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NUCLEAR REGULATORY COMMISSION e
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j OFFICE oF INVESTIGATIONS FIELD OFFICE. REGloN ll 101 MARIETTA STREET NW, SUITE 2900 e,
a ATLANTA, GEORGIA 303Z3 i
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April 20, 1994 t
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I MEMORANDUM FOR:
Ben B. Hayes, Director l
Office of Inves~ti afians
' fames Y.
AMs t
FROM:
- rse, rec or i
Office of Investigations Field Office, Region II 4
L
SUBJECT:
NOTIFICATION OF INVESTIGATION i
CASC NO. 2-94-013R 4
^
1 GEORGIA POWER COMPANY 50-424. 50-425 l'
Licensee / Vendor / Applicant Docket No./ License No.
i V0GTLE ELECTRIC GENERATING PLANT N/A Facility or Site Location Allegation No.
I A.
Title of Investiaation: ALLEGED FALSIFICATION OF A BATTERY CELL j
MAINTENANCE DATA SHEET i
What is the matter being investigated?
This investigation was initiated to r;etermine whether the falsification of a battery cell maintenance data tet, by a Vogtle technician, was
[
1 deliberate.
This matter surfaced as.a result of an NRC Region 11 inspection, and was presented at a pre-enforcement panel.
i B.
Purcose of Investiaation 1.
What is the basis for belief that the violation of a regulatory requirement is more likely to have been intentional or to have 3
i resulted from careless disregard or reckless indifference than from j
error or oversight?
i i
The licensee conducted its own investigation of this matter and l
determined that deliberate falsification of this data sheet had S
occurred. The licensee has terminated the individual involved. Per.
1 Region 11 counsel, the potential regulatory violations are 10 CFR 50.5 (wrongdoer rule) and 10 CFR 50.9 (inaccurate information -
written).
1 1
2.
What are the potential regulatory requirements that may have been violated?
If no violation, what is the specific regulatory concern?
f Potential regulatory violations are:
./ I 10 CFR 50.5 (wrongdoer rule) j/ [
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10 CFR 50.9 (inaccurate or incomplete information - written) 4
/'
ION --Jierf6idWHL1LDHCtostmE_W/04HWPROJAL i
,,KOHN95-211_
f DR.
e m.
I Ben B. Hayes 2
April 20, 1994 i
3.
What : staff members were coordinated with to determine these requi'rements or concerns? (Regional Counsel, etc.)
Ctrolyn F. Evans
- Regional Counsel Bruno Uryc
- Acting Director, EICS Linda J. Watson
- Acting Enforcement Coordinator Johns P. Jaudon
- Division of Reactor -Projects Pierce H. Skinner Division of Reactor Projects C.
Technical titaff Priority 1.
What is the priority of the investigation?
Low 2.
What is the initial estimated completion date (ECD) of this inytstigation, based upon facts and' circumstances known today?
ECD - 09/94 3.
What staff members were coordinated with to determine priority?
Stewart D. Ebneter - Regional Administrator i
D.
01 Cair Investicator/ Telephone No.
Larry L. Robinson - (404) 331-6509 A
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$UTJOR 0
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FUNCICLEARANCE#[..,.,,.1940@l3 STATUS A UNIT 1 MPL/ TAG 11562N7002M01 SYS 1562 EQP DESC CB ELEC PEN FLT UNT FAN M REASON IMPLEMENT MDD I
. INSTRUCT.
CONT N'-
1 MWO # LIST OUTAGE: TIME CODE
- REQUIRES LCO (Y/N) N CLEAR CONT SHEETS (Y/N)
I INDEPENDENT VERIFICATION (Y/N) Y SUBCLEAR CONT SHEETS (Y/N)
FIRE PROT. IMPAIR / NOTIFY (Y/N) N'
. FIRE PROT RESTORED / NOTIFY (Y/N) j j
LOCKED VALVES INVOLVED (Y/N) N LOCKED VALVES RESTORED (Y/N)
TRANSMITTAL #
LOCKED VALVES SHEET
~
) 'SCHED. DATE SCHED. TIME 0000 REQUEST DATE TIME 0000 i
REQUESTED BY EXT BEEP i iPREPARED/ DRAFTED BY R.DUNCAN DATE 02/01/94 i
REVIEWED'BY W.A. BUCHANAN DATE 02/23/94.
- - - - - - - - - - - - - - CLEARANCE INiiTALLATION - - - - - - --------
I AUTHCRIZED BY S.M.-ALLISON DATE 03/01/94 TIME 0640 INSTALLED BY P. M. HUNT DATE 03'/01/94 TIME 0750
)~ VERIFIED /ACTIVEBY T. MORRIS DATE 03/01/94 TIME'0843
- - - - - - - - - - - - - CLEARANCE REMOVAL - - - - - - - - - - - -
AUTHORIZED BY DATE TIME 0000 REMOVED BY DATE TIME 0000 VERIFIED / INACTIVE BY DATE TM j - ---------------------------------------------------------------- 0000 l
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CLEARANCE &' TAGGING FILE (2 OF 4) 8 :21:5!!
EM PAGE 2 FUNC I CLEARANCE # 19400134 i
STATUS A UNIT 1 MPL/ TAG 11562N7002M01 SYS 1562
- - - - - - - - - - - - - - HOLDPOINTS/ EQUIPMENT - - - - - - - - - - - - - - -
1 HOLDPNT/EQP 1HS2555 FI N AI l
SEQ # SUB POSITION OLD ACT N BV SEQ # SUB POSITION l
TAGGING 001 P.T.L.
REMOVAL
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DESC CONT SW FOR ELEC PEN RM HVAC 1-1562-N7-002-M01 1X3DBGD02T/
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DOC REF# 1X3DBGD01P#
DESC CONT SW (QHVC) FOR 1HV-2636B,ELEC PEN FILTER UNIT INLET DAMPER CURRENT HOLDPNTS/ EQUIP PAGE 001 NEXT HOLDPNTS/E
________________________________________________________ QUIP PAGE DR COMPLETE TRANSACTION FIRST PAGE
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- - - - - HOLDPOINTS/ EQUIPMENT - -
HOLDPNT/EQP 1BB0709 FI N AI SEQ # SUB POSITION OLD ACT N BV SEQ # SUB POSITION TAGGING 004 R.O.
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DESC POWER, SUPPLY'FOR 1-1562-N7-002-M01 1X3DBGD02T/
HOLDPNT/EQP 1BBC36 FI N AI SEQ # SUB POSITION OLD ACT N BV SEQ # SUB POSITION TAGGING 005-OPEN REMOVAL LOCATION 1CBB67 LOCK #
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DESC POWER SUPPLY FOR ELEC PEN HVAC HTR 1-1562-N7-002-H01 1X3DBAE02Y /
HOLDPNT/EQP 1BBC36W LINK 36-1 FI N AI SEQ # SUB POSITION' OLD ACT.N BV SEQ # SUB POSITION TAGGING 006 OPEN REMOVAL LOCATION LOCK #
DOC REF#
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DESC MCC1BBC, SECT 7R,MTB1BBC36W, LINK 36-1; ALARM CIRCUIT FOR 1BBC36 X3DOAF N s
CURRENT HOLDPNTS/ EQUIP PAGE 002 NEXT HOLDRCS/ EQUIP PAGE AA2 COMPLETE TRANSACTION
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NEXT PAGE 2 FUNC I CLEARANCE # 19400134 STATUS A UNIT 1 MPL/ TAG 11562N7002M01 SYS 1562
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HOLDPNT/EQP 1ACQHVCl-FU6-1-R FI N AI SEQ # SUB POSITION OLD ACT N BV SEQ # SUB POSITION TAGGING 013 FUSEPULLED 012 REMOVAL LOCATION LOCK #
DOC REF# 1X5AB01-314 DESC 1ACQHVC1, SECT. 1,F.B. FU6-1,RIGHT FUSE, PULL, BAG,& TAG: PWR TO 1HV2636A HOLDPNT/EQP 1ACQHVCl-FB'6-1-R FI N AI SEQ # SUB POSITION OLD ACT N BV SEQ # SUB POSITION TAGGING 014 UNFUSED 013 REMOVAL LOCATION LOCK #
DOC REF# 1X5AB01-314 p
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DOC REF# 1X5AB01-298 /
DESC 1BCQHVC1, SECT.
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FU1-3,LEFT FUSE, PULL, BAG & TAG: PWR TO 1HV2636B -
CURRENT HOLDPNTS/ EQUIP PAGE 005 NEXT HOLDPNTS/ EQUIP PAGE D.D5 COMPLETE TRANSACTION
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NEXT PAGE 2 FUNC I' CLEARANCE # 19400134 STATUS A UNIT 1 MPL/ TAG 11562N7002M01 SYS 1562
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HOLDPNT/EQP 1BYC118 FI N AI l
SEQ # SUB POSITION OLD ACT N BV SEQ # SUB POSITION TAGGING 010 OFF 000 REMOVAL l
LOCATION 1CBB67-LOCK #
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DESC CB ELEC PEN FLTR UNIT HUMIDITY CONTROLLER 1-1562-N7-002-000
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HOLDPNT/EQP 1ACQHVC1-FU6-1 L PI N AI SEQ # SUB -POSITION OLD ACT N BV SEQ # SUB POSITION TAGGING 011 FUSEPULLED 010 REMOVAL
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DOC REF# 1X5AB01-314 #
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'{ ~DESC 1ACQHVC1, SECT. 1,F.B. FU6-1,LEFT FUSE, PULL, BAG,ETAG: PWR TO 1HV2636A l
HOLDPNT/EQP 1ACQHVC1-FB6-1-L FI N AI l
SEQ # SUB POSITION-OLD ACT N BV SEQ # SUB POSITION TAGGING 012 UNFUSED 011 REMOVAL LOCATION LOCK #
DOC REF# 1X5AB01-314 /
DESC 1ACQHVC1, SECT.*1, FUSE BLOCK FU6-1,LEFT FUSE HOLDER 1
CURRENT HOLDPNTS/ EQUIP PAGE 004 NEXT HOLDPNTS/ EQUIP PAGE AQ1 COMPLETE TRANSACTION
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FUNC I CLEARANCE # 19400134 STATUS A UNIT 1 MPL/ TAG 11562N7002M01 SYS 1562
- - HOLDPOINTS/ EQUIPMENT - - - - -----------
1 HOLDPNT/EQP 1BYC114 FI N AI l
SEQ # SUB POSITION OLD ACT N BV SEQ # SUB POSITION TAGGING' 007 OFF REMOVAL j
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DESC PWR SUPPLY FOR MOTOR HEATER FOR 1-1562-N7-OO2-M01 1X3DBGD02T j -~TMYfiEGM;gg FI N AI
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FUNC I CLEARANCE # 19400134 STATUS A UNIT 1 MPL/ TAG 11'362N7002M01 SYS 1562 TECH SPEC NUMBERS LCO NUMBERS SI NUMBERS LOC 3.8.2.1/2 4
P&ID 1X4DB209 F3 3.8.3.1/2 MECH i
ELEM 1X3DBGD02T ELEC 1X3DAAE07A F-4 CONN MWO # ' S '
i 19400147 19400414 19400413 19401062 CURRENT MWO PAGE 01 NEXT MWO PAGE 21 4j REFERENC 1X3DAAF04A
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Filo: REA 94.VAA025 Log' SG13301 X45H06 Securitycode: NC Faet.at' Far Nois 7971 out pg,> J 4
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PotOfEseBos 1298 Birminghem, Alabama 15201 l
Dee,Mr.Myer:
l This is a Anal response to REA 94 VAA025 which requests an evaluation of the Unit 1 i
l Ausliary Building Pip *.ng Penetrat os Ares 7'irration and Exhaust System (PPAPES) with l
respwt to inadvertently de. energized stan exhaust dampers, The stack exhaust dampers (1P%2550B & IP%25515) are designed to o;en to a preset positionwhen the PFAFES l
is started in order te maintain a nesa6e pensure in the piping penetration tres. The PPAFES maintains the area under a negativc pressure to ensure that radioactive me' l
leakag Som the mechanical penetrat!m rows ar.d ECCS equipment ars flhered Mor is ressblagthe environment.
i l
Sirus the FPAFES is normally in standby, tne stack exhaust dampers would have been de.
ene3 :ed in the closed position. With thne dampers closed, the PPAFES could not 1
i maintain the piping penetration sres unde: a r.cgetive pressure, ponsMy a!!owing airborne rad.oactive material in the area served by the PPAFES to escape to the environment without passing through the filter syr.em. Fct the purposes of this evaluation,it is assumed that all siroorne radionedve rnatenals ho:r the mechanical penetration rooms and P.LCS stuipmem are released diree'.ly te 11 t c.W.ronmer.t.
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. April:3,1994 xenos Page 3 Legi SS.13303 Titlatent sahey evaluation for the PPAPBS associated with amendments 52 and 31 to operating licenses NPF48 and 81, esewnes ICCS lodine leakase is 2 sPm and in tha brra proselhed byRegulatory Guide 1.1, i.e. 9;% elemental,4% organic, and 5% porticulate.
i-i Further, the Star eSciencias are sasumed to be 9W., 30%, and 90% respectively. The composhe eSolencythenwould be:
l
(.91x.9+ 04x.3+.05x.9) =,176 or approxirantely 90%.
i i
The complete ey of the FPAFES rasy then increase the BCCs leakage contributionto o alte and comrci reem deset by a fheter of W n 10.
l However, the ounent ECCS leakage value hand on Technica! Sp+Non 6.7.4 is less i
than 0.1 spm, and historically t%. vrke has h.en less than 0.2 spm, therefore the ecpacted l
source term would be a factor cf 10 leu than usumed in the current does analysis. The l
not effect wo4d be that the EAB, LPZ, and C orr.rol Room doses as shown in the SER would remain essentially unchanged and wt.hin the.10 CFR 100 and GDC 19 acc4 j:
cdteria. This evaluation is conxMth's ft3 t.e' fb'!cwing fossons; 5
l During the pedod of dme that be staA ces r dampers were closed, the PPAT".5 l
ree!re.datiervfttretion sapabilit;' re:nalixd fc nettosa:. With exception of severs! p!p'ng g,..r.ssion rooms, ECCS eqWpraent subjo:t t post.LOCA recirculation toep leakage is locsted in rooms not a(acent to dira:t atme: der's release pathways,1.c. ECC5 leakaga j
would occur in rooms interior to th6 auxf.lary building and below grada, and would have to be transponed through severs! rooms prio te r Isase to the straosphere, Leekege through the containment isolation valve: into the piping penetration rooms is usumed to
)
leak directly to the atmosphere Wthouyroeru!ng or holdup. Rossuse the PPAPES recirculatieVfiltration f.mstion remairec Swiena!, ECCS leakaga to the Interior compartments of the auxiliary bu!1 ding would be expected to be filtered prior to transport j
to other rooms a4acent to semotpheri;haktge pathwsys. Leakage which difLeed l
throughout the building and bypassec' de f. iter unit would havelong tortuous patWP 'r fb!10w and would be subject to s'ar3r.w r.atural removal processes along the way j
(sett1 Lag, plateout, etc.). Further, as ind!:a:ci in the bases of the Technical Spec!Fet i
the heaters in the PPAFES are maln:ained for defense in depth. Thus the expected remova! e5eiency for the reciredatior.?.hrstion.tnction would be in excess of that orodhedin the SEIL In conclusion, inadvertently de energizing the PPAPES stack exhaust dampers would not j
have ssdted in exceeding the o5 site 2nd cmtml room dose limitations of to CFR 100 and GDC 19 respective %.
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Mr. C. A,i4c File: REA 94 VAA025 Ap.il 28,1994 X4RM06 Page 3 Los 1043303 This evaluation hu been reviewed with MWt!!!aes ef SNC.
Ifyou how any questions, pleau centset & Hayrs at extension 6852.
Verytrulyyours, k
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Docket No.
50-424 i
License No. NPF-6B
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EA 93-304, EA 94-036, EA 94-037, and EA 94-052 l
i Georgia Power Company 4
ATTN: Mr. H. Allen Franklin i.
President and Chief Executive officer 333 Piedmont l
At1anta, Georgia 30323 i
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES -
i
$200,000, AND DEMANDS FOR INFORMAT W4 (NRC Office of Investigations Report No. 2-90-020 and NRC Inspection Report No. 50-424,425/90-19, Supplement 1) 1 This refers to the investigation conducted by the Nuclear Regulatory j.
Commission's Office of Investigations (01) at Georgia Power Company's (GPC or
. Licensee) Vogtle Electric Generating Plant (VEGP) which was completed on 1
December-17, 1993. The investigation was initiated as a result of information 1
j.
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 Generatcas (DGs). The pertinent events involved in j
this matter are described below.
l 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
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failure of the only Unit 1 DG that was available (IA).
The other Unit 1 DG 1
(18) was unavailable due to maintenance activities.
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The NRC inmediately responded to the SAE at the VEGP site with an Augmented l
-Inspection Team (AIT). The NRC effort was upgraded to an Incident f
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 Ouring Mid-Loop Operations at Vogtle Unit 1 on i
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
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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
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in support of GPC's request to return VEGP Unit I to power operations. As part of this' presentation, GPC provided information on DG starts in res to a specific NRC request that GPC address DG reliability in its April 9 b
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1 presentation.
GPC submitted a written summary of its April 9 presentation in i
an April 9,1990 letter, "Vogtle Electric Generating Plant Confirmation of f
Action Letter."
J i
'1 On April 12, 1990, the NRC formally granted permission for VEGP Unit I to l
return to criticality and resume power operations.
On April 19, 1990, pursuant to 10 CFR 50.73, GPC submitted Licensee Event i
Report (LER) 50-424/90-006, " Loss of Offsite Power Leads to Site Area Emergency."
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 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 Team 1
Inspection at VEGP, as a result of NRC concerns about, and allegations related j
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 i
documented, in part, in NRC Inspection Report No. 50-424,425/90-19, l
Supplement 1, dated November 1, 1991.
1 1
i 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 01 investigation, information gathered i
during the IIT, NUREG-1410, Supplement 1 of NRC Inspection Report 90-19, discovery responses in the Vogtle operating license amendment proceeding (Docket Nos. 50-424 OLA-3, 50-425 OLA-3), and other related information.
i After careful and considerable deliberation, the NRC has concluded that the i
five violations described in the enclosed Notice of Violation and Proposed i
Imposition of Civil Penalties (Notice) resulted from the repeated failure of various levels of GPC management on a number of occasions from April 9 to 1
August 30, 1990 to provide the NRC with information that was complete and l
accurate in all material respects.
Each of these violations is discussed below.
Violation A:
Inaccurate DG Start Counts Reported in April 9, 1990 Restart i
Briefing and CAL Response Letter.
j The first violation that occurred (Violation A) involves the inaccurate DG start information that was provided in response to a specific NRC l
request that GPC address the issue cf DG reliability in the 1
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April 9, 1990 presentation and letter. The root causes of this violation were '(1) the failure of the VEGP General Manager in directing i
.the Unit Superintendent to collect DG start information and in assessing 3
what the Unit Superintendent gave him before he provided the DG start 4
information to the NRC and (2) the failure of the Unit Superintendent in performing and reporting his count. The VEGP General Manager was personally involved in the preparation of the data regarding the DG reliability and tasked the Unit Superintendent with collecting the number of successful DG starts for the 1A and IB DGs.. Although The VEGP General Manager was aware of problems on the IB DG during overhaul, he i
failed to adequately specify the starting point for the count to ensure that the count did not include these problems and failed to ensure that j
the Unit Superintendent understood his criteria for " successful starts."
In fact, the VEGP General Manager stated no criteria for successful starts, a term not formally defined, when he directed the Unit 4
Superintendent to gather successful DG starts. The Unit Superintendent l
collected DG start data from the Control Room Log and the Shift i
Supervisor's Log without determining from the VEGP General Manager when to start the counts and orally conveyed totals to the VEGP General Manager for the 1A and IB diesels. The VEGP General' Manager did not 1
determine the point at which the Unit Superintendent began his count I
(i.e., the specific start number, date or time) or whether the Unit Superintendent's data included any problems or failures.
Information was then presented to the NRC in an April 9,1990 oral presentation by l
the VEGP General Manager and in an April 9,1990 letter that since i
March 20, 1990, there were 18 and 19 successful consecutive starts on the 1A and IB DGs, respectively, without problems or failures.
By failing to specify or verify the starting point for the count, the 19 i-trouble-free starts for the IB DG that GPC reported in the presentation and letter included three starts with problems that occurred during DG overhaul / maintenance activities (a high lube oil temperature trip on I
March 22, 1990; a low jacket water pressure / turbo lube oil pressure low trip on March 23, 1990; and a failure to trip on a high jacket water l
temperature alarm occurring on March 24,1990). The correct number of consecutive successful starts was 12 for the IB DG--a number significantly less than that reported by GPC to the NRC on April 9, i
1990. The inaccuracy was material.
In considering a restart decision, l
the NRC was especially interested 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 j
reaching the NRC decision to allow Vogtle Unit I to return to power j
operation.
i Violation B:
Incomplete Information Regarding DG Starting Air Quality in April 9, 1990 CAL Response Letter.
Violation B involves the failure of GPC to include complete information regarding DG starting air quality in its April 9 letter. The air for i
starting a DG and operating its instruments and controls is derived from the starting air system. The starting air system contains dryers l
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designed to maintain moisture content (i.e., dew point) at acceptable j
levels.
GPC presented an incomplete discussion regarding control of dew points in its April 9,1990 letter by only stating that initial reports l
of high dew points were attributed to faulty instrumentation. A review of maintenance' records and deficiency cards associated with Unit I would
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I have revealed that high dew points were also attributable to system air
- dryers occasionally being out.of service for extended periods and to system repressurization following maintenance, as documented in NRC Inspection Report No. 50-424,425/90-19, Supplement 1, dated November 1, i
1991. This information should have been included in the April 9 letter.
The incompleteness was material.
In considering a restart decision, the NRC was especially interested in the reliability of the DGs and i
specifically asked that GPC address the matter in its presentation on restart. The NRC relied, in part, upon this information presented by l
GPC in its letter of April 9,1990 in reaching the decision to allow i
Vogtle Unit I to return to power' operation.
i Violation C:
Inaccurate DG Start Counts Reported in April 19, 1990 LER.
j Violation C involves the inaccurate number of DG starts subsequent to the controls systems being~ subjected to a " comprehensive test program" 3
(CTP) that were reported in the April 19, 1990 LER. The root causes for i
this violation were as.follows.
First, the VEGP General Manager inappropriately used the term CTP in the LER since this term failed to adequately identify when the reported count of consecutive successful DG j
starts began.
Second, the General Manager - Plant Support (Vogtle Project) and the VEGP Technical Support Manager, in the preparation of the April 19 LER, did not fully understand the term CTP (in light of the different interpretation of the tern CTP raised by the Acting VEGP l-Assistant General Manager - Plant Support, these individuals were on
- notice that the term was either imprecise or ambiguous). Third, the Acting VEGP Assistant General Manager - Plant Support failed to resolve i
his concern about the accuracy of the DG start counts prior to issuance of the April 19 LER.'
i 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, 1990 letter given i
that there were trips on the IB DG after March 20, 1990.
In order to l
address concerns that a count beginning on March 20 would include trips, i
the VEGP General Manager confirmed that the start count reported on April 9 began later than the trips--after completion of a CTP of the DG l
control systems.
In agreeing to the use of the term CTP in the LER, the 1
VEGP General Manager should have recognized that the term CTP was l
inadequate to specify the start point for the April 9 start count that 4
he intended.
In later discussions regarding the draft LER, the General 4
Manager, Technical Support Manager and Acting VEGP Assistant General Manager - Plant Support acknowledged that they could not identify the i
j specific DG start that represented the starting point for the count presented to the NRC, i.e., the first start following completion of the i
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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 would be a test program to determine root causes and restore operability. These three individuals collectively failed to clarify the term CTP before issuance of the LER.
l In. fact, the Unit Superintendent who collected the original April 9th data advised the Acting VEGP Assistant General Manager - Plant Support and the VEGP Technical Support Manager that he started his counts on j
March 20, prior to the time when a CTP could have been completed.
It was reasonable to conclude that the CTP ended with the completion of the j
- surveillance test and declaration of diesel operability, thus resulting i
in 10 and 12 starts for the iA and IB DG, respectively.
Consequently, i
the'1A and IB DG start counts reported on April 19, 1990 overstated the i
actual. counts by including starts that were part of the test program.
l The inaccuracy was material in that knowledge by the NRC of a lesser i
number of consecutive successful starts on IA DG and IB DG without i.
problems or failures could have had a natural tendency or capability to l
cause the NRC to inquire further as to the reliability of the DGs.
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l-Violation D:
Inaccurate and Incomplete Information Reported in June 29, 1990 LER' Revision Cover Letter.
Violation D involves three instances in which inaccurate and incomplete information was provided in the-June 29, 1990 LER revision cover letter.
l The first instance involves GPC's failure to include information clarifying the April'9, 1990 letter.
In this instance,.GPC failed to i
correct the omission after being notified that the letter failed to i
include information to clarify the DG start counts reported in the April J
i 9, 1990 letter, even though the letter stated that its purpose was, in part, to provide this clarification. The incompleteness was material in j
that the NRC subsequently requested GPC to make a submittal clarifying j
the April 9, 1990 letter.
The second instance involves GPC's failure in erroneously attributing DG start record keeping practices as a reason for the difference between i
the DG starts reported in the April 19 LER and in the June 29 LER revision.
GPC failed to correct the error after being informed of it prior to issuing the letter. As a result, the June 29 cover letter contained an incorrect reason for the difference between the DG 2 tarts reported in the April 19 LER and in the June 29 revision. The inaccuracy was material in that it cotild have led the NRC to erroneously conclude that the correct root causes for the difference in the number of diesel starts reported in the April 19, 1990 LER and the June 29, 1990 letter had been identified by GPC.
The third instance involves GPC's failure to state that the root causes for the difference between the DG start counts in the April 19 LER and
Georgia Power Company E - 9 994
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the' June 29 letter were personnel errors. Again, GPC failed to adequately resolve a concern raised during the review of the June 29 letter that the root causes for the reporting errors on April 19, 1990 were personnel error. As a result, GPC stated reasons in the cover 4
j letter that were incomplete.
The incompleteness was material in that, had correct root causes for the difference in the number of diesel starts reported in the April 19, 1990 LER and the June 29, 1990 letter i
been presented, this information could have led the NRC to seek further
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information.
A brief review of the facts surrounding Violation D is useful to characterize j
the significance of the Licensee's inadequate performan!:e on this matter. On April 30, 1990, the Acting VEGP Assistant General Manager - Plant Support gave l.
the VEGP General Manager a listing of IB DG starts, which, when confirmed on May 2, 1990, definitively showed that the start counts reported in the April 9 presentation, the April 9 CAL response, and the April 19 LER were incorrect.
After.being informed that the April 19 DG start counts were in error, the Senior Vice President - Nuclear Operations informed the Regional Administrator i
'that a revision to the April 19 LER would be submitted, in part, to correct i
the DG start counts. After being provided conflicting data for the second i
time, the Senior Vice President - Nuclear Operations again notified the i
Regional Administrator. He also requested that an audit be conducted by GPC's i
Safety Audit and Engineering Review (SAER) group to establish the correct data j
and to determine gby the errors were made. The audit, completed June 29, narrowly focused on a review of diesel records (Test Data Sheets, Shift Supervisor's Log, and Diesel Generator Start Log) to verify the number of DG starts. The audit did not identify any specific cause for the' error in the i
number reported in the LER.
The audit stated, however, that the error i
appeared to result from incomplete documentation. The audit also noted that i
there apparently was some confusion about the specific point at which the test program was completed. The audit was insufficient in scope, as it did not examine the performance of the VEGP General Manager and the Unit i
Superintendent in collecting the' initial data. Thus, it did not identify their inadequate performance as the root causes for the erroneous information j
reported on April 9 and in the April 19 LER.
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 -
l Nuclear Operations and the Vice President - Vogtle Project. During the site review, a VEGP Technical Assistant (TA) (formerly the Acting VEGP Assistant j.
General Manager - Plant Support) noted that the letter was incomplete and i
challenged the accuracy of the reasons stated in the draft cover letter in i.
conversations with the Supervisor - SAER, the VEGP Assistant General Manager -
Plant Support, the VEGP Manager - Engineering Support, and a Licensing i
Engineer - Vogtle Project. The VEGP TA stated that: (1) the letter failed to 1-clarify the DG starts reported on April 9, (2) DG record keeping practices I
were not a cause of the difference in the DG starts reported in the April 19 i
LER because adequate information'was available when the counting errors were j
made, and (3) the erroneous counts resulted from personnel errors in l:
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Georgia Power Company MAY - 91994 i
developing the count. The Licensin; Engineer - Vogtle Project, the VEGP j
Assistant General Manager, the Supervisor - SAER, and the VEGP Manager -
Engineering Support were fully aware of these assertions but failed to adaquately resolve these concerns before still another inaccurate and f
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incomplete submission was made to the NRC.
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 closely with the site to ensure that the submittal was accurate and complete.
Despite this clear i
direction, and after having been informed by the site of the clear failure of the June 29, 1990 draft cover letter to address the April 9,1990 letter that it referenced and that the April 9, 1990 errors were different from the April l
19, 1990 errors, the Licensing Engineer - Vogtle Project failed to address j
these concerns prior to issuance of the LER revision.
