ML20086U046
| ML20086U046 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/23/1995 |
| From: | GEORGIA POWER CO. |
| To: | |
| References | |
| OLA-3-A-073B, OLA-3-A-73B, NUDOCS 9508030250 | |
| Download: ML20086U046 (7) | |
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- PLEASE NOTE ******
The level of detail contained in this concern w111 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 this letter or the fact that this Information was obtained thru an allegation, to Vogtle or SONOPCO personnei.I fear that retalltation 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 false statements in written correspondence submitted to the NRC regarding Plant Vogtle's emergency diesel generator's control and starting air supplies and diesel generator testing.The statements are contained in correspondence ELV-01516 submitted on 4-9-90 in response to the NRC'S Confirmation of Action letter.The purpose of ELV-01516 was O,
to explain Georgia Power's review,1nvestigation and corrective actions taken with respect to the events involved in the Site-Area Emergency of 3-20-90 and to request the NRC to 11ft 1t'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 a1r 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 April 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 it presents a conclusion (that air quality is satisfactory) that cannot be concluded from objective evidence and knowidege of Vogtle's Diesel generator air systems. This includes 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
V a
i h1 story of air quality:
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)
1.vogtle's response to Generic Letter 88-14 presents 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 with no measurments taken in 1987 and only one taken in 1988.The 1988 value is theoretically i
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 impossible (less than 32 F).
3.Since the equipment used to measure dewpoints measures at atmospheric pressure and the criteria is 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 certain.
4.The maintenance procedure in use is contrary to the dewpoint measurment equipment vendors recomendations in that it uses a pressure regulator which the vendor says holds moisture and gives false readings.
- 5. Readings obtained on 3-9-90 and 3-31-90 exceeded
(T acceptance criteria and were as high as 80 F.This
\\l was explained as ' faulty equipment" but after that, s
on 4-6-90, valid dewpoint readings of 84 F were measured for Unit 1 DG air dryer K01 and 83 F for K02 as documented on DC 1-90-186. Maintenance work order 2-9000964 documents air cuality problems on the Unit 2A diesel where nearly every dewpoint measurment exceeded acceptance criteria when measured 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 written 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.Maint'enance work order 1-88-02991 was open from 5-10-88 to 5-2-89 to repair both the K01 and K02 dryers. Refrigeration compressors as well as condensing fans have been broken.When preparing to j
perform the UV testing of the diesels for the IIT, j
air dryers were found out of service.
7.Despite having the air dryers out of service the associated compressors have remained in service.
8.The diesel generator utilizes a pneumatic air control logic system which has extremely small orifices fS as small as 6 thousandths of an inch.This air control
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system takes its air from the starting air system.
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'9, Qualitative'and~ gross observations at a few' points in-the system.one air receiver. tank andc a-filter,
[,,1 1 Ps b is.not'suffic1ent to confirm satisfactory air quality and internal ^ cleanliness of hundreds:of:
i
.-airRlines'afterfyearsaof inadequate air dryer
~ maintenance andsdewpoint' testing..
- 10.Alr-in'the diesel building is'not air conditior.ed and therefore tne' air compressors utilize-amb.ent air which-in the Central Savanna P,ver Area 1s g
typically extremely warm and humidz much of'thel year.Withos.t dryers.In service, water in the system ;s: bound to be.a. problem.
11.For perloca of operat1on without dryers in service (which have been extensive) the air
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in the receiver would be saturated ~and have a dewpoint of that of room temperature. Receiver blowdown would not alter!those conditions. For' summer' l
at Vogtle that would be 90 -100 F.Using ps'ychometric charts:a' drop of.approximately 30 F.In dewpoint
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would occurr upon pressure reduction to the control air pressure of 80~psig.This would produce a dewpoint of.60 to 70.F which exceeds the acceptance criteria.This value i-s suppr1 singly close-to the valid.measurments recently taken with the dryers out of service. Clearly air quality should be expected to be unsatisfactory during periods when the dryers have been out of service.
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.wlth known lengthly-periods.
of. dryers out of service durini which times air quality probably was unsatisfactory against the acceptance criteria j
stated in response to Generic Letter 88-14.For.the most 1
recent period since 6-28-89 air quality was measured and generally met acceptance.criterla except when dryers were
'out of service (uthe-extent of which11s cificult'to reconstruct) at which times air quality was probably.again unsatisfactory.At theitime;thatJcorrespondence ELV-01516 was signed by Georgia Power, 2 of 4 diesels'had air cuality problems with high dewootnts (outside acceptance-criteria)
"j i
rard ng from 64.to:84F.
Dewpoints that h1gh could easily result'in water in the air' lines'as room temperatures cycle (when cool n1ght or
-i early morning air i s drawn into the room).The outside air dampers locations in:the D1esel rooms make thi~s a destinct=
i posibility.The presence of any. water in'the lines will. lead i
to corrosion and Darticulate matter format 1on which could be carried to the pneumatic' logic boards, sensor valves and
-I other pneumatic components and could easily cause
-j malfunctions.
