
Assuming there were no leaks what causes 12 water to be released from the Rad Waste System?
13 A
You mwan --
14 Q
In normal operations, if there is a cause?
15 A
If you have no leaks then there would not 16 normally be a release from the Rad Waste System from the 17 Demin RC Storage Tank, which is not really part of the Rad II Waste System.
Thers is actually another system.
But the 19 clean water from the evaporators, you know, they do go into 20 the DRCST Tank.
II Q
What system is the DRCST Tank in if it is not 12 the Rad Waste System?
I 13 A
I can't answer that --
j 14 Q
Okay.
15 A
-- from the standpoint of -- I'm not sure if
\\
45 1
it has a designation of DMW, you know, Demineralized Water, 2
or whether it's -- because, see, the water that comes from 3
the DRCST is normally water that is used for makeup water 4
to the reactor coolant system.
Because, see, that's clean 5
water, chemically that is very clean water.
An'd that water 1
6 then goes through demineralizers and then goes back into 7
8 BY MR. MARSH:
9 Q
So that's intended to be in the primary?
10 A
That's right.
11 Q
Okay, so the DRCST is part, through some 12 mechanism, part of the primary system?
13 A
Yes.
Because when you speak of the Rad Waste System that has connotations of water that is chemicakly not 14 15 clean, okay?
At least in my opinion.
The Miscellaneous 16 Liquide Rad Waste System, when I speak of that it's water 17 that's not chemically clean yet.
18 Q
Okay, when you say " chemically clean" th'at's 19 different than radioactively clean?
20 A
Yes, it's always considered radioactive.
So DRCST is considered radioactive but chemi-21 Q
l l
12 cally clean?
23 A
Yes.
24 Q
Rad Waste System is radioactive but not chemically clean, and therefore you would not want to put it 15 t
=
46 1
back into your Reactor Coolant System?
2 A
Exactly.
3 Q
Because that then deteriorates your tubing 4
also, those chemicals?
5 A
Yes, right, exactly.
6 Q
Okay.
7 A
You have certain criteria that you must meet 8
for the d:hemicsl makeup of the water that goes back into the 9
10 Q
Right.
11 A
-- you have certain criteria.
12 MR. MARSH:'
Ron, I want to slip one question 18 in here that has been disturbing me.
14 BY MR. MARSH:
15 Q
In the early days you said the engineers 16 were naive and underestimated the amount of water that would 17 be generated through this process in that they were 18 init.'aily sending it offsite or something.
19 A
No, I didn't mean -- I think they were naive 20 from the standpoint of the amount of water that they 21 thought -- and remember that I said the design was to meet 22 10 CFR 20 limits, not Appendix I limits.
But my own personal i
23 opinion.is that I feel that they were a little naive in the i
24 amount of water that would go through the Regen Holdup Tanks.
.l l
I 15 Q
Meaning that they had underestimated it?
l
.-------------.-_z-----.-
47 1
A Yes.
2 Q
Originally, then, what were they doing with it?
3 What had they planned to do with it?
4 A
Well, the plan was that all of this water 5
would go back to the Rad Waste System.
6 Q
And be disposed of as Rad Waste?
7 A
Well, I don't think -- that's what I mean 8
about them being a little naive.
You know, there is no 9
way that you could continue to operate and put all of your 10 water back downstairs.
11 Q
Okay, that's logical, I understand what you're 12 saying.
But the design and the process that they were 13 intending to operate under going to Rad Waste and disposed 14 of as Rad Waste, is that correct?
15 A
From a -- I don't know what size of tube leak 16 or what concentration of primary radioactivity that they 17 were designing to in order to move this water back down-18 stairs or whether or not they would move it offsite.
19 Q
Okay, but they weren't originally designing 29 thinking that they would have tube leaks.
I mean, they 21 were figuring originally, I assume, that we had a plant that 22 had a closed second loop and a closed primary loop and II everything was going to-work as it was designed and you would 1
24 have a finite amount of water in your Rad Waste System?
15 A
I really can't say that that's true or not. I a
4
i 48 1
can't really answer that.
I guess the only way that you 2
could answer that is to go back to the design engineers who 3
made the original design cales and all these things.
I don't 4
know the answer to that.
5 Q
okay, but in your opinion it wouid have 6
become. clear somewhere along the line that they were'having
(
7 a lot more water than what they were originally anticipating?
8 A
ell, I think -- I'm not sure it would have 9
1:ecome clear because I'm not sure that they would have 10 understood the implications.
Because we could operate.
I 11 mean, for instance, before, you know, the original tech 12 specs allowed us to release 1.25 curies of activity per 13 quarter.
14 I mean, we could release up to that and we 15 could even release past that for 10 curies per quarter up 16 to 20 curies per. year.
Okay, that was the original tech 17 specs which allowed us -- I mean, we could have released 18 that much material.
We have released less than, you know, 19 in the order of a half a curie for all the years we've 20 been operating of Cesium 137 and half a curie of Cesium 134 11 for all the years.
12 So, you know, original looking at -- and I 13 think that's what really threw people like myself off, you l
24 know, we were looking at what we were releasing and said 25 we weren't even coming close to this 1.25 curies, which is i
t
]
L-_----_-__--____________
49 1
what our first level was that was saying, " Hey, wait, folks, 2
we got to do something here because, you know, this is a 3
value."
4 And so I think that if the engineers were 5
looking at that they probably would have looked at that and 6
said, "Well, really, you know, there is not much of a 7
problem, you could just release this stuff down the creek."
s Q
Okay, well, when did that change?
9 A
That changed with the new RETs, the standard to Radiological Environmental Tech Specs.
11 Q
And what time frame was that?
12 A
That was, like, July of 1985, I believe.
It 13 may have been July of 84.
14 MR. MEEKS:
It was 1984.
15 THE WITNESS:
Okay, July of 84.
16 MR. MEEKS:
Right.
17 MR. MARSH:
Okay.
18 THE WITNESS:
So up to that time, you know, 19 that was the, you know, I think that the -- and that was 10 why people like myself that were in the plant were real 21 shocked when we -- you know, because we never approached 22 this 1.25 curie and all of a sudden we had 100 millirem 23 out here.
Because we weren't doing that calculation, some-1.
24 body else was doing that downtown.
25 BY MR. MARSH:
I
~~" -. - - _ _. -
50
.I Q.
okay, so up to July'of 1984 you were able to 2
make releases and as --
3 A
Up until October,_actually, of 84.
{
1 4
Q Okay, but in October you were told you weren't 5
going to make any more?
6 A
That's correct.
7 Q'
So you at that ti4ne understood that that was 8
relevant to the new RETS?.
You had said earlier that Miller 9
told you in october that you weren't going to make any more 10 releases?
11 A
Correct.
12 Q
And that you, if my memory serves me well, la you didn't say why he was telling you that, he just came.and 14 said that's the new policy?
15 A
No, I think I asked, I may have asked why 16 but I don't remember that I got a reason other than that's 17 what' management said we were going to.
18 Q
okay, so at that time you weren't --
19 A
"You're going to no longer regenerate the 20 resin."
11 Q
But at that time you weren't aware of the 22 new RETS?
23 A
Oh, no, no.
We were aware of the RETS at 24 that time, yes.
25 Q
okay.
a
'51 1-A We were aware that we no longer had the --
2 that the 1.25 curie and all those things were gone, but we A
were not aware that the number of gallens'that.we were 4
releasing would have an effect -- at least I didn't, because 5
I wasn't looking at that part of it -- would have an effect 6
on meeting the 10 CFR 50 Appendix I values.
7 Q-Okay.
8 A
You know, it goes back to the -- we felt if 9
we were meeting the lower level of detection Se to the 10 minus-7, which is in our tech specs, that we thought, all.of 11 us thought, that we would comply with meeting 10 CFR 50 12 Appendix I.
15 Q
Okay, I understand what you're.cying.
14 MR. MARSH:
Go ahead.
15 BY MR. MEEKS:
16 Q
Getting back to.the 1981 steam generator tube 17 leak, which when you first had that leak it was 60 gallons 18 a minute?
19 A
I think when it first started it was not 60 20 but it --
21 Q
Progressed up to that?
12 A
-- progressed up to approximately 60 gallons 13 a minute, if my memory serves me correct.
Yes.
24 Q
Okay, what is your recollectica of the amount 15 of leakage from the steam generator tubes through the years?
I I
I
9 52 l l'
You had'60 and you said that was the greatest you --
l 2
A Yes, I couldn't give you --
l 3
'Q
. Bring us through the years on-what kind of 4
leakage factor we're talking about.
I couldn't give you, you know, e.kact numbers,-l 5
A 6
but they were not anywhere near that.
I don't think they 7
were any more than -- that information is available.
I. don'G 8
have it right now on the top.of my head.
9 Q
I understand.
to A
But they were not of.the. magnitude of'the original first tube leak.
They.were in the order of 2 to II 12 5 or something like that.
But I can't give you the exact-13 numbers on each one.
14 Q
Okay, like in 84, give me a-ballpark figure 15 what you recollection would be of leakage.
16 A
In 84 I think we had, like, three tube leaks, 17 you know, practically back to back.
And I think they were
-c 18 I can't say exactly what the numbers,are.
But something 19 probably in the order of 2 to 5 gallons per minute, something 20 like that.
But we had also been operating up to that time 21 with about a 0.07 gallon a minute continuous leak.
22 Q
And it was okay to operate at that factor?
23 A
We were able to operate with that limit, yes, 24 with that value.
25 Q
What was the tech spec limit that required you e
o
________._____-______._____._____-__._-m
53 1
to stop and fix the --
2 A
One gallon a minute.
3 Q
one gallon a minute?
4 A
Yes.
5 Q
Okay, so in 84 your recollection'in those r
6 three leaks, then they exceeded the tech spe'c of one gallon c
7 a minute?
3 A
Yes, that's correct.
And that's why we had to e
shut down.
to Q
But you operated more or less with a -- what 13 did you say,.07 --
12 A
About a.07.
13 Q
-- leak?
14 A
Yes.
Gallon a minute.
15 Q
And then when you determined that it exceeded one gallon a minute then you shut down and had to find the 16 17 leak and fix it?
15 A
Right.
19 Q
So that.07 gallon a minute would also create 20 a need to take water out of the secondary system and put 21 it back into the Rad Waste Systam?
12 A
That's correct.
In addition to the leaks you would have, if 23 Q
at the time, any secondary pump leaks or 24 there were any 25 valve leaks, anything like that?
I k
54 l
1 A
That's correct.
j 2
Q I think it's been reported that 787,500 l
1 3
gallons of water were released from the DRCST Tank to'the i
4 RHUT Tank in 1985.
5 A'
That would only be -- see, if you look at it 6
that would be seven A tanks, which is 100,000 gallons, or.
7 it would.only be 3 if it was the 200,000 gallons.
8 Q
Right.
9 A
So that's not -- I mean, if you start talking 10 about moving water from the Regen Holdup Tanks backstairs 11 downstairs that's not a whole lot of those.
12 Q
What is the source of those 787,000 gallons?
13 A
Water that was from the recondary system. I'm 14 assuming that's probably what it came from, probably from 15 the secondary system.
And I'm not sure.
There could have 16 also been -- what year, this is 857 17 Q
This is 1985.
18 A
Okay, there was also -- you know, any leaks 19 from the primary system which come into the secondary will 20 also go over to there.
So, for instance, we had that high 21 point vent leak onithe:.B~line.which was all secondary water 22
-- I mean, sorry, all primary reactor coolant water. So any 1l primary. reactor coolant water also can then go into the 24 Miscellaneous Liquid Rad Waste System and then that water, 15 when you have to process that, would go back to the Demin RC 1
_L-.____.--_.
55 1
Storage Tank.
2 Q
This was in 1985, this high -- what did you 3
call it, high point?
4 A
High point vent.
5 Q
Vent?
Leak?
6 A
Yes.
I believe that was, like, July of 1985, 7
or June, something like that.
8 Q
And just very briefly explain what that was.
9 A
Okay, that was -- there was a vibration-induced 10 defect ina primary system piping that was on the vent line 11 on top of-'the -- what we call the B candy cane on top of 12 the primary loop which comes from the reactor.
And that 13 leak was reactor coolant leak right there, it came out of 14 there, went down to the sumps and then that water was 15 processed.
16 And also -- and I don't have the exact numbers 17
-- but any~ time you come down and you have to boiate your 18 system, okay, you borate the Reactor Coolant System to a 19 higher level.
Now, when you start up you have to dilute that 20 boron.
So in doing that you end up letting a water down, 21 adding a lot of water to it, but you and up processing _ that 22
. water also.
So you get some water from that.
23 And then we did have some water, too, still 24 that was in the secondary syctem also that each time we 25 had a tube leak then we had to process the water.
56 1
Q'
'You mentioned, like, in 1984, up to October 2
of 1984 you could be releasing an RHUT tank every other day, 3
is that what you --
4 A
Yes, something like that.
That may not be 5
exact.-
.6 Q
So say we have'in the neighborhood of, oh, 7
150 to 200 RHUT releases a year and we're talking on an 8
average, say, 150,000 gallons -.just an average of the two.
9 of them --
10 A
Yes.
11 Q
-- I assume when you get about full that's 12 when you' release them?
33 A
Right.
i 14 Q
So on an average, say, they would be 150,000 15 gallons upwards of 150 to 200 times.
