ML20129F243
| ML20129F243 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/19/1990 |
| From: | Kohn M KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | Robinson L NRC OFFICE OF INVESTIGATIONS (OI) |
| Shared Package | |
| ML20129F106 | List:
|
| References | |
| FOIA-94-208 NUDOCS 9610040082 | |
| Download: ML20129F243 (43) | |
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- ) KO H N, KO H N & CO LAPINTO, P.C.
ATTORNEYS AT LAW s a v ruonica Avtwut. Nw WA5MINGTON. DC 20001 (2024334 4663 c ast o.me w.. or cou=sru r se a r+.s = u. no =** + oameru. os.+vav** ! DAYto K. CoLAMNTo# + E ANNETTE N. ERONSTaoT* i
. . .m . . .a 810aefff $ $ NW God + &paertva p tse DC 8 608e17980 am asa June 19, 1990 ;
Confidant Larry Robinson NRC - OI
Dear Mr. Robinson:
As I mentioned today over the phone, the letter I sent you on June 13, 1990 was inaccurate inasmuch as Allen Mosbaugh advised Mr. Art Domby only once (rather than twice) that Mr. Skip Kitchens had stated in his presence that "I got to use my license." Mr. Mosbaugh advised me of the error when he first saw a copy of the FAX. You indicated that you would note the correction on the faxed letter I sent you. To eliminate any misunderstanding, , , please find enclosed a revision of my June 13th letter correcting the error. Respectfully yours, l
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Michael D./W Kohn, Counsel to Allen Mosbaugh l l l l 1 l l l 9610040082 960827 I O- /) [ 'l PDR FOIA COLAPIN94-200 PDR ;.
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***** PLEASE NOTE ******
The level of detall contained in tnis concern will allow the,Vogtle and SONOPCO management to conclusively ident1fy the autnor.Because of the h1gh level of the personnel involved and the ; serlousness of these concerns, I recuest that you do not reveal the text of th1s letter or the fact that this information was obtained thru an allegation, to Vogtle or SONOPCO personnel.I fear that retalltation including the possibility of physical harm could come to me or my family.I am concerned because of recent art 1cles surrounding Gulf Power,a Southern Co. subs 1 diary,and the Jake Horton case as well as my observations of Georgia Power,SONOPCO, and Vogtle ; management for many years. !
***** PLEASE NOTE ****** i l
The Georg1a Power Company has made two mater 1al false statements in written correspondence submitted to the NRC i regarding Plant Vogtle's emergency d1esel generator's ! control and starting air supplies and diesel generator testing.The statements are contained in correspondence ELV-01516 submitted on 4-9-90 in response to the NRC'S i Confirmatlon of Action letter.The purpose of ELV-01516 was to explain Georgia Power's review,1nvestigation and correct 1ve actions taken with respect to the events involved in the Site-Area Emergency of 3-20-90 and to request the NRC to 11ft 1t's hold on criticallity and resumption of power operations on Vogtle Unit 1. In ELV-01516 page 3, 1 tem 4 it states"GPC has reviewed air quality of the D/G air system including dewpoint control and has concluded that air qual 1ty 1s satisfactory. Initial reports of higher than expected dew points were later attributed to faulty instrumentation.This was confirmed by internal inspection of one air receiver on Apr11 6,1990 which showed no indication of corrosion and daily air receiver blowdowns with no sign 1f1 cant water discharge." The above paragraph 1s materially false by omission and/ or commission in that it presents a conclusion (that air quality is satisfactory) that cannot be concluded from objective evidence and knowldege of Vogtle's Diesel generator air systems. This includes the dewpoint measurments taken,the procedures used, the malntenance history of the DG 1A dryers, the operational allignments,the air qua'ity acceptance criterla requirments of the Vogtle diesel generators from the Vogtle FSAR and Vogtle's response to Generic Letter 88-14 in correspondence ELV-00197 page 3. The following substantiates a less than satisfactory
4 n1 story of a1r quality: 1.Vogtle's response to Generic Letter 88-14 presents i the " maximum dewpoint acceptance criteria for the VEGP diesel air start system ---as 50 F at system pressure i 225 to 250 psig).
- 2. Prior to 6-28-89 dewpoints were not regularly checked with no measurments taken in 1987 and only one taken in 1988.The 1988 value 1s theoretically impcss1ble for the refrigeration type dryers ,
installed (less than 32 F).The 2 measurments taken in 1989 prior to 6-28-89 were also theoret1cally imposs1ble(less than 32 F). 3.Since the equipment used to measure dewpoints measures at atmospheric pressure and the criterla is , at system pressure, a calculation or correct 1on must be performed to adjust to reference pressure. i The maintenance procedures used, do not include i instructions for this and there are no calculational records or data that show how 1t was done .Therefore ! the accuracy of even post 6-28-89 data is not certain. l 4.The maintenance procedure in use 1s contrary to the , dewpoint measurment equipment vendors recomendations i in that it uses a pressure regulator which the vendor . says holds moisture and g1ves false readings. !
- 5. Readings obtained on 3-9-90 and 3-31-90 exceeded acceptance criteria and were as high as 80 F.This i was explained as " faulty equipment" but after that, '
on 4-6-90, valid dewpoint readings of 84 F were l measured for Unit 1 DG air dryer K01 and 83 F for K02 1 as documented on DC 1-90-186. Maintenance work order j 2-9000964 documents air cuality problems on the Unit 2A diesel where nearly every dewpoint measurment exceeded acceptance criterla when measured with several kinds of instruments. Values as high as 95 F were measured on 4-9-90 thru 4-11-90.DC's were not wr1tten for these out of spec. conditions. Maintenance work order 2-9001136 documents continu1ng dewpoint problems on the 2A d1esel. 6.The air dryers for the Un1t 1A diesel generator have been out of service for excessive periods of time.Ma1ntenance work order 1-88-02991 was open from 5-10-88 to 5-2-B9 to repa1r both the K01 and i K02 dryers. Refrigeration compressors as well as I condensing fans have been bre sen.When preparing to i perform the UV testing of the d1esels for the IIT, j air dryers were found out of service. 7.Desp1te having the air dryers out of service the assoc 1ated compressors have remained in service. I 8.The diesel generator utilizes a pneumatic air control logic system which has e<tremely small or1fices as small as 6 thousandths of an inch.This air control system takes its air from the starting air system.
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. 1 9.Qualitat1ve and gross observations at a few points in the system.one air' receiver tans and a filter, i is not-sufficient to confirm satisfactory air j Quallt/ anc internal cleanliness of nundreds of air 1 1nes after years of inaceouate air cryer maintenance anc cewpoint testing.
10.Atr in the diesel building 1s not a1r conditior.ed i and theref;re tne air compressors utilire ame.ent alr.which 1 the Central Savanna P.ver Area is ; typically extremely warm and e am1d l much of the year.Witho'.t dryers in service, water l In the system .s bound to be a problem. j 11.For perloce of operation withcut dryers in i service (which have been extensive) the air ! In the rece1ver would be saturatec and have a ! dewpo1nt of that of room temperature.Rece1ver , blowcown would not alter those condit1ons. For summer ! at Vogtle that would be 90 -100 F.Using psychometric ; cnarts a crop of approximately 30 F in dewpoint j
-would cccuer upon pressure recuction to the :
control a r pressure of 80 psig.This would j produce a dewpoint of 60 to 70 F wnicn exceeds the acceptance criterta.This value is suppr1 singly , close to the valid measurments recently taken with the dryers out of service. Clearly air Quality should be expected to be unsatisfactory dur1ng per1ods when the dryers have been out cf ] service. i l Consider 1ng items 1 thru 11, the only conclusions that can l be drawn is that the air Quality for the Vogtle Unit 1 D1esels is unknown and indeterm1nant for the f1rst 2 1/2 1 years of post license operation with known lengthly periods ' of dryers out of serv 1ce curing which times air Quality i probably was unsatisfactory against the acceptance criter1a i stated in response to Gener1c Letter 88-14.For the most recent period since 6-28-89 air Quality was measured and generally met acceptance criteria except wnen dryers were out of service ( the extent of which is cificult to reconstruct) at which times air Quality was probably again unsatisfactory.At the t1me that correspondence ELV-01516 was' signed by Georgia Power, 2 of 4 diesels nad air cuality problems with h1gh dewpoints (outside acceptance cr1teria) ranging from 64 to 84F. Dewpoints that high could easily result in water 1n the airo lines as room temperatures cyc le(when cool night or early morning air-1s drawn into t'ie room).The outside air dampers locations in the 01esel rooms make this a dest 1nct pos1b111ty.The presence of any water in the. lines will lead to corrosion and carticulate matter formation which could be carried to the pneumatic logic boards, sensor valves and other pneumatic components and could easily cause malfunctions. I 4
- --- r* *-
l 2 In ELV-01516 page 3 item 9 It states'31nce March 20. 1990. ! GPC has perforned numerous sensor caliorations ( i nc l uc i r.g l jacket water temperature). extensive log 1c testing, spec 131 ; oneumat1c leaf testing, and multiple engine starts and runs under various conditions.Since March 20. the 1A DG has i been started 13 times,and the 18 CG has been started 19 times.tlo failures or oroblems nav e occurred during any o# these starts. In addition ,an undervoltage start test < without air roll was conducted on April 6.1990 and the 1A D/G started and loaded properly.' ' The above paragraph 1s materially false by om1ss1on and/or commission because according to Vogtle control room logs and procedure 14980 data sheets the 18 DG had been started 29 timestsee NOTE
- belowl since Marcn 20,1990. It experlenced 8 failures or problems during these starts and one prcolem i with control a1r pressure between starts as follows: ;
Start Date T1me Comment i 1 3-21-90 21:49 Diesel failled to start ]
- 2. 3-21-90 21: 56 Diesel failled to start !
3 3-21-90 22:02 4 3-21-90 22:59 Diesel had to be stopped due to j low luDe oil pressure and h1 oil ! filter DP 5 3-21-90 23:14 Diesel had to be manually ! stopped because of high fuel oil i DP 6 3-22-90 00:17 7 3-22-90 04: 28 9 3-22-90 07:14 ' 9 # 3-22-90 08:54 10 # 3-22-90 09:21 11 # 3-22-90 09:50 , 12 # 3-22-90 10:09 ! 13 3-22-90 11: 06 Diesel tripped H1 Lube 011 Temp i 14 3-23-90 05:09 Got B chase 127 Undervoltage relay flag on start 15 3-23-90 17:30 Diesel tripped Lo Jacket dater Press./ Turbo Lube Oil Press, 16 3-23-90 17: 44 17 3-24-90 00: 48 Got generator ground relay 164 dropout on start. Received DG1B Tr10 41 Jacket water alarm.DG snould nave tripped but didn't. 18 3-27-90 16: 49 19 3-27-90 19:09 20
- 3-27-90 19:51 l 21
- 3-27-90 19:57
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22- = 3-27-90 20:04 ; , 23 3-27-90 _2.:20 Diesel 18 undervoltage Test 24 { 3-23-90 04: 03 Diesel.TS Surveillance 14980 *
- 25. 3-28-90' 13:50 1
-26 3-28-90 13:56 3-29-90 15:27 Diesel 1B Ceclared Operable !
4-03-30 05: 15 Got Maint. Ic:kout alarm due to i low control air pressure (41 psi) ! 1 27 4-04-90 16:32 28 4-05-90 00:30 Funct1 coal test of design change 1 DCP 133 29 4-05-90 03:07 Diesel TS Surveillance 14980 Date of ELV-01516 4-9-90 ,
; 30 4-10-90 01:37 Surueillance 14980 l 31 4-12-90 10:20 Surveillance 14980 i 32 4-16-90 00:00 Surveillance 14980 i 33 4-19-90 07:59 Surveillance 14990 l 34 4-13-90 03:14 Diesel Inadvertently emergency !
started while performing i Surveillance CSP-14619-1 NOTE: # . Denotes start not logged in control log but 4 data sheet exists per procedure 14980-1 i
- Denotes start logged in control log but not 4
documented by data sheet per procedure 14980-1 , From the above it is clear that there have been numerous trips and problems with the 1B diesel since 3-20-90, many of ! i which are associated with features Deing investigated to determine the cause of the 1A alesel failure, such as CALCCN switches and control air.In addition, even if you disregard { the trips ar.d problems,there were only 14 successful starts i 1 on iB Diesel s1n:e the time of the last tr1D and only 3 , starts since the time of the last problem and the date of ! ELV-01516. ' It is clear that the data do not support the claims made in k the letter of" No failures or problems dJring any of these starts" fcr this diesel.It is particularly disturbing that l i Georg1a Power has misled'the NRC with this Information, 4 information presented to convince the NRO of the reliability of Vogtle's diesel generators and te obtain permission to , i resume power operations. l I i Since the cause for failure of the Vogtle diesel generator 1A and the subsequent testing and reliable operation of both
.1A and,1B diesels 1s particularly sign 1ficant to the Site-
. Area Emergency, the Confirmation of Action Letter and associated regulatory action and since ELV-01516 was signed !
by.the Senior V1ce' President SONOPCO, tnese Mater 1a1 False ! Statements are very disturbing. {
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1 Deta111ed informaticn and source occuments includ179 Diesel start and failure data used to como11e the abo.e concern have been provided to Al Chaffee of the NRC IIT team.
***** PLEASE NOTE *****
The level cf detall contained 1n this concern will allow the Vogtle and SONOPCO management to conclusively identiff the author.Because of the high level of the personnel involvec anc the seriousness of these concerns, I recuest that you do not reveal the text of this letter cr the fact that this information was obtained thru an allegation, to Vogtle or SONOPCO personnel.I fear that retalitatico including tne poss-b111ty of physical harm could ccme to me or my family.I am concerned because of recent articles surrounding Gulf Power,a Southern Co. subsidiarf,and the Jake Horton case as well as my observations of Georgia Power,SONOPCO, and Vogtle management for many years.
