ML20247F462
| ML20247F462 | |
| 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 8905300086 | |
| Download: ML20247F462 (58) | |
Text
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.N 1
BEFORE THE 2
UNITED STATES 3
NUCLEAR REGULATORY COMMISSION 4 '
REGION V ,
5 6
In the Matter of: )
7 )
INVESTIGATIVE INTERVIEW ) DOCKET NO: NONE l 8 I (CLOSED MEETING) )
9 10 Sunrise Sheraton Botel 11211 Point East Drive Rancho Cordova, California 11 12 An investigative interview was conducted with ,
13 ROGER I. MILLER, commencing at 1:30 p.m. herM, /9 P7 .
14 15 PRESENT:
16 RONALD A. ME m Investigator Office of Investigations, Region V 17 Nuclear Regulatory Commission 18 19 20 21 22 23 24 ,
y .
25 q l 8905300086 890516 PDR FOIA FRIEDMAB9-A-7 PDR 5 286_ ni o EXHIBIT m mh - -a - ss m
. 2 1
CONTENTS j 2
WITNESS PAGE
-3 Roger I. Miller 4 -
4 Examination by Mr. Meeks ,
5 6
7 8
EXRIBITS 10 (none)
. 11 12 )
13 .
14 l l
l 15 i
16 17 18 19 to 21 22 23 24 25
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EE2211E1E91 2 1:30 P.M.
3 the record, this is an
-MR. MEEKS: For 4 Mr.
interview of Roger -- what is your middle , initial, 5
Miller?
6 THE MITNESS: I. ,
7 An interview of Roger I. Miller.
MR. MEEKS: l 8
Miller is spelled, M-1-1-1-e-r?
9 Yes.
THE MITNESS:
10 Mr. Miller, what is your current MR. MEEKS:
employment right now?
THE MITNESS: I'm retired.
13 MR. MEEKS: Mr. Mil.ler is a former employee of 14 The Sacramento Municipal Utility District.
The location of this interview is Rancho l
16 Cordova. Present at this interview is myself, Ronald A.
I 17 Meeks, an Investigator with the NRC Office of Investigations 18 in Region V, as well as the court reporter, Margaret Devers.
19 As agreed, this interview is being transcribed 20 by Ms. Devers.
21 The subject matter of this interview concerns 22 Liquid Etfluents Program at the the management of the 23 Sacramento Municipal Utility District's Rancho Seco Nuclear Generating Station. '
l 25 Mr. Miller, if you will stand and raise your 1
4
t 4
1 right hand, I'll swear you in. l 2
Mhereupon, 3
ROGER I. MILLER {
4 was called as a witness and, having been first, duly sworn, 5
was examined and testified as follows:
6 Before the interview started, Mr.
MR. MEEKS:
7 Miller had a chance to review a Baptember 27, 1984 Report 8 Executive Director, from Mr. Ronald J. Rodriguez, the 9
Nuclear, for the Sacramento Municipal Utility District to 10 Mr. J. B. Martin, Regional Administrator for NRC's Region V.
'I The letter is entitled Special Report No.
84-07. Me will refer to it as 84-07. It involves the 13 reporting of radioactivity and liquid offluents exceeding
(. f 14 certain Rancho Seco Technical Specification Requirements and what is going to be done so that those Technical 16 Specificaf:lon Requirements are not exceeded in the future.
17 EXAMINATION BY MR. MEEKS 18 BY MR. MEEKS:
19 Q Mr. Miller what was your involvement in the 20 development of information for Report 84-077 21 A Mell, my direct involvement uns the 22 demuBWWWSMSqneb guese, of espessa of the corrective actions 23 that were attachments to that Report, essentially, thoss 24 that related directly to the control -- the measurement and
- control of radioactive releases.
i '
5 1
And this item related only to liquid releases; 2
this is several corrective actions that did relate to the 3
measurement of samples of the procedural controls utilized 4
in releases.
5 T- ' that Report, in September of Q At the time 6
1984, what was your position with SMUD and at Rancho Seco?
7 A I was the chemistry and Radiation Protection 8
Superintendent.
9 Can you give a brief description of your-Q 10 l responsibilities?
A Yeah. I had an organization that- was ,
12 radiation protection, onsite, and to the responsible for 13 that, was the Laboratory public. And associated with 14 required for Services because many of the measurements 15 radiation protection involved laboratory measurements.
16 Laboratory And, as an extension of the 17 Services, included in the Group's responsibilities was the 18 straight chemistry measurements.
19 Q Okay. As the Superintendent of the chemistry 20 and Radiation Protection Department?
21 Nell, it mas -- SNUD was never very ;
A Yes.
22 clear about department levels, in my mind. I was an area 23 head.
Q So you were Superintendent of the Chemistry 25 and Radiation Protection's responsibilities?
l l l
6 1
A Yes.
2 Q In other words, you were the number one 3
Operational Manager for Chemistry and Radiation Protection?
4 A Yes, it was part of the,- Operations 5
Organization.
6 Q When did you receive those responsibilities at 7
Rancho Seco?
8 A On my hire at the District in May of 1970.
9 Q And you continued in those responsibilities up 10 until when?
A Ontil June of '85.
12 Q And is that when you retired from Rancho seco?
A Ybat's when I retired. .
b 14 Q Now do I understand correctly that you I
returned to Rancho Seco to assume other functions under 16 contract to them?
17 After that retirement date, I did A Yes, I did.
18 return in late February of '86, under contract, to act as 19 I was managing the the -- I didn't have a real title.
Chemistry Section, essentially.
At that time, the Chemistry Department -- or organization, had been split off from the Radiation 23 Protection Organization. Yhey had a difficult time finding 24 m head for the new split-off Chemistry Group.
acted as the supervisor -- or So I I
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1 7
- 1 Superintendent of that organization until September of '86.
2 on Q specifically, can you expand your 3
involvement and input of information to Report 84-077 l 4
A Well, if I remember correctly, I did have some 5 Basically, the response review of the response, as written.
6 it was passed through was written by Ron columbo; and 7
various organizations for comment, criticism. And I believe 8 I don't I did have a few minor' comments on the basic text.
9 recall what they were at this time.
10 In the corrective Action area, I was not given
' a specific Action under Item 4. Action 4 was an attempt to 12 and tighten up things, packings, go around the plant 13 gaskets, and so forth, by the Operations Department. .
Bowever, the Chen Rad Department was given some direction to review the various known drips and leaks 16 because of our constant surveying of areas; and we did make 17 a listing of areas and items that we knew were contaminated 18 for the Operations Department to use.
19 Onder Action Item 5, which described the 20 the polishing program to uso disposable resins in-21 domineraliser beds, again, it was an Operational Item but 22 impacted quite heavily on the Chen Rad Department because 23 to be used, from that point on, required the resins solidification and disposal as radioactive waste; and the 25 chen Rad Department had the responsibility for proper l'
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disposal of radioactive waste materials. So that Action 2
lapacted quite' heavily on our future operations.
The Action Item 6, ahich invoked portable 4
domineralizers in the temporary piping, again, was an 5
Operational modification to enable movement, of fluid from G
one tank to another the Regenerate Boldup Tanks.
7 Again, it's an Operational Item, but impacted 8
on Chem Bad Department because of the sampling analysis 9 fluid between requirements involved in any movement of 10 tankage.
~ " Action Item 7 was one directed toward the 12 Chemistry and Radiation Protection Department; and it stated 13 unequivocally that any future releases to the environment I
14 would be based on the objective of controlling such that the Technical specification 3.17.2 limits would not be exceeded.
I And that commitment involved considerable 17 change to a number of Chemistry and Radiation Protection 18 procedures and involved a change to our methodology of 19 accumulating information and our technique for utilizing the measured radioactive levels in the Dose Commitment Program. 1 21 And the Dose Commitment Program was brought on under Action Item No. 9.
