ML20247F476
| ML20247F476 | |
| 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 8905300091 | |
| Download: ML20247F476 (77) | |
Text
-- . _ _ _
~~ '
g o lJ
.o 1
BEFORE THE 2 UNITED STATES ,
3 NUCLEAR REGULATORY COMMISSION ;
4 REGION V l)
' I 6 In the Matter of: )
)
7 INVESTIGATIVE INTERVIEW ) DOCKET NO: NONE
)
3 (CLOSED MEETING) )
' Sunrise Sheraton Hotel 11211 Point East Drive 10 Rancho Cordova, California II Tuesday, March 24, 1987 12 An investigative interview was conducted with GEORGE A. COWARD, commencing at 10 : 30 a.m.
g PRESENT:
15 RONALD A. MEEKS, Investigator 16 OWEN C. SMACKLETON, Jr. , Senior Inves tigator Of fice of Investigations , Region V yy Nuclear Regulatory Commission 18 19 20 21
~
22 23 .
24 G
N 8905300091 890516 hEDb -A 7 PDR
' S c 86 - 01 " EXHIBIT M Page I of 77 Pages
2 l . ,.
$o A
I CONTENTS 2 WITNESS PAGE 1 George A. Coward 4 Examination by Mr. Meeks , ,
3 5 Examination by Mr. Shackelton 30 i
( . '
6 Examination by Mr. Meeks 32 l
7 Examination by Mr. Shackleton 45 8 Examination by Mr. Meeks 46 9
10 11 12 is .
. 14 EXHIBITS 15 (None) 16 17 18 19 30 21 SS 24 15
3 f
wa 1 E E E E E E E 1 E E E.
2 10:00 a.m.
3 MR. MEEKS: For the record this is an interview 4 of George A. Coward. Coward is spelled C-o-w-a ,r-d, who is 5 employed by the Sacramento Municipal Utility District at the
. 6 Rancho Seco Nuclear Generating Station.
7 The location of this interview is Rancho 8 Cordova, California.
9 Present at this interview are Ronald A. Meeks, myself, Ronald A. Meeks, as well as Owen Shackleton. We're to 11 investigators for the NRC Of fice of Investigations, Field 12 Office Region V.
13 As agreed, this interview is being transcribed 14 by court reporter Margaret Devers.
15 The subject matter of this interview concerns 16 the management of the Effluent Program at Rancho Seco.
17 Mr. Coward, if you will stand and raise your 18 right hand, I will swear you in.
19 GEORGE A. COWARD 20 was called as a witness herein, and, having first been duly 21 sworn, was examined and testified as follows:
12 EXAMINATION 13 BY MR. MEEKS:
24 Q Mr. Coward, why don't you just briefly explain 25 what your current position is at Rancho Seco, how long you've e
l L/4' 1
been in that position, and then work back. What your 2 responsibilities were, back into 1984. l 3 A Okay.
4 0 Or you can start with 19 84 and work up if it's -
5 easier.
6 A Okay. That might be a little easier because 7 I'm kind of in a staf f position right now because of the re-3 start effort. I'm in an unusual position.
p Q Okay. We'll start in September of 1984, what 10 was your -- what were your responsibilities at the Rancho 11 Seco Nuclear Station?
12 A Okay. In September 1984 2 was the plant 15 superintendent and as the plant superintendent, I had the 14 responsibility for the operations Department, the Maintenance Department and what we called the Chem Rad Department, which 15 is is radiation protection,the Chemistry Department. Those 17 three departments reported to me as plant superintendent and 13 I in turn reported to the plant manager.
19 0 Okay and who was the plant manager at that time?
20 A The plant manager at that time was Pierre Oubre .
21 Q Okay and you had been plant superintendent for i 12 how long?
23 A From August of ' 83 and I was plant superinten-24 dent in September of ' 84 and I continued in that position 25 until September of '85, and then I was plant manager in '85
-.__ _m___._ . . _ - _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ . - _ _ _
- - ~ -
5
, 8 l 1 to September of '86.
2 O okay and what are your current functions now?
3 A In September of ' 86 I became what was called 4 the Deputy Restart Manager and I am now in a special staf f
' position working on the new organization develo'pment for the ,
5 6 Rancho Seco for the restart effort.
7 So, I'm not supervising any of the plant staff 8 or any of that part of the organization right now.
9 Q Okay. You, before we went on the record, you 10 reviewed Special Report 84-07. That report for the sake of 11 the record is a report f rom Mr. Rodriguez, Ronald J.
12 Rodriguez, who at the time was an Executive Director Nuclear 13 for the Sacramento Municipal Utility District. Ihe letter 14 is sent to J. B. Martin, the Regional Administrator of the 15 Region V, NRC Region V in Walnut Creek, California. As 16 we've referred to, it's entitled Special Report No. 84-07.
17 We'll refer to it as 84-07 and it's dated September 27, 1984.
18 That letter has attachments to them. The attachments are 19 called the Near-Term Corrective Actions and the Long-Term 20 Corrective Actions.
21 Mr. Coward, what was you involvement in the 12 development of information for Special Report 84-077 al A I didn't prepare the letter. I was involved 24 in a lot of the activities that were talked about as far as 25 the long-term or short-term and long-term correc'tive actions, t
e
-___________..__-._m.
1 But as f ar as the preparation of the letter, I did not 2 prepare the letter. I was not involved in the preparation 3 of the letter per se.
4 Q Okay. With whom did you interf ace, concerning 5 the input of information to 84-0 77 6 A That would have been Pierre Oubre, the plant 7 manager.
3 Q Did you interface with anyone else?
9 A I don't remember. It's been too long ago. I to really don't remember what the interfaces were. I know we 11 -- at the time we were having -- we'd just had a steam 12 generator tube leak, and we'd just had another steam genera- 1 13 tor tube leak. We' d gone through several tube leak outages
- 14 and there were a lot of things going on because of the water 15 generation problem, if you will , the radioactive water 16 generation problem. So there was a lot of meetings. There 1 17 was a lot of interface by a lot of people end I don' t -- I 18 can' t say specifically, you know, who I met with or who I 19 discussed this particular letter with.
20 Q Okay but you do recall that you interfaced with ! I 21 Pierre Oubre, who was your supervisor at that time.
22 A Yes.
23 Q- Okay and what tine frame are we talking about?
24 A In regards to what?
15 Q The preparation of the material or the input of T
m
~a _______mmm__mm___m.m_____._._-____.m
M ;
.s 1 information into .the letter.
A In the , if you will, late summer of '84 up 2
3 until the letter was mailed out, we were putting together 4 our corrective action program and how we were going to deal 5
with the radioactive waste probem that had developed because g - of. the steam generator tube leaks. -
Q 'Okay. The -- when did the steam generator 7
3 tube leak occur that preceded this letter?
9 A Well, the most immediate one prior to this letter -- wait a minute. We had one in July. We had one 10 gg about Labor Day.
32 O Okay.
gg A And then we had another one right af ter that.
We had three tube leaks from July to like October. We had
- 14 15 three tube leaks almost back to back to back. We'd run about 1g two weeks, then another tube leak, and we'd run about a week 17 and another tube leak.
13 Q Okay. Specifically what information did you 19 develop, or review, or analyze, or input to 84-077 20 A I don't remember that far back on any of those 21 kind of details. I really don't.
22 Q Okay. What other officials w. ire responsible 23 for the information in 84-07?
24 A Again , I don' t -- I can' t give you the names I know Pierre was ,
15 of people, but I know Rodriguez'was.
O k
e L
8
?
L ..
l 1 myself. Let's see, Roger Miller retired then? - Was Roger 2 retirad?
- 3) Q He retired in 19 85.
4 A ' 85, Roger Miller would have had input to th a t.
5 In all likelihood Fred Kelly. There was people in design engineering that were involved in what we were going to do.
6 7 Q When you say design engineering, who are you 3 referring to?
9 A .
The nuclear' engineering group, but I don't 10 know individuals by name as to - Lee Keown probably would 11 have, as the manager of nuclear engineering, would have been-12 involved in some of these meetings, as well as people that 13 worked for him. ,
i
- 14 Q Okay.
15 A Because we, if you will, when we recognized 16 where we were, we tried to put together a swat team so to 17 speak to go in and attack the problem. So there was resourc 18 coming from all parts of the organization, from outside of 19 the organization. From Bechtel in these evaporation ponds 20 we were talking about, we asked them to come in and give us 21 some help in that area.
12 So there was an awful lot of people involved 18 in what was going to be our corrective action plan, as to 24 how we were going to limit the releases going off-site.
25 0 Okay, okay. On page 2 of the report here, of
-__-_~____--_-______._--._--__m. _ . _ _ . _ _ _ _ _ . _ _ . _ - _ _ . - - _ _ _ _ . _ _ _
9 a
1 84-07, the last sentence in paragraph 3, starting right 2 th e re .
3 A The tube was subsequently, statement -- no.
4 This action may eliminate the major source of se,condary 5 system contamination which led to the exceeding of the above-6 stated limits.
7 Q Okay and that was the correction of the steam a generator tube leaks and they talk about that being a major 9 source of contamination. Are you aware, Mr. Coward, of any 10 other sources of contamination for the secondary system?
31 A No. The tube leaks were what caused the 12 secondery system' contamination.
33 Q Okay. Now on paragraph -- the last paragraph 14 on page 2 of this report describes the pathway of secondary water and its release to the environment. Were you respon-15 16 sible for the original input of information contained in 17 that paragraph?
13 A I doubt it because that's the standard 19 description and I would imagine that -- I don't know who 20 wrote that paragraph, but it would have been anybody from 21 the plant staf f.
12 Q When you say plant staff --
23 A It could have been somebody from operations.
24 It could have been Ron Colombo from regulatory compliance.
15 It could have been a number of people because, you know, O
e u-_ _________.____-_____._._____.___m_ . _ . _ _ _ _ . . _ _ _ _ .
10 4
I that's f airly common knowledge as to how water made its way 2 from the secondary plant out to those holdup tanks, if you 3 will. So it was f airly common knowledge and I don't now who wrote this paragraph. I could have written,it. I didn't 4
5 write it but the information there is f airly straightforward.
6 Q Okay. Now, there was a modification that was 7 made from the demineralized reactor coolant storage tank to 8 the regenerative --
l 9 A Regeneration holdup tank, to O okay, the regeneration holdup tank. For the 11 sake of expediency, why don't we refer to the demineralized 12 reactor coolant storage tank as the DRCST tank or DRCST, 13 dbat's the way I've heard it, and the regenerative holdup 14 tank as the RHUT, R-H-U-T tanks. The D-R-C-S-T or the 15 DRCST and RHUT tanks. There was a modification which allowed What 16 water in the DRCST tank to be transferred to the RHUT.
17 was the reason for not reporting the modification which 18 allowed that water to be transferred in Special Report 84-07?
19 A I don't know. My assumption would be that it 20 waspQt consiliered to be the type of modification that needed 21 tog _ talked. about in here and it wasn' t part of the -- that 12 pipe wasn'.t- put in as a result of the secondary site con-25 tamination necessarily. It was put there to be able to 24 release tritiated water, which we -- that tank could fill up .
25 So the evaporator process would basically clean water other m
11 4
1 tritium. Clean from a radioactive point of view. And it 2 was the modification was put in there 'to be able to move 3 the tritiated water over to those tanks so we could discharge 4 it and still be within limits , and it wasn' t the pipes that 5 was put- in there necessarily to deal with the radioactive 6 secondary sys tem.