I The VEGP Manager - Engineering Support was responsible for the Diesel Start Logs and agreed with the audit report findings regarding deficiencies in their i
condition.
Given that his logs had not been used to collect the DG start data, he pointed out that it was wrong to state that the condition of his logs caused errors in the information initially provided to the NRC. The VEGP j
Manager - Engineering Support, who understood and agreed that DG record i
keeping practices were not a cause of the difference in the DG starts reported in the April 19, 1990 LER and the June 29, 1990 letter, nevertheless approved l
the ' erroneous draft as a voting member of the Plant Review Board (PRB) without j
resolving the problems in the draft.
The Supervisor - SAER was aware that the audit (that formed the basis for the l
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reasons stated in the June 29, 1990 letter) was narrow in scope and did not i
identify a specific cause for the error in the number of 18 starts reported in the April 19, 1990 LER. The Supervisor - SAER was also aware that i
observations stated in the audit report were inappropriately being used to 1
identify the root causes for the errors in the April 19, 1990 LER. The VEGP l
TA and the VEGP Manager - Engineering Support made the Supervisor - SAER aware of this inaccuracy, but the Supervisor - SAER, with apparent indifference, defended the inaccuracy. Also, the Supervisor - SAER was made aware by the VEGP TA on June 12, 1990 that, to identify the root cause of the error in the April 19, 1990 LER (i.e., personnel errors), the audit scope would need to include an assessment of the performance of the Unit Superintendent and the VEGP General Manager, the individuals that developed the initial count. Yet, the audit report did not include either of these individuals in the list of persons contacted during the audit. On June 29, 1990, the Supervisor - SAER was again ma e aware by the VEGP TA that the root cause for the difference was d
l personnel error. Despite this knowledge, the Supervisor - SAER failed to adequately address these concerns prior to issuance of the June 29, 1990 j
letter.
I The VEGP Assistant General Manager was 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 TA identified to him the failure of the l
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l June 29, 1990 draft cover letter to address the inaccuracies in the April 9, 1990 letter that it referenced and the VEGP TA pointed out the erroneous 3
causes stated for the reasons for the difference in the June 29, 1990 DG start counts. The VEGP Assistant General Manager, as a voting member of the PRB, l
approved the proposed June 29, 1990 subsittal without addressing these i
concerns.
In addition to these performance failures, the NRC has also concluded that the l
VEGP General Manager,' the Vice President - Vogtle Project, and the Senior Vice
[
President - Nuclear Operations failed to ensure that information provided to the NRC in ~the~ June 29 cover letter was complete. 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 i
that its purpose was, in part, to clarify information provided to the NRC on April 9.
However, no such clarification, or even a relevant discussion of the
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April 9 information, was provided in the June 29 submittal, j
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Violation E:
Inaccurate and Incomplete Information Reported in August 30, i
1990 Letter.
l Violation E involves two instances in which inaccurate and incomplete i
i information was provided in the August 30, 1990 letter.
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i The first instance involves GPC's failure to provide accurate j
.information with respect to the correct root cause of the errors in the i
April 9, 1990 letter. The letter statad that the errors in the April 9
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letter and presentation and the April 19 LER were caused, in part, by confusion in the distinction between a successful start and a valid test. This information was inaccurate. The root cause for providing j
this inaccurate information in the August 30, 1990 letter was GPC's 3
failure to ensure that concerns about the accuracy of the information j
that were raised were fully and accurately resolved before the lctter was issued. During the August 29, 1990 Plant Review Board (PRB) j meeting, the VEGP Manager - Technical Support questioned if the Unit i
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 the data which was used to prepare the April 9 letter, but stated that the seritence 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 information.
Confusion after April 9 was not relevant to the reasons for the error in the April 9 letter. By retaining this wording, the first reason in the August 30 letter was inaccurate.
In addition, the members of the PRB who were reviewing the draft of the August 30 letter, collectively failed to adequately resolve the concern that had been raised about the accuracy of the first reason.
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As a result, the August 30 letter was inaccurate. The inaccuracy was material in that it could have led the NRC to erroneously conclude that
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the correct root causes for the error in the April 9, 1990 letter had i
been identified by GPC.
1 The second instance involves GPC's failure to provide complete
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information with-respect to the root causes of the error in the April 9, j
1990 letter and the April 19 LER. The August 30 letter states that the error in the April 9 letter and presentation and the April 19 LER were j
caused, in part, by an error made by the individual who performed the i
count of DG starts. This statement is incomplete in that it failed to l
identify personnel errors by the VEGP General Manager that also contributed to the problem. The incompleteness was material in that,
.had the correct root causes for the error in the April 9, 1990 letter i
regarding DG stari, counts been reported, this information could have led i
~the NRC to seek further information.
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GPC was clearly aware as early as May 2 that the April 9 letter was incorrect.
GPC failed to take sufficient actions to correct the April 9 letter and to determine the reasons for the errors it contained. While GPC unotrtook efforts to correct the April 19 LER, it narrowly' focused only on that submittal.
For example, GPC conducted an audit, the scope l
of which we limited to review of DG records, in an attempt to correct the start count reported in the April 19 LER.
Furthermore, in its 1
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 directly involved in the i
t development of the June 29 letter.
In fact, as of June 29, GPC had initiated no action to determine the root cause for the error in the i
April 9 letter. Subsequently, the NRC requested that GPC make a i
submittal addressing the April 9 letter. As of August 17, 1990, the i
Vice President - Vogtle Project was aware of NRC concerns regarding the i
errors in, and the misleading nature of, the April 9 letter. The Vice l
President - Vogtle Project committed during the August 17 meeting with
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the NRC special inspection team to provide clarification to the NRC regarding the April 9 letter.
Based on the evidence of Licensee i
discussions subsequent to this meeting with the NRC, the'Vice President - Vogtle Project was aware of the seriousness of the NRC concerns regarding the possible errors in the April 9 letter, including 4
l concerns that the errors in the information provided to the NRC may have 4
been intentional. Despite this knowledge, no root cause evaluation was i
initiated.
Rather, GPC forwarded a submittal 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 1
who developed erroneous information for the April 9 letter.
As a l
result, no adequate evaluation of the root causes of the error in the
{
April 9 letter was available to GPC at the time of the August 30 i
submittal. The NRC concluded that the Vice President - Vogtle Project i
j failed to exercise sufficient oversight of the preparation of the 5
i
i i-Georgia Power Company MAY -9 994
' August 30 letter to assure that serious NRC concerns were accurately l
addressed. The August 30 letter was inaccurate and incomplete with j
respect to the root causes for the error in the April 9 letter.
The circumstances surrounding these violations represent a very significant regulatory concern.
In particular, these violations are of regulatory 4
significance, not because of the effect that the inaccuracies had on the safety of plant operation, but because the circumstances surrounding the communications with the NRC demonstrate an inadequate regard individually by a number of senior Licensee officials, and collectively by the Licensee's management, for complete and accurate communications with the NRC. The violations involved, in part, the reliability of the DGs -- the failure of one L
of which was the very issue that caused an extended shutdown. GPC was clearly aware of the NRC's interest in the DGs, in that the NRC specifically asked GPC to address DG reliability as part of its restart presentation for April 9, 1990.
It was reasonable to have expected the licensee to have recognized that i
the DG reliability was an issue that would affect an NRC restart decision. On such a matter, the NRC expects and demands that licensees' presentations reflect a concerted effort to assure completeness and accuracy. That expectation was not met.
Rather, the record reflects an informal, unstructured, and not-well-defined effort to obtain information'to satisfy the Commission on an important issue having a direct bearing on the NRC's decision on restart.
Given the importance of the NRC's having complete and accurate information before making a restart decision, the Licensee's performance was unacceptable.
Even more significant was the Licensee's subsequent performance failures when its own staff questioned the accuracy of the April 9 information and the subsequent efforts to explain and correct the inaccurate information.
Notwithstanding the involvement of senior Licensee management, GPC repeatedly failed to ensure that information provided to the NRC was complete and accurate.
The NRC is very concerned about these violations. The circumstances surrounding them represent a serious breakdown on the part of GPC to ensure that information provided to the NRC is accurate and complete in all material respects.
From the initial inaccurate representations to'the NRC on April 9, 1990 in its presentation seeking to support restart, through the above-described series of inadequate efforts to modify, explain, clarify, and correct the original inaccuracies and subsequent clarifications and explanations, the Licensee has failed to meet the requirements of 10 CFR 50.9.
It is of fundamental importance in the nuclear industry that, when errors are made, they will be promptly corrected, lessons will be learned, and corrections to procedures and training will be developed through root cause analyses so that future performance can be improved. This was not done here.
Recognizing that the evidence reflects a variety of individual performances and attitudes, an overall review of that evidence nevertheless raises a question as to whether the Licensee's actions were directed toward defending the information provided in the restart presentation without an adequate understanding of the basis for the information and notwithstanding a recognition that the NRC sought the information as a part of a restart decision. Such an approach is inconsistent with responding to " inquiries with
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i the simple candor on which we must insist in order to discharge our own responsibility for public health and safety. Nothing less than simple candor is sufficient." Virainia Electric and Power Comoany (North Anna Power i
Station, Units 1 and 2), CLI-76-22, 4 NRC 480, 491 (1976).
GPC did not l
exhibit an attitude of being "as sure as they possibly can be that all l
submissions to this Commission are accurate." 16, at 486.
t After considering the Licensee's performance in this matter, including (1) the L
Licensee's knowledge that the information on DG reliability was important to ti.a NRC and likely would influence the NRC's decision on restart, (2) the i
repetitive and compounding nature of the errors and inaccuracies, (3) the degree of high level management involvement in the repetitive failures, and j
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(4) the apparent inability or apparent unwillingness of the Licensee to j
correct and resolve the problems despite clear indications from Licensee j
l personnel that errors and inaccuracies continued to be proposed for submittal i
to the NRC, the NRC has concluded that significant enforcement action is warranted. Therefore, to emphasize, as the Commission said in the VEPC0 j-decision, the need for licensees to scrutinize their operations to be as sure i
as they possibly can that all submissions to the Commission are complete and accurate, I have been authorized, after consultation with the Commission, to l
categorize these violations as a Severity Level II problem in accordance with the " General Statement of Policy end Procedure for NRC Enforcement Actions" 4
(Enforcement Policy), 10 CFR Part 2, Appendix C, and to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties (Notice) in the j
araount of $200,000 for this problem.
l The base value of a civil penalty for a Severity Level 11 problem is $80,000.
The escalation and mitigation factors in the Enforcement Policy were i
considered. The base amount was escalated 50 percent because the NRC, during l
its review of related allegations, identified most of the violations that were involved in this case. The base civil penalty was also escalated 100 percent for prior opportunity to identify since both Licensee and NRC staff personnel had, on a number of occasions, advised the Licensee of inaccuracies and the need to correct inaccuracies in the then-existing and proposed submittals that 2
were involved in this case. This resulted in an adjusted penalty of $200,000.
l The other adjustment factors in the Policy were considered but no further i
adjustment to the base civil penalty were considered to be warranted.
I~
In addition to this Notice, the NRC is issuing the enclosed Demands for Information (DFIs) to GPC regarding individual performance failures to enable the NRC to determine whether additional enforcement actions are necessary. By separate correspondence, the individuals who are the subjects of these DFIs have been given the opportunity to submit separate resconses to the DFIs.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice and DFIs when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
In addition, your response should specifically address what actions you plan to take, if any, to ensure that all employees involved in licensed activities at all levels of your organization understand their responsibilities to provide complete and
i Georgia Power Company MAY 9 894 4
I accurate information in submittals to, and communications with, the NRC.
After reviewing your response to this Notice, including your proposed i
corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure l
compliance with NRC regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of j
this letter, its enclosures, and your response will be placed in the NRC Public Document Room.
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 by the Papemork Reduction Act of 1980, Pub. L. No.96-511.
i i
Sincerely,
[.
M11hoan i ymputyExecutiveDirector vfor Nuclear Reactor Regulatim.,
Regional Operations,and Research
Enclosures:
1.
Notice of Violation and Proposed Imposition of Civil 4
Penalties - $200,000 2.
Demand For Information Regarding Messrs. Thomas V. Greene, Georgie R.' Frederick, Harry W. Majors, and Michael W. Horton 3.
Demand For Information Regarding Mr. C. Kenneth McCoy 4.
Demand For Information Regarding Mr. George Bockhold, Jr.
cc:
George Hairston Southern Nuclear Operating Company 40 Inverness Center Parkway Birmingham, Alabama 35242 Mr. J. D. Woodard Senior Vice President Georgia Power Company Nuclear Operations P.O. Box 1295 Birmingham, AL 35201 cO'd p2:01 #66T-60-50
Georgia Power Company
)gy _ g g DISTRIBUTION:
PDR SECY CA i
JTaylor, EDO j
JMilhoan, DEDR JLieberman, OE l
SEbneter, RII t
LChandler, OGC JGoldberg, OGC j
WRussell, NRR Enforcement Coordinators RI, RII, RIII, RIV, RV FIngram, GPA/PA EJordan, AE00 BHayes, 01 EA File-DCS lDE NRR RA:RII D:0E DEDR JGray WRussell-SEbneter JLieberman JMilhoan 05/ /94 05/ /94 05/ /94 05/ /94 05/ /94 Doc Name: G:\\0EC4SES\\V0GFIN.R12
i AND i
PROPOSED INPOSITION OF CIVIL PENALTIES i
Georgia Power Company Docket No.
50-424 i
Vogtle Electric Generating Plant License No. NPF-68 i
EA 93-304 During an NRC inspection conducted from August 6, 1990 to August 17, 1990 and
~
an NRC investigation completed on December 17, 1993, violations of NRC requirements were identified.
In accordance with the " General Statement of 2
l Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, i
j the Nuclear Regulatory Commission proposes to impose civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C.
I 2282, and 10 CFR 2.205. The particular violations and associated civil penalties are set forth below:
10 CFR.50;9(a) requires that information provided to the NRC by a licensee shall be complete and accurate in all material respects.
A.
Contrary to the above, information provided to the NRC Region II Office by Georgia Power Company (GPC) in an April 9, 1990 letter and in an April 9,-1990 oral presentation to the NRC was inaccurate in a material respect.
Specifically, the letter states that:
"Since March 20, the 1A DG has been started 18 times, and the IB DG has.been started 19 times.
1 No failures or problems have occurred during any of these starts."
These statements are inaccurate in that they represent that 19 consecutive successful starts without problems or failures had occurred on the 18 Diesel Generator (DG) for the Vogtle facility as of April 9, 1990, when, in fact, of the 19 starts referred to in the letter associated with the IB DG at the Vogtle facility, three of those starts had problems. Specifically, Start 132 tripped on high temperature lube oil, Start 134 tripped on low pressure jacket water and Start 136 had a high temperature jacket water trip alarm. As of April 9,1990, the IB DG had only 12 consecutive successful starts without problems or failures rather than the 19 represented by GPC. The same inaccuracy was presented to the NRC at its Region II Office during an oral presentation by GPC on April 9, 1990.
The inaccuracy was material.
In considering a restart decision, the NRC was especially interested 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 operation.
B.
Contrary to the above, information provided to the NRC Region II Office-by GPC in an April 9,1990 letter was incomplete in a material respect.
Specifically, the letter states, when discussing the air quality of the DG starting air system at the Vogtle facility, that:
"GPC has reviewed air quality of the D/G air system including dewpoint control and has i
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i l
concluded that air quality is satisfactory.
Initial reports of higher than expected dewpoints were later attributed to faulty f.
instrumentation."
This statement is incomplete in that it fails to state that actual high
~
j dew points had occurred at the Vogtle facility.
It also fails. to state that the causes of those high dew points included failure to use air i
dryers for extended periods of time and repressurization of the DG air i
start system receivers following maintenance.
i i
The incompleteness was material.
In considering a' restart decision, the NRC was especially interested in the reliability of the DGs and j
specifically asked that GPC address the matter in its presentation on
. restart. The NRC relied, in part, upon this information presented by GPC in its letter of' April 9,1990 in reaching the decision to allow Vogtle Unit I to return to power operation.
C.
Contrary to the above, information provided to the NRC by GPC in a Licensee Event Report (LER), dated April 19, 1990, was inaccurate in a material respect.
Specifically, the LER states:
" Numerous sensor calibrations (including jacket water temperatures), special pneumatic leak testing, and multiple engine starts and 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.
Subsequent to this test program, DGIA and DGIB have been started at l
least 18 times each and no failures or problems have occurred during any of these starts."
4 i
These statements are inaccurate in that they represent that at least 18 1
consecutive successful starts without problems or failure's had occurred l
on the DGs for Vogtle Unit 1 (IA DG and IB DG) following the completion of the comprehensive test program of the control systems for these DGs,
{
when, in fact, following completion of the comprehensive test program of i
the control systems, there were no more than 10 and 12 consecutive successful starts without problems or failures for IA DG and IB DG l
respectively.
The inaccuracy was material in that knowledge by the NRC of a lesser l
number of consecutive successful starts on IA DG and IB DG without problems or failures could have had a natural tendency or capability to
[
cause the NRC to inquire further as to the reliability of the DGs.
D.
Contrary to the above, information provided to the NRC by GPC ir an LER-l cover letter dated June 29, 1990 was inaccurate and incomplete in j
material respects as evidenced by the following three examples:
{
The letter states that:
"In accordance with 10 CFR 50.73, Georgia Power Company (GPC) hereby submits the enclosed revised report related to an
]
event which occurred on March 20, 1990. This revision is necessary to clarify the information related to the number of successful diesel i
generator starts as discussed in the GPC letter dated April 9,1990...."
i
_.. _. _ _ _ ~ _.. _ _.
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The LER cover letter is incomplete because the submittal did not L
provide information regarding clarification of the April 9,1990 q
1etter.
I The incompleteness was material in that the NRC subsequently
]
requested GPC to make a submittal clarifying the April 9,1990 i
letter.
j The letter states that:
"If the criteria for the completion of the test j
program is understood to be the first successful test in accordance with Vogtle Electric Generating Plant (VEGP) procedure 14980-1 " Diesel i
Generator Operability Test," then there were 10 successful starts of Diesel Generator IA and 12 successful starts of Diesel Generator IB i
between the completion of the test program and the end of April 19, j
1990, the date the LER-424/1990-06 was submitted to the NRC. The number i
of successful starts included in the original LER (at least 18) included some of the starts that were part of the test program. The difference is attributed to diesel start record keeping practices and the j
definition of the end of the test program."
2.
The last sentence in the above paragraph is inaccur2te because diesel record keeping practices were not a cause cf the difference j
in number of diesel starts reported in the April 19, 1990 LER and 4
the June 29, 1990 letter. The difference was caused by personnel i
errors unrelated to any problems with the diesel generator record i
keeping practices.
l The inaccuracy was material in that it could have led the NRC to erroneously conclude that the correct root causes for the l
difference in the number of diesel starts reported in the April l
19, 1990 LER and the June 29, 1990 letter had been identified by GPC.
l 3.
The last sentence in the above paragraph is also incomplete because it failed to include the fact that the root causes for the
[
difference in the number of diesel atarts reported in the April 19, 1990 LER and the June 29, 1990 letter were personnel 1
errors.
First, the Vogtle Plant General Manager who directed the Unit Superintendent to perform the start count (which formed the basis for the April 19, 1990 LER) failed to issue adequate 1
instructions as to how to perform the count and did not adequately i
i assess the data developed by the Unit Superintendent.
In addition, the Unit Superintendent made an error in reporting his 1-count. Second, the Vogtle Plant General Manager, the General Manager for Plant Support and the Technical Support Manager failed to clarify and verify the starting point for the count of successful consecutive DG starts reported in the April 19, 1990 LER.
The incompleteness was material in that, had correct root causes j
for the difference in the number of diesel starts reported in the 1
k
2 4
4 April 19, 1990 i.ER and the June 29, 1990 letter been presented, this information could have led the NRC-to seek further information.
E.
Contrary to the above, information provided to the NRC Region II Office l
by GPC in a letter dated August 30, 1990 was inaccurate and incomplete in material respects as evidenced by the following two examples:
i The letter states that:
"The confusion in the April 9th letter and the original LER. appear to be the result of two factors.
First, there was confusion in the distinction between a successful start and a valid j
test...
Second, an error was made by the individual who performed the l
count of DG starts for the NRC April 9th letter."
I 1.
These statements are inaccurate in that confusion between a i
successful start and a valid test was not a cause of the error regarding DG start counts which GPC made in its April 9, 1990 letter to the NRC.
l The inaccuracy was material in that it could have led.the NRC to i
erroneously conclude that the correct root causes for the error in l
-the April 9, 1990 letter had been identified by GPC.
t j
.2.
The statements are also incomplete. While an error was made by j
the Unit Superintendent who performed the count of diesel starts for the April 9, 1990 letter, the root causes of the error in that letter were not completely identified by GPC.
Specifically, the j
Vogtle Plant General Manager who directed the Unit Superintendent i.
to perform the start count failed to issue adequate instructions as to how to perform the count and did not adequately assess the
)
data developed by the Unit Superintendent.
In addition, the Unit Superintendent did not adequately report his count to the Vogtle Plant General Manager.
The incompleteness was material in that, had the correct root causes for the error in the April 9, 1990 letter regarding DG start counts been reported, this information could have led the NRC to seek further information.
l These violations in the aggregate represent a Severity Level II problem j-(Supplement VII).
1 Civil Penalty - $200,000 l
1 Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company (Licensee) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalties (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective
l steps that have treen taken and the results achieved, (4) the corrective steps
' that will be taken to avoid further violations, and (5) the date when full j
compliance will be achieved.
j If an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consideration may be given to extending l
the response time for good cause shown.
Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall'be submitted under oath or affirmation.
l Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalties by letter addressed to the l
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a i
check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or the cumulative amount of the civil penalties if more than one civil penalty is proposed, or may protest imposition of the civil penalties, in whole or in part, by a written answer addressed to the Director, Office of Enforcement,
- U.S. Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing.the civil penalties will be issued.
Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in whole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may:
(1) deny the violations listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalties should not be imposed.
In addition to protesting the civil penalties, in whole or in part, such answer may request remission or mitigation of the penalties.
In requesting mitigation of the proposed penalties, the factors addressed in Section VI.B.2 of 10 CFR Part 2, Appendix C should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorpo-rate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalties.
Upon failure to pay any civil penalties due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234(c) of the Act, 42 U.S.C. 2282c.
The response noted abave (Reply to Notice of Violation, letter with payment of civil penalties, and Answer to a Notice of Violation) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
k.
Notice of Violation 6-l Document Control Desk, Washington, D.C. 20555 with a copy to the Regional
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Administrator, U.S. Nuclear Regulatory Comission, Region II and a copy to the NRC Resident Inspector at the Vogtle facility.
I Dated at Rockville, Maryland this h day of May, 1994 i
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S UNITED STATES i
P NUCLEAR REGULATORY COMMISSION
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g waswinovow. o.c. -
i MM 0 9134 1
Th'omas V. Greene i
Southern Nuclear Operating Company 40 Inverness Center Parkway i
Birmingham, Alabama 35242 I
SUBJECT:
DEMAND FOR INFORMATION REGARDING THOMAS'V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON i
Dear Mr. Greene:
L Enclosed for your information and use is a DEMAND FOR INFORMATION REGARDING THOMAS V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON t
i (DFI) that is being issued to the Georgia Power Company (Licensee) on this i
date. This DFI deals, in part, with your actions in providing information to the NRC on the Vogtle diesel generators and is being issued to obtain additional information to determine whether NRC should take further action to restrict your participation in NRC licensed and regulated activities.
l You are invited to submit a response to the enclosed.DFI, separate from the i
response to be submitted by the Licenses.
We will consider any response that, you choose to provide, along with the responses of the Licensee, in l
determining whether enforcement action that may impact your future j
participation in licensed activities is warranted in this case.
If you do respond, your response should be submitted in writing to the 1
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, i
Washington, DC 20555 within 30 days of the date of the enclosed DFI.
Should you have any questions on this matter, please call James Lieberman, Director, 2
Office of Enforcement, at 301-504-2741.
i j
Sincerely i
- d. L.
.A W Mil can 3
eputy Executive Director for uclear Reactor Regulation, Regional.0perations and Research
Enclosure:
As Stated cc w/o
Enclosure:
Georgia Power Company a
9409tioon IP-00
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92:OT PSST-60-30
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UNITED STATES i
g NUCLEAR REGULATORY COMMISSION l
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u smwavow,o.c. - m
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IN 0 915 l
Georgie R. Frederick Georgia Power Company Vogtle Electric Generating Plant i
River Road l
Waynesboro, Georgia 30830
SUBJECT:
DEMAND FOR INFORMATION REGARDING THOMAS V. GREENE, 4
GEORGIE R. FREDERICK, HARRY MAJOR $, AND MICHAEL W. HORTON l
Dear Mr. Frederick:
i Enclosed for your information and use is a DEMAND FOR INFORMATION REGARDING THOMAS V. GREENE, GEORGIE R. FREDERICK, HARRY MAJOR 3, AND MICHAEL W. HORTON (DFI) that is being issued to the Georgia Power Company (Licensee) on this date. This DFI deals, in part, with your actions-in providing information to the NRC on the Vogtle diesel generators and is being issued to obtain additional information to determine whether NRC should take further action to restrict your participation in NRC licensed and regulated activities.
You are invited to submit a response to.the enclosed DFI, separate from.the response to be submitted by_the Licensee. We will consider any response that you choose to provide, along with the responses of the Licenses, in determining whether enforcement action that may impact your future participation in licensed activities is warranted in this case.
If you do respond, your' response should be submitted in writing to the Director, Office of Enforcement, U.S. Nuclear Regulatory Constission, Washington, DC 20555 within 30 days of the date of the enclosed DFI.
Should you have any questions on this matter, please call James Lieberman, Director, Office of Enforcement, at 301-504-2741.
Since. rely d.
t une M11hoan puty Executive Director for uclear Reactor Regulation, Regional Operations and Research
Enclosure:
as ' stated j
cc w/o
Enclosure:
Georgia Power Company ty d t06TI IP 60*d gg:of P66T-60-SO
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S UNITED STATES i
f NUCLEAR REGULATOf1Y COMMISSION j
4, WASHINGTON, D.C. 3000Mgo1 MAY 0 9194 l
l Harry Majors i
Southern Nuclear Operating Company 40 Inverness Center Parkway Birmingham, Alabama 35242 l
SUBJECT:
-DEMAN0'FOR INFORMATION REGARDING THOMAS V. GREENE, i
GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON I
Dear Mr.. Majors:
i l
Enclosed for your information and use is a DEMAND FOR INFORMATION REGARDING THOMAS.V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON
-(DFI) that is being issued to the Georgia Power Company (Licensee) on this L
date. This DFI deals, in part, with your actions in providing information to i
the NRC on the Vogtle diesel generators and is belpg issued to obtain additional information to determine whether NRC should take further action to i
l restrict your participation in NRC licensed and regulated activities, j
i You are invited to submit a response to the enclosed DFI, separate from the i
1-response to be submitted by the Licensee. We will consider any response that j
you choose to provide,- along with the responses of the Licensee, in detemining whether enforcement action that may impact your future
)
participation in licensed activities is warranted in this case.
l If you do respond, your response should be submitted in writing to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555 within 30 days of the date of the enclosed DFI. Should l
you have any questions on this matter, please call James Liebeman, Director, Office of Enforcement, at 301-504-2741.
i l
Sincerely i
r_ t. 7//Rha
^
ames L. M11hoan eputy Executive Director for uclear Reactor Regulation, Regional Operations and Research
Enclosure:
2., stated cc w/o
Enclosure:
Georgia Power Company QDS!h%Qj- (,>.
OT*d 4E:OT F66i-60-50
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- **:%s UNITED STATES
-j-NUCLEAR REGULATORY COMMISSION g
e WASHINGTON. 9.C. anses 4001 i
M4Y 0 91st i
Michael W. Horton i
4 Southern Nuclear Operating Company i
40 Inverness Center Parkway j
Birmingham, Alabama 35242
)
SUBJECT:
DEMAND FOR INFORMATION REGARDING THOMAS V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, Ale MICHAEL W. HORTON t
Dear Mr. Horton:
i Enclosed for your information and use is a DEMAND FOR INFORMATION REGARDING THOMAS.V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON
'(DFI) that is being issued to the Georgia Power Company (Licensee) on this date.' This DFI deals, in part, with your actions in providing information to the NRC on the Vogtle diesel generators and is being issued to obtain i
additional information to detemine whether NRC should take further action to restrict your participation in NRC licensed and regulated activities.
2 You are invited to submit a response to the enclosed DFI, separate from the i l
response to be submitted by the Licenses. We will consider any response that you choose to provide, along with the responses of the Licensee, in determining whether enforcement action that may impact your future participation in licensed activities is warranted in this case.
l If you do respond, your response should be submitted in writing to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, j
Washington, DC 20555 within 30 days of the date of the enclosed DFI.