23 I guess I should get Action Item No. 8 first ,
24 because it intervenes here. Action Item 8 said that there 25 was now a program that permitted the polishing sump or the
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Regenerate Boldup Tanks to be processed to the Rad Maste 2
system, to provide a reduction of activity and the option 3
from the exercise at the -- option of the Chemistry and 4
Protection personnel. That .gave us e Radiation 5
to determine some level of radioactive responsibility 6 content of those fluids that should be processed in the 7
than considered for release to f:he future rather 8
environment.
9 In other to do that Action, we required some 10 changes to procedures.
Back to Action Item No. 9, -4skick
~ -
12 methodology used for Dose Commitment when releases occlurred.
And it indicated that the ODCN, the offaite Dose Calculation 14 38anual, which had been used in tbs past, was considered not sufficient at that time and that the District had a new 16 policy which would use the NRC-verified computer codes to 17 the Effluent salease Reports and that those generate 18 prior to releases in the computer codes would be used, 19 future, to ensure that the Dose Commitment would not be ascoeded.
21 And that, again, was basically procedural 7.2 changes required to implement those ideas.
23 attachment was entitled Long-Term Another Corrective Actions; and I don't believe Chem Bad Department 25 had any involvement with those. They related to the various I ,
I
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concepts that had been brought up by that time about what 2
alternatives there were to the releasing of radioactive I
3 fluids.
4 Q On Near-Term Corrective Action, No. 7, it l l
5 states that policy was instituted to ensure that the Tech j
(
6 And those Tech specs, Spec limits wouldn't be exceeded. i 7
implemented by -
8 A 90 ell, it states specific Tech Specs, 3.17.2.
9 Q 3.17.2.
10 A IIe always called the Tech Specs; this was a
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new Technical specification.
Q This was July of '84.
A At the and of July, '84, that new Technical b 14 specification came into effect.
15 Ilhat was the policy that initiated actions Q
that ensured that you wouldn't exceed that Tech spec.
A gloald you repeat that question?
,Q IIbat was the specific policy here?
19 A DIhat was the policy?
Q Yes.
I Didn't you say you -
22 Ch, this - initiated the policy --
A 23 tibat was that policy?
Q 24 A IIe11, the policy is stated: All releases will 25 be controlled; it says that Tech spec limit, specifically i
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3.17.2, will not be exceeded.
2 Q so that was it?
3 A That was it; it use an endoramaant of a number 4
of new procedures, procedure changen, that won,1d accomplish that.
I 6
Q Outside of the RETS, the. Radiological )
7 {
Environmental Tech spece, RETS, R-E-T-S --
A Or Effluent Tech spece, depending on which NRC 9
person you talk to.
10 Q Whatimaa that again?
A Either Radiological Effluent or Radiological -
12 _
' Environmental?
Q .
14 A Environmental, depending on who you talk to.
15 RETS, what were the Q In addition to the
' procedures that were implemented to make sure that Tech spec 17 3.17.2 was adhered tot 18 A Well, I'm afraid I can'.t rama=her all the 19 I
procedures for the fact that, for a while mow, I don't 20 remember the specific muaber or the manes of any of the ]
21 procedarse. The hamic release procedure was la the 22 18.3.05;. and Radiation Protection 90anual, which was I .q 23 believe the procedure was a dash-13 procedure.
At that period - point in time, that 25 J procedure probably .wme eight or ten pages long. And, am I i i
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recall, by the time we got through modifying it to 2
accomplish the objectives of meeting those new Technical 3
rys,;ifications and .having the involvement of other 4
Gr1ganlutions that did the actual release of, liquide, it 3 5
protp % y *%ied up as a 30- or 40-page procedure.
6 That's - there were many other procedures )
peripheral to that change, also.
8 Q Okay. But the gist of that was that the Tech 9
spec limits would act be exceeded, Tech spec 3.17.2 would 10 not be escoeded?
A ch, the - well, I don' t think that was the entire objective. The changes to all the procedures were 13 required locause we we o changing our mode of operation b,* 14 quite considerably at that time.
In fact, the methodology of operating for
- releasing af change -- .so rapidly, that we had to -- either 17 major or minor changes to that control procedure almost 18 every mont.
19 But, you're right in that this commitment, at this time, said that the new Tech Spoc 3.17.2 was the basic 21 policy clunge and commitment and the procedures from th.at -
22 point on 48 reflect the ability to meet that.
23 9 Ins there eutt.hir.g, specifically, that you -
Q' ,
24 any speciSc instructions or direction or management actions 25 that you tak to luplement Action No. 7 there?,
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1 A Actions they took, yes. 90s ^=Med 2 Across the board, anything that had procedsres, as I said.
anything to do with meeting that particular Tech Spec, which 4
involved the susaation of all gas and liquid release isotope 5 rates of release, the -- of course, the concentrations, 6 involved with the gaseous releases, the meteorology got 7
ultimate accumulation of all those isotopic concentrations to enable the Dose Calculation to the population, all those 9
procedure changes and calculational A T es were now.
the did you principally interface with in Q
importing information into this A port?
A This particular Report?
4 Yes, Report 84-07.
G 14 it was written by Ron
& 84-07. As I say,
' Columbo. And, typically, I would review and discuss with 16 him any problems I had with the way it was written.
17 q And do you recall anybody else that you work 18 with?
19 .
A en this Report?
20 Q Yes.
21
& No.
22 Q Okay. And this --O 23 A Ch, except the people in my Group, of course.
24 You have to understand that I don't do this alone.
25 -
Q Right.
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A At that time I had, probably, oh, 45 people in 2
the Organir.ation. I had a Realth Physicist, a degreed 3
Esalth Physics Specialist that I talked to about this. I 4
had the follow that worked directly under me as an 5
Assistant; and he was responsible for impleme.nting all these 6
things in laboratories --
7 4 Who was that?
8 A - getting people to write the changes to the 9
procedures properly. That was Fred Kellie.
10 Q This would have taken place, I imagine, in the weeks and months preceding the September 27th date of that 12 Report?
13 sure, whatever -- busy making 1 A Yeah, modifications to procedures all througt the sumer of that 15 year.
Q Mhat ie your recollection of the officials 17 that had responsibilities for input into that Report?
18
.A tty recollection?
19 Q Tes.
A Of other officials.
21 Q Like yoursalf, that were responsible for arena 22 like you were in reporting information that's in 84-077 23 A Nell, I don't recall meeting or discussing 24 with any individuals that were on a similar level as myself.
25 They would .have been -- involved people in the Opersting
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Organiattion, the Plant Operations Group. There were six 2 ,
s upervators and the rest of management, it was at that time, ]
3 I as sure. George Coward, Pierre oubre -- let's see, '84 --
4 ProbablY Steve Roddeker, Tom Tucker. Collin - ,I don't know i
5 if he 's over there, but, you know, there's a whole list of )
6 management people that, now doubt, got a review in this.
7
% The Report talks about steam generator tube 8
leaks as being the main source of contamination of the 1 9
secondary system.
10 To your knowledge, were ~ there any other i 11 sources of contamination for that secondary system, other I
. than % steam generator tube leaks?
13 5 No; as far as I know, that's the only route of
( 14 entry sE radio-isotopes ever, the tube leaks.
15 And, as it states, the tube leak that we 16
- KP' in September of '83 was different from all the 17 others, Typically, we would shut down on a tube leak and 18 make % tube repair as necessary, do testing to determine 19
\ if o% tubes were incipient leakage problems or what not.
20 And, 35 know, like makes systems completely repaired --
21 comp % repaired s>efore returning to power.