7 Q Okay. Could you describe the path that water 8 took to get to the DRCST?
9 A Well, it primarily came out of our evaporators.
10 We have two evaporators. One is what's called a boric acid 11 concentrator evaporator, which primarily takes reactor coolant 12 system grade water and gets rid of the boron, most of the 13 boron, and the activity out of it. Of course the tritium 14 can't be separated from the water. So you take the water off 15 the top of the evaporator and it goes over to the reactor 16 coolant storage tank.
17 We also have another evaporator, which is 18 called a miscellaneous waste evaporator, which is a lot of 19 the drains and so forth that come into the plant to run 20 through the filters and processed through the evaporator.
21 That evaporator can also put water over to the reactor 22 coolant storage tank. It typically doesn't. It puts it into 23 another tank.
24 Primarily the reactor coolant storage
-6 tank is 25 water that's generated from the boric acid concentrator s
9 t j
O J
_-___._--_-_-_____-_-_-_______D
12 1 evaporator. But over a period of time of feeding and 2 bleeding the reactor coolant system and recycling water, d3' 3 reactor coolant storage tank slowly fills up and the plant 4 was never really designed from the beginning to be able to ,
5 deal with that tritiated water. Originally we were going to 6 ship it by truck, which we could when we des'igned the plant, 7 to be able to get rid of tritium and, of course, that then 3 was eliminated as the regulations changed.
Q Okay. Did water from the RHUT tank, did it 9
10 ever have occasion to be transferre'd to the DRCST tank?
A Not directly, no. No way. There was no way 33 12 to do that.
33 Q Directly or, indirectly did it ever -- did you s 14 have a cause to ever transfer water from the RHUT to the 15 DRCST? You said not directly, indirectly.
A Well, let me describe the process. I can't.
16 17 say specifically whether we took water that came from the 18 RHUT that made its way by way of the evaporator back to the 19 reactor coolant storage tank. I don' t know that. But the ,
20 process that we set up to be when we had activity in the f 21 RHUT's, we put in a. temporary piping system to pump that 22 water back to the turbine building to a sump where we could 23 then pump it back to the -- what we call the basenent of the auxiliary building. So we then could run it through 24 ,
Now, whether 25 evaporators to take the activity out of it. i m
- - - - - - - - - - ..----------__.-.----------------------------.--_--a__-- _ - - - - - - - - - - - - - , - - - - - . - - , - - - , - - , - _m
13 e
t- we transferred any of that, you know, water coming out of 2 the evaporators, which basically would be tritiated water.
3 It may or may not have tritium, because some of the secondary 4 activity water had very little tritium in it'. It may have 5 some - cobalts and cesiums and things- of that nature.
~
6 So, I can' t say precisely whether SHe ever 7 transferred any water by way of the evaporator from the RHUT 3 back to the demineralized reactor coolant storage tank. If 9 we did, it would have basically -- it would have had to gone through the evaporators. That was a given, and if it went 10 11 through the evaporator, basically you'd have had tritium 11 left in it.
13 Q Um-h uh .
s 14 A Did I answer your question?
Q Yes, you did. Who would know at that plant, 15 16 who would have knowledge if in fact water from the RHUT was 17 transferred indirectly,. like you said, through that system, 18 through the sump, to the basement, through the boron 19 evaporators, to the DRCST7 Who has the pulse speed of that?
10 A I can' t -- I wouldn' t know. Some of our 1
11 records, you know, again, some of the operations people might be able to tell you. Some of the radiation protection 12 13 chemistry people might be able to tell you. Or there might 14 be records that would indicate. Typically I don't know that 15 we -- when we pump water back to the basenent, that we
^-----m._______.m_,,,______, ___ __ _ _ _ _ _
I necessarily kept a record of it. Because we knew we had it 2 in the tank and we knew -- we ran tests on it and the ;
3 records might show we pumped it back into our storage tanks, 4 in the basement, and from there we didn' t -- I don't think 5 we really kept an accounting of how it made its way around 6 in the basement of the building, if you will'.
7 0 Okay. Who is responsible for -- who has the 3 authority to say: All right, RHUT water, it can be trans-9 ferred back into the primary system.
10 A It came out of chemistry, primarily out of the 11 chemistry radiation protection group. They would sample 12 the thing. There'd be a decision made that we didn't want 13 to release the tank and we would pump it back to the basement .
14 Q Okay and --
15 A And operations would actually perform the 16 function of pumping it to the basemeht.
17 Once it got in the basement, then it was 18 operations responsibility to decide what they did with the 19 various tanks of water, and where they processed, and what 20 they did with the water.
21 Q When you say operations, you're talking about !
12 the reactor operators?
13 A Right. The operations division of that 24 organization.
15 0 And who supervised, say in '84 and '85, who
__--____________m___a-_m_ _ _ _ - u.- _ _ _ _m-_ -__,_--_m-_.__m-
15 u- p
- ' . 1 1
g supervised daat division?. H u
2 A We've' gone through several supervisors. Th at ' n 3 why I'm thinking here. That would have been I think Dan 4 Comstock. .l 5 'Q Okay. At least during part of the . time, he wad g the supervisor of the operation division? ;
i 7 A Right.
3 Q During part of.that period of time ---
p A I think Dan was the guy. I'm trying to.get my dates straight. I think Dan was the operations superviso8 10 gg from summer of ' 83 until January or February of ' 85. So 12 that would have covered the ' 84 time frame that Dan would 33 have been the supervisor.
34 Q Okay. Do you recall who it would have been 15 during 19857 1g A 19 85 would have been Bill Spencer.
17 Q Okay. Now you say when a decision was made nog 13 to release the water from the RHUT, then when you sent it 19 back, what was the criteria that you used not to release the 20 water, or whether you were going to release the water or noti 21 A Well, it depended on the amount of activity 22 and the kind of activity. I can't quote you verbatim what 25 those numbers were at the time. Primarily the recommendation 8 24 would come out of the chemistry radiation protection people.
15 They' d do the analysis and then say it's got this much
_ . _ _ _ .._.___.____.________._.____m_-_...____-.__m_.m__ . _ . _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _
16 I activity on it, in the tank, and then we would transfer the 2 water back to the basement. But exactly what the criteria 3 was at that time, I don't recall what the numbers were.
4 .Q Okay. Roger Miller being in charge of that 5 department, he would know or at least he would know who 6 would know that?
7 A Roger would have a lot better knowledge than 3 I would, yes.
p Q Okay. Now, Roger reported to you?
10 A Yes.
gj Q Okay and Comstock and then Spencer reported 12 to you?
13 A Correct. Yes , that's true.
14 Q Okay. So when radioactivity in the RHUT was 15 at a level that was unacceptable to release by the regulatica 16 the guidelines, the tech specs, then it was sent back to 17 the system?
13 A Um-h uh .
19 Q Okay. When we say back to the system, we're 20 talking about through that path you described to the DRCST?
21 A Well, not necessarily to the DRCST. It would
' 22 go back to the basement of the auxiliary building and be 23 processed through one of the evaporators, and typically it 24 was a miscellaneous evaporator, which might put the ef fluent 25 in a miscellaneous water holdup tank, which was not the D
L - .- --_ - - - - - - - _ - - - - ___---_ _ - - __ _ _---_- _ _ _
17 j I
- g. DRCST. It was another tank and that water is reused when 2 .we. have to hose something down in the contaminated area, 3 we use that water because it basically is clean except that ,
I 4 it has tritium in it and it's piped into the reactor building 5
and we flush, we hose the field transfer canal hen we're 6 done refueling the things, with that same water. To try and 7 recycle water as much as possible.
8 So it wouldn't necessarily have been trans ferred 9 directly from the RHUTs through the evaporators back to the 10 DRCST. Not necessarily that pathway.
Q okay. If it did transfer to the DRCST, then 11 12 it went through the boron evaporators?
gg A It could have gon,e through either one of them. ,
s 14 Q It' d still have gone to the DRCST?
15 A Yes. We had a way of moving water out of the 16 miscellaneous waste evaporator to the DRCST. But primarily 17 the DRCST tank was fed by the boric acid concentrator 18 evaporator. 'Ihat's where the bulk of its water came from.
19 Q Okay and Mr. Miller or one of his individuals 20 would know whether the water coming out of the RHUT, say 21 for any particular transfer, the water coming out of the 22 RHUT back into the secondary sump and then into the basement, 13 for that' particular transfer, he would know whether thm 24 were going to put it to -- or his designee who is working 15 for him -- well, wait a minute.
M- __--------_---__-__..s - - - - - - - - - , - - - - - - - -
18 l r
1 A wouldn't necessarily. l 2 Q He would be, if I understand you right, he 3 would be responsible for determining that it has to be 4 returned back.
- 5 A That's correct. q 6 O And then once it got back into the system, 7 then the Comstock or Spencer would be responsible for 8 whatever the need would be at that time, where they' re 9 going to transfer it?
10 A Where do they have space, where do they have 11 need for the water, and where do they put it after they 12 process it. That would be their decision.
13 Q Okay and you say that once the water went 14 into the basement of the reactor building no record was 15 kept of it?
16 A Basement of the auxiliary building.
17 Q 3asement of the auxiliary building.
18 A Right. There I don' t think that there would 19 be any traceability, if you will, that the water went f rom 20 the RHUT, to this tank, to the evaporator, to this tank. I 21 don' t think you would find that traceability of the water.
22 You would find that the RHUT was pumped back 23 into the' basement but from there you probably wouldn',t find 24 -- that water would have been mixed with other water that 25 was maybe already in the tank. We had a 60,000 gallon tank.
e e
l 19 1 It might have had 20,000 gallons of water in it and you pump 2 another 30,000 gallons of water into the tank. So it, you 3 know, it mixed together, f rom there it would go through the 4 evaporators.
Okay. So what would be of record is the RHUT,
( 5 Q 1
6 the particular RHUT tank, that was tran*# erred back to the 7 s ump --
8 A Right.
9 Q -- in the secondary system. That would be to on record?
11 A To the best of my knowledge it should be.
12 Q But you're not familiar enough with the pro-9 13 cedures or the paperwork to determine whether it is?
14 A That 's right.
15 Q Okay. But Mr. Miller should be?
16 A "r. Miller, Mr. Comstock, or Spencer. One of 17 those folks.
18 Q Right and then operations picks up on that 19 water when it's transferred from the sump into the basement or auxiliary? l 20
. 21 A Right, right.
22 Q Okay and there you feel that probably that's 23 where the paperwork stops and that's where the need picks
. 24 up. You have this water, where is it needed or where can it 25 be stored?
" " - - ~ ~ - - - - - - - - - - - - - - - _ - _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
20_
. q 3
A That's right.
2 Q Okay. So based on what you've explained to ,
1 me, then water from the RHUT could end up in the DRCST tank 3
4 when you transferred it back? *
. i 5 A The answer, yes it could.
6 Q okay and then concerning that modification, 7 that water was transferred back to the RHUT?
g A If you're trying .to make the connection that 9 we ran u.tte; from the RHUT to the basement, to the DRCST, 10 back to the RHUT --
gg Q 'Ihat's conceivable?
A That's conceivable but there was never any 12 intent to do that directly. The DRCST tank was only emptied 33 b 34 when the level got high enough that we didn't think we had 15 enough space to deal with the water management and the pipe 16 was put in strictly to deal with tritiated water. And if 17 I remember right, that pipe was put in long before, we used that pipe prior to ' 84. Because we were drowning in 13 to tritiated water and before we ever had the steam generator 20 tube leak, we had excess tritiated water we had to get rid of. So, yeah, you could make that path. But I can tell you 21 22 straight-away that there was never any intent to say, 23 process it here, process it here to put it back over hers.
