ML20078F560
ML20078F560 | |
Person / Time | |
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Site: | Vogtle ![]() |
Issue date: | 01/04/1995 |
From: | AFFILIATION NOT ASSIGNED |
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References | |
CON-#195-16284 OLA-3-A-001, OLA-3-A-1, NUDOCS 9502020156 | |
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g/skou d % JAN 30 P12:14 WM SttpuTRions Relating to Om Repucter_ C < Re,1e r A1.leaations a Illeaal License Transfer 8 W Fn D x WiMY DOCKEI E m 1RWCE The Formation of Southern Nuc19/$rNW
- 1. The Southern Company is the parent firm of several electric utilities, including Georgia Power Ccmpany ("GPC") and Alabama Power Company ("APC"). GPC is the licensed operator and principle swner of the Vogtle and Hatch nuclear plants in Georgia. APC owns the Farley nuclear plant in Alabama and was its licensed operator
. until November 1991.
- 2. The Southern Company is also the parent firm of Southern Company Services, Inc. ("SCS"), a service organization, and the Southern Nuclear Operating Company (" Southern Nuclear"), a corporation formed to operate the Farley, Hatch and Vogtle nuclear plants
- 3. The formation of a separate nuclear operating company was recommended in 1987 by a task force of GPC and APC personnel. It was envisioned that the nuclear operating company would be the repository of the Southern system's collective nuclear expertise, would thereby maximize the safe and efficient operation of the O system's plants, and would not have any ownership interest in the plants or right to power output.
- 4. Because of co-owner and regulatory approvals required to form Southern Nuclear, the formation and transfer of responsibility was divided into three phases, as follows:
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- a. In Phase I, Southern system nuclear personnel from GPC, APC and SCS, other than nuclear plant personnel, are consoli-dated into a project organization referred to as the "SONOPCO i Project" and relocated to a single, central location. All personnel remain employees of GPC, APC or SCS.
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- b. In Phase II, after SEC approval, Southern Nuclear is incorporated as a wholly owned subsidiary of The Southern Company and all SONOPCO Project personnel are transferred from GPC, APC or SCS, as the case may be, to Southern Nuclear.
However, GPC and APC officers retain their positions and O responsibilities. With the exception of the on-site Safety i Audit and Engineering Review staff, who transfer to Southern Nuclear, plant personnel remain solely employees of GPC or -
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8 Stipulations, or portions thereof, which are marked witn 0 an asterisk are not agreed to by Intervonor. (Intervenor dis-agrees only with the underscored portion of Stipulation No. 32.)
Stipulations, or portions thereof, which are marked with a double asterisk are not agreed to by Intervenor and the NRC Staff. l 9502020156 950104 PDR ADOCK 05000424 O 0 PDR ,
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APC, as the case may be. All Southern Nuclear management O
personnel in the reporting chain above the plant General Managers are officers of Southern Nuclear and GPC, Southern Nuclear and APC or Southern Nucle;n. , GPC and APC, such that the NRC operating license holder always has management cos. trol over licensed activities. The GPC cnd APC Executive Vice Presidents report directly to the presidents of GPC and APC with respect to plant operations and all administrative O matters concerning GPC and APC plants and personnel, respec-tively. The Southern Nuclear Executive Vice President reports to the Southern Nuclear CEO concerning Southern Nuclear matters only. In this phase, Southern Nuclear has no manage-ment authority respecting GPC or APC matters, including rights under the NRC operating licenses.
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- c. In Phase III, after NRC approval, the NRC operating licenses for Plants Hatch, Vogtle and Farley are amended to designate Southern Nuclear as the exclusive operating licensee of each plant. GPC and APC remain on their respective licenaes as licensed owners. No changes occur in the owne -
O ship of, or entitlement to power output from, the plants. All plant personnel are transferred from GPC or APC, as the case may be, to Southern Nuclear. All Southern Nuclear management personnel will be officers of Southern Nuclear only, which will have exclusive control over licensed activities under the direction of the Southern Nuclear CEO. Southern Nuclear will O perate the plants pursuant to operating agreements entered into with the plant owners, or, in the case of Plants Hatch and Vogtle, with GPC as agent for the plant owners.
- 5. On March 2, 1988, GPC, APC and SCS personnel met with the NRC to discuss licensing considerations related to the formation of q' Southern Nt.ilear. The substance of that meeting is summarized in the NRC's March 9, 1988 letter (and enclosures) concerning the March 2, 1988 meeting, attached as Exhibit 1.
- 6. On March 18, 1988, representatives from GPC, APC and SCS met with the NRC to discuss details of the NRC operating license 73
amendments which would be required to properly transfer control of the operation of the system's nuclear plants to Southern Nuclear.
The substance of that meeting is summarized in the NRC's March 25, 1988, letter (and enclosures) which is attached as Exhibit 2.
- 7. On April 20, 1988, the GPC Board of directors elected Mr. R.
Patrick Mcdonald (who was already an officer of APC) to be a senior O officer of the GPC, giving the GPC Chairman of the Board authority to designate his title. GPC's Chairman designated Mr. Mcdonald as Executive Vice President - Nuclear Operations, effective Apr il 25, 1988. S_93 GPC's Minutes"of the Directors Meeting dated April 20, 1988, and Mr. Robert W. Scherer's designation letter dated April 22, 1988, attached as Exhibit 3. From that day forward, until his O,
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t retirement on June 1, 1993, Mr. Mcdonald was the GPC senior i O executive directly responsible for nuclear operr.tions.