And that water --
16 what percentage of that water would be coming from the II DRCST tank?
18 A
I don't know.
I couldn't give you an answer.
With the three leaks you had in 1984 would you 19 Q
say the majority of the water with those leaks -- because of 20 21 the leaks in 1984 --
22 A
Any water -- I'm sorry, I didn't mean to stop 23 you.
24 Q
Go ahead.
Any of the water that was additional water to 25 A
t
57 1
the balck box had to have come from a secondary system.
2 Because we did not -- we would not add water from -- see, J
we have the capability of. making up demineralized water to 4
the black box, but we never have had to do that.
So any
?
5 water that came in;o that black box came from he secondary 6
system.
7 MR. MEEKS:
Okay.
8 Could we just take a quick break to stretch 9
here?
10
-(Whereupon, a brief recess was taken.)
j 11 MR. MEEKS:
On.the record.
la BY MR. MEEKS:
15 Q.
Now, if I understand the Safety Analysis 14 Report it states that the system is designed to any nnusual 15 occurrences like minor tubes, it can handle. And I assume 16 that any minor leaks.
But from what you're explaining here practically any leaks at all of the kind you have described 17-38 takes the system's capacity, retention capacity, over its I'
limits.
So in that sense it seems like the Safety Analysis Report as well as the design is deficient in the ability of 10 the plant capacity to withhold water, to retain water and II process it, based on -- it said in the Safety Analysis 12 Report -- periodic unesual occurrences like small. or minor il steam generator tube leaks, based on what your explanation 24 15 is that you've told us today.
t 4
e
58'
'l Am I understanding it correctly?
2 A
I think from the standpoint of the original 3
design and people'looking at the original' tech, specs with' 4
the curie limits that were allowed and.with insuring you 5
comply with 10 CFR 20 limits, then I think that they may 6
have been reasonably close even though they gave us no 7
method of at least systemwise removing water from the
. 8 Domin RC Storage Tank. And I think one is that this was the 9
nation's first dry site nuclear power plant.
10 And I feel that in my own opinion that the 11 NRC didri't really understand the. implications of being a 12 dry site and the utility didn't understand the implications 18 of a dry site.
And as we changed and were required to 14 comply with 10 CFR 50, Appendix I, I don't think either one 15 of us at the time looked at that in enough depth to insure 16 at the time that we vould be able to do that.
17 So from the standpoint of Appendix I and the 18 original tech specs they may have -- the design may have 19
,been such that we could have operated with these leaks as 20 M ng as they weren't real major ones and as long as we 21 didn't have real bad fuel and the radioactivity in the 22 primary system was not exceedingly high.
28 Q.
It's your understanding in the plant design that 24 there wasn't anticipated to make any releases of radioactivity 25 offsite?
E o
a-
_--____n_---_--_-___.a-_____..
a---_____
L j
59 1
A I don't think that's true.. My original -- at 2
least what I was taught over the years and what I read, at 3
least, was that we would periodically do radioactive 4
releases as we had primary to secondary leaks.
5 Q
Okay.
6 A
That was my understanding.
7 Q
Fred, you have explained that the system was-8 designed normally not to have -- or there was~no necessity 9
to make any releases or to take any water out of the DRCST 10 or the primary system, that the plant operating in its normal Il mode did not require any -- did not require water to be 12 relea' sed from the primary system in normal mode where you 13 didn't have any leaks of any kind?
14 A
That's correct.
15 I mean, if you had. a complete tight system 16 and never had a feedwater leak in the reactor building, neves 17 had a steam leak, major steam leak in the reactor building, 38 never had a primary to secondary leak then you would not I?
have to have had any radioactive releases.
20 Q
Now, other than the modification from the 21 DRCST to the REUT are you aware of any releases that have --
or any water being removed from the primary and or Liquid 22 II Rad Waste System or the Miscellaneous Rad Waste System, 24 removed from that system and released to the environment?
15 A
At the first tube leak I think we had the
____m______________m_._
60 1
piping system set up that we could release water'from the l
i 2
Miscellaneous Water Holdup Tanks also.
But that was basic-3 ally that both lines came together and you could either 4
take one or the other.
The quality of thewate,r, both 5
radioactive and chemistry, were exactly the same.
It's 6
the same water.
It's just that it was coming from a 7
smaller tank, the Miscellaneous Water Holdup' Tank, which is 8
3000 gallon tank, rather than coming from the Demin RC 9
Storage Tank.
10 Q
Okay.
II A
But that's the'only, you know, right off
'12 the top of my head that I can think of, would be the only II other place that the water would come from.
14 Q
Now, I'm referring to just normal 6parations, 15 would there be any cause to remove water?
In other words, 16 in a normal functioning of the plant what would be the 17 occasion to remove water from the primary side,. including 18 its clean-up systems?
I?
A In the normal operation mode where you did not 20 have any major leaks, okay, yeu're always going to have some 21 minor,' leaks.
So it may take some period of time to build 12 up the inventory, okay.
So you may, you know, bulid up-some 13 inventory that would require you to release.
I don't have, 24 you know, any specific numbers but I'm just saying that it 15 could do that.
1 l
61 1 1
But generally the whole idea is that if you 2
have no leaks, you know, no feedwater leaks, no leaks from 3
the secondary system into the drains, or if you had no 4'
primary to secondary leak, all the water that'is kept within 5
the_ Miscellaneous Liquid Rad Waste System and'the_ Coolant L
6 Rad Waste System would be the same water.
You would use 7
the same molecules over and over again.
3 Q
okay.
9 Wasn't there a time when.they shipped water l
10 from the primary system offsite?
11 A
Correct.
12 Q
Could you explain your knowledge of that?
13 A
okay, I can't give you exact dates, but it's.
14 all in the -- it is in the annual reports.
It tells 15 exactly when we did it, how many gallons we did, and that 16 was a period of time in which we did -- at that time we had 17 no method of solidifying the liquid onsite, okay?
So this 18 water then was trucked and it was really basically tritiated 19 water that was sent to Beatty.
And there were some that 20 were sent --
11 Q
Who is Beatty?
12 A
Beatty, Nevada.
The disposal site. I'm sorry.
13 The disposal site.
And then we did send some 24 also to -- and it was my understanding that at Beatty they
'ook this water, mixed it with concrete, then put it in a 15 t
"a
.____i_______________________
62 1
burial site.
And then there was water at one time sent to 2
Todd Shipyard in Texas, also.
And that water, it's my 3
understanding at least -- and I was never part of a y i
4 Quality Assurance, or anything, of that -- was that they 5-demineralized that water, cleaned it up, and then met their 6
specifications for release and released part of that liquid 7
then into Galveston Bay or whatever they did with it. I'm 8
not real sure.
9 Q
Tell me the name of that place again?
10 A
Todd Shipyards.
11 Q
And --
12 A
And if you look at the annual report it tells 13 exactly how many gallons were shipped and all that.
14 BY MR. MARSH:
)
15 Q
Where did they take that water from, though?
16 What consolidation point did they take it from to --
17 A
Now, that water was not a distillate, okay?
18 But it was the bottoms.
Okay, the bottoms would be the 19 concentrated part.
Now, at that time we didn't coneyntrate 20 it that much, okay?
So we were then able -- I mean, just the 21 fact that we were doing it like that we were able to get 22 rid of, you know, a lot of liquid.
So therefore -- see, at 23 that time it was possible that you could have concentrated 24
- that more.
25 Like, for instance, now we concentrate that t
e m
)
63 1
down to 12,000 ppm boron.
I don't knoi what the concentra :
2 tion in that -- it was probably a couple of thousand ppm.
3 So you could have taken it down more.
But the radioactivity 4
levels may have been too hight for you to ship it, okay, so l 5
you didn't want to do that.
6 But the fact that you didn't have it concen-1 trated, that meant that you had less distillate coming off a
which would go over to the'Domin RC Storage Tank. So the s
more you hauled off that would: teep your inventory down in r.
10 the black box.
33 Q
So you were taking the water from the black 12 box?
13 A
That.'s right, that's correct.
l
(.
s.
34 Q
Well --
15 A
And this was -- instead of being distillate 16 water, though, or water that was clean this was the bottoms l
17 water.
See, like when you take an evaporator and you put-18 in -- you keep putting in water and you take this -- you 19 evaporate the water off, the steam comes over, you condense I
20 that, that was the water that was going to the Demin RC 21 Storage Tank.
22 BY MR. MEEKS:
23 Q
Through the boron evaporator?
(
24 A
Either one.
25 okay, but then the bottoms, this bottoms, now, 4
s
,--~mu----------.-------._:------------w_--
-A- - -
64 I
was water that concentrated then anything that came in. We 2
have boron in the Miscellaneous Liquid Rad Waste System 3
also, because if you have leaks from.the primary system, 4
which has boron in it, then you have boron there.
5 So that was the water that was used to -- that 6
we shipped out.
7 Q
So it's coming out of the black box, then, the 3
Miscellaneous --
9 A
Yes.
10 Q
-- Liquid Waste System?
11 A
Yes.
1 12 Q
What time frame were these shipments?
13 A
I can't give you a date.
That's in the records.
14 Q
Can you give me a decade?
Was it in the 70s.
15 80s?
16 A
It was in the 70s.
It seemed like it was the 17 late 70s.
But it's all in the annual reports.
18 Q
Okay.
19 A
It's all in the annual reports.
20 0
Why did you stop the shipments?
21 A
Well, because at the time it was legal to 22 ship radioactive liquids, okay?
But then there was no 23 longer -- the regulations changed, from what I recollect, 24 that you no longer could ship radioactive liquids.
And 15 obviously from a -- even though they were not a hazard from 1
l
65 1
a, you know, a hazard standpoint that we know of like toxic 2
materials and that sort of thing, because of the low concen-l 3
trations.
But the political impact of that was such that, i
4 you know, you wouldn't want a truckload of radioactive 5
liquid being involved in an accident and have the -- the g
political ramifications really were just -
it was too much 7
of a -- but legally,'though, they -- from my recollection.
3 it was!.no longer allowed to ship radioactive liquids.
Any shipment had to be encapsulated, any 10 liquid had to be encapsulated.
And so that required us then gg to bring in a contractor and we could then, by encapsulating it, take the concentration up higher so that we could have gg g3 less of a volume now.
We would end up with less of a volume 14 from the standpoint of bottoms waste but we end up having more of a volume now as far as the distillate that came off 15 is of that.
17 Q
Okay.
Is So with these leaks and the water you had to 19 release a modification was made to transfer the water from 20 the DRCST tank to the RHUT tank.
What was your involvement 21 in that modification?
12 A
Well, the first tube leak myself and Ron 15 Lawrence were given the responsibility -- he was given the 24 responsibility from the standpoint of piping and valves 15 and everything we had to do to implement getting -- to move L-
66 I
the water around.
And I was given the responsibility from 2
the standpoint of Chem Pad to insure that -- you know, to 3
expedite sampling and make sure we continued moving the 4
water and getting it analyzed so that we could move the l
5 water.
G.
And we worked together pretty much as a team l
7 to accomplish that.
And he pretty much -- he was the a
engineer, he did the necessary paperwork or whatever to get 9
the piping installed and to make the modifications to do 10 that.
II Q
And, once again, your responsibilities?
Just 12 go over that again.
la A
Okay, my responsibility was from a sampling 14 and analysis and insuring that we could expedite -- you know, 15 that I had people available to expedite getting the analysis 16 and doing the counting and getting the paperwork, b' cause e
you had to have a release permit for everything you released.
17 15 Getting the paperwork and getting all the documentation so 19 that we could, you know, continue to move the water or 20 whatever was decided, and where the water was going to go.
11 We worked, together, you know, to do that sort of thing.
22 Q
Okay.
13 You say this was in conjunction with the 24 first --
Yes, that was the first steam generator tube 15 A
--e e
f
i 67 1
leak.
And then as they progressed -- and I can't -- you 2
know,.my' memory is not that good to say -- but as it l
3 progressed with different tube leaks then we had different j
4 people-involved in doing those things.
But they followed 5
a lot of the same patterns as the original, you know, the 6
first time we did 12.
7 Q
What authority allowed you to do this?
In 3
other words, what modification was done under what authority 8 9
A I don't know.
I can't answer that.
I really 10 didn't have -- you know, they didn't come to me and say, you 11 know, "Can we put PVC from here to there?"
That was r.or.,
11 you know, asked to me.
I think, you know, at that time I 13 think everybody didn't think there was anything wrong with 14 doing that.
I mean, I truly believed that.
It was just, 15 you know, in the situation that we were in I think everybody 16 thought we were doing everything legal, all right.
I stilt 17 am not --
18 BY MR. MARSH:
19 Q
It sounds like you are drawing a conclusion 20 based on some conversations that must have taken place or 21 discussions that took place.
How do you draw the conclusion 12 that no one felt they were doing something wrong?
13 A
You know, it had been done before, before 8'..
24 I can remember that, you know, basically we were called in 15 a meeting and Pierre was leading the meeting and says, 'you s
uma_-_-._.
2
.68 I
know, "Theos people -- you'know, this parcon has this 2. responsibility and this person has this responsibility" --
3
'O Pierre is?
4 A
Pierre Oubre.
I 5
o cubre?
6 A
Right.
7 And he didn't say, you know, he didn't give And ;
[
8 specific directions on how this could be accomplished.
