ML20082C137

Prefiled Testimony of Hw Majors on DG Reporting Issues.* Related Correspondence

ML20082C137
Person / Time
Site:	Vogtle
Issue date:	04/04/1995
From:	Majors H GEORGIA POWER CO.
To:
Shared Package
ML20082B958	List: ML20082B955 ML20082C012 ML20082C045 ML20082C092 ML20082C112 ML20082C137 ML20082C143 ML20082C146
References
93-671-OLA-3, OLA-3, NUDOCS 9504060174
Download: ML20082C137 (10)

Text

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1 WTED CORRESPONDENCE-00CKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD W APR -4 All :07 0FFICE OF SECRETARY In the Matter of  : 00CMEii'iC a LViCE ,

Docket Nos. 50-424-OLA' '3)i GEORGIA POWER COMPANY, at al.  : 50-425-OLA-3

Re: License Amendment (Vogtle Electric Generating Plant, : (Transfer to Units 1 and 2)  : Southern Nuclear)

ASLBP NO. 93-671-OLA-3 PREFILED TESTIMONY OF HARRY W. MAJORS ON DIESEL GENERATOR REPORTING ISSUES 9504060174 950404 l PDR ADOCK 0500 4 4  ;

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p 1 TESTIMONY-OF RARRY W. MAJOR 8

- 2 Q: PLEASE STATE YOUR NAME AND CURRENT POSITION?

3 A: My name is Harry W. Majors. My current position is Project 4 Licensing Engineer for the Vogtle Project.

5 Q: WHAT ARE YOUR PROFESSIONAL QUALIFICATIONS?

6 A: A summary of my professional qualifications is attached hereto 7 as Exhibit A.

8 Q: WHAT WAS YOUR ROLE WITHIN THE VOGTLE PROJECT IN 1990, DURING 4

.9 AND FOLLOWING THE SITE AREA EMERGENCY?

10 A: I have been a Project Engineer in the licensing section of the 11 Vogtle Project's corporate office since 1988. During 1990, I 12 worked on a variety of licensing matters in support of the 13 operations of Plant Vogtle. I reported to the Vogtle Project 14 Licensing Manager (Mr. James Bailey) and performed whatever 15 task he assigned to me.

16 Q: WHAT ROLE DID YOU PLAY _ IN THE PREPARATION OF THE JUNE 29, 1990 17 REVISION TO LER 90-006 AND ITS ASSOCIATED TRANSMITTAL LETTER?

18 A: My principal task rega, ding the revised LER was to assure that 19 the diesel generator start numbers reported were accurate and 20 consistent with the diesel start numbers reported in a June 21 29, 1990 QA audit report (McCoy Exhibit M; GPC Exh. 15). I 22 had no involvement in the preparation of the April 9 23 presentation, the April 9 letter, or the April 19 LER 90-006.

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1 I recall that a draft of the revised LER had already been 2 prepared before I became involved and that I only assisted-in 3 making sure that the diesel start numbers reported therein 4 were correct and capable of independent verification as well 5 as making ninor modifications and wording changes to the body 6 of the revised LER.

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7 I recall spending the majority of my time on the 8 transmittal " cover" letter. The final draft of the cover 9 letter, which was the subject of discussion secretly recorded 10 by Mr. Mosbaugh on June 29, 1990, was based primarily on the 11 QA audit report and comments from various corporate and site 12 personnel. Working with Vogtle site as well as corporate 13 office personnel, I subsequently revised the cover letter to 14 incorporate comments received.

15 Q: HAVE YOU LISTENED TO THE TAPE OF THE JUNE 29, 1990 TELEPHONE 16 CONFERENCE IN WHICH YOU PARTICIPATED?

17 A: Yes I have. A transcript which accurately reflects that >

18 discussion is attached to Mr. Greene's testimony as Exhibit B 19 (GPC Exh. 44) at pp. 19-26.

20 Q: WHAT WAS YOUR UNDERSTANDING OF THE REASON FOR REVISING THE 21 LER?

22- A: Mainly to correct the number of diesel starts reported in the 23 April 19, 1990 LER. l

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'1. 'Q: .WHAT ' WAS . YOUR' UNDERSTANDING ' OF THE PURPOSE OF- THE - COVER

- 21 -LETTER?

- 3 A: -I- understood the cover letter was primarily intended to act as ;

'4 the transmittal mechanism for the-revised LER. We wanted to

Si explain' briefly why the diesel start numbers had been changed,

6. even though such an explanation was not required. .We also

'7' wanted to draw the NRC's attention to the fact that the LER:

~8 revision affected the April 9 letter.