Should you have any questions on this matter, please call James Lieberman, Director, Office of Enforcement, at 301-504-2741.
i Sincerely I
O A.'777 &
Milhoan i
puty Executive Director for uclear Reactor Regulation, Regional Operations and Research 1
Enclosure:
as stated l
cc w/o
Enclosure:
Georgia Power Company i
4
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UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of
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2 GEORGIA POWER COMPANY
)
Docket Nos.
50-425/50-425 (Vogtle Electric Generating
)
License Nos. NPF-68/NPF-81 Plant, Units 1 & 2)
)
EA 94-036 i
DEMAND FOR INFORMATION REGARDING THOMAS V. GREENE, GEORGIE R.' FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON l
Georgia Power Company (Licensee) is the holder of Facility License Nos. NPF-68 and NPF-81 (Licenses) issued by the Nuclear Regulatory Commission (NRC or Commission) pursuant to 10 CFR Part 50. The Licenses authorize the operation of the Vogtle Electric Generating Plant (VEGP) Units I and 2, in accordance with conditions specified therein.
II On December 17, 1993, an investigation of licensed activities was completed by the NRC's Office of Investigations (01) at Licensee's VEGP facility. The investigation was initiated in response to information received in June 1990 by NRC Region II alleging, in part, that material false statements were made to the NRC by senior Licensee officials 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
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i failure of the only Unit 1 DG that was available (IA). 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
~
1 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 f
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 i
March 20, 1990."
l 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 i
Unit I to criticality until the Regional Administrator was satisfied that appropriate corrective actions had been taken, and that the plant could safely i
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 i
to a specific NRC request that GPC address DG reliability in its April 9 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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. _ _ _ _ _ _.._ _ ~.____._
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!- On April 12, 1990, the NRC formally granted permission for'VEGP Unit I to I
return to criticality and resume power operations.
i I
~
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 l
Emergency.'
i
}
On June tv, 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 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.
i i
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 i
to, VEGP operational activities. This inspection examined the technical i
validity and safety significance of the allegations, but did not investigate alleged wrongdding. 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.
On August 30, It'90, 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,
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III j
The NRC has reviewed the evidence associated with these events, submittals, j
~
and representations to the NRC.
Specifically, the NRC reviewed information i
i 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 (Docket Nos. 50-424 OLA-3, 50-425 OLA-3), and other related information. The NRC has I
identified apparent violations of regulatory requirements involving five separate instances that occurred from April 9 to August 30, 1990, where the Licensee failed to provide information that was complete and accurate in all material respects. These violations are addressed in the Notice of Violation and Proposed Imposition of Civil Penalties issued to the Licensee on this date, and incorporated herein by reference.
)
The NRC has also identified several current Licensee employees whose significant performance failures contributed to one of these violations and whose failures to ensure that complete and accurate information was submitted I
to the NRC occurred after they were explicitly advised of inaccuracies.and problems in the draft submittal.
The circumstances surrounding these performance failures are described below.
On June 29, 1990, the draft cover letter for the LER revision was being reviewed at the VEGP site. The draft had originated in GPC corporate headquarters and included language personally developed by the Senior Vice President - Nuclear Operations (George W. Hairston, III) and the Vice I
.,e r--.
l President - Vogtle Project (C. Kenneth McCoy).
During this review, a VEGP Technical Assistant (TA) (formerly the Acting VEGP Assistant General Manager -
Plant Support) (Alan L. Mosbaugh) noted that the draft cover letter was j
~
incomplete and challenged the accuracy of the reasons stated in the draft cover letter in conversations with the Supervisor - Safety Audit and Engineering Review (SAER) (Georgie R. Frederick), the VEGP Assistant General Manager - Plant Support (Thomas V. Greene), the VEGP Manager - Engineering Support (Michael W. Horton), and a Licensing Engineer - Vogtle Project (Harry W. Majors). Mr. Mosbaugh stated that: (1) the letter failed to clarify the DG starts reported on April 9, 1999 (2) DG record keeping practices were not a cause of the difference in the DG starts reported in the April 19, 1990 LER because adequate information to formulate an accurate count was available when the counting errors were made, and (3) the erroneous counts resulted from personnel errors in developing the count. Mr. Majors, Mr. Horton, Mr. Frederick, and Mr. Greene were fully aware of these assertions but failed to adequately resolve these concerns before issuance of the June 29, 1990 letter.
Mr. Majors '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 closely with the site to ensure that the submittal was accurate and complete.
Despite this clear direction, and after having been informed by the site of the clear failure of the June 29, 1990 draft cover letter to address the April 9,1990 letter that it referenced and that the April 9, 1990 errors were different from the April 19, 1990 errors,
J j.. l Mr. Majors failed to address these concerns prior to issuance of the LER l
revision.
~
Mr. Horton was responsible for the Diesel Start Logs and agreed with the audit report findings regarding deficiencies.in their condition.
Given that his
-logs had not been used to collect the DG start data, he pointed out that.it 1
l was wrong to state that the condition of his logs caused errors in the information initially provided to the NRC. Mr. Horton, who understood and
. agreed that DG record keeping practices were not a cause of the difference in the DG starts reported in the April 19, 1990 LER and the June 29, 1990 letter,
}
nevertheless approved the erroneous draft as a vo' ting member of the Plant Review Board (PRB) without resolving the problems in the draft.
I-Mr. Frederick was aware that the audit (that formed the basis for the reasons stated in the June 29, 1990 letter) was narrow in scope and did not identify a specific cause for the error in the number of 18 starts reported in the April 19, 1990 LER.
Mr. Frederick was also aware that observations stated in the audit report were inappropriately being used to identify the root causes for the errors in the April 19, 1990 LER. Mr. Mosbaugh and Mr. Horton made Mr. Frederick aware of this inaccuracy, but Mr. Frederick, with apparent indifference, defended the inaccuracy. Also, Mr. Frederick was made aware by Mr. Mosbaugh on June 12, 1990 that, to identify the root cause of the error in the April 19, 1990 LER (i.e., personnel errors), the audit scope would need to include an assessment of the performance of the Unit Superintendent and the VEGP General Manager, the individuals that developed the initial count.
- Yet, the audit report did not include either of these individuals in the list of 1
l
_. ~ -
1 l-j persons contacted during the audit. On June 29, 1990, Mr. Frederick was again i
made aware by Mr. Mosbaugh that the root cause for the difference was l
personnel error.
Despite this knowledge, Mr. Frederick failed to adequately l
address these concerns prior to issuance of the June 29, 1990 letter.
~
j i
Mr. Greene was apprised of concerns regarding the June 29, 1990 letter by Mr. Mosbaugh (an individual who had been involved in preparing f he April 19, 1990 LER and had been involved in developing an accurate DG start count).
Mr. Mosbaugh identified to him the failure of the June 29, 1990 draft cover letter to address the inaccuracies in the April 9, 1990 letter that it referenced and Mr. Mosbaugh pointed out the erroneous causes stated for the reasons for the difference in the June 29, 1990 DG start counts. Mr. Greene was apparently indifferent to these concerns and, as a voting member of the PRB, approved the proposed June 29, 1990 submittal without addressing these Concerns.
1 IV l
The conduct of these individuals indicates a lack of regard for and adherence to regulatory requirements and a lack of management control and supervision over licensed activities, and raises a question as to whether the Licensee and theso individuals will, in the future, provide complete and accurate infor-mation to the NRC and otherwise comply with NRC requirements.
Therefore, further information is needed to determine whether the Commission can have reasonable assurance that in the future the Licensee, with the 1
involvement of particular Licensee personnel identified above, will provide complete and accurate information to the Comission and otherwise conduct activities in accordance with the Comission's requirements.
~
\\
V l
Accordingly, pursuant to sections 161c, 1610, 182 and 186 of the Atomic Energy Act of 1954, as amended, and the Comission's regulations in 10 CFR 2.204 and
]
10 CFR 50.54(f), in order for the Comission to determine whether the Licenses a
should be modified to restrict the participation of the individuals named below in licensed activities or other enforcement action taken to ensure compliance with NRC regulatory requirements, the Licensee is required to subnit to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, within 30 days of the date of this Demand for Information the following information, in writing and under oath or affirmation:
A.
A description of the current positions and responsibilities for Messrs. Thomas V. Greene, Georgie R. Frederick, Harry W. Majors, and Michael W. Horton.
B.
An explanation of why, notwithstanding being notified that the June 29, 1990 letter failed to clarify the April 9,1990 letter that it referenced and that it included erroneous root causes for the difference between the April 19, 1990 and June 29, 1990 DG start counts,
i t
- l Mr. Greene, as a voting member of the PRB, approved the inaccurate and incomplete June 29, 1990 submittal.
l
~
C.
An explanation of why, notwithstanding his direct knowledge that the i
observations stated in the aedit report were inappropriately being used i
to identify the root causes for differences between the April 19, 1990 I
LER and the June 29, 1990 DG start counts and his being notified that the correct root cause for the difference was personnel error, i
Mr. Frederick failed to address this concern prior to issuance of the June 29, 1990 letter.
D.
An explanation of why, notwithstanding his Wing notified that the June 29, 1990 letter failed to clarify the April 9,1990 letter and that the April 9, 1990 errors were different from the April 19, 1990 LER errors, Mr. Majors failed to address these concerns prior to issuance of the June 29, 1990 letter.
E.
An explanation of why, notwithstanding his disagreement with the statement that DG record keeping practices were the cause for the error in the April 9,1990 letter, Mr. Horton, as a voting member of the PRB, approved the June 29, 1990 letter.
F.
An explanation of the corrective actions taken, or planned by the.
Licen"m to address each of these individuals' performance failures.
i
,- H.
Given the violation of NRC requirements, an explanation as to why NRC
)
should'have confidence that the Licensee, with the involvement of Messrs. Greene. Frederick, Majors, and Horton, will in the future conduct licensed activities in accordance with all NRC requirements, including the requirement of 10 CFR 50.9, " Completeness and accuracy of information." Responses to this paragraph shall be provided separately for each individual.
Copies of the response also shall be sent to the Assistant General Counsel for Hearings and Enforcement, U.S. Nuclear Regulatory Commission Washington, D.C.
20555 and to the Regional Administrator NRC Region II,101 Marietta street,j t
Suite 2900. Atlanta, GA 30323.
After reviewing your response, the NRC will determine whether further action is necessary to ensure compliance with regulatory requirements.
FOR THE NUCLEAR REGULATORY COMMISSION s L.
b hees L. M11hoan sputy Executive Director for Nuclear Reactor Regulation, Regional Operations, and Research Dated at Rockville, Maryland thisqf5.dayofMay1994
-..d ET'd 02:0T P66T-60-SO
i 2
p $a **%,S.
s a-j 3
S UNITED STATES E
NUCLEAR REGULATORY COMMISSION k...+
l wAenimarow, o.c. same.4eos l
M 0 9194 i
Kenneth McCoy
-Southern Nuclear Operating Company
~
i 40 Inverness Center Parkway 1
Birmingham, Alabama 35242 l.
SUBJECT:
DEMAND FOR INFORMATION REGARDING KENNETH McC0Y t
Dear Mr. McCoy:
Enclosed for your information and use is a DEMAND FOR INFORMATION REGARDING KENNETH McC0Y (DFI) that is being issued to the Georgia Power Company (Licensee) on this date.
This DFI deals with your actions in providing information to the NRC on the Vogtle diesel generators and is being issued to obtain additional information to determine whether NRC should take further i
1 action to restrict your participation in NRC licensed and regulated activities.
~
You are invited to submit a response to the enclosed DFI, separate from the response to be submitted by the Licensee. We will consider any response that you choose to provide, along with the responses of the Licensee, in detemining whether enforcement action that may impact your_ future participation in licensed activities is warranted in this case.
If you do respond, your response should be submitted in writing to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555 within 30 days of the date of the enclosed DFI. Shmid you have any questions on this matter, please call James Lieberman, Director, Office of Enforcement, at 301-504-2741.
Sincerely L. $
ines L. Milhoan puty Executive Director for i
uclear Reactor Regulation, Regional Operations and Research
Enclosure:
as stated cc w/o
Enclosure:
Georgia Power Company 44YGll0G% /p-90'd 52:DT e661-60-50
s UNITED STATES NUCLEAR REGULATORY C0W11SSION In the Matter of
)
)
GEORGIA POWER COMPANY
)
Docket Nos.
50-425/50-425 (Vogtle Electric Generating
)
License Nos. NPF-68/NPF-81 Plant, Units 1 & 2)
)
EA 94-052 DEMAND FOR INFORMATION REGARDING C. KENNETH McC0Y I
Georgia Power Company (Lic.ensee) is the holder of Facility License Nos.
NPF-68, and NPF-81 (Licenses) issued by the Nuclear Regulatory Commission (NRC or Commission) pursuant to 10 CFR Part 50. The Licenses authorize the operation of the Vogtle Electric Generating Plant (VEGP) Units 1 and 2, in accordance with conditions specified therein.
II On December 17, 1993, an investigation of licensed activities wa's completed by the NRC's Office of Investigations (OI) at Licensee's VEGP facility. The investigation was initiated in response to information received in June 1990 by NRC Region II alleging, in part, that material false statements were made to the NRC by senior Licensee officials 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 (IA). The other Unit 1 DG (IB) was unavailable due to maintenance activities.
h4vD //CO7$2
__.m jc e.
t 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
~
s 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 Administ'rator 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 operstions. 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 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."
On April 12, 1990, the NRC formally granted permission for VEGP Unit I to return to criticality and resume power operations.
- . i 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 i
Emergency."
~
j On June 29, 1990 GPC submitted a revised LER, 50-424/90-006-01. The purpose j
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 corrective actions in the original LER.
i 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 Mspection 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 date 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.
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.
1 y
III The NRC has 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, information gathered during the IIT, NUREG-1410, Supplement 1 of NRC Inspection Report 90-19, discovery responses j
in the Vogtle operating license amendment proceeding (Docket Nes. 50-424 OLA-3, 50-425 OLA-3), and other related information. The NRC has identified apparent violations of regulatory requirements involving five separate instances that occurred from April 9 to August 30, 1990, where the 1
Licensee failed to provide information that was complete and cccurate in all i
material respects. These violations are addressed in.the Notice of Violation-and Proposed Imposition of Civil Penalties issued to the,;censec en this date, and incorporated herein by reference.
1 The NRC has also' determined that the Vice President - Vogtle Project at the j
time of two of these violations, Mr. C. Kenneth McCoy, failed to ensure that information provided to the NRC was complete. The circumstances surrounding i
his performance failures are described below.
Mr. McCoy was actively involved in the preparation of the June 29, 1990 cover letter for an LER revision that was being submitted to the NRC and reviewed it prior to forwarding it to the Senior Vice President - Nuclear Operations for i
signature and issuance.
The June 29, 1990 cover letter stated that its purpose was, in part, to clarify information provided to the NRC on April 9, i
4
r l -
1990. However, no such clarification, or even a relevant discussion of the April 9, 1990 information, was provided in the June 29, 1990 submittal.
~
Mr. McCoy also failed to ensure that the August 30, 1990 letter submitted to the NRC adequately explained the reasons for the errors in the April 9, 1990 letter. Mr. McCoy committed during the August 17, 1990 meeting with the NRC e
Special Inspection Team to provide clarification to the NRC regarding the April.9, 1990 letter.
Based on the evidence of Licensee discussions subsequent to this meeting with the NRC, Mr. McCoy was aware of the seriousness of the NRL concerns regarding the possible errors in the April 9, 1990 letter, including concerns that the errors in the information provided to the NRC may have been intentional. Despite this awareness, the NRC could not find evidence to indicate that Mr. McCoy.took steps to ensure that a root cause analysis was performed.
In particular, Mr. McCoy failed to ensure that the performance of the VEGP General Manager and the Unit Superintendent in
' developing the April 9,1990 DG start data were critically examined. Thus, the NRC concludes that Mr. McCoy failed to exercise sufficient oversight of the preparation of the August 30, 1990 letter to ensure that serious NRC concerns were accurately addressed.
IV The performance failures recounted above represent a lack of management control and supervision over licensed activities, and raise a question as to whether the Licensee, with Mr. McCoy involved, will, in the future, provide
t 6-complete and accurate information to the NRC and otherwise comply with NRC requirements.
Therefore, further information is needed to determine whether the Commission
~
i i
can have reasonable assurance that in the future the Licensee, with the involvement of Mr. McCoy, will provide complete and accurate information to i
the Commission and otherwise conduct activities in accordance with the Commission's requirements.
V Accordingly, pursuant to sections 161c, 1610, 182 and 186 of the Atomic Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR 2.204 and 10 CFR 50.54(f), in order for the Commission to determine whether the Licenses.
should be modified to restrict the participation of Mr. McCoy in licensed activities or other enforcement action taken to ensure compliance with NRC regulatory req'uirements, the Licensee is required to submit to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, within 30 days of the date of this Demand for Information, the following information, in writing and under oath or affirmation:
_A..
A description of Mr. C. Kenneth McCoy's current position and responsibilities.
i.
8 i
-7 i
i B.
A description of actions that Mr. McCoy, as a senior manager, took to ensure that the Licensee provided the NRC with complete and accurate j
information in each of the five submittals.
j 0
C.
An explanation of why, notwithstanding his direct involvement in.the preparation of the June 29, 1990 letter, Mr. McCoy failed to ensure that 4
the letter clarified the April 9, 1990 letter and an explanation of why, notwithstanding his knowledge of the seriousness of the NRC concerns regarding the possible errors in the April 9,1990 letter, including concerns about potential wrongdoing, Mr. McCoy failed to exercise sufficient oversight of the preparation of the August 30, 1990 letter to ensure that it was complete and accurate in all material respects.
1 D.
An explanation of the corrective actions taken, or planned by the i
Licensee to address Mr. McCoy's-performance failures.
E.
Given the two violations of NRC requirements, an explanation as to why NRC should have confidence that the Licensee, with the involvement of Mr. McCoy, will in the future conduct licensed activities in accordance j
with all NRC requirements, including the requirements of 10 CFR 50.9,
" Completeness and accuracy of information."
Copies of the response also shall be sent to the Assistant General Counsel for Hearings and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555 and to the Regional Administrator, NRC Region II,101 Marietta Street, Suite 2900, Atlanta, GA 30323.
s
1
< 1 After revi6 wing your response, the NRC will determine whether further action is necessary to ensure compliance with regulatory requirements.
)
FOR THE NUCLEAR REGULATORY COMMISSION 9
N l'h 1
Ceputy Executive Director
~i for Nuclear Reactor Regulation, Regional Operations, and Research Dated at Rockville, Maryland j
this tLday of May 1994 i
l 4
I l
4 4
i l
4 4
1 i
40*d 92:OT P661-SO-SO
,poceem 4
- i S
UNITED STATES j
(
NUCLEAR REGULATORY COMMISSION r,
WASHINGTON, D.C. 20046 4001 W 0 9 igm l
George Bockhold, Jr.
Southern Nuclear Operating Company 40 Inverness Center Parkway
]
Birmingham, Alabama 35242
SUBJECT:
DEMAND FOR INFORMATION REGARDING GEORGE BOCKHOLD,-JR.
Dear Mr. Bockhold:
l Enclosed for your information and use is a DEMAND FOR INFORMATION REGARDING GEORGE BOCKHOLD, JR. (DFI) that is being issued to the Georgia Power Company l
(Licensee) on this date.
This DFI deals with your actions in providing information to the NRC on the Vogtle diesel generators and is being issued to obtain additional information to determine whether NRC should take further action to restrict your participation in NRC licensed and regulated activities.
You.are invited to submit a response to the enclosed DFI, separate from the response to be submitted by the Licensee. Wa will consider any response that' i
you choose to provide, along with the responses of the Licensee, in determining whether enforcement action that may impact your future participation in licensed activities is warranted in this-case.
If you do respond, your response should be submitted in writing to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.
Washington, DC 20555 within 30 days of the date of the enclosed DFI.
Should you have any questions on this matter, please call James Liebennan, Director, l
Office of Enforcement, at 301-504-2741.
Sincerely 0
([
x 4.8/M i
.. M11hoan 1 3eputy Executive Director for Wuclear Rsactor Regulation, l
Regional Operations and Research
Enclosure:
as stated cc w/o
Enclosure:
Georgia Power Company 4
a
' ~
PO*d PE:OT P66T-60-50
'4 UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
GEORGIA POWER COMPANY
)
Docket Nos. 50-425/50-425 (Vogtle Electric Generating
)
License Nos. NPF-68/NPF-81 Plant, Units 1 & 2)
)
EA 94-037 DEMAND FOR INFORMATION REGARDING GEORGE BOCKHOLD, JR.
I Georgia Power Company (Licensee) is the holder of Facility License Nos.
NPF-68, and NPF-81 (Licenses) issued by the Nuclear Regulatory Commission (NRC or Commission) pursuant to 10 CFR Part 50. The Licenses authorize the operation of the Vogtle Electric Generating Plant (VEGP) Units 1 and 2, in accordance with conditions specified therein.
II On December 17, 1993, an investigation of licensed activities was completed by the NRC's Office of Investigations (01) at Licensee's VEGP facility.
The investigation was initiated in response to information received in June 1990 by NRC Region II alleging, in part, that material false statements were made to the NRC by senior Licensee officials 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 (IA). The other Unit 1 DG (IB) was unavailable due to maintenance activities.
%3 llc 6A/
[2pf i
o 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 j
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 I 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 presentation.
GPC submitted c written summary of its April 9 presentation in an April 9,1990 letter, "Vogtle Electric Generating Plant Confirmation of Action Letter."
On April' 12, 1990, the NRC formally granted permission for VEGP Unit I to return to criticality and resume power operations.
On April 19, 1990, pursuant to 10 CFR 50.73, GPC submitted Licensee Event l
Report (LER) 50-424/90-006, "Lors of Offsite Power Leads to Site Area i
Emergency."
]
~
On June 29, 1990,iGPC submitted a revised LER, 50-424/96-006-01. 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 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 1, dated November 1,1991.
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.
4
4.
III The NRC has reviewed 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 (Docket.Nos. 50-3 424 OLA-3, 50-425 OLA-3), and other related information. The NRC has identified apparent violations of regulatory requirements involving five i
separate instances that occurred from April 9 t'o August 30, 1990, where the Licensee failed to provide information that was complete and accurate in all material respects. These violations are addressed in the Notice of Violation and Proposed Imposition of Civil Penalties issued to the Licensee on this date, and incorporated herein by reference'.
The NRC has also determined that the VEGP General Manager at the time of the violations, Mr: George Bockhold, Jr., played a major role in the original formulttion of much of the data on DG reliability and in the submittals and events associated with four of these violations and that his actions reflected a substantial failure to carry out his responsibilities. The circumstances surrounding these performance failures are described below.
Prior to GPC briefing the Regional Administrator, Region II, on VEGP's readiness for restart, the NRC asked GPC to address DG reliability as part of its restart presentation on April 9, 1990.
For that presentation, Mr. Bockhold was personally involved in the preparation of data regarding DG
s
- t i
^ '
i reliability and tasked the Unit Superintendent with collecting the number of 1
j successful DG starts for the 1A and IB DGs. Although Mr. Bockhold was aware l
of problems on DG 1B during overhaul, he failed to adequately specify the
~
starting point for the count to ensure that the count did not include these problems and failed to ensure that the Unit Superintendent understood his
. criteria for " successful starts."
In fact, Mr. Bockhold stated no criteria for successful starts, a term not formally defined, when he directed the Unit Superintendent to gather successful DG starts. Mr. Bockhold subsequently j
failed to ensure that the data the Unit Superintendent provided was the information he sought and intended to present to the NRC.
Specifically, Mr. Bockhold did not determine the point at which the Unit Superintendent l
began his count (i.e., the specific start number, date or time) or whether the Unit Superintendent's data included any problems or failures.
Information was then presented to the NRC in the April 9,1990 oral presentation by Mr. Bockhold and the April 9,1990 letter submitted by GPC, after being reviewed by Mr. Bockhold, that there were 18 and 19 consecutive successful starts on the 1A and IB DGs, respectively, without problems or failures.
Because of, in part, Mr. Bockhold's performance failures identified above, GPC's report of starts in the presentation and letter included three IB DG starts with problems that occurred during DG overhaul and maintenance activities (a high lube oil temperature trip on March 22, 1990; a low jacket water pressure / turbo lube oil pressure low 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 consecutive successful starts without problems or failures was 12 for IB DG--a number significantly less than that reported by GPC to the NRC on April 9, 1990. As a result of Mr. Bockhold's
t l
failures, the NRC relied, in part, upon inaccurate information provided by GPC in the April 9,1990 oral presentation and letter in reaching the NRC decision to allow Unit I to return to power operation.
1 l
i 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 review of the draft
[
LER, site personnel questioned its accuracy. Given that there were trips in the IB DG after March 20, 1990, they did not think that the statement I
concerning "no problems or failures" was correct. A teleconference was subsequently held between site and corporate personnel to address concerns that a count beginning on March 20, 1990 would include trips.
During this i
conversation, Mr. Bockhold confirmed that the start count reported on t.pril 9, 1990 began later than the problems--after completion of "a comprehensive test progras' (CTP) of the DG control systems.
By agreeing to the use of the term CTP in the LER, Mr. Bockhold agreed to the use of a term that was inadequate to specify the start point for the April 9,1990 start count that Mr. Bockhold intended to convey. Mr. Bockhold intended to convey that the count began after testing of the DG control systems which did not require diesel starts, 1.e., the calibration of the Calcon sensors and logic testing of the control systems.
However, it was reasonable to interpret that the CTP was completed with the first successful test to demonstrate operability, a point in time significantly later than the point intended by Mr. Bockhold.
This was the interpretation given to this term by many individuals within GPC and the NRC.
Mr. Bockhold had no sound basis for agreeing that the term CTP was adequate to convey what he intended, i.e., that the count being used as the basis for the April 19, 1990 LER began after testing of the DG control systems that did not
t 7
require diesel starts. As a result of Mr. Bockhold's failure to adequately specify when he intended to begin the start count, the 1A and IB DG start counts r9 ported on April 19, 1990 overstated the actual counts by including starts that were part of a CTP.
~
4 In light of the questions raised about the accuracy of the DG start information, Mr. Bockhold failed to take sufficient action to ensure that these questions were resolved.
Sufficient actions, if taken, could have enabled GPC to identify errors in the April 9,1990 letter before the issuance of the LER. Given these questions and the fact that Mr. Bockhold was uniquely aware of the informal means by which the data was developed for the April 9, 1990 letter, a reexamination of the April 9, 1990 data was warranted before submission of LER 90-006. There is no evidence to show that Mr. Bockhold, knowing that the April 9,1990 information was quickly assembled and reported to him informally, directed any review of the data to assure that the information in the April 19, 1990 LER was accurate. There is no evidence that Mr. Bockhold made any effort to contact the Unit Superintendent who had collected the data which Mr. Bockhold was relying on. Mr. Bockhold's statement during an April 19, 1990 phone call that the count he presented on April 9, 1990 had been " verified correct" by the Unit Superintendent implied that no further investigation of the data was necessary and may have led some GPC personnel to conclude that an adequate review of the DG start data had been completed, when it had not. The Vice President - Vogtle Project's response that "You ought to use those numbers" indicated that he relied on Mr. Bockhold's assurances that the data was correct. The Senior Vice
e 8-President - Nuclear Operations also stated that he thought the April 19, 1990 data had been checked.
On May 2,1990, Mr. Bockhold was given a list of DG starts that showed that
~
the start counts reported in the April 9, 1990 presentation, the April 9, 1990 CAL response letter, and the April 19, 1990 LER were incorrect. Mr. Bockhold 2
agreed that the LER needed to be revised to reflect the correct number of starts. Mr. Bockhold also agreed that the April 9,1990 letter needed to be corrected because he asked and was informed that the April 9, 1990 error was different than the April 19, 1990 error.
It was also agreed that uniform language would be used to correct both documents. The June 29, 1990 LER was submitted in part to make these corrections. Mr. Beckhold reviewed a draft of the June 29, 1990 LER revision, but he failed to ensure that it was accurate and complete in all material respects.
Specifically, the June 29, 1990 submittal stated that it would clarify the April 9,1990 letter but no such clarification, or even a relevant discussion of the April 9,1990 information, was included in the June 29, 1990 submittal. Mr. Bockhold's failure contributed to the Licensee's failure to provide complete information in the cover letter transmitting the June 29, 1990 LER revision.
During the NRC's Special Team Inspection exit interview on August 17, 1990, GPC was specifically notified by the NRC that the revised LER did not adequately clarify the DG start infcrmation contained in the April 9,1990 letter, and NRC requested GPC to provide clarification of this submittal. GPC forwarded a submittal to the NRC on August 30, 1990 regarding the April 9, 1990 letter. A draft of the August 30, 1990 letter, sent to the site for
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review, erroneously suggested that one of the reasons for the error in the P
April 9, 1990 letter was " confusion in the distinction between a successful.
start and a valid test" by the individuals who prepared the DG start
~
information for the April 9, 1990 letter. During an August 29, 1990 Plant Review Board (PRB) meeting which, among other things, reviewed the proposed August 30, 1990 submittal to the NRC, the VEGP Nanager - Technical Support i
i raised concerns about the accuracy of that statement. Mr. Bockhold admitted i
l to the PRB that the Unit. Superintendent (who originally collected the DG start dat: at Mr. Bockhold's direction) was not confused about the distinction between successful starts and valid tests when the start data was collected for the April 9,1990 letter, but stated that the sentence was not in error i
because other people were confused. Mr. Bockhold acknowledged that there was confusion among individuals after April 9,1990, but admitted that the Unit Superintendent was not confused when he developed the information. Confusion 4
after April 9,1990 was not relevant in explaining the reasons for the error in the April 9,1990 letter.
