ML20072K577
| ML20072K577 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/07/1991 |
| From: | Mosbaugh A AFFILIATION NOT ASSIGNED |
| To: | Uric B NRC |
| Shared Package | |
| ML17229B299 | List: |
| References | |
| 2.206, NUDOCS 9408300179 | |
| Download: ML20072K577 (31) | |
Text
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ONWN W g h & Af TD Et OW y, j preAuCN DA) gi 3 9 / [ A V C U~C 7 A , &
- sd(' i u-N -,A, To: The United States Nuclear Reaulatory Commission (attention Bruno Uric. Alleantions Coordinator)
From! Allen L. Mosbauch
()
b
} c;[E MT j GEORGIA POWER /SONOPCO RESPONSE TO 2.206 PETITION JL N 0 7 1991 IS LIES. SMOKE. AND MIRRORS
. Georgia Power /SONOPCO's response to the many issues in the 2.206 petition is false, evasive, off the mark, and in many cases tries to " hide behind the NRC's skirt" or tries to involve and implicate the NRC to justify it's actions. Georgia Power /SONOPCO refuses to explain the l issues " head on" and accept or admit guilt and i responsibility where appropriate. From the point of view presented in the response, every issue is without merit and ;
Georgia Power /SONOPCO can do no wrong. l GPC/SONOPCO fails to make the technical and factual arguments required to support their response and instead the response is filled with fancy legal footwork with wording which states the obvious or the trivial and then tries to make a point with it.
The response also tries its best to blame the Petioners for the problems or imply that the Petitioners " extrapolated well beyond their personal knowledge" or "were not aware" or are " simply wrong". Well, such is not the case. In most every case the knowledge of the petitioner greatly I exceeds that of the response and because of this, the j response is challenged below. i l
Below are the Issues from the 2.206 petition, a common sense and plain language summary of the GPC/SONOPCO response, followed by appropriate questions and comment left unexplained by the Georgia Power /SONOPCO's response.
Section III.3 Diesel Generator Air Quality GPC/SONOPCO --------- Mr. Mosbaugh's letter (putting Response Summary us on notice of diesel air quality s is dated 4-10-90, after the problem')
date of the COAR on 4-9-90, so that proves that we couldn't have known (thru any other channel) about Diesel air quality problems before we sent in the COAR.
His memo does not say that air quality was bad the day we sent the NRC the COAR anyway.
OHB(L_4_ _ .
9408300179 940815 PDR ADOCK 05000424 G ,
Mr Mosbaugh is focused on " historic air quality problems and he doesn't really know about all the technical considerations of the engineers.
Finally we think the NRC agrees there is no problem here and they are more aware of the air quality than
- Mr. Mosbaugh who has only dated information.
The GPC/SONOPCO response is evasive and tries to hid behind the NRC.
GPC seems to admit the historic problems cited by Mr.
Mosbaugh. Certainly anyone familiar with instrument and pneumatic control air quality knows that yesterdays
' " historic air quality and moisture problems" cause " todays" corrosion, particulate, and operability problems especially in pneumatic control systems, such as Vogtle's, that have extremely small orifices in the fluidics devices as small as
.006 to .028 inch orifices.
Mr Mosbaugh's knowledge and information is more extensive than GPC states as evidenced by the following transcript of a conversation on 4-11-90 from tape recordings originals of which are in the NRC's possession:
Bockhold--We flapped around with the fact that we got a you know, we got a, on the 29th or so we got a crummy reading and no one knew about it till Milt Hunt picked it up.
, Mosbauch--Georce. we had a bad readino today. 80 F on 2A diesel.
Bockhold--Ok, the 2A diesel I think has-- we're working on a problem. Isn't that right.
Stokes ---They had left the dryers off, I think, following the PM both dryers the other day.
Horton -- Haven't we had any good readings?
Bockhold--Not on 2A.
Kochery---2A was high. They are trying to drain down the tank and--
Bockhold- I can double check with operations but I think we should be bleeding that tank down.
Kochery-- Cotty's going to do that today.
Bockhold--OK. When I heard about it and I heard about it.
I cuess vesterday or so. may be the day before vesterday. actually I heard about it iust before the meetino with the NRC. He mentioned the nossibility and thev finally took the readinos and I cot the information iust before they finally took the readinos and I think it was 60 F at that ooint. and I think I told Skin or someone in coerations to start the bleed --
feed and bleed on the tank.
EXHIBIT E PAGE/ 4 0 F_ @ PAG $S)
Clearly the above conversation shows that Bockhold knew of several unsatisfactory air quality readings before the !
COAR was issued to the NRC on 4-9-90. The COAR was issued J' later in the day after the verbal presentation made by Bockhold himself. Bockhold assissed in drafting the COAR.
l' In addition, GPC fails to reveal in their response that (contrary to GPC's extremely narrow (the day of) interpretation of the COAR air quality statement in their Petition response); on 4-9-90, the day the COAR was sent and on other days in or about that period, the air quality was bad (60 F dewpoint). The unacceptably high dew points were caused by operator error (failing to return the dryers to service after the PM) the same kind of maintenance and operations causes that had left the dryers out of service so many times before as evidenced in Mr Mosbaugh's letter to Bockhold of 4-10-90.
The dew point exceeded the dew point of 50 F attested to as acceptance criteria by Mr. Hairston in response to a Generic Letter.
GPC/SONOPCO must exclain why thev knowinalv made the false statement on diesel air cuality in the COAR.
CPC/SONOPCO must exclain why they continued to have a chronic condition of coor maintenance and dryers out of service in this critien1 air system.
It is also interesting to note from the transcript that neither Bockhold nor the engineers mention faulty instrumentation as being the cause of the unsatisfactorv air quality on the Mary day the COAR was _sioned out to the NBC.
Faulty instrumentation is what the COAR blamed the initial reports of high dew points on.
- Diesel Generator Starts:
- GPC's response is so fictitious and *
- materially false that it is also *
- covered by a separate detailed *
- allegation.
- GPC/SONOPCO --------- The site gave us bad information. We Response Summary had no idea it was wrong till Allen Mosbaugh told us on 4-30-90. Mr.
Hairston didn't participate in the phone call anyway so how co g Q PME /f0FN PAGE@
I l
have known. l The NRC was on site in large numbers and there were lots of discussions so its " ludicrous" we would have hid anything.
We wrote all those drafts as part of our effort to " improve the accuracy of the transmittal letter". It took l from 4-30-90 till 8-30-90 to correct )
our false statements because counting the starts was so hard.
We can't " divine" the design changes that we had to make to the diesel l and the petitioners didn't provide any articulated facts that we knew that the CALCON switches were unreliable so their allegations are j all without merit.
With respect to the CALCON switches specifically: ,
1 i
GPC states in their response at II.E, page 10: ;
" Fourth. the cetitioners' allecation that the reliability of "the comoonents" was known to be unreliable for years" is l succorted by no articulated fact."---
"GPC's knowledce of the comoonents' historic reliabilitv. I therefore. has alreadv been considered by the NRC staff.
Further review is not noorocriate on the basis of a bald conclusory alleantion."