9 I don't really know who gave, you know, approval or, you i
10 know, the stamp of approval to say, yeah, we can do that, i
11 I don't know.
12 BY MR. MEEKS:
18 Q
When was this meeting with Pierre Oubre?
Sometime right after the event and the l"eak 14 A
15 in 1981.
16 Q
Okay, part of the subject matter of that meeting was the modification and who had responsibilities a
17
[
)
It with what?
I' A
Well, I can't say that for sure.
I'm just saying that from my recollection it is that Ron Lawrence was 20 given the responsibility as far as the piping systems and 21 making the modifications, because he was the engineer. And J
L 12 13 I was '..the, Chnm Rad Repres2ntative.
And so, you know -- and it wasn't anything written that says, you 'know, "You do this 24 15 this and this."
It was just mainly a meeting to clarify, to 1
e e
-__._--m._
l 69 l
1 make sure everybody is aware that if Ron Lawrence needs 1
2 support'from Maintenance to get this work done then, you I
3 know, give him the support.
4 Q
Okay.
5 A
And if Fred needs support in order to get 6
the sampling done, operations should give him the support 7
to do that.
That type of thing.
8 Q
Were you involved in a subsequent -- were you 9
involved in any subsequent meetings where these types of 10 things were discussed?
31 A-I don't remember any meetings.
And I don't 12 ever remember even discussing whether or not we could do II or not do any of these things, you know, that were do,ne.
14 Q
In any of the meetings -- this particular-15 meeting you're talking about or any other -- what is your 16 recollection on reporting this modification to the NRC7 37 A
None that I'm aware of.
18 Q
You're not aware of any discussions where it I'
was brought up that this modification should be made known 20 to the NRC7 11 A
No, sir.
12 BY MR. MARSH:
13 Q
I would like for you to describe a little bit 24 further this meeting in which Pierre ubre gaye,the instruc-15 tions.
How did it come about, who called it, what was the s
L L
I 70 1
nature of it as far as its urgency, was it abrupt or "do 2
this, do this, you're responsible for that," gave specific 3
instructions, did anyone express concern about what they 4
were doing, that sort of thing?
I V
l 5
A From my recollection, you know, it was pretty I
6 much how I said. And, you know, this is some time ago and 7
a lot of things have happened.
But it was basically a 8
meeting in which, you know, assignments were made to 9
accomplish, you know, certain tesis but they were not 10 specific tasks.
You know, they were, as I said from my 11 recollection, Ron Lawrence was responsible for the piping 12 and for working with Maintenance to get whatever changes 13 had to be made to move water.
14 And I was responsible to expedite from the 15 standpoint of sampling and analysis and paperwork in order 16 to document each of the releases that were from the Regen 17 Holdup Tanks.
To my recollection there was never Eny csncerE 18 or any question that what we were doing needed notification I?
to the NRC.
I don't think anybody there --
29 Q
Would that have been your responsibility to 21 concern yourself about that or would you have assumed that 22 someone else --
13 A
If I would have felt that it was something 24 that I -- you know,, that we were in violation of something 25 in our tech specs or something like that and I knew about
___s_--__m
_m.
m.._-___.
71 1
it, yes, I would have brought it up.
For me, at least -- I 2
can only speak for myself -- I didn't realize or didn't know 3
that that was wrong.
You know, we've done -- you'know, it's 4
a common practice in these power plants to move water from 5
one system to another, not necessarily radioactive, but just 6
to move water and, you know, and maybe have temporary piping 7
or hoses to do things.
8 Q
Can you tell us who you recall being at the 9
meeting?
10 A
Roger was there, I was there, Ron Lawrence 11 was there.
There were other people there but I don't know 12 who they were.
I mean, I can't remember who they were.
13 Q
Was George Coward there?
14 A
The first meeting in 19817 15 o
Yes.
16 A
I don't remember.
17 Q
What was cubre's position at that time?
18 A
He was Plant Superintendent.
19 Q
Would it have been normal interchange between 20 the Plant Superintendent and you and Ron Lawrence for him 21 to have a meeting such as that and to give you these type 22 of instructions?
13 A
That's how the first one was done.
I mean, 24 some of the ones afterwards were done similarly to that.
25 You know, basically get the managers or the superintendents e
O
72 I
together and then say -
you know, they probably had an 2
idea before the meeting started who was going to be assigned
)
3 what roles and just have everybody there.
And it's a common practice to do that from the standpoint of getting 4
5 the cooperation from all of the other work groups to 6
accomplish the task that you have been assigned.
7 For instance, if I'm given a task to do --
especially if you are not at a high level and you have to 8
9 rely on people that are at a higher level than you to 10 accomplish your task.
Normally that is a common practice Il that the managers will get the people together and say, "I want you to give Ron Lawrence the support he needs in order 12 18 to make these necessary changes, I want you to give Fred the support he needs in order to expedite moving the 14 15 water offsite.
And that's a common practice, managerial 16 practice, to do that, to get that support.
17 Q
Did you take notes or make any entries into 18 your daily log as to --
19 A
No.
20 Q
-- your instructions?
[
21 A
No.
22 Q
Were you told at all to document or create a memo to the file or in some way explain your plan of 28 action of how you were going to accomplish your task?
24 25 A
Not that I remember.
I
73
)
l 1
0 Were you in any way specifically told not 1
2 to generate any writing on it?
j 3
A No.
I was told after it was over to dome up 4
with a procedure in order to -- you know, so that the next 5
time we had a tube leak that I could -- that we would have 6
a complete procedure that would cover everything that we 7
do.
And I didn't ever do-that because I just absolutely 8
didn't have the time.
9 Now, I was tasked afterwards to come up with 10 a list of items that we needed modifications on to enable 11 us to more easily handle water from the contaminated 12 secondary system.
And I had some meetings on that but I 13 was not necessarily successful in getting all of those 14 recommendations implemented basically because once the 15 plant was back operating then that didn't become a priority 16 so therefore it was difficult for a person, at least in my 17 position, to get a lot of these things accomplished.
18 BY MR. MEEKS:
19 Q
Who asked you to implement or draw up those 20 procedures for --
t 21 A
Pierre.
22 0
-- transferring the water?
23 Give us again exactly what he wanted you to do, 24 A
Well, what he wanted was a procedure that would 25 say exactly how we handled the water.
For instance, where I
I
~
L
.74' I
did we drain the steam lines, how did we drain those, how 2
did'we flush the steam lines, how did we drain the feed lines 3
where did we drain them to, what valve did we come out of,
'4
' how did we flush them, where did the water come from,.how 5
did we flush the hot well, what did we do with'the water?
6 That type of thing.
7 Q
He also wanted you to implement in those 1
8 procedures sampling instructions?
9 A
It wasn't specifically -- no, that was not i
IO part of the guidelines.
The guidelines for that, from 11 my recollection, were -- because the sampling was done all 12 the time.
You know, we sampled -- okay, there would have 13 been cases in which, for instance, you know we may have 14 - done some sampling in a syster., say, to determine what are 15 you going to do with it.
16-For instance, the steam generators themselve, 17 even though that was secondary water, as the tube leak 18 occurred and that boiled off -- as I said, we've had 19 activity in that steam generator higher than the activity 20 in the Rad Coolant System at the time once we shut down. And 21 we also had higher boron.
So, you know, we took that water i
22 used hoses all in.the -- that is, within the controlled area 23 and used hoses on a discharge of one of the drain booster 24 pumps and moved it back into the Coolant Rad Waste System 25 to we recovered all that boron and didn't go back to the --
t 1
m
--asu----.s-,--
-m----------x------
--a
75 1
i didn't go to the Miscellaneous Liquid' Rad Waste System 2
where all that would be, then, actually disposed of. We 3
were able to recover that liquid.
4 Those kinds of things is what he wanted to, 5
you know, be included in that procedure.
But I absolutely 1
6 did not have the time to do that, nor did I have the resource si 7
to complete that.
3 Q
This instruction from Oubre to you was in 9
conjunction with the 1981 --
10 A
Yes.
33 Q
Did you ever tell him that you don't have the i
12 resources to take care of that request?
13 A
Well, I told him a number -- I told;hbh, from 14 my recollection, that I wasn't able to do it. And his 15 answer, if I remember correct.'n was, "Well, just keep j
i 16 doing it, you know, do whatever you can."
i 17 Q
Did you mention the reason why you couldn't 18 do it?
19 A
Well, yes.
20 Q
And --
11 A
From my recollection, you know, I don't -- I 12 guess that I will just retract that statement and say that 23 I don't really remember.
I remember some conversations with 24 him but I don't remember the exact words.
15 Q
Ckay.
But it's your recollection that the 9
4
76-1 roacon you didn't do that was b2causa of resourcas?
l 2
A Right.
And I didn't really have the time, you
.3 know. I had other, su know, responsibilities that were going 4
on, you know, at the same time.
I didn't have, you know, l
5 unlimited resources and people.
Because I had'to rely a lot s
1 6
on'cther organizations to get some of this information.
7 Q
Okay.
8 What management controls did you utilize to 9
assure that water transferred from the DRCST to the RHUT 10 was properly sampled for radioactivity?
II A
7? ell, see, at that time we sampled -- you 12 know, there may have been samples on-the Demin RC Storage 13 Tank beform we moved it-over but there wasn't -- you know, 14 we were going -- at least from my experience in most of 15 the nuclear power plants in the country, you know, you move 16 the water to the tank that you're going to get rid of, that 17 you're going to be disposad from, and that's where you take 18 the sample.
And that was always'taken in that manner.
19 Q
Why don't you explain that process?
20 A
Okay, when -- if water was moved from the 11 Domin RC Storage Tank you would -- we would really sample it 12 from the standpoint of seeing what the tritium levels were 13 from an MPC standpoint and then put the water over into the 24 Demin RC Storage -- or into the Regen Holdup Tanks, and thenwith--youknow,alotodthiswaterthatwewerc 15 f
l' L_______-_____-_-____________
7 7~
I talking about before as far as the regeneration of the 2
demineralizers and the non-radioactive demineralizers would 3
then fill the tank up naturally and t en when you got ready 4
to sample you would do the complete nalysis on,it like you 5
would normally do at release 6
BY MR. MARSH:
l l
7 Q
Maybe I didn't understand, but did you in fact f
8 do chemistry sampling for radioactivity before the water was
]
9 moved to RHUT?
10 A
Not in all cases, no.
Q Sometimes you would move it from the DRCST 11 12 directly to the RHUT before you would sample it?
13 A
We would have a sample on it because we're 14 required to take tech spec samples on that at, you know, If like a weekly basis or something like that.
So, you know, 16 you would take a look at it and say, "Well, what was the 17 tritium concentration in that?"
Well, it's whatever it is.
18 And you would say, "Well, in order to make sure that I have I?
some dilution there so I don't have too high of an MPC for 10 tritium in the Regen Holdup Tanks then you would just say 21 I'll take 20,000 gallons or 50,000 gallons and put that over 22 into the Regen Holdup Tank.and let the Regen 'taldup Tank fill 13 up naturally with other water and then take a sample on that 24 before you released."
25 BY MR. MEEKS:
~
t a
m
J
~78 1
'Q.
When you did sample, though, it was just for 2
tritium in the DRCST tank?
.3 A
There may have been times when they did a 4
gamma' scan on it.
5 Q
That was in conjunction with the normal 6
surveillance and scampling of that tank, ' the ' RCST..That's D
7 what I understand you're saying.
In other words, there-8 were times when that tank, whether it was on a weekly basis 9,
or whatever the frequency, it was sampled?
10 A
Yes.
Il Q
For chemicals as well as tritium as well as 12 gamma?
IS A
Yes.
14 I'm not sure if -- I mean, I don't know, you.
15 would have to check the chemistry. manual.
And it has been 16 some time since I've been directly involved in that.
I don't 17 know if it was required to do a gamma scan every_ time they 18 did a sample.
I don't know.
I?
Basically what we said, okay, the criteria 20 for whether or not we would move water into the Demin RC 21 Storage Tanks from the tanks downstairs that-came from the 12 evaporator was that if it had any gross beta then we would II put it to the Domin RC Storage Tank.
If it did not' have any 24 gross beta then we would put it into the Miscellaneous Water 25 Holdup Tank. ' Because the Miscellaneous Water Holdup Tank is a
7-____
79~
\\
-1
.used throughout the contcolled area system to provide water:
2 for decontamination.
3 So we didn't want to have water that contained 4
any amount of beta contamination.. Because if you had beta 5
you probably had some -- you could have had some' gamma 4
emitting isotopes also.
7 BY MR. MARSH:
6 Q
So those gamma emitting isotopes would be in 9
the DRCST7 10 A
They could be.
But it would. depend, again, on 11 the criteria you used to' determine how long that you count 1
12 it.
18 Q
Okay, I guess I -- maybe you can explain it le differently so that I will understand, but it sounde to me 15 like what you're doing is moving water that has been contami-16 nated with radioactivity through the leaking,. tube leak 17 process, that has contaminated your secondary system, that 38 ands up in the RHUTs, that'is too radioactive to release.
l' 19 okay, so that is then moved --
20 A
Okay, you people got to keep separated from 13 when the Appendix I or when the RETS went into -- in July 21 of 84.
You've got to keep that separated from any of the 18 previous times before that.
14 Q
Okay, so we're talking about 1981.
So it 15 wouldn't have precluded you from releasing'it at that time, 1-
\\
e p
80 1
possibly?
