ML20077D097

Georgians Against Nuclear Energy Resubmittal of 910422 Filing to Include Signature of Representative.* Date on NRC Staff Motion Should Be Corrected to 910426.W/Svc List

ML20077D097
Person / Time
Site:	Vogtle
Issue date:	05/07/1991
From:	Carroll G GEORGIANS AGAINST NUCLEAR ENERGY
To:	Atomic Safety and Licensing Board Panel
References
CON-#291-11760 91-617-03-OLA, 91-617-3-OLA, OLA, NUDOCS 9105240195
Download: ML20077D097 (5)

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'91 MY14 lZ20 Unit.ed States of America Nuclear Regulatory Commission Atomic Safety & Licensing Board U

In the Matter of:

Docket # $0-424-OLA

1. 50-425-OLA ASLDP #90-617-03-OLA GEORGIANS AGAINST NUCLEAR ENERG't RESUBMITTAL GF APRIL 22, 1991 FILING TO INCLUDE SIGNATURE CF REPRESENTATIVE In response to the NRC staf f motion to strike GANE's April 22, 1991, filing for being improperly submitted without a signatura, we have enclosed that document (copies for all the parties) with the needed signature.

We request that since the incomplete filing is now corrected, that the filing will be considered for its content since the original filing was made in a tirely f ashion and in good f aith that it was complete, true and corrwet to the best of my knowledge.

GANE is an all-volunteer organization and has had volunteer legal counsel in past proceedings at the NRC. At this time, GANE does not hav.

legal counsel to assist us. We are happy to comply with all pertinent regulations and our overriding concern is to be able to assist the NF and Georgia Power in ensuring safety at Nuclear Plant Vogtle.

While we are clarifying the record, GANE requests that the date on the NRC staff motion be corrected from April 26, 1990 to read April 26, 1991.

Respectfully submitted,

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Gle.ftn Carroll for GANE

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United States of America Nuclear Regulatory Commission Atomic Safety & Licensing Board I

In the Fatter ofi Docket # %0-424-OLA

1. $0 42$-OLA ASLBP #90-61'-03-OLA i

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GEORGIANS AGAINST NUCLEAR ENERGY Response to Georgia Power Statement filed March 22, 1991 i

Georgians Agtinst Nuclear Energy (GANE) is glad for the

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opportunity-to comment on the safety concerns raised by the failure of the high jacket water temperature switch of the emergency diesel generator to operate properly at Nuclear Plant ~Vogtle. We comment

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favorably on the persistence of the parties in addressing this important i

safety issue, GANE's concerns have increased rather than lessened as this f

inquiry has proceeded. Every.round of affidavits exposes more mistakes i

and negligence on the part of Georgia Power.

f Georgia. Power's agreenent alth GANE that the rate of temperature rise to the Diesel Jacket Water upon loss of !keloor Service Cooling Water (NSCW)' is substantially greater than 2*F/ minute (10*F/ minute by

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Jtheir calculations)-is a positive: step but the work they show is flawed and inconsistent, and still incorrect.

GANE's -previous estimates of a rate of rise as high as 5

32*F/ minute were calculated based on Vogtle procedures (VEGP Procedure l

13145-1, Rev. 25, 5 2.2.6 (at p. 4 of 46)]-and data for " normal-

- i operation" that were provided by Georgia Power. The original Georgia Power data is not-consistent with the referenced FSAR Table and displays that their current procedures are incorrect. Georgia Power should i

correct these procedures.,

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2 FSAR Table 9.2.1-1 shows the appropriate heat load for the Diesel Jacket Water Cooling and states 17,1x106 BTU /hr. at 1000kw. If an extrapolation is performed using the Lisenby assumption of a linear relationship method then 13.5x106 BTU/ r at 5517 kw is the heat load.

h This is contradictory with Lisenby's affidavit which affirms 10.9x106 UTU / r' h

Georgia Power's calculations are not conservative. They cannot assume that the high jacket water temperature will always be at the low end (14 5') of a normal operating range of 145'-170*. Georgia Power calculations are also non-conservative in that the diesel generator nay be loaded up to its full rating of 7000kw during a Loss of off Site Power event, once the sequencer times out (FSAR Table 8.3.1-2). Another non-conservative indulgence exhibited _in Georgia Power's calculations is the use of a room temperature density of water of 62.41b/gg3 instead of the density of water at actual Jacket Water Temperatuaes which are as high as 200*r. At this temperature water density lo approximately 601b/

3 f t. _The mass of water to cool the diesel is overestimated.

