ML20082C143

Prefiled Testimony of Gr Frederick on DG Reporting Issues.* Related Correspondence

ML20082C143
Person / Time
Site:	Vogtle
Issue date:	04/04/1995
From:	Frederick G GEORGIA POWER CO.
To:
Shared Package
ML20082B958	List: ML20082B955 ML20082C012 ML20082C045 ML20082C092 ML20082C112 ML20082C137 ML20082C143 ML20082C146
References
93-671-OLA-3, OLA-3, NUDOCS 9504060178
Download: ML20082C143 (16)

Text

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, "* p RELATED CORRESPONDENCE DOCKETED USHRC l i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION '95 APR -4 All .07 l BEFORE THE ATOMIC SAFETY AND LICENSING BOEbCT Uvun[!!er"

- [;pf OF

' lC[ rCHET bi' imCH '

In the Matter of  :

Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY, at al.  : 50-425-OLA-3

Re: License Amendment (Vogtle Electric Generating Plant, : (Transfer to Units 1 and 2)  : Southern Nuclear)

ASLBP NO. 93-671-OLA-3 PREFILED TESTIMONY OF GEORGIE R. FREDERICK ON DIESEL GENERATOR REPORTING ISSUES  ;

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I 9504060178 950404 PDR ADOCK 05000424 T - - -

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L 1 TESTIMONY OF GEORGIE FREDERICK 2 Q: PLEASE STATE YOUR FULL NAME.

3 A: My name is Georgie Ray Frederick. I go by " George."

4 Q: WHAT POSITION DID YOU HOLD IN 1990?

5 A: In 1990, I was employed by Georgia Power Company as the On-6- Site Supervisor of Safety ' Audit and Engineering Review 7 ("SAER"). My immediate supervisor was Mark Ajluni, who was 8 the manager of SAER in Georgia Power's Birmingham office. Mr.

9 Ajluni reported to Mr. McCoy in Birmingham.

10 Q: WHAT ARE YOUR PROFESSIONAL QUALIFICATIONS IN THE NUCLEAR 11 INDUSTRY?

12 A: A summary of my qualifications is attached hereto as Exhibit 13 A.

14 Q: WHAT WAS YOUR INVOLVEMENT WITH THE MARCH 20, 1990 SITE AREA 15 EMERGENCY RECOVERY EFFORTS?

16 A: Shortly after the event, I was assigned to be a member of the 17 Event Critique Team. I was specifically assigned to review l I

18 the truck accident in the switch yard, including the l 19 qualifications of the truck driver. I also assisted, 20 generally, in the review of the event with other critique team l

21 members. '

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(i; 1 Q: DID.YOU. PARTICIPATE IN.THE PREPARATION OF AN APRIL 9, 1990

'2 PRESENTATION TO THE NUCLEAR REGULATORY COMMISSION REGION II IN 3 ATLANTA?

4- A: Yes. I did. The team leader of the Event Critique Team, Mr.

5 Ken Holmes, was either on vacation or on naval reserve duty.

6 Mr. George Bockhold requested assistance in developing his 7 presentation to the NRC on the Friday prior to April 9. I 8 recall working with Mr. Jim Roberts in the development of 9 overlays which addressed the Vogtle Emergency Plan and other 10 overlays not related to the diesel generators.

11 Q: WHAT WAS YOUR INVOLVEMENT IN THE ACTUAL APRIL 9 MEETING?

12 A: I attended the April 9, 1990 meeting. NRC person 1 in 13 Washington were also participating by telephone -confe ance.

14 The NRC asked many questions. Once the presentation got 15 started, the flow of the presentation is difficult to remember 16 because there were many open conversations between the NRC and 17 Georgia Power representatives that were not focused on the 18 transparencies.

19 Q: WHAT IMPRESSION DID YOU RECEIVE FROM MR. BOCKHOLD'S 20 PRESENTATION OF DIESEL TESTING INFORMATION?

21 A: I recall having an overall impression at the end of the 22 meeting that (1) the diesels had been demonstrated to start 23 and run successfully, (2) the current calibration of the 24 Calcon switches (sensors) was acceptable, and (3) the switches

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1 installed were currently acceptable so that the reliability of 2 the engine was no longer an issue.

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3 Q: WERE YOU RESPONSIBLE FOR PREPARATION OF THE APRIL 9, 1990 L 4 LETTER FROM GEORGIA POWER TO THE NRC OR THE APRIL 19, 1990 5 LICENSEE EVENT REPORT ("LER")90-006 WHICH ADDRESSED THE SITE 6 AREA EMERGENCY?