24 Q In talking about this modification, both af ter 25 1984 and before 19 84, September of 1984, this report, and
21 i- .
I' ' before. the [ initiation or the onset of.the' steam generator 2' tube. leaks, this modification existed and it existed to get g 3 rid of. tritiated water?
4' AL The modification -- what we _did was -- you-5 ,can call it'a modification. What we did, we used ' temporary 6 plastic pipe for some ways of. transferring water. Exactly.
7 when we used that, I don't -- I can't tell you in a year 8 time frame. Whether it happened in ' 81, or whether it 9 happened in '83, or exactly when it happened.
10 Q But you did say, didn' t you, that it was 1 11 before -- you did use it before the steam generator tube 11 leaks? That's what I understand you to say.
13 A Before these ' 84 tdse leaks. I'm not so sure-
< 14 we used it before the ' 81 tube leaks.
15 Q oh,.okay. All right. But the purpose of it_ ,
1 16 was you had a water buildup, you needed to release the 17 water, and that water had tritic s in it.
18 A' Right.
19 Q so it was mainly to get rid of the water 10 because you were waterlogged?
11 A That's right.
12 o You know, backed up.
23 A That's right.
24 Q Okay. Were you ever involved in any discussica 15 -- or what was your involvement actually in the discussions
-22 y ,
W-1 of whether that modification should be reported to the NRC 3 or not? i A I don't recall any discussions about that 3
4 particular aspect of it. ,
g Okay. In 19 85 it was reported th'at ther was 5
6 787,500 gallons of water that were released from the DRCST 7 to the,RHUT. What was it when that, the activities going 3
on in your- plant, that caused that amount of water to have 9 to be released? And I'm not saying .that's a great amount or 10 a small amount, or the -- but --
33 A In '85?
" Q In 19 -- you know, during 1985, that's the _
12 So 13 amount that was. transferred from the DRCST to the RHUT.
14 whK's causing that amount of water to be released?
15 A Well, to answer that question, all I could 16 give you would be the brief rundown of the operating history 17 of the plant. Because I, again, I don't know whether that's I never really tracked that 18 a big number or a small number.
19 number. So I guess I'm trying to figure out what's really 20 your question.
- 2) Q In other words, your water, your plant, your Okay. What's causing it 22 DRCST is filling up with water.
In other words, water keeps coming 23 to have 'to be released?
in and it keeps filling up.
What causes -- what's causing 24 25 th at , you know, that water to be -- have to be stored in the t
._a---x -,-. . - - - -~~-- - - - - . - -~--- , - _ . . - - - - , , - - - - , , - - - - - ~ - - - - - - - - - . _ - - - - - _ . - . ~ . _ _ _ - - , - - - - - - - - . - - - - - . - - - --a_.-__--__-w___- --_-,.__---_ua - - - _ _ - - - _ _ _ _ _ - - - - , - - , _ _ ,
23 O
O 1
DRCST continually, so that it continually has to be -- water has tc be released to the RHUT. Th ere 's ' s ome thin g , some.
2 ,
t 3
activities in that plant that's occurring and in 1985 you 4 were involved in an outage from March to October and -- way 5 I've got it here.
, 6 A Now, in --
7 Q That's the general -- my general impression, 3 from March to October, there's an outage.
p A Things that cause that to go up is a lot of 13 draining and filling of the reactor coolant system, because we end up with water to process. In '85 we had a refueling le 12 outage and we had to flood the canal, and drain the canal, 13 and reflood the canal. .
14 o What canal are you talking about?
A The fuel transfer canal, the refueling canal 15 in the reactor building. Because we were working on a 16 17 reactor coolant pump, we had to drain and fill the canal a 13 couple extra times. And again depending on our tankage 19 situation in the basement, depending on the evolutions that 20 are going on, depending on the quality of the water when 21 you drain it out, you end up processing water through the evaporators sometimes and sometimes you don' t. Okay.
22 I
23 Depending on the condition of the water that you drain out 24 of the system when you do those evolutions.
25 So, to say we had unusual conditions in ' 85, l
l l
24' t
1 1 I guess I don't know. We probably ended up with more water 2 in that tank. But I don't have a good answer for that one.
3 Q Okay. Who would know that? Who would have 4 the pulse beat on that?
5 A '85, it'd probably be Fred Kellie or -- Fred }
6 would probably have the best, Fred or Roger, because Roger 7 was there for the first half of ' 85. !
j 3 Q Okay. How about --
A Possibly the operations, Bill Spencer. Bill 9
10 Spencer may have.
33 Q Okay. What management controls did you 12 utilize to assure that water transferred from the DRCST to 13 the RHUT was properly' sampled for radioactivity?
, 14 A We used the analysis of the DRCST tank, was 15 analyzed on a regular basis, and when we got ready to move tg water over, we would look at what do we have in the RHUT 17 tank? And we would look at how much tritiated water could 13 we move over there and still be within our release require-19 ments, and then we would transfer that amount of water and 20 typically fill the RHUT tank up with clean water and then 21 make the release.
22 Q At what point did you sample for -- I think 23 you had mentioned earlier that cesium 137 and 137 were 24 particularly troublesome. What was there -- what was that 25 activity that was there? When did you sample to see what i
_------________-______________________m _
25 1
1 the amount of your gamma emitters were?
2 A I don't think we sampled each transfer. Because 3 we had very minute quantities of activity in the DRCST tank.
4 It was primarily tritium was the main contributor and as I 5 recall, we didn't make an individual sample as e trans ferred 6 -water over. We sampled the RHUT tank prior 'to release but 7 there was not --'I don't recall any individual sample of 3 the DRCST tank prior to pumping water from one tank to the 9 o the r.
10 0 Okay. Special Report 84-07, it has near-term 11 corrective action itens. You had nentioned that you were involved 12 in those -- implementing Ebose. Action Item No. 7, and why 13 don't we go to the description of it. It's on page 3 of s 14 the near-term corrective actions attachment, and it states 15 at action 7, and let's just read what it is:
16 "The district has initiated a policy that 17 all releases will be controlled, such that technical 18 specification 3.17.2 limits will not be exceeded. All 19 sampling of the RHUTs and releases of liquids will be based l 20 on this objective. The chemistry and radiation protection 21 personnel responsible for evaluating the releases have been instructed concerning these objectives. This action, 22 23 coupled with action 9, will provide a second level of con-24 trol beyond the other near-term actions specified herein."
25 What was the policy? You know, it talks about t
26 1 the district has initiated a policy that we will not exceed 2 tech specs 3.17.2. What was that policy? j 3 A Basically the commitment was that we wouldn' t 4 make -- I put this in the context of a public statement, 5 that we wouldn't make radioactive releases. Meaning by that 6 it was -- internally we defined that as based on our samples ,
7 out of the RHUT that we wouldn't have any gamma peaks when w t trans ferred water <to the retention basins.
9 So, that basically was the policy. We went 10 to throw away resins, we did a lot of things to say that we 11 were going to tighten up and attempt to meet the Appendix I ,
12 guidelines. Recognizing the plant was never designed initially to meet Appendix I, but we did a lot of things to 13 14 try to stay within the Appendix-I guidelines and diat was 15 really what that policy was. It was not a -- if you went 16 and said, "Well, where is this new policy?" I don' t think 17 there was ever a memo written that defined that thing in 18 detail as a policy statement.
19 Q But it's your understanding that what the poli 20 was , is you would not release gamma emitting nuclides. Okay.)
21 A Well, again, and I assume your questions are !
going to drive to this counting time things. You know, that 22 was based on our counting time. The sampling program we 23 24 had in pla8e at the time, if we had -- if there was no gamma. emitters, it was called LLD and it was released. You'll 25 f
27 1 probably want to know what LLD is.
2 Q Ri gh t .
3 A Lower limit of detection.
4 Q Okay. Yeah, well let's explore that a little 5 bit more a little later.
6 A Okay.
7 Q When we get to that area, but basically that 8 was it. You weren' t going to -- the plant, the commitment p was made to not exceed the Appendix I limits and essentially to what that meant was to do tha't, you don't release radio-11 activity --
12 A Gamma emitters.
13 Q -- of gamma emissions.
14 A Right.
15 Q Okay. What were your responsibilities and 16 how did you carry them out to assure that action, you know, 17 the Action 7 policy was implemented in conjunction with the 18 commitnent made in special -- in 84-077 19 A Well, that was basically what I just said, 20 that that was the direction that was put out to the 21 andssion and radiation protection people and the operations people. That we wouldn' t put out any activity that had 22
'9 the 23 gamma emitters in it and we would take it back 24 basement and process the water.
15 Q Okay. Who did you receive that instruction
28 1 from? In other words, let's talk about the coordination of 2 that.
~
3 A That came from Pierre.
4 Q Pierre Oubre. Were you ever present in 5 meetings where this action item was discussed $nd that you 6 were going to implement to make sure that you didn' t --
7 A As far as sitting in a meeting, I don't know.
8 I can' t recall that.
9 Q Okay. What actions did you take -- in other 10 words, what directions did you take to the individuals under 11 your supervision concerning the near-term -- Action 7 near-12 term corrective item?
13 A Well, basically it was verbal direction to the 14 operations and radiation protection chemistry people of 15 what the policy was. We may have issued some special 16 operating instructions to the shif ts but I don't recall 17 whether we did or not at this point in time.
18 Q Okay. So, Action 7, the policy in action 19 item -- near-term corrective Action Item 7, once again it 20 goes back to instructions that you received from Pierre 21 oubre, which you don't specifically recall any management 22 discussions or meetings about this, but you do recall if 23 not specifically, the fact th at instructions were given to 24 you or directions, or counsel, that you know, we adhere to 15 Appendix I limits, no gamma emitting nuclides are released?
e
__m__.-____.__ _ _ . __ ____ _ . _
29 1 A Right. That was the direction.
2 O okay and if there were gamma emitting nuclides 3 in, I assume in the RHUT, that was the point of release, then 4 the water went back into the system?
9 5 A Or we did something else with it. We put a --
6 we ultimately put a portable demineralized out there. But 7 the idea was we cleaned up the RHUT before we dumped into 8 the retension basin.
9 Q Okay. So you could put it back between the two 10 RHUTs A and B, through those portable demineralizers to 11 clean it out?
12 A Right.
13 Q Okay. Action 8 of the near-term corrective 14 action items, states that the processing of water from the 15 PDS to the RHUTs to the rad waste system, coupled with the 16 dilution of the liquids, will help insure compliance with 17 the limits of radioactivity released in liquid ef fluents.
18 What is meant by dilution of liquids?
19 A I guess I don't know. Th a t -- we -- th at 20 could mean the dilution at the creek level. Because we, 21 somewhere in that period of time, we increased the dilution 22 flow down the creek of what it had been. We'd normally run, 23 I don't know, three to five thousand gallons a minute and 24 we upped that to 10,000 gallons a minute. So, what ,
25 specifically is meant by that statement, I don' t know.
i 30 4 :.=
1 That's one possibility.-
2 O If you' d want the answer tr that_ ques tion, who .
)
3 would you'go to?-
4 A I guess I' d go to the guy that . wrote that
' l
- 5 paragraph and I don' t know who that is.