! The GPC response is evasive and tries again to hid behind I the NRC. Below is a transcript from tape recordings
! (originals of which are with the NRC) of GPC's formal l critique team convened to assess the Site Area Emergency of l 3-20-90 which gives a candid picture of what the responsible l GPC/Vogtle personnel knew and felt about the CALCON switches on 3-23-90. Despite these opinions and conclusions of the critique team including the I&C supervisor and maintenance superintendent (who had first hand field experience calibrating the CALCON switches at Vogtle) that the switches were unreliable; SONOPCO management intervened and assigned SONOPCO Birmingham personnel to prove the switches reliable and keep the diesel operable. Ultimately this attempt would also fail as even after SONOPCO and Wyle. Labs
" proved" the switches reliable and revised again the calibration procedures, the switches continued to be unreliable. The Diesels continued to trip and have similar problems as those that caused the Site / Area Emergency and GPC/SONOPCO was forced by events to make the design change to bypass the CALCON Jacket Water Temperature Switches on the diesels.
EXHBIL__7_._.
PAGEf4' 0F # # Pfa f(S) 1 I
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I Speakers are Holmes (critique leader), Briney (I&C supervisor), Mosbaugh, (Asst GM Plant Support)
Kochery (engineering supervisor),and Coursey (mechanical Maintenance Superintendent)
Briney---These are the worst temperature switches you ever seen in your life. Thev're funk.
I don't know if whether we need to advertism that RE DQ1, but if you ever looked at the calibration process for these temperature switches you'd say "lio.E 1h2 hell San ER DM11his on somethina like a diesel" Kochery--These CALCON switches have a lot of part 21's on them,you know.
I later:
Holmes---Typically when you go out and recalibrate them do they always require recalibration?
4 Briney---Always require recalibration or replacement.
Holms ---Because they are off.
Mosbaugh-Do you always use this tapping procedure?
Briney---Since the RER came back in 88 , I think we have, we did, we used that tapping procedure.
Prior to that, no, we did not because the vendor )
did not give us that information. I Hosbaugh-In what direction? I Briney---I say to hell with them because they are such l Junk!
and later:
Holmes----But the next time you go back and try to calibrate these things, essentially every time, they require recalibration.
. Briney----Especially on Jacket Water. i Especially on Jacket water.
and later:
Holmes--- So we 've just been living with it.
Briney--- Well we can get'them calibrated according to the vendors methodology. Whether they're reliable after that I don't know.
Holmes--- I think that based on the fact that they have failed after they have been calibrated several times, after we go back to recalibrate them we have to recalibrate them or replace; They're never Sat. Then I think we have a problem.
and finally: ;2.
EXHENT ,.
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' Coursey--If they're CALCON, CALCON you know it's going to be off anyway.
I Briney --Chances are. Yea.
1 Coursey--What he's saying, he's saying again is what he's j got to calibrate out there is a piece of carbaae j and you know there all going to blow!
As can be seen, the petitioners have more than a " bald faced conclusory allegation, indeed they have the " articulated" ;
I comments of the responsible Vogtle Instrument and controls i
! and maintenance staff as well as the Critique Team leader to l
- base their allegation on.
GPC/SONOPCO must exclain why the above convernations about I the CALCON nwitchen are not indicative of a condition "known
- to be unreliable for years" that involves a " Maintenance l j Related Caune" for the failure of the diesel
- system safety function "when actually called uoon to work" 1 that led to Voatle's Site Area Fearaoney.
GPC/SONOPCO must exclain why the information discunned in the above Critious and the valued ooinions of the IRC suoervisor. the maintenance nuoerintendent and the Site / Aran l Emeroency Critinue leader were not conveyed to the NRC an J
- j. "Sionificant Information identified by a licensee".
i GPC/SONOPCO must exclain why the CALCON switchen which j later had to be ramnved from the Dianel control loaic were' I i not oromotiv reoortad to the NRC an a 10CFR21 mince the above conversation shown that GPC had identified l l
2 i
a defect in thin basic enanonent which could fand did1 lead to a substantial safety innue (both diesel trains and both
?'
reactor units had the name defect 1. Since other licenseen j had these tvon and manufacture of switchen in safety related anolications. this information was sinnificant to the
! Nuclear industrv.
2
) Section III.5 t Load sequencers and i Tech. Spec.
3.0.3
- GPC/SONOPCO 3 Response Summary -----
Assuming that Tech. Spec. 3.0.3 applies to the sequencer, we have
- one hour to get ready and 6 additional hours to shutdown the plant. We only have to notify the NRC one hour after we begin to
} shut down.
The NRC has reviewed this and_said OHMT 2.
PAGE /8 0F 5 # Ff E (S)
d i
) our practices were only a weakness so the allegation is without merit.
i GPC is again evasive. GPC will not even state head on that Tech Spec 3.0.3 applies to the sequencers. GPC hides 4 behind the NRC once again and uses the OSI review as proof of compliance.
. GPC must address the followina-
! State that the Tech Specs apply.
State specifically which Tech Specs apply and which are most limiting (especially auxiliary
! feedwater channels) 4 Identify each interval the sequencers were out i
of service or otherwise inoperable..
]
Show the Tech Spec actions taken or should have been taken in each case.
j Show the NRC notifications made or should l have been made in each case.
! Explain why senior licensed persennel did not i understand the Tech Spec and functional safety ramifications of a sequencer out of service
- (especially with respect to its impact I on auxiliary feedwater). '
Explain why the training in this area was i
! inadequate. I j Explain why even after engineering personnel l 4
identified the errors to operations no prompt actions were taken. 1 Explain the actions taken by Tom Green after 3
the lengthy meeting on 6-8-90 with the system i engineers who raised the. concern.
Explain why corrective actions were not taken timely by GPC management after the issue was brought up by the system engineers.
'Section III.6a Willful violation of Tech. Specs.
Dilution. valves i GPC/SONOPCO i Response Summary-------- The petitioners allegation was already under NRC review, the company got a Tech. Spec. change
, approved by the NRC, and the
- allegation has already been adequately addressed by the company so their allegation is without merit.
gag E.
PAGE /70Ff6 PAGE(S)
This dilution valves allegation casts serious doubts on the actions of, the trustworthiness of and the commitment to safety of senior SRO licensed Vogtle management personnel.
This can not be dismissed as not " constituting a substantial safety issue" or one not appropriate to the relief requested by the petitioners since those personnel still hold the same Vogtle management positions.
The statement that the allecations of willful violation of Tech. Soecs. "are without merit" is at best oresumotive on Georcia Powers cart and ultimately will be found to be false.
Section III.6b Dilution valves j Repeat event l
GPC/SONOPCO Response Summary ---- The NRC only gave us a level 4 violation on this historic violation and that's a far cry from the willful violation alleged so the allegation is without merit.
We went and put a locking device on the valve anyway.
Again GPC has missed the point in their response. After being informed of the violation by the NRC the GPC Manager of Technical Support had to argue with the General Manager to get him to comply with the Tech Spec. The General Manager
- failed to take the "immediate action" required by Tech Specs. and stalled for 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. Since immediate action was knowingly not taken by the General Manager he therefore willfully violated the Tech Spec. Eventually the Technical Manager prevailed and the valve was secured. Locking the small valve was certainly not difficult, expensive or time consuming.
GPC/SONOPCO must exclain why the General Manaaer as well as the Assistant General Mannaer Ooerations with full knowledae of the reouirements and uoon the strona recommendation of the Technical Manaaer willfully violated Technical Snecifications by not takina immediate action as reauired by technical soecifications.
Section III.6c Shutdown Margin GPC/SONOPCO Response Summary ------ GPC admits that they made a calculation error and didn't EXHIBIT __A PAGE 26 0F M PAGE(S)
write a DC but that's all.