2 A-
-That's correct.
3 Q
Possibly.
4 A
Correct.
5 Q
But in some cases it would then have to go 6
back through the Rad Waste System in some way --
j 7
A That's correct.
8 Q
-- after it had been scrubbed in some process.
9 Well, then it could end up back in the DRCST tank?
10 A
Right.
11 Q
And that could in fact contain radioactivity 12 but it would be chemically clean water?
15 A
That is correct.
f k- '
14 Q
Then that water -- what you're saying is that 15 water, then, could be pumped back.into the RHUTs'through
(
16 this modification that was put together and then released 17 to the environment?
I 18 A
(No response.)
I?
Q And you would not check in all cases until it 20 had already been moved to the RHUT7 i
21 A
Well, we were checking it to make sure that II
-- you know, we had an idea'of the gross beta and the tritius 13 I'm just saying I'm not sure whether a gamma scan was done 24 every time.
25 Q
So it wasn't an absolute process?
i e
L 81 1
A You had an idea of what the tritium was so 2
you would know -- and based on the amount of tritium how 5
much you would have to dilute.
4 Q
So at that peint in time you knew that you i
5 were moving radioactive water into the RHUTs to release 6
from the plant?
7 A
Sure.
8 Q
And you would then monitor it?
9 A
Yes.
We monitored it always anyway.
10 Q
okay.
11 A
But since 1981 every Regen Holdup Tank that 12 has been released has been monitored.
IS Q
All right.
Now, the way you have descr,1 bed 14 it based on what you understood your specifications of 15 operating the plant to be caused you no concern that you l
16 were violating any specifications or operating procedures 17 or policies?
18 A
Correct.
39 Q
And required no additional reporting to NRC 20 or anything of that nature?
21 A
That's absolutely correct.
12 Q
Are you familiar with any discussions at all 18 about that and whether that was proper?
24 A
I'm not familiar with any discussions at all 15 of the impropriety of doing that.
-A-"------------------n-a---- - - - - - - - _ _
82 l
1
-Q Okay.
[
2 A
In fact, you know, I had no idea whatsoever 3
that anybody even questioned that.
4 Q
All right.
y 5
BY MR. MEEKS:
l 4
Q Why did you dilate the water when you brought 7
water out of the DRCST into the RHUT, why was it diluted?
L 3
A The tritium could be, you know, on'the order 9
of 10-1 The MPC for tritium is, like, 3 X 10~3 So you're le looking at a factor -- you're looking at, if it was all.
Il tritium -- you know, I have a 200,000 gallon tank. I mean, 12 I could have brought over 200,000 gallons.
But I would 13 and up on the order of 300 MPCs, while we're looking at 14 MPCs to get out the side boundary.
15 So obviously, you know, as I mentioned bef' ore, 16 you know, I would have a reduction of maybe three to go from 17 the Regen Holdup Tanks to the retention basins, that would 18 give me about 100 there.
And then to go offsite I only get 19 about a ten.
So that would leave me with greater MPCs to 20 go offsite.
So I couldn't do that.
21 So you wanted to insure if you brought over,-
12 say, you know, 20,000 gallons at 0.1 or 0.2 or whatever it 13 was, then let it fill up with water just from normal other 24 water that is coming into it, and then sample it and you 15 had a certain dilution, and then you' diluted as you got to J
ee 9
in i i ha i r
______u_
83 1
the retention basin and then you could insure that you were 2
below an MPC for tritium to go offsite.
1 3
Decause that's really what we were concerned 4
about, was to be below an MPC always when you 1 eft the site, 5
when the water left the site.
And that was the 10 CFR 20 6
limits.
7 Q
What effect did the dilution have on being 8
able to detect radioactivity of the other nuclides other 9
than tritium?
10 A
It would dilute those also.
11 Q
And what effect does that have on your ability 12 to detect --
13 A
Well, you know, as -- now.you're getting into 14 counting.
And as far as lower level of detection, you 15 know, we still counted the same length of time, you know, 16 for the releases from the Regen Holdup Tank.
But it would 17
-- if there was some gamma emitting isotopes there it would l
18 dilute it at the same ratio as if the tritium was diluted.
I 19 That's correct.
Or it may not.
It may go up.
20 Because you were putting water in from the 21 Regen Holdup Tanks from everywhere in the secondary system.
12 So it's possible that it would even go up.
13 MR. MARSH:
Because of the leaks?
24 THE WITNESS:
Yes.
15 BY MR. MEEKS:
l 9
_______.___________-_-_____._m.
E
~1 84 j
I 1
-Q Well, if-the water ',as not -- in other words, 2
let's say it was coming in from the secondary, or wherever 3
it came from -- where did it come from, anyway, the secondary 4
system?
Did the water all the time'come from,the secondary 5
system?
(
6 A
There may have been times. I don't know.
But
{
7 it was not a normal type of thing where we would have used 8
some water from, say, service water.
Because they may 9
have been.in a hurry to -- because tanks were filling up 10 and they may have wanted to get a tank out right away.
13 So there may have been-times.when we did use 11 service water.
But, my recollection anyway, that was not 13 a routine type of thing unless we were having problems and 14 tanks were getting filled up and you wanted to get rid of 1
15 a tank.
16 Q
okay.
17 A
Normally you would just let the water fill up 18 from water from regeneration of the Makeup Domins, water 4
from leakage from the secondary system, drainage from the j
. secondary system, that sort of thing.
1)
Q Do I understand your answer to be that if 12 vour dilution water doesn't contain the same radioactivity 13 as the water you bring out of the DRCST then you're reducing-24 the ability to detect radioactivity in that water by diluting 15 it?
l r
85 1
A-It would be reducing the -- you could - be, yes,-
2 reducing the activity, concentration, microcuries per ):c, 3
below the lower level of detection of your counting equip-4 -
ment, yes.
That's correct.
5 Q
Did you ever discuss with anybody that. fact, 4
that the practice of diluting that water --
7 A
No.
8 Q
-- could cause'you to lose that radioactivity 9
was in there?
10 A
No.
Because, you know, from my experiences 11 on other plants, that no plant in the country ever goes 12 back into'their system to sample -- you know, back, way back 13 into their system.
14 Q
'What procedure-allows you to dilute that water, 15 the DRCST water, when you --
18 A
I don't think there were any procedures written 17 that gave you guidance or were specific on what you would do'.
IS Q
Okay.
19 A
Not until just recently, you know, the recent 20 ones in 86 or whenever we did those. Those were very specific 21 in giving guidelines in what you should do.
But at the time 22 nobody really questioned whether or not, you know, that was 23 anything wrong with doing that.
24 Q
Well, who had the authority to determine that 25 that practice was justifiable at that time?
i L' 1 n-_u-_--_-- - _ - - - - _ - - - -. - - - - - -. - -
A
L 8.6 1
A I don't know.
I can't answer that.
t 2
Q You say now you do have procedures ~that call 3
for sampling before dilution?
4 A
Uh-huh.
I think at that time, you know, 5
there was never -- you know, as soon as it was pointed out 5
to us by Greg, you know, that it appeared that that's. what 7
was really happening, you know, it would make it appear thas 8
we were-doing that, then we made those changes to say, okay, 9
yes,.that makes sense, we probably should do sampling back 10 here.
11 But, like I said before, I'm not sure of other 12 nuclear power plants that go back into their systems and la sample back somewhere else.
Normally it goes to a tank and 14 they sample that tank before it's released.
15 Q
So your main concern was tritium, if I 16 understand?
17 A
Yes.
IS Q
And what.you needed to dilute for tritium?
II A
That's correct.
l l
20 Q
And that tritium sampling always took place J
21 at the DRCST, or at times took place at the DRCST and then 22 you brought it in?
.23 A.
Both.
l 24 Q
At the DRCST and --
25 A
And at the Regen Holdup Tank.
Every time you -
J
___._i_____________________.__________
r i
)
'87 i
1 Q
Before and after dilution.?
2 A
No.
-3 You know, it was always --_the final sample
]
4 was taken of the tank, you know, when it was filled up and 5
mixed.
6 Q
Okay, now, the release of tritium has to be i
7 at a specified MPC.
But still the release of tritium itself 8
isn't that much of a factor, whether it's -- how do I want 9
to say this?
What is the safety aspect of tritium?-
10 A
Well, it has a fairly high concentration for Il MPCs.
So from an environmental standpoint that implies that 11 it is not environmentally much of a problem.
But you have is to remember, you know, at these times we were strictly.trying 14 to'maistain the MPCs, okay?
We did not have the informati0n 15 as far as the imp 1'ications of what concentration that-you 16 may have, if you may have a very, very low concentration 17 of the Cesium 134 and 137, that wasn't brought to anybody's 18 attention and it was not brought to my attention until Ed' 19 Bradley's letter of October 31, 1985.
10 And even then with that letter it wasn't --
Il you know, when I got a copy of that letter it was dated 12 October 31, 1986, I gave that to one of my people to review 13 and say, What is the validity of this?
Because people like 14 myself'that were involved in these things on a day by day
~
15 basis, we were not privy to the kind of information that Ed i
e
__-____.--_m_
1 1
38 1
Bradley had.- And he never did -- none of those people talked l
2 to us and said anything to us until after this October 31st l
i 5
letter.
And Ed Bradley never came and talked to me and said,I 4
" Hey, look, you know, I think we really have a problem here,*
5 until December of 1985.
6 Q
Okay.
l
-1 7
What was Roger Miller's awareness of you l
i 8
diluting --
9 A'
I don't think he probably -- I'm not sure if 1
10 he knew.
I mean, that was just -- I don't knov if he knew l
11 that that was being done that way or not.
That was just, 12 you know, common practice that was done.
And we didn't even; 13 give it a thought that it was wrong.
If we were to ever 14
. have thought -- for instance, you know, we've made very-15 conscientiously over the years in our group -- and I think l
16 the number of ODRs that you see that were written by p' ople e
17. in my group'on any spills of radioactive liquid or anything II that could and up in a drain or offsite were very carefully,.
19 you know, to the best of our ability documented.
20 And I think that, you know, if we would:have 21 had any kind of indication that -- yois know, for one, we 22 veg&.looking very closely up until the RETS to insure that l
13 we were.below MPC at the site boundary.
And then after RETS 24 were not aware of the fact 'that if you released, depending--
15 on the numberof gallons you released that would depress or 4
l e
__m-
_ _ _ _ ~ _ _ _ _ _
.__m__._______
1 89 4
1 or lower your lower level of detection.
We were never aware 2
of that.
3 Q
But you were aware of the f act that the gamma 4
emitting nuclides did have the potential to be more damaging 5
than tritium?
l 6
A Some of them aren't.
l 7
O But some of them are?
8 A
Some of them -- well, that wasn't --
9 Q
Cesium 134 and 1377 i
10 A
We were never aware of that until -- you know, 11 just basically from a standpoint that, okay, you have a lower 12 value for MPC, okay?
But, you know, it was never made clear 13 to us, the people, you know, at the operational level, that 14 the -- you know, that the bad actors were the Casiums until 15 this October letter came out.
16 MR. MEEKS:
Let's go off the record.
17 (Discussion off the record.)
18 MR. MEEKS: On the record.
19 BY MR. MARSH:
20 Q
Mr. Kellie, one thing that I think that we 21 should explore now is that in 1981 you explained that you 12 were moving the water from the DRCST into the RHUT and 13 measuring it and making releases which were in violation of 24 any policies or specifications that you were aware of.
Then in October 1984 you were indormed that you 25 o
e 1
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/
4,,,,,
V s--
90 y
would not make any more releases of radioactivity through 2
releases of effluentsr 3
A They just said there would be no more radio-l 4
active liquid releases.
5 Q
okay, so that in your mind included --
6 A
In my mind that included tritium.
7 Q
okay.
A And I questioned that.
I said, "Well, what 3
9 about tritium?"
And the word that came back was, "Well, 10 tritium is okay.a 33 Q
But'everything else was of a concern?
12 A
Well, you know, then you get down to a defini-13 tion of what's a radioactive release.
14 Q
okay.
15 But I guess -- at that point in time were you 16 still experiencing problems with your steam tube leaks?
17 A
Yes.
18 Q
And still having the same build-up of radio-19 active water through the processes that you described that 20 were taking place in 1981, a not too much different problem, 21 or identical problem in late 1984-85 time frame, is that 22 correct?
13 A
That's correct.
Except that we shut down in, 24 like, February or March of 1985.
So after we shut down then, you know, other than draining systems, which ends up getting 25 e
91 I
some amount of water into the system that you would not normally be petting this water into, that a'dded some water 2
3 also.
4 o
okay, so when you're down you'have some of 5
the same problems you have when you're operating, plus you i
6 have some additional problems of flushing'.the systems?
f t
7 A
Yes, you have to, you know drain some of the 8
syntems and that sort of thing.
But you don't have the 9
continual input into the secondary system like you have 10 when you're operating.
Il Q
Okay.
11 Now, at that point in time subsequent to II October of 84 was the modification that moved water from 14 the DRCST to the RHUT still in place?
15 A
I can't answer that from the standpoint that, 16 you know, there were times when it was removed and replaced II and removed and replaced.
I have no idea.
I.8 Q
All right, subsequent to October 1984 are you IP, aware of it being in place at some point in time?
IS A
Yes.