6 Q Who would be able to tell you who wrote that.
7 paragraph? In other words, who had overall responsibility 3 for drawing the information in 84-07 and.its attachments 9 together?
10 A I think that was Pierre.
11 Q Pierre Oubre. .
12 A Um-huh.
13 Q Okay and then he would be able to indicate
- 14 the individual who worked with that particular thing?
15 A Yes.
16 Q And then that individual would be able to 17 explain dilution of liquids, if it meant more than what you 18 think it possibly might have meant.
19 Just from your own knowledge, who normally in 20 the plant would know that? In other words, whose bailiwick 21 is that area, the dilution of liquids type of thing?
22 A Typically the chem rad area.
23 Q Okay.
24 BY MR. SHAC KLETON: -
25 Q While you're looking to ask Mr. Coward a t
m
~
e
< \
question. When the water goes f rom the RHUT tanks to the 1
2 rention ponds, I understand there are two?
3 A Yes.
And then what typically happens ? 1he water 4 Q I'm 5
sits there for evaporation purposes or I'm not 'f amiliar, 6 asking.
7 A Okay. We have two retention basins which are 3
a half a million gallon capacity each, and when we would make 9
a release from the RHUT to the retention basin, we would 10 typically fill up a basin, sample it, and then' release it.
33 So while: one basin is filling, . the other other basin is on 3;
standby or is being sampled to be released, and it's a 13 second check before the RHUTs, if you will, REUT. water is discharged of f site. And it's not only for activity but 14 15 it's for all the stuf f to meet the California Water Quality 16 Control Board's things. If we've got to neutralize, we put a system out there. If the thing was out of spec cn1 pH or 17 18 any other things, then we had to correct that prior to 19 release.
0 That's a line -- those are lined ponds then?
20 A It's concrete ponds , yes.
21 Q
And then from the ponds the water is pumped or 22 25 released'into Clay Creek?
A That's correct. It's released off site.
24 25 0 And that's what takes it off site?
a
---"--------m.m._ _ . _ _ _ , _ . _ _ _ , _ _ _ _
32
~4 1 A That's right.
2 Q Thank you.
b 3- A It's at that point also that ' depending on the 4 chemistry in the retention basin, that pump . dilution water 5 in at that same. point. That's where the dilution water 6 comes in.
7 BY MR. MEEKS:
3 Q The bases in technical specification 3.171, l
1 9 limiting conditions for operations, and 4.21.1, surveillance ,
1r standards for liquid ef fluents, state that:
11 The specifications do not assure compliance 12 with 10 CFR 50, Appendix I, and dose objectives. Mainly 13 because of the insertion of the word not in the second .
1 s 14 sentence of those bases. Explain why these technical specifications cannot assure compliance with the dose 15 q 15 objectives of 10 CFR 50, Appendix I.
17 A Based on my recollection of when there tech 18 specs were prepared, that it was recognized by the people
-19 that put these tech specs together that if we had a bad 20 steam generator tube leak because of plant design, there 21 would be no way that we could comply with Appendix I for
~
22 that happening. And I think that's the logic of why that 23 word not was put in there.
24 Q Okay. Now these tech specs were implemented 25 in July of 1984. They're referred to as the RETS or i
33 j i
1 Radiological Environmental Tech Specs, and they became 2 effective in July 19B4, and so in those tech specs, they 3 refer to not -- refer not to unusual occurrences like a 4 steam generator tube leak. They ref er to the normal 5 operation of the plant, don't they ?
g A Tech specs govern at all times for plant 7 operation.
3 Q okay.
9 A I mean that's a given.
10 Q All right.
11 A It's part of our license.
13 Q Sure, absolutely. Okay. So, it's your under-13 standing that the draf ters of those tech specs realized that
- 14 with a steam generator tube leak of more than just minor 15 importance, you know,. significance, and possibly because of 16 that type of tube leak, then you couldn't keep within tech 17 spec -- excuse me, within the tech specs and naturally within 18 Appendix I limits?
19 A That's correct.
10 Q Okay. Who was responsible for the draf ting 21 of those technical specifications?
l l 12 A The guy that I would send you to to talk to 13 would be Ron Colombo, because he was our regulatory complianc e:
24 guy that handled tech spec changes. I know he didn't 15 necessarily draft these all by himself but he could tell you
H 34 1
' ~
1 who put together these tech specs. He's helped put it l
2 toge the r. I know Roger Miller was involved and there were 3 some others involved. But Ron Colombo and Roger Miller 4 would be the two key players.
5 Q Okay. When did you first become' employed at 6 Rancho Seco?
7 A I've been at Rancho Seco since 1970.
3 Q 1970, okay. But you were never involved in 9 the draf ting of the tech specs , these tech specs we' re 10 referring to now?
11 A Not the RETS, no. I was not involved in the 12 RETS in any way.
13 Q Okay. Now were you ever involved in any 14 discussions concerning the insertion of the word not in 15 these two bases?
16 A No, I was not.
17 Q Okay. Mr. Ed Bradley, he issued a draft, 18 lower limits of detection study on -- he issued it on October 19 29, 1985. And that draf t study indicated that Rancho Seco's 20 technical specifications on lower limits of detection was 11 not sufficient to assure compliance with the dose objectives 12 of 10 CFR 50, Appendix I. What management actions did you 13 take to ' assure that Bradley's concerns about the suf ficiency 14 of, you know, Rancho Seco's LLD's, were properly evaluated 15 and f actored into the district's commitment not to exceed a.
35 p
1 Appendix I dose objective limits?
2 A When did you say that was issued?
3 Q TMt was October 29, 19 85, he issued it.
- '4 A Well that was the first indication, that I knew 5 about, and I'm not exactly sure. Bradley had issued.a memo 6 that never made it's way through the chain and I don' t know 7 whether that's the one you' re talking about. Do you have a 3- copy of that memo?
y Q Yes, I do. I'll show it to you. It was sent 10 to Colombo, Kellie, Powers --
11 A Okay. Okay.
12' Q -- Braun and Kaplan.
13 A What we did was, and again I'm not sure of time 14 frames, that we changed our counting times .and we have now 15 even gone a step further and developed an elaborate program 16 for monitoring where we are at any point in time in regards 11 to Appendix I on an annual basis. Now there has been a lot 13 of things happen since October of ' 85, so I can' t put all 19 this in context of -- of course the plant shut down in 20 December, and there's been ongoing changes all throughout '86 .
21 The only immediate thing that I can think of, 22 and again Idm not exactly sure of time frame as to how it 13 relates 'to October 29, was changing the count times on the 24 samples, which effectively changed the LLD on the samples 15 coming out of the RIIUTs.
a
... _ _ _ _ _ . _m m m_ -__- _______.i__--m._m______.m___--m_______ ___.___________mm___-.---.-__ m__ - - . - _ _ _ - - - - - - -- --
36
. J 1 Q Um-h uh . Could you explain that in a little I
i 2 more detail? l i
3 A Well, what are you looking for? I mean are. j I
4 you looking for technical explanation of it? !
5 Q No. A little more detail. on this counting 6 time. The counting time proceGure and how i' t was evaluated 7 and what the -- why the decision was made to change it and 8 what that decision consisted of.
t 9 A Well, the -- with a given sample size, the 10 longer you count the sample the greater the sensitivity. In 11 other words, you can find lower and lower levels of activityd 12 And this memo concerned the fact that our 2,000.second count 13 time if that's -- if we. assumed that the activity in the s 14 sample was just below the detection limit with that 15 particular count time, and you added that up for all those 16 gallons of water that we released, that you exceed Appendix 17 I. Okay.
18 By lowering, by increasing the count time, we 19 then lowered the LLD where based on a given quantity of 20 water, we would exceed Appendix I. We assumed all that wates 21 was just under the sensitivity at that particular count timec 12 Q By not lowering the count tf.mo?
23 A By increasing the count time, you' ra lowering 24 your LLD. And the assumption had been that if you assume 15 all the water that you release there is activity in it, but e
______o__m____a__ .m_ _ _ _ . _ _ _ _ _ _ _ _ _ _ -
37 I
g it's just below your LLD sensitivity for a given count time. I In other words, we could put clean water in 2
3 there out of Folsom South Canal, and in some cases we did for 4 dilution water, the assumption was th at it had activity in 5 it just below the minimum level of detection for a given 6 count time. ,.
7 Q Okay. So, you gave instructions to increase y the count time?
f
, A Yes.
0 Okay. Do you recall specifically when that 10 13 was?
A No, I sure don't.
12 13 Q Who did you give those instructions to?
14 A That would have been Fred Kellie.
15 Q Fred Kellie and that was -- the instructions 16 were increase the count time, so that our tech spec LLD's 17 will be sure to be sufficient to meet Appendix I?
13 A. Increase the count time to such that th e --
1, because we were under the erroneous impression all along that 20 the 2,000 second count time, we would meet the tech specs ,
21 Fred Ke:111e and I were.
~
22 0 Um-huh .
l 23 A That the assumption was that if you meet the LLD in the tech specs, you meet Appendix I. The 2,000 second 24 count time would meet the LLD. In our particular case that 15 P
-__.-,____-_..----_-___m.__ . . _ _ . _ . - . _ _ _ _ . _ _ _ _ _ _ . _ _ - - _ _ - _ - - _ _ _ _ _ _ . - _ _ _ - _ _ . _ _ _ . _ _ - - - _ _ - - _ _
' l 38 I wasn' t true, which we found out later. i
. \
2 O So you increased it from 2,000 seconds to 3 what?
4 A I think we increased it 3,000 seconds at th at 5
time and the reason I'm fuzzy on that, because we've gone 6 through several evolutions in 1986 of changing our policy and doing some elaborate studies on what does it have to be 3
to know that we -- and that all depends on the volume of
, water and there's a lot of f actors that enter into that. So 10 in f act the count times could change if you really follow the 11 ODCM and you track you ef fluents correctly. But at th at time 12 I think we went from 2,000 to 3,000 seconds.
13 Q What do you mean by tracking the effluents 14 correctly?
15 A Well, there's a lot of factors that go into 16 that and without a big technical explanation, which is beyond 17 my capability because I'm not that indepth into it, it's 18 not only the activity that you have but it's the volume of 19 water that you have, is a f actor that goes into the thing, 20 and as far as where your Appendix I limits are. Because 21 obviously dilutions make a difference. If you took the same 1 .
12 amount of activity rnd dumped it in the Sacramento River, 13 nobody would ever find it, and you'd still meet Appendix I p
24 because you've got a large dilution f actor.,
t 25 So, that's why I'm a little fuzzy on whrre we I
f l
39 y
were because we've gone through a real elaborate process in
'86 of discussing what do we really need to do to meet 2 .
3 Appendix I? What do we need to do to track where we are at In other words , as of the 1st of March, !
4 any point in time?
how much of our Appendix I limit had we used up'? Th at 's th e g sort of program we're putting into place.
4 7 Q I see. Thank you.
A Does that answer your question?
3
, Q Yes. Can -- you're not involved in that 10 tracking the effluents correctly. Fred Kellie would be able 33 to expand on that?
12 A Yes.
Q I just want to make a note.
33 14 A I guess the bottom line is we have put in a lot 15 more elaborate tracking system of everything than we had 16 before. Not that we didn't keep track of the quantities 17 before, but we' re almost doing a real time calculation of 13 where we are. Rather than release water all year and then 19 you do all' your calculations at the end of the year and it 10 says, well, this is where we are. Because of the limits 21 being so tight in our particular situation, we're doing t
12 ' almost a real tine tracking against the thing.