22 And we thought we had done that again in 23 septa 4r af '83; but, when we returned to power, there was 24 It may still be there,
- F*%I leak and it continued.
25 for sGE know. It was on the order of .09 -- .05 to .09 j
i i
l i
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, 1 gym. And insufficient leakage rate to determine where it 2
was, by most any technique you could imagine.
Q okay.
4 A The only thing we could think of,was that one
'S of the tubes that had been plugged at that time, had a fault 6
l An the plug.
7 Q Let's turn to page 2, here. This last
, paragraph describes tne psthway of water to the environment, 9 I that you can' t contesinate water from -- the contaminated 10 !
secondary system water, as the result of the steam generator tube leaks.
12 Nho was responsible for that paragraph there?
13 A For writing this? ,
14' Q Yes. Do you know, specifically?
A No, I can't remember at this time. My 16 it because he's very presumption is that Columbo wrote 17 familiar with the equipment and the process used.
18 I might very well have modified it. I might 1R even have written it; I don't know.
Q okay. But it is your understanding that is 21
,,,,3gg,37 ,,
22 A Columbo was given the responsibility to draft ;
23 the responses to the NRC, almost all cases. I don't know 24 how upper management operated when there was any particular problem, but, in all cases I as familiar with, Ron columbo
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draftad the responses to NRC. J 2
Q It's possible that you could have inputted 3 i' that information; but that's not your recollection of it 4
- today? .
A I don't recall it today.
6 It's written pretty well; I might have done 7
it.
Q That describes the pathway of the contaminated 9 There was a modification running water to the environment.
10 the from the Demineralized Reactor Coolant Storage Tank, II DRCST tank to the Regenerate Boldup Tank, or the REUTs.
12 That was also a pathway to allow water and radioactivity to 13 be introduced to the environment. -
- 14 Why wasn't that modification mentioned in this Report?
A I haven't any idea in the world. Basically, 17 thJs Report is discussing the activity that's released to 18 and it doesn't, anywhere, suggest what i the environment; 19 isotopes are involved, as far as I know.
But I think, underlying this whole thing is j 21 the implication that no are dealing with radionuclides like 22 Cesiums, cobalts, and possibly lodines, that do impact on J the population exposure.
Now, the half you are referring to is a method 25 of reducing water inventory but only the inventory that i
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contains Tritium. And that's -- I don't know -- I suppose, J 2
if you want to get really very detailed an analysis of this 3 )
letter, the total amount of activity released to the l l
4 environment does impact on the whole body expogures and the 5
population exposures.
But Tritium was always used in a different 7
light; and I'm not surprised at all it's ignored in this 8
1stter. Tritium is such a low energy beta, it's so long-9 lived, its dose contribution to the public is essentially 10 nil.
Q It has a short half-life?
12 A Twelve years; .it's not short. But it's 13 indistinguishable from water, normal water. Tritium is
'b 14 involved in the water molecules and so it doesn't
' concentrate -- it doesn't create an environmental linkage 16 that leads to any particular source of exposure to the 17 public.
18
.Q Mas there any procedure to sample the DRCST 19 tank to confirm that there were no --
A Ch, sure.
21 Q ---ga mma saitting --
A _
Both routinely, before any releases.
23 Q Now was that procedure carried out?
24 How was the procedure carried out?
A 25 The procedure to sample the DRCST tank?
Q f
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A Just by procedure. l 2
Q you said that modification was set out through 3
the Tritiated water.
4
- A Well -- .
5 Q Now do you know there wasn't other gamma-6 emitting nuclides in there?
7 A Ch, okay. Well, there were, as a matter of 8
fact; you could detect other gamma emitters. But they are 9
very, very low level.
10 As I say, the tanks were sampled routinely. I
- 'I I don't remember the frequency believe -- I won't say that.
12 sampled; a at which they were but there is routine
' surveillance procedure in sampling those kinds of tanks.
14 And then anytime that the water inventory was 15 such that you had to release some of those gallons from the 16 DominRC Tank, we'd take another sample prior to the transfer 17 And, of course, then, after the water is of the water.
18 transferred, it is in a control tank and the control tank is 19 the tank that's sampled for the actual release permit. So, l.
20 it's actually sampled twice.
21 Q 5efore you n-22 A Three times; they are sampled doom in the 3 retention basins after we discharge to those.
Q So, before you release --
25 A Four times; wer sample the affluent as it was s
20
. 1 being released. Same water, sampled four times during the n
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release process.
3 Q Any more?
4
- A That's it. ,
5 Q Okay. Before you released it from the DRCST, 6
it was sampled for gamma-emitting nuclides?
7 A It would have been sampled and analyzed for 8 the major Tritium, specifically. That was contributor 9
activity. And our procedure, I am sure, would have called 10 for a gamma scan sample, too.
11 Typically, the gamma scan would not come up 12 with anything measurable. .
13 Who would know, specifically, if you did do a g Q L. 14 gamma scan on it or not? ;
In other words, you showed some doubt; you 16 said you believed that you think a gamma scan was made on 17 the water coming out of the DRCST and the REUT.
18 I can't verify averythiag like that.
..A Okay.
19 Q Mho would have had that direct responsibility, when it was taken out of there, to sample it?
21 A Just by procedure, procedural control.
Someone had to sign off that the sample had been taken and 23 checked to ensure that it was suitable for release purposes.
24 can't verify it that AP-305.13 was the And that -- I required that; but that was the basic procedure that
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controlling procedure. It might have spun off to some other 2
operating procedure or something else that required that 3
specific Action Item; but it was done.
4 Q And then, the DRCST water, once ' it was put into the REUT, was sampled again? )
6 A Yes.
Q Now, that water was -- the DRCST water in.the
> REUT was diluted with other water?
9 A Yeah, yeah, most of the time, probably.
10 What is difficult about this whole thing is
~
that it's tied up closely with the operations Organization, 12 how they manage their business. And the Operating Group had a lot of things to worry about besides - to operate a 14 plant.
15 They had -- the water inventory was the najor difficulty because of the plant's siting, a dry siting. And 17 so there is alwaya tha' laege -- not large, but an active 18 effort to limit the amount of water, in inventory, that 19 contained activity. That meant that the processing 20 equipment could be utilized to a good extent; and Operations 21 Organization did all that, had the whole basin full of 22 they filters, internalizers, evaporators, things that 3
operated.
24 So one of their najor functions was to enable the plant to operate by processing water and removing all r
22 1
the activity and keeping Tritiated water separated, keeping 2
its inventory under control.
3 To do that, they would allow these large tanks 4
to build up in level to a point where they decided 5
something's got to be done fairly soon. So then, they would 6
request a program of release.
7 In the earlier days, when they had a program 8
of either trucking liquid off site or solidifying liquid and 9
burying it, in this period we are talking about, activity 10 that they requested for was release of the Tritiated water.
. And so that meant that the Operating personnel 12 had to , decide how much they needed to release, see the --
13
.. measure the activities in the tanks to determine that ,it was 14 releasable, that -- and recommend a certain gallonage per batch of release.
16 Then the operating people would maneuver water 17 in the plant so that, somehow, they could get the Regenerate 18 Boldup Tank that contained that, whatever, 8,000 gallons 19 Tritiated water. It really didn't matter what other waters were in there as long as they didn't contain other 21 activities..
22 So the Operating people would take water from 23 the polishing sump, or from the condensate tank or whatever the -- wherever they had other waters rising from their 25 operations and fill the Regetierate Boldup Tank and somehow e
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get that other 5,000 or 8,000 gallons from the DominRC Tank '
I transferred to that Boldup Tank.
3 What I as trying to get at is, they had a 4 1arge amount of water manipulations going on, at any one 5 time.
6 If, in sampling the DRCST or the RHUT, they Q
7 came up with detectable nuclides, other than Tritium, then ,
8 what did you do?