***** PLEASE NOTE *****
i 4 Mcnagement News Summary 1 From: Public Relations Atlanta - Ext. 3133 l ! Clipped From: FULTON COUNTY DAILY REPORT Date: JUNE 15, 1990 DPLEGGNG THE i i PROSECLTION I How Georgia Power AvertedIndictment
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l I Troutman devoted a full-time team to the case on behalf of its moet important client. [ including (left to right) DeWitt Rogers, Bryan B. Iavine. Roger S. Reigner Jr., and I their leader James C. Fleming. - g//"7 By Ann Woolner,Sta/TReporter i n w>
i i i i l" j One of the principles that Steven A. Westby krow for sure after 10 yects as a
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"There are certain rules you don't
' violate," he says. I So he declined when the Justice Depart. .w ment invited him and the other defense J.n s I lawyers in the Georgia Power tax fraud in. ,' f,,. . I vestigation to come to Washington to pre. r[, " 3' w I i nent their side of the story. In fact, none of %~ l the lawyers representing individuals - l accused in the probe were planning to go to 1 Washington imtially. I ! But over at Troutman, Sanders, I Lockerman & Ashmore, the tax lawyers < ) representing the Southern Company and s l ,-*.. ] 1 Georgia Power Co. never doubted they , { would present the strongest defense possi. j j ble when the time came at the Justice De. 1 i partment. Set up to encourage uniform, na. ; i tional tax enforcement, the review process 4 e_ kicks in when the local prosecutor is ready .!l } to ask the grandjury to indict, h : I "It's your last chance," says James C. Jt 1 l Fleming, a Troutman tax panner who led ! I the utility companies' defense team. As a i ! tax lawyer and former Internal Revenue i Service omeial Fleming knew the review . process in Washington, and he knew the . hierarch,y there could tell the local U.S. King & Spalding partner Herschel M. Bloom took every opportunity to
.ItYat t h, f y u bkiev you have present his theory of the tax lasnes to the government.
l something to argue, you better argue it," j Fleming says. trated in this case-by the government. "I was so convinced of our position. In this case, a two-year probe by the IRS That happened when then U.S. that it was correct, and so conymced and a federal grand jury in Atlanta had Attorney Robert L. Barr Jr. held a that they were wrong," says King & reached the point where the U.S. attorney's press conference and released not.only Spalding's Herschel M. Bloom. "Dur. omee here was ready to prosecute. Assistant the IRS agent's amdavit supporting ing the course of the investigation, we U S. Attorney James E. Fagan Jr. was rec. the search warrant and a variety of put some real doubt in their minds." , ommendmg that the Georgta Power Co., the company memos, but also the entire He believes they did it in the begm. Southern Company and six individuals be transcript of the seemingly in. ning, and that they did it again when it l indicted on charges of defrauding the criminating taped conversations. counted most-in an unusual appear. United States government of tens of The pubhcity was personally hurtful ance in Washington at the very end. l i millions of dollars m tax revenues. to the mdividuals named, but the re. ! What had begun as an honest mistake had lease of the government's most damag. In The Beginning l grown into tax fraud and a criminal mg evidence so early m the probe en. It was a Wednesday evenmg m late j conspiracy and cover up, the government abled tne defense to spend a year and a summer when about 40 federal agents
- claimed. Evidence of employees hiding re. half poring over it and building a fanned out for searches and to serve l cords, of protecting higher.ups from prose. rebuttal. supbpoenas at Georgia Power head.
cution, of niing false information with the By the time the presentation in quarters, the home of a utihty omeial, ! 1RS had been carried in newspapers and on Washington opened-some 21 months and the omces of Arthur Andersen. television for a year and a half. The efter that press conference-the de- Suddenly. Troutman, Sanders lawyers Troutman team was eager to rebut them at fene lawyers knew the government's were getting calls from utility omcials ' last. in a forum that counted the most. case and were ready for it. The ques. reporting the searches: King &
- But'if only the utility compames' tio4 remained whether to present their Spalding was hearing from Andersen. - '
lawvers went to Washington, how c wn. and lawyers started calling the feds to e o u'l d the moet damaging King & Spalding answered with an nnd out what it was all about. evidence-taped conversations of e:n. immediate yes. The firm represents Troutman's Bryan B. Lavme reached ployees apparently conspiring-be ex. Arthur Andersen, which had advised the lead prosecutor in the case, Assist. plamed? Yet if lawyers for individual the utility on the tax practice in ques. ant U.S. Attorney Fagan. and got defendants appeared, would one per. tion. After an initial internal in. Flemmg on the line. too. Fagan told a son's defense implicate another vestigation persuaded them that their them it was all part of a crimmal tax ! potential defendant? Was there one client's tax position was reasonable. mvestigation into spare part account-l expianation that covered everythmg? Andersen's lawyers took eve y oppor- ing at Georgia Power. Troutmani mu3t And then there was the crimmal de. tumty to persuade the prosecution. imponant client. fense lawyer's natural reluctance to They were freer to do so, as the gov- "The issue was ident:0ed the St tell the government anythmg at all. ernment never told King & Spalding night." savs Flemmg. "I don't tnma it , Cenamly the dangers of over.exposmg that any ofits clients was on the target changed. ' one's evidence had been amply illus. list, it was also clear right o:T tne bat that l
this was going to require a lot of law- D
- yers. To avoid possible conflicts with the company's defense, Troutman ad.
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vised the individuals under subpoena *-
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1 yers although the utility company , , J94 would pay alllegal bills. v. .-- .Q, M 7. ' - C 3 4 Through most of the investigation, M j
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the utility defense team comprised % ;U e @. ~" - about a dozen lawyers. Working full .-
*tW ?. 7 time on the case for the Southern . . .. k , J INi:?;;f m Company and Georgia Power were .*
M. %,- Firming, Lavine, Roger S. Reigner Jr. n -.h4 AS M"F. ' . N
! end DeWitt Rogers. The lawyers for
-u *O _E.$NM MW.W~C individual empidyses er officials named in the probe were sole prac-t >
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m w titioners Robert J. Hi pie, Howard J. /'#' E/ .bh.: *IME Weintraub, Robert ff. Citronberg, rA %
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Steven W. Ludwick and Seth D. 1. . @ ? p C4 i l Kirschenbaum: Westby of Neely & v w/.g4 .. e 1 Player; Richard H. Sinkfield of Rogers 1
& Hardin; Bruce H. Morris of Fire.
stone, Cardon & Morris: Anthony L. sP[k W. M W h sff's y.
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E 0 1 Cochran and Nickolas P. Chilivis of ':%
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f Chilivis & Grindler; and others who i - 3 { rspresented witnesses or Southern
; Company a other subsidiaries. Worried about the prosecution, Robert J. Hipple organized meetings of We might ve gone overboard,,, defense lawyers, believing, "The steamroller was runniug, and we were all Flzming says now. But, ,It seemed like watchint, waiting for this to hit."
the right thing to do at the time." Likewise, Arthur Andersen had the came in the tape excerpts. A Southern warrant as not sufficient," he says. King & Spalding team: Bloom, Michael Company tax supervisor Timothy The government's documents can be
- C. Ruas, and David D. Willoughby, who Fallaw, instructed the informant a sealed only to protect the integrity of i brought in individual lawyers for the number of times to hide certain ac- the search, but no longer than that
- accounting employees identified as counting records, to take them home as "unless there is a very good reason the J possible suspects or witnesses. Fallaw said he had done. The tapes governnment can articulate," says It was on the Friday after the contained statements that senior util- Barr, who left the U.S. attorney's job Wednesday Aug. 24,1988, search that ity officials could be prosecuted for in February.
defense lawyers got their first, lying to the government if the truth Nevertheless, one of the Troutman extensive briefing on the probe in a about the spare parts came out. There lawyers began collecting newspaper
- five hour conference with Fagan in the was talk of ensuring that the spare clips and television news tapes of the
! U.S. attorney's office in the Richard B. parts issue be handled with "as little Georgia Power investigation. The Russell Building. evidence or exposure" as possible. collection-which included stories at-They learned a lot that day, but they The tapes contain such memorable tributed to unnamed federa1 j were about to learn a lot more, along quotes as this from Fallaw: "I mean if sources-would later be presented to i with the rest of the public. The following the IRS comes in, I mean, you're dead." Washington as part of the effort to Tuesday, stacks of documents the gov- The press conference and the release discredit the prosecution. It was an i ernment had corapiled to support the of so much inflammatory evidence ironic role for the Troutman lawyer in search warrants were unwealed, and enraged the defense team. "The gov- charge of the task DeWitt Rogers, Barr held a press conference to reveal ernment allowed the perception, if not former city editor of The Atlanta Con-their contents. Aniong the reams of created the perception, that all these statution. l papers were a 33-page affidavit from IRS people were engaged in wrongdoing," Yet as damaging as it was to reputa-4 Special Agent Arthur D. McGovern Jr., says Morrts, who represents Gary an affidavit from an unadentified tions, the release was a boon to build-Givens, corporate tax manager at ing the defense. "Normally we would
- Georgia Power employee who had been Georgia Power. "For two years, there been acting as a government informant; was no way to respond." never have had those tapes or tran-several company memos; and hundreds scripts until after arraignment," says
- Barr defends the release not only on Weintraub, a former federal prosecutor
~.
! of pages of transcripts of taped conver- legal grounds, but also for fairness , sat 2ons the informant had had with key reasons. "It surprises me the talk de- who represented one of the tax super-uuhiy employees. visors at Georgia Power. "You don't i fense lawyers take sometimes. I suP- have time to do that after an in-j It looked like compellmg evidence. pose they would rather have the search , McGovern was unequivocable: The conducted (with the utility] left hang. dictment comes down," he says.
" Southern Company and its ing out there with all sorts of pregnant The release of the full transcripts al-l lowed the defense to put the excerpted subadiaries got together and conspired implications. I think we had an i
to hide from the IRS the fact that they obhgation to explain what the search remarks into context. Hipple, who rep- , had expensed an enormous amount of was, and most importantly, what it was resented Fallaw, mamtains that when l spere parts which should have been not. There was a great deal of heard in their entirety, the seemingly inventoried." By the end of 1985, damning snippets take on a different, i confusion" at the time, he says. more innocent meaning. f McGovern wrote, " Georgia Power What's more, the government must company had fraudulently expenned The defense learned another thing j show probable cause for a search, Barr from Barr's press conference. Given the over $56,000:000 m spare parts ..." notes. "If you don't disclose enough, But the most damagmg revelations the defense will attack the search intense publicity the story had
i generated and ths mzssivs amounts of aweit an emergency. That's because to times they went to other lawyeri con-money involved, "We knew we were in operste safely, power plants must be ference rooms. They traded mforma-a for a long haul," says Weintraub, equipped for emergencies. tion, organized into committees to Westby uses the analogy of a spare handle specific legal issues, and they . What it's All About tire. It is simply not safe to drive exchanged ideas on strategy. Tax law on emergency spare parts around without one, so it is in use even The lawyers signed a joint defense accounting for public utility companies when it's idle in the trunk. agreement that allowed each of them to is not the sort of thing that most crim. As for the seemingly sinister " memo give his client's version of events inal defense lawyers happen to know. accounting" system, it was simply a without worrying that the information Not even the tax specialists in the de. way to track the different kinds of would be used against that client. fanse team knew the terrain intimately parts so that the utility could pay One of the first meetings was purely
- educational, with the Troutman and
- at first. It wasn't easy learning it. proper taxes, the defense asserts.
l The Troutman lawyers called on But if everything was on the up and- King & Spalding tax experts explain- , experta around the country and dug up, why was there all that talk about ing what they had learned about the into accounting books, law books and secreting files away on personal accounting and tax issues. The lesson revenue rulings. They even took an oc- computer disks and removing them came complete with a slide show, casional field trip to a power plant. from the premises? which was the first time some of the "It was so complicated," says Hipple, who representa Fallaw, the lawyers had seen a spare part for a ] Westby, "The first six months was man who made some of the most apc power plant. 4 spent trying to figure out how much of parently incriminating statementa, it was not until these sessions, some
- the allegations in the 35-page affidavit says his client merely meant to of the lawyers say, that they fully un-l was true legally or factually." emphasize that the IRS is not entitled derstood the issues.
to see everything ever written. Fallaw, By the close of 1989, the meetings i
- The lawyers m. terviewed their clients who hardly knew the informant, was I
- cxtensively and studied the hundreds trying to stress that "you don't leave of documents the government subpoe- things lying around." i n ed. For example, "you don't have a file At issue was the power company's that says, ' Tax planning for 1985' '
- tax treatment of spare parts for power (containing a debate whether) this is
! pl:nta. The controversy had its start in the right way or that is the right way. D $
1982 when the utility realized that it It's a blueprint for an audit," says wpI 1 e w s impri,per to do what it had been m ; gj ppg ,' doing, which was to claim the parts as Yet, time and time again, Fallaw expensen and deduct them at the time urged the informant to take documents f a
~
l of purchase. The IRS says the , utility home, insisting that he had done no, l can expense the part at the time of lummelf l 4 purchase only if it is immediately put ..No one really has an explanation for , to use. Otherwise, the ,part is put,into that, other than there was a lot of I
- inventory and se depreciated over time. macho talk," says Bloom. He notes that
- So utility officials won permission no documents were found in Fallaw's from the IRS to change the accounting home, which was searched at the same mrthod to the proper way, and to take time as the first search of the power i 10 years to pay the tax difference for company. And company officials say all I what had already occurred. of the papers detailing the spare parts But, as McGovern alleged accounting practices were found at the
- davit, the government beh,in eved huthatafh.-
company. power company offietals were only ! correcting part of the problem and weio lying about the rest of it. McGovern Getting Organized Bruce H. Morria, representing a asid that while the utility inventoried While the Troutman lawyers seemed utility employee, says the a lot of its spare paits, it hid many to be constantly responding to subpoe. investigation was too public, i millions of dollars worth, concocting a nas (Fleming estimates 500 were l secret, dual accounting system to issued during the course of the in- had become weekly events. It was aim 4 accomplish the scheme. vestigation). Hipple decided it was time about that time that Fagan informed . From the ::nvernment's evidence, i, t rganize the defense team. While the defense lawyers that he was rec. acemed an clear cut. As Westhy put it, there were a lot of telephone conversa- ommending that ex utility employees, i " Art McGov*rn <nys, Tm an exp. rt. tions about documents and other pieces the Southern Company and Georgia ~ i and he says ymi ran't du it thii, way . of information, each of the lawyers Power be indicted. The Justice De. representing individuals seemed to be He said it wau obviomly wrong: 1.ow partment inviteit the lawyers her tho-e
.culd st be right?" oft on his own while the prosecution particular defendants to inme to The answer, Ihe defenu may=. he, in seemed to be gaimng steam. Washington if they wish, and to take an the difference hetwren emergencv "At some point," says Hipple, "it be- much time as thev nevil to lay out their spare parts and parts bought fo'r came particularly evident the gov- case.
l normal maintenance. The utility in. ernment was really going to proceed For the lawyers who were represent. with this. The steamroller was ru n.
