ML20128G348
See also: IR 05000424/1990019
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Docket No.
50-424
in accordance with theJJeedom 01 Infom
License No.
"
Act, exem
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Georgia Power Company
ATTN: Mr. H. Allen Franklin
,
President and Chief Executive Officer
Post Office Box 1295
Birmingham, Alabama 35201
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SUBJECT:
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s,
's s 'FND
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(
C Office o
nvestigations Report No. 2-90-020 and NRC
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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
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Licensee) Vogtle Electric Generating Plant (VEGP) which was completed on
December 17, 1993. The investigation was initiated as a result of information
received in June 1990 by Region II alleging, in part, that material false
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.
On March 20, 1990, during a refueling outage at VEGP Unit 1, GPC declared a
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Site Area Emergency (SAE) when offsite power was lost concurrent with the
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failure of the only Unit 1 DG that was available (1A). The other Unit 1 DG
(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
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presentation. GPC submitted a written summary of its April 9 presentation in
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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
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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
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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.
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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
personally inv 6 1on of the data regarding the DG
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reliability and tasked the Unit Superintendent with co
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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
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was t en presente
in an pri
1990 ora
resentation by
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the VEGP f:eneral Manager and in an April 9, 1990 letter that since
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March 20. 1990, there were 18 and 19 successful consecutive starts on
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the 1A ano IB DGs, respectively, without problems or failures.
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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
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temperature alarm occurring on March 24, 1990).
The correct number of
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consecutive successful starts was 12 for the 18 DG--a number
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han that re rted by GPC to the NRC on April 9,
In considering a restart decision,
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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
reaching the NRC decision to allow Vogtle Unit I to return to power
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operation.
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he air or s arting a 8
= opera ing 1 s1
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derived from the starting air system.
The starting air system contains
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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
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for extended periods and to system repressurization following
maintenance, as documented in NRC Inspecti
No. 50-424,425/90-
19, Supplement I dated Nov
In consi ering a resta
ecision, the N
was especia y interested in
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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
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this information presented by GPC in its letter of April 9,1990 in
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reaching the decision to allow Vagtle Unit I to return to power
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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.
an
1 OG start coun s reported on pri
overs
the actual
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countsbyincludingstartsthatwerepartofthetestprogram.ll ERB
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dii' April 36,1990, the Acting VEGP Assistant General Ma
er - Plant
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
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Regional Administrator.
He also requ a ted that an audit be conducted by GPC's
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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,
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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
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starts.
The audit did not identify any specific cause for the error in the
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number reported in the LER.
The audit stated, however, that the error
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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
General Manager - Plant Support) noted that the letter was incomplete and
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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
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LER because adequate information was available when the counting errors were
made, and (3) the err
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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
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ensure that the submittal was accurate and co
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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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the Supervisor - SAER'was made aware by the
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EGP TA on June 12, 1990 t a , to identify the root cause of the error in the
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
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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
June 29, 1990 draft cover lett
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he inaccuracies in the A ril 9,
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etter
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The Vice President - Vogtle
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Project and the Senior Vice President - Nuclear Operations were actively
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involved in the preparation of the June 29 cover letter.
The VEGP General
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Manager and Vice President - Vogtle Project reviewed, and th. Senior Vice
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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
confus
in the
tinction between a successful start and a valid
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test.
uring
ugust 29, 1990 P
view Board (PRB)
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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
Superintendent was not confused about the distinction when he collected
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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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~ The August 30 letter states that the
ilresentation and the April 19 LER were
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error in the Apri
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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
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ce resident - Vogtle Project
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invol
development of the June 29 letter.
C re
ted
su
ressi
he
ril 9 letter
ice
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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
to the clearance procedures of the Office of Management and Budget as required
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by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Sincerely,
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James L. Milhoan
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Deputy Executive Director
for Nuclear Reactor Regulation,
Regional Operations,and Research
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Enclosures-
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DISTRIBUTION:
SECY
CA
JTaylor, EDO
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JMilhoan, DEDR
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JLieberman, OE
SEbneter, RII
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LChandler, OGC
JGoldberg, OGC
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WRussell, NRR
EReis, OGC
Enforcement Coordinators
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RI, RII, RIII, RIV, RV
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FIngram, GPA/PA
EJordan, AEOD
BHayes, 01
EA File
Vogtle Coordinating Group:
D. Matthews, Chairman
R. Pedersen, OE
P. Skinner, RII-
D. Hood, NRR
D. Wheeler, NRR
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D. Hoefling, OGC
M. Young, OGC
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GEORGE BOCKNOLD, JR.
General Manager at Vogtle during March - August 1990 time-
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frame.
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Sent to INPO for approximately 1 or 2 years.
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Currently serving as the General Manager of Nuclear.
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Technical Services for Southern Nuclear (promotion from
Vogtle General Manager).
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Has held current position for approximately 1 or 2 years.
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CU.rrent position considered licensed activities.
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Current position impacts operations at Vcgtle, Hatch, and
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Farley (currently conducting overview of work request
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process at all three facilities).
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Five supervisors report to him.
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Information in this record was deleted
in accordance with thje Fr edom of information
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Act, exemptions.
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