7 A: No, not that I recall.

8 Q: WHEN WERE YOU FIRST AWARE THAT THE APRIL 19, 1990 LER 9 ASSOCIATED WITH THE SITE AREA EMERGENCY WAS POTENTIALLY IN 10 ERROR?

11 A: After the April 19 LER was sent, several revisions to the LER 12 were presented to the Plant Review Board ("PRB"). My 13 recollection is that the Board was presented with various 14 lists of starts with start numbers and dates, and several 15 different examples were presented of what the revised LER 16 would say, with different wording for different counts.

17 Q: DO YOU RECALL WHEN A REVISED LER 90-006 WAS FIRST PRESENTED TO 18 THE PRB?

19 A: From reviewing the minutes of the PRB meeting, I know that a .

1 20 list of starts to revise the LER was presented to the PRB on l 21 May 8, 1990. I was concerned about the draft language, that 22 we still hadn't resolved the issue of what " comprehensive test F

l 23 program" meant -- where it started and stopped. I objected to

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x l 1 'the' revised LER draft presented to the PRB. The draft.LER i l

2 apparently said there had been 11 diesel starts " subsequent to j 3 the test program." I thought that the test program, at least-l 4 with respect to diesel generator 1A, would and . with an .!

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. 5 Engineering Test (No.90-016). Without further review, I j U 6. would have agreed that six successful -starts, were made 7- subsequent to the test program, rather than 11. .Han May 8, j 8 1990 Minutes attached to Mr. Aufdenkampe's profiled testimony l

9 as Exhibit-K (GPC Exh. 37). i i

l 10 Q: HOW WAS YOUR LACK OF CONCURRENCE ON MAY 8, 1990 ADDRESSED?

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'll A: A different proposed LER revision was prepared with a '

i 12 different statement about diesel starts.

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l 13 Q: WERE YOU TASKED TO ASSIST IN THE LER REVISION'S PREPARATION?

14 A: Yes, indirectly. About a month after the PRB meeting on May 1 15 8, I was asked to conduct an audit of the diesel count that l 16 had been included in the original, April 19 LER. I was told  :

17 there was an error in-the LER that had been submitted on April -l 18 19. My specific instructions were to determine an accurate-19 and repeatable count; I believe I got my specific instructions.

20 from Mr. Aj1 uni, who had been tasked by Mr. George Hairston. {

l 21 In trying to revise the LER, different people at the plant  ;

i 22 site got different start count numbers and Georgia Power i 23 management directed SAER to find out what the correct count  ;

-24. number was as of April 19. I understood that the revised LER j l

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1 was not going to be signed out until we had finished the audit

.2 and verified the correct start count.

3 Q: WHAT ACTIONS DID THE SAER GROUP UNDERTAKE TO PERFORM . THE 4 AUDIT?

5 A: Mr. Norm Mosely was the lead auditor and together he and I 6 tried to find all the pertinent records related to Unit 1 7 diesel starts. Mr. Mosely collected " start sheets" or ,

l 8 " Completion Sheets" which are to be completed by operators 9 avery time a diesel is started. He also reviewed the Shift 10 Supervisor's Log which is kept in the control room. We were 11 trying to find out what the count number should be, not 12 whether somebody made a mistake or what was the cause of that 13 mistake. As a copy of the audit indicates, we began the audit 14 on June 11 and completed it on June 29, 1990. A copy of the 15 audit report is attached to Mr. McCoy's testimony as Exhibit 16 M (GPC Exh. 15). i 17 Q: WHY DID IT TAKE SO LONG TO COMPLETE THE AUDIT?

18 A: The reason it took so long was that we could not find all the 19 documents we needed to complete the audit. We worked until 20 the last day to try to find all the pertinent records. As 21 documented in the audit, we were looking for multiple 22 documents that would support each other, not just one single 23 source of information. The records in the Plant's vault were 24 not complete and up-to-date. We traced the routing of missing

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l 1 Completion Sheets and even then we did not find them all until

.2 near the end of the audit. hiso during the period of the i 3 audit I was on vacation for one week, although Mr. Mosely 4 continued working'on the audit during that period of time. I 5 expected to be able to finish the audit fairly quickly, but we I 6 experienced problems in finding all of the documents.