- sists that while maintenance spare ing others who had been imphcated in parts must be inventoried unless they mng, and we were all watching. wait- the scheme, the narrowing of the target l ing for this to hit.
i .tre immediately put into service,apare list meant that their chcots had ectten S Hipple called together a meetinM oft the hook. For the re .t. the question l parts are ditferent An emergency of. the defense lawyers in what was to i spare part is "in use" when it is was whether to go to Wa r.h i ngton. bought, even af it m put on the shelf to become a (muent,nent. Lsually they Fagan kept assuring the crinunal de. met at Troutman s otFices. but some- fense lawyers that they would get a
i l 1 1 1 full, objective hearing. So did the tax ! lawyers in the group. based on their experience with the review process in . !' the criminal section of the tax division. % p /eg3 r. [ ' ' ' *" . Still, "I wasn't so sure." says Westby, J. reflecting a common sentiment among the criminal defense lawyers in the 1 ' g ) } group. A%, .s ksg l Westby believed he had a great de. er , Dj g d fense, because he could show .- y l 3 , .y
! unequivocably that his client Dean y g, 34 ; p p ,l I i
1 Hudson, Southern Company's comp-troller and vice president for taxes, had
;.. . . e.g
,g l i
j had nothing at all to do with emer. 1 gency spare parts during the time that . 7h,.-. 7 ;~4 ,;;,.,[_ - ! ) 1 investigators were probing. He be. ,
,.,'"*. ~'
i lleved the government did not realize %. '
*~
j Hudson was out of the city during ' much of the time.
~
+ But should he show his hand? . 6 l' Meanwhile, the Troutman lawyers F were making'it clear that they were headed for Washington, so there were lots of discussions within the defense ' i team about what strategy they would f .~ 1 take. I , j i Representing the corporate defend. . l anta, Troutman would hit hardest on e the underlying tax issue and on trae j accounting system. If the lawyers could , persuade the Justice Department that . l the utility's tax theory was correct-or Former U.S. Attorney Robert L. Barr Jr. says, in retrospect, he would do d8 n bi th perhaps nothing differently in the Georgia Power tax investigation. } llThen, "9 [))8 dg too, there were the incidents of
,illeged prcucutorial misconduct, such the tax division assigned to the case:
.a the use of a paid government in. and Charles Tamuleviz, a staff # "
formant and, of course, Barr's dealings attorney in the criminal section of the . u- % l with the press. The most difficult problem tvas ex. tax division. On Thursday and Friday, ending
** y O
' plaming those tapes. And although the Monday, Jan. 30, they argued and they i Troutman team could, and did, address answered questions. Some came away ~4 , them those were issues more fitting for optimistic, while others say they could ' S the individual defendants, not read the result. -
.J At first, the individuals' defense For Westby, the trip was worthwhile.
lawyers all decided to let Troutman do He believed that he had brought the 3 - the talking. In fact, some were pri. government exculpatory news about , *- % C. [' ' yi / vately concerned about whether even his client t!'at they did not know. - the utility's lawyers should go. But Then, on Tuesday, another session ' eventually, some of the lawyers for the took place that was not the normal sort Num" we I mdividual defendants decided they had of Justice Department criminal tax ,,4 ' something to say that the Justice De. review. At Huggard's invitation,
- i partment should hear. Andersen's lawyers at King & 2-57i
- Spalding made a special appearance.
~
< ~M l The, Big Pitch Bloom, Russ and Willoughby, joined by With the end of the investigation
- The presentation was set to begin on Andersen general counsel Donald came a prese conference by Georgia j Thursday, Jan. 25, 1990. Just three Dreyfus, met for two and a half hours PowerChairman A.W.Dahlberg.
~
, days before that, on Monday, Westby with Huggari and a lawyer one level decided he would go. In the end, law. higher, Ralph Belter, a tax technician. possible defendant, Justice could invite l yers for three of the six individuals Under the criminal tax procedures, the accounting firm's lawyers. appeared, Westby, Sinkfield and Belter would review the U.S. And who would better understand Hipple. attorney's argument for prosecution :he utility's tax and accounting And so, in nondescript, government and send it up the line through two :heories than the lawyers for the com. ! ofrices on the fourth floor of the main more levels before the final decision ;any's tax preparer, whose advice tne j Justice Department building, lawyers would be made by Assistant Attorney mility had been following? "We were , for the accused spent three days taking Genera 1 Shirley D. Peterson. .nvited by Justice to explain the tax turns arguing their clients' innocence Nonnally, Belter would not sit in on a -heory of the case to them." savs ! to three Justice Department lawyers: presentation, and normally only law. Bloom. "We came up as a friend of t'he i Fagan, who was there merely as an yers with clients facing prosecution iepartment.' is the way it was de.
- observer
- Stephen Huggard, the would appear. But precisely because scribed to us."
l, Washington-based trial lawyer that Andersen was out of the picture as a The Andersen lawyers were happy to i l ! a
. . . _ _ - , _ . -- - - . - - - . . - _ ~ _ - . - . . - - . .- .e .
3-I l *. accept. For although the accounting eihr hear of an indictawns or hear 4 firm was no longer considered a nothing at all. But Rukstele says that l potential defendant, "it was their as public as the case had been, he ' i client-Georgia Power-who was at figured in this instance it was the right risk," says Bloom. Arthur Andersen thing to notify the defense.
"obviously had an interest in the out. Nowit was time for the utility to hold 3
come and were more than willing to ' a press conference. Georgia Power Co.
;' present their position through us to the President A. W. Dahlberg did the ,
1 Justice Department." ' honors,withhisF ' _ , Bobert W. ! ! Bloom says the idea had come firem Scherer.looking on. l Huggard, who had =mi=*=ined to the " l As for the =."I h !' defenselawyers allalon
- decision," says Fagan. He only
- was open. The r========g that
=I-+4= to seek his mind add, "When you have a jury t-lal and it .
- l indictment had come than the IRS and comes out against yea,p say, 'I ac.
1 thun Fagan, not than Huggard. And all T 9l _, e decamon ' ' ! aleeg, Bloons and Russ had been press. Barr says,"As faras the case before I
- ing their of the case to Fagan lea. I wouldn't de differently.
4 and Huggard, laying rapport and, We were plug with a very i he believes, credibility. daiReult case.' ping
. - k. '
1 "After we Manahad our conference in "There was always a very sound 4 Washington, we abit quite clearly that basis for conducting the criminal in. Belter had heard and clearly under. vestigation," he says. In fact, the tax [ stood the tax position-and agreed with probe 1ed to reIa)ed utility in. it," says Bloom. . vestigations, one of which brought a l Whether it was Belter or another of. guilty plea from Southern suh-ha y j fleial up the line, someone in a Gulf Power Co. to charges of allegal '!
- position of authority in Justsee either campaign contributions. Too, the util.
agreed with the defense's position or at ity is still open to civil praa anlings on least figured a jury wouldn't disagree the spare parts tasus. i with it. While not ~.- - - -*N on the reason ] i On Friday, May 18, the U.S. for the decision not to prosecute, Barr , 4 attorney's ofBee in Atlanta heard ein. nonetheless notes that juries onen ac. : ' cially what it had been hearing quit when the issues are i r'- 'ly l unamei=Ily for some weeks. Nix to the comples and where defense lawyees are i prosecutaca. A week later, on the Fri. able to make thans appear to se even i day before the long Memorial Day more i
' weekend interim U S Attorney
, .. But ove'r at King & Spalding, Russ i p1===*== " Ray" Rukstele called b notes that complexity is not what !
defense lawyere to tell theen tLe news. killed the prosecution. says Russ, "The i l He wee under no obligation th do so, uncertainty of the suhetantive tax ; i and b lawyers assumed thof would issue ulthmately was the death knell of 1 , the case." O j ! l i I i i l 1 1 i j 9 A 6
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Georgia power has made an additional Material false statement in written correspondence to the NRC in L1censee Event Report 90-006 submitted 4-19-90.It 1s similar to the Material false statement made on 4-09-90 and involves the claims of successful starts without problems on Vogtle's Diesel generators that failed during the Site-Area Emergency of 3-20-90. On page 5 under item D it states " Numerous sensor calibrations (including jacket water temperatures),special pneumatic leak testing.and mult1ple 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, DG1A and DG1B have been started at least 18 times each and no fa11ures or problems have occurred during any of these starts.In addition, an undervoltage start test without air roll was conducted on 4-6-90 and DGIA started and loaded properly.' The above statement regarding the number of successful starts without" failures or problems" subsequent to the control systems comprehens1ve test program is materially false by ommission or commission.The 18 diesel control log 1c testing was completed on 3-27-90 just prior to performing the first undervoltage test at 22:04 CST on 3-27-90 and prior to declaring the diesel operable at 15:27 CST on 3 90. Completion of this testing, is the earliest point in time that a claim of completing a comprehensive control systems test program could be made.Subsecuent to that date and time i until 4-19-90 DG1B has been started only 11 times. The 1A diesel control logic testing was completed on 3-31-90 Just prior to performing the first undervoltage test at 22:53 CST on 3-31-90 and prior to declaring the diesel operable at 11:54 CST on 4-01-90. Completion of this testing is the earliest point in time that a claim of completing a comprehensive control systems test program could be I made. Subsequent to that date and time until 4-19-90, DG1A has also been started only 11 t1mes. This material false statement is similar to the one made by j Georgia power on 4-9-90 in correspondence ELV-01516 and again falsely overstates the extent of reliable starting experience with DG1B and DG1A. Concern was ralsed by plant staff on 4-18-90 with the SONOPCO Licensing Engineer,the SONOPC0 Licensing Manager,the SONOPCO General Manager Plant Support,the Vogtle General Manager,the SONOPCO V1ce President Vogtle,and the SONOPCO Senior Vice President Nuclear as to the accuracy of the Diesel start information and the fact that there had been "fa11ure ano problems" l l
pr1or to submittal of the LER.SONOPCO was pressed for time and issued the LER without adeauate verification and in the face of concerns for the accuracy of the information raised by the site.The 1ssue of the accuracy of corresoondence ELV-01516 including specific failure information was raised by ' site personnel on the phone call with the above personnel at , the same time. On 4-30-90 the Vogtle General Manager was provided a memo with start data on the DGIB ,derrived from control logs, shift supervisor logs and source diesel operating logs,that , clearly showed that previous statements made to the NRC were false.He took no immediate action anc ask for the information to be validated by operations and engineering.The information was validated on 5-1-90 and found correct.It was presented again to the General Manager on 5-2-90 and in this presentation it was stated that statements on both diesels 1A and IB were Incorrect in the
'LER and that the letter ELV-01516 was wrong as well.St111 he took no action to promptly inform the NRC of the false
- statement and suggested that a revision to the LER be prepared. He also suggested that the letter ELV-01516 be corrected by including a correction in the letter being prepared for submittal to the NRC on 5-15-90.
The General Manager did not follow up on the progress of these revision actions or set any time table for , completion.as he normally would on important issues. A revision was made to the LER and approved by the PRB ! on 5-8-90.Cn 5-10-90 the PRB reviewed the 5-15-90 letter ! (actually submitted on May 14)to the NRC.It had nothing that 6,ddressed or corrected the material false statement as , previously suggested by the General Manager.SONOPCO and the
- General Manager were heavily involved in writing , editing and specifying the contents of the May 15 letter.The PRB made a comment on the fact that the letter did not address the material false statement and assigned the General Manager an action 1 tem to resolve that.
? After the General manager saw the action item nis secretary came to the PRB secretary's office and said "Doesn't NSAC have anything better to do than assign the General Manager action items". Later on 5-24-90 the general Manager signed the action item off as complete and attached a note instruting the Technical Support Manager to use the LER cover letter to correct the other incorrect document.SONOPCO most always drafts the cover letters, not the Technical Manager. i On 5-11-90 the PRB met again with the General Manager to approve the " final" version of the May 15 letter to be sent to the Senior Vice President SONOPCO for signature.Again no correction had been made and the. previous material false statement was not addressed.The " final" version was approved.The individual that had raised the issue of the l material false statements had been removed from the PRB by a j l
)
1 __--. ____ _ _ _I
d ! memo from the General Manager (NOTS-00382) dated 5-10-90 and i effective 5-11-90. ! By May 15 the revised LER was with SONOPCO.No action ' occurred to submitt the LER to the NRC until about the first week in June when again site personnel began asking SONOPCO about what was taking so long to submit the correction.SONOPCO licensing personnel told site personnel that the Senior Vice President Nuclear planned to sign the revision on June 8 (the day of the IIT presentation to the Commission on the Vogtle Site-Area emergency). On June 8.11 and 12 an extrordinary number of meetings and telephone calls occurred over the D1esel start information. Quality assurance was directed by the Senior Vice President , to audit all of the Diesel start logs.When this was completed ,no errors were found in the information that had been presented to the General Manager over a month before on , 4-30-90.With th1s done the Senior Vice President ask for a complete rswrite and updating of the LER.This was begun and is in progress with expected completion 6-22-90. r
.l 1
l j J I l l
\
l l 1 a
)
Georgia power has made an acc1:1cnal Material false j statement in written correspondence to the NRC in Licensee Event Reoort 30-006 submitted 4 *3-30.It is stwilar to the Material. false statement mace on 4-09-90 and in.cives the claims of successful starts without problems on vog:le's D1esel generators that failed during the S1te-Area Emergenc, of 3-20-90. On page S under item O it states ' Numerous sensor cal.1brations(including Jacket water temperatures) special pneumatic leah testing and mult1ple engine starts and runs were per'ormed ut the 3-20-90 event,the contro 7.pg been subjected to a c: g / ,, fouent to this test program. OG at least 18 curred dur1rg times eacn and n any c# tnese sta witnest air roll hg hy ' ge start test G1A started f and 1:acec prope
?b (N f t The aco e staterr . ! Vf ( l0v sccessfu' I starts without" control systems hpg g -
p6 int to the mater 1al1y 7 fa'se by ommissi - control log c testing was comt c lh 4{ ( a diftass > cerform:ng , tne f$rst unders 7 27-90 anc prior to declar- % < !? CST on 3 90. Completion oi *4'#M A t point in time
- that a claim of 9 trol s, stems test program coi h g g8, date and time until 4-19-90, '
'.>. .imes.