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Q: WHY DID THE COVER LETTER FAIL TO CLARIFY THE DIESEL GENERATOR t

10 STARTS REPORTED IN THE APRIL 9, 1990 LETTER?

11 A: My understanding, at the time, was that the statement in the ,

12- cover letter addressing the diesel start' information l

13 previously provided to the- NRC in the April 9, 1990-

- 14 presentation (and corresponding letter of the same date) was- l 15 added to convey to_the NRC that Georgia Power understood such  !

16 information was affected as a' consequence of' revising the LER ,

17 to change the diesel, start count terminology from " successful 18 starts" (which was not defined) to " valid tests" (as defined ,

19 in NRC Regulatory Guide 1.108). In essence, the cover letter l b

20 statement was intended to convey that the diesel start numbers -!

21 in the revised LER affected the' numbers reported in the April i

- 22 9 letter and superseded those in the original LER. The cover  ;

23 letter, in my mind , emphasized that the diesel start numbers  !

24 reported in the attached LER revision was based on precise .

25 regulatory terminology, which could be independently verified. ,

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Lit Furthermore, I believed that the clarification of the April 9, ,

~2' 1990 letter resulted from the shift in'the revised LER to this" 3 precise diesel start - terminology and was unaware of any  !

n. 4 ' specific error in the April'9, 1990 letter. In fact,,I stated-

'5 in the taped conversation on June 29, 1990, that I thought the 6- April 9 diesel start information was not in error because the l

~7 presentation made by Georgia Power. to the NRC on that date 8 identified each individual start and, thus, the participants 9 must have understood the " successful start" terminology. Egg i

-10 Greene Exhibit B at 25.

l 11 Q: WHY DID YOU NOT PAY SPECIAL HEED TO MR. MOSBAUGH'S COMMENTS 12 DURING THE JUNE 29, 1990 CONVERSATION THAT THE REVISED LER 13 COVER LETTER DID NOT EXPLAIN- THE ' DIESEL START NUMBER l 14 DISCREPANCIES IN THE APRIL 9 LETTER?

15 A: I thought the cover letter and LER were intended to provide. ,

16 correct numbers, not explain errors. Mr. Mosbaugh's comment 17 regarding the purpose of the LER revision (agg Greene Exhibit ,

18 B at 24) misquoted the letter by leaving out "the numbers."

t 19 I did not attribute his misquote to anything other than an 20 honest oversight and I responded based on the actual cover

.21 letter language (i.e. , the LER revision is intended to clarify 22 the numbers). This clarification of the diesel start numbers 23 in the revised LER as a natural consequence clarified the  ;

24 . diesel start numbers previously reported in the April'9 letter 25 (as well as the April 19 LER) whether or not those previous f

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m 1- nusNrs were erroneous. I explained to Mr. Mosbaugh my belief- i

2 that since the diesel starts reported on April 9 were.

3' individually identified on the presentation slide . used by .  !

4 Georgia Power, the NRC participants at the April 9 meeting -

S would not be_ confused about the number of starts reported in 6 the April 9-letter -- they were' consistent with the April 9 7 presentation. The June 29, 1990 cover letter was foremost a 8 device used to transmit the revised LER, and the diesel start 9 numbers reported in the revised LER were independent of the 10 previously reported numbers. Therefore, Mr. 'Mosbaugh's 11 statement that errors 'in the April 9, 1990 letter were 12 different from errors in the original LER was not significant 13 to me for the purposes of the. cover letter or revised LER. I 14 simply never understood that the cover letter for the revised 15 LER was to address " errors" in the April 9 letter.

16 Q: WHY DID THE REVISED LER COVER LETTER STATE THAT DIESEL RECORD 17 KEEPING PRACTICES WERE A CAUSE FOR THE DIFFERENCES IN DIESEL 18 STARTS REPORTED IN THE ORIGINAL LER ON APRIL 19 AND THE JUNE 19 29 REVISED LER? -

20 A: My understanding was that Georgia Power had already informed 21 the NRC that there was an error in the diesel generator start 22 numbers reported in the April 19 LER. That was one of the 23 purposes for issuing the revised LER. Thus, the statement 24 regarding record keeping practices was both an acknowledgement 25 of the error and an explanation as to why it had occurred.

'l This statement, as well as the diesel start number reported in 2 the revised LER, were based on and designed to be consistent 3 with the June 29 QA audit of diesel starts.

4- Q: WHY DID YOU NOT INCLUDE " PERSONNEL ERRORS" IN YOUR EXPLANATION 5 OF THE CAUSE FOR THE ERROR IN THE ORIGINAL LER?

6 A: In my opinion, to say that the inaccurate information was due 7 to personnel error was a statement of the obvious and not an 8 explanation of the cause. A person can make a counting error i 9 by making a simple counting mistake, by counting the wrong 10 thing, by counting over the wrong period of time, or by 11 counting from records that are not up to date. Poor record 12 keeping practices can contribute to the first mistake by 13 making the counting process more difficult and can cause the 14 other mistakes by not being accurate and up to date. I 15 understood the QA audit report to mean that had the Diesel 16 Start Log been kept up to date then the task of counting 17 diesel generator starts would have been simpler and capable of 18 verification by others.