By retaining this wording, the first reason was inaccurate.
As a result of Mr. Bockhold's failure to adequately resolve this concern, the August 30, 1990 letter was inaccurate.
l IV 4
The performance failures recounted above collectively represent a very substantial failure on the part of Mr. Bockhold, a senior Licensee official, to ensure that information provided to the NRC is accurate and complete in all material respects. Mr. Bockhold was aware of the NRC's interest in DG b
reliability in the context of an NRC decision on restart and he was aware of
c
, questions and concerns about the adequacy, accuracy, and completeness of information that GpC was providing to the NRC on this issue, yet he failed to adequately address these concerns. Mr. Bockhold's actions and inactions as 1
the senior manager significantly contributed to the perpetuation and
~
escalation of the errors and omissions in the Licensee's submittals to the NRC. Mr. Bockhold's failures involved documents of significant regulatory importance. The NRC corsiders these failures particularly significant, because as VEGP General Manager, Mr. Beckhold wer in a position of considerable responsibility and influence and he appears to have not only used that stature to affect the submittals to the NRC, but through his actions he rendered ineffective the efforts of others, including the PRB, to provide accurate information to the NRC. These performance failures raise a question as to whether the Licensee, with Mr. Bockhold involved, will, in the future, provide complete and accurate information to the NRC and otherwise comply with NRC requirements.
Therefore, further information is needed to determine whether the Commission can have reasonable assurance that in the future the Licensee, with the 4
involvement of Mr. Bockhold, will provide complete and accurate information to the Commission and otherwise conduct activities in accordance with the Commission's requirements and why the Commission should not issue an order removing, or restricting the participation of Pir. Bockhold in NRC licensed activities.
=
c.
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Accordingly,. pursuant to sections 161c, 1610, 182 and 186 of the Atomic Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR 2.204 and l
10 CFR 50.54(f), in order for the Commission to determine whether the Licenses l
should be modified.to restrict the participation of Mr. Bockhold in licensed activities or other erdorcement action taken to ensure compliance with NRC regulatory requirements, the Licensee is required to submit to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, within 30 days of the date of this Demand for Information, the following information, in writing and under oath or affirmation:
e A.
A description of Mr. George Bockhold, Jr.'s curitr.t positio.n and l
responsibilities.
i J
B.
An explanation of why, notwithstanding his knowledge of the NRC':
interest'in DG reliability and the importance of information on this issue to an NRC decision on restart, Mr. Bockhold failed to take sufficient steps to ensure that information presented to the NRC in the April 9, 1990 presentation and letter regarding DG reliability was accurate and complete.
C.
An explanation of why, notwithstanding his lack of a sound basis for agreeing that the term CTP was adequate to conyey what he intended (i.e., that the DG start count being used as the basis for the April 19, 1990 LER began after testing of the DG control systems that did not B
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12 -
require diesel starts), Mr. Bockhold allowed this language to be included in the April 15, 1990 LER.
An explanation of why, notwithstanding his knowledge that questions had D.
been raised regarding the accuracy of the DG ste-t information and his knowledge of the informal means by which the data he was relying on was developed, Mr. Bockhold failed to take sufficient steps to ensure that information included in the April 19, 1990 LER was complete and accurate.
29, 1990 An explanation of why, notwithstanding.his review of the June E.
letter, which stated that it would clarify the April 9,1990 letter, Mr. Bockhold failed to ensure that the June 29, 1990 cover letter 1
Clarified the April 9, 1990 letter.
An explanation of why, notwithstanding his knowledge that the Unit F.
Superintendent was not confused about the distinction between successful i
starts and valid tests when the Unit Superintendent collected start data j
f for the April 9,1990 presentation and letter, Mr. Bockhold allowed the information to be included in the August 30, 1990 letter as one of the reasons for the error in the April 9, 1990 letter.
l An explanation of the corrective actions taken, or planned by the I
G.
Licensee to address Mr. Bockhold's performance failures.
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~x UNITED STATES
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NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 2088H001 W 0 9134 l
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Kenneth McCoy.
Southern Nuclear Operating Company
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40 Inverness Center. Parkway B$ aingham, Alabama 35242 j
SUBJECT:
DEMAND FOR INFORMATION REGARDING KENNETH McC0Y l
Dear.Mr. McCoy:
l Enclosed for your information and use is a DEMAND FOR INFORMATION REGARDING KENNETH McC0Y (DFI) that is being' issued to the Georgia Power Company l
(Licensee) on this date. This DFI. deals with your actions in providing l
information to the NRC on the Vogtle diesel generators and is being issued to i
obtain additional information to determine whether NRC should take further action to restrict your participation in NRC licensed and regulated i
activities.
1 I
You are invited to submit a response to the enclosed DFI, separate from the :
l response to be submitted by the Licensee. We will consider any response thatA j
you choose to provide, along with the responses of the Licensee, in determining whether enforcement action that may impact your future participation in licensed activities.is warranted in this case.
If you,do respond, your response should be submitted in writing to the i
Director, Office of Enforcement, U.S. Nuclear Regulatory Comeission, l
Washington, DC 20555 within 30 days of the date of the enclosed DFI.
Should j
you have any questions on this matter, please call James Lieberman, Director, Office of Enforcement,'at 301-504-2741.
f Sincerely i
1 f
L l
hues L. Milhoan puty Executive Director for i
i uclear Reactor Regulation, j
Regional Operations and Research i
Enclosure:
as stated cc w/o
Enclosure:
j Georgia Power Company r
I; L
1 l
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f UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
GEORGIA POWER COMPANY
)
Docket Nos. 50-425/50-425 (Vogtle Electric Generating
)
License Nos. NPF-68/NPF-81 Plant, Units 1 & 2)
)
EA 94-052 i
i i
DEMAND FOR INFORMATION l
REGARDING C. KENNETH McC0Y l
I Georgia Power Company (Licensee) is the holder of Facility License Nos.
NPF-68, and NPF-81 (Licenses) issued by the Nuclear Regulatory Commission (NRC or Commission) pursuant to 10 CFR Part'50. The Licenses authorize the operation of the Vogtle Electric Generating Plant (VEGP) Units 1 and 2, in accordance with conditions specified therein.
E l
II On December 17, 1993, an investigation of licensed activities was completed by the NRC's Office of Investigations (01) at Licensee's VEGP facility.
The investigation was initiated in response to information received in June 1990 by NRC Region 11 alleging, in part, that material false statements were made to the NRC by senior Licensee officials 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 l
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 (IA). The other Unit 1 DG l
(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 cf 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 1
Unit 1 to criticality until the Regional Administrator was satisfied that i
appropriate corrective actions had been taken, and ~that the plant could saf y i
return to power operations.
On April 9, 1990, GPC made a presentation to the NRC in the Region II offices l
in support of GPC's request to return VEGP Un n 1 to power operations. As a
part of this presentation, GPC provided information on DG starts in response l
to a specific NRC request that GPC address DG reliability in its April 9 presentation.
GPC submitted a written sumary of its April 9 presentation in i'
an April 9,1990 letter, "Vogtle Electric Generating Plant Confirmation of a
j Action Letter."
On April 12, 1990, the NRC formally granted permission for VEGP Unit 1 to return to criticality and resume power operations.
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1
- On April 19, 1990, pursuant to 10 CFR 50.73, GPC submitted Licensee Event i
Report (LER) 50-424/90-006, " Loss of Offsite Power Leads to Site Area:
Emergency."
j 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 that were discussed in the April 9, 1990 letter and the April 19, 1990 LER, i-and to update the status of corrective actions in the original LER.
i 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 1, dated November 1, 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.
t
- 4 III l
The NRC has reviewed the evidence associated with these events, submittals, and representations to the NRC. Specifically, the NRC reviewed information i
l 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 (Docket Nos. 50-l 424 OLA-3, 50-425 OLA-3), and other related information. The NRC has l
identified apparent violations of regulatory requirements involving five separate instances that occurred from April 9 to August 30, 1990, where.the 1
J Licensee failed to provide infomation that was complete and accurate in all-l j
material respects. These violations are addressed in the Notice of Violation f
and Proposed Imposition of Civ,1 Penalties issued to the Licensee on this date, and incorporated herein by reference.
l The NRC has also deterO ned that the Vice Prasident - Vogtle Project at the
[
time of two of these violations, Mr. C. Kenneth McCoy, failed to ensure that
[
information provided to the NRC was complete.
The circumstances surrounding his performance failures are described below.
1 Nr. McCoy was actively involved in the preparation of the June 29, 1990 cover letter for an-LER revision that was being submitted to the NRC and reviewed it prior to forwarding it to the Senior Vice President - Nuclear Operations for signature and issuance. The June 29, 1990 cover letter stated that its purpose was, in part, to clarify information provided to the NRC on April 9,
c h
1990. However, no such clarification, or even a relevant discussion _of the l
April 9, 1990 information, was provided in the June 29, 1990 submittal.
Mr. McCoy also failed to ensure that the August 30, 1990 letter submitted to the NRC adequately explained the reasons for the errors in the April 9,1990 t
letter. Mr. McCoy committed during the August 17, 1990 meeting with the NRC j
l Special. Inspection Team to provide clarification to the.NRC regarding the April 9, 1990 letter. Based on the evidence of Licensee' discussions i
subsequent to this meeting with the NRC, Mr. McCoy was aware of the j
l seriousness of the NRC concerns regarding the possible errors in the April 9, j
1990 letter, including concerns that the errors in the information provided o i
the NRC may have been intentional. Despite this awareness, the NRC could not l
j find evidence to indicate that Mr. McCoy took steps to ensure'that a root j
cause analysis was perfe'ined.
In particular, Mr. McCoy failed to ensure that the performance of the VEGP General Manager and the Unit Superintendent in developing the April 9,1990 DG start data were critically examined. Thus, the NRC concludes that Mr. McCoy failed to exercise sufficient oversight of the preparation of the August 30, 1990 letter to ensure that serious NRC concerns were accurately addressed.
IV The performance failures recounted above represent a lack of management control and supervision over licensed activities, and raise a question as to whether the Licensee, with Mr. McCoy involved, will, in the future, provide I
_ _. _ =
l l
i 6-i complete and accurate information to the NRC and otherwise comply with NRC requirements.
1 Therefore, further information is needed to determine whether the Commission i
can'have reasonable assurance that in the future the Licensee, with the involvement of Mr. McCoy, will provide complete and accurate information to i
the Commission and otherwise conduct activities in accordance with the
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Cosmiission's requirements.
i I
j Accordingly, pursuant to sections 161c, 161o, 182 and 186 of the Atomic Energy i
l Act of 1954, as amended, and the Commission's regulations in 10 CFR 2.204 and-t 10 CFR 50.54(f), in order for the Commission to determine whether the Licenses should be modified to restrict the participation of Mr. McCoy in licensed
~
activities or'other enforcement action taken to ensure compliance with NRC i
regulatory requirements, the Licensee is required to submit to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, within 30 days of the date of this Demand for Information, the following information, in writing and under oath or affirmation:
A.
A description of Mr. C. Kenneth McCoy's current position and responsibilities.
s w
i
- B.
A description of actions that Mr. McCoy, as a senior manager, took to I
ensure that the Licensee provided the NRC with complete and accurate 4
information in each of the five submittals.
C.
An' explanation of why, notwithstanding his direct involvement in the preparation of the June 29, 1990 letter, Mr. McCoy failed to ensure that the letter clarified the April 9,1990 letter and an explanation of why, notwithstanding his knowledge of the seriousness of the NRC concerns regarding the possible errors in the April 9,1990 letter, including concerns about potential wrongdoing, Mr. McCoy failed to exercise sufficient oversight of the preparation of the August 30, 1990 letter o ensure that it was complete and accurate in all material respects.
D.
An explanation of the corrective actions taken, or planned by the Licensee to address Mr. McCoy's performance failures.
E.
Given the two violations of NRC requirements, an explanation as to why
~
NRC should have confidence that the Licensee, with the involvement of Mr. McCoy, will in the future conduct licensed activities in accordance with all NRC requirements,. including the requirements of 10 CFR 50.9,
" Completeness and accuracy of information."
Copies of the response also shall be sent to the Assistant General Counsel for Hearings and Erfforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.
~
20555 and to the Regional Administrator, NRC Region II,101 Marietta Street, Suite 2900, Atlanta, GA 30323.
i e
J i After reviewing your response, the NRC will determine whether further action is necessary to ensure c'ompliance with regulatory requirements.
FOR THE NUCLEAR REGULATORY COMISSION 4
9 i
N l'ho eputy Executive Director j
for Nuclear Reactor Regulation, i
Regional Operations, and Research Dated at Rockville, Maryland this A day of May 1994 s
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3-UNITED STATES e
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NUCLEAR REGULATORY COMMISSION j
- $g.....,/
wasuiwoTon, o.c. sosas.cooi L
HU 0 91994 1
t George Bockhold, Jr.
j Southern Nuclear Operating Company 40 Inverness Center Parkway Birmingham, Alabama 35242 i
SUBJECT:
DEMAND FOR INFORMATION REGARDING GEORGE BOCKHOLD, JR.
l
Dear Mr. Bockhold:
J Enclosed for your information and use is a DEMAND FOR INFORMATION REGARDING GEORGE BOCKHOLD, JR. (DFI) that is being issued to the Georgia Power Company (Licensee) on this date. This DFI deals with your actions in providing i
4 information to the NRC on the Vogtle die.sel generators and is being issued to j
obtain additional information to determine whether NRC should take further action to restrict your participation in NRC licensed and regulated activities.
f You are invited to submit a response to the enclosed DFI, separate from the j response to be submitted by the Licensee. We will consider any response thar you choose to provide, along with the responses of the Licensee, in 2
i determining whether enforcement action that may impact your future participation in licensed activities is warranted in this case.
j If you do respond, your response should be submitted in writing to the l
Director, Offic9 of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555 within 30 days of the date of the-enclosed DFI.
Should you have any questions on this matter, please call James Lieberman, Director, Office of-Enforcement, at 301-504-2741.
L j
Sincerely I
0 l
(
L.8/ M (W
Milhoan L
I peputy Executive Director for l
9duelear Reactor Regulation, Regional Operations and Research l
Enclosure:
as stated cc w/o
Enclosure:
j Georgia Power Company h
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UNITED STATES NUCLEAR REGULATORY COMISSION In the Matter of
)
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)
GEORGIA POWER COMPANY
)
Docket Nos. 50-425/50-425 (Vogtle Electric Generating
)
License Nos. NPF-68/NPF-81 Plant, Units 1 & 2)
)
EA 94-037 DEMAND FOR INFORMATION REGARDING GEORGE 80CKHOLD, JR.
I j
I Georgia Power Company (Licensee) is the holder of Facility License Nos.
NPF-68, and NPF-81 (Licenses) issued by the Nuclear Regulatory Commission (NRC l
or Commission) pursuant to 10 CFR Part 50. The Licenses authorize the operation of the Vogtle Electric Generating Plant (VEGP) Units 1 and 2, in i
1 l
accordance with conditions specified therein.
4 s
II 4
On December 17, 1993, an investigation of licensed activities was completed by i
j the NRC's Office of Investigations (01) at Licensee's VEGP facility. The investigation was initiated in response to information received in June 1990 by NRC Region II alleging, in part, that material false statements were made to the NRC by senior Licensee officials 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 j
failure of the only Unit 1 DG that was available (IA). The other Unit 1 DG i
(IB) was unavailable due to maintenance activities.
l 9/b@eM /RP
4
. 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 tetter (CAL) to GPC that, among other things, confirmed that GPC had agreed not to return VEGP l
Unit I to criticality until the Regional Administrator was satisfied that appropriate corrective actions had been taken, and that the plant could safe y return to power operations.
l 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 I 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 presentation.
GPC submitted a written summary at fts April 9 presentation in an April 9,1990 letter, "Vogtle Electric Generating Plant Confirmation of Action Letter."
On April 12,'1990, the NRT %, ally granted permission for VEGP Unit I to return to criticality and resume power operations.
1
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 i
Emergency."
On June 29, 1990, GPC submitted a revised LER, 50-424/90-006-01. The purpose of the submittal was to clarify information related te successful DG starts that were discussed in the April 9,1990 letter and the April 19, 1990 LER, i
and to update the status of corrective actions in the original LER.
From August 6 through August 17, 1990, the NRC conducted a Special Team InspectionatVEGP,asaresultofNRCconcernsabout,andallegationsrelath t
to, VEGP operational activities. This inspoction examined the technical 4
validity and safety significance of the allegations, but did not investigate l
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 l
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.
b 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.
. III l.
l l
The NRC has 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, information gathered during the IIT, NUREG-1410, Supplement 1 of NRC Inspection Report 90-1g, discovery responses in the Vogtle operating license amendment proceeding (Docket Nos. 50-l 424 OLA-3, 50-425 OLA-3), and other related information. The NRC has identified apparent violations of regulatory requirements involving five separate instances that occurred from April 9 to August 30, 1990, where the Licensee'failedtoprovideinformationthatwascompleteandaccurateinal1$
material respects. These violations are addressed in the Notice of Violatiod and Proposed Imposition of Civil Penalties issued to the Licensee on this date, and incorporated herein by reference.
The NRC has also determined that the VEGP General Manager at the time of the violations, Mr. George Bockhold, Jr., played a major role in the original formulation of much of the data on DG reliability and in the submittals and events associated with four of these violations and that his actions reflected a substantial failure to carry out his responsibilities. The circumstances surrounding these performance failures are described below.
Prior to GPC briefing the Regional Administrator, Region II, on VEGP's readiness for restart, the NRC asked GPC to address DG reliability as part of its restart pre'sentation on April 9, 1990.
For that presentation, Mr. Bockhold was personally involved in the preparation of data regarding DG i
l
. reliability and tasked the Unit Superintendent with collecting the number of successful DG starts for the 1A and IB DGs. Although Mr. Bockhold was aware of problems on DG 18 during overhaul, he failed to adequately specify the l
starting point for the count to ensure that the count did'not include these l
l problems and failed to ensure that the Unit Superintendent understood his criteria for " successful starts."
In fact, Mr. Bockhold stated no criteria l
for successful starts, a term not formally defined, when he directed the. Unit Superintendent to gather successful DG starts. Mr. Bockhold subsequent 1v failed to ensure that the data the Unit Superintendent provided was the information he sought and intended to present to the NRC.
Specifically, Mr. Bockhold did not determine the point at which the Unit Superintendent j
beganhiscount(i.e.,thespecificstortnumber,dateortime)orwhetherthe Unit Superintendent's data included any problems or failures.
Information was then presented to the NRC in the April 9, 1990 oral presentation by Mr. Bockhold and the April 9, 1990 letter submitted by GPC, after being reviewed by Mr. Bockhold, that there were 18 and 19 consecutive successful starts on the 1A and IB DGs, respectively, without problems or failures.
Because of, in part, Mr. Bockhold's perfortance failures identified above, i
GPC's report of starts in the presentation and letter included three IB DG starts with problems that occurred during DG overhaul and maintenance activities (a high lube oil temperature trip on March 22, 1990; a low Jacket l
l water pressure / turbo lube oil pressure low 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 consecutive successful starts without problems or faflures was 12 for IB DG--a number significantly less than that l
reported by GPC to the NRC on April 9, 1990. As a result of Mr. Bockhold's l
l l
i failures, the NRC relied, in part, upon' inaccurate information provided by GPC f
in the April 9, 1990 ora 1' presentation and letter in reaching the NRC decision l
to allow Unit I to return to power operation.
LER 80 006, submitted to the NRC on April 19, 1990, was based, in part, on information presented to the NRC on April 9, 1990. During review of the draft l
LER. site personnel questioned its accuracy. Given that there were trips in l
j
.the IB DG after March 20, 1990, they did not think that the statement concerning "no problems or failures" was correct. A teleconference was i
subsequently held between site and corporate personnel to address concerns 4
that a count beginning on March 20, 1990 would include trips. During this l
conversation, Mr. Bockhold confirmed that the start count reported on April 9, 4
1990 began later than the problems--after completion of "a comprehensive test i
program" (CTP) of the DG control systems.
By agreeing to the use of the tem l
CTP in the LER, Mr. Bockhold agreed to the use of a tem that was inadequate to specify the start point for the April 9, 1990 start count that Mr. Bockhold 5
l' intended to convey. Mr. Bockhold intended to convey that the count began after testing of the DG control systems which did not require diesel starts, i.e., the calibration of the Calcon sensors and logic testing of the control systems. However, it was reasonable to interpret that the CTP was completed with the.first successful test to demonstrate operability, a point in time l
significantly later than the point intended by Mr. Bockhold. This was the interpretation given to this term by many individuals within GPC and the NRC.
Mr. Bockhold had no sound basis for agreeing that the term CTP was adequate to convey what he ' intended, i.e., that the count being used as the basis for the f
April 19, 1990 LER began after testing of the DG control systems that' did not i
r i
. require diesel starts. As a result of Mr. Bockhold's failure to adequatuly specify when he intended to begin the start count, the 1A and IB DG start counts reported on April 19, 1990 overstated the actual counts by including starts that were part of a CTP.
l In light of the questions raised about the accuracy of the DG start l
information, Mr. Bockhold failed to take sufficient action to ensure that i
these questions were resolved.
Sufficient actions, if taken, could have enabled GPC to identify errors in the April 9,1990 letter before the issuance of the LER. Given these questions and the fact that Mr. Bockhold was uniquely l
aware of the informal means by which the data was developed for the April 9,'
i l
l 1990 letter, a reexamination cf the April 9, 1990 data was warranted before submission of LER 90-006. There is no evidence to show that Mr. Bockhold, knowing that the April 9,1990 information was quickly assembled and reported to him informally, directed any review of the data to assure that the information in the April 19, 1990 LER was accurate. There is no evidence that j
l Mr. Bockhold made any effort to contact the Unit Superintendent who had l
collected the data which Mr. Bockhold was relying on. Mr. Bockhold's statement during an April 19, 1990 phone call that the count he presented on April 9, 1990 had been " verified correct" by the Unit Superintendent implied that no further investigation of the data was necessary and may have led some GPC personnel to conclude that an adequate review of the DG start data had been completed, when it had not.
The Vice President - Vogtle Project's response that "You ought to use those numbers" indicated that he relied on Mr. Bockhold's 4ssurances that the data was correct. The Senior Vice
l l
{ r President - Nuclear Operations also stated that he thought the April 19, 1990 data had been checked.
l On May 2, 1990, Mr. Bockhold was given a list of DG starts that showed that i
the start counh reported in the April 9, 1990 presentation,.the April 9, 1990
.l CAL response letter, and the April 19, 1990 LER were incorrect. Mr. Bockhold agreed that the LER needed to be revised to reflect the correct number of I
starts. Mr. Bockhold also agreed that the April 9, 1990 letter needed to be corrected because he asked and was informed that the April 9, 1990 error was different than the April 19, 1990 error.
It was also agreed that unifom language would be used to correct both documents. The June 29, 1990 LER was-submitted in part to make these corrections.. Mr. Bockhold reviewed a draft of the June 29, 1990 LER revision, but he failed to ensure that it was accurate and complete in all material respects.
Specifically, the June 29, 1990 submittal stated that it would clarify the April 9,1990 letter but no such clarification, or even a relevant discussion of the April 9, 1990 information, 4
was included in the June 29, 1990 submittal. Mr. Bockhold's failure contributed to the Licensee's failure to provide complete information in the cover letter transmitting the June 29, 1990 LER revision.
4 During the NRC's Special Team Inspection exit interview on August 17, 1990, GPC was specifically notified by the NRC that the revised LER did not adequately clarify the DG start information contained in the April 9,1990 letter, and NRC requested GPC to provide clarificttion of this submittal. GPC forwarded a sutimittal to the NRC on August 30, 1990 regarding the April 9, f
1990. letter. A draft of the August 30, 1990 letter, sent to the site for l
l.
4
- review, erroneously suggested that one of the reasons for the error in the April 9, 1990 letter was " confusion in the distinction between a successful start and a valid test" by the individuals who prepared the DG start l
information for the April 9, 1990 letter. During an August 29, 1990 Plant Review Board (PRB) meeting which, among other things, reviewed the proposed August 30, 1990 submittal to the NRC, the VEGP Manager - Technical Support raised concerns about the accuracy of that statement. Mr. Bockhold admitted to the PRB that the Unit Superintendent (who originally collected the DG start data at Mr. Bockhold's direction) was not confused about the distinction between successful starts and valid tests when the start data was collected fortheApril9,1990 letter,butstatedthatthesentenetwasnotinerrori because other people were confused. Mr. Bockhold acknowledged that there wa4 confusion among individuals after April 9,1990, but admitted that the Unit
' Superintendent was not confused when he developed the information. Confusion after April 9,1990 was not relevant in explaining the reasons for the error in the April 9, 1990 letter. By retaining this wording, the first reason was inaccurate. As a result of Mr. Bockhold's failure to adequately resolve this concern, the August 30, 1990 letter was inaccurate.
IV i
The performance failures recounted above collectively represent a very i
substantial failure on the part of Mr. Bockhold, a senior Licensee official, to ensure that information provided to the NRC is accurate and complete in all material respedts. Mr. Bockhold was aware of the NRC's interest in DG reliability in the context of an NRC decision on restart and he was aware of
l l
' questions and concerns about the adequacy, accuracy, and completeness of information that GPC was providing to the NRC on this issue, yet he failed to
(
adequately address these concerns. Mr. Bockhold's actions and inactions as the senior manager significantly contributed to the perpetuation and escalation of the errors and omissions in the Licensee's submittals to the NRC. Mr. Bockhold's failures involved documents of significant regulatory importance. The NRC considers these failures particularly significant, because as VEGP General Manager, Mr. Bockhold was in a position of considerable responsibility and influence and he appears to have not only used that stature to affect the submittals to the NRC, but through his actions he rendered ineffective the efforts of others, including the PRB, to provide I
accurate information to the NRC. These perf.ormance' failures raise a questiod as to whether the Licensee, with Mr. Bockhold involved, will, in the future, provide complete and accurate information to the NRC and otherwise comply with NRC requirements.
Therefore, further information is needed to determine whether the Commission can have reasonable assurance that in the future the Licensee, with the involvement of Mr. Bockhold, will provide complete and accurate information to the Commission and otherwise conduct activities in accordance with the Commission's requirements and why the Commission should not issue an order removing, or restricting the participation of Mr. Bockhold in NRC licensed activities.
l i
l l
l
e V
\\
Accordingly, pursuant to sections 161c, 161o, 182 and 186 of the Atomic Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR 2.204 and 10 CFR 50.54(f), in, order for the Commission to determine whether the Licenses should be modified to restrict the participation of Mr. Bockhold in licensed actv ities or other enforcement action taken to ensure compliance with NRC i
i regulatory requirements, the Licensee is required to submit to the Director, Office of Enforcement, U.S. Nucle'ar Regulatory Connission, Washington, D.C.
l 20555, within 30 days of the date of this Demand for Infomation, the following information, in writing and under oath or affirmation:
i i
A.-
A description of Mr. George Bockhold, Jr.'s current position and l
responsibilities.
B.
An explanation of why, notwithstanding his knowledge of the NRC's interest in DG reliability and the importance of infomation on this issue to an NRC decision on restart, Mr. Bockhold failed to take i
sufficient steps to ensure that information presented to the NRC in the April 9,1990 presentation and letter regarding DG reliability was accurate and complete.
C.
An explanation of why, notwithstanding his lack of a sound basis for agreeing that the tern CTP was adequate to convey what he intended 4
(i.e., t!!at the DG start count being used as the basis for the April 19, 1990 LER began after testing of the DG control systems that did not f
-. - ~
b*
3 H.
Given the four violations of NRC requirements, an explanation as to why NRC should have confidence that the Licensee, with the involvement of t
Mr. Bockhold, will in the future conduct licensed activities in
]
accordance with all NRC requirements, including the requirements of 10 CFR 50.9, " Completeness and accuracy of information."
l i
Copies of the response also shall be sent to the Assistant General Counsel for j
Hearings and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.
)
i
.20555 and to the Regional Administrator, NRC Region II, 101 Marietta Street, 1
l Suite 2900, Atlanta, GA 30323.
1 l
l a
After reviewing your response, the NRC will. determine whether further actio is necessary to ensure compliance with regulatory requirements.
i FOR THE NUCLEAR REGULATORY C0fetISSION l.
l Milhoan
)
'puty Executive Director
.i D i l
or Nuclear Reactor Regulation, j
Ntegional Operations, and Research i-Dated at Rockville, Maryland l
this y'thday of May 1994 i
i
i i require diesel starts), Mr. Bockhold allowed this language to be included in the April 19, 1990 LER.
D.
An explanation of why, notwithstanding his knowledge that questions had
{
been raised regarding the accuracy of the DG start information and his knowledge of the informal means by which the data he was relying on was developed, Mr. Bockhold failed to take sufficient steps to ensure that information included in the April 19, 1990 LER was complete and accurate.
E.