8 A Well, if it was fr.on the Domin Reactor Coolant 10 storage Tank we found other isotopes, we make an evaluation 11 to see whether that would contribute anything to this 12 problem of Cesium, cobalt, lodine released to the 13 environment. And, typically, it did not because the, levels
[i 14 were down in the mud, they were hardly measurable.
15 And then -
16 What levels would we be talking about? They Q
17 are below the LLD, what -
18 A Nell, the LLD, we were trying to hit we s 18 three-tenths to the minus seven microcuries per cc. So I 20 don't recall the numbers; but I au sure that they were 21 something 8, below the Tech spec level.
22 Q If that water was diluted, as you stated it 23 was, what af fect would that have on ,the ability to (stect 24 gamma-emitting nuclides in that water, if you didn't do the 25 sampling until after the dilution in the RBUy?
24 I A Well, of course, if it gets more diluted, you 1
2 have a more difficult time measuring it.
3 So, it should be sampled before dilution?
Q
- Well, here's where the NRC ha,e done their A
s 5
biggest job, I think, on SMUD. They always and forever, in 6
their inspections and their program evaluations, would 7 consider the Regenerate Boldup Tanks as release tanks.
8 And SNUD is a little different from most other 8 utilities who -- that the other utilities have a holding 10 tank or something that they release to the river or the 11 ocean or some large body of water, a huge dilution.
12 Well, SMUD didn't design the plant around a 13 large body of water; they de, signed it around a dry site.
C 14 And, therefore, we didn't exactly have a holding tank like 15 other plantu would have, a holding tank that would slowly 16 dribble out activity into a largo dilution.
17 And, in fact, when we released the Regenerate ,
18 Moldup Tank, we had very little dilution with water, just 18 whatever was going out the plant at that time, the wasta 20 water flow. l 21 And so that - not really related to that at 22 but, the design of the plant, they also had all, in 23 retention basins. And the reason for those, basically, was i 24 for chemistry control. j to take the fluid out of the 25 We elected I '
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to 1 Itagenerate Noldup Tanks, always put that in a retention 2 basin before we released it to the environment.
3 The idea was, I think, pretty good in that,.
4 you- are dry-sited and need whatever dilution you can 5 possibly get to release to the environment.
6 And, if you go through an extra step, putting )
l 7 it into a retention basin, which is large, half a million l 8 gallons, and you have other waters in there, you are l
9 automatically getting some dilution. Plus the fact that you l 10 can control the flow from the retention basins and put that 11 mater out of the plant at a fairly low flow rate ar4 even 12 add more dilution water, latentionally, if you wish .to at 13 that point. ,
14 A lot of good points, I think, to increasing 15 the capability for dilution by taking the affluent from the 16 Regenerate Boldup Tank to the retention basin.
17 The difficuity we got into with NRC was that, 18 af ter years and years and years of diiscussing the Regenerate 19 Roldup Tanks as our . control point, as our release point, 20 they decided tha.t, based on the question you raised here,
- 21 they decided that you really have to go back into th plant 22 , further, to the other source tanks, and analyze that stuff 23 and . not assume that your Regenerate Boldup yanks are your 24 control tanks in a sense, and saying you got to go one step 25 farther back into the plant and look at all your sources for i
a
26 d
1 this, the DominRC Storage Tank, or the Miscellaneous Water 2 Boldup Tank, and I presume, if we had activity coming out of 3 the Component Cooling teater System or something like that, 4 they would want us to measure that and analyze that and 5 estimate gallone from that.
6 But the whole approach toward control moves 7 from W Regenerate Boldup Tartn back to the source tanks in 8 the plant.
e Q When was this?
10 A That uns just about the time I left. They 11 were just getting really fussy about it.
12 4 IEnst une their basis for -
13 A 95 ell, their basis was brought about by the 14 ease kind of question you asked, I believe, that, if you 15 have a measurable asuunt of activity, back in. the plant, 16 and you put that in the Regenerate -Boldup Tank and it's 17 diluted at that point, then you can't measure it any longer.
18 Then, by the proper reading of the sfodes of 19 Federal Esgulatioos, you hava to take W known quantities -
I 20 and use those as a known, fixed Laount ot' activity, even 21 though you can't measure it any longer.
22 - Q And then figure out the diantica rate, based 23 on that activity.
What's wrong with that? .
24 A There's nothing wrong with that. That's the 25
( ,
1 _-_ _ - - - _ - _ - - _ - - - - - - -- -
27 l
l 1 way they are operating. But it's a change in philosophy, is 2 sy opinion.
3 It changed the designated control tank onsite 4 for whatever source coming into it, to tanks.back in the I
5 plant that you know were contributing to that tank.
6 q or, just when water goes in there, just sample 7 it - well, like in this case, before it goes in, if there 8 is water already there, or, after it goes in and then sample l 9 it. And then you bring it in from other sources, you know, 10 have that sampled, so you get -- before that RNUT is released, you get a picture of what the activity is in
~
11 12 there.
13 A Though you can't asesure it any longer.,
14 It's the whole question 'of the concept of notching. The NRC's really expert at it. They've developed <
15 16 it over many years. You find out what the utility knows; 17 and all of a sudden, if they know something that isn't i
18 required, it becomes a requirement. It's very simple.
19 Q In this instance, like you are talking about, 20 the fact that it was the requirement to sample the RNUT tank 21 as the control, the release tank -
22 A That's right. Tech Specs required us to 23 sample and analyze that tank as a control tanh, release 24 tank.
25 Q And then, beginning in mid '85, they started
. 24 )
1 to lapose requirements that really, to get up, they should 2 be sampling before unter went into the REUT tank?
3 A Yes.
4 Q In order to be able to determine -- ,
5 A Yes.
6 Q And you are saying -- ,
7 A It spills over into other areas, too. Another 8 good azample - back in '80, '81, some period like that, the 9 country got all upset because of the amount of waste volume, 10 radiological wastes that were going into burial sites. And 11 we were going to run out of burial sites. Only Manford and 12 Nevada were available. And Bernal (phonetic), South 13 Carolina is going to fill up real quick. What the hell are
(, 14 we going to do?
15 So the question of what is radioactive, or 16 what is enough radioactivity to require burial came about.
17 And the NRC put forward a real neat document 18 at thr.t tina. I think it was -- it wasn't a Reg Guide, but 19 it was something similar to that publication.
20 And they requested the utilities that, if you 21 have any wastes that are extrema low level activity, that 22 you think shouldn't be considered as radioactive wastes --
23 they are'not active enough to require burial in your eyes --
24 tell us about it, we'll evaluate it and we any give you some 25 options rather than take up valuable burial space.
(
29 1 At that time, it was costing -- I don't know, 2 maybe $15.00, $18.00 a cubic foot.
3 They said, tell us what you 2have, describe 4 what options you have for removal or disposal of the 5 material and we will evaluate it; we may let you do 6 something.
7 So we had a real choice example, had some 8 graphite -- or charcoal, it wasn't graphite -- charcoal that 9 had been used in air filters -- systems. And had large 10 quantities of it because, once it had been used for six 11 months or so, it deteriorated to the point where it was no 12 longer effective, had to change out these big filter banks 13 all the time.
14 So we had barrels and ' barrels and barrels, Probably 150, 200 barrels at that time, ese thought, " Rey, 15 16 here's something that has the very smallest amount of 17 acti'rity in it. An1 we had measured it, analyzed it, and 18 had - I forget now, some cobalt or something in it that wa-4 l 19 just barely detectable.
I 20 So we found several options for removal and 21 disposal, one of which was just burial in landfill. The 22 other was to be used by another company that would use it for filtration purposes, since it still had some 23 ef festiveness as a filter. And I forget, one or two other 24 25 uses of it that we found for it. ,
l 1
O 30 a.