4 GPC personnel, Bockhold and Green, can't remember their discussions of
, the significance of the near miss.
Green can't remember saying he did not want to make a big deal over the event because "it would split the organization apart".
GPC says no violations of NRC regulations occurred and the
. company took corrective actions to prevent reoccurrence.
i What never happened because no DC was written and no Critique investigation was ever performed, was to look at all the other times the operations shifts made calculational errors due to their lack of understanding of shutdown margin calculations and procedures. Without this GPC cannot say ,
that "Un violations of BBC reculations occurred" from these '
errors. To the contrary, senior operations department consultants indicated to Allen Mosbaugh that they were aware of other events where similar errors in shutdown margin calculations were made.
GPC also fails to address the training inadequacies that allowed the mistakes by the operations shifts.
SECTION III.6 d Taking LER's i GPC/SONOPCO Response Summary ----- Since the NRC had so many people on site on 3-22-90 we certainly wouldn't have said that at that time. We don't know what the petitioners are talking about and we believe they are being intentionally vague.
The OSI identified a statement that was similar to taking LERs but there's no significance to that since it was said to a supervisor.
The alleged conversation occurred, as hard as it is for GPC to admit, on 3-22-90 and as transcribed below:
Speaking are Carter (the OSOS) and Cash (operations Superintendent) to about 20 shift personnel at the turnover and work coordination meeting.
Cash ---We have a lot of work to do.
Carter----It can be done as long as you can take the LER's EXHIBIT E PAGE E / OF 5Of(S(S)
- ~ . _ - _ . .-. - - . . . - . _ ._ _- - - _ _ _ _
r i
l l This statement in front of the 20 or so subordinates of f
Carter (OSOS)' to whom the Shif t supervisors, reactor operators, plant operators as well as all the other l I
department support staff report is, in the words of GPC,
" incredible". i SECTION III.6 e Coghainment Isolation Valves N - M ode Change (5 to 6) Violation
\ RHR Pump inoperability 4
GPC/SONOPCO Response Summary ------- We'didn't conceal anything. We reported these events to the NRC except the RHR event because it didn't occur. We explained that to the OSI and Westinghouse said we were right too.
Perhaps the petitioners wording in the petition was insufficient to state the kind of " concealment" alleged.
Certainly after the OSI both the NRC and GPC clearly know that what was alleaed concealed, was that the Tech Spec violations were made "knowinoiv". They are examples of "taking LER's" to "get a lot of work done".
Nonetheless GPC uses this legal loophole to evade answering for the seriousness of the issue.
Secti'on III.7 Safeguards Documents !
_____________________ 1 Concealment of Problems AND ,
Failure to Report GPC/SONOPCO Response Summary----- We can't figure out what events the Petitioners are talking about but we have reported several problems.
Corporate said they weren't reportable anyway but to please the Security Manager we reported them so he "was not prevented from reporting" as alleged.
Specifically GPC/SONOPCO's response at II.A page 3, last sentence of that section states:
"Notwithstandina these differina coinions. g PAGE 22 0F 5'# Pt/f(S)
the events were renorted the events were not concealed.
and the Security Manacer was not orevented from recortino ,
them."
This is false. Reporting of loss or compromise (by improper handling or control) of safeguards documents that could "significantly assist" in an "act of radiological sabotage" is required under NRC regulation 10CFR73.71 to be reported to the NRC operations center within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the time of discovery. NUREG 1304 further defines " discovery" and
" reasonable suspicion" to clarify that a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> notification is required when there "is some logical or factual basis" to believe that significant safeguards documents were lost or compomised.
The security manager was prevented from reporting (Red Phoning) the event on 7-23-90 until 16:13 when he had indeed determined that it was reportable at approximately 10:30 and as such violated the reporting requirements b; not placing the call by 11: 30 on 7-23-90. His determination of improper control of significant safeguards informaticin at 10:30 is documented by tape recordings originals of which are in the possession of the NRC, GPC/SONOPCO must exclain why thev intentionally orevented the Vootle Security Manacer from comolvina with NRC reculations and renortino within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the event he deemed r_e.DDraable at 10:30.
Equally as disturbing is the fact that on 7-19-90 Allen Mosbaugh who was the most knowledgeable individual at Vogtle on NRC security regulations and " safeguards information" requirements (having managed those areas since 1986) put Tom Green, Bill Shipman, and Paul Rushton on notice on 7-19-90 that a Red Phone notification was required for j the loss of control of "significant safeguards" documents '
in Birmingham. They were the responsible management authorities for the event with Tom Green having line authority over security. They took no action and ignored Mr.
Mosbaugh's no'tice. They countered by offering the excuse that Vogtle was under a gracs period granted at the 5-22-90 enforcement conference.
Mr. Mosbaugh who had attended the 5-22-90 enforcement conference, stated that no such grace period on Red Phoning was discussed or granted at the enforcement conference.
Still they took no action.
Shipman and Rushton stated th&t the engineer, Amy Streetman, in Birmingham who had notified the site of the safeguards problem was " fairly junior and inexperienced" and therefore not knowledgeable of the problems. Interestingly enough this is the same engineer GPC/SONOPCO credits with questioning the Security Managers judgment about the significance of the safeguards documents in their response.
S H BIT 8 PAGE 23 0F M Pt E (S)
9 GPC states:
"The licensino enaineer cuestioned this conclusion and advised the Security Manaaer to discuss the matter with his mannaement." ;
l Actually what the licensing engineer said was " Don't call l the NRC on this , I'm over here in SCS and there is a i problem here" and then "you have to call Shipman or Bailey before you call the NRC." ;
Since neither Shipman or Bailey was in the Security Managers !
line Management, one wonders what GPC means. Its fairly I clear what the licensing engineer meant, " Don't call the !
NRC." '
The above is documented by tape recordings originals of which are in the possession of the NRC.
f GPC/SONOPCO must exclain why thev intentionally violated NRC i reculations for recortino safeauards events after they had
! been informed of a renortable event by a Vootle Mannaer who was an authority on security reaulations. They must exclain whx,thav did not recort the event within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> on 7-19-90.
False Statement at Enforcement Conference and concealment of problems.
'GPC/SONOPCO l l
Response Summary------ Mr. McCoy identified locations of two safeguards containers in Birminghom. He forgot a third l location but then corrected himself.
He also fo~rgot about a fourth location which was later found to have safeguards documents but did not have any on or before 5-22-90. Mr.
Mosbaugh must have been listening in on a conversation on 8-29-90 when we were talking about that and he is simply wrong.
l
.GPC/SONOPCO's response really misses the mark here and goes off on a tangent explaining an irrelevant statement made by McCoy. This must be in an attempt to evade the real issue, the one stated in the petition:
"Moreover the SONOPCO Vice President made false statements about the status of safeauards material in Birminaham.
f Alabama."
PAGE 24 op 10 egg
The allegation concern is " status" not the " locations" of the safeguards documents.
GPC/SONOPCO must exclain why McCov stated in the Enforcement Conference that:
"We have reviewed the controls in corocrate-- in Birminaham and safecuard documents there are all controlled by document control under a sound orocram."
when in fact that was not true. The Birmingham controls were less than sound as evidenced by problems reported in the Red Phone notification on 7-23-90, the LER 90-03S, the additional problems admitted in GPC's response to Notice of violation 90-11 as well as security reports 4243-90 and 4159-90, all of which describe the problems of safeguards document controls in Birmingham.
