ML20128G716

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Partially Deleted Investigation Rept 2-90-020 & Insp Repts 50-424/90-19 & 50-425/90-19,Suppl 1,conducted by NRC OI at Gpc Re Reliability of DGs
ML20128G716
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 02/22/1994
From: Milhoan J
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Mccoy C
GEORGIA POWER CO.
Shared Package
ML20128F432 List: ... further results
References
FOIA-95-81 EA-93-304, EA-94-036, EA-94-36, NUDOCS 9610090107
Download: ML20128G716 (11)
v • d • e


See also: IR 05000424/1990019

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DRAFT

PREDECISIONAL INFORMATION

NOT FOR RELEASE WITHOUT THE APPROVAL OF THE DIRECTOR, OE l

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Rev. 7: VOGCOVER.R7 2/22/94

Docket No. 50-424

License No. NPF-68

EA 93-304, and EA 94-036 l

Georgia Power Company l

ATTN: Mr. C. K. McCoy i

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Vice President -

Vogtle Project

Post Office Box 1295

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Birmingham, Alabama 35201

SUBJECT: NOTICE OF VIOLATION

MAND FOR INFORMATION (NRC

TIGATIONS REPORT NO. 2-90-020 AND NRC l

INSPECTION REPORT NO. 50-424,425/90-19, SUPPLEMENT 1) i

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 l

declared a Site Area Emergency (SAE) when offsite power was lost l

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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

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

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 l

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Unit 1 to power operations. As part of this presentation, GPC

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provided information on DG starts in response to a specific NRC

request that GPC address DG reliability in its April 9 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 l

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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."

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On June 29, 1990, GPC submitted a revised LER, 50-424/90-06-01. l

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 1

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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 l

about, and allegations related to VEGP operational activities. l

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.

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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 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

l (Docket Nos. 50-424 OLA-3, 50-425 OLA-3), and other related

gformation.

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inrormation was

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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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i 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

at GPC reported in the presentation and letter included

j 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

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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i The air or starting a DG an operating its

] instruments and controls is derived from the starting air

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system. The starting air system contains dryers designed to

J maintain moisture content (i.e., dew point) at acceptable

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maintenance records and deficiency cards associated with

l Ursit I would have revealed that high dew points were also

attributable to system air dryers occasionally being out of

l service for extended periods and to system repressurization i

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following maintenance, as documented in NRC Inspection

! Report No. 50-424,425/90-19, Supplement 1, dated November 1,

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1991.

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During the preparation of the LER, the Acting VEGP Assistant

General Manager questioned the accuracy of the April 9

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letter given that there were trips on the 1B DG after

j March 20, 1990.

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In later discussions regarding the draft LER,

the General Manager, Technical Support Manager and Acting

)' VEGP Assistant General. Manager acknowledged that they could

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

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also different interpretations about what testing tha term

l CTP encompassed. The General Manager - Plant Support

! (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

i the CTP was that it would be a test program to determine

root causes and restore operabili

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l acquired the data a ised Mr. Mosbaugh and Mr. Aufdenkampe

} that he started his counts on March 20, prior to the time

! 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),

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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j in error, the Senior Vice President - Nuclear Operations

l informed the Regional Administrator that a revision to the

i April 19 LER would be submitted, in part, to correct the DG

start counts. After being provided conflicting data for the

i second time, the Senior Vice President - Nuclear Operations .

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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

j audit, completed June 29, narrowly focused on a review of

diesel records (Test Data Sheets, Shift Supervisor's Log,

j and Diesel Generator Start Log) to verify the number of DG

j starts. The audit did not identify any specific cause for

j the error in the number reported in the LER. The audit

i stated, however, that the error appeared to result from

) incomplete documentation. The audit also noted that there

apparently was some confusion about the specific int at

which the test program was completed.

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On June 29, 1990, the draft cover letter for the LER

i revision was being reviewed at the site. The draft had

originated in GPC corporate headquarters and included

i language personally developed by the Senior Vice President -

j Nuclear Operations and the Vice President - Vogtle Project.

j During the site review, a VEGP Technical Assistant (TA)

l (formerly the Acting VEGP Assistant General Manager - Plant

j Support) noted that the letter was incomplete and challenged

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

j in conversations with the Supervisor - Safety Audit and

i Engineering Review (SAER), the VEGP Assistant General

Manager - Plant Support, the VEGP Manager - Engineering

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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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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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August 30 letter states that the error in the April 9 letter '

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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submittal.

While un ertoo

e April 19 LER, it narrowly focused only on that

For example, GPC conducted an audit, the scope

of which was limited to review of DG records, in an attempt

to correct the start count reported in the April 19 LER.

efforts to

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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

April 9 letter. As of August 17, 1990, the VEGP General

Manager and the Vice President - Vogtle Project were aware

i of NRC concerns regarding the errors in, and the misleading

l nature of, the April 9 letter. The Vice President - Vogtle

l 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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! evaluation was initiated. cause

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Rather, GPC forwarded a submittal

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regarding the April 9 letter on August 30 that was drafted

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

j particular time-frame and made a general observation that GPC

avbihirad a closed. adversarial attitude toward the NRC. M

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l 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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l Enclosures *

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2. Demand For Intornation

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