An explanation of why, notwithstanding his review of the June 29,1990h letter, which stated that it would clarify the April 9,1990 letter, k
Mr. Bockhold failed to ensure that the June 29, 1990 cover letter clarified the April 9, 1990 letter.
F.
An explanation of why, notwithstanding his knowledge that the Unit Superintendent was not confused about the distinction-between successful starts and valid tests when the Unit Superintendent collected start data for the April 9, 1990 presentation and letter, Mr. Bockhold a1 Towed the information to be included in the August 30, 1990 letter as one
' the reasons for the error iti the April 9,1990 letter.
j G.
An explanation of the corrective actions taken, or planned by the Licensee to address Mr. Bockhold's performance failures.
/
s f
A UNITED STATES
}
NUCLEAR REGULATORY COMMISSION i
5 j
/
WASHINGTON, D.C. 2006H001
}
lim 0 91994 d
Thomas V.: Greene Southern Nuclear Operating Company 40 Inverness Center Parkway l
Birmingham, Alabama 35242 i
SUBJECT:
DEMAND FOR INFORMATION REGARDING THOMAS V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON i
e
Dear Mr. Greene:
}
Enclosed for your information and use is a DEMAND FOR iniORMATION REGARDING l
THOMAS V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON l
(DFI)_that is being issued to the Georgia Power Company (Licensee) on this date. This DFI deals, in part, with your actions in providing information w the NRC on the Vogtle diesel generators and is being issued to obtain 1
additional-information to determine whether NRC should take further action to-i
~
restrict your participation in NRC licensed and regulated activities.
4 You are invited to submit a response to the' enclosed DFI, separate from the 8 l
response to be submitted by the Licensee. We will consider any response that l
you choose to provide, along with the responses of the Licensee, in determining whether enforcement action that may impact your future participation in-licensed activities is warranted in this case.
l If you do respond, your response should be submitted in writing to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, j.
Washington, DC 20555 within 30 days of the date of the enclosed DFI. Should j
you have any questions on this matter, please call James Lieberman, Director, Office of Enforcement, at 301-504-2741.
4 Sincerely L
l
- d. L.
Mil oa i
14puty Executive Director for i
luclear Reactor Regulation, Regional Operations and Research 5
Enclosure:
As Stated t
cc w/o
Enclosure:
l Georgia Power Company f
b i
I 4
k/Nhb '
i
... _... _.. ~ _. _ _ _ _. _. _ _ _ _ _ _..,
L*
- a n,%
S UNITED f8TATES j
i NUCLEAR REGULATORY COMMISSION
.....,/
g-wasuiworow. o.c. nosswooi MAY 0 9194 l
I Georgie R. Frederick
^
Georgia Power Company Vogtle Electric Generating Plant River Road Waynesboro, Georgia 30830 l
SUBJECT:
DEMAND FOR INFORMATION REGARDING THOMAS V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON
Dear Mr. Frederick:
Enclosed for your information and use is a DEMAND FOR INFORMATION REGARDING THOMAS V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS,'AND MICHAEL W. HORTON (DFI) that is being issued to the Georgia Power Company (Licensee) on this date. This DFI deals, in part, with your actions in providing information to the NRC on the Vogtle diesel generators and is being issued to obtain i
additional information to determine whether.NRC should take further action to.
i restrict your participation in NRC licensed and regulated activities.
i-You are invited to submit a response to..the enclosed DFI, separate from the response to be submitted by the Licensee. We will consider any response that you choose to provide, along with the responses of the Licensee, in determining wh' ether enforcement action that may impact your future participation-in licensed activities is warranted in this case.
i If you do respond, your response should be submitted in writing to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555 within 30 days of.the date of the enclosed DFI. Should i
you have any questions on this matter, please call James Lieberman, Director, j
Office of Enforcement, at 301-504-2741.
Sincerely
- l..
A mes
. Milhoan puty Executive Director for uclear Reactor Regulation, Regional Operations and Research
Enclosure:
as stated cc w/o
Enclosure:
Georgia Power Company l
q&m e.
l
y **"*%
s k
e, e UNITED STATES 5
NUCLEAR REGULATORY COMMISSION
- \\.....,/
WASWNGTON, D.C. 20 2 0001 i
)
ll4Y 0 9 19H Harry Majors-
. Southern Nuclear Operating Company 40 Inverness Center Parkway j
Birmingham, Alabama 35242
SUBJECT:
DEMAND FOR INFORMATION REGARDING THOMAS V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON
Dear Mr. Majors:
3_
j Enclosed for your information and use is a DEMAND FOR INFORMATION REGARDING THOMAS V. GREENE, CEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON
-(DFI) that is being issued to the Georgia Power Company (Licensee) on this date. This DFI deals, in part, with your actions in providing information to i
the NR( on the Vogtle diesel generators and is being issued to obtain additional information to determine whether NRC should take further action to i
restrict your participation in NRC licensed and regulated activities.
You are invited to submit a response to the enclosed DFI, separate fro = the I response to be submitted by the Licensee. We will consider any response that you choose to provide, along with the responses of the Licensee, in l
determining whether enforcement action that may impact your future
. participation in licensed activities is warranted in this case.
1 i
If you do respond, your response should be submitted in writing to the i
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555 within 30 days of the date of the enclosed DFI. Should you have any questions on this matter, please call James Lieberman, Director, j
Office of Enforcement, at 301-504-2741.
1 Sincerely I
C (Jw 1.
( ames L. Milhoan I geputy Executive Director for Wuclear Reactor Regulation, Regional Operations and Research
Enclosure:
as stated cc w/o
Enclosure:
Georgia Power Company k
3 4
%CO.'c5 L/A
. - - _ -.. ~ -. -.
- purm%
i f
i j
UNITED STATES
(
f NUCLEAR REGULATORY COMMISSION g
WASHINGTON, D.C. WAA "1
.....j j
MY 0 9134 Michael W. Horton Southern Nuclear Operating Company 40 Inverness Center Parkway l
Birmingham, Alabama 35242
]
SUBJECT:
DEMAND FOR INFORMATION REGARDING THOMAS V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON 1
i l
Dear Mr. Horton:
i Enclosed for your information and use is a DEMAND FOR INFORMATION REGARDING
[
THOMAS V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON (DFI) that is being issued to the Georgia Power Company (Licensee) on this f
date. This DFI deals, in part, with your actions in providing information to
{
the NRC on the Vogtle diesel generators and is being issued to obtain j
additional information to determine whether NRC should take further action to restrict your participation in NRC licensed and regulated activities.
i You are invited to submit a response to the enclosed DFI, separate from the j
{
response to be submitted by the Licensee. We will consider any response that you choose to provide, along with the responses of the Licensee, in 3
determining whether enforcement action that may impact your future j
participation in licensed activities is warranted in this case.
4 i
If you do respond, your response should be submitted in writing to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555 within 30 days of the date of the enclosed DFI. Should you have any questions on this matter, please call James Lieberman, Director, Office of Enforcement, at 301-504-2741.
Sincerely C
- 4. 7 77 &
Milhoan eputy Executive Director for uclear Reactor Regulation, Regional Operations and Research
Enclosure:
as stated cc w/o
Enclosure:
Georgia Power Company
%c5Ulu)?
/ ?-
/
i l
UNITED STATES j
NUCLEAR REGULATORY COMNISSION j
In the Matter of
)
)
GEORGIA POWER COMPANY
)
Docket Nos. 50-425/50-425 (Vogtle Electric Generating
)
License Nos. NPF-68/NPF-81 4
Plant, Units 1 & 2)
)
EA 94-036 s -
DEMAND FOR INFORMATION j
REGARDING THOMAS V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL _W.
HORTON' j
I a
i Georgia Power Company (Licensee) is the holder of Facility License Nos. NPF-68 i
and NPF-81 (Licenses) issued by the Nuclear Regulatory Commission (NRC or i
Commission) pursuant to 10 CFR Part 50. The Licenses authorize the operation of the Vogtle Electric Generating Plant (VEGP) Units 1 and 2, in accordance,
e l
with conditions specified therein.
i i
I II l
i l
l On December 17, 1993, an investigation of licensed activities was completed by i
l the NRC's Office of Investigations (01) at Licensee's VEGP facility. The 1
l investigation was initiated in response to information received in June 1990 by NRC Region II alleging, in part, that material false statements were made i
l to the NRC by senior Licensee officials regarding the reliability of the l
Diesel Generators (DGs). The pertinent events involved in this matter are l
described below.
i 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 I
i j
l9 '!a^dwNL//Op?
! L failure of the only Unit 1 DG that was available (IA). The other Unit 1 DG l
(IB) was unavailable due to maintenance activities.
i l
The NRC immediately responded to the SAE at the VEGP site with an Augmented t
i Inspection Team (AIT). The NRC effort was upgraded to an Incident i
1 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 Sr. item During Mid-loop Operations at Vogtle Unit 1 on March 20, 1990."
l i
On March 23, 1990, theNRCissuedaConfirmationofActionLetter(CAL)toGhc that, among other things, confirmed that GPC had agreed not to return VEGP Unit I 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 I 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 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."
. p l
On April 12, 1990, the NRC formally granted permission for VEGP Unit I to l
return to criticality and resume power operations.
i
}
On April 19, 1990, pursuant to 10 CFR 50.73, GPC submitted Licensee Event j
Report (LER) 50-424/90-006, " Loss of Offsite Power Leads to Site Area l
Emergency."
1 l'
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 that were discussed in the April 9, 1990 letter and the April 19, 1990 LER, i
and to update the status of corrective actions in the original LER.
I l
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 l
validity and safety significance of the allegations, but did not investigate l
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 claiify 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.
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.
l i
I
i:.
4 s
III The NRC has reviewed 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, j
NUREG-1410, Supplement 1 of NRC Inspection Report 90-19, discovery responses i
in the Vogtle operating license amendment proceeding (Docket Nos. 50-t
)
424 OLA-3, 50-425 OLA-3), and other related information. The NRC has identified apparent violations of regulatory requirements involving five i
separate instances that occurred from April 9 to August 30, 1990, where the l
Licensee failed to provide information that was complete and accurate in allj material respects. TheseviolationsareaddressedintheNoticeofViolatio$
j and Proposed Imposition of Civil Penalties issued to 'the Licensee on this date, and incorporated herein by reference.
r l
The NRC has also identified several current Licensee employees whose i
significant performance failures contributed to ont; Of these violations and j
whose failures to ensure that complete and accurate information was submitted to the NRC occurred after they were explicitly advised of inaccuracies and problems in the draft submittal. The circumstances surrounding these performance failures are described below.
On June 29, 1990, the draft cover letter for the LER revision was being reviewed at the VEGP site. The draft had originated in GPC corporate headquarters arid included language personally developed by the Senior Vice President - Nuclear Operations (George W. Hairston, III) and the Vice
- l. President - Vogtle Project (C. Kenneth McCoy). During this review, a VEGP Technical Assistant (TA) (formerly the Acting VEGP Assistant General Manager -
l Plant Support) (Alan L. Mosbaugh) noted that the draft cover letter was j
incomplete and challenged the accuracy of the reasons stated in the draft l
cover letter in conversations with the Supervisor. Safety Audit and l
Engineering Review (SAER) (Georgie R. Frederick), the VEGP Assistant General i
Manager - Plant Support (Thomas V. Greene), the VEGP Manager - Engineering i.
Support (Michael W. Horton), and a Licensing Engineer - Vogtle Project (Harry 1
j W. Majors). Mr. Mosbaugh stated that: (1) the letter failed to clarify the DG starts reported on April 9, 1990 (2) DG record ~ keeping practices were not a l
cause of the diffu ence in the DG starts reported in the April 19, 1990 LER :
because adequate information to formulate an accurate count was available whtn t-i the counting errors were made, and (3) the erroneous counts resulted from personnel errors in developing the count. Mr. Majors, Mr. Horton, Mr. Frederick, and Mr. Greene were fully aware of these assertions but failed to adequately resolve these concerns before issuance of the June 29, 1990 letter.
Mr. Majors 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 closely with the site to ensure that the submittal was accurate and complete. Despite this clear direction, and after having been informed by the site of the clear failure of the June 29, 1990 draft cover letter to address the April 9,1990 letter that it referenced and that the April 9, 1990 errors were different from the April 19, 1990 errors,
4 e
. Mr. Majors failed to address these concerns prior to issuance of the LER revision.
Mr. Horton was responsible for the Diesel Start Logs and agreed with the audit report findings regarding deficiencies in their condition.. Given that his logs had not been used to collect the DG start data, he pointed out that it was wrong to state that the condition of his logs caused errors in the l
information initially provided to the NRC. Mr. Horton, who understood and agreed that DG record keeping practices.were not a cause of the difference in
]
the DG starts reported in the April 19, 1990 LER and the June 29, 1990 lette,
nevertheless approved the erroneous draft as a voting member of the Plant I
Review Board (PRB) without resolving the problems in the draft.
l i
Mr. Frederick was aware that the audit (that formed the basis for the reasons stated in the June 29, 1990 letter) was narrow in scope and did not identify a specific cause for the error in the number of 18 starts reported in the April 19, 1990 LER. Mr. Frederick was also aware that observations stated in d
the audit report were inappropriately. being used to identify the root causes for the errors in the April 19, 1990 LER. Mr. Mosbaugh and Mr. Horton made Mr. Frederick aware of this inaccuracy, but Mr. Frederick, with apparent indifference, defended the inaccuracy. Also, Mr. Frederick was made aware by Mr. Mosbaugh on June 12, 1990 that, to identify the root cause of the error in the April 19, 1990 LER (i.e., personnel errors), the audit scope would need to include an assessment of the performance of the Unit Superintendent and the VEGP General Manager, the individuals that developed the initial count. Yet, the audit report did not include either of these individuals in the list of
l i !
persons contacted during the audit. On June 29, 1990, Mr. Frederick was again i
i j
made aware by Mr. Mosbaugh that the root cause for the difference was personnel ' error. Despite this knowledge, Mr. Frederick failed to adequately l
address these concerns prior to issuance of the June 29, 1990 letter.
i i
i j
Mr. Greene was apprised of concerns regarding the June 29, 1990 letter by Mr. Mosbaugh (an individual who had been involved in preparing the April 19, i
1990 LER and had been involved in developing an accurate DG start count).
Mr. Mosbaugh identified to him the failure-of the June 29, 1990 draft cover i
letter to address the inaccuracies in the April 9,1990 letter that it i
j referenced and Mr. Mosbaugh pointed out the erroneous causes stated for the i reasons for the difference in the June 29, 1990 DG start counts. Mr. Greens 1
was apparently indifferent to these concerns and, as a voting member of the j
i PRB, approved the proposed June 29, 1990 submittal without addressing these i
concerns.
i IV The conduct of these individuals indicates a lack of regard for and adherence to regulatory requirements and a lack of management control and supervision over licensed activities, and raises a question as to whether the Licensee and these individuals will, in the future, provide complete and accurate infor-mation to the NRC and otherwise comply with NRC requirements.
Therefore, furt%er information is needed to determine whether the Commission can have reasonable assurance that in the future the Licensee, with the
l l \\
involvement of particular Licensee personnel identified above, will provide complete and accurate information to the Commission and otherwise conduct l
activities in accordance with the Commission's requirements.
i V
i l
Accordingly, pursuant to -sections 161c,1610, 182 and 186 of the Atomic Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR 2.204 and 10 CFR 50.54(f), in order for the Commission to determine whether the Licenses should be modified to restrict the participation of the individuals named j
below in licensed activities or other enforcement action taken to ensure i
l compliance with NRC regulatory requirements, the Licensee is required to j
submit to the Director, Office of Enforcement, U.S. Nuclear Regulatory I'
Commission, Washington, D.C.
20555, within 30 days of the date of this Demand i
l for Information the following information, in writing and under oath or l
i affirmation:
1 i
i A.
A description of the current positions and responsibilities for i
l Messrs. Thomas V. Greene, Georgie R. Frederick, Harry W. Majors, and i
Michael W. Horton.
l l
B.
An explanation of why, notwithstanding being notified that the June 29 f
1990 letter failed to clarify the April 9, 1990 letter that it i
referenced and that it included erroneous root causes for the difference j
t between the April 19, 1990 and June 29, 1990 DG start counts, 3
i i
i
I i
j l l Mr. Greene, as a voting member of the PRB, approved the inaccurate and incomplete June 29, 1990 submittal.
l i
C.
An explanation of why, notwithstanding his direct. knowledge that the observations stated.in the audit report were inappropriately being used i
to identify the root causes for differences between the April 19, 1990 l
LER and the June 29, 1990 DG start counts and his being notified that 4
the correct root cause for the difference was personnel error, Mr. Frederick failed to address this concern prior to issuance of the l
f D.
An explanation of why, notwithstanding his being notified that the j
June 29, 1990 letter failed to clarify the April 9,1990 letter and that the April 9,1990 errors were different from the April 19, 1990 LER errors, Mr. Majors failed to address these concerns prior to issuance of 1
i the June 29, 1990 letter.
b i
E.
An explanation of why, notwithstanding his disagreement with the statement that DG record keeping practices were the cause for the error i
.in the April 9,1990 letter, Mr. Horton, as a voting member of the PRB, approved the June 29, 1990 letter.
i F.
An explanation of the corrective actions taken, or planned by the 4
Licensee to address each of these individuals' performance failures.
i t
i 5
O a
i i H.
Given the violation of NRC requirements, an explanation as to why NRC i
should have confidence that the Licensee, with the involvement of j
Messrs. Greene, Frederick, Majors, and Horton, will in the future l
conduct licensed activities in accordance with all NRC requirements, including the requirement of 10 CFR 50.9, " Completeness and accuracy of information."
Responses to this paragraph shall be provided separately 4
for each individual.
Copies of the response also shall be sent to the Assistant General Counsel for Hearings and Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555 and to the Regional Administrator, NRC Region II,101 Marietta Street,I i
Suite 2900, Atlanta, GA 30323.
After reviewing your response, the NRC will detemine whether further action is necessary to ensure compliance with regulatory requirements.
FOR THE NUCLEAR REGULATORY COP 911SSION p {,
toes L. Milhoan i
eputy Executive Director or iluclear Reactor Regulation, Regional Operations, and Research I
Dated at Rockville, Maryland thisqta.dayofMay1994 4
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Osnoe C3:59 VP CORPORATE Com + 99H17023 m.721 P001 i
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Georgia Power Company i
Corporate Communication Department 22nd Floor /333 Piedmont Avenue Building l
Atlanta, Georgia 30308 (404) 526-6526 l
FAX (404) 526-2441 4
i To:
O Phone Number: 33 -70A3 DNI From: Dm
@ Ad Phone Number:
Number of Pages (including cover sheet): E i
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FACSIMILE TRANSMITTAL U. S. NUCLEAR REGULATORY COMMISSION REGION II ATLANTA, GEORGIA l
ENFORCEMENT AND INVESTIGATION COORDINATION STAFF b
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TO:
SUBJECT:
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FROM:
BRUNO URYC, JR.
OFFICE: 404+331-4192 FAX: 404+331-4479 SENT BY:
TIME:
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! diFiDIA!Tl's 1.
i Georgia Power Company Response to NRC action l
May 10,1994 l) he Nuclear Regulatory Commission has informed the Company of a proposed $200,000 fine for providing i
inaccurate and incomplete information to the agency The ny a a o
edg a
nfo ation initially l!
provided to the NRC was inaccurate. The inaccuracies were il' discovered by the Company and reported to the NRC.
"Unfortunately, we made some mistakes in collecting and l
reporting information when this event occurred four years ago,"
said Allen Franklin, president and CEO of Georgia Power.
l I "Those mistakes were honest and unintentional. When we f
discovered them, we reported it ourselves to the NRC. We've always had a policy of providing complete, accurate and clear information to the NRC."
Franklin.said that safety has always been a top priority and that "the people of Plant Vogtle have already achieved much success in operating the plant safely."
"We're confident that our employees approached this matter honestly and in good faith,".he added.
Franklin said that the company is looking forward to pro-viding more information to the NRC. "We know this additional information will be considered by the Commission."
l Franklin also said that, in any event, if a civil penalty is finally ordered, it will not be paid for by Georgia power customers.
.i +,s*e44+seeito****4+++*
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EA NUMBER REQUEST FORM 60 2 j
LINDA J. WATSON REGIONAL CONTACT DATE OF hdGUEST MAY 11,1994 REGION 11
)
LICENSEE GEORGIA POWER COMPANY l
FACILITY / LOCATION VOGTLE / WAYNESBORO, GA UNITS 1 AND 2 LICENSE / DOCKET NO(S).
CPPR 91,60 390: CPPR-92,50-391 LAST DAY OF INSPECTION MAY 29,1994 l
01 REPORT NO.
N/A DATE OF 01 REPORT N/A
SUMMARY
OF FACTS OF CASE (ANNUAL REPORT FORMAT FOR EATS ENTRY) (MAXIMUM OF 300 CHARACTERS) '
i BREAKERS WERE TAGGED OUT WHICH RESULTED IN DEENERGlZATION AND CLOSURE OF DAMPERS REQUIRED TO BE THROTTLED TO to PERCENT OPEN BY TECHNICAL SPECIFICATION 3.7.7, PIPING PENETRATION AREA FILTRATION AND EXHAUST SYSTEM.
BRIEF
SUMMARY
OF INSPECTION FINDINGS (IF NOT SUFRCIENTLY DESCRIBED ABOVE) '
EXHAUST DAMPERS FOR BOTH TRAINS WERE DEENERGlZED BY HOLD CLEARANCES FOR APPROXIMATELY EIGHT WEEKS.
REASON FOR POTENTIAL ESCALATED ACTION-SUPPLEMENT 1.C.2.A - A SYSTEM DESIGNED TO PREVENT OR MITIGATE A SERIOUS SAFETY EVENT NOT BEING ABLE TO PERFORM ITS INTENDED FUNCTION UNDER CERTAIN CONDITIONS - BOTH TRAINS OF A TECH SPEC REQUIRED VENTILATION FILTRATION SYSTEM WERE DEGRADED DELEGATED CASE YES X
NO MED INST PHYSICIAN NUC PHARM RADIOG IRRAD WELL LOGGERS ACADEMIC GAUGE MOISTURE DENSITY OTHER TYPE:
CITE SIMILAR CASE: EA NO.
SHOULD OE ATTEND ENF CONF YES X
NO NONDELEGATED CASE X
YES NO M
NONDELEGABLE TYPE 01 REPORT /WILLFULL COMPLEX / NOVEL DISCRETION COMM APPROVAL Of INTEREST SL 1 OR 2 OTHER REASON:
IS THERE A BASIS TO CLOSE ENFORCEMENT CONFERENCE? Y/N IF YES, EXPLAIN: NO 5/'A,/fy EA # ASSIGNED BY OE EA 4 87 DATE:
ES ASSIGNED s/ain 9M&
C 3;L
. )J e
U s'. - t>
3 dy VEGP-TSAR-9
'p"
. r.
TABII 9.aa.3-5 (SHEET 2 0F 6)
E Plant 90ethod of failure Effect Go to Item Descri pt ion Safety ating Failure Fa ilure on System Safety ftee
.2 Ope r-L of Cocoonent Function Mp(p Models1 Ogtectten Function CapahiIety No.
{
7 Electric contact to Provide conticulty A
Fall to close Pressure dirrerential flone; loss or train 8
a la rm low A; train 8 available.
energize item 8; for ites 8 iten 8 is en NC/rc It0 Position indicating damper; thus it will Y
block air passage 4
f ig'st discharge to ma intain
.r
- e l ve a r= = w ~
'[
8 PY25508. electric / ' Open to maintalit."
A rail to cran Pressurge dirrerential leone; loss or train 9
alare low A; train 8 avellable.
hydraulic modeleting A negative pressure Item 8 is an feC/FC I
damper; leC/FC, train ' loside A8 Posstion indicating damper; thus it will block air passage A; foo; ressen open light discharge to naintain j
negative pressence -
j9 CO2; tors-io danger Open tc allow
/
rait to open Pressure differential Mone-euss or train 10 alarm low A; t ra in It avai'able a
NC, t ra e r A negateve pflessure enside A8 and prevent backrsow into tus i ldi ng 10 No. D breaker on Provsde continuity A
Inadvertent Positson endicateng More; loss of t ra i n 11 IAYE1; panel and proteret motor, ope's light A; train 8 available
( 120/2f40-V ); 1ABC itoo 12 MCC rs80-v; t ra i n A; IOC 11 i ectric contact to Provide continuity A
rail to close Flow alarm low 9fone ; loss or train 12 A; t rain 8 ava ilabse i
n e rg ize i tem 12; Ito ror item 12; Position iridicating 8e0; remain open iights 12 HV12614, on-off Allow return air A
fail to open Flow storm low None; loss of train 13 A; train 8 available dasper; train A; to item 2 Position indicating NC/fC lights 13 No. 04 breaker en
. Provide continuity A
Fall to close Switchgear a lars None; loss of train fis
, A; train B ava ilable 1AB1*> 480-V and protect heater, Moisture alars swi tcttgea r; 1[ bus; Iten Tie v
train A; 80 0 Temperature indicator 4
t
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.O..
i
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VEGP-FSAR-9
~
TAsif 9.4.3-5 (SHEET ts OF 6)
.p 4
Plant i
Ope r-Method or Felture Effect Go to ecom Description Safety sting Failure Failure on System Safety Itee A
of Component Lunc t ion peode Modelst Detection fynctlen Capab.i.fity 980. _.
j i
20 No. 28 breaker Provide continuity A
inadvertent Pressure dirrerential Mone; loss of train 24 Ji t
en 18YC1 papel and protect motor, open starsi Iow B; t ra in A ava i l-able.
Item 22 is (120/240-Y); ISDC i test 22 Position indIcetisig en seC/FC damper; MCC 480-V; trein B, light thus it will block i
NC a i r pa s sage d i s-charge to maintain f
negative pressure.
21 Electric centact Provide contintelty A
Fait to Pressure dirrerential None; loss of train 22 L(i to energize for item 22; close alare low B; train A ava il-able.
Item 72 is 6 tem 22;.40 MO: remain open Position indicating an 00C/FC danper; lijht thus it will block sir passage des-cha Mr in saintain rwres t a ve,rtre sses re.
22 PV2nts, electric /
open to esentsin A
reai s to Pressure dirrerentis t Mone; ens; of f..e i n 23 hydrau ic eoduttating negative pressure cl.s+n a le m low U; train A avail-l s
- b le. I tem 2;'
- 5 l
cooper; 10C/TC; inside AB Position indicating sn sic /Ft; das'peir; j
train 8; N0; light Lttus it well htock remain open air passage des-charge to eaintain inegativo pressure..
21s t ra i n 23 U01, tornado oper, to at low A
fail to Pressu re di f fe rent ia l Mone, loss of damper; NC:
negative pressure opers alare low 8; train A available train 8.
inside AB ard prevent l
backflow into building 24 Ito. 30 bresher on Provide centinuity A
Inselvtertent Position indicating None; loss of train 2$
18YC1 permet (120/
and protect rintor, ope.-
a lge t B; train A available
[t n
240-V), 198C MCC iten 26 3
480-V, train B, IOC 1
2$
Electric contact to Provide contineetty A
IJa. t.o F*ns alarm low Itone; loss of train 26 energize s tem 26; for item 26; close B; train A available
-: tion indicating NO Mo; reesic cpen I s elht s i
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t UNITED STATES -
NUCLEAR REGULATORY COMMISSION o
l4
.l' "
,d REGloN 11
~
101 MARIETTA STREET. N.W., sulTE 2I00
/
ATLANTA, GEORGIA 3o3234108 I
MAY 181994 Docket Nos. 50-424, 50-425 4
i License Nos. NPF-68, NPF-81 l
EA 94-87 4
j Georgia Power Company ATTN: Mr. C. K. McCoy l
Vice President J
Vogtle Electric Generating Plant l
P. O. Box 1295 Birmingham, AL '35201 1
Gentlemen:
i
SUBJECT:
NRC INSPECTION REPORT NOS. 50-424/94-15 AND 50-425/94-15 This refers to the inspection conducted by R. Starkey of this office on April 24 - May 12, 1994. The inspection included a review of activities i
j authorized for your Vogtle facility. At the conclusion of the inspection, the findings were discussed with those members of your staff identified.in j
the enclosed report (Enclosure 1).
Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of l
activities in progress.
The purpose of the inspection was to determine whether activities authorized by the licensee were conducted safely and in accordance with NRC requirements.
Based on the results of this inspection, one apparent violation was identified and is being considered for escalated enforcement action in accordance with the " General. Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), 10 CFR Part 2, Appendix C.
The apparent violation concerned the extended operation of Unit I with a degraded piping penetration ventilation system. Accordingly, no Notice of Violation is presently being issued for these inspection findings.
In addition, please be advised that the characterization of the apparent violation. described.in the enclosed inspec-tion report may change as a result of further NRC review.
An enforcement conference to discuss this apparent violation has been scheduled for June 2, 1994. This enforcement conference will be open to pub-lic observation in accordance with the Commission's trial program as discussed in the enclosed Federal Register notice (Enclosure 2). The decision to hold an enforcement conference does not mean that the NRC has determined that a violation has occurred or that enforcement action will be taken. The purposes of this conference are to discuss the apparent violation, its cause and safety significance; to provide you the opportunity to point out any errors in our inspection report; and to provide an opportunity for you to present your pro-posed corrective action (s).