< 1 We sent it to the NRC. NRC came back, about j I
2 six months later, saying "We're evaluating this." And so I 3 pressed them again, after that; and another three or four 4 months went by. And they finally came back with the neat 5 stetement that you can do anything -- any of these proposed 6 uses, provided that the State accepts your proposals.
7 And, you know, here they are, an Agreement 8 State, California. The NRC had full cognizance of the 9 radioactivity on the site. The State has absolutely no 10 knowledge of what we do or what we have or what we propose
. 11 for this material.
12 so, I went to the State and I. asked them if 13 they -- what is their opinion of it. And they had an b 14 immediate opinion; it says, "If it's radioactive, you have 15 to comply with the NRC rules."
16 And we went back to the NRC and says, "Well, 17 as we said, you can do anything you want provided the State 18 gives you a release."
19 Q So you felt like you were chasing your tail?
20 A yeah. Then we got into a little esoteric 21 discussion with the Inspector who came, telling us that we 22 really should have put it in landfill or something, and gone 23 ahead and done it.
1 24 And he liked -- and the conclusion he came to 25 is that we should not have measured it. Either we should t
( ,
O 31 o
1 not have measured it at all with the, again, analyzer; or we 2 should not have measured it so effectively.
3 Now do you like that one?
4 Q That's interesting. ,
5 As far as analyzing offactively with gamma 6 emitters, your Tech Spec 4.21.1, Footnote.C, says that, when 7 you get identifiable peaks -- and I will show that to you --
8 you should report it.
9 A Mhat's that part of?
10 Q Your Tech Spec.
. 11 A What part?
12 Q 4.21.1.
13 A Which is Environment --
b 14 Q The Environment:a1 Tech Specs, yes. Excuse me; 15 I am sorry.
16 (Document proffered.)
17 Eumber C.
is A 4.21 is Liquid Maste; okay.
19 This is not the Environmental; this is the 20 release requirements.
21 Q That's not part of the RET $7 22 A Well, yeah. But there's another table of 23 stutf that requires you to measure environmental samples to certain specific concentrations. This is not the 24 25 Environmental samples we are measuring, these are releases.
e
, 32 j s' 1 Q Right.
2 A Plant samples.
3 Q I am getting bc.ck on the liquid offluents.
4 A Yes. ,
5 Q I don't want to --
6 A But you talk about the environment. You go 7 back to Radiological s' environmental or Radiological Effluent.
8 Q Effluents. l 9 A Effluent Tech Specs; okay.
10 We started out talking about Environmental !
. 11 Tech Specs.
12 Q Environmental; okay. We will make it 13 Environmental from now on.
b 14 A Now, they are Effluent Tech Specs.
15 Q Well, what is the official name?
16 A I don't know; it's RETS.
17 Q Radiological Environmental Tech Specs, I think 18 is what it is. But, anyway, Footnote C, here, mentions 19 that, when you 40 --
20 A Okay; that refers to the release tank gamma 21 unalysis, five times ten minus seven LLD; okay.
22 That's the only place that refers to that:
23 okay.
24 Q So it says, when you have peaks identified of 25 radionuclides --
i
o 33 '
1 A Yes. l 2 Q -- they should be reported?
3 A Right.
1 4 It calls out the LLD for manganese, iron, j q
5 cobalts, zines, and co'sius and so forth. dnd then the 6 Footnote just says, "If you find anything else detectable, 7 you shall report it." That's fine.
8 Q Does that also include -- in other words, if j e these were detectable --
10 A Oh, yeah; you have to report it. You have to 11 look for these at that level, at that five times ten minus 12 seven level. You have to search for those. But, if you see 13 anything else in the meantime, you have to report it.
14 Q Now, let's say you had Cesium 137 that you detected below five times ten to the minus seven. According 15 16 to that Fe,otnote, would you have to report it?
17 A Yeah, yeah, anything measurable.
18 Q In that case, then, you couldn't release it if 19 there were identifiable peaks there?
20 A ch, it has nothing to do with release, nothing 4 21 to do with release at all. It just says you have to measure 22 it at that level of sensitivity.
Nessure it and, if anything that is 23 Q measurable, even if it's below the Tech Spec, that Tech 24 25 Speck level there, you report it?
O
~
____.-._--___----__----------a- - - - - - - - - . - - - . , , - - ,,.
34 1 A You have to account for it.
2 Q That's right; but you can release it?
3 A well, you may or may not be able to release )
I 4 it. It all depends on your Dose Estimates. You have to 5 estimate what the public exposure will be froa your proposed i
6 discharge.
7 Q And then you decide?
8 A And then you decide you shall or shall not 9 release.
10 g okay. In this, what were the activities that
. 11 created the excess water that required it to be released?
12 A Well --
13 Q Actually, the activities that filled up the b 14 DRCST tank and then, therefore, you had to release the DRCST 15 tank.
16 And what was it that was going on at the plant 17 that caused that to fill up and have to be released and fi.11 .
18 up again and have ta be released?
19 A Well, I don't feel qualified to answer that 20 question. The plant equipment all has leakage. There's --
21 You car.'t build a pump or valve or system, operating system, 22 that doesn't have some sort of leakage.
And, of course, there is a one-gpa limit for 23 l
the primary system to leak. And, if you have unknown paths 24 25 in excess of one gym, you have a Tech Spec to assure them to
mmm.-__ _ , _ _ _ _ _ _ _ _ _ , _ , _ , _ , _ _
i 35 1 do something about it. ,
2 And, as far as I know, the plant systems 3 leaked to that extent. l 4 Q The Operations personnel would .be better
.- t qualified to answer that question?
5 6 A As far as I as concerned.
7 Q Bow did you assure that water coming out of 8 the DRCST was properly sampled for gamma esitters?
g A Nell, you asked that before; and I don't have 10 m hard answer except that it's done by procedure. There's a
. Si surveillance procedure for routine sampling of the tanks 12 and, somewhere, a procedural requirement for sampling prior 13 to the release program.
14 Q Could we look at page 2 of that Special Report again (indicating). In that Action a here, under the Near-15 16 Term Corrective Actions -- is that 87 17 l't states that, "The processing of water from 18 the FDS and the REUTs to the Rad Maste System, coupled with 19 the dilution of the liquids, will help essure compliance 20 with the limits of radioactivity released in liquid 21 effluents."
22 Could you explain what is meant by dilution of 23 the liquids?
A Now, let's see what it says -- ...a 24 25 progras... polishing sump or Regenerate Boldup Tanks to be l
a
36 1 processed back to Rad Stasta...*; okay. "The option could be 2 exercised at the option of Chen Rad Protection personnel.
3 This method, coupled with dilution of the liquids, will help 4 ensure that any liquid waste release may be....to this 5 program."
6 I guess I wouldn't care to comment on that 7 because I don't know exactly what it's talking about.
a Q Okay.
9 A The option of sending the water back to the 10 plant for processing was the Action that was implemented.
11 And it did give the Chen Rad Department the responsibility, 12 then, to determine when that should be done.
13 And that meant that we had to look at water in .
14 the polishing sump or in the Regenerate Boldup Tank and say 15 yes or no, that water has too much activity to be released.
16 And that's, at that time, our judgment call 17 but we set up some program to accomplish the decision making 18 that we should or should not release that amount of activity 19 because it would or would not, over a considerable period of 20 time, result in a population exposure that was unacceptable.
21 But I won't comment on the next statement that 22 says, *This may be coupled with dilution of the liquids..."
with because I can only guess what they are commenting on 23 their dilution of liquids.
24 25 Q So it would be best to go to whoever the
(
e
- - - _ _ _ _ _ _ _ _ _ _ _ _ _ __..--_-__--._-__-_____--__-___.-__.___m.__m._______
37 1 author is?