)-
13 Q Now, you say?
24 A Yes.
25 Q Okay. That wasn' t the case back then?
s 4
' a.
40 A No it was not. That's something we developed .
1 2 in 19 86.
Q 'Okay. . So -- okay. Why were instructions 3
4 given to lower the counting times on analysis of RHUT.
5 samples?
A At the time that we made the one change to.
6 7 lower the counting time, number one- there was an assumption 3
that the lower counting time would still meet tech specs.
g And I can remember a conversation with Fred Kellie that, you 10 know, with this lower counting time, do we meet tech specs, 33 LLD's? And the answer was yes.
12 The lower counting time was essentially a public relations move, if you will. Because we had made the 33 s 14 statement we wouldn' t release any' activity and everybody 15 knows that if you count long enough, there's a certain amound 16 of activity in any tank of water. And it wasn' t a -- there i 17 was no coverup. There was no attempt to hide anything f rom 13 anybody, other than to say, yeah we've counted it for this 1 19 many seconds. Yes , that LLD meets tech specs , therefore we 1 10 can release it, and it was called a nonradioactive release.
21 Because had it had gamma peaks in it from a public relations I point of view, it would have been called a radioactive ;
12 l 13 release. And in retrospect, . you know, I understand tne 1 1
24 Commission's view that, veah, there's some activity in theres 25 Why didn' t you tell us about that activity? 'I t w as n ' t --
moser a
41 1
There was no intent to hide anything from the Commission, buc f
I 2 it was because we had made the public statement that we were 3 not going to release gamma emitter and everybody knew that 4 th at was based on an LLD and that was the reason for the 5 change.
g Q Okay. Who in the management chain authorized 7 the lower count time and analysis of RHUT samples ?
3 A I did. t 9 0 Okay.
10 A And Fred Kellie.
11 O When was that?
12 A When was that? I can' t tell you the date, but 13 the records have been looked at. I'm sure you can find that 14 real easy. There's a form 50, for. example, that was counted I
15 at a few thousand seconds and then I think it was counted at Ig 1,000 seconds. It's in our log books. I remember the dis-17 cussion with Fred. We had a tank of water and we said, well,[l l
18 we got this, and we can do this. We count it at 1,000. We 19 assume the tech specs. I said, then let's do that. So Fred 20 and I both were involved and we had a discussion about it.
21 Q Okay. Did you discuss that decision or review 12 that decision with your supervisor, Pierre Oubre?
23 A When -- let"s see. That depends on when the <
7,4 decision was made.
15 0 Well, let's say did you discuss that with your
. m-- ._______ _ _ ____ _ - - _ - ___.___-_.m_ _ . _ _ _ _ _ _ _ _ _ - . _ . . _ _ _ _
42
'O G
1 supervisor, whoever it might have been? When you assumed 2 Pierre Oubre's post, you reported to Ron Rodriguez?
8 A Ron Rodriguez.
4 Q Then the ques tion would be either --
5 A At the time Fred and I had the d'scussion i 6 there was nobody available and by that, I don't recall 7 where they were. The day that decision was made, I did not 8 discuss that with anybody above me.
9 There were subsequent discussions about it, 10 but I don't recall any of the details about th a t.
I 11 Q About what?
12 A About any subsequent discussions of how manage-;
13 ment above me became aware of it. I know the day the 14 decision was made it wasn't because it was late in the day 15 when Fred and I talked about it. Ron or Pierre, or both, 16 weren' t around or weren' t available. I didn't make any 17 discussion with them at that point in time. 1 15 Q okay. Did you --
19 A And the fact that it met tech specs, you know, 20 didn' t put a great big importance that I go and tell them 21 about it --
22 Q Sure. l 23 A -- in my mind. Because the answer was , yes ,
24 we meet tech specs, and therefore it was within, you knos, 25 my prerogative to make that decision.
e
- _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . . _ - _ . _ _ _ _ _ _ _ _ _ _ -___-__.-2. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ - . - _ - _ _ . _ _ _ - _ _ _ _ - _ .
43 1 +
1 Q Okay. What's your awareness of the subsequent 2 discussions about th at lowering the counting time that took 3 place among Rodriguez and whoever else you might have -- 1 4 A There wasn't any big discussion. I don't even 5 remember exsetly when Ron or Pierre became aware of it. I'm 6 not exactly sure when that happened.
7 0 Okay. It's your general impression that it 3 was discussed and somehow they were aware that that policy p was -- or that decision was made?
10 A Yes. But I, you know, as far as any formal 11 communication, I don't recall whether I called them up- or 12 whether they happened to talk to somebody. I don't know how 33 they became aware of that or exactly when.
. 34 Q ' What's your recollection of discussions with 15 them about that? With either one of them or both of them.
Is A If there was a direct discussion with me, 17 between me and them, there was not any -- there weren' t any 18 big issues, I guess is the best way to put it. Because I 19 don't recall. If there had been a big issue of, you know, 20 why did you do that? Or that kind of issue, I think I would 21 have remembered it.
12 Q Sure.
13 A But I don't remember any.
24 Q The impression that you have now is that '. hey.
1F were aware of it. They reviewed it and evidently from the
- - - - - - - - - , - - - - - _ - _ - - _ - _ _ . . - - - - - - - , - - - - - - - - - - - . - - - _ _ _ _ _ _ - - - , - - - _ _ _ _ , - , - - - - _ J
44 I actions that took, you know, that happened or actions th a t 2 didn't happen, then they agreed with you or at least didn ' t ,-
3 agreed to the point that it didn' t require daem to take any 4 actions to change that policy or that decision.
5 A I would not make the absolutely hositive 6 s tatement of, you know, that they became aware of it, you 7 know, immediately after. Because I don't recall when they 3 became aware et it.
p Q Okay. We can ask them. But --
10 A Because I made the decision independently at 11 the time I made it.
12 O They never gave you any instructions to change 13 that decision?
14 A No.
15 Q Or to review it again?
16 A No.
17 Q I'm going to give you a record of telephone 18 conversation. It's called -- it's entitled telecons with 19 the Nuclear Regulatory Commission. It was initiated by Fred 10 Kellie. Greg Yuhas was contacted and the date was January 6, 21 1985. It states reason for call: Resolve meaning or 12 interpretation of second sentence, table notation C, table 13 4.21-1, page 4-71. Resolution reached. If a nuclide is 24 below minimally required LLD (SE-7 microcuries per cubic 15 centimeter) but is a positive value, it must be recorded and
' emus
-_m.__ . . _ __._--._m._ a
45 1 reported and then there's a distribution down at the bottom.
2 Mr. Coward is one of those on distribution.
3 When you received that record of telephone 4 conversation between Yuhas and Kellie concerning reporting 5 identifiable peaks and what we're referring to'here, when
, 6 they refer to table 4.21-1, page 4-71, they ' re referring to 7 technical specification 4.21.1 and the table on 4-71. It 3 says table notation and there are, oh, four notations. C,
- 9 notation C states
. 10 Other peaks which are measured and identifiable ,
11 together with the listed nuclides, shall also be identified 12 and reported. .Nuclides which are below the' LLD for' the 13 analysis should not be reported as being present at the LLD 14 level.
15 When you received that, this record of telephone 16 conversation, with whom did you speak and what was the con-17 tent of the conversation?
18 A Even though I was on distribution for that and 19 very likely quickly read over it in the pile of mail that I 20 get every day, I didn't take any action. I didn't talk to 21 Fred at all about that particular telephone conversation.
22 Q Okay. Did you take any action based on this 13 telephone conversation?
24 A Not that I recall.
}- 25 BY MR. SHACKLETON:
I-Q When you s aid Fred, you mean ' Fred Kellie?
t l
46_
4 1 A Fred Kellie, yes.
2 BY MR. MEEKS:
3 0 I understand -- what do you understand from 4 this record of telephone conversation as you read it now?
5 A That tells me that Greg Yuhas ha , if you will, 6 changed -- or given an interpretation of that second 7 sentence, which doesn't appear to be there in the sentence 3 as you read it literally.
9 Q Okay and what -- you mean the second sentence 10 where it states nuclides?
11 A It says, nuclides which are below the LLD for a 12 the analysis, should not be reported as being present at the 13 LLD level.
- :(
- 14 Q Okay.
15 A And this says if a nuclide is below minimally 16 required LLD but its deposit value must be ' recorded and 17 reported.
18 Q Okay. How about the first sentence of that:
19 Otber peaks which are measurable and identifiable, together 1
20 witn the listed nuclides, shall also be identified and 1 21 reported.
22 A Well, that agrees with Greg's statement but 23 the second --- if you put both of those sentences together, l
24 I guess I would say it's a little bit confusing. l 25 Q Okay. Could that be interpreted in your l
- l i
1 I
a ___- _---____-______ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
h understanding to mean that peaks that are identified in 1
]
1 2 analysis should be reported?
i 3 A With the second sentence tacked onto the first 4 sentence in paragraph C, to me th a t 's a disclaimer that says l 5 if it's below LLD you don't need to report it.'
6 Q Okay but this is talking about nuclides which 7 are below the LLD for the analysis. In other words , that 8 are there but are below the LLD for the analysis, should not 9 be reported as being present at the LLD level.
10 A Explain to me what you're saying. I don't 11 understand what you mean.
12 Q Okay. We stated that to you that indicates 13 if there are nuclides there that are below the LLD, meaning 14 your tech spec LLD?
15 A No. Your analysis LLD.
16 Q Okay.
17 A In other words if you count for 2,000 seconds 18 and that establishes your LLD.
19 Q Um-huh.
20 A And you don't see it, you don't report it.
21 Q Okay.
22 A That's what that tells me. !
23 Q Okay. Other peaks which are measurable 24 and identifiable, together with the list of nuclides, shall 25 also be f.dentified and reported. So, that's in your analysis E
e e
48 t
1 if you see it, you report it. No matter what. Right?
2 A well, bear in mind this first sentence has to !
3 do with other peaks other than those that are in the list.
4 There's a list of nuclides that you -- it's in the tech specs;.
5 Q Um-h uh .
- 6 A And I interpret this sentence to say, othe r 7 peaks , which are other than the list of nuclides.
3 Q Um-h uh .
9 A Okay. It says nuclides which are below the LLD to for the analysis should not be reported and it said -- in 11 reading it right today, it looks to be a little bit of a 12 conflict. But to me the second sentence is a disclaimer 13 saying, when you analyze if you' re below LLD you don' t s 14 report it.
15 Q Okay. On che resolution reached of the 16 telephone conversation record, it says: If a nuclide is 17 below minimally required LLD, and then they specify that by la saying, SE-7 microcuries per cubic centimeter.
19 A Is that the one out of tech specs?
20 Q Yes, uh-huh.
21 A Okay.
22 Q Which is the tech spec LLD. But is a positive 23 value, it must be recorded and reported. So that's the 24 instruction the Yuhas gave to Kellie. In other words, if
~
25 you have nuclides that even though they're below your LLD,
],
l
l 49 i 1 they are identified. They are peaked in there. Then you 2 report -- you record them and report those. J 3 A That's what th at says. I agree with that 4 statement.
l
~5 Q Yeah. Okay. In other words, Kellie is putting -
l 6 in here the LLD that they' re referring to, at least I would 7 assume the first sentence: Other peaks which are measurable 8 and identifiable, together with the listed nuclides, should 9 also be identified and reported. Nuclides which are below 10 the LLD for the analysis, should not be reported as being 11 present at the LLD level. .