These problems were under Mr. McCoys area of responsibility and control, problems that occurred before the enforcement conference, problems that had even been discovered, recognized and investigated before the enforcement conference such as the open and unattended SCS safe event which was well known to Bill Ramsey SCS Manager of Vogtle Engineering.
GPC/SONOPCO must exclain why Bill Ramsey a hiah level Mannaer of Enaineerina in SCS for Voctle who was thorouahly familiar with the unattended safeauards safe incident of Nov. 1989 in Birminaham did not assure that it was recorted to security at the site and to the NRC as recuired.
As stated in the Petition, McCoy's assurances on 5-22-90 that the controls in the Birmingham corporate offices "were sound" and therefore the safeguards problem was confined to Vogtle site and to"the one significant event, "the Prestifillipo safe", materially affected Abg NRC's action and the amount of the c1v11 cenalty emoosed.
On another phone call on or about the period 7-23 to 7-30 the licensing engineer who was continuing to investigate the multitude of safeguards problems in Birmingham stated "It's still unraveling and it's real bad." In a subsequent call in that period with the site on the Birmingham safeguards problems, the SONOPCO Licensing Manager stated " Potential breakdown? It's not potential."
GPC/SONOPCO must also exclain why the lack of safeauards controls in SONOPCO Birminaham and the conditions at the desian aaencies in Birminoham. Gaithesburo. Los Anaeles. and Atlanta are not indicative of a Proarammatic breakdown of safeauards controls.
E{[
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GPC/SONOPCO must exclain the breakdown of controls at the
- above locations in relationshin to their affect on the other licensed facilities. Hatch and Farlev.
l l GPC/SONOPCO must evolain all this instead of "missina the j mark" in their renconse.
i
SUMMARY
l
! GPC/SONOPCO characterizes the " safeguards" events as
" historic" and fails to address the issue of McCoys j false statement. The most important issue here is not.
i " historic". It is the decentive and untrustworthy nature of-j GPC/SONOPCO management which contrary to the GPC response i does " rise to the level of substantial safety issues"
- as discussed in 10 CFR2. Appendix C, item V. B&C .
I J Section-III.8
- " FAVA" Radwaste system l GPC/SONOPCO------- The FAVA system was initially installed i Response Summary in 1988 and removed from service after i QA found significant problems with it meeting quality requirements. FAVA
{ was then reinstalled under a 2
satisfactory. safety evaluation and has i
now been replaced with a new system j that meets all requirements. Applicable
- accident analysis'for the ARB was
- covered in initial licensing and the SER supplements 3, 4, & 8.
George Bockhold did not intimidate the -
j PRB even though'one member said so. !
- Bockhold later addressed the PRS and
} ,
stressed the importance of their ,
! independence in. voting. The PRB l
- vote didn't matter anyway because
! they are just an advisor to the 1 General Manager.
i
- GPC/SONOPCO state specifically in their response ,
3 page 1 item II fifth paragraph: '
1 j "The basis on which this innue can be dinnosed of is the fact that the tamnorary FAVA system was taken out of service at Voatle in Auaust. 1990."----- "Therefore no health and safety issues exist."
GPC can not dispose of this issue so easily. The manager 4 of Chemistry and Health Physics Ron LeGrand (who holds a SRO l license) was informed prior to the initial installation of FAVA, that the system did not meet NRC regulations, nd g j
! PAGE24 0F/B PAGE(!
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l authorized the installation anyway. l GPC/SONOPCO must exclain why Mr. Learand knowinalv and willfully violated NRC reaulations.
l GPC/SONOPCO state specifically on page 2, item III : l "When the system was returned to service in 1990.
113 safety evaluations gang adeounte and its use was recommended by the PRB."
i This is a false statement. The safety evaluations were
, inadequate as exhaustively detailed by technical arguments l presented in the numerous quality concerns filed by Mr. I Mosbaugh. The inadequacy was also admitted by the SONOPCO manager of engineering and licensing, Paul Rushton to Allen 1 Mosbaugh in March of 1990. Because of the significant x inadequacies, the safety evaluations were redone several 4
times and even as late as August 1990 the safety evaluation was so inadequate that it mistakenly assumed that radioactive leakage from the ARB would flow directly into the Savannah River from the " Plant discharge" instead of in the opposite direction thru storm drains leading to Beaver i '
Dam Creek.
Also during the OSI, GPC admitted in discussions and its white paper that the safety. evaluations were defective. NRC resident Ron Aiello stated to Allen Mosbaugh in August 1990 that GPC's then current safety evaluation was inadequate.
1 GPC/SDNOPCO must exclain why Pat Mcdonald han made another false statement.
I GPC/SONCPCO specifically state on item II, page 2 ,second paragraph:
"An a result. the General Mannaar addressed all PRR i members and reinforced the imoortance of their indeoendence in votina" Actually what occurred was Bockhold requested that only full members (no alternates) attend a PRB meeting. Bockhold briefly ccvered the issue of intimidation with the board, emphasized independence, stated that he had done nothing wrong complying with Vogtle procedures on handling non-unaminous votes, and then stated that he planned to make no changes with his intervention in board meetings.
He then stated that "I know none of you are intimidated by my presence, if.any of your alternates have a problem with that then you need to get a new alternate".
With that Bockhold disposed of the intimidation issue and if the members of Board were not intimidated before, they certainly were thereafter.
E PAGE E70F/# fAGSS)
j 1
GPC/SONOPCO must exclain why they did not characterize the
- General Manaaer's arroaant and intimidation address to the Board in its true licht.
j GPC/SONOPCO must exnlain why the inadeauncies in the desian.
4 orocurement. construction. materials. installation and in l the contractor services to modify and reinstall FAVA. were not recorted under 10CFR21 to the NRC. This is sianificant as the FAVA comonny has sucolied eauioment and services to other NRC licensed facilities includina Plant Hatch.
i i Section III. 9
- Taking Risks and 1
not Investigating events.
1 i GPC/SONOPCO l Response Summary ------ The petitioners allegation 4 is broad and gives no facts.
. Recently the NRC said we were doing l well in this area so the allegation 4
is without merit.
, GPC says there are no facts or examples, well perhaps not in section III.9 but this is a statement of deduction and conclusion from all the examples III.1 thru III.S. Again GPC/SONOPCO has chosen to duck the issue and hide behind the recent NRC reports. Perhaps GPC has imoroved in recent ,
months (under the pressure of these issues that is not l j surprising), but this allegation is to the previous period, l i i j With respect to GPC/SONOPCO's statements that:
q " Mr. Mosbauch thouah stands alone in claimino retaliation i
as a result of diveraent views on a technical matter"
) one need only look at recent section 210 cases filed j against GPC/SONOPCO to cast that statement a lie.
i
- The record shows that Yonkers /Fuscoe raised nearly I identical technical security issues (improper control of ;
i~~ safeguards information) as Mosbaugh in their Section 210 i case against GPC for which they claimed retaliation. Their i claim was substantiated by the US DOL Wage and Hour j investigation. So clearly Mosbaugh does not stand alone.
