ML20091H853
| ML20091H853 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/19/1995 |
| From: | GEORGIA POWER CO. |
| To: | |
| References | |
| OLA-3-A-134, NUDOCS 9508140286 | |
| Download: ML20091H853 (7) | |
Text
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i NUCLEAR REGULATORY COMMISSION (7AC f
Docket No. 50-424/425-OLA 3 EXHIBLT NO_
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in the inatter of Georaia Power Co. et al.. Voatle Units 1 & 2
% Applicant O Staff O intervenor O Other
'[ Identified IT Received O Rejected Reporter l(H (_M Date 3 f D !.9 $ _ Witness DOSb%k
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Georgia power has made an acc1tlonal Mater 1a1 false statement in wr1tten correspondence to the NRC in L1censee Event Report 90-006 submitted 4-19-90.It 1s similar to the Mater 1al false statement made on 4-09-90 and invc1ves the claims of successful starts without problems on Vog;1e's
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-Diesel generators that failed during the 51te-Area Emergency of 3-20-90.
On page 5 under item D it states " Numerous sensor calibrations (1ncluding jacket water temperatures),special
-pneumatic leak testing.and multiple engine starts anc 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.Suoseousnt to this I
test program. DG1A and DG1B have been started at least 16.
t1mes 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 DG1A started and loaded properly."
The above statement regarcing the number of successful l
starts without" fa11ures or problems" subsecuent to the control systems.comprehens1ve test program 1s mater 1all>
false by ommission or commission.The 1B diesel control logic testing was completec on 3-27-90 just prior to performing the first undervoltage test at 22:04 CST on 3-27-90 anc prior to declaring the diesel operable at 15:27 CS~ on 2 90. Completion of this testing, 1s the earliest point in time that a cla1m of completing a comprehensive control systems test program coulc be made.Subseauent to tnat date and time until 4-19-90, DG1B has been started only 11 t1mes.
Tne 1A diesel control logic testing was completed on 3-31-90 Just prior to perform 1ng the first undervoltage test at 22:52 CST on 3-31-90 anc prior to declaring the ciesel operable at 11:54 CST on 4-01-90. Comcletion of this testing 1c the ear 11est point in time that a cla1m of completing a comprehensive control systems test program could be made.Subsecuent to that date anc time until 4-19-90, CGiA has also been started oni) 11 times.
This material false statement is similar to the one made by Georgia power on 4-9-90 in correspondence ELV-01016 ahd again falsely overstates the extent of rellacle starting experience with DG1B and DG1A. Concern was raisec D) :Jant staff on 4-16-9C with the SONCPCO Licensing Engineer,the SONOPCO Licensing Manager,the SONOPCO General Manager Dian:
Supacrt,the Vogtie General Manager,the SONOPCO Vice President Vogtie,ano the SONOPCO Senior Vice Pres; dent Nuclear as to the accuracy of the D1esel start information and the fact that tnere had been "fa11ure and problem &
EMBIT f
PAGEL (OF kPAGSS; i
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o prior to submittal'cf the LER.SONOPCC was pressed for t1ms and issued the LER without adequate verificat1on anc 1r. the.
face of concerns for the accuracy of the 1nformat1on raised by the s1te.The 1ssue of the accuracy of corresponcence ELV-01516 including specific failure information was raised by s1te personnel on the phone call with the above personnel at the same time.
On 4-30-90 the Vogtle General Manager was providea a memt with start data on the DG1B,derrived from control icgs.
shift supervisor logs and source diesel operating logs.that clearly showed that previous statements made to the NRC were false.He took no immed1 ate action and ask for the information to be validated by operations and engineering.The information was validated on 5-1-90 and t
found correct.It was presented again tc the General Manager on 5-2-90 and in this presentat1or. it was stated that statements on both diesels 1A and 1B were 1ncorrect in the LER and that the letter ELV-01516 was wrong as well.St111 he took no act1on to promptly inform the NRC of the false statement and suggested that a revision to the ER oe i
prepared. He also suggested that the letter ELV-01516 be corrected by including a correction in tne r
letter being prepared for submittal to the NRC on 5-15-90.