7 Q: IN YOUR AUDIT, DID YOU DETERMINE WHAT " COMPREHENSIVE TEST 8 PROGRAM" IN LER 90-006 MEANT?

9 A: No. No one knew the definition. We could not find any place 10 where " subsequent to the test program" had been expressly l

11 defined. No one in Engineering or Technical Support or 12 Operations or management had a specific definition. Although 13 the term " comprehensive test program" had been discussed, the 14 Plant Vogtle staff had not agreed on different versions.

15 Since our task was to come up with an accurate count to 16 complete the audit, we defined " subsequent to the test 17 program" in the audit report.

18 Q: HOW DID YOU DEFINE THE " COMPREHENSIVE TEST PROGRAM 7" 19 A: The audit report, prepared by Mr. Mosely and me, defined the 20 comprehensive test program as being completed when we 21 completed an operability run pursuant to the Plant Vogtle 22 surveillance procedure (No.14980) . Our reasoning was that if 23 a diesel generator was declared operable, it clearly could not

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>1~ be in a test program. The only clear point in. time I could

2. come up with was when we said the diesel was operable.-

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3 Q: DO YOU HAVE A DIFFERENT UNDERSTANDING OF THE ORIGINAL INTENT I 4 OF THE PHRASE " COMPREHENSIVE TEST PROGRAM" TODAY?

5 A: Yes. Subsequent to the audit, during an August, 1990 special 6 NRC inspection, I learned that the original start count for 7 the April 9, 1990 confirmation of action letter response '

8 included tests that were before the operability tests, 9 although they were tests that were conducted after the plant 10 had finished testing the diesel control systems.

11 Q: AS A RESULT OF THE AUDIT, DID YOU COME TO ANY CONCLUSIONS 12 REGARDING THE DIFFERENCES IN THE APRIL 19 LER DIESEL START 13 NUMBERS AND THE DIESEL START NUMBERS DEVELOPED IN THE AUDIT?

14 A: Yes. Based upon our audit report, we inferred that the error 15 in the original LER was a result of two factors: (1) the point 16 in time where the start count began, and (2) the condition of 17 the diesel start records. The diesel generator Start Log 18 maintained by the Engineering Support Department was not up to 19 date on April 19, 1990. The Start Log is compiled from the 20 Completion Sheets. These Sheets are filled out by the t

21 operator when the diesel is started. We determined that it 22 took a significant period of time for the Completion Sheets to 23 reach the Engineering Support Department. Also, operators had 24 not filled out a sheet every time the diesel was started. In

-m 1 addition, the control room logs were not accurate; they_

2: reflected that the diesel was " started and stopped several-

~3 times" without identifying specific starts. This state of

4 documentation made it very difficult for a person to determine 5 the number of successful starts accurately, completely and 6 with precision. Because the control room log entries were not' 7 complete, a person relying on the logs would not have had 8 enough information to know ' whether starts had problems or 9 failures.

10 Q: WHAT WAS YOUR KNOWLEDGE AS TO THE SOURCE OF THE APRIL 19 LER 11 START COUNT DATA DURING YOUR AUDIT?

12 A: My understanding was that the April 19 LER used the April 9 13 presentation numbers. Either during, or prior to, the audit i

14 I knew that Jimmy Paul Cash had prepared that information for I 15 George Bockhold's presentation on April 9. My understanding 16 at the time was that there had not been a separate count made 17 for the LER.

18 Q: WHAT DO YOU BELIEVE IS THE REASON FOR THE ERROR IN THE DIESEL 19 STARTS STATEMENT MADE IN THE APRIL 9 PRESENTATION AND LETTER? I 20 A: I do not think that all the records were accurate enough to l

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21 make the count, and I am not sure that the person who started 22 counting knew where to start his count. The records were in 23 such bad shape that a reasonable person just couldn't 24 accomplish this task. I recognize that since 1990 Georgia

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11 Power'has identified personnel error as also contributing to 2- the errors in these statements.

3 Q: SINCE YOU UNDERSTOOD THAT MR. CASH WAS THE SOURCE OF THE

-4 APRIL 9 START COUNT, DID YOU CONTACT CASH, INTERVIEW HIM AND 5 RECONSTRUCT HIS LIST?