And I can say the same for after 1984, 25 that it was in place, yes.
12 Q
So leading up to October 1984 you were using 13 it and then subsequent to October 1984 there were occasions 24 when you continued to use it?
15 g
- yes,
l 92 1
Q And it may have been disa,ssemblad and reassem-2 bled on various occasions --
'S A
That's right.
4 Q
-- during that time frame?
5 A
Yes.
6 Q
Can you describe to me what was different about 7
your process of mcking releases from the RHUTs after 8' October of 1984 from your process of the 1981 time frame F
that you've described to us?
10 A
The process was the same.
11 Q
So even though you knew you were releasing 12 radioactivity in 1981 through that process --
13 A
I didn't say that.
I didn't say that I knew 14 that we were releasing radioactivity from that, from that 15 process.
I knew we were releasing radioactivity.
16 0
Okay.
17 A
Whether it came from the Regen Holdup Tank --
38 or from the Demin RC Storage Tank or whether it came from 19 the secondary system --
20 Q
You wouldn't be able to be tell because you 21 were only sampling after it had been mixed in the RHUT?
22 A
Exactly.
13 Q
Okay, and the process that you had in 84 was l
24 the same --
25 A
After October 84 was the same.
O L_-_-_----_----
l 93 1
Q
-- after October or 84 was the same?
2 A
Yes.
3 O
And so you would still be releasing radic-4 activity through the release of effluents, is that correct?
5 A
We were still doing radioactive releasen 6
because o(- critium.
7 Q
Because of tritium.
Why would there be no 8
other nuclides than tritium?
9 A
Well, at that time using the 2000 second count 10 we were -- and if there was nothing there then we were --
11 that was what we knew whether or not it was radioactive, 12 or at least that was the criteria.
And we felt that if we 13 could meet the LLD limit that was in the tech specs, the 14 5 x 10-7, we felt if we met that then we were -- we didn't 15 violate anything.
16 Q
Okay, but you knew that you were making 17 releases, but you did not believe you were in violation?
18 A
We knew we were making radioactive releases 19 from tritium, yes, that.'s correct. And we did not know we 20 were in any violation as far as the gamma emitting isotopes.
11 Q
Because --
12 A
Because we didn't know --
13 0
-- they would be -- according to your LLD 24 formula, they were below the --
15 A
Less than the 5 x 10-7 value thaE was ir. the se
94 1
tech specs, that's correct.
2 O
Okay.
8 A
We never ever had any activity for gamma that 4
was sampled by any other labs that was ever greater than the 5
5 x 10-7 We are always less than that when we released.
6 Whether we counted it for the 1000 seconds or the 2000 7
seconds, we were always less than the 5 x 10-7, 8
And if we knew what we know today from % e 9
standpoint of the Cesium and as far as complying with 10 Appendix I there wouldn't have been any problems, we wouldn't li have done that.
We didn't knew that.
12 Q
So you would not have done what you were doing 13 had you known --
If A
Exactly.
Had we known that the lower level 15 of detection for the Cesiums, which turned out to be the bad 15 actors based on Ed Bradley's letter of October 31, 1985, 17 then there would not have 1>een that problem. I can assure of 18 that.
19 Q
You would have taken some action?
10 A
Exactly.
21 Q
What would you have done had you learned of 12 that condition?
13 A
I would have stopped it, absolutely would have 24 stopped it.
Then that would have forced something to have 15 been done as far as, "Well, now what are we going to do? We'v e m
n____
95 3
got the Regen Holdup Tanks full, we got the Demin RC Storage 2
Tanks full, and we cannot -- you know, what it would have 3
'done is it would have required us, then, to go to the NRC
{
4 and say, " Hey, look, we probably are not going to comply 5
with 10 CFR 50 Appendix I guidelines and we're going to 6
have to -- we know we're going to exceed them.
And we're 7
going to have to do that."
g But that was not -- that never was ever given y
to the people at the plant. That was never given to any of 10 the people there that I'm aware of.
I was'not ever told that gg this was a problem, not until, you know, officially the 33 letter came out.
33 BY MR. MEEKS:
34 Q
Did you have occasion to detect, in running 15 this sampling, the presence of Cesium 134 and 1377
-16 A
Yes.
But, you know, those low levels, you 17 have to realize that we are in a counting-room that also has is activity of Cesium, you know, throughout as far as other 19 samples that are much, much higher levels that this environ-20 mental-type sample that we're counting.
And it was very 21 difficult sometimes to discern whether or not it was 21 contamination from some piece of equipment or contamination l
23 from something that was in the lab, or, you know, when we 24 down at those levels.
It's very difficul't.
25 MR. MARSH:
Okay, we'll take a break now. Let 9
e
_____-__._____---________.____.___.m_
r 96 1
the record show that Mr. Meeks and Mr. Shackleton are going-2 to excuse themselves frein this interview and the interview will continue-after the break with Mr. Joukoff and Mr. Marsh.!
3 4
(VTnereupon, a short recess was tak,en.)
5 MR. MARSH:
On the record.
6 We're back on th record after approximately 7
a ten minute break.
Present are Mr. Kellie, Mr. Joukoff 8
and Mr. Marsh.
9 BY MR. MARSH:
10 Q
The basis in Technical Specification 317.1, 11 Limiting Conditions for operations, and Technical Spec 421.1c 12 Surveillance Standards, state that specifications do not 18 assure compliance with 10 CFR 50, Appendix I, Dose Objectivec 14' can you explain why these technical specifica-15 tions cannot assure compliance with dose objectives of 16
17 A
I was not aware of that statement and when we 18 read those things, you know, to be honest with you, it went 19 ccmpletely over me.
And I felt that, in reading those, that 20 we thought we would meet that criteria.
I was not instru-El mental in rewriting the technical specifications after the 22 RETS implementation.
And I did review them but I was not 28 the people -- I think that was Ron Columbo and my boss at 24 the time, Roger Miller.
~
25 And I do not remember at all those words being 9
L_________._._________________._____________________________
l 97 )
I there until they were pointed out to me by Greg Yuhas in his 2
hispection.
3 Q
You mentioned a letter. prepared by Ed Bradley l
1 4
earlier?
5 A
Right.
6 Q
Ed Bradley discussed in his letter, or with.
7 some folks personally,-- I'm not sure all of the rigamarole 8
that went on there - but during the first part of 1985 the 9
possibility that Rancho Seco's technical specification on 10 the lower ILmits of detection was not sufficient to assure 11 compliance with the dose objectives of 10 CFR 50, Appendix'Ic 12 Now, you mentioned that you were not aware of II Bradley's letter until --
14 A
Until it was sent to me.
I mean,. even 15 october 31 is when it was dated, but I don't think I received 16 it October 31st, it was sometime in November. And I gave it 1
17 to one of my people to review, you know, to give an assess-18 ment of what that meant.
And, in fact, the review that came 19 back was somewhat of a negative review that questioned the 20 validity of that.
21 And, you latow, that's where -- there was n'o 12 request from me to respond to that letter in any way, at 15 least that I remember, other than, you know, here was a copy.
24 I was 'on the mailing list and I reviewed it to see, you know 15 what my people thought about it.
0 e
i I
98~
1 Q
Okay, but you're not aware of any discussions 2
or actions or preparation of that letter or concerns around 4 3
that letter dating back to the first part of-19857 l
4 A
No, absolutely not.
I i
5 Q
Have you been informed by anyone since that 6
time that that letter evolved back during the first part 7
of 19857 8
A Well, Bradley talked about it.
He said that 9
if my recollection of when he talked to me -- you know, at 10 least some of the times, I'm not sure of the exact times.
Il But I know that in December he came and talked to me about 12 this letter and about the lower level of detection and that 13 it, you know, may not be sufficient to meet the criteria 14 for compliance with 10 CFR 50, Appendix I.
15 And he said at that time that he knew about 16 it in early 1985, like February, but that he gave that 17 information to his boss -- I guess, Roger Powers or Ron 13 Rodriguez -- sometime in July, I guess, June or July. And, 19 you know, that's basically what -- and that's what he told 20 I had no idea of the validity of that or anything. It's me.
21 just what he told me.
22 Q
Okay, he told you that he alerted Powers and 23 who?
14 A
I'm assuming Ron Rodriguez was alerted about II it also at that time.
e
____-_-----__-------------.----------__-.-.-----m.-
99 1
Q Did you take any action in December based on 1
t
(
2 what you had. -- other than sending it to one of your people 3
to review?
i 4
A No, I did not.
5 Q
Did you tell Bradley in December that you had i
6 questions as to the validity of his --
7 A
I mentioned that to him, that.I had.it, you-3 know, reviewed by my people and what their responses were.
9 Q
And how did he respond to that?
10 A
I don't remember exactly his response.
11 Q
So in October 1985 you understood the issue 12 that Bradley was bringing up on the lower limits of detec-13 tion?
s 14 A
Well, I'm not sure I completely understood it 15 at that time.
I'm saying that, you know, that was the first 16 that it was brought out to somebody from us on an operational 17 level.
18 Q
And the --
l 19 A
You have to admit some of those things are 20 pretty complex and, you know, we were not privy to a lot of 21 the information that Ed Bradley has for his dose calculations 12 The only thing we had was, you know, releases.
13 Q
But the only thing you did was send it to one 24 of your staff for review and analysis?
15 A
That's corract, right.
8 e
~
1 l
100 1
Q Who was that?
2 A
Jim Reese.
3 Q
And the results of his analysis was that he 4
had some questions about the validity of Bradley's calcu-5 1ations?
6 A
Yes.
7 Q
Now, we've talked about the process of 8
counting for a specified period of time --
9 A
Yes.
10 0
-- on doing your sampling. Can you explain 11 what is involved in doing a test where the amount of time 12 is a factor?
18 A
Okay, you know, the lower level of detection 14 is based upon the length of time that you count a sample.
15 You know, we have done -- you know, we were using 2000 16 seconds just all along because that was a reasonable period 17 to count time and we were able to do that and meet easily i
18 the 5 x 10~7 And we did change to the 1000 in June and 19 July of 1985 based on the fact that we felt that we could 20 still meet the LLD, which we did, we still met the LLD of 21 5 x 10-7 And by meeting that 5 x 10-7 we would not 22 i
13 exceed 10 CFR 50, Appendix I, at least what we thought at 24 the time.
25 Q
Okay, well, what are the different variable t
e
_-mm._---__--__-__________m-___.m___
i 101 1
Lfactors in taking those samples?
2 A
The factors that affect'-- you mean that i
3 actually affect what the LLD is?
4 Q
Right.
5 A
Okay, the factor that affects the LLD are
)
6 volumes, efficiency of the counter at the particular loca-7 tion of the gamma isotope, the actual number of any other a
radionuclides that you may have there.
In fact, that was 9
the -- you know, our technical -- our ODCM, cur Of fsite 10 Dose Calculation Manual, says that the LLD should be an a 11 priori evaluation, meaning it's done actually to prove that 12 your counting equipment can meet.that.
13 And at least some of the data that I've d
14 reviewed-over the years it says that you may not always 15 be able to meet that.
But if you are less than that value, 16 or if you are less than number, then you are still considered 17 to be LLD.
Meaning that you could have a number even 15 greater than 5 x 10-7, but as long as it was a less than 19 number you would still be considered an LLD value.
19 MR. JOUKOFF:
I don't understand what you just 11, said.
22 THE WITNESS:
All right, what, that means is 13 that, for instance, if we count something and it's this 24 water here.
25 (Indicates glass of water on thit ' table.)
l
\\
1 o
e /
4
102
. Okay,' and we go right down and the ' line and g
we say that if there was any Cesium in there what would the 2
3 concentration be?
Okay, and we get a number and say that we get less.than 1 x 10-7, Now, if I have other isotopes 4
5 in'there, such as cobalt, cesiums, manganese, odines, now, g
at may still -- that may actually raise that LLD up to the Point to where it is at greater than 5 x 10-7 but still a 7
g a less-than number.
And some of the other literature said that 9
if that occurred you would still consider it as-LLD.
le 33 BY MR. JOUKOFF 12 O
It's LLD for this particular circumstance because of other radionuclides being present --
33 14 A
That's correct.
15 Q
-- is that what you're saying?
16 A
That's correct.
And our understanding, our knowledge of LLD 17 18 before, you know, any of this ever took place was that --
19 that was not a common thing.
You know, we would look at always being less than 5 x 10-7 20 21 Q
so what you're.saying is that you're below 12 detection limit, is that what you're saying?
13 A
Below the detection limit.
24 Q
Of the equipment being used?
15 A
Of the equipment being used.
t
103 1
BY-MR. MARSH:
3 Q
Or the count time?
l 3
A Or the count time.
See, count time makes a 4
difference.
I mean, I could count this long enough and 5
I would see some radioactivity in there.
6 (Indicates glass of water.)
7 I could count you long enough and you're a
going to see some radioactivity.
So, you know, where does 9
the definition as far as radioactivity, you know, determine 10 whether it's radioactivity.
Count time, volume, efficiency, 11 even the sample, the particular sample is a variable. The 12 actual -- whether other isotopes are in the sample can make 13 a difference on what the LLD would be.
14 There are a number of' variables.
I mean, even 15 if somebod walked in with another sample, a sample of 16 reactor coolant, at the time this was sampling could have 17.
an effect.
If the tack wasn't mixed properly it could have 18 an effect.