12 Okay. But anyway what you're saying is, even 13 though you probably reviewed that, you had no occasion to k 14 converse with Fred Kellie about that telephone conversation, 15 or the policy of reporting identifiable peaks?
16 A No. Fred and I didn' t have any conversation 17 about that that I recall.
18 Q Okay. Are you aware of any conversations that 19 Fred Kellie had with anybody about this subject?
20 A No, I'm not aware of any.
21 Q Did you have any discussions with any other 22 person concerning the reporting of identifiable peaks that 23 are below the' LLD level?
24 A In what period of time? I mean we have had j 25 NRC meetings over the last year and a half. There's ?een a u__-__. _m.:
- - . _ _ _ _ _ -_ - _ - _ __A__m*
50 1
l I
1 lot of discussions.
i 2 O Oh, okay. I'see. Being the June '85 time 3' frame. From June ' 85 to the latter part of 1985.
4 A As f ar as that particular time frame, I can't 5 say one way or the other. I don't recall. I know there was 6 a lot of discussions about a lot of things in regards to )
1 7 radioactive water management in ' 85, because that was a real l l
3 problem to us. That's all I recall.
9 MR. .SHACKLETON: Do you want to take a --
10 THE WITNESS: I' d just as soon keep going if 11 you guys do, because I have to get back out to the plant.
-12 MR. MEEKS: If you want to take a break, we can 13 MR. SHACKLETON: No, no. That's fine. I was k 14 just considering him. He's the one that's sitting there 15 get asked all the questions.
16 THE WITNESS: I'm fine.
17 BY MR. MEEKS:
18 Q In October 19 85 the Lawrence Livermore Nationa8 19 Laboratory reported detecting cesium 137 in downstream 20 sediments at levels not anticipated. Due to the fact that 21 no releases of radioactive products had been reported for 22 1985. What action did you take to insura that the LLD issue 23 ' raised by Bradley, which is the fact that Rancho Seco's 24 technical specification LLD does not necessarily assure 25 compliance with Appendix I limits as published in his draft-e m - _ _ _ _ _ _ _ - - _ - _ _ - _ _ ___-_-___.______m__-_____________m.________--_._____.m__________.____._____m __________m. - _ _ _ _ _ _ _ . _ _ - _ _ - _ _ _ _ . _ _ _ _ _ - _ _ _ - _ _
51 l 1 1
1 October 29 draf t studies. What actions did you take to make l
2 sure that' that LLD issue was not the cause of activity being_'
3 detected by the Livermore Lawrence National Laboratory?
4 A . What was the last part of that question? I 5 didn't understand that.
6 Q .okay. Let me explain it. In October of '85 7 the lab with repor:s of --
3 A I'm aware of.that.
9 Q -- ceaium in the sediments that they didn' t-10 expect really would be there at that level. Mainly because 31 there was no releases during 19 85, up to that time there 'werd 12 no reported releases. Okay. I assume that that fact came 13 to your attention in the fall of 1985. Okay. When that
- 14 fact, put together with the issue, the LLD issue that : Rancho 15 seco's tech spec LLD might not be sufficien.t to assure 16 compliance with Appendix I, what actions did you take to makd 17 sure that that LLD issue did not -- was not the cause of thag 18 activity being detected by the Livermore Lawrence Lab?
19 A So you're --
20 Q Let me ask you --
21 A You're only asking a question having to do with 12 the activities surrounding the LLD, not what we did as a 23 general program to reduce the of f-site ef fluent?
24 Q Right. I'm tying it into the issue of the LLDo 25 A Well, that was the time --
o h .________.__.___m____ . _ _ _ _ _ ___.__.___________.-_.._.-__..__-______________..____________________m__ _ _ _ _ - _ . _ _ _ _ _ _ _ . _ . _ _.i..m____.___.__._____.______m _m-___m-.__.m______..__.mi_ __._.___..__-. _ _ . _ _ _ _ .._
52 1 0 The suf ficiency of the LLD.
A That was the time frame that we changed LLD 2
but I don' t recall exactly when it was. I mean the LL --
3 4 the Lawrence Livermore Lab study , Bradley's memo, you know, 5 that's when everybody's conscious level got raised on LLD 6 and off-site releases.
7 0 What meetings did you attend where this was 3 dis cus s e d , these two items together alcng with everything 9 else?
A I don't recall specific meetings.
Io 11 O But there were meetings where this was 12 discussed?
13 A Yes. .
. 14 Q Okay. What was --
15 A I say yes because, you know, there would be --
16 it might possibly be discussed at our morning meeting in the 17 normal operation of the plant about, we're backed up on 18 water. We've got to do something with water and those sorts 19 of issues. But I don't recall any meeting that was called 20 specifically. Well, as the Libermore study came out, we had 21 a lot of meetings but I don't recall specifically the 22 contents of those meetings.
23 Q Okay. Do you recall the policy that came out 24 or the resolution that came out? Of, hey, here we have a 25 tech spec, you know, and evidently that tech spec is not-1 4
m_ _. m_ .-. __._.___ _ _ _ _ _ _ _ _ _ _ _ _ _ .m____-______m__.____ . _ _ . _ _ _ _ ._w
53 e
i sufficient for us to adhere to Appendix I li mi ts . And then l
2 you have the issue of who? Look at this activity that's i s' cropping up downstrea here. Maybe th a t 's why . Maybe because 4 we've been basing our decision on the tech spec limits --
5 A Oh , we had that --
6 0 --
are our activities --
7 A That discussion came up. Absolutely it came a up because we were under the impression that if we met the 9 tech spec LLD, then we would be within Appendix I and it to became very obvious that that was not the cas e . So, that's it what I said, we did a lot of things of changing count times ,
12 of changing water processing systens, of really tightening 13 up, if you will, on the amount of water going of f-site. ,
s 14 0 Okay. Were any of th'ese decisions taken before 15 Mr. Yuhas's inspection in March -- excuse me, in April and 16 May of 1986?
17 A Yes.
13 Q Do you recall specifically what they were?
19 You named, you know, several of them.
20 A You know, at the time frame that we did them, 21 there were a lot of things done and to reconstruct th at 22 year, I couldn' t put it in proper perspective. I really 23 couldn't.
24 0 Okay. If you wanted to reconstruct what was 25 done up to that inspection in relation to the activity being 6.
e m--x--._ ----_----------------s-----_---- - - - - - - , _ - - . - . - -
54 t
I detected by Livermore and the LLD issue, how would you go 2 back and reconstruct that? j A Well, I'd go back to get all of the, if you 3 f I
4 will, the' key players , the Ed Bradley's, the Fred Kellie's ,
, i 5 a lot of those people involved in the program and start 6 piecing it together. Because we did have a ' lot of discussioW 7 There were a lot of things that went on and a lot of things e internally that went on as f ar as the processing of the 9 water. But I'd have trouble reconstructing exactly when 10 all these things occurred time frame wise. Whether we did I 11 things prior to Greg's inspection, we have done things 12 subsequent to his inspection, as far as the changing of the 13 program, the overall program. .
14 0 What I'm looking for is what your responsible 15 acts were to correct this deficiency or this sof t area that 16 has surf aced? First of all, maybe let's -- would you agree 17 with me that some action did need to be taken?
18 A Ch , ye ah .
19 Q Well, you've already stated that.
20 A Oh, absolutely.
t 21 Q You've already stated that. Sure.
12 A Oh, absolutely.
13 0 I'm not trying to put words in your mouth.
L 24 A It was changed. You know, we changed count L
l l 25 times. We started -- we put in some of these portable l
P 1
demineralized, again to help clean up the water. So we could l
2 get it down to the lower levels. We ended up pumping more '
3 water to the basement than we had previously done. The l l
4 whole water management program, we ' d gone to these throw 5 away demineralizers, resins in the secondary system. So, in 6 order to clean up secondary water rather than put it out in 7 the RHUTs and dilute and whatever we did with it, we would 3 run the condensate system and pump the water through one of 9 those demineralizers until we got it to the point that we had to it cleaned up and then we'd throw that resin away.
11 All of those kinds of issues were what I would 12 call better water management practices that we struck off on.
13 I think we even changed the dilution flow in the creek to 14 help our situation some in that time frame. Because we had 15 increased it at one time and then we'd back down on it and 16 then we increased it again.
17 But to go back and reconstruct the time frames 18 of all that, it would take, you know, take some work to do 19 th a t . But we did recognize the problem and we were taking 20 action to correct it.
21 Q Okay. Assume you were plant manager still and 22 you wanted to reconstruct th at . In other words, here NRC l 23 and the acticns we took before Mr. Yuhas came on site and 24 did that inspection. In other words, we were aware of it.
We were taking action, you know, and in certain areas. As 25
56 P.
3 plant manager, who would you turn to to say, let's reconstru 2 that. Let's give this to them and show them, you know, what, 3 we did? Mr. Miller wasn't there at that time.
4 A No. I -- !
5 Q We' re talking about the latter.part of '85.
6 A As the plant manager I would probably start 7 with Fred Kellie and get Fred and none of his staff to start 3 putting the pieces of the puzzle together and go back, you 9 know. We would involve -- we' d involve the operations. It 3 l
would involve a lot people. But Fred is the primary one ' if 10 33 I were plant manager that I' d turn to help recons truct that. ,
12 Q What was Ron Rodiguez's involvement in these ,
13 action that you were taking?
14 A Ron was involved because, if you will, "it t 1
15 becane a big issue when the Libermore study came out and 16 when Bradley raised the question that where we had thought 17 we were meeting Appendix I and it was pretty obvious that 18 we weren't. Ron was very concerned and he was involved in 19 the throw away resin decision in ' 84 to help improve things.
20 And again I -- Ron and I had a lot of discussions about it.
21 So he was, you know, he was in on the decision making 12 process. A lot of the recommendations came out of myself or out of Fred Kellie as to what ve cov.id to improve eur 23 24 situation and so I guas) I could say Ron supported it.
25 / / /
m
--A-__-_- _-m_. ,__ _ . .__ __._ _ _ _ _
L 57 e
1 g Did he ever mention to you the fact that i
2 there might be a problem with the tech specuality, and it 3 might not assure compliance with Appendix I?
4 A You mean prior to the Bradley memo?
5 0 Yes. Prior to the -- in other words, we' re 1 6 talking about the fall, this winter, you know, November /
7 December of ' 85, January of '85, that time frame. In other 3 wo rds , did this issue come up to him or at --
9 A In early '85 or late '85?
10 0 Had he mentioned to you prior to your having it to concentrate on this decision, and what's going to have to be done about it? In other words, there came a time ,
12 g3 like you said, that the focus became, and we realized any 14 changes were going to have to ' be made. Prior to that focus o 15 was there any discussion from anyone else, Rodriguez or Ig anyone else to you about this issue?
17 A I'm trying to put into perspective the f ocus 13 you're talking about, because we had a -- we had one focus 19 in the fall of '84 when this memo came out, or this letter 20 to Jack Martin, 84-07, okay. We had another focus in the 21 f all of ' 85 when the Livermore Study, and the Ed Bradley memo, and c11 that stuff came out. Are we talking about thG 12 1s second focus?
14 0 Yes, uh-huh.
25 A I don't recall specifically discussions with I'
e e
L_ __ _ _ _ _ _ _
59 j
. 1 i
1 Ron about that. That doesn't mean he didn't mention it to 2 me, but in the summer of ' 85, we were going through all of 3 this turmoil with the high point vent break and there was a 4 lot of -- and then management changes at the first of ,
5 September, Pierre was no longer a plant manager.
6 So there was a lot of turmoil'in the organiza- {
7 tion at that time, and specific discussions, I don't recall, 8 I don't recall one way or the other.