Tna 1A diesel c he *M N eted on 2-31-3C ge test at de%/ fdf045, Jtat prior to p 22:52 C3T on 3- he ciesel operaole at 11: -- ,c f .his testing is the earliest *comoleting a comprehensive c fjj suld De made.Subsecuent r u fi .-19-90, CG1A has also been s
.This material false statement is s1minar uv che one made bf Georgia power on 4-9-90 in correspondence ELV-01516 and again falsely overstates the extent of rel1able start 1ng expertence with DG1B and DG1 A. Concern was raised by p' ant staff on 4-18-90 w1th the SONOPCO Licensing Engineer,the SONCPCO L1eensing Manager,the SONOPCO Genera 1 Manager P1an.
Support,the Vogtle General Manager,the SONOPCO vice President'Vogtle and the SONOPCO Senior Vice Fres1 dent Nuclear as to the accuracy cf the Diesel start information and the fact that there had been "fallure and problems" e I , l
/2.'. % c
Georgia power has made an accit1cnal Material false statement in written correspondence to the NRC in Licensee Event Report 30-006 submitted 4-19-90.It is sin 11ar to the Material false statement maoe on 4-09-90 and invcives the claims of suc;essful starts without proolems or. Vog:le's Diesel generators that failed during the $1te-Area Emergenc, of 3-20-90. On page 5 under item D it states ' Numerous sensor calibrationr.t'ncluding jacket water temperatures).special pneumat1C leak test 1ng,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 to this subjected to a comprehensive test program.Subseouent test program, DG1A and DG1B nave been started at least 18 times each and no failures or problems have occurred during an undervoltage start test any of tnese starts.In add 1 tion, without air roll was conducted on 4-6-90 and DG1A started and Icaceo properly. The above statement regaroing the number of successful starts without" failures or problems" subsequent to the control systems comprehens1ve test program 1s materially false by ommission or comm1ssion.The 18 diesel control logic testing was completec on 3-27-90 just crior to perform:ng the first under.oltage test at 22:04 CST on 3-27-90 and prior to declaring the diesel operable at 15:27 CS* on 2 90. Completion of this testing, 1s the earliest point in time that a cla1m of completing a comprehensive control systems test program coulc be made. Subsequent to that date and time until 4-19-90. DG1B has been started only 11 times. The 1A diesel control logic testing was completed on 2-31-9C at just prior to performing the first undervoltage test 22:53 CST on 3-31-90 and prior to declaring the c1esel operable at 11: 54 CST on 4-01-90. Comclet1on of this testing is the ear 11est po1nt in time that a claim of completing a comprehensive control systems test program could be made.Subsecuent to that date and time until 4-19-90, CGiA has also been started only 11 times. Th's material false statement is similar to the one made b f Gec.gla power on 4-9-90 in correspondence ELV-01E*6 and again falsely overstata= the extent of reliable starting experience with DG1B and DG1A. Concern was raised b) p'3nt staff on 4-18-90 with the SONOPCC Licensing Engineer.the SONOPCO Licensing Manager,the SONOPCO General Manager Plant Support,the Vogtle General Manager.the SONOPCO Vice President Vogtle,and the SONOPCO Senior Vice President Nuclear as to the accuracy of the Diesel start information and the fact that there had been "fallure and problems' L
prior to submittal of One LER.SONOPCC was pressed for time a and issued the LER without adequate verification anc 1r. the face of concerns for the accuracy of the information raised by the site.The issue cf tree accuracy of corresponcence ELV-01516 incivaing specific failure infcrmation was raised by site personnel on the phone call with the above cersonnel at the same time. On 4-30-90 the Vogtle General Manager was provided a memc with start cata on the DG1B .cerrived from control legs, shift supervisor logs ano source diesel operating logs.that clearly showed that previous statements made to the NRC were false.He took no immed1 ate action and ask for the informat1on to be validated by operations and engineering.The information was validated on 5-1-90 and found correct.It was presented again to the General Manager on 5-2-90 and in this oresentation it was stated that statements on both diesels 1A and 1B were incorrect 1n the LER and that the letter ELV-01516 was wrong as well.Still he took n3 action to promptly Inform the NRC of the false statement ano suggested that a revision to the .ER De prepared. He also suggested that the letter i ELV-01516 be corrected by including a correction in tr.e letter being prepared for submittal to the NRC on 5-15-30. The General Manager dia not follow up on the progress of these revision actions or set any time taole for completion as he normally would on important issues. A revision was made to the LER and approved by the PRE on 5-8-90.On 5-10-90 the PRB reviewed the 5-15-90 letter (actually submitted on May 14)to the NRC.It had nothing that addressed or corrected the material false statement as previously suggested by the General Manager.SONOPCO and the General Manager were heavily involved in writing . edit ng and specifying the centents of the May 15 letter.The PRB l made.a comment on the fact that the letter d1d not address l the material false statement and assigned the General Manager an action item to resolve that. After the General manager saw the act1on item his secretary came to the PRB secretary's office and said "Doesn't NSAC have anything better to do than assign the General Manager action items". Later on 5-24-90 the general Manager signed the a;;1..n item off as complete and attached a note instruting the 'ecnnical Support Manager to use the LER cover letter to correct the other incorrect document.SONOPCO most. always drafts the cover letters, not the Techn1 cal Manager. On 5-11-90 the PRB met aga1n with the General Manager to approve the 'ftnal' version of the May 15 letter to be-sent to the Senior Vice President SONOPCO for signature.Again no correction had been made and the previous material false statement was not addressed.The " final" version was approved.The individual that had raised tne issue of the material false statemen s had been removed from the PRB by a
memo frcm the General ManagertNOTS-00382) datec 5-10-30 anc
,. effective 5-11-90.
By May 15 the rev1 sed LER was w1th SONOPCO.No action occurred to submitt the LER to the NRC until about the first week in June when again site personnel began asking SONOPCO about wnat was taking so long to submit the correction.SONCPCO licensing perscnnel told site personr.el tnat the Senior vice Presicent Nuclear planned to sign the ! revision on June 8 (the day of the IIT presentation to One Commission on the vogtle $1te-Area emergency). ! Cn June 8.11 and 12 an extrorcinary number of meet'ngs anc telephone calls occurred over the Diesel start information. l Quality assurance was directec by the Senior vit a President to avait all of the D1esel start logs.When tnis .vas completed ,no errors were founo in the information that had ) been presented to the General Manager over a month tefore cn : 4-30-90.With this done the Senior vice Pres 1 dent ask for 2 complete revision' and upcating of the LER.This was done and a revised LER was PRB aooroved by 6-22-9Ql3n!/ 3 of 3 "6 ages neecea any rewrite on tne ' complete revision".A ) complete revisicn nad or191nally not been planec until 6 4 montns after tne event. V j The ' complete rev is tor, LER switches the counting and 9 recorting of Diesel generator starts and failures to val d" g4 starts and failures per Reg Guide 1.108.By doing so N correlation Detween the previous LER can not be made without detailed ano speci f ic cata on each start.While the or19:qa1 ' LER was being drafted it was suggested that we might want tc sq use '.alid starts and failures' but that method was 4 discountea because it was recognized that we haa very few g valid tests.If tne original LER were stated in terms of valid starts we could only say 'Subsecuent to this test kg program the CG 1A and CG 18 have had 6 valid starts without $ problems or failures k* l Cn 6-23-90 and 6-29-90 a total of 6 cover letters to be sent in with tne LER revision were originated anc propCse3 1 oy SONOPCO.Each 1s different and attempts to expla n ne l Material False statement in a different manner: DRAFT 07:51 6-28-90 Th15 draft says that all tests were counted but only valid failures were censidered in reaching a conclusion tnere were no problems or failures. 08:55 6-23-90 This draft says that all tests were counted regarcless of wnether they were valid or not. l l' 07 55 6-29-90 This draft says that the COA response letter used the words "Sunsecuent to Y 3 ! l i
e *
- the event' and that tne LER Inadvertently used the worcs h
'Subsecuent to the test program" l but snould have been cons 1 stent l with the COA response letter and 8 the verbal presentation In Atlanta.
1*: 42 6 '3-90 Th1s draft says the LER statement
. didn't consider failures and oroolems ,
associated with troubleshoot 1ng anc l l restarting the Diesel and should have ' i been ' Subsequent to the event" which 15 consistent with the COA response l and the verbal presentation. i* ( l 12:06 6-29-90 This draft says that 'If the comprehensive test program completec with the first Surveillance 14980-1 , than there were 10 successful starts j on DGIA and 12 on DG1B as of 4 *9-90. ! 13: 11 6-29-90 This draft says that 'If the r I comorehensive test program comoletec with the first Surve111ance 14980-1 ) then there were 10 successful starts on DGIA and 12 on DG18.It also says that test program starts were inciuces 4 in the original count and tnat was cae to poor record keeping oractices anc g no def1nition of the end of the test % program. These explainations are all untrue ar.d are being concocted
- after the fact without regard to.how anc why the errors ere actually made.In short these are l ies and an atemot tc coveruo the careless personnel e:rors made by the coeratic,s
- superintencent and General Manager wnich originated in the vprDal oresentation.were repeated in tne
- CA resconse letter and were carelessly restated in the LER.
A look at the Diesel generators starting anc failure hist:rf after the LER was written on 4-18-90 provides a technical as well as a objective view of the reliability of' the diesels which is at the heart of the Material False Statement. D1esel Generator 1B DATE TIME RESULT r ! 04-19-90 03: 14 Diesel was inadvertently started \ 1
due to persor.nel error in perfcrming
- Surveillance 14619-1 f 04-19-90 09:55 Successful start f 04-29-90 09:09 Successful start 05-23-90 12:26 Diesel Tripped after start 05-23-90 13:10 Diesel tripped after start 05-23-90 14: 12 Successful start manual trip 05-23-90 14:45 Successful start manua: trio 05-23-90 21:18 Diesel trioped after start on 1:w l turco lube oil pressure 1 05-23-90 21: 38 Diesel tripped after start on low l turbo lube oil pressure j 05-23-90 21:57 Diesel tripoed after start on icw )
turbo lube oil pressure 1 05-23-90 22:55 Diesel tripped after start on H1 l Jacket water temperature l 05-23-90 23:37 D1esel tripped after start on H1 l l Jacket water temperature 05-24-90 12:29 Successful start l 05-24-90 12: 42 Successful start ; 05-24-90 12:53 Successful start I 05-24-90 13: 10 Successful start ; 1 05-24-90 15:19 Successful start ; 05-24-90 15:30 Successful start 05-24-90 19:16 Successful start 05-26-90 20:28 Successful start 06-01-90 11:45 Successful start k Clearl f this diesel generator continued to e perience an 4 excessive rate of trips and failures most of which were the same kind of failure that led to tne station blackout at b i mid-loop that occurred on 3-20-90. Clearly this diesel was ' l l not reliable as the COA response letter and the LER tried to I j convey.As further proof of the unreliability Georgia Power ] had to initiate a design change to remove scme cf the . unreliable components from the control logic after l 4 experiencing all the additional failures. ,
- Considering the evidence
*The words are false in counting the starts.
.They overstate the rellability of the diesel. l
.They were used by NRC to make dec1sions S i g n 1 f 1 c ar,t to the Regulatory Process" (To allow Restart) i aConcern was raised about the accuracy of tne start data before submittal of LER. !
- SONOPCO personnell ' recogni zed that the previous ( CCA !
startements were false before submittal of the LER. j . Factual data was presented discuting the data after ! submittal and stating that information prov1oed to NRC was l l incorrect. '
.Substant1al delays occurred in starting to correct tne LER. '
- Additional delays were introduceo after beginning correction (QA audit). ,
I l
e e Revisions were delayed ur.t11 after crit 1 cal meetings oitn k V NRC 16-08-90 IIT presentation to Ccmmissioners)
. Additional unplanned delays were introduced (ccmolete revision) after QA audit substa1ntated Inaccuracy claim.
