ML20128G348

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Discusses Partially Withheld Insp Repts 50-424/90-19 & 50-425/90-19 & Forwards NOV & Demands for Info
ML20128G348
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 05/31/1990
From: Milhoan J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
GEORGIA POWER CO.
Shared Package
ML20128F432 List: ... further results
References
FOIA-95-81 EA-93-304, EA-94-036, EA-94-037, EA-94-052, EA-94-36, EA-94-37, EA-94-52, NUDOCS 9610090009
Download: ML20128G348 (15)
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See also: IR 05000424/1990019

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Docket No. 50-424

License No. NPF-68 information in this record as deleted

EA 93-304, EA 94-036, in accordance with theJJeedom " 01 Infom

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EA 94-037, and EA 94-052 Act, exem -

Georgia Power Company

ATTN: Mr. H. Allen Franklin

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President and Chief Executive Officer

Post Office Box 1295

, Birmingham, Alabama 35201

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SUBJECT: NOTICE OF VIOLATION

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's s 'FND s' ci s i'f- s'

s, UE

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( C Office o nvestigations Report No. 2-90-020 and NRC

Inspection Report No. 50-424,425/90-19, Supplement I)

This refers to the investigation conducted by the Nuclear Regulatory

' Commission's Office of Investigations (01) at Georgia Power Company's (GPC or ,

Licensee) Vogtle Electric Generating Plant (VEGP) which was completed on l

December 17, 1993. The investigation was initiated as a result of information l

received in June 1990 by Region II alleging, in part, that material false I

statements were made to the NRC by senior officials of GPC regarding the

reliability of the Diesel Generators (DGs). The pertinent events involved in

this matter are described below.

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On March 20, 1990, during a refueling outage at VEGP Unit 1, GPC declared a

l Site Area Emergency (SAE) when offsite power was lost concurrent with the

failure of the only Unit 1 DG that was available (1A). The other Unit 1 DG

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(IB) was unavailable due to maintenance activities.

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The NRC immediately responded to the SAE at the VEGP site with an Augmented

Inspection Team (AIT). The NRC effort was upgraded to an Incident

Investigation Team (IIT) on March 23, 1990. The IIT was composed of NRC

Headquarters technical staff and industry personnel. The results of this

investigation are documented in NUREG-1410, " Loss of Vital AC Power and the

Residual Heat Removal System During Mid-loop Operations at Vogtle Unit 1 on

March 20, 1990."

On March 23, 1990, the NRC issued a Confirmation of Action Letter (CAL) to GPC

that, among other things, confirmed that GPC had agreed not to return VEGP

Unit 1 to criticality until the Regional Administrator was satisfied that

appropriate corrective actions had been taken, and that the plant could safely

return to power operations.

On April 9, 1990, GPC made a presentation to the NRC in the Region II offices

in support of GPC's request to return VEGP Unit 1 to power operations. As

part of this presentation, GPC provided information on DG starts in response

to a specific NRC request that GPC address DG reliability in its April 9

9610090009 960827

PDR FOIA

WILHOTH95-81 PDR

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I presentation. GPC submitted a written summary of its April 9 presentation in '

an April 9,1990 letter, "Vogtle Electric Generating Plant Confirmation of'

Action Letter."  ;

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On April 12, 1990, the NRC formally granted permission for VEGP Unit I to '

j return to criticality and resume power operations.

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On April 19, 1990, pursuant to 10 CFR 50.73, GPC submitted Licensee Event

Report (LER) 50-424/90-006, " Loss of Offsite Power Leads to Site Area '

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' Emergency."

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On June.29, 1990, GPC submitted a revised LER, 50-424/90-006-01. The purpose

, .of the submittal was to clarify information related to successful DG starts

t that were discussed in the April 9,1990 letter and the April 19, 1990 LER,

and to update the status of corrective' actions in the original LER.