2 A yes.
3 Q Whoever the author was of that particular 4 section?
5 A I Presume it means that we now have better 6 capability for dilution of the stuff that ' we decided to 7 release. But it's not clear at all.
Q Let's look at those Tech specs again -- more 8
9 specifically, the bases in Tech spec 3.17.1, Limiting to Conditions for operation and Tech spec 4.21.1, surveillance standards. If you look in th+e bases, in the second 11 12 sentence, there is a word inserted in there; and it is the 13 word "not", in that second sentence.
- r. essentially, what that word "not" V 14 And, indicates is that the specifications do not assure 15 16 compliance with 10 CFR Appendix I Dose Objectives.
17 Explain why these Technical specifications I
18 cannot assure compliance with the Dose objectives of 10 CFR 19 50, Appendix I.
20 A I'm not auch on bases in Tech specs; Columbo 21 generated all of them and they just were, I think, gleanings 22 from the FSAR or whatever he got at the time.
23 If you are asking me to read this and comment 24 what it means, I'll try; but it's speculation on my part.
25 Q I am just asking you why couldn't these Tech i '
1 38 !
1 specs assure compliance with Appendix I.
2 A Why it --
3 Q The insertion of the word "not", essentially 4 what it is stating is, you cannot assure compliance with 5 Appendix I.
6 A Okay; but these are not recent Tech Specs; 7 these are something that was generated a long time ago.
8 Q Mell, these are the recent ones, the RETS Tech 9 specs, the Radiological Environmental --
10 A When did that bases get put in Tech specs?
11 Q From what I've been able to determine, the 12 word "not" was inserted when these Tech specs were recently 13 drawn up.
b 14 A Yeah, probably back in '73 or --
15 Q '75, '76. And --
16 A They weren't in the original Tech specs?
17 Q You mean the pre-RETS Tech specs?
18 A Yeah. ,
19 Q Not that I'm aware of.
20 A Okay; so they got in somewhere when RETS --
21 Q Mas being formulated.
22 A Mas being formulated.
Q I mean, RETS kind of got put on the shelf 23 24 during the TMI flap.
25 A Yes.
1 I
39 1 Q After TMI, NRR got around to implementing the 2 RETS; and so these -- the Tech Specs that were drawn up back 3 in '76, '76, '77, were. eventually implemented in July of 4 '84.
.~
5 A Correct.
6 Q &nd this word "not" stayed in there during 7 that whole process.
88Y question to you is: Why was it put in 8
9 there? Why couldn't the Tech Specs assure compliance with 10 Appendix 17 A Oh, I think -- this is - is this the -- oh,
- 11 12 yeah; okay. This is the thing that NRC got so upset about 13 when they found the word "not", I guess.
b 14 I didn't recognize it; but Columbo apparently 1
15 initiated the RETS Tech Specs with this concept that Rancho seco was designed prior to 10 CFR 50, Appendix I, that wo 16 17 should not be held to them.
18 That was the agreement with NRC at the time 19 Appendix I was promulgated, that they would not be back-fit 20 to existing plants, but that we would attempt to do whatever 21 we could to v.ilize the concepts under, Appendix I.
22 Q Okay; thank you.
So when did you become aware that Rancho 23 24 Seco's Tech Spec limit -- or the Tech , Spec Lower Limit of 25 Detection SE-7, might not be sufficient or is not sufficient i I
. 40 1 to assure compliance with Appendix I?
2 A Well ., I heard it talked about it; but I guess 1
3 I'm still not sure that that's true.
4 Q When did you first hear it talked about?
5 A Probably spring of '86. I don't remember the 6 exact period.
7 Q So, it was after you retired?
8 A Yeah.
9 Q This fact, this issue, mover came to your 10 attention --
11 A No.
12 Q -- while you were Superintendent of Chemistry 13 and Radiation Protection?
No. We had arguments about what LLDs meant, !
> 14 A 15 how to define them and how to try to make NRC's definition 16 come to mean something. I don't know -- I don't recall, 17 prior to hearing in '86, that there was a question that wo 18 could not measure to the sensitivity required to meet 19 Appendix 1.
20 Q So it was your impression that the Tech spec 21 was always sufficient to assure compliance with Appendix I?
22 A Yeah.
23 You know, that just makes sense, that those are standard Tech specs, they are promulgated for all 24 25 Pl ants. And NRC set out the LLD level and the whole table i
_ a____mm___.--____-a_.______._--__ _ _ _ _ - _ _ _ - _ _ _ _ , _ _ _
I 1
41 1 of required measurements, obstensibly to meet that 2 Appendix I criteria.
3 So, absolutely no reason to believe that they 4 weren't coherent.
Q Why were instructions given to lower the 5
6 counting time on analysis of the REUT samples'? 4 7 A Well, that came about as an item just as I was 1
8 leaving in June of '85. And, to my best knowledge, best reco11setion, the counting time had been set at 2,000 e
10 seconds for -- as part of the procedure, for quite a while
. 11 and had come about, probably, because it was a convenient i 12 time designation to set in the instrument.
4 5 Technicians just sort of grew that way; they 14 put a sample in and set it for 2,000 seconds and walli.ed q 15 away. When the timer went off, it was -- the count was )
16 finished.
And about June or, I don't know, maybe a 17 18 little before that, of '85, well apparently we ran into a 19 huge backlog on counting. Instruments might have been out of service; I'm not sure. But there was a big backlog; anr1 20 a question came to me. "Do we have to count for 2,000 21 22 seconds?" Tho' answer was no, we can meet the sensitivity requirements by shorter counts. Probably met it by 500-23 24 second count.
25 So whoever was trying to get samples pushed
o 42 l 1 through at that time, probably Fred Kellie, decided to just 2 cut the time. l Okay. Do you know who, in the annagement 3 Q 4 chain, authorized the lower count time on the enalysis of
.- 1 i
5 REUT samples?
6 A Mer.t through as a procedure ' change, that's 8
7 all. No, I don't know who authorized it.
8 Q I want you to look at a record of a telephone 9 conversation between Fred Kellie and Greg Yuhas of the NRC, 10 And the reason for the call was to resolve the meaning or
. 11 interpretation of the second sentence of the Notation C, .-
12 Tech Spec A.21-1, here.
And the resolution reads, "If a nuclide is 13 b 14 below minimally-required LLD...", which is SE-7, " ...but 15 is a positive value, it must be recorded and reported.",
16 which you have similarly stated that earlier today.
17 A Yes, uh-huh.
18 Q And then Kellie wrote up that record of that telephone call here (indicating). And you were on --
19 20 A Distribution.
21 Q -- distribution for that.
22 A Yeah, I probably got that the day I left.
I Q When did you leave, the first part of June?
23 A Yes, the 12th, 13th, something like that. 1 24 Q
What was the background behind that telephone f 25 l ,
-_________m __________m_ . . - _ _
43 1 call? What was your involvement in that? !
2 A Ch, I remember Fred came to se and asked me to i
interpret this for him. And it isn't real clear. It says, 3
4 "Nuclides which are below the LLD for the analysis should !
5 not be reported as being present at'the LLD level."
6 And he was a little confused asi to whether the 7 value of a positive which was less than the LLD number had i l
And I said yes, because it was my l 8 to be reported or not.
9 understanding NRC always wanted positive numbers reported, 10 anything measurable.
. 11 And he said, "We'll go talk to NRC and see if 12 that's what they mean." So that's the result there.
13 Q When you got that, did you have an opportunity 14 or an occasion or did you discuss it further with KellAe7 15 A I don't think so.
16 Q Fardon?
17 A I don't think so.
You don't think so. Did you give any 18 Q based on this telephone 19 constructions or directions 20 conversation?