Tne General Manager did not follow up on the progress of these revision actions or set any t1me taole for complet1or, as he normally would on important issues.
A rev1sion was made to the LER and approved by the PRE on 5-6-90.On 5-10-90 the PRB rev1ewed the 5-15-90 letter (actually submitted on May 14)to the NRC.It had nothing that j
addressed or corrected the material false statement as i
prev 1ously suggested by the General Manager.SONOPCO anc the l
General Manager were heavily involved in writing,ec1 ting ano spec 1fy1ng the contents of the May 15 letter.The PRB made a comment on the fact that the letter did not address the material false statement and assigned the General Manager an action item to resolve that.
j After the General manager saw the action item h1s secretary came to the DRB 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 cff as complete arc attached a note instruting the Technical Support Manager to use the LER cover letter to correct the other incorrect document.SONOPCO most always drafts the i
cover letters, not the Technical Manager.
On 5-11-90 the PRB met again with the General Manager t.c aoprove the " final' version of the May 15 letter to be sent i
to the Senior Vice Presloent SONOPCC for signature.Again i
nc' correct 1on had been made and the previous material fe,lse statement was not addressed.The "f1nal" version was i
aoproved.The ind1v1 dual that had raised tne issue of the material false statements had been removed from the PRE by a E!
PAGE p 0F M PAGE(S) l
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memo from the General Manager (NOTS-00382) datec 5-10-90 anc effective 5-11-90.
i By May 15 the rev1 sed LER was with SONOPCO.No action occurred to submitt the LER to the NRC until about the first week in June when aga1n site personnel began asking SONOPCO about what was taking so long to submit the correction.SONOPCO licensing personnel told site personnel that the Senior Vice Presiaent Nuclear planned to sign the revision on June 8 (the day of the IIT presentation to the Commiss1on on the Vogtle S1te-Area emergency).
On June 8,11 and 12 an extrordinary number of meet 1nss anc telephone calls occurred over the Diesel start informat.on.
Quality assurance was directed oy the Senior v1ce Pres dent to aucit all of the Diesel start logs.When tn1s was completed,no errors were found in the information that had been presented to the General Manager over a month tefore en 4-30-90.W1th th1s done tne Senior Vice President ash for a
" complete revision" and updating of the LER.This was done and a revised LER was PRB acoroved by 6-22-90f3nly 3 of S "6 ages needed any rewrite on tne " complete revis1on'.A complete revision had orig 1nally not been planec until 0 months after tne event.
The " complete" revision LER swltches the counting and gd reporting of Diesel generator starts and failures to 'valld' starts and failures per Reg Guide 1.108.By do1ng so N
correlation between the previous LER can not be made witnout detailed and spec 1fic data on each start.Wnile the original LER was being drafted it was suggested that we m1gnt want tc sq use "salld starts and failures' but that method was discounted because 1t was recognized that we hac'very few g
valid tests.!f tne original LER were stated in terms of valid starts we could only say " Subsequent to this test k
crogram the CG 1A anc DG 1B have had 6 val-d starts without problems or failures' k
On 6-2E-90 and 6-29-90 a total of 6 cover letters to be g
l sent in with the LER revision were originated anc proposec 4k oy SONOPOO.Each is 01fferent and attempts to excla n One Material False 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 tnere were no problems or failures.
06: 55 6-26-90 This draft says that all tests were counted'regaroless of wnethe-they i
i were valid or not.
C7:55 6-29-90 This draft says tnat the COA response letter used the words 'SuosecJent tc J
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the event"~and that tne LER inadvertently used the woros
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"Subsecuent to the. test program" but snould have beer consistent
'l with the COA response letter and 4
the verbal presentation in Atlanta.
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11':42 6-29-90 This craft says the LER statement didn't consider failures and croolems associated.with troubleshooting anc restarting the Diesel and should have been " Subsequent to the event" wnich
.1s consistent with the COA resconse and the verbal presentation.