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From August 6 through August 17, 1990, the NRC conducted a Special Ter

Inspection at VEGP, as a result of NRC concerns about, and allegations altted

to, VEGP operational activities. This inspection examined the technica:

validity and safety significance of the allegations, but did not investigate

alleged wrongdoing. The Special Team informed GPC that the June 29, 1990

submittal failed to address the April 9,1990 data and requested that GPC

clarify DG starts reported on April 9,1990. Results of this inspection are

documented, in part, in NRC Inspection Report No. 50-424,425/90-19,

Supplement 1, dated November 1,1991. t

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On August 30, 1990, GPC submitted a letter, " Clarification of Response to

Confirmation of Action Letter." The purpose of the submittal was to clarify

the diesel start information that was addressed in the April 9, 1990

submittal.

The NRC has carefully reviewad the evidence associated with these events,

submittals, and representations to the NRC. Specifically, the NRC reviewed

information gathered as part of the 01 investigation, information gathered

during the IIT, NUREG-1410, Supplement 1 of NRC Inspection Report 90-19,

discovery responses in the Vogtle operating license amendment proceeding

(pocket Nos. 50-424 OLA-3, 50-425 OLA-3),'and other related information.

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' The VEGP Gsheral Man'ager was

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personally inv 6 1on of the data regarding the DG

reliability and tasked the Unit Superintendent with co ti the

number of successful DG starts for th nd IB DGs.

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In fact, che VEGP General Manager stated no criteria for successful

starts, a term not formally defined, when he directed the Unit

Superintendent to gather successful DG starts. The Unit Superintendent

collected DG start data from the Control Room to and the Shift

Supervisor's Log

ora y cony

Mana er for the 1A and 18 di

ormation

( was t en presente in an pri , 1990 ora resentation by

( the VEGP f:eneral Manager and in an April 9, 1990 letter that since

i March 20. 1990, there were 18 and 19 successful consecutive starts on

i the 1A ano IB DGs, respectively, without problems or failures.

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ro ree s e pr n W on

and_1_etter inIluded three starts with problems that occurre during DG'

(overhaul / maintenance activit'ies'(a high lube oil temperature trip on

la 6 22, 1990; a low jacket w'ater pressure /turba lube oil pressure low

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trip on March 23, 1990; and a failure to trip on a high jacket water

! temperature alarm occurring on March 24, 1990). The correct number of

l consecutive successful starts was 12 for the 18 DG--a number l

l han that re rted by GPC to the NRC on April 9,

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In considering a restart decision,

l the NR was especially interes in the reliability of the DGs and

specifically asked that GPC address the matter in its presentation on

restart. The NRC relied, in part, upon this information presented by

GPC on April 9, 1990 in the oral presentation and in the GPC letter in

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reaching the NRC decision to allow Vogtle Unit I to return to power l

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operation.

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he air or s arting a 8 = opera ing 1 s1 e - 5 and con ro s is

derived from the starting air system. The starting air system contains

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'f dryers designed to ntain moisture content (i.e., dew poin

acceptable levels.

eficiency cards

associated wi nit I would have revealed that high dew points were

also attributable to system air dryers occasionally being out of service

l for extended periods and to system repressurization following

maintenance, as documented in NRC Inspecti No. 50-424,425/90-

19, Supplement I dated Nov

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In consi ering a resta ecision, the N was especia y interested in

the reliability of the DGs and specifically asked that GPC address the

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matter in its presentation on restart. The NRC relied, in part, upon

i this information presented by GPC in its letter of April 9,1990 in

! reaching the decision to allow Vagtle Unit I to return to power

l operation.