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In.ELV-01516 page 3 item 9 it states"Since March 20 1990.
GPC has performed numerous sensor calibrations (including jacket water temperature), extensive logic test 1ng, spec 1al l
pneumatic leaf testing, and multiple engine starts and runs I
under various conditions.Since March 20, the 1A DG has been started 18 times,and the 18 DG has been started 19 times.No failures or problems have occurred during-any o' these starts. In addition,an undervoltage start test without air roll was conducted on April 6,1990 and the 1A D/G started and loaded properly.'
The above paragraph is materially false by omission and/or commission because according to Vogtle control room logs and i
procedure 14980 data sheets the 1B DG had been started 29 l
t1mest see NOTE
- below) since March 20,1990.It experienced 8 i
failures or problems during these starts and one problem with control air pressure'between starts as follows:
Start Date T1me Comment 1
3-21-90 21:49 Diesel failled to start 2
3-21-90 21:56 Diesel failled to start 3
3-21-90 22:02 4
3-21-90 22:59 Diesel had to be stopped due to O
low luce oil pressure and h1 oil 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 04: 28 9
3-22-90 07:14 9
8 3-22-90 08:54 10 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 Hi Lube 011 Temp 14 3-23-90 05:09 Got B chase 127 Undervoltage relay flag on start 15 3-23-90 17:30 Diesel tripped Lo Jacket Water Press./ Turbo Lube Oil' Press.
16 3-23-90 17: 44 17 3-24-90 00: 48 Got generator ground relay 164 dropout on start. Received DG1B Trip Hi Jacket water alarm.DG should have tr1pped but didn't.
13 3-27-90 16: 49
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19 3-27-90 19:09 20 3-27-90 19:51
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21 3-27-90 19:57 i
____._______-_-_________.____-_-.-_____m
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3-27-90 20:04 22
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23 3-27-90 22:20 'D1esel 18 Undervoltage Test
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24 3-28-90 04: 03 Diesel TS Surveillance 14980
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25 3-28-90 13:50 s
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26 3-28-90 13:56 3-28-90 15:27 Diesel 1B' Declared Operable 4-03-90 05:15 Got Malnt. lockout alarm due to low control air pressure (41 psi) j 27 4-04-90 16:32 L
28 4-05-90 00:30 Functional test of design-change V
DCP 133 29 4-05-90 03:07 Diesel TS Surveillance 14980 Date of ELV-01516 4-9-90 30 4-10-90 01:37 Surueillance 14980 l'
31 4-12-90 10:20 Surveillance 14980 32 4-16-90 00:00 Surve111ance 14980 33 4-18-90 07:59 Surveillance 14980 34 4-19-90 03:14 Diesel inadvertently emergency started while performing Surveillance OSP-14619-1 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 O
From the above it is clear that there have been numerous trips and problems with the 18 diesel s1nce 3-20-90, many of which are associated with features being investigated to determine the cause of the 1A diesel failure, such as CALCON switches and control air.In addit 1on, even 1f you disregard the trips and problems,there were only 14 successful starts on 18 Diesel since the time of the last trip and only 3 starts since the time of the last problem and the date of ELV-01516.
It is clear that the data do not support the claims made in the letter of" No failures or problems during any of these starts" fcr this diesel.It 1s part1cularly disturbing that Georgia Power has misled the NRC with this informaticn, Information presented to convince the NRC of the reliability of Vogtle's diesel generators and tc obtain permission to resume power operations.
Since the cause for failure of the Vogtle diesel generator 1A and the subsequent testing and reliable operation of both 1A and 18 diesels is particularly significant to the Site-Area Emergency, the Confirmation of Action Letter-and associated regulatory action and since ELV-01516 was s1gned by the Senior Vice President SONOPCO, tnese Material False
,j ).
Statements are very disturbing.
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-- - __--__- __ - __ _- _-_-_______ - ___.____ - - - _ Q
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- Detailled information.and source-documentsLincluding
/,h Diesel.: start and f ailure data used to compile the above-(/
concern have;been provided to Al Chaffee of1the NRC IIT
- team, j
i PLEASELNOTE
.The level of detail 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 andL the i
seriousness of these concerns,.I request that you j
do'not reveal the text of'this11etter cr the fact
~l that-this information was obtained thru an allegation, 1
toivogtle or SONOPCO personnel;I. fear that ietalitation.
includ1ng tiua possibility of physical harm cauld come j
to me or my family'.I am-concerned because of recent-articles surrounding Gulf Power,a7 Southern'Co.
-subsidiary,and the Jake Horton' case as we'll as my:
observations of' Georgia Power,SONOPCO, and Vogtle management for.many years.
~
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