. Multiplicity of revision letters (also f alse i to explain tne mistake. g
.Sucmittal to AEOD by LER revision to correct multiple ron- A LER errors. %
. Performance of the Diesel itself proves the unreliability anc tne falseness of the statements given tc tne NRC. hg
.Above actions did not proceed without repeated and centinuing expression of concern from tne plant employee wno exposed the Material False 5tatement .
cne can only conclude that G.eorgia Power dio inceed make Material False Statements in written correspondence to the NRC dye y? as, a minimu,m c.areless disrega,rd, anc willf ul y N, conspired to delay.,and, cover _up_the disclosure of those false statements. i z
i interoffice Correspondence . Georgia Power d June 29, 1990 Memo To: George Bockhold, Jr. - General Manager Nuclear Plant-Vogtle
Subject:
Vogtle Electric Generat hg Plant - Units 1 & 2 Special OA Audit of Unit 1 Emergency Diesel Generator Starts - OP26-90/33 File: X78G17-P-OP26 4 Log No: VSAER-90-159 Audit Stone: This narrow-scoped audit was conducted at the request of the l Mana ;er Safety Audit and Engineering Review. Its purpose was to investigate the records of the Vogtle Electric Generating Plant Unit 1 Emergency Diesel Generators (EDG's) starts conducted in response to the failure of EDG 1A ca March 20, 1990. This audit reviewed test data sheets generated during i troubleshooting / maintenance testing and surveillance testing as well as the ' Unit 1 Shif t Supervisor's Log and the Diesel Start Log maintained by the diesel generator system engineer. Summary of Problems Found: ! o No procedural noncompliances were identified. However, the number of Unit i' 1A and 18 successful diesel starts (18) identified in License Event Report (LER) 424/90-06 subseauent to comoletion of the test
- nrocram was determined to be incorrect. The correct' numbers should have been 10 and i
12, respectively, using the guidance of the LER. Evaluation: The Diesel Generator Start Log was found to be substantially i ' behind with regard to entries and diesel start evaluations. Substantial delays were found in processing information on diesel start attempts from the Control Room to the diesel system engineer. When combined, these items ' prevented having a single source document readily availa' o le that reflected diesel starts and valid tests. The current methodology should be reviewed and j revised to remove these problems. Action: None required. M g G. R. Frederick Supervisor - SAER NCM/GRF/btp
I I
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Special QA Audit of Unit 1 Emergency ! Diesel Generator Starts - OP26-90/33 Page 2 j ; I l
' Attachments xc: R. P. Mcdonald H. G. Hairston, III C. K. McCoy M. J. Aj1 uni i M. E. Mundy NORMS . !
C. T. Davis . G. A. McCarley J J. G. Aufdenkampe, Jr. O. A. File ' N. M. Norton J.'E. Swartzwelder 4 1 I f I 4
]
- i l, PLANT
' Plant Vogtle - Units 1 & 2 ACTIVITY i Special QA Audit of Unit 1 Emergency Diesel Generator Starts i
AUDIT NO. ! . OP26-90/33 , DATES AUDITED June 11 through 29, 1990 (non-continuous) l 1 AUDITORS ! N. C. Moseley, Jr., Senior 0A Engineer (Audit Team Leader) ! 1 G. R. Frederick, Supervisor - SAER , PRE-AUDIT POST-AUDIT CONTACTS CONFERENCE &LlDil CONFERENCE l T. V. Greene x N. F. Kitchens x l P. H. Drawdy x
- M. T. Pearce x
- D. O. Vickery x
- S. A. Lockhart x
- F. P. Sharkey x
- l. REFERENCES PROCEDURE REVISION DESCRIP*.IQti 13145-1 21 Diesel Generators 14980-1 19 Diesel Generator Operability Test
- 55038-C 1 Diesel Stcrt Log 4
PURPOSE / SCOPE The purpose of this narrow-scoped audit, conducted at the request of management, was to verify the testing of the Unit 1 Emergency Diesel t Generators, (EDG. The s,cepe, of the- audit, covered. the testtag.~ conducted subsequent to the test program performed in response to the failure of EDG 1A to start on March 20, 1990. The audit consisted of reviewing the test data sheets (surveillance and troubleshooting / maintenance), the Shift Supervisor's Log and the Diesel Start Log maintained by the diesel generator engineer. The information obtained from these sources was correlated and compared for consfstency.
~
EVALUATION 2
.The results of this audit indicate that the tracking of Emergency Diesel Generator starts has - been effective within the scope of the audited areas.
The problems noted appear to be the result of slow processing of the test data sheets. 4 l
- 1. I Sr.ecial 04 Audit of Unit 1 Emergency Diesel Generator Starts - OP26-90/33
- Page 2
] AUDIT DETAILE I. Shift Supervisor's Log i j A. Requirement VEGP Procedure 13145-1 requires that all start attempts be logged
- in the Unit Shift Supervisor's or the Unit Unit Control Logbook and include the following information: Start time, reason for start,
) and success or failure of the start attempt. B. ~ Results ! The Unit 1 Shift Supervisor's (S/S) Log was reviewed for the time i period March 20 through June 12, 1990. All entries that identified l the starting (automatic or planned) of either EDG 1A or IB were
- noted. The level of detail recorded in the S/S Log book varied.
1 For some EDG starts the start and stop times were logged as well as a notation as to the results (successful, failure, valid, non-valid, tripped, etc.). For other starts, the only notation was that a surveillance test had been authorized or that a surveillance t task sheet had been reviewed and determined to be satisfactory. l Comparison with the other sources of information (test data sheets and Diesel Start Log) determined that in addition to some entries , not being complete as noted above, not all EDG starts had been ' i logged in the S/S Log. (See Attachments A & B for comparison data). As the other sources provided more complete Oc:umentation l of each EDG test, the Unit Control Log was not .eviewed to i determine if the referenced requirement had been met. The ! ' redundant requirement may need to be reviewed to determine if it ! serves a useful purpose or is merely a burden on the Control Room J l staff. l II. Surveillance Testing (14980-1) i A. Requirement l ! VEGP procedure 14980-1 requires that the pertinent data be entered j on " Completion Sheet 1" whenever the procedure is used to
- demonstrate the operability of the EDG's.
I' O. Results
- l
~
- Completion sheets from procedure 14980-1 for the subject interval ! '(3/20/90 to 6/12/90) were reviewed in the Document Control Vault on l 6/12/90.- Additional completion sheets were reviewed on 6/29/90. Some difficulties were encountered in retrieving the. data sheets j from the vault. Some were filed under various surveillance task i numbers (14890-101 -102,...-112) and others were filed under just ; i the procedure number (14980-1). The information from these sheets ! (see Attachments A & 8) was taken from the Diesel Generator Start Evaluation and Comments sections.
i
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Special QA Audit of Unit 1 Emergency I Diesel Generatcr Starts - OP26-90/33 Page 3 III. Troubleshooting / Maintenance Testing (13145-1) A. Requirement VEGP Procedure 13145-1 requires that pertinent data be entered on
" Completion Sheet 1" whenever the procedure is used for testing the EDG's.
B. Results Completion sheets from 13145-1 for the subject interval (3/20/90 to 6/12/90) were reviewed in the Document Control Vault on 6/12/90. Some difficulties were encountered in retrieving the completion sheets. Seventeen completion sheets, for tests performed on April
- 6. May 23, and May 24, 1990, could not be retrieved on June 12, 1990. The sheets were, however, retrieved and reviewed on June 29, 1990. The information from these sheets (See Attachments A & B) was taken from the Diesel Generator Start Evaluation and Comments sections. As identified on the Attachments, a complete evaluation of the start was not always indicated (some did not indicate success or failure of the start and others did not indicate a valid or non-valid test).
IV. Diesel Generator Start Log (55038-C) l
\
A. Requirement VEGP procedure 55038-C requires that the results of all EDG tests 4 performed under procedures 13145-1 and 14980-1 be recorded in the Diesel Start Log. j 8. Results The information recorded in the Diesel Start Log was reviewed and j compared with the information obtained from the review of 13145-1 , and 14980-1 data sheets (see Attachments A & 8 for results). The . Diesel Start Log war determined to contain entries for all 13145-1 and 14980-1 data sheets that were reviewed for the subject time i period. The two entries in the S/S Log (ref. Attachment B) on May 15 and May 23 that do not have corresponding entries in the Diesel - Start Log were determined to be log entry errors in the S/S Log based on EDG run hours and the lack of data sheets (13145-1 or 14980-1). ! V. Results A. The number of sucesssful starts (18) without problems specified in LER. 424/90-06, dated April 19, 1990 tras determined to be , incorrect. Apply $ng the criteria of subseauent to comnletion of the test nroaram. the first successful start performed using l procedure 14980-1 " Diesel Generator Operability Test," was l counted. Through April 19, 1990, 10 successful starts were made on the Unit IA diesel and 12 successful starts were made on the Unit
i Special 04 Audit of Unit 1 Emergency , Diesel Generator Starts - OP26-90/33
- - .Page 4 I -
. 18 diesel. It should be noted that successful is not meant to i ; imply a. "Valtd" start using regulatory criteria. Based on ,
i evaluations made by the responsible diesel system engtheer, 7 valid i starts were made on both the 1A and 18 diesel subseauent to ; j comnletion of the test nrocram and through April 19, 1990. As
! discussed in the audit details above,' entries in the Diesel '
i Generator Diesel Start Log were confirmed during the audit by ' j independent verification using several sources. t ! No specific cause for the error in the LER number of 18 starts was I identified. However, it appears the major problem was that on 4 April 19,1990, when the LER was prepared, the Diesel Generator ! Start Log had not been updated. Based on a review of the log, no , i entries were made in the Unit 18 diesel Log between March 15 and : May 2, 1990: no entries were made in the Unit IA Diesel Log between March 16, 1990, and May 2, 1990. Therefore, no single source document was readily available for determining the results of diesel start attempts following the Site Area Emergency March 20, 4 ! l 1990, and prior to submittal of the LER April 19, 1990. Also, it j appears that confusion about the specific point at which the itit
- nroaran was ca=aleted exists. Therefore, successful starts made
{ during the test program were counted. l ! As discussed in the audit details, the data sheets from procedures j 13145-1 and 14980-1 are used by the system engineer when completing . i th6 start log. Substantial delays were noted in processing these i forms. In some cases, 24 days passed from the diesel start attempt ] until the form was sent to the system engineer (March 31,1990 to j April 24, 1990). Because of the routing delays and the unknown l location of the forms during that interim period, an individual attempting to identify diesel starts would not know if a complete 2 set of sheets was accumulated. As noted above, the diesel start j log was not up to date when the LER was submitted. i 8. The Unit 18 diesel start log was again updated June 6, 1990, l- however, through June 28, 1990, no additional entries have been j made in the Unit 1A Diesel Generator Start Log. Since the system l engineer makes the determination on " Valid" starts, his i determination was used to count the valid starts through June 7, a 1990 -8 the r-tatlan af the tesi. ne-am. Tha. rasaltowere 10 i on the Unit IA diesel and 11 on the 18 diesel. However, the i auditors identified several additional successful starts performed j in accordance with procedure 14980-1, " Diesel Generator Operability ! Test." It appears that througi. June 7,1990, the Unit 1A diesel ! will have had 16 valid starts and the 18 diesel will have had 12 ' ! valid starts. l 4 l VI. Recommendations , i l The error introduced in the LER appears to be the result of incomplete
- documentation. It was determined ttat on the date of the LER submittal, entries in the Diesel Generator Start Log were not up-to-date. !
Additionally, data forms generated by the Control Room during each start had not been processed. 1
Special QA Audit of Unit 1 Emergency Diesel Generator Starts - OP26-90/33
, Page 5 i
.It also appears that the current methodology of forwarding data forms to the diesel system engineer has several processing delays. Procedure 55038-C. " Diesel Start Log," does not contain specific guidance on timeliness in making entries and thus an up-to-date log does not exist.
The system engineer indicated he typically updates the log monthly. During the period of frequent starts monthly updates were inappropriate. o The methodology for logging and (etermining " Valid" diesel starts should be changed or more specific requirements for maintenance of ' the Diesel Generator Start Log developed. o It is also recommended that the need for redundant entries made in the Shift Supervisor's Logs and Unit Control Room Logs be reviewed. Since many entries in the SS log were either incomplete or missing, it provides little benefit as a source document with regard to diesel operations. TE!Lilf!d5 i From previous audits: None.
." rc::: this audit: None. i POST-AUDIT CONFERENCE No post-audit conference was held. Individual management personnel were briefed on the results of this audit.
jf /$ Y N. C. Mose r. G. R. Frederick Senior QA En neer Supervisor - SAER l l i i l
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- . VEGP PLANT REVIEW BOARD MEETING MINUTES i j ~*ETING NO. 90-96 DATE 7/12/90 PAGE 1 OF 4 j MEETING CONVENED 1:10 AN/PM; MEETING AD7OURNED 2:40 AN/PM t i (
- VIA TELECON) -
THIS MEETING CHAIRED BY:- l (X) CHAIRMAN ( ) VICE CHAIRMAN W. F. Kitchens l VOTING MEMBERS PRESENT: 'N. M. Handfinger R. L. LeGrand
- M. W. Horton J. E. Swartzwalder J. G. Aufdenkampe l
T. V. Greens PRB SECRETARY A. Rodgers/C. Cross Tynan NON-VOTING MEMBERS PRESENT: K. R. Holmes C. P. Stinespring 1 l, G. R. Frederick j
; VOTING ALTERNATES PRESENT:
4 FOR
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FOR l 4 l l 'N-VOTING ALTERNATES PREStNT: FOR
'l FOR
! FOR FOR !' i I; FOR 1 i GUESTS / TECHNICAL ADVISORS: W. K. Smith R. L. Mansfield i PRB ACTION ITEMS OPENED: 90-96-01
'N j PRB ACTION ITEMS CLOSED: 90-67-01, 90-06-01 [ ( } ,'j f PRB MINUTES APPROVED : 90-91, 90-93, 90-94, 90-95 s
h'f ff 0Tf" PRB SECRETARY , PRB CHAIRMAN CC: NRC RESIDENT INSPECTOR , (FORM NAME=PRBAGEND)
14
- i. i 5
PRB 90-96
- Page 2 of 4 4'
i
.' Pas unsTIse MInvTas couTIwamTzou sassT 1
i l A. Meeting Minutes 90-91, 90-93, 90-94 and 90-95 were ' unanimously approved as presented. i B. The following items were unanimously recommended for l 4 approval. No unreviewed safety question involved.
" Primary System l TCP 18001-C-7-90-1 Instrumentation Malfunction" d
i LDCR FS 90-031 Revise FSAR Table 10.3.3- ! 1: Add MSIV breather l caps to table (DCP 89- ' V1N0016) LDCR FS 89-088 Revise FSAR Table 3.5.1-
- 1: Add new item to Missile Table -
l Attachment #1 (DCP 87-4 V1E0216) Revised Response to NRC IE Bulletin 90-01 Response, " Loss of Fill-Oil in Transmitters Manufactured by Rosemount".