21 A No. Fred asked me a question, to interpret this, and I interpreted it for him. And he said, "I'm going 22 to go ask Yuhas about it." And I said, " Fine." And so he 23 24 did; and he got the same answer that I gave him.
25 Q You mean you exited stage left, huh?
44 1 A I had one foot out the door right then.
2 Q Did you take any- management action to make 3 sure that peaks that were identified were reported before 4 you left, before the other foot went out the doo,r?
5 A No, that was the general direction given to 6 everybody, anything measurable was reportable.
7 Q You had a practice of taking composite samples )
8 of the REUT for analysis for controls for the environmental )
l 9 pollution --
10 A Wait a minute; start again. 'You had a
. 11 practice of taking composite -- 7 You took composite samplings. In other words, 12 Q 13 out of every sample that you took of the REUT -- ,
C ,4 A oh, okay.
15 Q - you should separate a little bit and put 16 that in a container and then all samples that were taken out 17 of the REUT had a little bit taken out and put in that same It was a composite of of the RINf. And, on a 18 container.
19 monthly basis, that was sent to the CEP, the controls for 20 Environmental Protection.
21 A Pollution.
22 Q Follution, Why were there only samples taken 23 when the.REUt sampled positive for nuclides, radionuclides?
A I guess I can't answer that. The reason for 24 _
analysis was for the -- I don't 25 sending them out for i
1
- --__--_--_________,_____u______
45 1 remember that -- I guess gross betas and Strontiums and 2 alphas.
3 Q I think that was --
\
4 A I don't remember if they did gross beta also 5 on those or not, just Strontiums and alphas, as I recall.
6 I can' t answer except that there would be 7 absolutely no expectation for Strontium or alpha for contaminants not in conjunction with beta or gamma -- the 8
9 plant just simply had no sources of alpha or Strontiums.
Q I understand that -- I think we might have 10 11 touched on this very briefly; let'r just go over it again.
Who was responsible for collecting and 12 13 maintaining records on water transfer from the DRCST to the 14 REUT7 15 A Records on the amount trzasferred?
Yes, and than the subsequent analysis or 16 Q 17 analysis before?
A I don't recall the exact stepwise 18 responsibilities. It bounced between the operations 19 organization and the Chen Rad Group. And the procedure 20 21 controlling movement would be done with sign-offa at every 22 step of the way, that water would be analyzed prior to 23 movement, the movement would be done by operations, the 24 amount of water transferred would be dictated by Chen Rad, 25 and the actual measurement of that quantity would be by 4 .
46 1 Operations.
2 So, somewhere, there were procedures, steps 3 saying, "I, Mr. Operator, transferred so many gallons of 4 water at a particular time."
5 Q I guess all or part of that wou[d be on the 6 Release Permit, too --
7 A Yes.
8 Q -- since that water was destined for release, 9 that's --
10 A well, I can't guarantee that either because 11 the Release Permit -- the release procedure controlled from 12 the Regenerate Boldup Tanks outward. Stuff going into the 13 Regenerate Boldup Tanks --
b 14 Q You'd have to track it by the individual 15 Procedures from there?
16 A Yes, it may or may not be involved in this 17 procedure.
f 18 Q There were only a few records of that 19 modification from the DRCST to the REUT that were located.
20 Ne have back in '75 which disconnected the modification.
21 You had another one in '81 which set it up again for a certain time period, another in '81, '82 ti'se period -- in 22 the end of '81 into January of '82. I think there was one 23 !
! 24 record that showed it setting it up; but there was no record
~
l of taking it down.
25 )
l
_.____._______._m______ __ _ _ _ _ _ _ ]
n !
1 The point I na trying to make is: SMUD has 2 officially replied to a question I asked that, "We don't We know that, when we had high 3 have all the records.
4 records of treating releases to the environment, that it Probably came from the DRCST tank. And here, ' when we had 5
6 high records of treating releases (motioning) we don't have 7 any record of that; but we assume that it came from the ]
8 DRCST tank."
g My question to you is: Why weren't all those 10 records kept or maintained?
- 11 A I haven't any idea. The modifications were 12 done with the Maintenance Group to operator's desires --
4 13 operation's desires.
Okay; you just got the marching orde'rs to 14 Q 15 sample it when --
would be surprised if the first 16 A I 17 installation, that wasn't accompanied by some engineering 18 analysis and a review of the safety analysis or something
- 19 like that.
Well, as a matter of fact, there was no 20 Q 21 engineering analysis or safety analysis -- .
22 A Never --
Q But you would expect it should have been done 23 24 or would have been done or most likely certainly wouldn't 25 have been out of order to do one?
e e
--_.-- ._. - - _ _ . _- m_-_-__-_-___.___.___m_ _ _ _ _ _ _ . .
48 1 A No, it would have been in line with most of 2 the other things that were changed and analyzed.
3 Q Whose responsibility was it to update this 4 modification into the Safety Analysis Report? ,
5 A I can't tell you that, part of the 6 Engineering.
7 Q Engineering?
8 A There is several Engineering Groups,; and I don't understand the differentiation of responsibilities 9
10 between the groups.
11 There was a Plant Assistance that did minor modifications, utilizing the Maintenance Department.
12 13 There's a Tech =ical Support Engineering function that was nnaite, that did a little more extensive modification 14 15 programs. And there is an Engineering org,anization downtown 16 that did major modifications.
17 And somewhere in that melee, was a Phys-B 18 (phonetic), the data responsibility.
Were you ever involved in any discussions 19 Q 20 where you talked about updating the safety Analysis Report p1 with that modification?
22 A No.
Q Were you ever involved in any discussions 23 24 where you talked about reporting that modification to the 25 NRC, make them aware of it?
e
- 49 1 A No.
We talked about offsite shipments, the l 2 Q 1 3 Tritiated water. That was stopped because of the law?
4 A Well --
- 5 Q Regulations?
A Regulations, the regulators. I don't think l 6
)
7 there was ever any -- a law propounded. There may have been 8 a change in the Code that would have made that happen; I 9 don't recall.
10 There was, somewhere back in the - let's see, 11 the period '77, '78, something like that -- we started out to keep the water inventory of the plant 12 attempting 13 minimized so that any untoward occurrences, we'd have some
~
14 volume to play with.
15 And the first option used for the removal of 16 Tritisted water was trucking it out by bulk liquid. And 17 that went on for some time, hauled some to Beatty, Nevada 18 and hauled it to GE Valve seals (phonetic) . We hauled some 19 down to Texas.
20 Q What determined where you hauled them to?
21 A Nhoever would take it. The various wasta disposal companies would provide bids. SNUD, of course, had I 22 23 to go low bid, get bids on waste disposal every year -- and 24 whatever option was available that year.
And your recollection that it was stopped 25 Q l
a
_ .__.____._________-a _ _ - _ - - _ _ - _ _ _ _ _ _ _ . _ _ _ . _ _ _
50 O
1 because of NRC's --
2 A Their concerns about transportation accidents, 3 no real hazard but just- the publicity; poor esistions 4 developed if you have an accident.
5 Q What did you do with the water after that?
6 A We started solidifying it onsite. Wie brought 7 in a waste disposal company each year that would make 8 concrete out of it. They hauled it out as concrete.
9 That went on until, I don't know -- in a way, 10 it's still going on, I guess, still disposing of stuff by 11 solidification to concrete.
12 Q And the fact that you have to make releases 13 from the DRCST, that doesn't -- that can't be traced back to br 14 the fact that you don't ship water offsite any more or --
A Well, it's all related. You know, they have 15 16 this question of how you deal with the water inventory I
17 onsite that contains Tritium. And the plant design said J that every -- well, at some period. As I recall, it's like 18 19 overy ten years, there has to be some program of eliminating 20 water inventory that contains Tritium.