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LER 90-006, submitted to the NRC on April 19, 1990, was based, in part,

on information presented to.the NRC on April 9, 1990. During the

preparation of the LER, the Acting VEGP Assistant General Manager -Plant

Support questioned the accuracy of the April 9, 199 en that

there were trips on the IB DG after Mar

iscussions regar ing the draft LER, the Genera Manager,

Technical Support Manager and Acting VEGP Assistant General Manager -

Plant Support acknowledged that they could not identify the specific DG

start that represented the starting point for the count presented to the

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NRC, i.e., the first start following completion of the CTP. The General

Manager - Plant Support (Vogtle Project), the VEGP Technical Support

Manager, and the Acting VEGP Assistant General Manager - Plant Support

were aware that the VEGP General Manager had earlier stated that his

April 9 count began after instrument recalibration. The Acting VEGP

Assistant General Manager - Plant Support stated that his understanding

of the CTP was that it woul

tore rabili

In ct, Unit

uperin o co e origina pri th data advised the

Acting VEGP Assistant General Manager - Plant Support and the VEGP

Technical Support Manager that he started his cou on March 20, rior

to the time when a CTP could have been completed.

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1 OG start coun s reported on pri , overs the actual

, countsbyincludingstartsthatwerepartofthetestprogram.ll ERB

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l dii' April 36,1990, the Acting VEGP Assistant General Ma er - Plant

i gave the VEGP General Mana er a listing of IB DG starts

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After being informed that the April 15 DG start counts were in error, the

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Senior Vice President - Nuclear Operations informed the Regional Administrator

that a revision to the April 19 LER would be submitted, in part, to correct

the DG start counts. After being provided conflicting data for the second

time, the Senior Vice President - Nuclear Operations again notified the

l Regional Administrator. He also requ a ted that an audit be conducted by GPC's

l Safety Audit and Engineering Review (SAER) group to establish the correct data

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and to determine why the errors were made. The audit, completed June 29,

narrowl focused on a review of diesel records (Test ' Data Sheets, Shift

rvisor's Log, and Diesel Generator Start Log) to verify the number of DG

s starts. The audit did not identify any specific cause for the error in the

j number reported in the LER. The audit stated, however, that the error

i appeared to result from incomplete documentation. The audit also noted that

there apparently was som confusion about the s ecific oin at which the est

rogram was completed.

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On June 29, 1990, the draft cover letter for the LER revision was being

reviewed at the site. The draft had originated in GPC corporate headquarters

and included language personally developed by the Senior Vice President -

Nuclear Operations and the Vice President - Vogtle Project. During the site

review, a VEGP Technical Assistant (TA) (formerly the Acting VEGP Assistant

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General Manager - Plant Support) noted that the letter was incomplete and

challenged the accuracy of the reasons stated in the draft cover letter in

conversations with the Supervisor - SAER, the VEGP Assistant General Manager -

Plant Support, the VEGP Manager - Engineering Support, and a Licensing

Engineer - Vogtle Project. The VEGP TA stated that: (1) the letter failed to

, clarify the DG starts reported on April 9, (2) DG record keeping practices

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were not a cause of the difference in the DG starts reported in the April 19

LER because adequate information was available when the counting errors were

made, and (3) the err us ts resulted from

devel the coun

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The Licensing Engineer - Vogtle Project had staff responsibility for preparing

the cover letter for the LER revision and was specifically instructed by the

Senior Vice President - Nuclear Operations to work cl with the site to

j ensure that the submittal was accurate and co ete.

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l The VEGP Manager - Engineering Support was responsible for the Diesel Start

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Logs and agreed with the audit. report findings regarding deficiencies in their

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condition. Given thar. his logs had not been used to collect the DG start

data, he pointed out that it was wrong t( state that the conditi his logs

caused errors in the information initially provided to the NRC.

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l the Supervisor - SAER'was made aware by the

EGP TA on June 12, 1990 t a , to identify the root cause of the error in the

l April 19, 1990 LER (i.e., personnel errtirs), the audit scope would need to

include an assessment of the performanco of the Unit Superintendent and the

VEGP General Manager, the individuals taat developed the initial count. Yet,

the audit report did not include either of these individuals in the list of

persons contacted during the audit. Or June 29, 1990, the Supervisor - SAER

f was again made a r TA ths.t the root cause for the difference was

ersonnel error.