Correcting for the above non-conservatisms and using Georgia Power's methods of calculation one arrives at a rate of rise of 15'r/ minute for loss of all jacket water cooling. By both the NRC staf f's and Georgia Power's testimony, it takes up to three minutes for an operator to respond.to the Diesel Generator Control Room.

In the case of a failure in the cooling system resulting in complete loss of cooling, the alarm is received at 190' and the operator arrives three minutes and 45' (235') later. Using Georgia Power's 10'r/ minute figure the temperature af ter three minutes would be-220'F.

As_regards a Control Room Fire the initial rate of rise would be 10'r/ minute -and the operator would arrive three minutes later with the temperature in excess of 210'r.

Thus, even Georgia Power's calculations prove that an _ operator cannot perform the function of the original trip design at 200'r as required by their operating license.-

The f oregoing concents address the most important aspects of switch function compared to operator function. There art other notable displays of either misunderstandings or denial of very real accident scenarios. For instance, Lisenby claimo on page 9 of his affidavit that

'if damage were to occur to the diesel generator that the other train

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3 would be available, This was not the case on March 20, 1990.

Similarly, strike-outs and insertions of unexplained different figures on page 2 of attachment 3 in the most recent filing by Georgia Fower imply a poor scientific attitude.

The discussion of calibration drift is proven in Lewis Ward's affidavit to be a danger that Georgia Power has not resolved. Also, in a position that has no basis in logic or common sense, Kenneth Stokes describes routine testing of the diesel generator with the switch they seek to bypass in place. lie claims that this satisfies regulations, but we see a failure to address safety or prove that this in a safo procedure.

In conclusion, we have shown that an operator cannot get to the emergency diesel generator in time to trip the generator if it is overheating. We hope that the Atomic Saf9ty & Licensing Doard and the Nuclear Regulatory Commission will rule in a way that mandates Georgia Power's immediate resolution of the matter, We of fer the solution of an

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upgrade on the generator from the pneumatic logic, which we believe is the root cause of the switch failure, to an electronic logic. Then, it must be proven that that system works in a uncompromised and safe manner.

t A swift and effective ruling on this currently unsafe condition at Plant Vogtle will help protect the health'and safety of residents of Georgia and South Carolina.

Respectfully submitted,

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/ Glenn Carroll Representative for GANE Dated at Decatur, Georgia i

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April'22, 1991 Signed May 7, 1991 1

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abrC Service Lists i

s Administrative Judge Charles Bechhoefer Nb 21 l

Cha.rman Atomic Safety and Licensing Board

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U.S. Nuclear Regulatory Commission Washington, DC 20555 i

Administrative Judge Emmeth A. Luebke

$500 Friendship Boulevard Apartment 1923N Chevy Chase, MD 20815 l

Administrative Judge James H. Carpenter Atomic Safety and Licensing Board i

U.S. Nuclear Regulatory Commission Washington, DC 20555 Secretary of the Commission i

U.S. Nuclear Regulatory Commission-Washington, DC 20555 c/o: Emile Julian Docketing and Services Branch i

Charles-A. Barth, Esquire Office of the General Counsel U.S. Nuclear Regulatory Commission l

Washington, DC 20555 i

Arthur H. Domby i

Troutman, Sanders, Lockerman & Ashmore 1

Candler Building, Suite 1400 127 Teachtree Street NE i

Atlanta,.GA 30303 I

-Ernest L. Blake, Jr., P.C.

-Shaw, Pittman, Potts and Trowbridge 2300 N Street NW-Washington, DC 20037

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