19 Q
Well, whenever you sample a volume of water 20 this volume of water is passing by your sampling spot, is 21 that correct?
22 A
No.
23 Q
Oh.
24 A
Not in the Regen Holdup Tanks.
The Regen 25 Holdup Tanks have -- you know, they are large tanks -- you'v(
9
.e
=
1 104
)
I seen them before -- and they have'a propeller, motor-driven 2
propeller.
You could go up on the top of these things and 3
just see how the water is swirling around to insure you have 4
good mixture.
And actually the samples were taken, like, 5
out of the side of the tank, okay.
And that sample is 6
taken usually in a clean one gallon container, you know, 7
because.you want to minimize any of these problems as far 8
as cross-contamination or anything.
And you usually try.to 9
use a clean or new Maranelli.
30 BY MR. JOUKOFF:
Il Q
What is a Maranelli?
12 A
A Maranelli is the apparatus in which you pour 18 the liquid in order to set it over thte detector.
If the 14 detector is like this -- and we have wall detectors -- then 35 a Maranelli fits dowTi over that and comes around like this.
16 So that's what it is.
1 37 Q
so it's.a type of container that is specially 18 used for this type of work?
19 A
Yes, correct.
20 And it depends on the J'you know, the efficien 21 cy depends on the size, you know, and you have to get 22 reasonable from the standpoint of size. You know, I mean, 23 if you got a big container like this, you know, you could 24 probably get a lower LLD.
But you reach a poirit now where 25 the counting statistics are such that if you have a big e
e no
105 i
1 thing like this then some of this activity that is out here 2
could be absorbed by water molecules between here and. there. I i
3 So you can become real complicated here real 4
quick when you get into this.
\\
5 O
There is no industry standard test or Reg 6
Guide specified test as to how you are supposed to do the 7
type of sampling that was being done?
Is there an ANSI 8
standard or some other standard that specifies that: you will 9
use a counter of such and such sensitivity coupled with a 10 Maranelli holding so many liters of water with a count tire 11 of so many seconds and that this is now an industry standa.rd8 12 A
No, sir.
13 Q
Not that you are aware of?
14 A
Not that I'm aware of.
15 Now, we do have -- there are Reg Guides, Reg 16 Guide 4.15, which I don't know in depth, now, because I am 17 not, you know, in those areas.
But that had to do with a 18 quality control system for environmental-type samples.
But I?
that was basically to determine whether or not your equip-20 ment is working properly.
You test it on a day by day 25 basis using sources and see where the counts fall in and 12 see if they are outside of a certain control graph and then II you look at doing something about that.
24 And the NRC comes in on a, regular basis, cross <
25 samples, take cross-check samples to determine'the operabili<
h I
e
106 1
ty of the equipment.
2 BY MR. MARSH:
3 Q
All right, now that we somewhat understand how 4
the sampling process works -- and you said that during the 5
period of time leading up to June-July 1985 time frame you 6
were counting for 2000 seconds?
7 A
Yes.
There were apparently some times before s
that in which they didn't count exactly 2000 seconds.
9 Q
But can you tell us why 2000 seconds was the 10 norm?
11 A
That was just thirty minutes.
I don't know, 12 we just kind of -- you could --
13 Q
That seems to be kind of an imprecise way of 14 doing things in a discipline that is based on very prhcise 15 measurements.
1G A
Well, okay, the 2000 seconds -- at least, you 17 know -- it was just something for doing releases which 4
18 seemed like a reasonable count time.
You know, it's not 19 going to take forever.
Because if you start counting real 20 long count times then, I mean -- you have to realize that at 21 the time in June and July, that time period, that's when 22 we had the B candy cane leak in the reactor building.
And e
18 those aren't the only samples that were taken, see.
24 And I don't remember if we had two counting 15 systems, but I know there was a period of time in which one r
_____-__.________.________m_
107 i
of the counting systems was down, okay?
So there were lots 2
of samples in some cases, not always -- I'm not saying 3
every time -- but there were some cases where a lot of 4
samples were backing up.
t 5
If Rad Protection, they.took a s' ample because g
we had a leak of gas down in the minus-20 somewhere, they 7
brought that up to the lab; if the counting equipment is a
tied up with very long count times trying to count this water we're trying to leave offsite then you would not be 10 able to count these other samples, which may be just as 33 important for the people that are down there working.
37, So, you know, that was just a reasonable length 13 of. time, thirty minutes, and also was able to easily meet 14 the 5 x 10-7 15 Q
I guess, how did you know that thirty minutes 16 met the criteria for 5 x 10-77 s
17 A
Well, we did enough samples.
You've done 18 enough of them over the year,s.
We do have the procedure, 19 which you are well aware of, as far as -- but that didn't 20 really come out until 84.
I mean, that procedure didn't 21 come out on an LLD until after PETS was incorporated..And 22 we were always doing, you know, 2000 seconds up to that time.
23 Q
Whose responsibility in the organization was 24 it to choose the standard counting time and have everyone q
25 comply with that?
I
l 108 1
A That was just a standard time, I think, when 2
we first started operating the plant and we had B&W come in 3
to assist us in setting up the count room, that was the, 4
you know, the time that was set up.
5 Q
So that had been the way you had'been doing it 6
for as long as you remembered?
7 A
For quite a while.
For effluent releases.
5 Q
Uh-huh.
p A
There were times in which we counted less than 10 2000 seconds just to determine what contamination levels 11 we might have in a system.
And if you have activity it's 12 a lot easier.
You don't have to count as long if there is 13 activity there.
It's just where you get down to so low 14 of activity and then you have to determine.
15 Because the difference at this time between 16 1000 seconds and 2000 seconds is like 1 x 10-7 and 2 x 10-7 i
17 That's the difference in the number you get for microcuries 38 per cc.
i 19 Q
Okay, but clearly the shorter the time you 10 measure, the less likely it is that you will detect radio-11 activity?
12 A
At a low level, yes, that's true.
13 Q
And that's the purpose of testing, is to 24 detect low levels?
15 A
You know, there is -- I have no (unims of l
e o
i.
109-1 saying that -- and I have to take the responsibility at this 2
time, in the June-July time period -- that.it was my decision 3
based on discussions and looking at the tech specs from the
.4 standpoint of -- and not knowing that this Cesium 134 or 137problemwas--youknow,notknowingthatdnformation,-
5 6
you know, it was my decision to shorten the counting time
.7 in order for us to handle the liquids that we had.
8 In retrospect, you know, ethically that looks 9
wrong.
But at the time I felt that it was legal and that 10 I wasn'.t doing anything wrong.
And, you know, looking at 11 the tech specs and seeing that we could still comply with our technical specifications as being less than 5 x 10~7, 12 13 you know, I felt we could do it.
14 BY MR. JOUKOFF:
15 Q
Did anybody direct you to change the count 16 time from 2000 to 10007 17 A
'No, sir.
18 Q
so this was a decision that you made on your 19 own in your position with the company?
20 A
That's correct.
And I discussed that with --
you know, with George Coward and I felt that we could do it.
21 22 Q
Is the methodology used for doing one_of these i
23 tests proceduralized somehow?
24 A
Basica13y the methodology is proceduralized, 15 yes.
110 1
Q Is the procedure --
1 2
A But it doesn't -- the procedure, other than i
3 saying if you want to meet a particular LLD, no, this 4
procedure that says how long the count time will be -- the 5
procedure that goes through the mechanics of s mpling and 6
analyzing it does not say what count time to use.
7 O
Okay.
8.
So consequently -- whose -- this procedure is 9
a SMUD procedure?
10 A
Yes.
11 Q
And in that procedure the time that you would 12 count for is not definitively stated, is that correct?
13 A
No, it is.
14 In the LLD procedure there was, okay?
It says i
15 for this particular type of sample count for this time.
But 16 those can change, okay?
And in fact that is what I had l
1.7 thought my people had done.
I thought my people were 18 going back and changing that procedure because there was 19 nothing that said we couldn't change that procedure to say, 20 "All right, we're going to show that we can count for 1000 l
21 seconds and still meet the techinical specification, the 12 5 x 10-7 and not violate anything."
And it would shorten 23 up the count time.
2i And I'll repeat it: obviously if we had known 1
15 about the Cesium 137 and the 134 thing we certainly wouldn't 1
I S
6
111I l
1 have done'anything like that.
But at.the time we'didn't
- 2 know that and thought we could do it.
1 5
BY MR. MARSH:
4
.Q Tell me again why you wanted to cut the time.
Whyallofasuddenataparticulartimewerehouwanting 5
'6 to cut the time?
7 A
Well, we -- you know, the pressure and I guessd 3
you know, there was not anybody holding a gun to my head'or 9
anything to do that, but, you know, we strictly. looked at I
10 it and thought that we could lower the count time and still Il be legal and then not have to consider the radioactive 12 release and, you know, still be legal.
15 Q
And what was motivating that, though.
I mean, I4 were you getting -.was your budget being cut to wher'e.you 15 couldn't have the equipment or the bodies to do the tests 16 or --
17 A
Well, there were times when we didn't have 18 enough equipment, okay?
Because of some of the equipment 19 being out of service, you know.
But I can't give you 20 exact dates and when these things went on.
But there were 21 times when we were pressed, there were times we had a lot 22 samples going on at the time that were starting to back up.
13 But I wouldn't say those were the primary 24 reasons.
You know, the primary reason was, you know, we 25 thought that we could say that it wasn't a radioactive t
e
___._____._-__m-.__.._
i 112 1
release and we were not violating anything.
q i
2 Q
I guess that's a confusing term to me.
You 3
could say that it wasn't a radioactive release because you 4
had counted it for a particular period of time and it had not shovn in your test that it exceeded the lower l'evels of 5
6 detection.
7 Now, if you had counted it'for 2000 seconds 8
instead'of 1000 seconds --
9 A
You would have seen probaly a positive peak 10 less than the LLD that's in the tech specs, okay?
So, you II know, that's very true --
12 Q
Could you have possibly found a peal that was 15 above the lower levels of detection?
14 A
No.
15 Q
Tell me why.
16 A
The -- because at 1000 seconds we could still prove that we would always meet the less than 5 x 10~7, 17 18 which was the tech spec LLD.
N 19 Q
IY these were. arbitrary figures of time period 20 for testing how could you prove that, how would we know that 21 you could prove that?
How would you know that you could 22 prove that?
13 A
My people would -- as I thought they did right away when we started discussing this -- would have the 24 25 procedure -- you know, change the procedure in the count, O
I
- ?
____m._
113) l 1
the LLD procedure, to say that we're going to count this and I
2 have the documentation to show that that would in fact be l
3 true.
And, in fact, they did do that, but it was, like, in
^
4 July.
They didn't do it right away.
j 5
Q So they validated the process.
3 6
A Yes, exactly.
7 Q
Tell me how you validate that.
3 A
You just take a sample and count it for 1000 1
9 seconds.
le Q
And if you --
J
~7 II A
If all your LLDs are less than S x 10 then 12 it shows that counting for 1000 seconds you would meet the 13 LLD.
Actually you could have counted 100 seconds, as we 14 found later in doing this, and still meet that 5 x 10~7
-1 l
15 Q
Why then would anyone count for 2000 seconds?-
16 A
It was just a routine that people, you know, 17 got into.
'I 18 Q
I feel that there's more to this story than 19 that.
I don't understand.
When you' rein business and you'rC 20 responsible for efficient utilization of resources and to 21 get things done in an expedient manner; and then a scientifiG 22 discipline, such as chemistry, you have processes that you 23 go through.
And there is a reason for going through that 24 process because your testing *can only be valid'if you do it 25 a certain way.
114 I
I And to choose arbitrarily one of the material.
2 factors and just routinely do it in excess doesn't seem to
.3 make sense to me in relationship to the discipline that you
.4 are operating in, the scientific discipline of chemistry, 5
which is the measurement of interaction of molecules.
It's-6 justbeyondmetocomprehendwhatyou'resa[inghere.
7 A
To be honest with you, I really don't know why 8
2000 was picked, other than that was, you know, when they 9
initially set up the counting system that was, you know, a 10 reasonable count time to do that wou13, you know, insure Il that we met the 5 x 10-7, and it would easily meet it.
We 12 could have picked 4000 seconds, could have picked 1000 la seconds, could have picked 500 seconds.
.e U
14 Q
But the longer you count it the more likely 15 it will be that you will detect presence of radioactivity.
16 A
That is correct.
It And at that time remember ~that it was not known 38 to us about the problems with the Cesium 137 and the Cesium I?
134 and that they could be at concentrations much less than 29 that technical specification that was in the tech specs, 21 that that number, the 5 x 10~7 that was in the tech specs, 22 and we would be in violation of 10 CFR 50, Appendix I.
23 BY MR. JOUKOFF:
24 Q
Could you: explain that?
I don't: understand 15 what you're saying.'I was under the impression that the LLD 9 4 4
._________m.___
_____._____________m._
115 I
is the lower level of detection of your equipment, your 2
measuring --
3 A
But that lower level of detection can change
)
4 based on the variables that we talked about before: sample l
5 size, the activity of the sample, the count time, the i
6 efficiency of the detector, the type of of detector, volume 7
of the sample.
8 Q
okay, so you're saying that the LLD of your j
equipment is a moving target, it varies depending upon these 10 variables?
11 A
That's right, yes.
12 Q
What do your -- we keep using the number of 13 5 x 10-7 v
14 A
Right.