The VEGP Assistant General Manager war apprised of concerns regarding the

June 29, 1990 letter by the VEGP TA (an individual who had been involved in

preparing the April 19, 1990 LER and had been involved in developing an

accurate DG start count). The VEGP Tu identified to him the failure of the

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June 29, 1990 draft cover lett he inaccuracies in the A ril 9,

j etter

l The Vice President - Vogtle

j Project and the Senior Vice President - Nuclear Operations were actively

j involved in the preparation of the June 29 cover letter. The VEGP General

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i Manager and Vice President - Vogtle Project reviewed, and th. Senior Vice

President - Nuclear Operations signed, the June 29 cover letter which stated

that its ur ose was, in art to 1 tion rovided to the NR

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letter and presentation and the April 19 LER were caused, in part, by

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confus in the tinction between a successful start and a valid

test.

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uring ugust 29, 1990 P view Board (PRB)

mee ing, e VEGP Manager - Technical Support questioned if the Unit

Superintendent (the individual who originally collected the DG start

data) was confused in the distinction between a successful start and a

valid test. The VEGP General Manager admitted that the Unit

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Superintendent was not confused about the distinction when he collected

the data which was use'd to prepare the April 9 letter, but stated that

the sentence was not in error because other people were confused. The

VEGP General Manager acknowledged that there was confusion among

individuals after April 9, but admitted that the t Superintendent was

not confused when he developed the information.

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! E ~ The August 30 letter states that the

I error in the Apri 9 e er an i

lresentation and the April 19 LER were

f caused, in part, by n error made b the individual who performed the

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count of DG starts.

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The' Senior ~Vice President-Nuclear Operations ano

e ce resident - Vogtle Project rectl invol

development of the June 29 letter.

C re ted

su ressi he ril 9 letter

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ect commit ng ugus meeting with

+he NRC special inspection team to rovide clarification to th> RC

arding the ril 9 letter.

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GPC forwarded a submittal regar ing t pri

letter on August that was drafted at corporate head uarters under the

direction of the Vice President - Vootle Pro.ie'ct.

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The responses directed by this letter and the enclosed Notice are not subject l

6 to the clearance procedures of the Office of Management and Budget as required i

by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.

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Sincerely,

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l James L. Milhoan

Deputy Executive Director

for Nuclear Reactor Regulation,

Regional Operations,and Research

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Enclosures-

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DISTRIBUTION:

PDR

SECY

CA

JTaylor, EDO I

JMilhoan, DEDR *

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JLieberman, OE

SEbneter, RII i

LChandler, OGC

JGoldberg, OGC .

WRussell, NRR

EReis, OGC

Enforcement Coordinators  ;

RI, RII, RIII, RIV, RV l

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FIngram, GPA/PA

EJordan, AEOD l

BHayes, 01

EA File

DCS

Vogtle Coordinating Group:

D. Matthews, Chairman

R. Pedersen, OE

P. Skinner, RII-

D. Hood, NRR

D. Wheeler, NRR l

D. Hoefling, OGC  !

M. Young, OGC .l

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GEORGE BOCKNOLD, JR.

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General Manager at Vogtle during March - August 1990 time-

frame.

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o Sent to INPO for approximately 1 or 2 years. l

o Currently serving as the General Manager of Nuclear.

Technical Services for Southern Nuclear (promotion from

Vogtle General Manager).

l o Has held current position for approximately 1 or 2 years.

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i o CU.rrent position considered licensed activities.

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o Current position impacts operations at Vcgtle, Hatch, and

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Farley (currently conducting overview of work request

j process at all three facilities).

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j o Five supervisors report to him. l

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Information in this record was deleted

! in accordance with thje Fr edom of information

' Act, exemptions.

FolA- W "X/-. -

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