ML20086U032

Applicant Exhibit A-73A,consisting of 900613 or 0614 Rept

ML20086U032
Person / Time
Site:	Vogtle
Issue date:	05/23/1995
From:	GEORGIA POWER CO.
To:
References
OLA-3-A-073A, OLA-3-A-73A, NUDOCS 9508030242
Download: ML20086U032 (6)

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$ h /f 2 f y'2 5 - t V R $ W 3f5 US C O 95 att i4 aio:4o Georgia power.has made an additional Material ~falso L statement in written correspondence to the NRC OFFt0E:EstureCRETARY-L Event Report .90-006. submitted- 4-19-90. It is .sim0tEKEtBHfoileSERVICE E

Material f alse statement made on 4-09-90 and involves 886#CH claims of successful starts without problems on.Vogtle's Diesel generators that failed during the Site-Area Emergency-

of.3-20-90.

On page.5 under item D.it states " Numerous sensor calibrations (including jacket water temperatures),special pneumatic. leak testing and multiple engine starts and runs-were performed under.various conditions.After the 3-20-90 event,the control systems of both engines' have been subjected to a comprehensive test program. Subsequent to this-test program, DG1 A and DG1B have been started at least 18 times each and no failures or problems have occurred during any of these starts.In addition,. an undervoltage start test without air roll was conducted on 4-6-90 and OG1 A started and loaded properly."

The above statement regarding the number of successful starts without" failures or problems" subsequent to the control systems comprehensive test program is materially false by ommission or commission.The 18 diesel control logic

-O testing was completed on 3-27-90 just prior to performing the first undervoltage test at 22:04 CST on 3-27-90 and l prior to declaring the diesel operable at 15:27 CST on 3 90. Completion of this testing, is the earliest point in time that a claim of completing a comprehensive control systems test program could be made. Subsequent to that date and time  ;

until 4-19-90, DG1B has been started only 11 times. '

The 1A diesel control logic testing was completed on 3-31-90 just prior to performing the first undervoltage test at 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-is the earliest point in time that a claim of completing a comprehensive control systems test program could be-made. Subsequent to that date and time until 4-19-90, DG1 A has al,so been started onl y 11' times.

This material f also state- ont is similar to the one .made by Georgia power on 4-9-90 ir; correspondence ELV-01516 and again falsely overstates the extent of reliable starting experience with DG1B and OGIA. Concern was raised by plant-staff on 4-18-90 with the SONOPCO Licensing Engineer,the SONOPCO Licensing Manager,the SONOPCO General Manager Plant Support,the Vogtle General Manager,the SONOPCO Vice President Vogtle,and the SONOPCO Senior Vice President O

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, y and the fact that there had been " failure and problems" prior to submittal of the LER.SONOPCO was pressed for. time

[~'. and issued the LER without adequate verification and in the face of concerns for the accuracy of the information raised by the site.The issue of the accuracy of correspondence ELV-01516 including specific. failure information was raised by site personnel on the phone call with the above personnel at the same time.

On 4-30-90 the Vogtle General Manager was provided a memo with start data on the DG18 ,derrived from control logs, shift supervisor logs and source diesel operating logs.that clearly showed that previous statements made to the NRC were false.Me 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 to the General Manager on 5-2-90 and in this presentation it was stated that statements on both diesels 1 A and 1B were incorrect in the 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 be prepared. He also suggested that the letter ELV-01516 be corrected by including a correction in the letter being prepared for submittal to the NRC on 5-15-90.

The General Manager did not follow up on the progress of these revision actions or set any time table for completion as he normally would on important issues.

O 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 addressed or corrected the material falso statement as previously suggested by the General Manager.SONOPCO and the General Manager were heavily involved in writing , editing and specifying the contents of the May 15 letter.The PRB made a comment on the fact that the letter did not address the material falso statement and assigned the General Manager an action item to resolve that. .

Af ter the General manager saw the action item his secretary came to the PRB secretary's office and said "Doesn't NSAC have anything better to do than assign the General Manager action items".

Later on 5-24-90 the general Manager signed the action item off as complete and attached a note instruting the Technical Support Manager to use the LER cover letter to' correct the other incorrect document.SONOPCO most always draf ts the cover letters, not the Technical Manager.

On 5-11-90 the PRS met again with the General Manager to approve the " final" version of the May 15 letter to be sent to the Senior Vice President SONOPCO for signature. Again no correction had been made and the previous material falso statement was not addressed.The " final" version was

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material' false statements had been. removed from the PRB by a memo from'the General Manager (NOTS-00382) dated 5-10-90 and O 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 J about what was taking so long to submit the i correction.SONOPCO licensing personnel told site personnel that the Senior Vice President Nuclear planned to sign the revision on June 8 (the day of the IIT presentation to the  !

Commission on the Vogtle Site-Area emergency). l On June 8,11 and 12 an extrordinary number of meetings and  !

telephone calls' occurred over the Diesel start information.

