ML20128G716
See also: IR 05000424/1990019
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DRAFT
PREDECISIONAL INFORMATION
NOT FOR RELEASE WITHOUT THE APPROVAL OF THE DIRECTOR, OE
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Rev. 7:
VOGCOVER.R7
2/22/94
Docket No.
50-424
License No.
Georgia Power Company
ATTN:
Mr.
C.
K. McCoy
Vice President -
Vogtle Project
Post Office Box 1295
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Birmingham, Alabama
35201
SUBJECT:
MAND FOR INFORMATION (NRC
TIGATIONS REPORT NO. 2-90-020 AND NRC
INSPECTION REPORT NO. 50-424,425/90-19, SUPPLEMENT 1)
This refers to the investigation conducted by the Nuclear
Regulatory Commission's Office of Investigatione (OI) at Georgia
Power Company's (GPC) 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 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 (1B) was unavailable due to
maintenance activities.
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
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actions had been taken, and that the plant could safely return to
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power operations,
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Information in this record was deleted
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in arrordance with the fjeedom of Information
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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
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Unit 1 to power operations.
As part of this presentation, GPC
provided information on DG starts in response to a specific NRC
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request that GPC address DG reliability in its April 9
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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
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Unit 1 to return to criticality and resume power operations.
On April 19, 1990, pursuant to 10 CFR 50.73, GPC submitted
Licensee Event Report (LER) 50-424/90-06, " Loss of Offsite Power
Leads to Site Area Emergency."
On June 29, 1990, GPC submitted a revised LER, 50-424/90-06-01.
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The purpose of the submittal was to clarify information related
to successful DG starts that were discussed in the April
9,
1990
letter and the April 19, 1990 LER, and to update the status of
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corrective actions in the original LER.
From August 6 through August 17, 1990, the NRC conducted a
Special Team Inspection at VEGP, as a result of NRC concerns
about, and allegations related to
VEGP operational activities.
This inspection examined the technical 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 I, dated November 1991.
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 reviewed the evidence associated with these
events, submittals, and representations to the NRC.
Specifically, the NRC reviewed information gathered as part of
the OI investigation, informat'
gathered during the IIT, NUREG-
1410, Supplement 1 of NRC Inspr
, ion Report 90-19, discovery
responses in the Vogtle operating license amendment proceeding
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(Docket Nos. 50-424 OLA-3, 50-425 OLA-3), and other related
gformation.
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inrormation was
pril
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1990 oral
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presentation by the VEGP General Manager and in an April
9,
1990 letter that there were 18 and 19 successful consecutive
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starts on the 1A and 1B DGs, respectively, without problems
or failures.
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the 19 troub e-free star s for the 1B
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at GPC reported in the presentation and letter included
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three starts with problems that occurred during DG
overhaul / maintenance activities (a high lube oil temperature
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trip on March 22, 1990; a low jacket water pressure / turbo
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lube oil pressure low trip on March 23, 1990; and a failure
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to trip on a high jacket water temperature alarm occurring
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on March 24, 1990).
The correct number of consecutive
successful starts was 12 for the 1B DG--a number
less than that reported by GPC to the NRC on
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The air
or starting a DG an
operating its
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instruments and controls is derived from the starting air
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system.
The starting air system contains dryers designed to
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maintain moisture content
(i.e., dew point) at acceptable
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maintenance records and deficiency cards associated with
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Ursit I would have revealed that high dew points were also
attributable to system air dryers occasionally being out of
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service for extended periods and to system repressurization
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following maintenance, as documented in NRC Inspection
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Report No. 50-424,425/90-19, Supplement 1, dated November 1,
1991.
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During the preparation of the LER, the Acting VEGP Assistant
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General Manager questioned the accuracy of the April 9
letter given that there were trips on the 1B DG after
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March 20, 1990.
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In later discussions regarding the draft LER,
the General Manager, Technical Support Manager and Acting
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VEGP Assistant General. Manager acknowledged that they could
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not identify the specific DG start that represented the
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starting point for the count presented to the NRC,
i.e.,
the
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first start following completion of the CTP.
There were
also different interpretations about what testing tha term
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CTP encompassed.
The General Manager - Plant Support
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(Vogtle Project), the VEGP Technical Support Manager, and
the Acting VEGP Assistant General Manager 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 stated that his understanding of
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the CTP was that it would be a test program to determine
root causes and restore operabili
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Superintende
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acquired the data a
ised Mr. Mosbaugh and Mr. Aufdenkampe
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that he started his counts on March 20, prior to the time
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when a CTP could have been completed.