- c. The following item was unanimously recommended for approval with comment. No unreviewed safety question involved.
j
" Painting Activity
! LER 1-90-14 Results in Inoperable i Diesel Generator". ! Section G.2 - Change l Previous Similar Events to "None". Sectf.on E - i Is this reportable under ! a loss of a safety
- function?
J. G. Aufdenkampe and l W. F. Kitchens to review notes from conference i ' call on determination. 5 / e
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PRS 90-96 Page 3 of 4 l D. The following item was approved with comment. The vote was l 5:0. No unreviewed safety question involved. Hata: H. M. l Handfinger was not present at the meeting when the vote on this procedure took place. 00704-C, Rev. 5 " Personnel Qualification ; Program". Materials . Engineering Procedures ! not listed. Section i 4.6.5 - Question the , requirement for annual ; training - Will do the following but will not
- proceduralize
- (1)
Initial /requalification , j course provided every 2 ' years, (2) Management , j, observation will provide I ! sample of training. 1 Sections 2.4/4.6.3 - I j Nomenclature for Signoff j Criteria List (SCL) not l l consistent throughout !
- precedure. l l E. The board reviewed Event Report 2-90-003, " Unit 2 Manual l Reactor. Trip Due to Loop 3 MSIV Closure". T. V. Greene
- questioned the root cause being the age of the 0-ring. The j i Event Report needs to include more information. The Report was returned to the Event Review Team Leader for 4 investigation.
F. The board unanimously concurred with the reportability determination for the following Deficiency Cards. 2-90-0061 1-90-288 2-90-0062 1-90-289 2-90-0063 1-90-290 2-90-0064 1-90-291 2-90-0065 1-90-292 1-90-278 I i l l
l. e 1 s i PRB 90-96 j . Page 4 of 4 1 G. Procedure 00663-C, Rev. O, " Fitness-For-Duty Program" was tabled. The board did not have sufficient ti.' to review
- the procedure. The procedure will be reviewed / discussed at the next regularly scheduled meeting.
The following comments were noted:
- - Section 7.0 - Include statement on emergency situations /callouts. Discuss with C. P. Stinespring.
i] - Section 8.2 - NRC resident interprets this as requiring i Supervisor training prior to assigning to supervisory ! duties. C. P. Stinespring to get input on how other ! l SONOPCO plants handle this. I E E Qign_ Item 90-96-01 assigned to C. P. Stinespring to ! obtair."information from other SONOPC0 plants relative to ! the need for supervisory training prior to assuming l Supervikory duties. Due 8/17/90. 1 ! H. Temporary Procedure T-ENG-90-21 (TER 90-008), Rev. O was j tabled. This procedure is to determine the Letdown ! Isolation function of Level Channel 460. The following l comments were noted: ( l - cycle between Letdown was not addressed e Change procedure to apply to Mode 5 conditions ! - Safety Evaluation question 1.6 is answered incorrectly. ! I. PRB Action Item 90-06 Review Engineering Procedures for standardizing Special Tests /2ngineering T-ENG procedures was j closed. PRB closed this item based on a QA Audit Finding Report tracking this same issue. J. PRB Action Item 90-67-01 for the General Manager to
- determine if the Letter of Confirmation (Site Area l Emergency) needs to be clarified, since the LER was revised j and the NEy 14th letter to clarify diesel starts was issued.
i It was detitrained that no additional clarifications were { needed. The board concurred. j Meeting Adjourned 1
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' Confidential !
j Larry: Robinson i ( NRC - OI
Dear Mr. Robinson:
l 1990 you interviewed i As you are aware, on February.8,OI's investigation of the t- Mr. Allen Mosbaugh regarding NRC mid-loop injection of hydrogen peroxide and Georgia Power l-Company's decision not to report that incident. At the time of the interview, Mr. MosbaughSee, wasFebruary represented 12, by 1990 theletter Troutman, Sanders law firm. from Arthur Domby to Mr. Mosbaugh. On page 47 of the transcript of Mr. Mosbaugh's interview, you asked Mr. Mosbaugh about rumors on site regarding the decision to open the valves resulting in the injection of hydrogen peroxide At that point you went off the the record so Mr. mid-loop. I Domby could advise his cllent how to answer the pendingDuring the co question. ' held off the record, Mr. Mosbaugh advised Mr. Domby that he could provide first hand information as to who opened the t. Domby advised his client not to volunteer that information l because the question pending only concerned " rumors" not ' - first hand information. t After the interview was closed, Mr. Mosbaugh became He ! more draftedand more uncomfortable a memo regarding the statement with the advice of counsel. Mr. Kitchens made in i-i his presence and contacted new counsel. It appears that a conflict of interest existed between I Mr. Mosbaugh and GPC's counsel and as a result of that l conflict Mr. Mosbaugh was improperly advised to withhold ; s information during the course of your investigation. l Enclosed please find the draft Mr. meno Mr. Mosbaugh Mosbaugh believes this created afteris the interview. information important and he would have provided it at the time of his interview but for the adivce he received i from his then Counsel of Record. l - lt 'ff"/
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i n , Larry Robinson June 13, 1990 Page Two i i Mr. Mosbaugh looks forward to meeting with you in the near future and will assist you in any way he can. I an I t sincerely yours, h /L Michael D. Kohn
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4 W. S. Meersten, m senor v<e P'es cent j %cearOce'a ons j ELV-01729 0 June 29, 1990 Docket No. 50-424 U. S. Nuclear Regulatory Commission f ATTN: Document Control Desk
- Washington, D. C. 20555 Gentlemen
1 ! V0GTLE ELECTRIC GENERATING PLANT
' 1 LICENSEE EVENT REPORT LOSS OF 0FFSITE POWER LEADS TO SITE AREA EMERGENCY 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 generator starts as discussed in the GPC letter dated April 9, 1990 and the LER dated April 19, 1990 and to update the status of corrective
- actions in the LER. If the criteria for the completion of the test program is understood to be the first successful test in accordance with Vogtle Electric-l Generating Plant (VEGP) procedure 14980-1 " Diesel Generator Operability Test,"
i then there were 10 successful starts of Diesel Generator IA and 12 successful starts of Olesel Generator IB between the completion of the test program and the i and of April 19, 1990, the date the LER 50-424/1990-06 was submitted to the NRC. The number of successful starts included in the original LER included some of the starts that were part of the test program. The difference is attributed to diesel start record keeping practices and the definition of the end of the test ' j program. , ! In order to correct the LER and to provide more useful and up to date
- information the LER has been revised to state the number of valid diesel i ganarator tas,t.s in accordance with Regylatory Guide 1.108 rather than the number of successful starts since the event. The number of"valTd tests was established by reviewing diesel generator testing data from Mar 6h 21 through June 7, 1990.
Sincerely, J.J. ? % W. G. Hairston, !!! I WGH,!!!/HWM/gm
Enclosure:
f1 LER 50-424/1990-006-01 y{ 7 k
/1 9eM+M98' Aff,
/ .' Georgia Power d U. S. Nuclear Regulatory Commission ELV-01729 xc: Georaia Power Comoany Mr. C. K. McCoy Mr. G. Bockhold, Jr.
Mr. R. M. Odom Mr. P. D. Rushton
- NORMS U. S. Nuclear Reaulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. T. A. Reed, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident Inspector, Vogtle a
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On 3-20-90, Unit I was in a refueling outage and Unit 2 was operating at 1007, ; i power. At 0820 CST. the driver of a fuel truck in the switchyard backed into a support for the phase 'C' insulator for the Unit 1 Reserve Auxiliary Transformer ! (RAT) 1A. The insulator and line fell causing a phase to ground fault. Both ' Unit 1 RAT 1A and Unit 2 RAT 2B High Side and Low Side breakers tripped, causing a loss of offsite power condition (LOSP). Unit 1 Diesel Generator (DG) 1A and i Unit 2 DG2B startede but DGIA tripped, causing a loss of residual heat removal 1 (RHR) to the reactor core since the Unit 1 Train B RAT and DG were out of i service for maintenance. A Site Area Emergency (SAE) was declared and the site !. Emergency flan.masr implammatad. Tha.Raactor Coolant System heated up to 136 i degrees F from 90 degrees F before the DG was emergency started at 085E CST and i RHR was restored. The initial notifications were not made within the required
- 15 minutes due to the loss of power to the Emergency Notification Network (ENN).
At 0915 CST. the SAE was downgraded to an Alert after onsite power was restored. l The direct cause of this series of events was a cognitive personnel error. The truck driver failed to use proper backing procedures and hit a support, causing the phase to ground fault and LOSP. The most probable cause of the DG1A trip . was the intermittent actuation of the DG jacket water temperature switches. Corrective actions include strengthening policies for control of vehicles. , extensive testing of the DG, rep acement of suspect DG temperature switches, and
- improvements in the ENN system.
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I A. REQUIRENENT FOR REPORT 4 I This event is reportable per: a) 10 CFR 50.73 (a)(2)(iv), because an unplanned Engineered Safety Feature (ESF) actuation occurred when the ESF
. Actuation System Sequencer started, and b) Technical Specification
! 4.8.1.1.3, because a valid diesel generator failure occurred. Additionally, this report serves as a susuary of the Site Area Emergency event.
- 8. UNIT STATUS AT TIME OF EVENT l Unit I was in Mode 6 (Refueling) at 05 rated themal power. The reactor had
- been shut down since 2-23-90 for a 45 day scheduled refueling outage. The l reactor core reload had been completed, the initial tensioning of the
! reactor vessel head studs was complete, and the outage team was awaiting l j permission from the control room to begin the final tensioning. Reactor l j Coolant System (RCS) level was being maintained at mid-loop with the Train A 4 Residual Heat Removal (RHR) pump in service for decay heat removal. The i temperature of the RCS was being maintained at approximately l 90 degrees F. i l l Due to the refueling outage maintenahce activities in progress, some j equipment was out of service and several systems were in abnormal ,
- configurations. The Train B Diesel Generator (DG1B) was out of service for i
- a required 36 month maintenance inspection. The Train 8 Reserve Auxiliary Transformer (RAT 1B) had been removed from service for an oil change. The
- Train 8 Class IE 4160 Volt switchgear, 18A03, was being powered from the Train A RAT 1A through its alternate supply breaker. All non-1E switchgear i was being powered from the Unit Auxiliary Transformers (UAT) by backfeeding ,
! from the switchyard. All Steam Generator (S/G) nozzle dans had been i removed, but only S/G's 1 and 4 had their primary manways secured. - l Maintenance personnel were in the process of restoring the primary manways i on S/G's 2 and 3. RCS level was f sing amintained at mid-loop for valve ! repairs and the S/G manway restorations. In addition, the pressurizer l menwerwee remove 6 ter provide, an, RC.S vant, panth... i C. DESCRIPTION OF EVENT ; i On March 20, 1990, at approximately 0817 CST, a truck driver with a security ! escort entered the protected area in a fuel truck. Alt k not a member of ; the plant operating staff, the driver was a Georgia Power any employee belonging to a service group used to perfors various plant services. The driver checked the welding machine that was in the area and found that it , did not need fuel. He returned to the fuel truck and was in the process of : backing out of the area when he hit a support holding the phase 'C' : insulator for RAT 1A. The insulator and line fell causing a phase to ground fault, and the transformer breakers tripped.
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0lI 0 l3 os 0 l9 At 0820 CST, both Unit 1 RAT 1A and the Unit 2 RAT 28 High Side and Low Side breakers tripped causing a loss of offsite power condition (LOSPPte the Unit 1 Train A Class IE 4160 volt bus IAA02, the Unit 2 Train B Class IE bus 2BA03, and the 480 volt busses supplied by 1AA02 and 2BA03. The Unit 1 Train B Class IE 4160 volt bus IBA03 also lost power since RAT 1A was feeding both Trains of Class IE 4160 volt busses. The loss of power caused the associated ESF Actuation System Sequencers to send a start signal to one Unit I and one Unit 2 Diesel Generator. DGIA and DG28 started and sequenced the loads to their respective busses. Further description of the Unit 2 response to this event is provided in LER 50-425/1990-002. One minute and twenty seconds after DGIA started and sequenced the loads to the Class IE bus, the engine tripped. This again caused an undervoltage l (UV) condition to class IE bus IAA02. Tk UV signal is a maintained signal i at the sequencer. However, since DGIA was coasting down from the trip, the i shutdown logic did not allow the DG fuel racks or starting air solenoids to ! open and start the engine. This properly caused the engine starting logic ! to lock up, a condition that existed until the UV signal was reset. For this reason, DGIA did not automatically re-start after it tripped.
- After the trip, operators were dispatched to the engine control panel to investigate the cause of the trip. According to the operator, several l annunciators were lit. The operator briefly reviewed several instrument
. read-outs and detected no imediate problem. In order to restore emergency l power, the operator reset the annunciators without delaying to evaluate or i rs:ord the annunciators that were present. During this time, a Shift l Supervisor (SS) and a Plant Equipment Operator (PEO) went to the sequencer i panel to detemine if any problems were present on the 1A sequencer. The SS l pushed the UV reset button, then reset the sequencer by doenergizing and i energizing the power supply to the sequencer. This caused the DG air start 4 i solene W k ease 96 aerter another L sacando e ach.causad,tho eag,ina.ta start, i This happened lg minutes after the DG tripped the first time. The engine started and the sequencer sequenced the available loads as designed. After 1 minute and 10 seconds, the breaker and the engine tripped a second time. It did not automatically re-start due to the starting logic being blocked as
- described above. By this time, operators, a maintenance foreman and the
- diesel generator vendor representative were in the DG room. The initial i
report was that the jacket water pressure trip was the cause of the trip.
- This report was discounted because the maintenance foreman and vendor I
representative observed that the jacket water pressure at the gauge was about 12-13 PSIG. The trip setpoint is 6 PSIG and the alare setpoint is 8 PSIG. Also, the control room observed a lube oil sensor malfunction alarm. m-.