15 Q
What are the units that go with that?
16 A
Microcuries per cc.
17 o
so am I correct in stating that you are required to be able to measure down to 5 x 10-7 microcuries 18 19 per ce?
10 A
That's correct.
11, o
okay, so if you hav& a concentration that! is 12 greater than that number you have to be able to detect it?
13 A
That's correct.
14 Q
Okay, now, varying the counting tiime from 15 2000 seconds to 1000 seconds, at 2000 seconds is your LLD O 9 I
I i
126' l
1 5 x 10~7 microcuries per ce?
l
~7 2
A It is less than 5 x 10 microcuries per ec.
3 Q
What is it?
4 A
It depends, again, on the sample., In this 5
time period that we're talking about here in June and July,
)
1 6
which is the really the only period of time ~which is really l 7
pertirent to this particular problem, it was in the order of' s
1 to 2 x 10~7 And if you counted for 1000 seconds it was 9
still within that range, 1 to 2 x 10-7 I
i le Q
So therefore by using all of these variables
-c 11 is there a formula that is used to empirically calculate Il the LLD7 13 A
Yes.
-)
14 Q
So that's --
15 A
That's in the -- or with RETS it is in the 16 ODCM, the Offsite Dose Calculation Manual, that particular 17 formula that is used is there.
4 18 Q
And was that formula in place during the time 19 frame that we are discussing?
10 A
Yes, that's correct.
11 Q
And by using that formula in the time frame 12 that you used varying the count time from 2000 seconds to 13 1000 seconds did not alter the LLD, is that what you're 24 telling us?
15 A
It did not appreciably alter the LLD.
I
+9 e
e o
117 1
Q After you changed the count time was the new 2
LLD still within the requirements?
i I
3 A
Yes, it was.
Absolutely.
4 BY MR. MARSH:
Q In June of 1985 you called Greg Yuhas regarding 4
the reporting of identifiable peaks of radioactivity in the 7
sample analysis.
Can you tell us about that circumstance?
8 A
Yes, it was a concern of having a positive 9
peak less than the LLD and whether or not that would have to 10 be counted as a positive, and he said yes.
11 Q
So by counting for less time you would hav6 12 reduced your reports of positive peaks?
13 A
That's correct.
14 Q
Did you understand that?
s 15 A
Yes.
16 Q
Did you discuss that with anyone in the SMUD 17 organization?
18 A
Yes.
I 19 Q
Can you tell us what --
20 A
George Coward.
11 Q
Tell us about your discussion.
12 A
Just the fact that, you know, counting for a 23 shorter period of time we would still meet the LLD that's 24 required for our tech specs and that I felt that we were not 25 in violation of anything, that we would -- you know, at that
=
l
1 l
118 I
time, you know, again, didn't know anything about this proble m,
2 with the Cesium 134 and 137, at this time.
And, you know, I 3
thought we could do that.
4 Q
Okay, but did you discuss at all that this 5
might be a manipulation of the record in that you would be 6
taking action to reduce the number of reportable peaks that 7
you would have?
8 A
I'm not sure, you know, what exactly the 9
conversation -- I can't say for sure.
10 Q
Did your conversation with him in June 1985 Il precede your instructions to reduce the counting time?
12 A'
I don't know that.
13 Q
Was your reduction in counting time predicated 14 on the fact that you were going to have to report the peaks 15 unless you reduced your counting time?
16 A
Well, it was, you know, predicated on the fact 17 that we felt that it could be legally done and that we did not -- you know, we were so far below on MPC for these things 18 19 we had no idea that it could be a problem as far as 10 CFR 50 l
10 Appendix I values.
21 Q
Did you report to more than just Coward about i
12 the conversation with Yuhas?
13 A
I don't remember.
24 (Pause.)
15 Not, you know -- to correct that I talked to t
e 6
__.._.__._..____________________________m_____
119 1
Coward about the -- you know, the fact that we were reducing 2
the count time and that, you know, we felt that we were 3
legal in doing that.
4 Q
Why would it be necessary to discuss whether 5
you were legal or not?
6 A
Just to -- you know, from the standpoint of 7
what's a radioactive release.
g Q
Well, if you have a peak that is detected you 9
would then have a radioactive -- a known radioactive release.
10 A
That's true.
11 Q
So basically what you're telling me is that 11 you manipulated your counting time so that you would be 13 having -- you would possibly have radioactive releases that e
s-14-were not reportable because they were below your threshhold 15 of detection because you were counting for a lesser time?
16 A
Manipulation may be a, you know, strong term.
17 But the count time was changed and, yes, that's true that l
18 that could happen.
19 Q
Wasn't that in fact the results?
20 A
You know, as it turned out later that a lot I
11 of the counts were not counted at 1000 seconds, they were 12 even counted at 2000 seconds after we even had this change la to 1000 seconds.
And, again, you know, I must reiterate 24 that we had no idea that there was a problem with meeting
~
15 Appendix I.
We were meeting tech specs and we helt we were f
120 1
meeting technical specifications, and we were clearly meeting 2
the maximum permissable concentrations at the site boundary.
.3 MR. MARSH:
I'd like to show you a paper and 4
see if you could identify this for us, please.,
5 (The document was proffered to the witness.)
6 THE WITNESS:
Yes.
7 BY MR. MARSH:
3 Q
Could you describe what that is?
9 A
Okay, that was to resolve whether or not if 10 you had a positive peak even below the require LLD of
-7 11 5 x 10 whether or not it must be recorded and reported.
12 And he said, yes, it should be.
13 Q
And what date is that?
I j
14 A
6th of June..
15 0
And the document that you're talking from is 16 a documentation of your own?
17 A
Yes.
18 Q
Based on a telephone conversation with Greg 19 Yuhas?
20 A
That's correct.
21 Q
That took place on June 6, 19857 22 A
Yes.
13 Q
So at that point in time it was clear to you 24 that if you had a peak through your sampling process of 15 radioactivity that it was reportable?
t
_._.__._._____.m__-___________.__-_.__-__.m_
121 1
1 A
That's correct.
2 Q
And could you refer to the copies section of l
l 3
that document?
Can you stete for.the record who you provide @
l 4
copies of that to?
k 5
A Ron Columbo, George Coward, Bob Dieterich, 6
Lee Keilman, John McCulligan, Roger Miller,' Pierre Oubre,
.7 R.J. Rodriguez, Andy Schwieger, Bill Spencer, Admin. Files, 3
QA Files, Fourth Floor Files.
Q Did you have any conversations with any of those folks concerning this interpretation you received 10 gg from Yuhas?
12 A
I don't remember.
33 Q
Did anyone contact you in regards to the nature of this interpretation after they received the copies 8 34 15 A
No, sir, not that I remember.
16 Q
Did anyone contact you in regards to that 17 with this ruling by the NRC it was going to be necessary to is manipulate the testing?
19 A
No,. sir.
20 Q
I ask you again:
When did you change your al counting time from 2000 seconds to 1000 seconds?
12 A
I can't give an exact date, I don't know.
But 13 it was some time in early June /
24 Q
Subsequent to -- the first week in June is 25 pretty early.
Are we talking about the 6th of June?
?
122 1
A I'm sure it's on the record of when we --
l 2
because all the count times are there for the lengths of 3
time we counted.
4 Q
Would you initial this paper at the bottom 5
to indicate that you have reviewed it so that if you have 6
to identify it again you will be able to?
7 (Witness initials the document.)
8 Thank you.
9 What did you feel was the reason for such a 10 wide distribution of that record?
11 A
That's common.
Any telecom had those 12 distributions.
13 Q
When the LLD issue that Bradley brought up
)
14 in October 29 time frame to you what did you do to assure 15 that the lowering of the count time on the analysis, the 16 samples together with the LLD issue would not impact on the 17 ability to conform to the 10 CFR 50 Appendix I dose objectivc 18 limits?
19 A
Well, at that time we still didn't know whetheE 20 what he was saying was valid or not.
So then nothing was 21 done.
22 Q
At what time did you determine that possibly 13 his findings were valid?
24 A
It was after Greg Yuhas came and'did his 15 inspection.
I t
I
~
~
123 1
Q And when was that?
2 A
April of 86, March-April of 1986.
3 Q
Okay, so based on an NRC inspection it was 4
then learned --
5 A
Yes.
6 0
-- that there was --
7 A
Because nothing ever came from up above to 3
-- you know, to express the validity of what he was saying.
9 Q
Did anyone ever tell you that they had agreed 10 with Bradley in any way earlier than October 297-II A
No.
12 Q
Did you give any instructions to your people 13 that were actually making the tests and taking the samples J
I4 to insure that they reported pdaks that would be identified 15 in accordance with Yuhas' interpretation?
16 A
I don't understand your question.
17 Q
okay, on June 6th you had the conversation 18 with Yuhas in which the interpretation was that it was 19
.necessary to report the peaks of any radioactive contamina-10 tion that was discovered in your testing?
21 A
Right.
I don't ::amember discussing that with 12 any of our people.
13 Q
Was that the policy prior to that time frame 24 of reporting it?
15 A
When we were told.that -- actua11y, you know,
124 1-the policy was that if it was there we:would-have recorded 2
it.but they said -- you know, they told us that you couldn't 3
do any radioactive releases.
So, you know, you get back inte 4
the definition of what is a radioactive release again.
5 Q
So your position on it uns that if it was 4
below the lower limits of detection, even though it was 7
identifiably present, you could release it --
3 A
That's right.
9 Q
-- and report it as no radioactive release?
10 A
That's correct.
11 BY MR. JOUKOFF:
Il Q
I don't understand how you can read something 18 that is below the lower limit of detection.
w) 14 A
Well, if it is below the LLD number'-- that's 15 the 5 x 10-7 -- if it was below that number and a less-than 14 value then we said my interpretation was that it was not 17 a radioactive release.
18 Q
But iny* question is:
Is that the lower level 19 of detection of your equipment?
How can you see something 19 your equipment can't detect?
11 A
Your equipment has proven that it can detect 12 down to, or as low as, less than 5 x 10~7 !
13 Q
But how much less than?
24 A
How much less do yo,u want'to go?' You know, that'swhereyougetintoallthecounttimeskndallthat.
15 I
9
_______.___________________m____.
i:
l.-
I 125 1
And, again, I will stress it, is that if we would have known 2
that there was a problem as far as the concentration for the 1
l 3
Cesium isotopes had to be that low in order to comply with 4
the 10 CFR 50 Appendix I we certainly would not.-- I certain$
5 would not have done anything to jeapordize that.
But L
6 unfortunately I did not know about it at the time.
l 7
Q I'm trying to get an understanding of this 8
for myself.- So what you're saying is that the LLD of 9
5 x 10-7 is what is required?
10 A
That's what is in the tech specs, yes.
Il Q
And you have to be able. to detect less than 32 that.
And your equipment was capable of detecting a lot lesa 18 than that?
14 A
It may have been, yes.
15 Q
I mean, at certain points in time, a varying 16 degree, okay?
l 17 A
Yes.
19 Q
So, therefore, seeing something lower than 19 that number your equipment was capable of it but your to interpretation was that you didn't have to report that you Il saw it?
22 A
As long as it was a less-than number.
13 Q
As long as it was less-than?
24 A
Right, that is correct.
15 MR. JOUKOFF:
Okay, thank you.
e
..___.------.._-_--_-_ --- _- --- -__ ----- -_-_.____---- L _--- -
126 1
MR. MARSH:
Let's get back to the question
)
2 here.
3 BY MR. MARSH:
4 0
You took no action to identify to your people 5
that they should insure to report any peaks after your 6
conversation with Yuhas?
7 A
Other than, you know, we discussed the going 3
to 1000 seconds as count times, I don't really specifically 9
remember -- again, this was a period of time in which I was to taking over for Roger Miller, Roger Miller was leaving, and 11 this wasn't the only thing that was going on at the time.
12 Q
In October 1985 Lawrence Livermore Laboratory 13 -made a report concerning Cesium 137 being present downstream
.)
14 from the plant.
Are you aware of that report?
15 A
Yes, I am.
16 Q
Can you tell us your knowledge of that and 17 when you became aware of that report?
18 A
I can't tell you the exact dates when I 19 became aware of that.
I was not, you know, in that chain, 20 so Bradley had it first.
So I don't know when exactly that 21.
came up, I really don't.
But it was, if you take a look at these, all those nuibers are less than the 5 x 10-7 for 22 23 Cesium 137 and 134.
l 24 Q
Were you aware of the Lawrence Livermore i
25 study that was going on at that time?
l l
t
127 1
A I was aware of the study from the standpoint 2
of them taking samples, fish samples and soil samples and 3
mud and silt samples.
I was not aware them taking the 4
samples like that in the retention basin.
5 Q
Okay, when you did become aware of their 6
report and their findings what action did you take?
7 A
None.
I was still less than 5 x 10.3 O
So basically what you're saying is tiot it
.9 wasn't your responsibility to do anything other than test 10 to the lower limits of detection based on whatever you 11 believed those to be at the time and, even though there was 12 evidence of Cesium 137 being found downstream, which was 13 possibly coming from your releases, you had no responsibility l
14 to --
I 15 A
I still did not at that time have any indicatie l
16 that with that concentration there that we could exceed l
17 10 CFR SO Appendix I.
You know, that was never really made 18 clear.