Quality assurance was directed by the Senior Vice President to audit all of the Diesel start logs.When this was I completed ,no errors were found in the information that had been presented to the General Manager over a month before on 4-30-90.With.this done the Senior Vice President ask for a

" complete revision" and updating of the LER.This was done and a revised LER was PRB approved by 6-22-90.Only 3 of 8 pages needed any rewrite on the " complete revision".A.

complete revision had originally not been planed until 6 -l months after the event. i The " complete" revision LER switches the counting and ,

reporting of Diesel generator starts and failures to " valid" I starts and failures per Reg Guide 1.108.By doing so correlation between the previous LER can not be made without

.O. - detailed and specific data on each start.While the original LER was being drafted-it was suggested that we might want to use " valid starts and failures" but that method was discounted because it was recognized that we had very few valid' tests.If the original LER were stated in terms of valid starts we could only say " Subsequent to this. test program the DG 1 A- and DG 18 have had 6 valid starts without problems or failures".If the COA response letter were stated in terms of " valid starts" we could only say " Subsequent to the event the DG1 A has had 1 v'alid- test with no failures and -

the DG1B has had 2 valid tests with no failures".If valid tests are a more "useful" measure of Diesel performance then -

clearly the perception.of the Diesel reliability changes from that previously provided to the NRC.

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On 6-28-90 and 6-29-90 a total of 6 cover letters to be sent in with the LER revision were originated and proposed by SONOPCO.Each is different and attempts to explain the Material Falso statement in 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

.O there wara no problems or failures.

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08:55- 6-28-90' This draft says that all-tests were

- /h. . counted regardless of whether they lt/ were valid or not.

'07:55 ;6-29-90 This draft says that'the COA respense 4

letterzused the words " Subsequent to' the event" and that the LER inadvertently used the words.

" Subsequent to the test program" but should have been consistent with the COA response letter 1and the verbal presentation in Atlanta.

11:42 6-21-90 This draft says the LER' statement-didn't consider failures and problems associated with troubleshooting and restarting the Diesel and should.have been " Subsequent-to the event" which is consistent with the COA response and the verbal presentation.

12:06 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 OG1B as of 4-19-90.

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 DGIA and 12 on DG18.It also says that test program starts were included in the original count and.that was due to poor record keeping practices 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 and why the errors were actually made.In short these are lies and an atempt to coverup the careless personne1' errors made by the operations superintendent and General Manager which originated in the verbal presentation,were repeated in the COA response letter and were carelessly restated in the LER.

A look at the Diesel generators starting and failure history after the LE9 was written on 4-18-90 provides a technical as ,

well as a objective view of the reliability of the diesels

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which is at the heart of the Material. False' Statement.'  !;

l} ) Diesel Generator 18 j DATE LTIME RESULT l;

04-19-90 03:14 Diesel was inadvertently. started l due to personnel error in performing i Surveillance 14619 i 04-19 09:55 Successful start  !

04-29-90: 09:09 Successful start- j 05-23-90 12:26 Diesel Tripped'after start  ;

05-23-90 13:10 Diese1_ tripped after start 05-23-90 14:12 Successful start manual trip 23-90 14:45 Successful start manual trip  !

05-23-90 21:18 Diesel tripped after start on low turbo lube oil pressure 1 05-23-90 21:38 Diesel tripped after start on low l 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 tripped after start on Hi 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 1 12:53 0 05-24-90 05-24-90 05-24-90 13:10 15:19 Successful start Successful start Successful start 1

. 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 excessive rate of trips and failures most of which were the same kind of failure that led to the station blackout at mid-loop that occurred.on 3-20-90. Clearly this diesel was not reliable as the COA response letter-and the LER tried to convoy.As-further proof of the unreliability Geor91a Power had to initiate a design change to remove some of the unreliable components from the control logic after experiencing all the additional failures.

Considering the evidence:

The words are falso 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.

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I SONOPCO personne11 recognized that the previous (COA)

L startements were falso before submittal of the LER.

k / Factual data was presented disputing the data after submittal and stating that information provided to NRC was L incorrect.

Substantial delays occurred in starting to correct the LER.

Additional delays were introduced after beginning correction (QA audit).

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Revisions were delayed until after critical meetings with NRC (6-08-90 IIT presentation to Commissioners)

Additional unplanned delays were introduced (complete E

revision) after QA audit substaintated inaccuracy claim.

Multiplicity of revision letters (also false) to explain the mistake.

Submittal to AEOD by LER revision to correct multiple non-LER errors.

Performance of the Diesel itself proves'the unreliability 2

and the falseness of the statements given to the NRC.

Above actions did not proceed without repeated and I continuing expression of concern from the plant employee yho exposed the Material Falso statement .

one can only conclude that Georgia Power did indeed make Material False Statements in written correspondence to the NRC due to as a minimum careless disregard and willfuly conspired to delay and cover up the disclosure of those i false statements.

() These se'rious and Georgia Powers' commitment to safety and it's events bring into question SONOPCO's I

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fundamental trustworthiness as a licensee. )

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