6 A: I did contact Mr. Cash, but I did not reconstruct: his effort.

7 In performing our audit, we did not want to use someone else's 8 review effort. We were generating our own accurate, complete 9 and documented numbers. We did not try to verify or justify 10 someone else's review; that approach would bias the SAER 11 review one way or another. We believed it would be better to 12 go with our own independent number and then sit down and 13 compara our numbers with prior numbers and figure out why they 14 didn't match. The Technical Support group was actually  ;

15 working on the LER revision at the same time we were doing the 16 audit, and we continued to do our review independent of that 17 effort.

18 Q: PLEASE DESCRIBE YOUR INVOLVEMENT IN THE PREPARATION OF THE I 19 COVER LETTER TO THE REVISED LER.

20 A: Although I did not draft the cover letter transmitting the 21 revised LER, I reviewed it during its preparation along with 22 other Plant Vogtle managers. The cover letter was based in l 1

23 part on the SAER audit which was issued the same day. The ,

24 letter explained the differences in start counts between the ,

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1 April 19 LER and the June 29 revised LER as we understood 2 them.

3 Q: WERE YOU AWARE THAT THE OBSERVATIONS STATED IN THE AUDIT 4 REPORT WERE INAPPROPRIATELY BEING USED TO IDENTIFY THE 5 CONTRIBUTORS OR " ROOT CAUSES" TO THE LER'S INACCURACY?

6 A: No. First, I knew from direct observation in PRB meetings 7 that the phrase " comprehensive test program" was subject to 8 different interpretations. The definition proposed on May 8, 9 1990 at the PRB was different than the one that we adopted in 10 the SAER audit report, for example.

11 Second, I personally observed different start numbers 12 being generated in the April through June time frame by 13 different individuals. Therefore, even in early June, 1990, j 14 I felt that the diesel start numbers in the original LER were 15 potentially incorrect because of various problems with the 16 surveillance completion sheets and operators' logs and other l 17 information recorded by Engineering Support. e Se_q e,c,,

18 June 8,1990 PRB Meeting Minutes attached hereto as Exhibit B. I 19 My participation in the audit confirmed my initial belief that 1

20 recordkeeping was a major contributor. Although the SAER l

21 audit was narrow in scope and did not identify a specific 22 cause per A.g, my personal opinion was that recordkeeping 23 practices (i.e., sloppy processing of Completion Sheets and 24 the fact that the Engineering Support Department's Diesel 25 Start Log was not kept updated) led to inaccurate numbers in i

11 the April 19 .LER. These numbers were different than the -

2 audit's' documented, retrievable, defined numbers.

-3. Finally, I did not feel that the conclusions being drawn

-4 by. corporate' office representatives, including Mr. George 5 Hairston,- from the audit were illogical, unsupported or. -

6 inappropriate. Although the audit did not say why an' error 7 had been made, the audit did identify the conditions that i 8 existed when the LER was written. Because of the lack of 9 documentation in one location, I could not conceive how 10 anybody accurately counted starts because nobody-knew where ,

11 all the starts were documented. If the Diesel Start Log had <

been up to date, individuals would not have had to go to the ,

13 Completion Sheets or the control roca logs.

14 Q: WERE YOU AWARE THAT MR. MOSBAUGH BELIEVED THAT THE CORRECT 15- ROOT CAUSE FOR THE DIFFERENCE IN START COUNTS BETWEEN THE f 16 APRIL 19 LER AND - THE JUNE 29, 1990 CORRESPONDENCE WAS 17 PERSONNEL ERROR?

18 A: No, not completely. I understood that Mr. Mosbaugh felt that  !

19 the draft cover letter was not completely true. I.did not 20 know what Mr. ' Mosbaugh was attempting to identify as ' an ,

21 underlying personnel error. I believed that if we did not 22 admit the fact that our recordkeeping practices were not 23 right, we would have been avoiding the truth. I voiced these 24 same views in a conversation on June 29, 1990 that I had with 25 other Plant Vogtle managers which wa s secretly tape recorded 11 -

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i by Mr. Mosbaugh (Tape No. 187). Others in the conversation 2 concurred with my view that documentation historically had l

3- affected verification efforts. A transcript of that 4 conversation, which is attached to Mr. Greene's testimony as 5 Exhibit B-(GPC Exh. 44), reflects that conversation. As the .

6 transcript indicates, Mr. Mosbaugh did not explain the basis 7 of his comments to us. If he had, the result might have been 8 different. Today, I know that Mr. Mosbaugh had developed an j l

9 analysis in June 1990 which indicated that the Unit 'l 10 Superintendent had included problem starts in the 19 11 " successful starts" of the 1B diesel for the April 9 12 presentation. Notwithstanding my various discussions with 13 him, Mr. Mosbaugh never informed me of the April 19 14 performance failures but, rather, made vague statements to the 15 effect that I should talk to Mr. cash and Mr. Bockhold.