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i VEGP - UNIT 1 o Is lo lo le l4 l 2l4 910 - 0l0l 6 - 0l1 0l4 or 01 i i Fifteen minutes after the second DGIA trip, DGIA was started from the engine j control panel using the emergency start breakglass button. The engine i started and loads were manua'ly loaded. When the DG is started in the
; emergency mode, all the trips except four are bypassed. However, all alarms
- will be annunciated. During the emergency run, no trip alarms were noticed l by the personnel, either at the contro room or at the engine control panel.
- The only alarus noted by the control room operator assigned for DG operation 4 were lube oil pressure sensor malfunction and fuel oil level high/ low alarm,
- neither of which would have tripped the diesel. )
i ! At 1040 CST, RAT 18 was energi::ed to supply power to 4160 volt bus IBA03.
; DGIA supplied power to 4160 volt bus IAA02 until 1157 CST, at which time bus i IAA02 was tied to RAT 18.
I : 1 A Site Area Emergency was declared at 0840 CST, due to a loss of all offsite and onsite AC power for more than 15 minutes. The Emergency Director signed i the notification form used to inform offsite government agencies of the I ! emergency at 0848 CST. The shift clerk attempted to initiate offsite
- notification utilizing the primary ENN in the control room but found it
! inoperable due to loss of power. The shift clerk then went to the back-up ! ENN and initiated notification after roll call on this system at 0857 CST.
- Due to the loss of power, which rendered the primary Emergency Notification i Network (ENN) inoperable, and some mis-cossuunication, the initial l notification was not received by all agencies until 0935 CST.
4 ! The Emergency Director instructed personnel to complete various tasks for i restoring containment and RCS integrity. All work was accomplished and ! maintenance personnel exited containment by 1050 CST. i ! The SAE was downgraded to an Alert Emergency at 0915 CST after restoration ! of core cooling and one train of electrical power. By 1200 CST, plant
- conditions had stabilized with both trains of electrical power being supplied from an offsite source (RAT 18). After discussions with the NRC ]
i and local government agencies, the emergency was terminated at 1247 CST and 1 l, all agencies were notified by 1256 CST. i j D. CAUSE OF EVENT l Direct Cause: l 1. The direct cause of the loss of offsite Class IE AC power was the fuel truck hitting a pole supporting a 230kV line for RAT 1A. This was a cognitive personnel error on the part of the truck driver. There were i no unusual characteristics of the work location that directly contributed to this personnel error. I 2. The direct cause of the loss of onsite Class IE AC power was the failure of the operable DG, DGIA, to start and load the LOSP loads on bus IAA02. l l MMEO
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- 3. The direct cause of the failure of the primary ENN system in the l
control room was the loss of electrical power to Unit 1. The primary i ENN in the control rcos is powered from Unit 1 Class IE AC power. i Therefore,whart Unit 1.. lost Class IE AC electrical power, the primary i ENN in the control room did not work. Root Cause: 1 I
- 1. The truck driver met all current site training and qualification
- requirements, including holding a Class 2 Georgia driver's license. ;
However, site safety rules, which require a flagman for backing ; j vehicles when viewing is impaired, were violated. . I I
- 2. The root cause for the failure of DGIA has not been conciusively
- i determined. There is no record of the trips that were annunciated i
after the first trip because the annur-iators were reset before the 1 condition was fully evaluated. Theretore, the cause of the first trip can only be postulated, but it was most likely the same as that which l caused the second trip. The second trip occurred at the end of the ! timed sequence of the group 2 block logic. This logic allows the DG to l achieve operating conditions before the trips become active. The block logic timed out and the trip occurred at about 70 seconds. The annunciators observed at the second trip included jacket water high l temperature along with other trips. In conducting an investigation,
- the trip conditions that were observed on the second DG trip on 3-20-90 l
could be duplicated by '/enting 2 out of 3 jacket water temperature sensors, simulating a tripped condition. The simulation duplicated both the annunciators and the 70 sec. trip time. The most likely cause of the DG trips was intermittent actuation of the jacket water j temperature switches. i
- Following the 3-20-90 event, all three jacket water temperature !
( switches, which all have a design setpoint of 2000F, were bench tested. ' SWiten T5;NITV' war finmt to hevrs'setpetnt of M deepeesJ, whicL, was approximately 6 degrees below its previous setting. Switch i TS-19111 was found to aave a setpoint of 199 degrees F, which was i approximately the same as the original setting. Switch TS-19112 was found to have a setpoint of 186 degrees F, which was approximately 17 l degrees F below the previous setting and was re-adjusted. Switch TS-19112 also had a small leak which was judged to be acceptable to !' support diagnostic engine tests and was reinstalled. The switches were i recalibrated with the manufacturer's assistance to ensure a consistent i calibration technique. l mwe
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; en n - .-- . .e . wm ! During the subsequent test run of the DG on 3-30-90, one of the
{ switches (TS-19111) tripped and would not reset. This appeared to be j an intermittent failure because it subsequently mechanically reset. i This switch and the leaking switch (TS-19112) were replaced with new switches. All subsequent test.ing.was conducted with no additional j problems. ) A test of the jacket water system temperature transient during engine j starts was conducted. The purpose of this test was to determine the i actual jacket water temperature at the switch locations with the engine in a normal standby lineup, and then followed by a series of starts without air rolling the engine to replicate the starts of 3-20-90. The
- test showed that jacket water temperature at the switch location i decreased from a standby temperature of 163 degrees F to approximately 156 degrees F and remained steady.
s Numerous sensor calibrations (including jacket water temperatures), j 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 were subjected to a comprehensive test l program. Additionally, the jacket water high temperature switches were l sent to an independent laboratory, which found the switches set at temperatures ranging from 162 degrees F to 195 degrees F rather than ! the 200 degree F setting that was required. The calibration technique l was changed and switches were re-calibrated and installed on DGl8 on l 5-23-90. However, another failure occurred on DG1B (See Technical i Specification Special Report 1-90-4.). These switches were also sent l to the independent laboratory, which found the settings to be from 164 ' degrees F to 169 degrees F. Subsequent to this testing, the onsite calibration procedure was again revised to provide a technique that is consistent with the actual operating conditions that the switches j experience. Switches were calibrated using this new technique, i installed and found to operate within the expected parameters. Since the event of S-20-90 through 6-7-90, DG18 had received 12 valid tests witR the one ftifurs menttonet stMrve; ant 981* hetrece+ve+ WM14- p I testt with no failures. l Based on the above facts, it is concluded that the jacket water high i temperature switches were the most probable cause of both trips on j 3-20-90. ! The investigation and testing following the 3-20-90 event revealed that l pressure sensors in the diesel generator lube oil system had not been replaced in accordance with a 10 CFR 21 notification from the manufacturer dated 5-12-88. The 10 CFR 21 notification was confusing relative to the requirements for their replacement. It was subsequently revised in an addendum dated 6-8-90. The pressure trip I ( ens een.nn nam - I - . - _ . _ _ ._.
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i instructions. GPC does not believe that these sensors contributed to j the diesel generator trip on 3-20-90. i, E. ANALYSIS OF EVENT l The loss of offsite power to Class IE bus 1BA03 and the failure of DG1A to j start and operate successfully, coupled with DG1B and RAT 18 being out of J service for maintenance, resulted in Unit I being without AC power to both I Class 1E busses. With both Class IE busses doenergized, the RHR System could not perform its required safety function. Based on a noted rate of j rise in the RCS temperature of 46 degrees F in 36 minutues, the RCS water
- would not have been expected to begin boiling untti approximately I hour and l 36 minutes after the beginning of the event. Using more conservative assumptions and methods, but the same actual time of the event, the l
calculated worst case time to boiling was found to be approximately I hour and 11 minutes, and time to core uncovering was fcund to be approximately 11 hours and 5 minutes. This assumed no gravity feed from the RWST. l 1 l Restoration of RHR and closure of the containment equipment hatch were ! completed well within the estimated I hour and 36 minutes for the projected i onset of boiling in the RCS. A review of information obtained from the l Process and Effluent Radiation Monitoring System (PERMS) and grab sample i analysis indicated all normal values. As a result of this event, no l increase in radioactive releases to either the containment or the environment occurred. l [ Additional systems were either available or could have been made available
- to ensure the continued safe operation of the plant
i l 1. The maintenance on RAT 18 was completed and the RAT was returned to j service approximately 2 hours into the event. l l 2. Offsite power was avaliaDie to mm-!E egirtymevet titreeg6r the generater step-up transformers which were being used to "back-feed" the Unit and supply the non-1E busses. Provided 1 Auxiliary that the phase to ground fau was cleared, Class IE busses IAA02 and Transformers (UAT)lt 4 18A03 could have been powered by feeding through non-1E bus INA01.
- 3. The Refueling Water Storage Tank could have been used to manually i establish gravity feed to the RCS to maintain a supply of cooling water to the reactor.
l Consequently, neither plant safety nor the health and safety of the public was adversely affected by this event.
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i i VEGP - UNIT 1 o lsidlolsl4l2 l4 9 l0 - 01016 - 0 11 0 18 o' 0 19 i ~,enn . . ea aimw.m F. CORRECTIVE ACTIONS i 4 1. A management policy on control and operation of vehicles has been j , established. l
- 2. Temporary barricades have been erected with' signs which direct -
authorization for control of switchyard traffic to the 55. I 3. The Loss of Offsite Power (LOSP) diesel start and trip logic has been modified on both Unit I and Unit 2 so that an automatic " emergency" l l start will occur upon LOSP. Therefore, non-essential diesel engine l 1 trips are blocked upon LOSP. Additionally, high jacket water ! , temperature has been deleted as a trip signal in the emergency start i mode. 1 ! 4. The DG1A test frequency was increased to three times per week until ) 4-20-go when the test frequency was changed to once every 7 days in accordance with Technical Specification Table 4.8-1. This frequency ! will be continued until 7 consecutive valid tests are completed with no i more than one valid failure in the last 20 valid tests. Up to and
- including the two valid failures of the 3-20-90 event, there were a ,
total of four valid failures in alid tests of DGIA. ' i m j 5. The jacket water temperature swi" es for each DG were replaced or i re-calibrated using a more appropriate technique prior to their i installation.
- 6. A back-up ENN system powered from the AT&T system, which previously existed and was operational for South Carolina agencies, has been extended to include Georgia local and state egencies. Instructions have been given to Emergency Directors and Communicators concerning use of the emergency communication systems.
l l G. ADDITIONAL INFORMATION
~
- 1. Failed Components:
Jacket Water High Temperature Switches manufactured by California Controls Company. i Model #A-3500-W3 l l 2. Previous Similar Events: ! None cxmn _ - - _ - _ -
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- 3. Energy 9nthirtry Identification System Code: ..
Reactor Coolant System - A8
- Residual Heat Removal System - BP l *
- Diesel Generator Lube 011 System - LA j Diesel Generator Starting Air System - LC ;
' Diesel Generator Cooling Water System - LB Diesel Generator Power Supply System - EK j l
- Safety Injection System - BQ ;
! 13.8 kV Power System - EA .
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i 4160 volt non-lE power system - EA ' , i 4160 volt Class IE power system - EB l - Chemical and Volume Control System - CB i Containment Building - NH 480 volt Class IE Power System - ED ! Engineered Safety Features Actuation System - JE 1 Radiation Monitoring System - IL i I i l i i t i 1 i _ . fMW1 - _ _ _ _.___ _-- - - - - - -
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June 22, 1990 ,,w u a - ec- . .,...- 4 w. a. w,w a. m i se N0' W e #:f509 1 *
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! ELV-01723 0409 3 ,
! Docket Nos. 50-424 1 50-425 U. 5. Nuclear Regulatory Comission i
ATTN: Document Control Desk Washington, D. C. 20555 j Gentlemen: 1 l V0GTLE ELECTRIC GENERATING PLANT i CORRECTIVE ACTIONS FOR SITE AREA EMERGENCY i The attachment to our May 14, 1990 letter on this subject stated: l
- " Maintenance procedures for temperature switches will be revised by i 5-15-90 to include lessons learned from laboratory testing. All jacket
- water high temperature switches will be cleaned and calibrated using the
! . revised procedures by 5-31-90. Other non-essential trip temperature switches will be cleaned and calibrated by the end of the next refueling i outage for the associated unit." i In response to the above commitment, we revised the calibration procedure, j cleaned and calibrated three new jacket water high temperature switches and installed them in Diesel Generator 18. During a routine Technical Specification ~
- surveillance of Diesel Generator 18, we experienced a valid diesel generator failure. The cause of this failure was determined to be the calibration
! hardware and techniques used to calibrate the replacement jacket water high
- temperature switches. The jacket water temperature switches were tested by an
- independent inberatory and the trip setpatats.wara.datesmined.ts be u-36.
degrees F less than the required 200 degree F setpoint. The onsite calibration procedure has been revised to provide a technique that is consistent with the actual operating conditions that the switches experience.
- As a result of these additional problems with the jacket water high temperature
- swit
- hes, we submitted (by letter dated May 25,1990) a request to revise
- Technical Specification 4.8.1.1.2h(6)(c) which would allow the jacket water high temperature trip to be bypassed to minimize the potential for spurious diesel j generator trips in the emergency start mode..
- The installation of a modification which allows this trip to be bypassed has been accomplished on all four diesel generators. This action was completed by i
5-31-90 in lieu of cleaning and calibrating the jacket water high temperature switches as stated in our May 14 letter. t
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U. S. Nuclear Regulatory Commission ELV-01723 Paas Two i Usine th's revised calibrstion procedure, the jacket water high temperature switches have tiow been calibrated for the diessi generators in both units. These switches will be maintained on a nomal maintenance schedule. I Sincerely, ; (). . . W. G. Hairston, !!! 4 WCH,111/ JAB /gm j i xc: Caorofa Power comoany Mr. C. K. McCoy Mr. G. Bockhold, Jr. Mr. R. M. Odom Mr. P. D. Rushton NORMS U. S. Nuclear Raoulatory Commission Mr. S. D. Ebneter, Regional Administrator + Mr. T. A. Reed, Licensing Project Manager, NRR
- Mr. B. R. Sonser, Senior Resident Inspector, Vogtle 1
J I
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, - Mar ta Gecrg a 30306 -
'eerrone 401526 3195 '
' Ma e rg Address .