Moreover in the 1990 Southern Electric System PPP survey (in which employees can answer confidentially) the flavor of fear from retaliation comes out loud and clear.
i WE l PAGEf80F8 PAGM ,
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! Question 51---Fmolovees Arm afraid in voice AD coinion
! that manaaement does not want is hear, j l
Vogtle Specific response: Of 334 responses 73% of the 4 people agreed with the l' statement as follows:
30% strongly agreed l 22% agreed 16% slightly agreed 13% slightly disagreed 10% disagreed 4% strongly disagreed l
l Question 65--- 1 Am afraid in voice AD coinion that m1 l mannaement does Dat want to hear. i Vogtle Specific response: Of 331 responses 52% of people agreed with the statement as follows:
16% strongly agreed 16% agreed 20% slightly agreed 12% slightly disagreed 25% disagreed 11% strongly disagreed GPC/SONOPCO must exclain why they continue to make false statements about Mr. Mosbauch.
l
SUMMARY
- From the 2.206 Petition and the allegations by '
this petitioner against GPC/SONOPCO's response to our petition are identified the following numbers of examples of extremely serious allegations:
14 False Statements made by GPC/SONOPCO Officers in writing to the NRC including statements willfully false.
5 Willful Violations of Technical l Specifications 3 Examples of Failure to properly and timely report safeguards events to the ,
NRC as required by regulations EXHIBIT E
, PAGE f_f_ 0F N P W l
. ~ . - . . - - _
w a 6 %e, :.-s.. 4 e ,.ua w,-a. .-
h i
, 2 Examples of failure to properly and
{ timely report Part 21 defects to the NRC i
1 Willful Violations of other NRC
- requirements.
1
] 1 Example of withholding Significant j Information not associated with the i above false statements i
How many violations does it take of this kind to i conclude that this licensee has not " achieved the meticulous i attention to detail and the high staridard of compliance which the NRC expects" and is a " serious case whore.the j
licensee's actions in not correcting or providing
- information raises questions about its commitment to safety.
and its fundamental trustworthiness" ?
i In cases such as these the full measure of NRC enforcement 2
sanctions and orders as discussed in 10CFR2-Appendix C items j V and VI should be applied to modify, suspend or revoke
- GPC/SONOPCO's license.
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EXHST 4 t
PAGE 88 OF 88 PAS $S) i
. . . _ -. , . . , _ _ m _ , . _ . .
- PLEASE NOTE ******
The level of deta11 contained in this concern will allow the Vogtle and SONOPCO management to conclusively identify the author.Because of the high level of the personnel involved and the seriousness of these concerns, I request that you do not reveal the text of th1s letter or the fact that this information was obtained thru an allegation, to Vogtle or SONOPCO personnel.I fear that retal1tation including the possibility of phys 1 cal harm could come to me or my family.I am concerned because of recent articles surrounding Gulf Power,a Southern Co.
Subsidiary,and the Jake Horton case as well as my observations of Georgia Power,SONOPCO, and Vogtle management for many years.
- PLEASE NOTE ******
The Georgia Power Company has made two material falso statements in written correspondence submitted to the NRC regarding Plant Vogtle's emergency diesel generator's i control and starting air supplies and diesel generator l testing.The statements are contained in correspondence ELV-01516 subm1tted on 4-9-90 in response to the NRC'S Confirmation of Action letter.The purpose of ELV-01516 was to explain Georgia Power's review,1nvestigation and corrective actions taken w1th respect to the events involved l in the S1te-Area Emergency of 3-20-90 and to request the NRC l to l1ft it's hold on criticallity and resumption of power operations on Vogtle Unit 1.
In ELV-01516 page 3, item 4 it states"GPC has reviewed air quality of the D/G air system including dewpoint control and has concluded that air quality is satisfactory.In1tlal reports of higher than expected dew points were later attributed to faulty instrumentation.This was confirmed by internal inspection of one air receiver on Apr11 6,1990 which showed no indication of corrosion and daily air receiver blowdowns with no significant water discharge.'
The above paragraph 1s materially false by omission and/
or commission in that 1t presents a conclusion (that air Quality 1s satisfactory) that cannot be concluded from objective evidence and knowldege of Vogtle's Diesel generator air systems. This 1ncludes the dewpoint measurments taken,the procedures used, the maintenance history of the DG 1A dryers, the operational allignments.the air Quality acceptance criteria recuirments of the Vogtle diesel generators from the Vogtle FSAR and Vogtle's response to Generic Letter 88-14 in correspondence ELV-00197 page 3.
The following substantiates a less than satisfactory BHBli 8 PAGE 2 or /(pAge(s)
h1 story of air Quality:
1.Vogtle's response to Generic Letter 88-14 presents j'
the " maximum dewpoint acceptance criteria for the VEGP diesel air start system ---as 50 F at system pressure " ( 225 to 250 psig).
- 2. Prior to 6-28-89 dewpoints were not regularly checked a with no measurments taken in 1987 and only one taken in 1988.The 1988 value 1s theoretically
, impossible for the refrigeration type dryers installed (less than 32 F).The 2 measurments taken
- in 1989 prior to 6-28-89 were also theoretically j imposs1ble(less than 32 F).
! 3.Since the equipment used to measure dewpoints measures at atmospheric pressure and the criterla 1s at system pressure, a calculation or correction must be performed to adjust to reference pressure.
The maintenance procedures used, do not include instructions for this and there are no calculational records or data that show how it was done .Therefore the accuracy of even post 6-28-89 data is not certa 1n.
4.The maintenance procedure in use is contrary to the dewpoint measurment equipment vendors recomendations in that it Lses a pressure regulator which the vendor says holda moisture and gives false readings.
- 5. Readings obtained on 3-9-90 and 3-31-90 exceeded
- acceptance criterla and were as high as 80 F.This was explained as " faulty equ1oment" but after that, on 4-6-90, valid dewpoint readings of 84 F were 1 measured for Unit 1 DG air dryer K01 and 83 F for K02 as documented on DC 1-90-186.Haintenance work order 2-9000964 documents air Quality problems on the i Unit 2A d1esel where nearly every dewpoint measurment exceeded acceptance criteria when measured l
with several kinds of instruments. Values as high as 95 F were measured on 4-9-90 thru 4-11-90.DC's were
- not weltten for these out of spec. conditions.
Maintenance work order 2-9001136 documents continuing dewpoint problems on the 2A diesel.
6.The air dryers for the Unit 1A diesel generator have been out of service for excessive periods of time. Maintenance work order 1-88-02991 was oper' from 5-10-88 to 5-2-89 to repair both the kO1 and 1 K02 dryers. Refrigeration compressors as well as i
condensing fans have been broken.When preparing to perform the UV testing of the diesels for the IIT, air dryers were found out of service.
. 7.Despite having the air dryers out of service the assoc 1ated compressors have remained in service.
8.The diesel generator ut1112es a pneumatic air control 4
logic system which has extremely small or1fices as small as 6 thousandths of an inch.This air control system takes its air from the starting air system.
EXHBir #
PAGE_5 OF kPAGE(S.
- 9. Qualitative and gross observations at a few points in the sys*.em,one air receiver tank and a filter, l 1s not sufficient to confirm satisfactory air avality and internal cleanliness of nundreds of air lines after years of inadequate air dryer maintenance and dewpoint testing.
- 10. Air in tne diesel building is not air conditio".ed ;
and therefore tne air compressors utilize amb.ent '
air which in the Central Savanna P.ver Area is typ1cally extremely warm and rumid ,
much of the year.Wi tho'.t dryers in service. water in the system .s bound to be a problem.