12:06 6-29-90 This draft says that "If the i
comprehens1ve test program como,letec with the first Surve111ance 14980-1 then there were 10 successful starts on DG1A and 12 on DG1B as of 4-19-90.
j 12:11 6-29-90 This draft says that "If the comprehensive test program completed with the first Surveillance 14980-1 thisn there were 10 successf ul starts on DG1A and 12 on DG18.It also says thtt test program starts were included
'a the or1ginal count ano that was due to poor record keep 1ng practices anc g
no definition of the end of the test DN program.
These explainations are all untrue and are belns concocted after the fact witnout regard to how anc why the errors were actually made.Ir. short these are lies and an atempt to cove up the careless personnel errors made by tne operations superintendent and General Manager which originated 1n the verbal presentation,were repeated in tne COA response letter and were carelessly restated in tht LER.
A look at the Diesel generators start 1ng ano failure history after the LER was written on 4-18-90 provices a techn1 Cal as well as a objective view of the rel1 ability of the d iesEIS l
which is at the heart of the Material False Statement.
Diesel Generator 1B 1
DATE TIME-RESULT
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t 04-19-90 02: 14 Diesel was inacvertently started N
EBMT C PAGE /2 OF M [PG(S; i
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'4 due to personnel error in perform 1ng Surveillance 14619-1 04-19-90 09:55 Successful start 04-29-90 09:09 Successful start 05-23-90 12:26 D1esel Tripped after start 05-23-90 13:10 D1esel tr1pped after start 05-23-90 14: 12 Successful start manual trip 05-23-90 14: 45 Successful start manual trip 05-23-90 21:18 Diesel tripped after start on low turbo lube oil pressure 7
05-23-90 21:38 Diesel tripped after start on low 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 H1 Jacket water temperature 05-24-90 12:29 Successful start 05-24-90 12:42 Successful start 05-24-90 12:53 Successful start 05-24-90 13: 10 Successful start b
05-24-90 15:19 Successful start W
' 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 k
Clearly this diesel generator continued to experience an i
excessive rate of trips and failures most of which were the same kind of failure that led to tne station blackout at m10-loop that occurred on 3-20-90. Clearly this diesel was not reliable as the COA response letter and the LER tried to 9
convey.As further proof of tne unreliab111ty Georpss Power j
had to in1tlate a design change to remove scme of ;ne 1
unreliable components from the control log 1c after experiencing all the additional failures.
)
l Considering the evidence:
The words are false in counting the starts.
They overstate the reliability of the diesel.
They were used by NRC to make dec1slons "Significant to the Regulatory Process' (To allow Restart)
Concern was raised about the accuracy of tne start data before submittal of LER.
SONOPCO personne11 recognized that the previous (CCA) j startements were false before suom1ttal of the LER.
i Factual data was presented discuting the data after submittal and stating that information prov1ced to NRC was i
f incorrect, i
Substantial delays occurred in starting to correct tne LER.
Adc1tional delays were introducec after beginning correct 1or
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(QA aud1t).
M _~Y PAGE__.(!_OF k PAGSS
t Revisions were delayed until after crit 1 cal meetings witq NRC (6-08-90 IIT presentation to Commissioners)
Additional unplanned delays were introducea (comclete revision) after QA audit substaintated inaccuracy claim.
Mult1plic1ty of revis1on letters (also false; to explain the mistake.
9 Submittal to AEOD by LER revision to correct multiple non-Os LER errors.
\\pg N
Performance of the Diesel itself proves the unreliability and the falseness of the statements given to tne NRO.
N Above actions did not proceed without repeated and continuing expression of concern from the plant employee who exposed the Material False statement one can only conclude that Georgia Power d1a Indeed make Mater 1al False Statements in wr1tten correspondence to the NRC due to as a minimum careless disregard anc willfuly
$7 conspired to delay and cover up the disclosure of those false statements.
EXWili 3 PAGE N OF M PAGMS)
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