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- GPC EXHIBIT 46 l FREDERICK EX. A i

SUMMARY

OF PROFESSIONAL QUALIFICATIONS i GEORGIE R. FREDERICK i i

I entered the Nuclear Navy Program upon graduation from high school in 1961, obtained a degree in electrical engineering with the Navy and was commissioned .

an officer in the Navy in 1968. I held various positions in the Navy Nuclear j Program, until I worked for Admiral Rickover to maintain oversight of the- )

operation of the Surface Nuclear Plant operated by Westinghouse Electric for the Navy in Idaho, a position I held for the period 1975-77; I reported to Mr. Zack .

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'Ihereafter, I served as chief engineer on a nuclear cruiser and then served in the )

Atlantic Fleet on the Operational Reactor Safeguards Utamining Board. The  !

Board reviewed the overall operation and safety of nuclear-powered ships in the j Atlantic fleet, including submarines, aircraft carriers and cruisers. I retired from  !

the Navy as the Chief of Staff, Material Officer for Cruiser Destroyer Group l Eight. The staff was responsible for the nuclear cruisers and forty-th ee other l non-nuclear ships.

l In November of 1984, I was hired by Mr. Paul Rice of Georgia Power and underwent auditor training. I was qualified to ANSI standards. I held several j positions in the Quality Assurance groups at Plant Vogtle until I began SRO j licensing school in the fall of 1990. I received my Senior Reactor Operator  ;

license in 1992 and was the Manager of Maintenance at Plant Vogtle from l January,1992 until January,1995. I am currently a Manager-in-Training assigned to an Operations crew at the Plant.

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. ~~ VEOP PLA T REVIEW BOARD NEETING INkJTES GPC EXHIBIT 47 FREDERICK EX. B MEETING ND. 90-66 DATE 5/4/90 PACE 1 0F 2 F2 TING CONVENED 9:15 AM/PN; MEETING ADJOURNED 10:00 AM/PN

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• VIA TELECON)

TNIS MEETING CHAIRED BY:

() CHAIRMAN (X) VICE CHAIRMAN A. L..Mosbaugh VOTING MEMBERS PRESENT: J. G. Aufdenkampo J E. Swartkwelder H. Handfinger M. W. Horton PRB SECRETARY W. C. Gabbard NON-VOTING NEMBERS PRESENT: G. R. Frederick l

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VOTING ALTERNATES PRESENT: 1 I. A. Kochery FOR R. L. LeGrand  !

FOR I

NON-VOTING ALTERNATES PRESENT:

FOR FOR ,

FOR FOR FOR GUESTS / TECHNICAL ADVISOR 8:

W. K. Smith T. E. Webb T. Y Greene

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PRB ACTION ITEMS OPENED: 90-66-01 PRB ACTION ITEMS CLOSED: None PRB MINUTES APPROVED  : None l

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PRB SECRETARY PRB CHAIRMAN a

cc Nke RESIDENT INSPECTOR (FORM NAME=PRBAGEND)

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1 PRB 90-66 Page 2 of 2 l

PRB MENTING MINUTE 5 CONTINUATION 8E837  !

A. Thw following items were unanimously recommended for  !

approval with comment. No unreviewed safety question i involved.  !

LER 1-90-11 " Manual Reactor Trip Due to Inadvertant closure of Main Feed Regulating Valve". I Sections D & F:(Cause and corrective Actions) - Remove references to labeling and locking device.

NOTE: PRB Action Item 90-66-01 issued to Trip Reduction Committee to re-evaluate Trip Hazards-and Single Point Tripe (Ref. review of LER 1-90-11). Report results to PRB.

LER 1-90-6, Rev. 1 " Loss of Gffsite Power Leeds to site Area Emergency".

Section D (Cause of Event) -

clarify what comprehe.5sive Test Program means.

comment to PRB minutes of 5-8-90 by G. R. Frederickt Do not concur that 11 diesel starts " subsequent to tha test program" as stated in last paragraph of section E, page 6 of 8, for DG1A is accurate. Based on the information presented to the board start #39 completed the program using T-ENG-90-016 which makes 11 an incorrect value. Without further review I would agree 6 successful starts were made starting on 4/6/90 at 2347.

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