11.For per1oe.s of operation without dryers In !
service (which have been extensive) the air in the rece1ver would be saturateo and have a dewpoint of that of room temperature. Receiver l
blowdown would not alter those conditions. For summer _ j at Vogtle that would be 90 -100 F.Us1ng psychometric l charts a orop of approx 1mately 30 F in dewpoint I would occuer upon pressure reduction to the I control a r pressure of 80 psig.This would l produce a dewpoint of 60 to 70 F wnich exceeds the acceptance criteria.This value is supprisingly l close to the valid measurments recently taken W1th the dryers out of serv 1ce. Clearly air Quality should be expected to be unsatisfactory J during periods when the dryers have been out of '
service. I Considering items 1 thru 11, the only conclusions that can be drawn is that the air quality for the Vogtle Unit 1 Diesels is unknown and indeterminant for the first 2 1/2 years of post license operation with known lengthly periods of dryers out of serv 1ce during wh1ch times a1r quality probably was unsatisfactory against the acceptance cr1teria stated in response to Generic Letter 88-14.For the most recent period since 6-28-89 air quality was measured and generally met acceptance criteria except wnen dryers were out of service ( the extent of which is cificult to reconstruct) at which times air quality was probably again unsatisfactory.At the time that correspondence ELV-01516 was signed by Georgia Power, 2 of 4 diesels nad air cuality problems with high dewpoints (outside acceptance cr1teria) ranging from 64 to 84F.
Dewpoints that high could easily result in water in the air lines as room temperatures cycle (when cool night or early morning air is drawn into the room).The cutside air dampers locations in the Diesel rooms make this a dest 1nct posibility.The presence of any. water in the, lines will lead to corrosion and Darticulate matter formation which could be carried to the pneumatic logic boards, sensor valves and other pneumat1c components and could easily cause malfunctions.
EXHEIT F PAGE 4 _OF /4 PAGE(S)
i In ELV-01516 page 3 item 9 It states'31nce March 20, 1995.
GPC has perforned numerous sensor calibrations (includtr.g i Jacket water temperature). extensive logic testing.special oneumatic leaf testing, and multipie engine starts and runs under var 1ous cond1tions.S1nce Marcr 20, the 1A DG has been started 18 times,and the 18 CG nas been started 19 l times.No fa11ures or problems have C: curred during any o#
these starts. In addition ,a6 under.oltage start test !
without air roll was conducted on Ap-11 6,1990 and the l 1A D/G started and loaded properly.
The above paragraph is materially false by omission andfor commission because according to Vogtle control ~ room logs and procedure 14980 data sheets the 18 DG had been started 29 timestsee NOTE
- below> since March 20,1990.It expertenced 8 failures or problems during these starts and one proolem j with control air pressure between starts as follows: '
Start Date T1me Comment l 1 3-21-90 21:49 Diesel failled to start ,
2 3-21-90 21: 56 Diesel failled to start 1 3 3-21-90. 22:02 4 3-21-90 22:59 Diesel had to be stopoed due to j low luce oil pressure and h1 cil filter DP 5 3-21-90 23:14 Diesel had to be manually stopped because of high fuel oil DP 6 3-22-90 00:17 7 3-22-90 i04: 28 8 3-22-90 07:14 9 # 3-22-90 08:54 10 8 3-22-90 09:21 11 # 3-22-90 09:50 12 # 3-22-90 10:09 13 3-22-90 11: 06 Diesel tripped H1 Lube 011 Temo 14 3-23-90 05:09 Got 8 onase 127 Undervoltage relay f;ag on start j 15 3-23-90 17:30 01esel tripped to Jacket Water '
Press.JTurbo Lube 011 Press.
16 3-23-30 17: 44 17 3-24-90 00: 48 Got generator ground relay 164 dropout on start. Received DG1B Trio H1 Jacket water alarm.0G should nave tr1pped but d1dn't.
l 1B 3-27-90 16: 49
! 19 3-27-90 19:09 20
- 3-27-90 19:51 21
- 3-27-90 19:57 B M BIT E PAGE EOF /kPAGE(S) l l
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22 = 3-27-90 20:04 23 3-27-90 22:20 Diesel 18 undervoltage Test 24 3-26-90 04: 03 Diesel TS Surveillance 14960 l 25 3-28-90 13:50 26 3-28-90 13:56 3-28-90 15:27 Diesel 18 Declared Operacle ,
4-03-90 05: 15 Got Maint. Ic;kout alarm due to I low control air pressure (41 psil I 27 4-04-90 16:32 l 28 4-05-90 00:30 Functional test of destga change OCP 133 l 29 4-05-90 03:07 Diesel TS Surveillance 14980 l
Date of ELV-01516 4-9-90 30 4-10-90 01:37 Surueillance 14980
~
31 4-12-90 10:20 Surveillance 14980 32 4-16-90 00:00 Surveillance 14980 l 33 4-18-90 07:59 Surveillance 14980 l 34 4-19-90 03: 14 D1esel inadvertently emergency l started wh11e performing l Surveillance OSP-14619-1 i I
NOTE: # Denotes start not logged in control log but data sheet exists per procedure 14980-1
- Denotes start logged in control log but not documented by data sheet per procedure 14980-1 From the above it is clear that there ha.e been' numerous trips and problems w1th the 18 diesel since 3-20-90, many of wh1cb are associated with features oeing investigated to determine the cause of tne 1A diesel failure, such as CALCCN switches and control air.In addition, even if you disregard the trips and problems,there were only 14 successful starts on 18 Diesel s1n e the time of the last trip and only 3 starts since the time of the.last problem and the date of l ELV-01516.
It is clear that the data do not support the claims made in l the letter of" No failures or problems daring any of these l Starts' fcr this diesel.It is particularly disturbing that l Georgia Power has misled the NRC with tt 1s informat1cn, information presented te convince the NRO of the reliability of Vogtle's diesel generators and te obtain permission to resume power operations.
I Since the cause for f ailure of the Vogtle diesel generator 1A and the subsequent testing ano reliable operation of both 1A and 18 diesels is particularly s1gnificant to the Site-Area Emergency, the Confirmation of Action Letter and associated regulatory action and since ELV-01516 was s1gned by the Senior Vice Pres 1 cent SONOP00, tnese Material False Statements are very disturbing.
M_ ..
PAGEL 6 OF /f PAGES)
i u
Deta111ed information and source occuments including D1esel star t and f al iure data used to corr.Dile - the abc.e concern have been crcsided to Al Chaffee of the NRC IIT l team.
i l
4
- ==== PLEASE NOTE *****
The level cf detail contained in this con:ern will allow the Vogtle and SONOPCO management i to conclusively identify the author.Because of the high level of the personnel involvea and the seriousness of these concerns, I reauest that you i do not reveal the text of this letter cr the fact 4
that this information was obtained thru an allegation, to Vogtle or SONOPCO personnel.I fear that retalitation in:1uding tne poss-b111ty of physical harm could come ]
to me or my family.I am concerned because of recent articles surrounding Gulf Power,a Southern Co.
Subsidiary.and the Jake Horton case as well as my observations of Georgia Power,SONOPCO, and Vogtle ;
management for many years, j
- =** PLEASE NOTE ***** i l
EXHRT 8 PAGE kOF /4 PAGE(Sj
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l l Georgia power has made an adaltional Material false statement in written correspondence tc the NRC in Licensee l Event Report 90-006 submitted 4-19-90.It 1s sin 11ar to the Material false statement made on 4-09-90 and invcives the claims of successful starts without problems on.Vog-le's i Diesel generators that failed during the Site-Area Emergenc) '
of 3-20-90.
l On page 5 under item D lt states " Numerous sensor l calibrations (1ncluding jacket water temperatures),special !
l oneumatic leak testing,and multiple engine starts and runs l were performed under various conditions.After the 3-20-90 event,the control systems of both engines have been l subjected to a comprehensive test program.Subsecuent to this i
test program, DG1A and DG1B have been started at least 18 times each and no failures or problems have occurred during I any of these starts.In addition, an undervoltage start test 1 without air roll was conducted on 4-6-90 and DG1A started and loaded properly.."