9 Q Okay.
10 (Pause) 11 Q When you becane aware of this LLD issue, what 12 did you do to assure that the lowering of the count time 13 on the analysis of the RHUT samples, together with the LLD 14 issue, would not impact on Rancho Seco's ability to conform 15 to the appendix high dose limits?
16 A Run that by me again? Repeat the question, 17 because I'm not exactly sure what you're asking.
18 Q Okay. You had mentioned -- we have talked 19 about the significance of the LLD issue, --
20 A Right.
21 Q -- the tech spec LLD issue.--
22 A Right.
23 0 -- and its sufficiency with respect to s
14 Appendix I. We've also talked about the lowering of the 25 count time, and you know, the reason why that was done.
e
59 o-s 1 A You mean from going to 2,000 to 1,000 seconds?
2 O Yes, uh-huh.
3 A Okay.
4 0 When you became aware of the LLD issue, how 5 did you marry up those two f acts, or those two' areas , the I
6 fact that the lowering count time was in essence all -- it 7 met your tech spec LLD, you know, you could lower the count a time, and it still allowed you to meet your tech spec LLD, 9 but then the knowledge is coming to you that the tech spec /
lo LLD is not sufficient, or might not have the sufficiency to 11 assure ' compliance with Appendix I. What did you do to 12 resolve that apparent discrepancy or conflict to make sure !
1 13 that Appendix I limits were adhered to?
14 A Well,there'stwopiecesofinformationcominhl 15 one that the thousand second count time, and even though it 16 met tech spec, we weren't goinc., to meet Appendix I. And thG 17 other piece of information is that possibly two thousand 18 second count time wasn't adequate either, if you assume 19 that everything was right at the -- you know, right below 20 the sensitivity level.
21 So, what I asked for at that time is for 22 Bradley's group, you know, to give me some guidance, okay.
23 Here I- had a tech spec, I was living with a tech spec, I 1
l J
14 thought I was meeting Appendix I, and I get information thag l
25 says that's not trup, and they said, well, go back and tell
[
l l
a
^^- - - - - - - - - - - - - - - - - - - - - _ _ _ _ _ _ , _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _
cn I 4
1 me, you know, if 7 go to 2,000, does.that -- is that really
{
2 going to meet LLD, or do I need to go to 3,000 or 4,000?
A What do I need to do, so I basically , my response was , give 4 me some information, because I thought I was acting on good 5 info rmation , give me information that tells me what I should i
j 6 set the limits at as the plant manager, because Bradley's 7 group really had the data, the expertise, and the analysis.
8 capabilities to do that. So that was my response to them.
9 O And when was this?
10 A You keep asking me -- there's been so much 11 happening the last two years, I'm -- you know --
12 Q Uas it a written request, or did you pick'up 13 the -- .
14 A No, it was a verbal request to say, hey guys, 15 you know, I'm getting mixed signals here. I need to have 16 some guidance and some direction, and -- because we were 17 f aced with a situation which, you know, yeah, you can count 18 for 6,000 seconds, but it takes you forever to get samples, 19 yeah, you've got -- you know, you can go to the point of 20 being ridiculous.
21 0 Sure.
A And no, it was a verbal request. I know 22 25 there was a lot of communication between Fred Kellie and 24 Ed Bradley, and those people as to what was practical, but 25 still meet Appendix 1. Did I answer your question?
samuasmusump w
61 g-1 Q- Ye ah . What was the resolution, when did ,
2 - Bradley cone back?
3 A Well, the ultimate solution was the program 4 we put together in 86, which is this real time, tracking of 5 where ve are in regards to Appendix-I with every release 6 that we make, and a pretty elaborate progra'm. But that's 7 the ultimate result of that direction.
8 0 What was his first reply to you, his first
- 9. response?.
10 A The first response was to jack the ' count time
- 11 up to -- as an immediate action,- that's something we could do, you know, instantly. That was the first response, and - -
12-
, 13 Q So you -- when you jacked the count time up, 14 - that was actually in conjunction with Bradley's input to 15 you in helping you resolve this --
16 A Once we found out we had a problem with tech 17 specs, meeting tech specs didn't meet Appendix I, that was 18 the immediate action was to raise the count time, which 19 effectively changed the LLD.
20 Q And you didn't recall exactly when that was, 21 but it would have been in conjunction with Bradley's input 12 to that, his -- in other words, he came back with, well, 13 that's one thing you can do, you can do it right now.
14
- A We changed dilution flow, I think was another 25 thing that we did, which was again an instant fixing that we
'I
'mt #W
' mm _._ m ,alW.MamWau f em WWWW e
m _ _ - - _ ----------------------,,_u--- - - - - . -
62 r
4 1 could bump the flow back up in the creek. So there 's been 2 lots of meetings, and lots of things happened in the last 3 two years.
4 O Let me just go back over this one more time.
5 Did you have an occasion to reconcile the instructions that 6 were given to the chemistry and radiation protection 7 technicians to lower the RHUT sample analysis. count time in 3 conjunction with technical specification Footnote C, which ,
9 -- and Yuhas' instructions here to report peaks, even 10 though they're below, you know, tech spec limits of 5; 8, 11 and minus 77 12 A I don't -- I didn't exactly catch all your 13 question, but let me give you the answer on the lowering 14 of the count time. When Fred Kellie and I talked about 15 changing the count time, we had a tank of water that was --
l 16 that we needed to get rid of and specifically, Fred and I --
17 I asked Fred this specific question, "If we change the 13 count time, will we meet tech specs? Will vn meet tech )
19 specs LLD7" The answer to that was "Yes. " hnd then said fine, I don't have a problem with it. I mean, that was 20 21 the gist of the conversation.
Yeah, you've already gone over that.
12 O 13 A So I'm trying to figure out what is his i l
question, basically it's different. --
2 24 Well, I just want to revisit it. What's youg 25 Q 1
c- -
__.____..-_-______-_-._-__m.__.-__-.._m_ _ . _ _
'63 I recollection of the . discussions, hey, what~do we do when-2- we;get. pecks of radioactivity? Say we get a peah, it's 3 .below,LLD, but we get a peak of.say cesium 137.- Well -- l 4 A We didn't have that discussion. ,
5 0 Okay. <
YE 6 A That never came up, because with LLD, if 7 you' re clean, okay , you count f or _l,000 seconds , and you 8 get no peaks, then there was no discussion about what if 9 you get' a peak, because there wasn't any.
10 Q Okay. Did Kellie ever come to you and say, 11 Newhouse just told me if we get a peak below LLD we should 12 report it, and we haven't been reporting it, now what do we i 13 do, or anything akin to that. You' understand what I'm A 14 trying to achieve, in other words, did that topic come up?
13 A At sone point in time, it did, but I don't' 14 know exactly when. I couldn't tie it down to June of '85 11 where that telecom occurred, but at some point in time that 18 did occur, yes , that- discussion came up, but I don't recall 19 when.
10 0 And I understand your, you know, everything 11 is coming in to you and you' re putting it back out to the 12 various levels, or various divisions and everything. But as that -- who brought that to your attention, was it Kellie?
34 A I can't say f or sure, but ug best guess would 15 be that it was probably Fred Kellie, because he was the one 8
menu
A - - - - - - _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ , _ _ _ _ _ _ _ _ .
64 4
+
1 that I communicated a lot with concerning the problem, I i
2 mean, the water management problem in general, Fred and I :
3 had a lot of conversations about it. So I have to assume 4 that Fred was probably the one that brought it to my
- 5 attention, but I don't recall any snecific conversati7n 6 where that happened.
7 O Okay. Do you' recall the concensus of what 3 you were going to do about those peaks?
9 A No, because I know Fred and Ed Bradley had 10 conversations about it, and I don't recall any concensus of 11
-- I remember the ultimate resolution, but as we went 12 through this phase of how are we going to deal with it, I 13 don't recal) specifics about it.
0 okay. I can ask the same question also 14 15 about -- and just f actor in the detection of the cesium 16 by Livermore as another f actor that's coming up showing that 17 you know, there is a source someplace. What were your 13 discussions concerning, you know, we have the LLD issue, 19 we have the lowering of the count time, now we have 20 activity thing coming out that is -- that wouldn't be 21 anticipated to be there.
12 A Again, I don't recall specific meetings. I 13 know there was discussion that, you know, that this activity 24 could have, you know, some of it obviously came f rom the tube leak we had in what, '81, I guess, because we had 15 0
I 65 1 released water prior to the RHUT's going into the tech soecs 2 So I think there was recognition that all that Cesiun didn't; 3 come about as a result of.the time frame from July of '8t-4 to the fall of '85, and that there was recognition'that, c . I 5 you know, some of that was prior to '84, and the tech spec
. l 6 being changed.
7 Again, I guess I don't know exact -- you know, 8 'as far as specific meetings, and specific topics, there was 9 a lot of meetings, sone of which I went in, some of which 10 I weren' t, were we talked about,.you.know, we talked about 11 evaporation ponds, we talked about a lot of things, how are 12 we going to deal with this issue, because the plant'was
'13 never designed to meet Appendix I, and you know, the
~
14 Livermore study told us, hey, we've got a problem, had the-15- guy who was eating 50 pounds of fish out of the creek, 14 which we hadn't counted on. We had had the errors and the 17 argues of the NRC's computer code, you know, all' that prior 18 history. So there was a lot of discussions about that.
19 So to give you specifics, Ron, on what went on, I don't 20 really remember very honestly, I really don't.
21 O Okay. What was the reason for not taking 12 composite samples for control for environmental protection 13 analysis from the RHUT for all RHUT releases?
14 A I don't know, I have no idea.
15 okay. Who would know that? Understood, it's 0
+
t
66 n
1 our information that they were only taken when there was
~
2 radioactivity, and then they took a composite sampling.
1 A That would probably be Roger Miller, whom I 4 know, but I don't recall who' established that policy. ,
IThy were sore of the set controls for 5 Q
.6 environmental protection composite analysis documents 7 missing?
8 A What was missing?
9 Q The composite analysis documents, in other 10 words, their composite analysis that they did, those -- ;
11 they couldn't be located.
12 A I have no idea, other than lost in the 13 administrative paperwork, I really have no idea. .
Were you aware that they were missing, some
- 14 Q of the documentation was missing? f 15 l 16 A Not until we started going back through I 17 collecting a lot of this information, no, I was not-aware.
18 I don't think we'd done a very good job of auditing the 19 records ourselves, and until this -- until we started 20 looking through records, no, I was not aware that they 21 were missing.
22 Q Defore taking a sample analysis, why was the 23 RHUT diluted with water, surf ace water, or secondary water 24 after the transfer of DRCST water into the RHUT7 25 A To give a -- number one, that was the volume O
l
(
\ -
1 of water, number two, that was the -- you wanted your 2 sample to be representative of what you were releasing.
3 So that was standard policy.
4 Q Okay. Who authorized the dilution of the 5 RHUT containing DRCST water before taking the analysis i 6 sample? .
7 A Who authorized it? I guess you could say the 3 plant manager did, because it became -- it was an accepted 9 policy, and the chemistry people would, if you will 10 implement their policy, they would say tran'sfer this amount it of water, fill the tank up with this, and depending on how 12 much water was in the tank to start with, and they were the administrative people of the policy. But I, you know, it 13
- 14 had been our standard operating practice for a long time.