And I did not get any -- even in December when Ed 19 Bradley talked to me, you know, I did not get any guidance 20 from anybody above me, from Ron Rodriguez or Roger Powers 21 or anybody to say, " Hey, you better be changing your LLDs 12 here."
You know, " Change them, you got to do this. "
There 13 was no guidance.
24 Q
Well, wouldn't there be some responsibility on 15 you as a supervisor to --
1 4
128 g
A Yes, absolutely.
If I would have known that 2
with those concentrations we could have possibly been 3
violating 10 CFR 50 Appendix I.
4 BY MR. JOUKOFF:
5 Q
Why did you think that you weren't violating g
7 A
I had no reason to believe that I ever was.
g Q
So, therefore, are you saying that the report 9
by LLNL reported concentrations that did not. violate 10 10 CFR 50 Appendix I?
gg A
That's just one sample, one retention basin.
12 That does not give me enough information and I was not privy 13 to the Reg Guide 1.109 evaluations that Ed Bradley do,es 14 for calculating the fish uptake and uptake and' demand to 15 determine, you know, what isotopes and what concentrations l
16 you should be seeing based on the releases that you've done, 17 or how many gallons that you've released.
So I didn't know 18 that.
19 BY MR. MARSH:
20 Q
So you took no action to detemine if the 11 lowered count time was contributing to these contaminations?
22 A
That's correct.
13 Q.
Are you familiar with the company Controls for 24 Environmental Protection?
j 25 A
Yes, I am.
0
___.x__-m__
__-___.2_-_
129 1
Q Can you tell us what they performed, what 2
r' n ice they performed for your --
3 A
They performed environmental samples for us, 4
liquid, particulate, charcoal, milk, pretty muc.h the whole 5
gamut of environmental type samples.
6 Q
What kind of samples would you provide to 7
them?
3 A
We were providing samples from the plant p
effluent.
I think that there may have been -- or in fact to there were, there were samples sent there for the releases 11 from the Regen Holdup Tanks for those that we considered 12 as radioactive releases to determine gross alpha and I 13 believe the strontium 89.
I'm not real sure, yJu know, 14 exactly all the analysis they were doing on that.
15 Q
Are you aware of what the term composite 16 sample means?
17 A
Yes.
18 Q
Would you describe that, please?
19 A
Okay, that's -- each Regen Holdup Tank that 20 was considered radioactive release a sample was taken -- I 11 don't know a gallon or two gallons, whatever -- and then 12 based on the total number of gallons that was released a 13 certain Alquat would be removed from that contaiaer and 24 placed in another container and a composite of'all the 25 releases would be made.
9
_C______.-.________.-______:.__
'130 g
Q Are you aware that composite samples were not 2
taken to Controis for Environmental Protection at any 3
particular time?
4 A
To be honest with you, I wasn't that close 5
as far as to, you know, determine when composite samples
.6 were going and when they weren't going.
ILjust say that
.7 I don't know.
3 Q
What kind of records were required to be p
kept on the analysis'of the composite samples?
10 A
Well, the records that were taken at the time 33
-- and I don't think there was any requirement to do a 12 gamma' scan on those composite samples -- but that record 15 as far as the gross alpha and whatever else they run on it' I
would come back and that data vould be then utilized as 14 15 far.as the total information that would go to Ed Bradley.
16 Q
okay, at any one time did you discover that 17 there were missing documents from the CEP reports?
IS A
I'm not aware of missing documents.
19 Q
You described earlier in the interview that 10 you would dilute the RHUT with service water after the DRCST 11 water had been moved to the RNUT.
12 A
It wasn't a common practice.
It was only done 13 in cases where there was a situation where, you know, you 24 had one Regen Holdup Tank full and you were ge ting another 15 one full and you may want to get -- you know, to speed up as
.a D e e
131,
1 far as the process goes, you didn't have enough water, you
?
2 were shut down, you weren't regenerating the.demineralizers, 1
,3 that sort of thing. It wasn't a, you know, purposely done l
l 4
to dilute so you wouldn't see something.
I l
5 Q
But isn't that in fact what would happen?
6 A
Yes.
7 BY MR. JOUKOFF:
1 3
Q Isn't it also true that this same thing would occur in normal operation, that after transferring water 10 from the DRCST to the RHUT and then allowing all the other 11 secondary waters to come in you would get the same effect?
12 A
Exactly.
l 13 BY MR. MARSH:
14 Q
Who authorized the dilution of the RHUT?
15 A
I can't answer that.
i 16 Q
Would that fall under the responsibility of 17 your department or would that fall under someone else's i
1 18 responsibility?
1, A
We would probably make the recommendation, 10 but based on, you know, Operations saying, "Well, we need
]
21 to get this tank out of here," or whatever, you know, that j
)
22 may be.
Or we may, in situations where pre-October 1984 13 where we had a lot of MCPS there, we may want to dilute it.
24 Q
Where does service water come from, what is 25 service water?
---_____.-________._____--_-2,.____-_.______m-
132' 1
A
'Folsom South Canal.
2 O
Okay, so we're bringing in clean water?
3 A
Yes, clean.
4 Q
Clean, non-radioactive water?
5 A
Right.
6 Q
And if you have a problem with disposing of 7
more water then you --
3 A
It adds more water to it.
p Q
And now you're going to bring more water in-10 to compound your problem II A
Right.
43 Q
-- but the result of that compounding of the is problem is that you are bringing the total volume to A 14 point that creates a more difficult detection of the nuclideo v
15 isn't that true?
16 A
Again, I reiterate that that's exactly the 17 same process that we were going pre-1984; ever since we 18 started the plant up we have done those same things as we i
JP went along.
39 Q
But things changed.
21 A
obviously, in retrospect you're right that, 22 you know, we should have realized these changes and what 23 effect they may have.
I'll be honest with you, we didn't 24 realize it.
25 Q
Who was responsible for collecting and k
i 133 1
maintaining any records of moving water from the DRCST to 3
the RHUT?
3 A
I don't think there was anything specifically 1
4 in any procedure that said, you know, "You're going to be
' j
)
5 responsible" or "this group is responsible" for moving the i
6 water.
I don't think any records were kept of that.
The 7
operators may ha've put in their records to say, " Hey, I 3
moved 20,000 gallons over."
But those are not -- you know, i
e those are in a book that they use for turn over for their 10 people just to say, you know, "We put 20,000 gallons over 11 here, 50,000 gallons over here."
Those probably don't even 12 exist today.
13 And it wasn't any procedure that says you 14 should put those -- you know, you should keep track of how 15 many gallons you put over and that sort of thing.
16 Q
Are you aware of any sort of discussion 17 concerning the modification which the DRCST was able to be 18 moved to the RHUT, were you aware of discussions to conceal 19 that or not report it to the NRC7 10 A
Absolutely not.
21 Q
Are you aware of any discussions at all 22 concerning whether it should be reported to them or whether 18 it met the criteria for being reported?
14 A
I'm not awar's of any discussions Prior to the modifications to mode the DRCST 15 Q
d 0
l l
j j
__ a
h[
l 134 g
water to the RHUTs how was that water being disposed of?
2 A
Fall, we had -- do you have a time frame here?
3 0
Well, you choose a time frame.
4 A
okay.
5 Q
Give us a complete rundown of what you.know 6
about it.
7 A
Well, we have had before 1981 releases from 3
the Demin RC Storage Tank to RHUTs.
There was a period of 9
time, though, in which we were -- as we mentioned earlier 10 in the investigation -- that we were transporting liquid 33 by tanker to Beatty, Nevada to be solidified and to Todd 12 Shipyards in Galveston, Texas, And'the amount offliquid 33 that we were, you know, disposing of at that time aided us r
%s 34 in that we weren't building up the water in the Demin RC 15 Storage iank.
16 Q
' Okay,-isn't it true that part of the reason 17 that that was stopped was that it was very expensive?
Is A
No, sir, absolutely not.
It was a lot cheaper 19 for us to ship that water.
We were getting rid of water 20 for, you know, in the order of -- my numbers, I remember, 21 like, one to two or three dollars a gallon.
Whereas when 22 I solidify a gallon of water it's costing me, you know, in 25 the order of twelve -- at that time I think it was, like, 24 twelve to sixteen dollars.
15 Q
So once the NRC precluded you'fr m shipping f
a i
135 1
the liquids it then became more expensive to dispose of it 2
because you would have to convert it to a solid?
3 A
Uh-huh.
Except that now you have to work the 4
other way. These things are all balances from the standpoint 5
now you have to take and say -- before, as 2 mentioned, we
.6 weren't concentrating as much, okay?
So now we had to 7
turn around and concentrate it to higher levels but still 8
meet the shipping criteria to be able to meet all the 9
applicable Department of Transportation limits and that sort 10 of thing.
11 So you, therefore, reduce the total gallons 12 of water that now that you have to solidify.
But now what 18 that does is increases the total gallons that you have that 14 is distillate or distilled water that goes back to the 15 Demin RC Storage Tank.
l 16 Q
Do you know who was involved in the decision 17 not to start up the shipments in the solid form to be 18 disposed of?
You were disposing of it in a liquid form then If you stopped doing that and you had to make a decision as to II whether you were going to start disposing of it in a solid il form or --
22 A
I think you may have a misconception here.
28 Once you started and you have to, you know -- the difference N
is that the Demin RC Storage Tank is clean water, you know, 25 it's clean chemically clean.
That water can be reused back i
84
's e
's.
136 1
into the system,okay?
Now, the liquid that is solidified 2
is bottoms waste and it is a lot more radioactive.
Chemi-5 cally it is -- you don't ever want to use it.
It's got, 4
you know, high concentrations of chlorides and, things like 5
that.
So you can't reuse that water.
6 So there was no decision made that says we 7
won't solidify this water.
That water was solidified, the 3
aater that was from the bo' toms waste.
t 9
Q Is there any bottom waste in the DRCST?
i 10 A
No, nc.
Absolutely not.
33 Q
I notice that you have been taking notes of j
12 the questions and so forth. Are you under any instructions 33 at all to bring back the nature of the questions?
j I4 A
Yes.
15 Q
Who are you supposed to bring this to?
16 A
To Ray Ashley.
17 Q
And what role does Ray Ashley play?
18 A
He is the Licensing Manager.
And I think 19 their concern is because of the litigation that's going on 20 with SMUD for the liquid effluents that they feel that the 21 District needs some' knowledge of what's taking place here.
12 I haven't really taken real good notes because 13 I am relying a lot on what the transcripts are going to say.
4 24 MR. MARSH:
Phil, do you have anf other 15 questions?
t
'137 3
MR. JOUKOFF:
No, I don't have any other 2
questions.
3 MR.. MARSH:
Mr. Kellie, we covered a lot c'f 4
territory in the interview and asked.a lot of questions and 5
you have'given answers to most of our questions.where you 6
' had knowledge. _Is there anything that you would like to 7
voluntarily state for the record concerning the nature of 3
the release of the radioactive effluents that you feel is 9
important or relevant at-this. time?
19 THE WITNESS:
I think -- you know, I have said itanumberoftk.mes--thatit'sanunfortunatething.
33 I*
12 think it was a learning process for both the District and 13 for the NRC from the standpoint of radioactive affluent i
14 releases from a dry site, which ~1s new ground. And I -think 15 that both NRC and the utility was a little naive in realizin 16 what potential effects may have in doing these radioactive 17 releases and that, you know, I felt, and still feel that, 18 you know, the change in the count titne was not an illegal 19 thing to do, that I didn't violate anything, that I was i
29 always less than the LLD.
Any numbers that you see are 21 always less than the LLD when it's taken in the -- is less l
22 than this 5 x 10-7 23 And unfortunately, you know, we were not awareo 24 the people at the plant, I was not aware when these types 25 of things were going on at the time, the effect that those -d 3
e P
138 1
I even at those low levels that we were at -- the'effect that 2
that may.have on complying with 10 CFR 50 Appendix I.
3 BY MR. MARSH:
4
~Q Mr. Kellie, were you here freely and voluntarily 5
to answer questions?
6 A
Yes, I was.
7 Q
Was there any coercion or threats'or offers 8
of. rewards made to you by anyone, either th's NRC or from 9
your company, to answer questions?
1 10 A
No, sir.
Il Q
Were you coerced or intimidated in any way to 4
12 answer questions in a particular manner by your company?
13 A
No, sir.
14 MR. MARSH:
That will conclude the interview.
w 15 I would like to express my appreciation for your candor and 16 preparation for the interview and thorough answers.
17 The record is closing at 11:14 a.m.
IS
'(Whereupon, at 11:14 a.m.,
the interview was 19 concluded.)
20 l
21 22 23 24
__..m_.-----_____._m
._-____.__-__.___.----.-_m__-____.___--____m_
.... ~,. _.. i w
Tais is to cartify that the attached proceedings hoforo tho q
cvr *zD STATES NUCLEAR NEGUIATORY COMMISSION in the matter of:
.NE OF PROCEEDING:
INVESTIGATIVE INTERVIEW (CLOSED)
DOCEET No.:
NONE
'PIACE:
Rancho Cordova, California 2( March 1987 DATE:
were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear i
Regulatory Canaission..
~
.f.t
'~'!l W f,-
,.;> C.
I k
<s b s w. HIGGINS icial 'asportar v
Esporter's Aff111ation Jim Higgins and Associates l
9 EXHIBIT 9
Pase l% l of \\'6 9 Pages
.