In addition, this is an opportunity for you to i /(
thNl)!zS pm y
l Georgia Power Company 2'
MAY l 81994 provide any information concernir$g your perspectives on 1) the severity of the violation (s), 2) the application of the factors that the NRC considers when it determines the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other.
application of the Enforcement Policy to this case, including the exercise of discretion in accordance with Section VII. You will be advised by separate l
correspondence of the results of our deliberations on this matter.
No response regarding this apparent _ violation is required at this time.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
Sincerely,
$1L M4*+e~
hJonR.(Johnson,ActingDirector Division of Reactor Projects
Enclosure:
- 1. NRC Inspection Report
- 2. Federal Register Notice cc w/ encl:
J. D. Woodard Senior Vice President-Nuclear Georgia Power Company 1
i P. O. Box 1295 Birmingham, AL 35201 J. B. Beasley '
General Manager, Plant Vogtle Georgia Power Company P. O. Box 1600 Waynesboro, GA 30830 J. A. Bailey Manager-Licensing Georgia Power Company P. O. Box 1295
'Bireingham, AL 35201 Nancy G. Cowles, Counsel Office of the Consumer's Utility Council 84 Peachtree Street, NW, Suite 201 Atlanta,'GA 30303-2318 cc w/enci cont'd:
(See page 2) b
1 Georgia Power Company 3
MAY l 81994 i
1 cc w/enci cont'd:
i Office of Planning and Budget Room 615B j
270 Washington Street, SW i
Atlanta, GA 30334 i
' Office of the County Commissioner Burke County Commission Waynesboro, GA 30830 Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334 i
Thomas Hill, Manager j
Radioactive Materials Program Department of Natural Resources 4244 International Parkway Suite 114 Atlanta, GA 30354 Attorney General 132 Judicial Building Atlanta, GA 30334 Dan H. Smith Vice President Oglethorpe Power Corporation 2100 E. Exchange Place Tucker, GA 30085-1349 Charles A. Patrizia, Esq.
Paul Hastings, Janofsky & Walker 1050 Connecticut Avenue, NW Washington, D. C.
20036 6/23
.. - _. - _ ~ _ _
i n
UNITED STATES fa aso,S a
f NUCLEAR REGULATORY COMMISSION
- g REGION It o-
'ih (
"o 101 MARIETTA STREET. N.W.. SUITE 2000 l
l ATLANTA, GEORGIA 3E234100
(,..
/
j Report Nos.: 50-424/94-15 and 50-425/94-15 j
l Licensee: Georgia Power Company P. O. Box 1295 Birmingham, AL 35201 4
l Docket Nos.:
50-424 License Nos.:
NPF-68 and NPF-81 Facility Name:
Vogtle Units 1 and 2 i
Inspection Conducted:
April 24 - May 12, 1994 Inspector:
'N.~'
A/"3"
.a
% R. D. StarKey, Resident Inspector Date signeo
- 0. E /
5 N 94 e -P. A. Balm p Resident inspector Date Signed d
4 r?
Approved by:
de I//M'U m
P. Skinner, Chief Date Signed Reactor Projects Section 3B i
Division of Reactor Projects SUWiARY s
Scope:
This special inspection, conducted by the resident inspectors, l
concerns an event where the Unit 1 Piping Penetration Area Filtration and Exhaust System (PPAFES) was in a degraded condition for 54 days.
Results:
An apparent violation was identified involving the Unit 1 PPAFES.
The licensee unknowingly deenergized, for 54 days, the PPAFES exhaust flow dampers which are designed to maintain a negative pressure in the auxiliary building following.a containment ventilation isolation.
)
- 23
- c.,, -,
a n.
"i 'T VWLA461
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I REPORT DETAILS i
1.
Persons Contacted Licensee Employees J. Beasley, General Manager Nuclear Plant S. Bradley, Reactor Engineering Supervisor
- W. Burmeister, Manager Engineering Support j
S. Chesnut, Manager Engineering Technical Support
- C. Christiansen, SAER Supervisor C. Coursey, Maintenance Superintendent
- R. Dorman, Manager Training and Emergency Preparedness
- G. Frederick, Manager Maintenance W. Gabbard, Nuclear Specialist, Technical Support
- J. Gasser, Operations Unit Superintendent M. Griffis, Manager Plant Modifications M. Hobbs, I&C Superintendent
- K. Holmes, Manager Operations D. Huyck, Nuclear Security Manager
- W. Kitchens, Assistant General Manager Plant Support R. LeGrand, Manager Health Physics and Chemistry
- G. McCarley, ISEG Supervisor R. Moye, Plant Engineering Supervisor
- M. Sheibani, Nuclear Safety and Compliance Supervisor C. Stinespring, Manager Administration
- J. Swartzwelder, Manager Outage and Planning C. Tynan, Nuclear Procedures Supervisor J. Williams, Supervisor Work Planning and Controls Other licensee employees contacted included technicians, supervisors, engineers, operators, maintenance personnel, and office personnel.
Oglethorpe Power Company Representative T. Mozingo NRC Inspectors
- 0. Starkey,-Resident Inspector
- P. Balmain, Resident Inspector
- D. Wheeler, NRR Project Manager
- Attended Exit Interview An alphabetical list of abbreviations is located in the last paragraph of the inspection report.
2.0
(..
I I
2 2.
Event Description l
On April 24,-1994, during a review of MWO 19401858, the Unit 1 USS recognized that the PPAFES Train A and Train B exhaust flow con-trol dampers, IPV-2550B and IPV-2551B, were deenergized closed and L
had been in that condition since March 1, a period of 54 days.
When the licensee recognized the degraded condition on April 24 the dampers were promptly reenergized to return the PPAFES to its lf normai standby condition.
After evaluating.the potential reportability of the event, the licensee made a four-hour non-emergency notification to the NRC on April 26.
The licensee subsequently initiated an event critique team to investigate the event. During that review the licensee identified three addition-i al instences, one in 1992, and two in 1988, when the PPAFES exhaust flow control dampers were closed for a period of time that e
i exceeded the TS allowed outage time, i
j 3.
System-Description l
The PPAFES is a safety-related system and is designed to maintain a negative pressure on the piping penetration area rooms and fil-l ter the exh m t from those areas. The.PPAFES is part of the Aux-iliary Building Emergency Ventilation Sy. tem which functions after 1
an accident to keep ESF equipment rooms cooled, maintain a nega-tive pressure on the area, and filter the exhaust from the 4
}
negative pressure boundary to prevent release of radioactivity to j
the atmosphere. The PPAFES ensures that airborne radioactive i
i.
materials leaking from the mechanical penetration rooms and ECCS j
equipment rooms are filtered prior to-reaching the environment.
The Vogtle FSAR, Section 6.5.1.1.B. ESF Filter Systems-Design i
Bases, states, in part, that the PPAFES filter exhaust system is f
designed to maintain the filtration unit rooms at -1/4 inch WG i
with respect to the atmosphere which ensures that the piping j
penetration areas are maintained at a negative pressure with i
respect to adjacent areas. The system is in standby readiness i
during normal plant operations and is activated by a CVI signal.
The CVI signal isolates the Auxiliary Building Normal HVAC system-i from the piping penetration areas and ti,4rts both trains (A and B) of the filtration and exhaust units, opens their inlet and outlet dampers, and the exhaust flow control dampers. This results in the filtration and exhaust unit serving the various rooms, valve j.
galleries and corridors within the Auxiliary Building.
4 j
'The PPAFES exhaust flow control dampers,- IPV-25508 and IPV-2551B, i
which were deenergized during this event, are butterfly type i
electro-hydraulically operated valves. Upon a CVI, they are de-signed to open to a pre-set position and exhaust approximately 105 of the total PPAFES exhaust fan's air flow to the atmosphere via i
j the plant stack. FSAR Table 9.4.3-5 describes the safety function of these dampers as "open to maintain negative pressure inside the auxiliary building." When the PPAFES is in standby, these dampers i
l are normally closed and will fail closed upon loss of power to the O
i-L 3
i dampers. During the time when these two dampers were deenergized 2
and failed close, negative pressure could not have been ensured in j
the piping penetration areas.
i 2
.Cause of the Event 4.
The primary cause of this event was the-inadequate preparation and review of hold clearances by licensee personnel which resulted in an alteration of the PPAFES which prevented it from performing its function of maintaining a negative pressure in the' piping penetra-i tion areas. The licensee-had initicted clearances 19400133 and 19400134 on February 28 and March 1, 1994, for the purpose of i
allowing work to be performed related to M00 93-V1M138. The MOD l
was written to delete the Electrical Penetration Filtration System and abandon in place as much of that system as possible. The system was partially installed on Unit I and had never been in-stalled on Unit 2.
Two breakers, IAYEl-33 (Train A) and IBYCl-28 j-(Train B), were tagged out under these clearances with the intent of removing power from dampers related to the Electrical Penetra-tion Filtration System.
Personnel writing the clearances:were i
unaware that these two breakers also supplied vital 120 VAC power i
to the two PPAFES dampers, IPV-2550B and IPV-25518. Thus, when the breakers were opened, the two dampers were deenergized and failed to their' closed position.
i The licensee discovered, during a review of reference material, j
that both the electrical load list. and the one-line electrical i
drawing related.to breaker IAYEl-33 (Train A) did not indicate that the breaker supplied power to'PPAFES damper IPV-2550B. How-l ever, similar reference material related to breaker 1BYC1-28 i
(Train B) correctly indicated that PPAFES damper IPV-2551B was one of its loads.
Breaker 1AYEl-33 had been previously tagged out.on two other occasions, once in 1992 and once in 1988, with the in-l tent of deenergizing components related to the Electrical Penetra-tion Filtration System.
In both of these examples, the exhaust flow control. damper in the PPAFES was unknowingly deenergized.
l Also, in 1988, during a ta0 out of the "B" Train of the Fuel Han-i dling Building Filtration System another breaker, 18YCl-30, was F
opened, which deenergized the PPAFES Train "B" suction damper, 1HV-12614, for a period of 18 days. The ispect on the PPAFES was j~
apparently not identified when the above clearances were written and subsequently implemented. The licensee has taken action to l
correct the deficient electrical load list and drawing.
The licensee had several opportunities between March I and i-April 24, to identify that the dampers were deenergized and failed L
closed. For example, once each 31 days, as required by TS 1
surveillance 4.7.7, on a staggered basis, one of the two trains of j
PPAFES is run for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per operations Procedure 14515-1, Pip-ing Penetration Area Filtration and Exhaust System Operability l
Test. Data Sheet 1 of that procedure. requires the operator to
[
i
l i
l 1
I 4
verify that the exhaust flow damper-(IPV-25508/IPV-25518) is open.
1 During surveillances performed on March 28, (Train B) and April ll, (Train A), Data Sheet 1 indicated that the dampers were j
open, although hold clearances were in effect and the dampers were deenergized.
Inspector discussions with members of the event cri-a l
tique team indicated that during these surveillances the operators observed that the PPAFES had normal flow and negative pressure indications and assumed that the dampers were open, even though-i the control room indications for the dampers were deenergized (not-illuminated).
It should be noted that the negative pressure is read on control room indicators PDI-2550 and PDI-2551 and that j
these indicators reflect only the pressure within the Piping i
Penetration Filtration Exhaust Unit Room. Neither of the two surveillances contained any remarks in the " comments" section of i
the procedure to indicate that there was any problem with damper i
position indication. However, on March 28, the lack of position i
indication was observed by operators and discussed by the control room staff following the surveillance. That observation was not-l documented with a WRT or turned over to subsequent shifts for investigation. Also, during the performance of the surveillance j
on April 11, two system engineers were dispatched to damper IPV-l 2550B to verify its operation..Due to the normally limited
~
movement of the damper, they concluded that it was open, when in fact it was deenergized and failed closed. After the performance l-of the surveillance on April ll, a WRT was written identifying i-that the control room damper position indicators were not t
illuminated. That WRT resulted'in the issuance of MWO 19401858 and the eventual discovery of the deenergized dampers by electri-cians on April 20. The electricians informed the USS on April 20 l_
of their discovery; however, this USS did not recognize the impact l
to the PPAFES.
It was not until April 24, during a review of the MWO package, that another USS identified the affect on the PPAFES.
j Also, during the period from March 1 - April 11, numerous back panel control board walk-downs were conducted by licensed control i-room personnel, and the damper position indicators not being i
illuminated was not identified and corrected.
i 5.
Requirements 1
Technical Specification 3.7.7, Piping Penetration Filtration and Exhaust System, requirea that two independent PPAFES shall be
[
operabie in Modes 1,2,3, and 4.
The ACTION statement for TS 3.7.7 I
allows only owe of the two systems (trains) to be inoperable for a 1
i period of seven days after which the Unit must begin a shutdown.
No provision is made in TS 3.7.7 for both systems being inoperable simultaneously and therefore the provisions of TS 3.0.3, Limiting i
Conditions for Operation and Surveillance Requirements, would apply.
In 7,ddition to the degraded condition of the PPAFES described above, the inspector was concerned about the adequacy of TS Sur-veillanca Requirement.4.J.7.d.3, which requires that at least once shs
- j i
1 4
L.
5 per 18 months that the Piping Penetration Exhaust Unit Room be l
verified to maintain a negative pressure of greater than or equal to 0.25 inches WG relative to the outside atmosphere. According i
to TS 4.7.7.d.3, this is the only location in which negative pres-j sure is required to be measured within the piping penetration i
area. The piping penetration area includes numerous rooms at i
various elevations in the auxiliary building. The exhaust unit l
room pressure is considered to be representative of a typical room j
in the PPAFES. The inspector. learned during discussions with the system engineer and a review of system drawings, that the exhaust room pressure is maintained by manually idjusting ventilation duct supply and exhaust registers located within the exhaust room (one l
register on the suction side of the filter unit and one register j
on the exhaust side of the filter unit) to achieve the desired 3
room pressure. A negative pressure can therefore be maintained in the exhaust room, by adjusting these registers, independent of the i
position of the exhaust flow dampers,1PV-2550B and IPV-2551B. It I
would appear that there is no relationship between the negative pressure measured in the exhaust unit room and the pressure in the i
other rooms within the PPAFES. This could explain how operators i
observed a negative room pressure on March 28 and April 11 when the exhaust flow dampers were closed.
In order to address the effect that the closed dampers would have i
i' had on off-site and control room dose limitations of 10.CFR 100 and GDC 19, if an emergency had occurred during the period that the dampers were closed, the licensee initiated a Request for.
Engineering Analysis, REA 94-VAA025, with its corporate headquar-j'
-ters engineering staff.
The licensee's evaluation, based on the j
current ECCS leakage value,' as determined by the visual inspection i.
required by TS 6.7.4, Primary Coolant Sources Outside Containment, i
concluded that off-site and control room dose limitations would l
not have been exceeded. Vogtle personnel provided a copy of the' l
REA to NRC for evaluation.
i This event is significant because an ESF system was in a degraded condition for 54 days during which time a negative pressure in the auxiliary building may not have been ensured during an event.
J Additionally, numerous opportunities existed for the licensee to have prevented this event or to have identified tha degraded i
condition earlier.
Pending further NRC management review, this event is identified as Apparent Violation 50-424/94-15-01, Unit 1 i
Piping Penetration System Degraded for Extended Period of Time.
i 6.
Exit-Meeting i
j The inspection scope and findings were summarized on May 12, 1994, with those persons indicated in paragraph 1.
The inspector de-i scribed the areas inspected and discussed in detail the inspection findings. No dissenting comments were received from the licensee.
1 i
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6 The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during the inspection.
Item No.
Description and Reference APPARENT VIOLATION 424/94-15-01 Unit 1 Piping Penetration Ventilation System Degraded for Extended Period of Time 7.
Abbreviations CFR
- Code of Federal Regulations CVI
- Containment Ventilation Isolation ECCS
- Emergency Core Cooling System ESF
- Engineered Safety Feature FSAR
- Final Safety Analysis Report HVAC
- Heating Ventilation Air Conditioning IR
- Inspection Report t
MDD
- Minor Departure from Design MWO
- Maintenance Work Order NPF
- Nuclear Power Facility NRC
- Nuclear Regulatory Commission NRR
- NRC Office of Nuclear Reactor Regulation PPAFES
- Piping Penetration Area Filtration and Exhaust TS
- Technical Specifications USS
- Unit Shift Supervisor VIO
- Violation WG
- Water Gage WRT
- Work Request Tag
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a May 26,1994 LCV-0370 Docket No. 50-424 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington D. C. 20555 Ladies and Gentlemen.
VOGTLE ELECTRIC GENERATING PLANT LICENSEE EVENT REPORT CLOSED DAMPERS RENDER TWO TRAINS OF HVAC INOPERABLE in accordance with the requirements of 10 CFR 50.73, Georgia Power Company submits the enclosed report related to an event which was initially reported to the NRC per 10 CFR 50.72 (b)(2)(iii) on April 26.1994.
Sincerel r
a C. K. McCoy i
CKM/AFS
Enclosure:
LER 1-94-003 xc:
Georeia Power Comoany Mr. J. B. Beasley Jr.
Mr. M. Sheibani NORMS
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U. S. Nuclear Reculatory Commission Mr. S. D. Ebneter. Regional Administrator Mr. D. S. Hood. Licensing Project Manager Mr. B. R. Bonser. Senior Resident inspector, Vogtle ilf25
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LICEsesEE COMTACT POR 1 Mas LER (121 receP e e u eR Mehdi Sheibani. Nuclear Safety and Compliance 71016 812161-1312101-cossPLETE Ons test FOR EACM CoasPOIERNT FAR.URE MM*SSO Ist leers pun f (131 l SyriTM COaspONENT MAfeUFACfuRfR RE1'OsrTAGLE j
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On April 24.1994. exhaust dampers in both trains of the piping penetration area filtration and exhaust system (PPAFES) were found to be closed due to circuit breakers being deenergized while a design change was being performed on another air filtration system that utilized the same circuit breakers. The exhaust dampers were reenergized and restored to service. Concurrently, an initial
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determination was made, based on test results, that this condition had not rendered the system
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moperable. On April 26.1994, a further engineering evaluation determined that having the exhaust i
dampers closed would limit the ability of the PPAFES to control radioactive releases in a post-I LOCA scenario.
The cause of this event was cognitive personnel error and lack of attention to detail. This resulted in an inadequate review of the circuit breaker clearances associated with the design change. Also, i
subsequem personnel errors occurred which delayed the identification and resolution of the problem.
Personnel were counseled and additional training will be conducted to emphasize the importance of j
clearance reviews for proper configuration control.
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A. REQUIREMENT FOR REPORT This repon is required per 10 CFR 50.73 (a)(2)(v) because a condition existed that alone could have prevented the fulfillment of a safety function of a system needed to control the release of radioacave i
material. It is also required per 10 CFR 50.73 (a)(2)(i) because the unit operated in a condition i
prohibited by the Technical Specification (TS) when a system was inoperable for a period of time longer than that allowed by the action statement.
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B. UNIT STATUS AT TIME OF EVENT j
At the time of this event. Unit I was operating in Mode 1 (power operations) at 100 percent of rated
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thermal power. Other than that described herein, there was no inoperable equipment that contnbuted to the occurrence of this event.
i C. DESCRIPTION OF EVENT 1
i The Unit 2 c!cctrical penetration filtration system had never been installed and as part of a design i
change to abandon the Unit I system, on February 28,1994, and March 1,1994, personnel installed l
clearances by opening the applicable circuit breakers. These clearances removed power to several i
i dampert n this filtration system. However, power was also unknowingly removed to piping I
penetration area filtration and exhaust system (PPAFES) train A and B exhaust dampers, IPV-i 2550B and IPV-2551B, because they share circuit breakers with the system being abandoned. This l
left the PPAFES exhaust dampers in their closed positions and inoperable. These exhaust dampers open to preset positions to maintain negative pressure during PPAFES operation. Thus, the PPAFES was limited in its ability to control the release of radioactive materials from the piping penetration j
rooms, had it become necessary to do so m a post-LOCA scenario.
TS surveillances were performed for the Train A PPAFES on March 15,1994, and April 11,1994, and for the Train B PPAFES on March 28,1994. Personnel noted that the position indication lights, used for verifying modulation of dampers IPV-2550B and IPV-2551B, were not illummated during two of these three surveillances. During the March 28,1994, surveillance, an mvesugation of the apparent position indication problem was initiated, but was not pursued due to shift turnover.
Since the acceptance criteria for the surveillance was met, the surveillance was signed off as satisfactory. A more thorough and complete investigation was conducted during the April 11.1994, surveillance.
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i Visual indication of IPV-2550B valve linkage led the personnel involved to believe that the valve had actually moved to its preset demanded position, and a work order was initiated to effect repairs of the position indication. On April 20,1994, an investigation by an electrician, per the work order, revealed that both the indicator lights and the dampers were removed from service because the i
power had been removed. The unit shift supervisor (USS) was notified that the position indicanon was lost due to the breakers being open. However he did not realize that opening the breakers had l
also removed power to the dampers. On April 24.1994, during work order closeout, another USS
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recognized the impact on the PPAFES. While reviewing the clearance for modification to ree.
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j the exhaust dampers, PPAFES testing was performed to determine operability. System flows, differential pressures, and alarm indications all indicated normal, with the only abnonnality being the indication for the exhaust dampers. After discussion of the test results with the system engmeerms
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supervisor and plant managemem. an initial determination was made that this condition had not i
rendered the system inoperable. However, plant management requested a design review of this i
condition to determine the complete impact to the PPAFES. Power was restored and the system i
returned to service.
i On April 25,1994, the design engineering staff began to evaluate the effect of the deenergized dampers on the operability of the system and on April 26,1994, it was determined that PPAFES had l
been rendered inoperable and that the safety function of the system had been degraded by the i
dampers being deenergized while in their closed positions. A four-hour non-emergency notification I
was made to the NRC Operations Center per 10 CFR 50.72 (b)(2)(iii) because a condition existed l
that alone could have prevented the fulfillment of a safety function of a system needed to control the release of radioactive material.
A broadness review found that similar events had occurred when damper circuit breakers were I
deenergized for one train ofPPAFES on three other occasions. Train A breakers were deenergized from October 28,1988, to November 9.1988, and from July 30,1992, to August 19,1992. One j
train B breaker was deenergized from August 8,1988, to August 26,1988. No Unit 2 events were found.
i D. CAUSE OF EVENT l
The cause of this event was cognitive personnel error and lack of attention to detail by the operation work planner and the support shift supervisor (SSS). This resulted in an inadequate review of the i
circuit breaker clearance associated with the design change. The operation work planner's and SSS's j
reviews did not find the PPAFES train A exhaust damper on the appropriate breaker drawing or its i
respective load list because it was not listed on these documents. The PPAFES train B exhaust
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l' damper was shown on its respective drawing and load list, but these were not adequately rev since the train A and train B clearances were being developed at the same time.
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Subsequent personnel errors committed during performance of surveillance testing and in i
of damper position indication prevented the early detection snd correction of the clearance error.
The occurrence of these cognitive personnel errors by the Georgia Power Company personne
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involved was not the result of any unusual characteristics of the work location.
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A contributing cause of this event is that the single line diagram and electrical load list failed to l
specifically identify by equipment number that the train A exhaust damper was a device bei powered from the affected circuit breakers. The single line diagram and electrical load list identsfied oth:r dampers and an HVAC panel as devices being fed from the circuit breakers which were deenergized on February 28,1994. However, the tram A exhaust damper was also being fed from these circuit breakers via the HVAC panel.
E. ANALYSIS OF EVENT The functions of the PPAFES are to maintain a negative pressure boundary on the piping in.m..G area rooms and to filter the exhaust from those areas. Safety Evaluation Report dated July 9,1992, assumes iodine leakage from the piping penetration rooms and emergency core cooling system (ECCS) equipment to both offsite and control room locations during post-LOCA conditions.
l Therefore, the control room and offsite dose analyses are potentially affected by the degradation this system caused by the inoperable exhaust dampers.
Based upon the latest dose analysis, had the ECCS leakage risen to the design basis analyzed va 2 gpm with the PPAFES exhaust dampers closed, the offsite dose would have remained within the 10 1
CFR 100 limits, and the control room dose would also have remained within the General Desig Criteria 19 acceptance criteria.
Several other factors also existed that would have mitigated the consequences of this scenario:
1)
The latest surveillance value for ECCS leakage, based on the requirements of TS 6.7.4 and taken during the last Unit i refueling outage, indicated the leakage was less than 0.1 gpm.
This would result in the expected source term being significantly less than the 2 gpm assumed in the design basis dose analysis.
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t Although the PPAFES exhaust dampers were inoperable and would have resulted in an increase of radioactivity release, the niter and recirculation function of the PPAFES was i
operable and would have sitered out a majority of the airborne radiation resulting from i
ECCS leakage.
i Combining these two conditions of a low ECCS leakage value and the operability of the j
recirculation / filtration function of PPAFES being unaffected by the inoperability of the i
exhaust dampers, results in maintaining the expected source term within the design basis dose analysis value.
2)
ECCS leakage which occurred would enter the auxiliary building in interior rooms below grade, and have to diffuse through several rooms or be transported via the filter system to rooms bordering on the exterior of the building prior to release. ARer filtration, the expected discharge flow of 2700 cfm would have been retumed with the recirculation flow of 117f0 cfm to the vanous ECCS rooms. These rooms are typically provided with sealed penetrations and solid doors (not wire mesh) maintained closed for flood protection, radiation protection, fire protection, etc., and would provide a substantial barrier to radioactivity release. Therefore, the majority of the leakage would be processed through the PPAFES fihers, perhaps being recirculated several times, prior to release. The leakage which bypasses the filters would have a long winding pathway to follow prior to exiting the auxiliary building and would be subject to natural removal processes along the way, such as settling and plateout.
I 3)
The PPAFES charcoal filter iodine removal efficiency is supplemented by heaters that aid in decreasing humidity. Since the expected relative humidity at the charcoal filter inlet (following the guidance of Regulatory Guide 1.52) is much closer to the controlled environment value of 70 percent than to the uncontrolled environment value of 95 percent, the PPAFES efficiency ofiodine removal would be greater than that taken credit for in the design basis dose analysis. In addition, the filter actually has a bed depth of four inches as opposed to the two inches taken credit for in the accident analysis. Therefore, the recirculation / filtration which would occur would be more effective than discussed above Finally, there was no leakage event during the period of time involved. Based on these considerations, there was no adverse effect on plant safety or on the health and safety of the public as a result of this event.
IRY-26-1994 16,:12 FPO1
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. c n,n F. CORRECTIVE ACTIONS
- 1) The work planner and SSS involved have been counseled on the significance of configuration control when preparing, reviewing, and approving clearances.
i
- 2) The operation work planners and system engineers will be trained regarding this event with emphasis on configuration control, by June 15.1994.
- 3) Licensed operators will review this event in continuing training by July 15,1994, with particula instruction on configuration control. Emphasis will also be given to utilizing a questioning attitude when test indications are not clearly understood.
- 4) The appropriate Unit I and Unit 2 single line diagrants and electrical load lists, which failed to identify by equipment number that the Train A PPAFES exhaust damper was being powered from the circuit breakers, have been corrected. An initial sample review of other breakers that power similar loads revealed no fdtther drawing problems. An additional review will be completed by August 1,1994.
- 5) An evaluation of the test methodology for the current PPAFES TS surveillances will be complete with recommendations for system and procedure improvements by July 1,1994 G. ADDITIONALINFORMATION 1)
Failed Components:
None 2)
Previous Similar Events:
None 3)
Energy Industry Identification System Code:
Emergency Core Cooling System - BJ, BP Piping Penetration Air Filtration and Exhaust System - VA (7[23 TOTf4. P.08 i
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M MW M smr Rt.TRATION AND EMMAUSTSVWTEM (2f2S
I ENCLOSURE 1 i
NOTICE OF VIOLATION During the NRC inspection conducted on April 24 - May 28, 1994, a violation _of j
NRC requirements was identified.
In accordance with the " General Statement of d
Policy and Proceduras for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below.
i Technical Specification 3.7.7 requires that two independent Piping Penetration Area Filtration and Exhaust Systems shall be Operable in 4
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Modes 1,2,3, and 4.
If one Piping Penetration Area Filtration and i
Exhaust System is inoperable for.more than 7 days, the reactor must be F
placed in a Hot Standby condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown with the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, from Marc'h 1, 1994 to April 24, 1994, Unit 1 Piping Penetration Area Filtration and Exhaust System, Train A and Train B, was in a degraded condition due to dampers IPV-25508 and IPV-2551B being deenergized.
The dampers were in a failed closed position which prevented the system from ensuring that a negative pressure would be maintained in the piping penetration rooms in the event of a Containment-Ventilation Isolation.