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the 1A and 1B DG start counts
reported on April 19,
(and earlier on April 9),
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overstated the actual counts by including starts that were
part of the test program.
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the Acting VEGP Assistant General Manager - Plant Support
gave the VEGP General Manager a listing of 1B DG starts
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After being informed that the April 19 DG start counts were
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in error, the Senior Vice President - Nuclear Operations
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informed the Regional Administrator that a revision to the
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April 19 LER would be submitted, in part, to correct the DG
start counts.
After being provided conflicting data for the
Nuclear Operations
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second time, the Senior Vice President
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again notified the Regional Administrator.
He also
requested that an audit be conducted to establish the
correct data and to determine why the errors were made.
The
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audit, completed June 29, narrowly focused on a review of
diesel records (Test Data Sheets, Shift Supervisor's Log,
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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
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the error in the number reported in the LER.
The audit
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stated, however, that the error appeared to result from
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incomplete documentation.
The audit also noted that there
apparently was some confusion about the specific
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which the test program was completed.
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On June 29, 1990, the draft cover letter for the LER
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revision was being reviewed at the site.
The draft had
originated in GPC corporate headquarters and included
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language personally developed by the Senior Vice President -
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Nuclear Operations and the Vice President - Vogtle Project.
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During the site review, a VEGP Technical Assistant (TA)
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(formerly the Acting VEGP Assistant General Manager - Plant
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Support) noted that the letter was incomplete and challenged
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the accuracy of the reasons stated in the draft cover letter
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in conversations with the Supervisor - Safety Audit and
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Engineering Review (SAER), the VEGP Assistant General
Manager - Plant Support, the VEGP Manager - Engineering
Support, and a Licensing Engineer - Vogtle Project.
The
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VEGP TA stated that: (1) the letter failed to clarify the DG
starts reported on April
9,
(2) DG record keeping practices
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
erroneous counts resulted from personnel errors in
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d a'ta l an i nrv +ho r tiin nt .
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The Vice President - Vogtle Project and the
Senior Vice President - Nuclear Operations were actively
involved in the preparation of the June 29 cover letter.
The VEGP General Manager and Vice President - Vogtle Project
reviewed, and the Senior Vice President - Nuclear Operations
signed, the June 29 cover letter which stated that its
purpose was, in part, to clari
information provided to the
NRC on April 9.
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the April 9,
1990 letter.
The letter
stated that the errors in the April 9 letter and
presentation and the April 19 LER were caused, in part, by
confusion in the distinction between a successful start and
During the August 29, 1990
Plant Review Board meeting, the 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 used 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 Unit
Superintendent was not confused when he developed the
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inrnematinn
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The
August 30 letter states that the error in the April 9 letter
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and presentation and the April 19 LEP were caused, in part,
by an error made by the individual who performed the count
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While
un ertoo
efforts to
e April 19 LER, it narrowly focused only on that
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submittal.
For example, GPC conducted an audit, the scope
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of which was limited to review of DG records, in an attempt
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to correct the start count reported in the April 19 LER.
Furthermore, in its June 29 submittal, while GPC referred to
both the April 9 letter and the April 19 LER, it attempted
to explain only the reasons for the error in the April 19
LER.
The Senior Vice President - Nuclear Operations and the
Vice President - Vogtle Project were directl
involved in
the development of the June 29 letter.
Subsequently,
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the NRC requested that GPC make a submittal addressing the
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April 9 letter.
As of August 17, 1990, the VEGP General
Manager and the Vice President - Vogtle Project were aware
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of NRC concerns regarding the errors in, and the misleading
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nature of, the April 9 letter.
The Vice President - Vogtle
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Project committed during the August 17 meeting with the NRC
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special inspection team to provide clarification to the NRC
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regarding the April 9 letter.
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cause
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evaluation was initiated.
Rather, GPC forwarded a submittal
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regarding the April 9 letter on August 30 that was drafted
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at corporate headquarters under the direction of the Vice
President - Vogtle Project, without an assessment of the
actions of the VEGP General Manager and the Unit
Superintendent who developed erroneous information for the
AJril 9 letter.
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It is our understanding that
Mr. Bockhold is currently working T'or Southern Nuclear as the
General Manager of Nuclear Technical Servic
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investigation primarily focused on actions and communications
involving the DGs, OI also reviewed other communications within a
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particular time-frame and made a general observation that GPC
avbihirad a closed. adversarial attitude toward the NRC. M
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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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Demand For Intornation
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