The above statement regarding the number of successful starts without" failures or problems" subsequent to the control systems comprehens1ve test program is materiall) l l
false by ommission or commission.The 18 diesel control logic !
testing was completec on 3-27-90 just prior.to performing 1 the first undervoltage test at 22:04 CST on 3-27-90 ana .
prior to declaring the diesel operable at 15:27 CS* on 2 '
l 90. Completion of this testing, is the earllestl point in time !
l that a claim of completing a comprehensive control systems I test program coulc be made. Subsequent to that-date and time i until 4-19-90, DG1B has been started only 11 times.
The 1A diesel control logic testing was completed on 3-31-90 l just prior to performing the first undervoltage test at l
22:53 CST on 3-31-90 and prior to declaring the diesel operable at 11:54 CST on 4-01-90. Completion of this testing I
is the earliest point in time that a claim of compie:1ng a comprehensive control systems test program could be made.Subsecuent to that date and time until 4-19-90, CG1A has also been started only 11 times.
This material false statement is similar to the one made by Georgia power on 4-9-90 in correspondence ELV-01C16 and again falsely overstates the extent of reliable starting experience w1th DG1B and DG1A. Conc.ern was raised by p' ant staff on 4-18-90 with the SONOPCO Licensing Engineer,the SONOPCO Licensing Manager,the SONOPCO General Manager Plant 1 Support,the Vogtie General Ms. nager,the SONOPCO V1ce President Vogtie,and the SONOPCO Senior Vice President Nuclear as to the accuracy of the Diesel start ir. formation I and the fact that tnere had bean " failure and problems BHBIT 5 PAGR 9_OF Y P E R Sj 1
4 l
4 3-'
prior to submittal of the LER.SONOPCC was pressec for time ,
and issued the LER without adequate verification ano 1r. the )
face of concerns for the accuracy of the information raised i I
by the site.The issue of the accuracy of corresponcence ELV-i 01516 including spec 1f1c failure information was raised by 1
site personnel on the phone call with the above personnel at j the same time.
l On 4-30-90 the Vogtle General Manager was providea a mem. ,
j with start data on the DG1B .cerrived from control icgs, shift supervisor loss and source diesel operating loss.that i clearly showed that previous statements made tc the NRC were I
false.He took no immediate action and ask for the information to be validated by operations and engineering.The information was validated on 5-1-90 and
! found. correct.It was presented again tc the General Manager on 5-2-90.and in this presentatlor, it was stated that statements on both diesels 1A and 1B were incorrect in the i LER and that the letter ELV-01516 was wrong as well.Still he took no action to promptly inform the NRC of the false statement and suggested that a revision to the LER De 4
prepared. He also suggested that the letter ELV-01516 be corrected by including a correction in tne a.
letter being prepared for submittal to the NRC on 5-15-30.
1 The General Manager did not follow up on the progress of these revision actions or set any time taole for j completion as he normally would on 1mportant issues.
A revision was made to the LER and approved by the PRB on 5-8-90.On 5-10-90 the PRB reviewed the 5-15-90 letter (actually submitted on May 14)to the NRC.It had nothing that l addressed or corrected the material false statement as previously suggested by the General Manager.SONOPCO anc the General Manager were heavily involved in writing , editing-and specifying the contents of the May 15 letter.The PRB f made a comment on the fact that the letter did not address the material false statement and assigned the General Manager an action item to resolve that.
After the General manager saw the action item his secretar) 2 came to the ORB secretary's office and said "Doesn't NSAC have anything better to do than assign the General Manager action items".
1 Later on 5-24-90 the general Manager signed the action 1 tem off as complete ano attached a note instruting the Technical Support Manager to use the LER cover letter to' correct the other incorrect document.SONOPCO most always drafts the cover letters, not the Technical Manager.
, On 5-11-90 the PRB met again with the General Manager to approve the " final' version of the May 15 letter to be sent to the Senior Vice President SONOPCC for signature.Again nc correction had been made and the previous mater 1a1 false statement was not addressed.The " final' version was approved.The individual that had ra1 sed the issue of the material false statements had been removed from the PRB by a E
PAGE N OF M PAGSS)
memo from the General Manager (NOTS-00382) datec 5-10-90 and effective 5-11-90.
By May 15 the revised LER was with SONOPCO.No action occurred to submitt the LER to the NRC until about the first week in June when again site personnel began asking SONOPCO about what was taking so long to submit the correction.SONOPCO licensing personnel told site oersonnel that the Senior V1ce Presicent Nuclear planned to s1gn the revision on June 8 (the day of the IIT presentation to the Commission on the Vogtle Site-Area emergency). 1 On June 8,11 and 12 an extrordinary number of meetings anc telephone calls occurred over the Diesel start information.
Quality assurance was directed oy the Senior Vice Pres-dert to auait all of the Diesel start logs.When tnis was completed ,no errors were found.in the information that had been presented to the General Manager over a month before on 4-30-90.W1th this done tne Senior V1ce President ash fcr a ,
" complete revision" and updating of the LER.This was done
- l and a rev_ised LER was PRB approved by 6-22-90,(3nly J cf S l
'"pages neeaed any rewrite on the " complete revision" A g complete revision had originally not been planec until C l
months after the event. V l The " complete" revision LER switches the counting and h )
reoorting of Diesel generator starts and f ailures to ' val-d" g l starts and failures per Reg Guide 1.108 By doing so l correlation between the previous LER can not be made witnout 1 detailed and specific data on each-start.While the original l LER was being drafted it was suggested that we might want to sq use ' valid starts and failures' but that method was discounted because it was recognized that we haa very few g valid tests.:f tne original LER were stated in terms of valid starts we could only say "Subsecuent to this test k program the DG 1A anc DG 1B have had 6 valid starts without problems or failures k
On 6-25-90 and 6-29-90 a total of 6 cover letters to be g sent in with the LER revision were originated anc proposed 4R oy SONOPOO.Each 1s different and attempts to exclain the Material False statement 1n a different manner:
DRAFT 07:51 6-28-90 This draft says that all tests were counted but only valid failures were considered in reaching a conclusion there were no problems or failures.
06: 55 6-26-90 This draft says that all tests were counted regaraless of wnether they j were val 1d or not.
07:55 6-29-90 This draft says tnat the COA response letter used the words 'Sunsecuent to Y E.,
PAGE_ // OF M PE(S)
I l
i the event" and that tne LER l inadvertently used the worcs b "Subsecuent to the test program" but should have been consistent
)
l with the COA response letter and l the verbal presentation in Atlanta. i l
11:42 6-29-90 This araft says the LER statement didn't consider failures and croolems )
i associated with troubleshooting anc !