. . 40 :r,er ess Ceme' Pa'**av Poe 0"ceBca*295 B.rm.rtgham A.acama 35201 Te<eonone 205 868 558' June 22, 1990 t'v " 'u'e e" r' " +"
W. G. Heerston, Hi Sertor Vce Prescent Nac ear Operat ons ELV-01793 0447 Docket No. 50-424 h U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, 3. C. 20F'i5 Gentlemen: V0GTLE ELECTRIC GENERATING PLANT SPECIAL REPORT VALID DIESEL GENERATOR FAILURE In accordance with the requirements of the Vogtie Electric Generating Plant Technical Specifications, Sections 4.8.1.1.3 and 6.8.2, Georgia Power Company hereby submits the enclosed Special Report concerning a valid diesel generator failure. Sincerely, I Q..
~
W. G. Hairston, III WGH,III/NJS/gm
Enclosure:
. Special Report 1-90-04 xc: Georaia Power Comoany Mr. C. K. McCoy Mr. G. Bockhold, Jr.
Mr..P. D. Rushton Mr. R. M. Odom NORMS U. S. Nuclear Reaulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. T. A. Reed, Licensing Project Manager, NRR nr. .. R. .onse,, Sento, Resident Ins, ecto,, vo, tie g hl 7 h j X .- 70ir+ %D062 pff' FDR ADOCE 0500042C /p 3 PDC
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b ENCLOSURE V0GTLE ELECTRIC GENERATING PLANT - UNIT 1 TECHNICAL SPECIFICATION SPECIAL REPORT l-90-04 vat 1D DIESEL GENERATOR FAILURE A. REQUIREMENT FOR DEPORT Plant Technical Specifications, Section 4.8.1.1.3.This repo This section of the Technical Specifications requires that all diesel generator failures, valid or non-valid, be reported to the Commission in a Special Report pursuant to Technical Specification 6.8.2. B. DESCRIPTION Of VALID FAILURE FOR DIESEL GENERATOR IB On 5-23-90, at 1226 CDT, Diesel Generator (DG) IB was started pursuant to a normal routine Technical Specification surveillance requirement. Just prior to this surveillance test, the jacket water temperature switches had been replaced with recalibrated switches as part of a DG reliability upgrade and the DG had baen declared operable. and the following alarr; were noted: At 1228 CDT, DGlB tripped
- "Lo Turbo Oil Pressure," "Hi Jacket Water Temp.," and "Lo acket Water Pressure" ,
Several troubleshooting starts were made and it was determined that the jacket water temperature 4 switches were the source of the trip signal. jacket water temperature switches were reinstalled on DGIB.On 5-24-90, the ori Both normal and emergency service starts the same day were at 2254 successfully conducted and DGlB was returned to CDT ; During this time Diesel Generator IB was unavailable minutes. for emergency ope. ration for a period of 34 hours and 26 The jacket water temperature switches were tested by an independent less than the required 200 degree F setpoint. laboratory and The onsite calibration procedure has been revised to provide a technique that is consistent with the actual operating conditions that the switches experience. C.
SUMMARY
This event is classified as a valid failure per Reg. Guide 1.108, Section C.2.e. Since this is the second valid failure in the past 20 valid i tests, the test frequency for DG1B has been changed to once per 7 days in accordance with Table 4.8-1 of the Technical Specifi. tions. As of i 5-23-90, failures, there have been a total of 71 valid tests of DGIB and 5 valid i i
Georg a Power Comcany 333 P+rw Annue At:a*u Georg a 30300 s Te,onone 404 526 3195 Ms.ng Acceess 40 smerness Corner Parkway Post OHee Bos 1295 Sermengham Alaoama 35201 Telephone 2o5 868 5581 July 17, 1990 ene ., n:- : , . r.-- W. G. Meeeeeevi. NI Senor v.ce Pres.oern Nuoear Operm.ons ELV-01905
- 492 Docket No. 50-424 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:
V0GTLE ELECTRIC GENERATING PLANT LICENSEE EVENT REPORT PAINTING ACTIVITY RESULTS IN INOPERABLE DIESEL GENERATOR in accordance with 10 CFR 50.73, Georgia Power Company hereby submits the enclosed report related to an event which was discovered on June 19, 1990. Sincerely, 4 u).2. $ht= - W. G. Hairston, !!! . WGH III/NJS/gm
Enclosure:
LER 50-424/1990-014 xc: Georcia Power Comoany Mr. C. K. McCoy Mr. G. Bockhold, Jr. , 1 Mr. P. D. Rushton Mr. R. M. Odom NORMS ' U. S. Nuclear Reaulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. T. A. Reed, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident Inspector, Vogtle v , P q AeeisQ Mil Gy.
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On 6-19-90, two unsuccersful start attempts were made for the lA diesel generator. At 2359 CDT, the diesel was declared inoperable and the Technical Specification action requirements for an inoperable diesel generator were initiated. Upon investigation, a Support Shift Supervisor discovered that masking tape had been applied to the diesel generator fuel racks which was holding the racks in the shutdown position. The tape was removed and the diesel was restored to operable status at 0554 CDT on 6-20-90. Subsequent review determined that the tape had been applied during the morning / afternoon of 6-18-90 during painting of the diesel by craft personnel. 1 Therefore, the diesel was inoperable for an approximate 30 to 35 hour period during which it was thought to be operable. The root cause for this occurrence was determined to be a lack of t?.auste administrative ..,ntrols for evaluating 4 and monitoring painting activities. Prior to the initiation of the painting, a ' walkdown of the diesel was performed by a Shift Supervisor accompanied by the painting coordinator. However, due to the lack of adequate administrative controls, the walkdown failed to identify that diesel operability could be impacted. As an interim measure, a walkdown checklist has been implemented for all ongoing painting activities within the plant. Plant procedures will be revised by 9-1-90 to require the checklist to be made a part of all future work orders for performing painting.
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VEGP - UNIT 1 o Is lo lo lo l4 1 2l4 9l 0 0[1l4- 0, 0 0 g2 o, 0;5 1 l A. REQUIREMENT FOR REPORT ! This report is required per 10 CFR 50.73 (a)(2)(l) due to discovery of fire j evidence that a diesel generator was inoperable for an approximate 30 tu 35 hour period during which the diesel was thought to be operable. Since action requirements contained in Technical Specification (TS) 3.8.1.1 for an i inoperable diesel generator were not completed during this time, this resulted in the plant operating in a condition prohibited by the Technical ' a Specifications. This report is also required per TS 4.8.1.1.3 since two i diesel generator (nonvalid) start failures occurred as a result of the inoperable condition of the diesel. I ! B. UNIT STATUS AT TIME OF EVENT l i 1 During the time that the diesel was inoperable Unit I was operating in Mode l 1 (Power Operation) at 100% of rated thermal power. Other than that .' described herein, there was no equipmsnt which was inoperable or in an off ! normal status such that it contributed to the occurrence of this event, j C. DESCRIPTION OF EVENT l On 6-19-90, at 2225 CDT, the Unit 1 Shift Supervisor authorized the i performance of surveillance procedure 14980-1, " Diesel Generator Operability Test," for the 1A diesel generator. At 2349 COT, the Balance of Plant l Operator depressed the 1A diesel start pushbutton but released it a second ! later after being distracted by receipt of both a fire alarm and a hydrogen I stator cooling annunciator. A Plant Equipment Operator (PE0) present at the diesel observed the diesel roll, but then it stopped and the " Engine Failed ! to Start annunciator came in. This start attempt was evaluated as a , nonvalid failure due to operator error. At 2359 CDT, a second start attempt for the lA diesel was made. The PE0 observed the diesel roll, but again it stopped and the " Engine Failed to
- Start" annunicator came in. The 1A diesel was then declared inoperable and the action requirements of TS 3.8.1.1 for an inoperable diesel generator were initiated.
*fter the second start attempt, a Support Shift Supervisor (SSS) and an Instrumentation and Controls (I&C) Supervisor were sent to the 1A diesel to investigate. The 555 climbed up on top of the diesel and noticed that masking tape had been applied to the rack on each fuel injector pump. The tape had apparently been applied by painters assigned to paint the diesel.
The movement of the fuel rack was checked and it was determined that the
- tape was holding the fuel rack in the shutdown position. This prevented the t
injection of fuel into the diesel cylinders. By 0121 CDT on 6-20-90, all a i
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, ven. . anc m .uwem c ls lo lo ls l4 l 214 910 - 0l114 ~ 0 l0 0 l3 or 0l5 ! the tape had been removed from the diesel and a successful start was performed per system operating procedure 13145-1, " Diesel Generators". The diesel was then satisfactorily tested per surveillance procedure 14980-1 and at 0554 CDT, the 1A diesel was restored to operable status. i D. CAUSE OF EVENT The root cause of the event was a lack of adequate administrative controls for evaluating and monitoring painting activities within the plant. At the , Vogtle Electric Generating Plant, painting is presently performed by craft l personnel who work under the supervision of a Georgia Power Company (GPC) coordinator. On 6-14-90, the GPC coordinatnr requested a walkdown of the 1A diesel by an Operations Department representative so that painting of the diesel could be initiated. The area to be painted was the 1A diesel generator skid, the room walls, and the room floor. A Shift Supervisor performed the walkdown but, due to the lack of administrative guidance for performing such walkdowns and poor comraunications between the two individuals, the Shift Supervisor did not recognize that the operability of the diesel could be impacted. The painters' standard practice is to tape up stainless steel and moving parts of equipment to be painted. This practice was not communicated to the Shift Supervisor during the walkdown and he therefore failed to consider the possible effects of applying tape to such ; diesel parts. The Shift Supervisor did communicate the fact that the diesel was to remain available for emergency starts and that the painters should anticipate a start of the diesel at any time. The Shift Supervisor also l pointed out that contact with the governor adjustment knobs should be avoided. Since the Shift Supervisor did not specifically point out the fuel racks as a component to be aware of, the painters proceeded to tape up the fuel racks during the morning / afternoon of 6-18-90 prior to applying a primer coat of paint. A contributing cause for the event was that the maintenance work order (MWO) initiated for performance of the painting activity contained only a vague description of the work to be performed. The work description provided on the MWO stated to " coat walls, floors, steel and equipment" and listed an equipment tag number that corresponded to the Unit 1 Train A Diesel Generator Room. The Work Planning Group, in reviewing this MWO, failed to l recognize that " equipment' included the diesel generator and therefore did not identify the MWO as a critical component MWO or provide any special precautions within the work instructions. This breakdown in the MWO review process also prevented the painting of the diesel from being discussed in the daily Plan of the Day (POD) meeting. Had this discussion taken place, plant management could have addressed the operability concerns that taping of the diesel could pose.
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3 VEGP - UNIT 1 o ls jo lo le l412l4 %0 - 0l1 l4 * - 010 0l4 or 0 l5 i inner-. . ea an.mm i E. ANALYSIS OF EVENT l The 1A diesel generator failures to start (Start Numbers 1-90-187 and - l 1-90-188) are considered to be nonvalid failures per Regulatory Guide 1.108, j Section C.2.e. These failures did not result from a malfunction of diesel <
; subcomponents or from a bona fide diesel trip signal. As of 6-19-90, there
- had been 87 valid tests including 4 valid failures for diesel generator IA. !
Also, there had been 1 valid failure in the last 20 valid tests. Since 19 consecutive f ailure free demands had been performed since the last valid 1
- failure, the required test frequency per 15 Table 4.8-1 is once per 31 days. l
! Based on post event interview statements made by the painters, the tape was ! ! applied to the diesel during the morning / afternoon of 6-18 30. Therefore, ! the 1A diesel was unavailable for emergency operation for an approximate 31 ; l j to 36 hour period until removal of the tape was complete at 0121 CDT on j 6-20-90.
- Following the discovery of the inoperable condition of the 1A diesel, the operability of the required A. C. offsite sources was verified by 0027 CDT
- and the operability of the 18 diesel was verified by 1127 CDT on 6-20-90.
- This indicated that there was a source of A. C. power availatle for both i Train A and Train 8 safe shutdown components during the time that the 1A l
diesel was inoperable. Additionally, all Train B safe shutdown components ! were operable during this time with the exception of I out of 4 Train B l containment cooler fans. (Note: The inoperable containment cooler fan was
- restored to operable status at 1415 CDT on 6-19-90). Therefore, had a loss
! of offsite power occurred during the time that the lA diesel was inoperable, i all required safety functions could have been performed by Train B ! components with the possible exception of the containment cooler fans. The capability of the containment cooler fans to perform their safety function
- may have been degraded since only three Train 8 containment cooler fans were available during a portion of this time. However, no event occurred during this time which required the containment coolers to perform their safety Based on these considerations, the inoperable condition of the
! function. i 1A diesel did not adversely affect plant safety or the health and safety of the public. F. CORRECTIVE ACTIONS i 1. The 1A diesel generator was restored to operable status at 0554 CDT on , ! 6-20-90 and all painting within the 1A diesel generator room was ! temporarily stopped.
- 2. The IWO for painting of the 1A diesel was returned to the Work Planning
- Group and reclassified as a critical component MWO.
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- 3. An interim painting walkdown checklist has been developed to ensure operability concerns are identified and addressed prior to allowing the 1
application of tape, masking material, or paint to plant equipment. The ' checklist also addresses operability concerns which may be created by placing scaffolding and/or ladders near operable equipment. In addition to an Operations Department representative, technically qualified 1 individuals from departments may be designated by the checklist to participate in the walkdown and/or operability review. ! 4. The interim painting walkdown checklist has been implemented for all j areas in the plant where painting is currently in progress. l 5. Procedure 29402-C, "WPG Work Request Processing," will be revised by i 9-1-90 to require the painting walkdown checklist to be made part of the i ! MWO package. 1 4 G. ADDITIONAL INFORMATION 1 i 1. Failed Components Identification None i
- 2. Previous Similar Events
, None . 3. Energy Industry Identification System Codes i
- Emergency Onsite Power Supply System - EK j Containment Fan Cooling System (PWR) - BK 4
J l 4 f 4 ' l 1
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