ML20085N589

Intervenor Exhibit I-MOSBA-3,consisting of Rept Re Employees Potential Safety Issues

ML20085N589
Person / Time
Site:	Vogtle
Issue date:	05/17/1995
From:	AFFILIATION NOT ASSIGNED
To:
References
OLA-3-I-MOSBA-3, NUDOCS 9506300249
Download: ML20085N589 (4)

Text

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(J To: The Nuclear Regulatory Commission persuant to

% JLN -6 P2:33 Employees' Potential Safety Issues OFF. ICE OF SECRETARY On 10-13-88 at approximately 10:30 and agaigDG6Ei#eQ& c6WVICE Plant Vogtle Unit 1 ( operated by the Georgia PodNd4M6Mpany) was willfully and intentionally placed in a condition prohibited by it's Technical Specifications. At the time Unit 1 had just been shut down for a refueling outage and the RCS had been drained to 188'-0"(midloop).

Specifically valves 1-1208-U4-176 and 177 which are required locked closed were opened while the RCS was at midloop, a condition prohibited under Technical Specification ( 3.4.1.4.2 ) .By opening vnives 1-1208-U4-176 and 177 a flow path was created resulting in unborated water flowing from the RMWST into the RCS.

In addition, the above action placed the plant in an unanalyzed condition and constituted an unreviewed safety question since this path (RMWST to the RCS) had not been analyzed for a boron dilution accident by Westinghouse for MODE 5 with reactor coolant loops not filled conditions.

The plant was placed in this condition by the Operations Manager, Skip kitchens, who holds a SRO license. ON at least one of these occasions he personally opened these valves

/,,T because other licensed personnel had refused.

V Valves 1-1208-U4-176 and 177 were opened to add the chemical hydrogen peroxide for chemical cleaning.This had been planned by the outage schedule to occurr prior to reaching midloop and in fact 2 additions were made prior to reaching midloop.Due to coordination problems however, the Operations Manager was faced with the need to add at midloop.In the interest of schedule he decided to order the addition.

On cbout 9-12-89 other plant personnel discovered the reference event and began investigating . The Operations Manager wrote a letter to the General Manager (NOV-00385) explaining his interpretation that an Immediate Action statement can be voluntarily entered and that the plant was not really at midloop during the additions on 10-12-88 and 10-13-88.The latter contention is false based on the Unit 1 Control Log.The former interpretation is contrary to the position taken by NRR of the NRC which has interpreted immediately as "without delay" or "as your next action" and the position taken by the NRC (NUREG\BR-0110, ISSUE NO.87-2, AUGUST 1987) on voluntary entry into Specification 3.0.3.

The issue of voluntary entry into Immediate Action

,S statements was referred to SONOPCO corporate within about

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NUCLEAR REGULATORY COMMISSION fc- 9 29 C44-3 Docket No. T6- 92 5-* - 3 Otticial Exh. No. Ia * ~3 la the matter of G/C eut S!Iff IDENTIFIED Apcant RECENED 7 Intervenor / REJECTED Cont 0 0ff r Contractor DATE O T-i 7 4 E OCier Witness 9tlp la+<J Reporter G.8no l

'xhibit 5 ,pagg } 0g 3 a week .A position (ELE-00919) was issued which stated,

[('N -" voluntary entry into an LCO which expressly prohibits a given condition and requires immediate corrective action should that condition exist,should not be made", but came l short of concluding that it was prohibited. Based on that )

policy, this event has never been reported to the NRC under  !

10CFR50.72 or 10CFR50.73.

In the case at hand, the violation of the LCO goes far beyond the issue of " voluntary entry" and the intrepretation i of "immediately". Valves required locked closed were intentionally opened .Unborated water was then intentionally flowed into the RCS (for the purpose of adding chemicals) diluting the RCS boron concentration .This created the possibility of uncontrolled boron dilution of the filled portion of the Reactor Coolant System and a subsuquent inadvertent criticallity accident,the very condition stated in the bases of Technical Specifications that is to be protected against.Fortunatly the above accident did not occurr, but because no analysis or testing had been done the safety of the plant was placed in the hands of luck.It would have taken only one single failure (such as a wrong size orifice or leaving the valve open too long ) to escalate this event into an accident with serious safety significance. Finally th!F risk was taken in the interest of schedule, without requesting engineering evaluation,without ,

I adequate monitoring and controls,and without contacting the

) NRC for consideration or the advisability of discressionary s/ enforcement.

ON 11-21-89 Georgia Power submitted a change (ELV-01077) to Technical Specifications to allow opening valves 1-1208-U4-176 and 177 at midloop.The stated purpose is to allow for chemical additions at midloop in MODE 5 and MODE 6.

Since Georgia Power has now deemed a change to Technical Specifications necessary for subsequent opening of these valves it has tasitly admitted the violation of Technical Specifications which occurred on 10-13-88.

Despite costing approximately $50,000. to analyze, this previously unanalyzed condition ,no disciplinary l action was ever taken with the Operations Manager for j his caviller approach to the requirments of regulations  ;

and the safe operation of a nuclear power plant. In fact he I was subsuquently promoted to Assistant General Manager.

The details of this event are known to all line management up to and including the Senior Vice President SONOPCO.

This event as well as numerous other events:

Failure to perform adequate PORV surveillance Failure to perform adeTaate Steam Generator blowdown valve servaillance Failure to perform adequate E-bar surveillance f Installation of Microfiltration test unit designed k

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in violation of Reg. Guide 1.140

) [ Failure.to perform adequate shutdown margin calculations Failure to report missing fire penetration seals involving "intrepretation" of regulations and reporting of events has signaled to plant personnel, management's concurrance with this cavilier approach to regulations.

A quick review of recent trends at Plant Vogtle indicates a return to the kind of conditions that existed in early 1987 when the same people were "in charge".Under SONOPCO they have been allowed if not encouraged to return to the operating philosophy of that troubled period.If this is not kept in check and reversed the quality of operations will not improve and there will be a serious event occurr at the plant.

A Concerned Employee O .

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