21 Q Why is that?
22 A Why is it?
Q Nhy, yes.
23 I6. that because you meet your limit or why do 24 25 you have to --
8
. 51 1 A The plant was built with a large amount of 2 tankage so that you can imanage that water. And there is no 3 way of separating Tritium from water; nobody can do that 4 except with isotope separators.
i So the plant, by design, has an inventory 5
accumulation of Tritiated water, just from leakage of 6
7 primary systems processing that water.
And,'as I say, the FSAR was talked about 8
removing large quantities of bulk liquid 9 periodically 10 containing Tritium.
. 11 Q Why can' t you just continue using it in the 12 system?
You can; but you run out of tankage. You 13 A
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U 14 recycle as much as you can; but pretty soon your inventory 15 builds up.
16 -Q Right; okay, because of leakages, because of 17 outages --
18 A Yes.
19 Q -- just the natural operation --
20 A Yes.
21 Q -- of the plant, you are going -
~
A It doesn't evaporate. You've got one gym --
22 Q No matter how much you wish.
23 24 A -- up to one gym continuously coming off.
25 Q And so the method of taking care of that first
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52 1 was offsite shipments, then solidification --
and/or 2 solidification came next --
3 A Uh-huh.
4 Q And then you also release it to 1:h,e REUT7 5 A Yeah.
6 Q I guess that's one of NRC's big concerns, is 7 the fact that that water also contained other -- contained 8 gamma-emitting nuclides and what care and provisions were 9 taken to make sure that you weren't just processing it as i
10 Tritiated water but also looking at it as water that l
. 11 contained gamma-emitting nuclides.
12 A Uh-huh.
13 -Q Kind of summing up this whole thing, what can C u you .ay about that as far as yo r --
15 A As far as I am concerned, we've measured to a 16 Good degree -- that is, our samples were taken assiduously 17 and analyzed with good equipment and always to the Tech spec 18 requirements. And, if we found detectable isotopes, are 19 always added to the base of information, always accounted l
20 for. We tried to run a good program.
l 21 Q &nd, if I understand you right, if your dose 22 calculations indicated that you were beyond the limits that ,
23 would allow you to release it and still be within the Technical specification Appendix I, the Technical 24 implemented Appendix I, 10 CFR 50, 25 Specification that I ,
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l
53 1 Appendix I, then you sent it back to the systes?
2 A If it looked as though it would add to the 3 inventory released in such a way that we would come -- we 4 had some moving targets through the quarters of the years, f 5 the period. If it looked as though it was going to approach 6 some of those moving targets, we'd recommend' sending it back 7 for processing, yes.
8 Q But eventually, that didn't really solve your 9 problem. You would send it back knowing that, sooner or 10 later, it's going to - - those molecules are going to come
. 11 right back out again.
12 A Well, Tritium was no dose problem, you see.
13 Q Yes.
14 A It was the other isotopeer Amal, yeah,* mar _:5uej 2 - J=
15 remember,2 it did get to the point-Wre the cesi==
16 were so low in those tanks that you had a real question 17 whether you benefit by sending it back to the, plant, that it 18 would actually be able to -- that the plant equipment would 19 be able ts reduce the content.
We were down to the 10-6, 10-7 concentrations 20 21 already. Can the plant equipment actually improve on that?
22 And, probably not. There's a real question there about how 23 these specifications, the dose resulting from very, very low 24
. concentrations, activity, could be met or not. ;
25 Q What was the management decision that was made i ,
a e
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. 54 i 1
1 when you did have it at those low levels that you mentioned, l 2 minus six, minus seven? What was the decision -- sending it r- 'J back, and'actually you are not going to get any cleaning up
- -- + process, to just go ahead and release it?
5 A Mell, as I said, if it met our cr'iteria of not 6 exceeding the Appendix I dose-projected target levels, we'd 7 release it.
8 Q So, conceivably, there could be a period when 9 -- you looked at that back on the whole year right? So, if 10 you are releasing -- or if you want to release something, 11 that 10-8 or -7, and it was towards the end of the year and 12 you looked back and that alght be actually a lower amount 13 than what you had previously sent back --
14 A Ch, yeah --
15 Q Do you see what I am getting at?
16 A I see what you are -
17 Q By releasing that, you would exceed the -- in 18 the limit, you would send it back, even though it was lower 19 than amounts which could have been released earlier because 20 there wasn't a factor into --
21 A Yes.
22 Q Mas that what happeneds or could that have 23 happened?
That's possible that it could happen in that 24 A 25 way. But, more realistically, what would have happened is
( I 9
60 o"
1 that our releases were conservative toward the front of the 2 year. In other words, our targeted limits on exposure were 3 always higher than our actual exposure calculations; okay?
4 So we didn't release as much as we could have in the first 5 Portions of the year.
6 Then, toward the later portion of the year, 7 you'd run into this little -- you've gained some, so you 8 have a little more ability to release toward t.5e end of the 9 year...
10 Q And who made those kind of - those calls?
11 A ch, it was - I don't know; we tried to set up '
12 those procedures, as I said, on allocation of the exposures 13 throughout the year for dose calculation purposes.
14 And, at just about the time I left, it'was --
15 I don't know whether that procedure actually got 16 implemented, as I saw it last, or not; but it was attempting 17 to set a window of concentrations that could be released in 18 a fixed period of time.
19 Q Was any SNUD official, annager or supervisor, 20 given any indication that they want you to furnish a summary 21 of this interview today?
22 & Yeah.
23 Q Who was that?
A That was the lawyer I spoke to.
24 25 Q One of the --
( .
4
. 56 6
1 A Corporate lawyer.
2 Q Nhat suas his name?
3 A Did I talk to Dave? Yeah, I think I did --
4 Dave, Dave Kaplan. ,
5 Q Eow long has he been with SMUD anyway?
6 A Since SNUD was originated, probably.
7 Q Eis name goes back to --
8 A 1944, '46 --
9 Q Into the '40s?
10 A Yes.
. 11 4 With SMUD7 12 A Yes.
13 Q so be's an elderly gentleman?
b 14 A yeah, right.
15 Q I have never met him.
16 Nr. Miller, have I or any other NRC 17 representative here threatened you in aart manner, or offered l
18 you any rewards in return for this statement?
19 A I wish you had.
20 4 Say yee or no.
21 A No.
22 Q Eave you given --
A - even get. mileage cut of this one.
23 Eave you given this statement freely- and 24 Q 25 voluntarily?
I ,
t.
57' e' ,
1 A Yes.
2 Q Did Mr. Esplan's request for a s===ary of this 3 interview affect, in any way, the way in which you responded 4 to these questions? ,
5 A No, not at all.
6 Q Zs there anything further you would care to 7 add for the record at this time?
8 A No, I guess not.
g NR NEEKS: Okay. yhank you very much.
10 - (Whereupon, at 3:24 p.m., the interview was
. 11 concluded.)
12 13 14 15 16 17 18 19 20 21 22 23 24 25 o
___._.u__ _ _ _ _.-_-_m_m_ _ _ - _ - _ - _ _ _ _ . . _ _ _ _ - - - -
W Thic is to certify that tho attachcd prccccdinga baforo tho s
UNITED STATES NUCIZAR REGULATORY COMMISSION in tho mattOr of:
E OF PROCEEDING: INVESTIGATIVE INTERVIEW (CLOSED)
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- DOCKET NO.: NONE
- PIACE: Rancho Cordova, California. ,
DATE: 2f March 1987 waro held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory c-4ssiod.
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(Sicrt).f h I 4- -
I M b d DETERS Officia Rape ter
. Reporter's Affiliation Jim Higgins and Associates 1 ;
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