This is a Severity Level III violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Georgia Power Company is hereby required to submit a written statement of explanation to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D. C. 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector Vogtla Nuclear Plant, within 30 days of the date of the letter transmittin9 this Notice of Violation (Notice). This reply should be clearly marked as a " Reply lto a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or if contested, the basis for disputing the violation, (2) the corrective steps that have been.taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order or demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Dated at Atlanta, Georgia this day of 4
-THIS DOCUMENT CONTAINS PREDECISIONAL INF)RfdKTION-kCpdQT BE DISC 1(THE REGIONAL A ED OyT HE NR
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PLANT SYSTEMS 3/4.7.7 PIPING PENETRATION AREA FILTRATION AND EXHAUST SYSTEM l
LIMITING CONDITION FOR OPERATION 4
3.7.7 Two independent Piping Penetration Area Filtration and Exhaust Systems
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shall be OPERA 8LE.-
APPLICABILITY:
M00ES 1, 2, 3, and 4 I
l ACTION:
With one Piping Penetration Area Filtration and Exhaust System inoperable, restore the inoceraele system to OPERABLE status within 7 days or be in at least HOT STAN08Y within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the j
following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
l SURVEILLANCE REOUIREMENTS 4.7.7 Each Piping Penetration Area Filtration and Exhaust Systas shall be.
j demonstrated OPERABLE:
a.
At least once per 31 days on a STAGGERED TEST BASIS by initiating, s
from the control room, flow' (FI-12629, FI-12542) through the HEPA filters and charcoal adsorbers and verifying that the systes operates for at least 10 continuous hours with the heater control circuit energized; b.
At least once oer 18 months or (1) after any structural maintenance on the HEPA filter or charcoal-aosorber housings, or (2) following j
painting, fire, or chemical release in any ventilation zone communi-cating with the system by:
l 1.
Verifying that the cleanup system satisfies the in-place testing i
acceptance criteria of greater than or equal to 99.95% filter retention while operating the system at a flow rate of 15,500 cfm t 10% and performing the following tests:
(a) A visual inspection of the piping penetration area filtration and exhaust system shall be made before each 00P test or activated careon adsorcer section leak test in accordance with Section 5 of ANSI M510-1980.
(b) An in place 00P test for the HEPA filters shall be perforneo in accordance with Section 10 of ANSI N510-1980.
(c) A charcoal adsorber section leak test with a gaseous halogenated hydrocarbon refrigerant shall be performed in accordance with Section 12 of ANSI N510-1980.
23 V0GTLE UNITS - 1 1 2 3/4 7-17 Amendment No. 21 (Unit 1)
Amenesent No. 2 (Unit 2)
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This is a Seal response to ERA M.VAA088 which requans en evalunden of the Unit 1 l
AuxiliaryBuildingMplagPenettsdon AreaPiltradosandEsbaustSystem(FFAFES)whh i
respect to inadvertaely A 24=4 stock exhaust danpers. The stack exhaust despers (IPV45HE di 1PV4551B) are designed to open ta a preset posiden when the PFAfBS is martadin ortlerto ensintain a nuestive Preemrein the piping p
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PPAFES sushasins tbs aren under a napitive pressure to smene that sadleesdvs assadals lealdag tasa the mesheniset passermian rooms and ECC8 equipment are altered prior to resshlagthe ouvireament.
l Sinoa the FFAFRE la normath in sandby, the mask suhaust dampers would have been de eensissa in the enoud peelden. Widtthese dampers olosed, ths PPAFBB could nel smisasia the piping pensereden aren under a nagstive pressme, passMy allowlas at:6 ems j
redlesados nusadalla tbs ares servalby the PPAPES to snaps to the envkeement I
without seeing throuds the filter systemt For the purpassa of this oveloaden,18 is i
assened that sE siebarns radionedve maserials tem tim mesbaalcal poesneden rooms and ECCS equipunset are seisesed direedyito the envireenset.
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Thalesent eedily evehaden ist the PPAFBI associated with amendments St and 31 to l
- pensing Heemass NFF.68 and 31, assumes ECCS lodine leakaps is 2 spa and la the Amt l
presedied by Reguistory Gulds 1.3, i.e. 91% elemental, 4% organia, and 5% peniculate.
j Further, the Star essiensies are ammmed to be 90%, 30%, and 90% respeedvely, the l
compedleeSalenartheawinidbe' l
(.91st.b.04s.3+.05s.9) =.876 or appromisessly 90%.
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. of the FFAF58 may then ineresse the BCCS leslage l
N ie and somret suomdeses by a tager of appreuksessfy 10.
However, the current ECCS leakage valse hosed on Teekniest Speeldenden 6.7.4 is less 4
l then 0.1 spei, and himeriaally the vales has been less than 0.2 spm, theredwo the supoeted i
souros tenn would be a dheser e(101essaham assened la the surrent does eastyeis. The not smetwould be that the1AB, LPZ, and Cosmal Room desse as shoem in the SEE wouki remain ensamisty unehenged and:within the 10 CFA 100 and GDC 19 aseopinase i
eriseria. 11ds evalunden ia sesservetive he the' Adlewing masses i
l Duriesthe period of time then the emek saheum dumpers were closed, the PPAFB8
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would oscurla rooms lassier to the andBay bulkling and haiow grade, and would hans to be transponed through severat rooms pdar to rulesse to the emnosphes. Leekage through the sentainment isoledes valves into the piping pensection rosse is asenned to 1
teelt,directly to the anneophae witinut procesdag or heldup. Rosense the PPAPE5 i
reoiraileshmermies a==ien russinmi w '. Eces leakage to tis imerior l
compenments of the easilissy bulkBag would be esposted to be Stered prior to smaspett i
to aber seems adjesent to esmospherislosings pathways. Leenage which dSimed throughout the buildlag and bypassed the Seer unit would havslang tortuous pathways.to adlow and womid be addest to sigeleses meanni removat prosesses elems the j
(sealles, pieleeut, sie.). Father, as imisseed la the benes of the Tooheiset 8 the hamers in the PPAPES are =d-l=ad hr ddene in depth. Tips the egneted 5
runevel he tin resinaladen@lnsion Amation would be in amese of that tredliediathe l
In==a d-inadvensady de merghlag ths FFAFES neek enheum dampets would not have sessiend ia amendagthe of site and control room dose guitstions of 10 CPR 100 i
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UNITED STATES NUCLEAR REGULATORY COMMISSION i
0FFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C.
20555-May 24, 1994 1
i-NRC INFORMATION NOTICE 94-36: UNDETECTED ACCUMULATION OF GAS IN REACTOR I
COOLANT SYSTEM i
Addressees i
All holders of operating licenses or construction permits for nuclear power reactors.
Purpose The U.S. Nuclear Regulatory Commission (NRC) it issuing this information notice to alert addressees to problems that could result from unrecognized evolution and accumulation of gas in reactor coolant system high points.
It is expected that recipients will review this information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems. However, suggestions contained in this information notice are not NRC requirements; therefore, no specific-action or written response is required.
DescriDtion of Circumstances
~
- Sequoyah Unit I had been shut down in March 1993.
In early September 1993, after the unit had been ' refueled, the reactor vessel was reassembled and the I
reactor coolant. system was degassed, filled, and vented. The reactor coolant system was then depressurized to atmospheric pressure. One pressurizer power-operated relief valve (PORV) was open and the reactor coolant system average temperature was being maintained at approximately 49'C [120*F]. Nitrogen cover gas was being supplied to the volume control tank at approximately 239 kPa [20 psig) and reactor coolant was being circulated by the charging system and the residual heat removal (RHR) system. The reactor vessel level indication system (RYLIS) was functional for a significant portion of the event.
Before this event, instrument maintenance stickers were placed on the RVLIS indicators for other maintenance work. Although the RVLIS information was'available, the operators were not monitoring'this information because it was not procedurally required to be used in shutdown modes of operation.
Reactor coolant system inventory was being monitored using pressurizer cold calibration level indications.
On December 17, 1993, the operators began to pressurize the containment to 191 kPa (13 psig) in order to perform a contginment integrated leak ~ rate test.
As containment pressure increased, the operators noticed a decrease in pressurizer water level and, over a' period of time, added approximately 31,400 liters [8,300 gallons] of water to maintain the pressurizer level.
Licensee personnel evaluated this situation and recognized that gas was accumulating in the reactor coolant system. However, they failed to recognize the magnitude i
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IN 94-36 May 24,~1994 i.
Page 2 of 4 i
.or cause of the problem. Three days later, as the containment was being depressurized upon completion of the containment leak test, the operators l
noted that approximately the same amount of water had to be removed from the reactor coolant system to maintain the level. On December 21, 1993,.on.the l
basis of operators' observations of the changing coolant system inventory j
during the containment leak test, the reactor vessel head was vented.
It was subsequently vented several times to maintain appropriate reactor vessel inventory based on RVLIS information. The reactor vessel gas voiding conditions went undetected from early September 1993, when the reactor coolant system _was verified to be filled, until December 21, 1993, when the reactor
~
head was vented.
The gas evolution resulted from the temperature in the volume control tank being much lower than that normally expected.
(This lower temperature was due to unusually low component cooling water temperatures and to a maintenance problem with a cooling water valve that resulted in the reduction of the heat sink temperature in the letdown heat exchanger.) The lower temperatures increased the solubility of gas in the volume control tank water so that more gas was dissolved in the water. This gas evcived when the water was transferred to the reactor coolant system by the charging system and heated up in the reactor vessel.
Further details concerning this event are in NRC Inspection Report No. 50-327; 50-328/94-04.
Discussion The licensee completed a final evaluation in January 1994 and determined that during this event-the reactor vessel water level had decreased to slightly below the top of the hot leg, and that the steam generator tubes were nearly empty. The reactor coolant system inventory was being monitored solely on the basis of pressurizer level, which was not indicative of the reactor vessel and steam generator levels. Calculations by the licensee indicated that an equilibrium had been reached during the event so that the water level was approximately 1.6 meters [5.25 feet) above the top of the core. Any additional gas evolved in the reactor vessel would be expected to be vented through the hot leg and surge line to the pressurizer and out through the open pressurizer PORV.
The reactor water level at which equilibrium was established at Sequoyah was sufficiently high so as not to interfere with reactor coolant flow through the RHR cooling system. However, at other plants, the equilibrium level,'which is related to pressurizer surge line geometry and RHR suction line location, might be such that a similar event could interfere with shutdown cooling.
Another potential safety conteni is related to the capability of the steam generators to transfer heat from the reactor coolant to secondary coolant.
In the equilibrium condition at Sequoyah, the steam generator tubes were almost empty during at least'a portion of the duration of this event. During this s.
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=
IN 94-36 l
May 24,.1994 Page 3 of 4 f.
period, the steam generators were assumed to be available as an alternate means for shutdown cooling.. It is not clear that cooling through the steam l
generators could have been established, if needed, especially because the j
plant operators were unaware that the tubes were empty.
Several factors involving licensee performance contributed to the delay in the l-identification ~and evaluation of this event. They included (1) lack of consideration on the part of licensee personnel with respect to compression of gas in the system caused by containment pressure transmitted to the reactor coolant system water through the open pressurizer PORV; (2) misunderstanding ty the operators about the operability of RVLIS; (3) failure to stop the l
-cintainment leak test when water level changes were first noted so that the j
situation could have been adequately evaluated; (4) an apparent lack of j
thorough evaluation of previously published information on similar events.
The event discussed in this information notice highlights the potential for 4
gas evolution and accumulation in the reactor coolant system in locations and quantities that may not be evident to operators. Changes in temperature and pressure can have significant effects on the solubility of gas in water, especially at or near atmospheric pressure conditions. During. cold shutdown, this phenomenon can permit significant quantities of cover gas to be dissolved in lower-temperature, higher-pressure volumes such as the volume control tank and to evolve into a large gas bubble in the reactor vessel (a lower-pressure, higher-temperature area). This phenomenon can occur without a sudden change
~
in pressurizer level, which is the indicator normally used by the' operators to monitor water inventory. Use of available instrumentation in shutdown modes to monitor reactor vessel water level can provide detection of unexpected system conditions when reduced vessel inventory is not planned as well as in reduced inventory evolutions.
On April 12, 1994, a similar gas accumulation event was identified at the Salem Generating Station (Unit 1) shortly after it entered Mode 5 (cold.
shutdown) operation. Although this occurrence did not involve amounts of gas accumulation as large as in the Sequoyah event, many similarities existed regarding both the process of gas formation and the lack of operator awareness of the abnormal condition.
In both events, reactor vessel level information was or could have been made available for prompt identification of the problem.
Related Generic Communications e
NRC Information Notice 93-12, "Off-Gassing in Auxiliary Feedwater System. Raw Water Sources," discusses similar solubility considerations related to air pockets in piping at the McGuire Nuclear Station.
NRC Information Notice 87-46, " Undetected Loss of Reactor Coolant," discusses undetected loss of reactor coolant inventory at North Anna Unit I resulting from inadequate use of available indications and failure to perform mass inventory balances.
n----
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l
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IN 94-36 May 24, 1994 i
Page 4 of 4 c
l This information notice requires no specific action or written response.
If you have any questions about the information in this notice, please contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
/s/'d by BKGrimes Brian K. Grimes, Director Division of Operating Reactor Support Office of Nuclear Reactor Regulation Technical contacts:
R. Benedict, NRR (301) 504-1157 S. M. Shaeffer, RII (615) 842-8001
Attachment:
List of Recently Issued NRC Information Notices i
1 l
IN 94-36 l
May 24, 1994 Page 4 of 4 This information notice requires no specific action or written response.
If you have any questions about the information in this notice, please contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.
Orig /s/'d by BKGrimes Brian K. Grimes, Director Division of Operating Reactor Support Office of Nuclear Reactor Regulation Technical contacts:
R. Benedict, NRR (301) 504-1157 S. M. Shaeffer, RII (615) 842-8001
Attachment:
List of Recently Issued NRC Information Notices i
- See previous concurrence 0FFICE
- 0EAB:00RS
- DRP:RII
- 0GCB: DORS
- SC/DRP:RII
- TECH ED NAME RBenedict SMShaeffer PCWen MLesser MFMejac DATE 05/04/94 05/05/94 05/05/94 05/05/94 05/05/94
- AC/SRXB:DSSA
- AD/DSSA
- C/0EAB: DORS
- AC/0GCB:00RS D/ DORS TEcollins MVirgilio AChaffee AJKugler BKGrimes 05/06/94 05/09/94 05/09/94 05/12/94 05/19/94
. DOCUMENT NAME:
94-36.IN NOTE: The PMs for Sequoyah (D. LaBarge) and Salem (J. Stone) have been informed of the development of this information notice and they have reviewed the draft information notice.
l Peter Wen, 5/10/94 l
Attachment IN 94 36 May 24, 1994 a
Page 1 of 1 LIST OF RECENTLY ISSUED NRC INFORMATION NOTICES Information Date of Notice No.
Subject Issuance Issued to 91-81, Switchyard Problems that 05/19/94 All holders cf OLs or cps
.Supp. 1 Contribute to Loss of for r,aclear power reactors.
Offsite Power 94-35 NIOSH Respirator User 05/16/94 All holders of Ols or cps Notices, " Inadvertent for nuclear power reactors, Separation of the Mask-and all licensed fuel Mounted Regulator (MMR) facilities.
from the Facepiece on the Mine Safety Appliances (MSA) j Company MMR Self-Contained Breathing Apparatus (SCBA) and Status Update" 94-34 Thermo-Lag 330-660 05/13/94 All holders of OLs or cps Flexi-Blanket Ampacity for nuclear power reactors.
Derating Concerns I
94-33 Capacitor Failures in 05/09/94 All holders of OLs or cps' Westinghouse Eagle 21 for nuclear power reactors.
Plant Protection Systems 93-53, Effect of Hurricane 04/29/94 All holders of OLs or cps Supp. 1 Andrew on Turkey Point for nuclear power reactors.
Nuclear Generating Station and Lessons Learned 94-32 Revised Seismic Hazard 04/29/94 All holders of OLs or cps Estimates for nuclear power reactors.
94-31 Potential Failure of 04/14/94 All holders of Ols or cps Wilco, Lexan-Type HN-4-L for nuclear power reactors.
Fire Hose Nnzzles 90-68, Stress Corrosion Cracking 04/14/94 All holders of 01 or cps Supp. 1 of Reactor Coolant Pump for pressurized water Bolts reactors.
94-30 Leaking Shutdown Cooling 04/12/94 All holders of OLs or cps Isolation Valves at for nuclear power reactors.
Cooper Nuclear Station OL = Operatirg License CP = Construction Permit
I We" A?N. 16: 08 FFOI -5t0: 80GTLE EllG LIC TO t F': PEGICil ' l l P.02 v.ono. e aos en - z:
u Georgia Powei-c.x.mecoy ve. 5,eceni t;ucer i
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May 26,1994 i
LCV-0370 i
Dockct No. 50-424 U. S. Nuclear Regulatory Commission i
ATTN; Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen.
VOGTLE ELECTRIC GENERATING PLANT LICENSEE EVENT REPORT CLOSED DAMPERS RENDER TWO TRAINS OF HVAC INOPERABLE In accordance with the requirements of 10 CFR 50.73, Georgia Power Company submits the enclosed report related to an event which was initially reported to the NRC per 10 CFR 50.72 (b)(2)(iii) on April 26,1994.
. Sincerely i
C. K. McCoy CKM/AFS 1
Enclosure:
LER l-94-003 xc:
Georeia Power Comoany Mr. J. B. Beasley, Jr.
Mr. M. Sheibani NORMS U. S. Nuclear Reculatory Commission Mr. S. D. Ebneter, Regional Administrator -
Mr. D. S. Hood. Licensing Project Manager Mr. B, R. Bonser. Senior Resident Inspector, Vogtle h'
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On April 24,1994, exhaust dampers in both trains of the piping penetration area filtration and exhaust system (PPAFES) were found to be closed due to circuit breakers being deenergized while a design change was being performed on another air filtration system that utilized the same circuit breakers. The exhaust dampers were reenergized and restored to service. Concurrently, an initial detemtination was made, based on test results, that this condition had not rendered the system inoperable. On April 26,1994, a further engineering evaluation determined that having the exhaust dampers closed would limit the ability of the PPAFES to control radioactive releases in a post-LOCA scenario.
The cause of this event was cognitive personnel error and lack of attention to detail. This resulted in an inadequate review of the circuit breaker clearances associated with the design change. Also, subsequent personnel errors occurred which delayed the identification and resolution of the problem.
Personnel were counseled and additional training will be conducted to emphasize the importance of clearance reviews for proper configuration control.
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A. REQUIREMENT FOR REPORT This report is required per 10 CFR 50.73 (a)(2)(v) because a condition existed that alone could have i
prevented the ful611 ment of a safety funcion of a system needed to control the release of radioactive material. It is also required per 10 CFR 50.73 (a)(2)(i) because the unit operated in a condition prohibited by the Technical Specification (TS) when a system was inoperable for a period of time longer than that allowed by the action statement, I
B. UNIT STATUS AT TIME OF EVENT At the time of this event. Unit I was operating in Mode 1 (power operations) at 100 percent of rated 4
thermal power. Other than that described herein, there was no inoperable equipment that contributed to the occurrence of this event.
C. DESCRIPTION OF EVENT The Unit 2 electrical penetration filtration system had never been installed and as part of a design change to abandon the Unit I system, on Febmary 28,1994, and March 1,1994, personnel installed clearances by opening the applicable circuit breakers. These clearances removed power to several dampers in this filtration system. However, power was also unknowingly removed to piping penetration area filtration and exhaust system (PPAFES) train A and B exhaust dampers, IPV-2550B and IPV-2551B because they share circuit breakers with the system being abandoned. This left the PPAFES exhaust dampers in their closed positions and inoperable. These exhaust dampers open to preset positions to maintain negative pressure during PPAFES operation. Thus, the PPATES was limited in its ability to control the release of radioactive materials from the piping penetmtion rooms. had it become necessary to do so m a post-LOCA scenario.
TS surveillances were performed for the Train A PPAFES on March 15,1994, and April 11,1994, and for the Train B PPAFES on March 28,1994. Personnel noted that the position indication lights, used for verifying modulation of dampers IPV-2550B and IPV-2551B, were not illuminated during two of these three surveillances. During the March 28,1994, surveillance, an investigation of the apparent position indication problem was initiated, but was not pursued due to shift turnover.
Since the acceptance criteria for the surveillance was met, the surveillance was signed off as satisfactory. A more thorough and complete investigation was conducted during the April 11,1994, surveillance.
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Visual indication of IPV-2550B valve linkage led the personnel involved to believe that the valve had actually moved to its preset demanded position, and a work order was initiated to effect repairs i
of the position indication. On April 20,1994, an investigation by an electrician, per the work order, revealed that both the indicator lights and the dampers were removed from service because the
{
power had been removed. The unit shift supervisor (USS) was notified that the position indication l
was lost due to the breakers being open. However, he did not realize that opening the breakers had j
l also removed power to the dampers. On April 24,1994, during work order closecut, another USS l
recognized the impact on the PPAFES. While reviewing the clearance for modification to reenergize j
the exhaust dampers, PPAFES testing was performexi to determine operability. System flows, differential pressures, and alarm indications all indicated normal, with the only abnormality being the j
indication for the exhaust dampers. After discussion of the test results with the system engineering supervisor and plant management, an initial determination was made that this condition had not j
rendered the system inoperable. However, plant management requested a design review of this condition to determine the complete impact to the PPAFES. Power was restored and the system returned to service.
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j On April 25,1994, the design engineering staff began to evaluate the effect of the deenergized
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dampers on the operability of the system and on April 26,1994, it was determined that PPAFES had been rendered inoperable and that the safety function of the system had been degraded by the dampers being deenergized while in their closed positions. A four-hour non-emergency notification was made to the NRC Operations Center per 10 CFR 50.72 (b)(2)(iii) because a condition existed that alone could have prevented the fulfillment of a safety function of a system needed to control the release of radioactive material.
i A broadness review found that similar events had occurred when damper circuit breakers were deenergized for one train ofPPAFES on three other occasions. Train A breakers were deenergized a
from October 28,1988, to November 9,1988, and from July 30,1992, to August 19,1992. One train B breaker was deenergized from August 8,1988, to August 26,1988. No Unit 2 events were f
found.
i D. CAUSE OF. EVENT i
The cause of this event was cognitive. personnel error and lack of attention to detail by the operation work planner and the support shift supervisor (SSS). This resulted in an inadequate review of the 3
l circuit breaker clearance associated with the design change. The operation work planner's and SSS's h
reviews did not find the PPAFES train A exhaust damper on the appropriate breaker drawing or its
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respective load list because it was not listed on these documents. The PPAFES train B exhaust e
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damper was shown on its respective drawing and load list, but these wera not adequately reviewed since the train A and train B clearances were being developed at the same time.
3 i
Subsequent personnel errors committed during pedormance of surveillance testing and investigation of damper position indication prevented the early detection and correction of the clearance error.
The occurrence of these cognitive persorcel errors by the Georgia Power Company personnel involved was not the result of any unusual charsseristics of the work location.
4 l
A contributing cause of this event is that the single line diagram and electrical load list failed to i
specifically identify by equipmcat number that the train A exhaust damper was a device being powered from the affected circuit breakers. The single line diagram and electtical load list identified other dampers and an HVAC panel as devices being fed from the circuit breakers which were decnergized on Febmary 28,1994. However, the train A exhaust damper was also being fed from j
these circuit breakers via the HVAC panel.
l E. ANALYSIS OF EVENT i
The functions of the PPAFES are to maintain a negative pressure boundary on the piping penetration area rooms and to filter the exhaust from those areas. Safety Evaluation Repon dated July 9,1992, i
j nsumes iodine leakage from the piping penetration rooms and emergency core cooling system l
(ECCS) equipment to both offsite and control room locations during post-LOCA conditions.
Therefore, the control room and offsite dose analyses are potentially affected by the degradation of this system caused by the inoperable exhaust dampers.
i Based upon the latest dose analysis, had the ECCS leakage risen to the design basis analyzed value of 2 gpm with the PPAFES exhaust dampers closed, the offsite dose would have remained within the 10 CFR 100 limits, and the control room dose would also have remained within the General Design i
Criteria 19 acceptance ciiteria.
{
Several other factors also existed that would have mitigated the consequences of this scenario:
4 1)
The latest surveillance value for ECCS leakage, based on the requirements of TS 6.7.4 and taken during the last Unit i refueling outage, indicated the leakage was less than 0.1 gpm.
l This would result in the expected source term being significantly less than the 2 gpm f
assumed in the design basis dose analysis.
i i
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l Although the PPAFES exhaust dampers were inoperable and would have resulted m an l
increase of radioactivity release, the filter and recirculation function of the PPAFES was operable and would have 61tered out a majority of the aittorne radiation resulting from- -
l ECCS leakage.
Combining these two conditions of a low ECCS leakage value and the operability of the recirculation / filtration function of PPAFES being unaffected by the inoperability of the exhaust dampers. results in maintaining the expected source term within the design basis l
i dose analysis value.
2)
ECCS leakage which occurred would enter the auxiliary building in interior rooms below grade, and have to diffuse through several rooms or be transpotted via the filter system to i
rooms bordering on the exterior of the building prior to release. After filtration, the expected
)
discharge flow of 2700 cfm would have been returned with the recirculation flow of 11760 i
cfm to the vanous ECCS rooms. These rooms are typically provided with sealed
~
penetrations and solid doors (not wire mesh) maintained closed for flood protection, radiation protection, fire protection, etc., and would provide a substantial banier to radioactivity release. Therefore, :he majority of the leakage would be processed through the PPAFES 4
filters, perhaps being recirculated several times, prior to release. The leakage which bypasses the filters would have a long winding pathway to follow prior to exiting the auxiliary building and would be subject to natural removal processes along the way, such as settling and 4
plateout.
3 3)
The PPAFES charcoal filter iodine removal efficiency is supplemented by heaters that aid in decreasing humidity. Since the expected relative humidity at the charcoal filter inlet
]
(following the guidance of Regulatory Guide 1.52) is much closer to the controlled j
environment value of 70 percent than to the uncontrolled environment value of 95 percent, the PPAFES efficiency ofiodine removal would be greater than that taken credit for in the design basis dose analysis. In addition, the filter actually has a bed depth of four inches as opposed to the two inches taken credit for in the accident analysis. Therefore, the recirculation / filtration which would occur would be more effective than discussed above.
Finally, there was no leakage event during the period of time involved. Based on these considerations, there was no adverse effect on plant safety or on the health and safety of the public as a result of this event.
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i F. CORRECTIVE ACTIONS l) The work planner and SSS involved have been counseled on the significance of con 6guration control when preparing, reviewing, and approving clearances.
i
- 2) The operation work planners and system engineers will be trained regarding this event with emphasis on configuration control, by June 15,1994.
- 3) Licensed operators will review this event in continuing training by July 15,1994, with particular l
instruction on connguration control. Emphasis will also be given to utilizing a questioning attitude when test indications are not clearly understood.
- 4) The appropriate Unit I and Unit 2 single line diagrams and electrical load lists, which failed to identify by equipment number that the Train A PPAFES exhaust damper was being powered from the circuit breakers, have been corrected. An initial sample review of other breakers that power similar loads revealed no further drawing problems. An additional review wili be completed by August 1,1994.
- 5) An evaluation of the test methodology for the current PPAFES TS surveillances will be completed with recommendations for system and procedure improvements by July 1,1994 G. ADDITIONALINFORMATION 1)
Failed Cornponents:
None 2)
Previous Similar Events:
None 3)
Energy Industry Identification System Code:
Emergency Core Cooling System - BJ, BP Piping Penetration Air Filtration and Exhaust System - VA TOT 4. P.08
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Piay 26,1994 LCV-0370 Docket No. 50-424 U. S. Nuclear Regulatory Commission ATTN; Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen.
VOGTLE ELECTRIC GENERATING PLANT LICENSEE EVENT REPORT
_ CLOSED DAMPERS RENDER TWO TRAINS OF HVAC INOPERABLE In accordance with the requirements of 10 CFR 50.73, Georgia Power Company submits the enclosed report related to an event which was initially reported to the NRC per 10 CFR 50.72 (b)(2)(iii) on April 26,1994.
Sincerely
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a C. K. McCoy j
1 CKM/AFS Enclosure LER l-94-003 j
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Ocgraia Power Company Mr.1. 3. Beasley, Jr.
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Mr. M. Sheibani NORMS U. S. Nuclear Reculatory Commission Mr. S. L). Ebneter, Regional Administrator Mr. D. S: Hood. Licensing Project Manager Mr. B. R. Bonser, Senior Resident inspector, Vogtle
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Mehdi Sheibani, Nuclear Safety and Compliance
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On April 24,1994, exhaust dampers in both trains of the piping penetration area filtration and exhaust system (PPAFES) were found to be closed due to circuit breakers being deenergized while a design change was being performed on another air filtration system that utilized the same circuit breakers. The exhaust dampers were reenergized and restored to service. Concurrently, an initial determination was made, based on test results, that this condition had not rendered the system inoperable. On April 26,1994, a further engineering evaluation determined that having the exhaust dampers closed would limit the ability of the PPAFES to control radioactive releases in a post-LOCA scenario.
The cause of this event was cognitive personnel error and lack of attention to detail. This resulted in an inadequate review of the circuit breaker clearances associated with the design change. Also, subsequent personnel errors occurred which delayed the identification and resolution of the problem.
Personnel were counseled and additional training will be conducted to emphasize the importance of clearance reviews for proper configuration control.
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m,-, = m A. REQUIREMENT FOR REPORT This report is required per 10 CFR 50.73 (a)(2)(v) because a condition existed that alone could have prevented the fulfdiment of a safety function of a system needed to. control the release of radioactive material. It is also required per 10 CFR 50.73 (a)(2)0) because the unit operated in a condition prohibited by the Technical Specification (TS) when a system was inoperable for a period of time longer than that allowed by the action statement.