. restarting the Diesel and should have been " Subsequent to the event" wnich l 1s consistent w1th the COA response l
and the verbal presentation, j i
12:06 6-29-90 This draft says that "If the !
comprehens1ve test program comoletec )
with the first Surveillance 14980-1 -
then there were 10 successful starts I on DG1A and 12 on DG1B as of 4-19-90. l 13: 11 6-29-90 This draft says that "If the comprehensive test program completed with the first Surveillance 14980-1 then there were 10 successful starts on DG1A and 12 on DG18.It also says that test program starts were included in the originai count and that was due to poor record keeping cractices and no definition of the end of the test program.
These explainations are all untrue and are being concocted after the fact without regard to how anc why the errors were a tually made.In short these are lies and an atempt to coverup the careless personnel errors made by tne coerations superintendent and General Manager which originated in the verbal presentation.were repeated in tne 20A response letter and were carelessly restated in the LER.
l A looh at the Diesel generators star 1ng and failure history -
after the LER was written on 4-18-90 provides a technical as ,
well as a objective view of the rel1 ability of the-diesels which 1s at the heart of the Material False Statement. -l 1
Diesel Generator 1B I DATE TIME RESULT 04-19-90 03: 14 Diesel was inacvertently started \(
W $. _.
PAGE /2 0F /f PG(8,
due to personnel error in performing Surveillance 14619-1 04-19-90 09:55 Successful start 04-29-90 09:09 Successful start -
05-23-90 12:26 Diesel Tripped after start 05-23-90 13:10 Diesel tripped after start 05-23-90 14:12 Successful start manual trip 05-23-90 14:45 Successful start manual trip 05-23-90 21:18 Diesel tripped after start on low turbo lube oil pressure 05-23-90 21:38 Diesel tripped after start on low turbo lube oil pressure 05-23-90 21:57 Diesel tripped after start on low turbo lube oil pressure 05-23-90 22:55 Diesel tr1pped after start on H1 i Jacket water temperature '
05-23-90 23:37 Diesel tripped after start on Hi Jacket water temperature 05-24-90 12:29 Successful start 05-24-90 12: 42 Successful start 05-24-90 12:53 Successful start 05-24-90 13:10 Successful start 05-24-90 15:19 Successful start g 05-24-90 15:30 Successful start 05-24-90 19:16 Successful start 05-26-90 20:28 Successful start 06-01-90 11:45 Successful start Clearly this diesel generator continued to experience an k excessive rate of trips and failures most of which were the same kihd of failure that led to tne station blackout at m1o-loop that occurred on 3-20-90. Clearly this diesel was not reliable as the COA response letter and the LER tried to convey.As further proof of the unreliability Georgia Power had to initiate a design change to remove scme of the unreliable components from the control log 1c after experiencing all the additional failures.
Considering the evidence:
The words are false in counting the starts.
They overstate the reliability of the diesel.
They were used by NRC to make decisions "Significant to the Regulatory Process" (To allow Restart)
Concern was raised about the accuracy of the start data before submittal of LER.
SONOPCO personnell recognized that the previous (CCA) startements were false before suom1ttal of the LER.
Factual data was presented d1souting the data after submittal and stating that information proviced to NRC was I incorrect.
Substantial delays occurred in starting to correct tne LER.
Additional delays were introduced after beginning correction k/
(OA audit).
BMBli 8 PAGE_ YOF QPAGE(S
i 4
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h l Revisions were delayed until after critical meetings Wit, 1
NRC (6-08-90 IIT presentation to Commissioners)
Additional unplanned delays were introduceo (comclete
- revision) after QA aud1t substaintated inaccuracy cla1m.
I Multiplicity of revision letters (also false) to explain the j mistake, g j Submittal to AEOD by LER revision to correct multiple non- A i LER errors.
Performance of the Diesel itself proves the unreliability 4 j and the falseness of the statements given to the NRO.
Above actions did not proceed without repeated and h
continuing expression of concern from the plant employee j 4
who exposed the Material False statement . I i 1
. one can only conclude that Georgia Power dio inceed make l
! Material False Statements in written correspondence to the i I NRC due to as a minimum careless disregara anc willfuly
! Conspired to delay and cover up the disclosure of those b7 false statements.
4 1 j l
l l
1 1
MEMOF /RPA34s>
. g. ...w..
i e 101 MAAIETTA STREET.CD.
i I ATLANTA.CE0 mite 3egr3 g,.... 11AR 2 31930 1 -
) I
! Docket No. 50-424 j License No. NPF-68
?
Georgia Power Company i ATTN: Mr. W. G. Hairston, !!!
j 5enior Vice president -
3 Nuclear Operations 1
- p. 0. Box 1295
! Sirmingham, AL 35201 i
- Gentlemen:
1
SUBJECT:
CONFIRMATION 0F ACTION LETTER
- On March 20, 1990, a site Area Emergency was declared due to a loss of offsite power with a concurrent loss of onsite emergency diesel generator capability.
i Because of the potential significance of this incident to public health and l safety, the NRC's Executive Director for Operations has formed an Incident Investigation Team (IIT) to investigate the circumstances surrounding the incident. This IIT will replace the Aupented Inspection Team (AIT) presently i
d on site in an orderly transfer of team authority. Unit 1 was in cold shutdown I
at the time of the incident for refueling. Unit 2 tripped from 100 percent
- ' pomer.
i ,
i This letter confirms the conversation on March 23,1990, betueen R. P. Mcdonald !
and myself related to this incident. With regard to the matters discussed, me '
j understand that you have agreed to cooperate with the IIT and you have taken or l
} will promptly take the following actions necessary to support this investigation:
- 1. Unit I will not be taken critical until the Regional Administrator is satisfied that appropriate corrective action has been taken and the 1
plant can safely return to operation.
] 2. Equipment involved in the incident may be quarantined by the IIT.
personnel access to areas and equipment subject to this quarantine will be minimized, consistent with plant safety.
I The licensee is responsible for quarantined equipment and can take action involving this equipment it deems necessary to: (1) achieve or maintain safe plant conditions, (2) prevent further equipment degradation, or
- (3) test or inspect as required by the plant's Technical Specifications.
I e
d PAGE / OF_ 2- P#R(S) l gofomjpo
Georgia Power CampaQy 2 ggg 2 3 M r
( To the maximum degree possible, these actions should be coordinated with the !!T team leader in advance or notification made as soon as practical. '
The 117 team leader may authorize a release, in whole or in part, of those areas or equipment subject to the quarantine upon a determination that the IIT has received sufficient information concerning the areas or equipment !
requested to be released, or to permit necessary troubleshooting of the equipment, required testing or maintenance to be performed.
- 3. 1 All records or damaged equipment will be preserved intact that may be l related to the event and any surrounding circumstances that could assist in understanding the event. i Records shall be retained for at least two years following the event regulation or license condition. whether or not required to be retained'by
- 4. The licensee will make available to the IIT for questioning such individuals employed by the Itcensee or its consultants and contractors with knowledge of the event or its causes as the IIT deems necessary for its investigation.
5.
The licensee will ensure that any investigation to be conducted by the licensee or a third party will not interfere with the IIT investigation.
The licensee will advise the IIT of any investigation to be conducted by the Itcensee or a third party. Reports of such investigation will be promptly provided to the IIT.
Issuance of this confirmatory action letter does not preclude the issuance of
[ an good for order cause. formalizing your commitments. The above commitments may be relaxed please call me immediately.
If your understanding differs from that set forth above, Sincerely.
ps Stewart D. Ebneter
, Regional Administrator CAL-50-424/90-CI cc: !!T Leader NRC Office Directors Regional Administrators (cc cont'd - See page 3) l 1
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