19 Q: DID MR. MOSBAUGH MADE IT CLEAR TO YOU DURING THE CONFERENCE 20 CALL THAT THE REVISED LER COVER LETTER FAILED TO ADEQUATELY 21 EXPLAIN THE ERROR IN THE APRIL 9 LETTER?

22 A: No. In order to understand why this is the case let me 23 explain what I knew on June 29. I knew that: (1) there was an 24 error in the diesel start numbers reported in the original V -

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L 1". LER,: (2)- previous:Lcounts by individuals involved were i 2 inaccurate, (3).the NRC was informed the diesel start numbers s

,3; in the original LER- were wrong, (4). Georgia Power had  ;

- 4 committed to ' revise the LER with correct numbers by the end of I 5 June 1990, (5) a QA audit was performed to verify the correct -;

6- numbers, and (6) the QA audit report would also be given to

-7 the NRC. In drafting the revised LER cover letter, I was not-

'8 trying to address any error in the April-9 letter. In fact, j 9 I did not know there was an error in the April 9 letter. I ,

l 10 believed the purpose for mentioning the April 9 letter was to- l J

~ 1 11 acknowledge the consequential difference between it and the 12 revised LER's diesel start numbers. The taped conversation 13 reflects that I openly discussed my understanding of, and the  ;

i 14 basis for, the information contained in the cover letter; at l

15 the end of the conversation I believed that agreement had been 16 reached regarding the cover letter by all participants, j l

17 including Mr. Mosbaugh. ' Egg Greene Exhibit B ct 20-26.

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18 Q: MR. MAJORS, DID YOU KNOWINGLY PROVIDE FALSE INFORMATION TO THE l l

19 NRC BY AGREEING WITH THIS COVER LETTER LANGUAGE?

i 20 A: Absolutely not. In my opinion, the conversation recorded by l 21 Mr. Mosbaugh on June 29, 1990, demonstrates conclusively that  ;

22 I did not knowingly provide false information to the NRC. The 23 tape reflects that I openly explained my understanding cf the

- 24 purpose of the LER revision (i.e., to report the correct i

25 diesel start numbers) and that I was not aware of any " error" 1

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2 1! ' in the' April 9 letter. 'I'also explained that the QA audit 2~ report was the basis for ~ the new numbers as well - as the .

3 " record keeping practices" explanation as the most likely 4 . cause for the error in the original LER. S.gg Greene Exhibit 5~ B at 21. Mr. Mosbaugh did not challenge these explanations.

6 At no time did Mr. Mosbaugh inform me of-his understanding 7 that the cover letter-was supposed to address the specific l 8' cause of the errors in either the April 9 letter or the 9 original LER. The purpose of the revised LER was.to correct 10 the diesel start numbers in the original LER. With respect to 11 the April-9 letter, I did not know it was not correct because 12 it was based on Mr. Bockhold's presentation with which I was i

13 not involved. However, my understanding of the purpose for  ;

l 14 mentioning the April 9 letter was the consequential affect of- ,

15 the revised LER's start numbers on the start numbers reported

. 16 in the April 9 letter. My practice has always been and will 17 continue to be to provide complete and accurate information to I

18 the NRC to the'best of my ability.

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~ GPC EXHIBIT 48 MAJORS EX. A

SUMMARY

OF PROFESSIONAL QUALIFICATIONS HARRY W. MAJORS EDUCATION 1971 Master of Science, Nuclear Engineering 1970 Bachelor of Science, Aerospace Engineering Georgia Institute of Technology, Atlanta, Georgia WORK HISTORY:

Georgia Power Company / Southern Nuclear Operating Company Birmingham, Alabama 1988-Present Project Licensing Engineer; provide project licensing coordination and support associated with NRC approval for major design and operations changes for the Vogtle Electric Generating Plant (e.g.,

power uprating)

Southern Company Services, Inc.

Birmingham, Alabama 1987-1988 Senior Licensing Engineer; provide licensing engineer support for the initial start-up and commercial operation of the Vogtle Electric Generating Plant Electric Supply Commission South Africa ,

1981-1987 Consultant; coordinate multinational team assessment of the design, performance, safety and regulatory requirements of the Koeberg Nuclear Power Station Southern Company Services, Inc.

Birmingham, Alabama 1972-1981 Senior Licensing Engineer; coordinated the regulatory requirements engineering review for the Vogtle Electric Generating Plant; coordinated the preparation of the Vogtle and Hatch Safety Analysis Reports PROFESSIONAL LICENSES:

Registered Professional Engineer, State of Alabama