Q What effect did diluting the RHUT before 15 16 taking a sample have on tne ability to detect radioactivity 17 in the DRCST water that was transferred to the RHUT?
13 A .Well, I -- a technical point of view, you 19 reduce the likelihood of seeing anything. That was not the 20 intent, but technically, that's exactly what was happening, three times as much water in their tanks. Did I answer 21 22 your question?
23 0 Yes.
i A You look puzzled.
24 .
25 Q No, no, I'm just --
ew
1 A Okay.
2 O Yes, you did answer it. Who was respons'ible 3 for collecting and maintaining' records on water transfers 4 from the DRCST to the RHUT?
5 A Probably the radiation protection chemistry 6 people, there's -- our records are split between operations 7 and chem rad, and so it would be one of those two groups , J 8 I'm not exactly sure which one had the custody of that 9 process , but it would be, I think, the chem rad people.
10 0 Okay. And Miller would be able to give more 1
l 11 specifics on that?
12 A Right.
IS O Why were all hut a few of the records on the 14 transfer of the water from the D.RCST to the RHUT not kept 15 or maintained?
16 A I don't know the reason. I don't know the I
17 answer to that.
18 0 Once again, you would look, assuming we go 19 back in time, and you're plant manager, and you wanted to 20 know that answer in a --
l 21 A I'd look down into the organization to get 1
1 22 that answer.
23 0 You'd look to Miller or --
24 A Tred Kellie.
25 0 -- or Kellie.
69 0
f
. 1 A Right. [
)
2 O What discussions, and I think we're going to 1
3 revisit this, I just want to make sure that we've covered 4 it. What discussions were you involved in regarding whether ,
f
- 5 or not the modification that allowed the transfer of water 6 f rom the DRCST to the RHUT should be made known to the NRC?
I 7 A Well, again, that's a repeat question. As j 8 far as I know, there was never any discussion about that 9 one way or the other. I don't think anybody considered it 10 a reportable type modification. Obviously, we didn't, or 11 we would have.
12 Q Okay. What discussions were you invnived in 18 that that modification should be updated in the safety 14 analysis report?
15 A I was aware that that issue was raised by 16 Region V, and we have subsequently gone back and done that.
17 0 How about prior tr them raising that issue, 18 what discussions were you a party to that net modifications 19 should be made as an update to the safety analysis report?
20 A I don't think we had any discussions. I 21 don' t know that we ever considered that as that type of modification. It was a temporary installation, it was not 12 13 a permanent installation.
24 0 You say temporary, but it was used over yearst 25 right?
u- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - _ _ - - - - - _ - - - - ----_- _ - ___ m
70-L J.
l 1 A It was put in and taker out several times .j 2 because we would take the plast.".cl pipe out if we had l 3 certain .other things to do, and then we'd put the plastic. f 4- pipe back, depending on our plant conditions. But it was !
5 a temporary modification because it was, you Anow, there 6 weren't any engineering drawings changed, there was -- it 7 was a way -- it.was .almost like you string fire hoses to 8 take water f rom one place to another, we put plastic pipe I 9 in. 'And because it was a temporary installation, I don't
~10 think anybody looked at it as something you needed to 11 update the Safety Analysis Report.
12 0 Well, you have records going back to 1975 13 that this modification was made, as well as '81 '82 time'
- 14 frame, '83, '84, '85, '
- 86. You have some documentation on
- 15. that, but then again, you don't have documentation on a 16 . lot of it. In our -- SMUD has since reported that whenever 17 you had a high level of tritium releases, then you would 18 probably have -- those were probably releases from the 19 DRCST to the environment, through the RHUT, so everytime
. 30 you have those, even though' we don' t have documentation, 21 it's safe to assume, telling us, that those were releases
~
22 made.
23 1k There could have been other ones from the 24- secondary system that we could have put the activity in 25 the polishing demineralizers on the condensate system, and t
71 e
I then we drained the het wetl, and the hot well would have 2 tritium in it, and that would go into the RHUT. So you do l
3 have another possibility that it didn't all come -- but 4 that's beside the point, I mean the fact is that temocrary l c- .- 1 5 modification went in and out, that's true.
6 0 Okay. How do you reconcile the -- your basis '
7 for it was a temporary modification when, in fact, you knov,.
8 as f ar as its usage, it's certainly not temporary, temporary 9 meaning a one-tine thing or something. This is a normal 10 occurrence over the years. How do you justify the term 11 temporary with that type of usage and utilization of that 12 modification?
13 A I guess I never thought of it in that contex,tg s 14 since it was not a permanent plant change, as shown. in the 15 drawings and everything else, you know, that's a different 16 paperwork process 'that it goes 'through to review, and ensurG 17 that you update the Safety Analysis Report, and those sorts 18 of issues, so it was a different paperwork process, and I 19 don' t think that probably ever crossed anybody's' mind that 20 we needed to update the safety analysis report because it 21 was a temporary mod.
22 Granted, it was a temporary mod that was used a lot longer than -- it should have been made permanent, if 23 24 you will, if that's the way we intended to do business, and 25 that's the program we're going through right now, to reduce m.__ ______________.__________________m__-m_ _ _ _ _ _ _ _ . _ _ _ ____ _ _ _ _ . _ _ - --- -
72 g.
I the temporary mods that we have outstanding in a lot of 2 areas, not necessarily with the nuclear side of the plant, 3 but we've had a lot of them.
4 0 Okay. Bef ore the modification, how was 5 excess rad waste water disposed of?
6 A Before which modification?
7 O The modification from the DRCST to the RHUT?
8 A What we did in the early days, we did a lot 9 of -- and we've done a lot of solidification of liquid 10 waste, primarily evaporator bottoms, but in the early days 11 of plant operation, we didn't have a large generation of 12 water, and the plant's up and trucking real well, you don't 13 end un filling that DRCST tank up like you do when you go 14 up and down like a yo-yo, because you've got to fill in 15 the vent, and fill in the drain, and fill in the drain, and I all of that process.
! 16 17 So you just create a lot more water, and the 18 same, as soon as we have steam generator tube leaks, you 19 end up generating more water on the secondary side of the 20 plant.
21 0 okay. So that really -- there was a time when 12 you shipped the water off-site, correct?
13 'A That was the original intent. I c an ' t recall 24 back in the mid-70's whether we actually ever shipped any.
25 I think we did, but I can't say for sure one way or the
73-
- I other. I was kind of -- I was over in the engineering ;.
2 group at the time, and I didn't pay a whole lot of attention' 1
I to that. ]
4 li o Okay. So the -- according to your knowledce, 1 i
5 . there is no provision to -- like you said, there's no
, 6 necessity, with normal plant functioning to release rad 7 waste water, you know, there's no exc'ess. It's going to 8 have' to be released under normal plant functions.
9 A That's right.
10 0 It's when, with the onset of like, for 11 instance, like the steam generator tube leaks, and the 12 outages that happen because of those leaks, from the other 13 outages, that's when you start, your plant starts reaching 14 it's capacity, water holding capacity. .
15 A That's right, it causes a lot more generation 16 than for radioactive water process.
17 Q What were the discussions about this 18 modification from the DRCST to the RHUT7 What discussions 19 took place about whether or not this safety evaluation 20 should be conducted on that?
11 A I don't think there were any discussions 12 when we put that modification in initially, and once we'd 13 done it initially, everybody is gee, we've done that before, 24 let's go do that again, when we had water to get rid of.
15 0 But now, it's your understanding that that t
h -u2____.__ -._____-___._m______.-.___-.m_.-._.._._..__m_._m_____m
74 J ;f
- l. .-
f- ,
)
n; 1 . modification is being nade permanent?
)
L 2 A We have plans.to make it permanent. j 3 O Plans to make it permanent, and -- l l
4 A or is, you know, maybe not that modification. j 5 We have -- engineering has an assignment to d a lot of 6 modifications to the plant to help us imorove the water 1
7 processing capability of the plant, and whether.that's 8 specifically' going to include a pipe from the DRCST to the-l 9 RHUT, I don't know, I don't know that. i 10 Q Okay.
11 A. But we are making, you know, we've built a 12 new tank, we've done a lot of things during this outage to 13 help improve the water management capability for the plant.
14 Q Would you expect a safety evaluation to be' 15 conducted in conjunction with that design change?
16 A Yes.
17 Q Mr. Coward, has any SMUD official, a manager 18 or supervisor, given any indication that they want you to 19 f urnish a summary of your interview today?
20 A I've been asked to provide a summary, yes.
21 Q Okay. How has that affected your responses j
' 22 in your desire -- how has that affected your responses and 23 your intent to the interview today?
24 A It hasn't. Very honestly, with two hours of 25 questions, I'm going to find it very difficult to recall 1.
75 w .
I very many of them.
2 O Ue'll give you a record so that you can refer 3 to that. l l
4 A No, it hasn't in any way.
5 0 Who spoke to you that would be I- that they 6 would like a summary of it? Who was it that you discussed 7 this with?
~
8 A Our licensing manager.
9 O Okay , and who's that? Is that Ray Ashley?
10 A Ray Ashley.
11 O Okay.
12 MR. MEEKS: Owen?
13 MR. SEACKLETON: No, I have no further questio2 14 BY MR. MEEKS:
15 0 nr. Coward, have I, or any other NRC represend 16 tative here threatened you in any manner, or offered you 17 any rewards in return for this statement?
18 A No, sir.
19 O Have you given this statement freely and 20 voluntarily?
21 A Yes, sir.
22 O Is there anything further you'd care to add 23 for the record?
24 A Yes. I recognize why this investigation 25 started, because I think there's some feelings on the part l
e in .
p 1 o f ', I guess, Region V peonle, that we intentionally 2 covered tgr things,fwe intentionally did sone _ things to give
. 31 or release water from the plant, and there was never any 4 intention to deceive anybody. There was never any intention L 5 to not. report things to'the NRC, as required.'
4 tiaybe we didn' t manage things as 'well as we 1
7 should have, but I can certainly state that everybody 3 involved with the process, at least on the plant side of-9 the house, was doing everything honestly and- above-board 10 at all times.
11 So I would just like that to be part of the 12 record. 'In fact, we may not have managed it as well as 13 we should have, we may not have communicated as well as.
14 we should have-interna'lly, but there was certainly no 15 intent on anybody's part to cover up anything, or deceive 16 anybody in any way, shape or form, either internally or 17 externally. ,
18 MR. MEEKS:- Thank you very much for your tine 6 19 liR. COWARD: Okay.
20 (Whereupon the interview was concluded at 12:12 p.m.)
21 --o0o--
22 SS 24 15 e
2 .__m - __.._. a__._____L._. __._.& _ . _ . . _ _ _ _ _ m _____m ___.__A__. u__a__ __--________-____._______m.___.____-___.____m__--- u -__ -
- Thio 1.s to cartify that tho attachcd prccccdinga baforo tho
,s ,
UNITED STATES NUCLEAR REGULATORY CCMMISSION in the matter of:
!E OF PROCEEDING: INVESTIGATIVE INTERVIEW (CLOSED)
DOCKET NO.: NOME PLACE: Rancho Cordova, California DATE: 2f Marcti 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Comm.ission. , ,
J (Sigt). Mb -
(TIPED)
MARGARET DE RS I
Official .apo. r Reporter's Affiliation Jim Higgins and Associates e
I f
e EXR8;T m
,,,, , g ,,,
v - - - -
- - -