4 s
B. UNIT STATUS AT TIME OF EVENT At the time of this event Unit I was operating in Mode 1 (power operations) at 100 percent of rated thermal power. Other than that described herein, there was no inoperable equipment that contributed to the occurrence of this event.
l C. DESCRIPTION OF EVENT The Unit 2 electrics.1 penetration filtration system had never been installed and as part of a design change to abandon the Unit I system, on February 28,1994, and March 1,1994, personnel installed clearances by opening the applicable circuit breakers. These clearances removed power to several i
dampers in this filtration system. However, power was also unknowingly removed to pipin8 penetration area filtration and exhaust system (PPAFES) train A and B exhaust dampers, IPV-i 2550B and IPV-2551B because they share circuit breakers with the system being abandoned. This I
left the PPAFES exhaust dampers in their closed positions and inoperable. These exhaust dampers open to preset positions to maintain negative pressure during PPAFES operation. Thus, the PPAFES was limited in its ability to control the release of radioactive materials from the piping penetration rooms, had it become necessary to do so in a post-LOCA scenario.
l TS surveillances were performed for the Train A PPAFES on March 15,1994, and April 11,1994, and for the Train B PPAFES on March 28,1994. Personnel noted that the position indication lights, used for vcirifying modulation of dampers IPV-2550B and IPV-2551B, were not illuminated during two of these three surveillances. During the March 28,1994, surveillance, an investigation of the apparent position indication problem was initiated, but was not pursued due to shift turnover.
Since the acceptance criteria for the surveillance was met, the surveillance was signed off as
' satisfactory. A more thorough and complete investigation was conducted during the April 11,1994, surveillance.
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- Visual indication of IPV-2550B valve linkage led the personnel involved to believe that the valve had actually moved to its preset demanded position, and a work order was initiated to effect repairs of the position indication. On April 20,1994, an investigation by an electrician, per the work order, i
revealed that both the indicator lights and the dampers viere removed from service because the i
power had been removed. The unit shift supervisor (USS) was notified that the position indication was lost due to the breakers being open. However, he did not realize that opening the breakers had i,
also removed power to the dampers. On April 24,1994, during work order closecut, another USS recognized the impact on the PPAFES. While reviewing the clearance for modification to reenergize the exhaust dampers, PPAFES testing was performed to determine operability. System flows, differential pressures, and alarm indications all indicated normal, with the only abnormality being the indication for the exhaust dampers. ARer discussion of the test results with the system engineering 4
supervisor and plant management, an initial determination was made that this condition had not i
rendered the system inoperable. However, plant management requested a design review of this i
condition to determine the complete impact to the PPAFES Power was restored and the system returned to service.
i On April 25,1994, the design engineering staff began to evaluate the effect of the deenergized dampers on the operability of the system and on April 26,1994, it was determined that PPAFES had been rendered inoperable and that the safety function of the system had been degraded by the dampers being deenergiard yhile in their closed positions. A four-hour non-emergency notification was made to the NRC Oper:tions Center per 10 CFR 50.72 (bX2Xiii) because a condition existed -
that alone could have pre eent;d the fulfillment of a safety function of a system needed to control the release of radioactive material.
A broadness rev'ew found that similar events had occurred when damper circuit breakers were deenergized for une train of PPAFES on three other occasions. Train A breakers were deenergized from October 28,1988, to November 9.1988, and from July 30,1992, to August 19,1992. One train B breaker was deenergized from August 8,1988, to August 26,1988. No Unit 2 events were found.
D CAUS.3 ( F EVENT The cause of this event was cognitive personnel error and lack of attention to detail by the operation work planner and the support shift supervisor (SSS). This resulted in an inadequate review of the circuit breaker clearance associated with the design change. The operation work planners and SSS's reviews did not find the PPAFES train A exhaust damper on the appropriate breaker drawing or its respective load list because it was not listed on these documents. The FPAFES train B exhaust
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damper was shown on its respective drawing and load list, but these were not adequately reviewed i
since the train A and train B clearances were being developed at the same time.
l l
i
' Subsequent personnel errors committed during performance of surveillance testing and investigation l
of damper position indication prevented the early detection and correction of the clearance error.
4 The occurrence of these cognitive personnel errors by the Georgia Power Company personnel involved was not the result of any unusual characteristics of the work location.
l 1
A contributing cause of this event is that the single line diagram and electricalload list failed to specifically identify by equipment number that the train A exhaust damper was a device being i
i powered from the affected circuit breakers. The' single line diagram and electrical load list identified other dampers and an HVAC panel as devices being fed from the circuit breakers which were l
deenergized on February 28,1994 However, the train A exhaust damper was also being fed from these circuit breakers via the HVAC panel.
E. ANALYSIS OF EVENT The functions of the PP AFES are to maintain a negative pressure boundary on the piping penetration i
area rooms and to filter the exhaust from those areas. Safety Evaluation Report dated July 9,1992, assumes iodine leakage from the piping penetration rooms and emergency core cooling system (ECCS) equipment to both offsite and control room locations during post-LOCA conditions.
Therefore, the control room and offsite dose analyses are potentially affected by the degradation of this system caused by the inoperable exhaust dampers.
Based upon the latest dose analysis, had the ECCS leakage risen to the design basis analyzed value of 2 gpm with the PPAFES exhaust dampers closed, the offsite dose would have remained within the 10 CFR 100 limits, and the control room dose would also have remained within the General Design Criteria 19 acceptance criteria.
Several other factors also existed that would have mitigated the consequences of this scenario:
1)
The latest surveillance value for ECCS leakage, based on the requirements of TS 6.7.4 and taken during the last Unit I refueling outage, indicated the leakage was less than 0.1 gym.
This would result in the expected source term being significantly less than the 2 gpm assumed in the design basis dose analysis.
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-nxw n..n -...-.-- - see m m Although the PPAFES exhaust dampers were inoperable and would have resulted in an increase of radioactivity release, the filter and recirculation function of the PPAFES was operable and would have filtered out a majority of the airborne radiation resulting from ECCS leakage.
Combining these two conditions of a low ECCS leakage value and the operability of the recirculation / filtration function of PPAFES being unaffected by the inoperability of the exhaust dampers, results in maintaining the expected source term within the design basis dose analysis value.
2)
ECCS leakage which occurred would enter the auxiliary building in interior rooms below grade, and have to diffuse through several rooms or be transported via the filter system to rooms bordering on the exterior of the building prior to release. After filtration, the expected discharge flow of 2700 cfm would have been retumed with the recirculation flow of 11760 l
cfm to the various ECCS rooms. These rooms are typically provided with sealed penetrations and solid doors (not wire mesh) maintained closed for flood protection, radiation protection, fire protection, etc., and would provide a substantial barrier to radioactivity release. Therefore, the majority of the leakage would be processed through the PPAFES filters, perhaps being recirculated several times, prior to release. The leakage which bypasses the filters would have a long winding pathway to follow prior to exiting the auxiliary building and would be subject to natural removal processes along the way, such as settling and plateout.
3)
The PPA'FES charcoal filter iodine removal efficiency is supplemented by heaters that aid in decreasing humidity. Since the expected relative humidity at the charcoal filter inlet (following the guidance of Regulatory Guide 1.52)is much closer to the controlled environment value of 70 percent than to the uncontrolled environment value of 95 percent, the PPAFES efficiency ofiodine removal would be greater than that taken credit for in the design basis dose analysis. In addition, the filter actually has a bed depth of four inches as opposed to the two inches taken credit for in the accident analysis. Therefore, the recirculation / filtration which would occur would be more effective than discussed above.
Finally, there was no leakage event during the period of time involved. Based on these considerations, there was no adverse effect on plant safety or on the health and safety of the public as a result of this event.
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. e.=un F. CORRECTIVE ACTIONS
- 1) The work planner and SSS involved have been counseled on the significance of configuration control when preparing, reviewing, and approving clearances.
- 2) The operation work planners and system engineers will be trained regarding this event with emphasis on configuration control, by June 15,1994.
- 3) Licensed operators will review this event in continuing training by July 15,1994, with particular instruction on configuration control. Emphasis will also be given to utilizing a questioning attitude when test indications are not clearly undersiced.
- 4) The appropriate Unit I and Unit 2 single line diagrams and electrical load lists, which failed to identify by equipment number that the Train A PPAFES exhaust damper was being powered from the circuit breakers, have been corrected. An initial sample review of other breakers that power similar loads revealed no further drawing problems. An additional review will be completed by August 1,1994.
' 5) An evaluation of the test methodology for the current PPAFES TS surveillances will be completed with recommendations for system and procedure improvements by July 1,199'.
4 i
G. ADDITIONALINFORMATION 1)
Failed Components:
None 2)
Previous Similar Events:
None 3)
Energy Industry Identification System Code:
Emergency Core Cooling System - BJ, BP Piping Penetration Air Filtration and Exhaust System - VA TOTAL P.CG
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,o SOUTHERN NUCLEAR OPERATING COMPANY VOGTLE PROJECT 42 INVERNESS CENTER PARKWAY BIRMINGHAM, ALABAMA 35242 l
BUILDING 40, BIN B042 FAX COVER SHEET VOGTLE PROJECT -4TH FLOOR b Ob 1
DATE:
l NUMBER OF PAGES:
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(EXCLUDING COVER SHEET)
PLEASE NOTIFY SENDER IF YOU HAVE PROBLEMS RECEMNG THIS FACS! MILE.
Ken McLod E s: neic o Sk w e I
EXTENSION:
EXTENSION:
LOCATION:
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FAX:
bbb I' YY- 003 COMMENTS:
I EXECUTIVE FAX 205-877-7885 MCCOY/8HIPMAN 4
ADMINISTRATION MAINTENANCE FAX # 205-868 5124 BUSH /CARDONA,
FAX # 205 868-5465 WARD /AJLUNI COBB/STYSLINGER VERIFY # 205-868-5119 OR VERIFY # 205-877-7878 205-877-7071 ENG. & UCENSING HUMAN RESOURCES j
FAX # 205 877-7885 BAILEY /MYER/GREENE FAX # 205-868 5317 AGRO l
VERIFY # 205-868-5180 (CONFIDENTIAL)
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L/o 4 fk J
EA 94 - 8'7 V
l' Date of Enforcement Conference (ef2!@/
N6J Ad/
Presiding NRC Official.
E. /77en5dhe>h;',i M/
/
49 7*
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i e
Impact on The NBC's Ability to Conduct an Enforcement Conference and/or Implement The Agency's Enforcement Program i
i 1.
Was there a delay in the enforcement process % ~
olding l
an open enforcement conference?
a.
Yes b.
No If yes, what was the cause for the delay?
I a.
Providing sufficient ~public notice of the conference.
}
b.
Licensee requested additional time to prepare for the open enforcement conference.
j c.
Other.
Explain.
i i
If yes, how long was the delay?
)
2.
Were any members of the p ruptive to the proceedings?
a.
Yes b.
No i
e Impact on Licensee 8s Participation During the Open Enforcement Conference i
)
3.
Does the staff believe that the licensee's cewnanmication j
with the staff during the open enforcement conference was less candid or more guarded than in past enforcement conferences or in other meetings where the public was not i
present?
In answering this question, consideration should l
be given to whether the licensee tended to answer staff j
questions more narrowly or whether the licensee volunteered additional information or whether the staff had to be more i
persistent in questioning the licensee to gain full information during the open enforcement conference.
Consideration should also be given to whether there was any change in practice in the licensee having an attorney j
present at the conference.
4 (a.
Nodifference) n.
Little alrrerence.
j c.
Big difference.
Explain.
L
~ _.... _ __ _. _.. _ _ _ _. _... _.. _ __
1 4
1 5
12.
Was substantially more staff time spent ring for the open enforcement conference?
a.
Yes b.
No If yes, explain.
i
')
In answering questions thirteen through nineteen, the staff should give consideration t.o such issues as the need for certain staff members to attend the open enforcement conference, the need j
to provide escorts, the need to make copies of handouts, the need i
to answer questions from,the audience after the conference, the need'to respond to the open enforcement conference survey, etc.
1 13.
Was a higher level of management involved in the open conference than the level of typically involved in closed conferences?
a.
Yes b.
No If yes, explain.
l 14.
Were there substantially in emands on the public affairs staff?
a.
Yes b.
No 3
If yes, explain.
15.
Were there substant reased demands on the legal j
staff?
a.
Yes b.
No i
i If yes, explain.
J 16.
Were there substant creased demands on the security staff?
a.
Yes b.
No If yes, explain.
17.
Were there substantially increanad d===nds on the enforcement staff?
a.
Yes If yes, explain.
18.
Were there substant4=11v increased damands on the technical
{b. " No staff?
a.
Yes If yes, explain.
1
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U. S. NUCLEAR REGULATORY COMMISSION i-REGION' II i
- ATLANTA, GEORGIA i
DATE:
June 2. m 4 l
COMPANY NAME:
Geogia. Power Company 4
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!,*,'%RO FORM 549 U.S. NUCLEAR (;EGULATORY COM AlON MEETIN3 NOTICE nut 4SER I j
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PUBLIC MEETING ANNOUNCEMENT
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Interested persons should notify the contact of their attendance NLT 5 days before the meeting.
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onts RETURN THIS FORM TO:
MEETNG NOTICE COOfCHATOR, MAR. STOP P-375.
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Far'ema F CM)11403 7313. N1) 4934735 OR 4N 472
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May 12 Nobh W(vthL Shto An o(gg
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- r UNITED STATES g
NUCLEAR REGULATORY COMMISSION
%g WA8HINGTON. D.C. 20665 4001 JIM 0 219N Docket No. 50-424 EAs93-304, 94-036,94-037, and 94-052 Georgia Power Company W. G. Hairston, III 40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201
Dear Mr. Hairston:
SUBJECT:
REQUEST FOR EXTENSION OF TIME FOR RESPONSE I have received you letter of May 27, 1994, in which you request a sixty h
day extension for Georgia Power Company's (GPC) response to the May 9, 1994 Notice of Violation and Proposed Imposition of Civil Penalties and responses to three Demands for Information.
This is to advise that, after due consideration and consultation with the NRC staff, I have decided'to grant your request for a sixty day extension. Accordingly, responses on these matters are due no later than August 8, 1994.
I would urge you to provide GPC's responses.as far in advance of that date as possible.
Sincerely,
[w,L jL.---
ames Lieberman, Director ffice of Enforcement cc: Mr. J. D. Woodward Senior Vice President Georgia Power Company Nuclear Operations P. O. Box 1295 Birmingham, AL 35201
~
J. B. Beasley General Manager, Plant Vogtle Georgia Power Company
/
P. O. B
.a,nes,ox 1600 g
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o,o. GA 308,0 l
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J. A. Bailey Manager-Licensing Georgia Pcwer Company
-P. O. Box 1295 s
i Birmingham, AL 35201 Nancy G. Cowles, Counsel Office of the Consumer's l
Utility Council
~
84 Peachtree Street, NW, Suite 201 Atlanta, GA 30303-2318 Office of Planning and Budget Room 615B 270 Washington Street, SW Atlanta, GA 30334 i
1 Office of the County Commissioner Burke County Commission
-Waynesboro, GA 30830 Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE, Suite 1052 Atlanta, GA Thomas Hill, Manager Radioactive Materials Program Department of Natural Resources 4244 International Parkway, Suite 114 Atlanta, GA. 30354 Attorney General Law Department 132 Judicial Building Atlanta, GA 30334 Dan H. Smith Vice President-Power Supply Operations Oglethorpe Power Corporation 2100 E. Exchange Place Tucker, GA 30085-1349 Charles A. Patrizia, Esq.
Paul, Hastings, Janofsky & Walker 12th Floor 1050 Connecticut Avenue, NW Washington, DC 20036 NRC Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 572 Waynesboro, GA 30830
+
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UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 11
'I
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101 MARIETTA STREET, N.W.. SUITE 2000 e
a
.j ATLANTA. GEORGIA 30323-0100
]
JUN - 71994 Docket Nos.:
50-424, 50-425 License Nos.:
Georgia Power Company ATTN: :Mr. C. K..McCoy-
'Vice President j
Vogtle Electric Generating Plant P. O. Box 1295 i
. Birmingham,- AL 35201 Gentlemen:
SUBJECT:
ENFORCEMENT CONFERENCE
SUMMARY
- V0GTLE UNITS 1 AND 2 (NRC INSPECTION REPORT NOS. 50-424/94-15, AND 50-425/94-15)
This letter refers to the Enforcement Conference held at our request.on June 2,1994, at the Region II office in At'lanta, Georgia. This meeting concerned activities authorized for your Vogtle facility. The issues discussed at this conference related to an event where the Unit 1 Piping Penetration Area Filtration and Exhaust System was in a degraded condition for approximately 54 days. This conference was to discuss the apparent violations, the causes and safety significance of this event, and to provide you the opportunity.to point out any errors in the inspection report. A list of attendees ~ and a copy of your enforcement conference handout are enclosed.
Your presentation provided additional information and clarification.of the issues ' associated with the apparent violations and the items. identified in our inspection report.
We are continuing our review of these apparent violations to determine the appropriate enforcement action.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice", a copy of this letter 'and its enclosures will be placed in the NRC Public Document Room.
Should you have any questions concerning this letter, please contact us.
Sincerely,
\\% ft wn L/Jon RL/ Johnson, Acting Director Division of Reactor Projects
Enclosures:
[
1.
List of Attendees j
i 2.
Handout'
)/
I cc w/encis:
(See page 2)
S%u?juf al';
AlY
o i
Georgia Power Company 2
y7g cc w/encls:
J. D. Woodard.
j Senior Vice President-Nuclear j
Georgia Power Company P. O. Box 1295 i
Birmingham. AL 35201 J. B. Beasley General Manager, Plant-Vogtle Georgia Power Company P. O. Box 1600 Waynesboro, GA 30830 l
J. A. Bailey Manager-Licensing Georgia Power Company P. O. Box 1295 l
Birmingham, AL 35201 Nancy G. Cowles, Counsel Office of the Consumer's Utility Council 84 Peachtree Street, NW, Suite 201 Atlanta, GA 30303-2318 Office of Planning and Budget j
Room 615B 270 Washington Street, SW Atlanta, GA 30334 Office of the County Commissioner Burke County Commission Waynesboro,'GA 30830 Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334-l Thomas Hill, Manager-Radioactive Materials Program Department of Natural Resources 1711 I n t o rn a t 'i nn a.1 Dsrkway i
Suite 114 l
Atlanta, GA 30354 I
~ Attorney General Law Department 132 Judicial Building Atlanta, GA 30334 (cc-w/encls cont'd - See page 3) i
i I
1 4
I J
Georgia. Power Company 3
JUN - 7 [994
.l (cc w/encis cont'd)-
Ernie1Toupin Manager:of Nuclear Operations Oglethorpe Power Corporation
.2100 E. Exchange Place P
Tucker,'GA-30085-1349
~
~
' Charles A. 'Patrizia, Esq.
j ePaul, Hastings, Janofsky & Walker d
12th Floor i
1050 Connecticut Avenue, NW Washington,- D. C.
20036 a
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l ENCLOSURE I LIST OF ATTENDEES U.S. Nuclear Reaulatorv Commission E. W. Merschoff, Acting Deputy Regional Administrator, Region II (RII)
J. R. Johnson, Acting Director, Division of Reactor Projects (DRP), RII B. S. Mallett, Deputy Director, Division of Radiation Safety and Safeguards (DRSS), RII i
L. L. Wheeler, Sr., Project Manager, Project Directorate II-3, Office of Nuclear Reactor Regulation (NRR)
P. H. Skinner, Section Chief, Reactor Projects Branch 3B, DRP, RII B. Uryc, Director, Enforcement and Investigation Coordination Staff, RII C. F. Evans, Regional Counsel, RII L. J. Watson, Enforcement Specialist, RII B. R.- Bonser, Senior Resident Inspector, Vogtle, DRP, RII R. D. Starkey, Resident Inspector, Vogtle, DRP, RII T. Decker, Chief Radiation Effluent and Chemistry, DRSS, RII Georoia Power Company W. Hairston, Jr., Executive Vice President J. Woodard, Senior Vice President C. McCoy, Vice President J. Beasley, General Manager, Vogtle Electric Generating Plant (VEGP) j J. Bailey, Manager Licensing T. Wright, Manager Public Information J. Gasser, Unit Superintendent, Operations (VEGP)
C. Williams, Shift Superintendent, Operations (VEGP)
W. Stephens, Jr., Unit Shift Supervisor, (VEGP)
W. Evans, Reactor Operator (VEGP)
J. Wehrenberg., Principal Engineer, Southern Company Services i
K. Rubin, Engineer, Westinghouse
,m-we
r ENCLOSURE 2 NRC ENFORCEMENT CONFERENCE PIPING PENETRATION AREA FILTRATION AND EXHAUST SYSTEM INOPERABILITY i
i OPENING STATEMENT GPC / NRC-DESCRIPTION OF SYSTEM BARNIE BEASLEY PURPOSE r
TECHNICAL SPECIFICATION j
CHRONOLOGY OF EVENT BARNIE BEASLEY CAUSES OF EVENT BARNIE BEASLEY SAFETY SIGNIFICANCE ANDY WEHRENBERG f
CORRECTIVE ACTIONS BARNIE BEASLEY r
SUl4 MARY KEN McCOY i
l i
l r
i t
PURPOSE OF PIPING PENETRATION FILTRATION SYSTEM i
Limit / Reduce releases due to ECCS recirculation and component leakage during a LOCA.
)
+
Maintain negative pressure in piping penetration areas.
)
i Additional filtration through charcoal filters.
i Sends exhaust to plant vent stack.
Acceptance Criteria lodine leakage to both offsite and control room i
locations during post-LOCA will meet 10CFR 100 limit and GDC 19 acceptance criteria
_j
PIPING PENETRATION AREA FILTRATION AND EXHAU'<." SYSTEM l
(SIMPLIFIED DIAGRAM)
PLANT VEh T STACK C EXHAUST
( / DAMPER IPV-2051B i
j PIPING PENETATION d
d-ROOM FILTER &
j (#
EXHAUST UNIT l
+
TRAIN 8 PIPING PENETRATION
+
COOf.ERS 7
ROOMS & OTHER
[
LOCATIONS PIPING PENETAT!ON ROOM FILTER &
i j_
j i
EXHAUST UNIT r
p TRAIN A EXHAUST DAMPER
[
j j(
1PV-25508 PLANT VENT STACK I
4 I
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I TECHNICAL SPECIFICATION T.S. 3.7.7 Two independent Piping Penetration Area Filtration and Exhaust Systems shall be OPERABLE.
APPL.lCABILITY: MODES 1,2,3, and 4 ACT lON:
1 With one Piping Penetration Area Filtration and Exhaust System j
inoperable, restore the inoperable system to OPERABLE status l
within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
j
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TECHNICA.L SPECIFICATION SURVEILLANCE REQUIREMENT TECHNICAL SPECIFICATION 4.7.7a SURVEILLANCE REQUIREMENT:
- Once pei 31 days, initiate flow through the HEPA filters and charcoal adsorbers f
l i
- Verify that the system operates for at least 10 continuous hours with the heater control circuit energized PURPOSE:
l To verify the system operates for 10 continuous hours to reduce moisture buildup in the adsorber and HE PA filters l
i i
1
g EVENT CHRONOLOGY 2/l/94 Clearances prepared by work planner for use during electrical j
penetration filter units deletion.
-l 2/23/94 Clearances reviewed by Support Shift Supervisor.
2/28/94 Train 'A' Clearance authorized and installed.
j 3/i/94 Train 'B' Clearance authorized and installed.
3/15/94 Train 'A' Piping Penetration Filter Unit surveillance test completed and j
4 documented as satisfactory.
3/28/94 Train 'B' Piping Penetration Filter Unit surveillance test completed and documented as satisfactory with damper indication discrepancy observed 4/l I/94 Train 'A' Piping Penetration Filter Unit surveillance test
)
performed. WRTs on damper indications written 4/20/94 Electrician, during troubleshooting, discovered that the clearances removed the power supply for the light indicators - USS notified, but he did not l
realize that the dampers were not operable
]
_4B4/94 During Work Order closeout, Piping Penetration Filter Unit impact i
recognized, dampers energized and operability /reportability evaluation initiated.
f i
4/25/94 Engineering review of configuration and impact on piping penetration filtration system functions begun.
l 4/26/94 Reportability/ operability determination completed; NRC notified.
l i
b 1
i f
CAUSES OF EVENT Inadequate Reviews of Circuit Breaker Clearances j
- Personnel errors due to inadequate reviews of Train 'B' drawings Drawing Discrepancies
- Exhaust damper not shown on Train 'A' drawing & load list j
t I
Failure to Discover Event Earlier -- Personnel Errors j
- Operators not resolving the position indication problem 1
Surveillance Guidance Unclear for Damper Position i
j i
I l
I
t 6
PREVIOUS SIMILAR EVENTS No previous events were found with both trains of piping penetration filtration system inoperable at the same time due to exhaust dampers
{
being deenergized One occurrence was found with one train of piping penetration filtration j
system inoperable for longer than the 7 days allowed out of service j
time due to an exhaust damper being deenergized. The train 'A' exhaust l
damper was deenergized from October 28 - November 9,1988, when an l
Electrical Penetration Filter System circuit breaker was opened.
l i
[
t I
I f
[
i l
i i
SAFETY SIGNIFICANCE i
System Acceptance criteria 4
- Limit / reduce releases to both offsite and control room l
i locations due to leakage from the piping penetration rooms and ECCS components during post-LOCA condition to meet:
10 CFR 100 Limit i
. GDC 19 Criteria f
L i
t i
i h
j 9
~
i CORRECTIVE ACTIONS 1
t Involved personnel have been counseled on significance of.
plant configuration control i
Review event with work planners, system engineers & licensed operators, emphasizing configuration control Drawings and load lists corrected Tech. Spec. surveillance procedures being reviewed to j
determine if improvement is needed' l
Sample of drawings revea :d no similar drawing / load list problem r
The drawing review is continuing j
I t
.i l
SUMMARY
I GPC considers this a significant event due to failure of administrative Controls.
i The piping penetration filtration system was degraded due to-j personnel errors and drawing error.
-Problem discovered by licensee during performance of surveillance l
testing.
3 Dampers restored to service as soon as system impact realized.
Reportability determination made.
i Minimal safety significance since the GDC 19 and 10 CFR 100 i
acceptance criteria were satisfied.
i i
t
PIPE PENETRATION AREA IEAKAGE EVAIJINTON
- MODEI, ECCS ID01' OUTSIDE CONTAINMENT IEAKAGE (3 GPM) 1 I PIPING PENETRATION 2700 CFM UNFIIlfERED J L AREA IEAKAGE TO ATMOSPIIERE FILTER EFFICIENCY
+
i ELEMENTAL = 0.00 ORGANIC = 0.30 i
PARTICULATE = 0.90 FILTERED RECIRCULATION FIDW = 14400 CFM
RESlJI; TANT T IYROID DOSES L'RE$
1 CURRENT FSAR ANALYSIS EAU IPZ CONTROI H00M CONTAINMENl' IEAKAGE 50.6 57.2 26.0 CONTAINMENl' PURGE 0.3 0.1 0.0 FILTERED EXIIAUST (2700CFM)
ECCS LEAKAGE 1.0 1.5 0.3 TOTAL 51.9 50.H 20.3 l
REVISED ANALYSIS UNFILTERED IEAKAGE (2700CFM) i ECCS IEAKAGE I.4 TOTAL 27.4 i
b m.___
-u,
....m
C0NSERVATIVE MODEL PARAMETERS ANAL,YZED EXPE(,TED SOURCE 'l ERM
- CORE FRACTION (%)
50 10
- IODINE FORhl (%)
91,
<1, 5
N0 ORGANIC (El.1:MENTAI. ORGANIC, l'ARTICU!. ATE)
ECCS LEAL, AGE (GPhl) 2
< 0.1 j
PIPE PENkTRATION AREA 2700 1800-2600 IEAKA(;E (CFM)
PPAFES Fil,TER EFFICENCY ("'!
00, 30, 90
= 01).11 PPAFES FillfER RII (%)
95
< = 7,1 CONTROL liOOM FILTER EFFICIENCY (%)
99, 99, 99
>= 0 9.8 1000 CONTROL 1:00M INTAKE (CFM) 1500 s
RELEASE l'ATIIWAY DIRE (.T TO AllXillARY ATMOSPIIERE IllllLDING
- PIATEOUT NONE YES
- SEITLING NONE YES 1
-HOIDUP/ DECAY NONE
-YES
SAFETY SIGNIFICANCE SIB 1 MARY EAB IFZ CONTROL ROOM l
TIIYROID DOSI:
300 300 30 ACCEPTANCE CRITERIA ('REhl?
g RE-ANALYSIS WELL WITIIIN WELL WITIllN 27.4 RESULTS CONCLUSION: THE PPAFES REMAINED CAPABLE OF MEETING TIIE ACCEPTANCE CRITERIA DURING TIIIS EVENT.
. _.. _ _ _.. - _ - _ _ - _ - _ _ _ _. _ _ _ _.. _ -