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- 8. On May 18, 1988, The Southern Company Board of Directors and I the GPC Board of Directors passed resolutions authorizing eventual "
formation of a new subsidiary to operate the nuclear facilities owned by subt..idiaries of The Southern Company. En The Southern ,
V n Company Minutes of Special Meeting of the Board of Directors :
attached as Exhibit 4 and the GPC Minutes of Organizational Meeting !
of Directors attached as Exhibit 5. On cist saae date, the GPC !
Board of Directors elected Mr. William G. H thston, III to the position of Senior Vice President - Nucl(ar Operations of GPC and Mr. Charles K. McCoy to the position of Vica % resident - Nuclear of ;
GPC. S1q Exhibit 5.
- 9. In June,1988, The Southern company filed a Form U-1 "Applica-tion or Declaration" with the Securities and Exchange Commission !
("SEC") to form Southern Nuclear an a. wholly owned subsidiary. A :
copy of the Form U-1 Application or Declaration, with the exhibits ,
described below, is attached as Exhibit 6. Exhibit B-1 of that O filing is a form of Agreement for Shared Employment which was entered into by Mr. Mcdonald, GPC and APC on June 1, 1988 and which provided, in part, that as an employee of GPC, Mr. Mcdonald "shall :
devote his time, attention, and energies in the performance of the i duties designated by GPC, and will, during such time, be under the i sole supervision, direction and control of GPC," (An executed copy ;
.O of the agreement is attached as Exhibit 7). Exhibit B-2 of that Form U-1 is a copy of the " Phase I" organizational structure. I Exhibits B-3 and B-4 depict the Phase II and Phase III organiza- [
tions, respectively, as they were then envisioned. That SEC filing !
contemplated that control over actual plant operations would remain '
with the licensed operators, i.e. , GPC and APC, until the operating O licenses were amended by the NRC to designate Southern Nuclear as the sole licensed operator, i.e., until Phase III. Sam, e.o., SEC i Notice of Filing (Release No. 35-24694), dated August 12, 1988, '
attached as Exhibit 8. -
- 10. On July 25, 1988, GPC personnel met with NRC Region II staff O to discuss the GPC nuclear plant operations organization and the planned reorganization. An organizational chart depicting the
" Nuclear Operations - Transition Organization" was provided to the NRC identif ying Mr. Mcdonald as the Executive Vice Preside"t -
Nuclear Operations. A copy of % meeting summary issued by the .
NRC on August 11, 1988 is attact u as Exhibit 9. )
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- 11. On September 21, 1988, Mr. Edward L. Addison, Pr sident of The Southern Company, issued an informational memorandum to all employees of GPC, APC and SCS briefly describing the progress made on the phased formation of Southern Nuclear. That memorandum, a copy of which is attached as Exhibit 10, announced the implementa- !
O tion of Phase I and stated that Mr. Mcdonald would serve as ;
Executive Vice President of both GPC and APC and would be responsi- ,
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O ble for the operation of Plants Hatch, Vogtle and Farley.
Mr. Addison also noted that each company, as the licensee, would be O responsible for operating its respective plants.
- 12. On or about November 1, 1988, the GPC, APC and SCS personnel who would be working within the SONOPCO Project were physically consolidated in the Birmingham, Alabama offices of SCS. Ege NRC Inspection Report dated February 7, 1989, attached as Exhibit 11, C) Enclosure 1 at 2.
- 13. On November 23, 1988, GPC submitted to the NRC Amendment No.
39 to the Plant Vogtle Final Safety Analysis Report ("FSAR"). That amendment included changes to the GPC organization and specifically described the Executive Vice President -
Nuclear Operations
() position as one which was shared between GPC and APC and which reported directly to the chairmen and CEOs of those companies concerning GPC and APC matters, respectively. The GPC letter and selected pages of the attachment to that letter are attached as Exhibit 12.
() 14. In December, 1988, the NRC conducted an inspection of the GPC corporate offices in Birmingham to review areas of corporate organization, responsibilities, and functions. A management meeting was also held on December 19, 1988. In rcspor:ie to an NRC inquiry during the inspection, GPC notified the NRC by letter dated December 29, 1988 (attached as Exhibit 13) that the nuclear support O departments in the corporate office were " organized as a staff function to support the plant operation and not as a line function to direct the operation of the plant." The letter further stated that line management direction for operation of the plant was provided by the Executive Vice President, the Senior Vice President ;
- Nuclear Operations, and the Vice President - Nuclear, as shown on FSAR Figures 13.1.1-2 and 13.1.1-3.
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- 15. The NRC issued a report on the December, 1988, inspection on !
February 7, 1989, which is attached as Exhibit 11. The inspection ,
report states: '
O In preparation for combining the management of Vogtle, Hatch l and rarley into one organization, GPC has reorganized and ;
moved the corporate nuclear operations to Birmingham. . . .
l Currently, the Executive Vice President and Senior Vice President for Nuclear Operations are officers of both GPC and l
APC. .. . The Vice Presidents for each of the three projects !
(Vogtle, Hatch and Farley) report to the Senior Vice President l O of Nuclear Operations. '
The inspection report also concluded that the corporate organiza-tion was functioning as described in FSAR Amendment No. 39 and that
"[t]he philosophy of operations of the corporate staff functioning in a support role as opposed to an overview role appears sound."
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- 16. On July 25, 1989, GPC and SCS personnel met with NRC personnel O to discuss the Southern Nuclear /GPC organizations and generic activities. An overview of the then-current organization status was provided to NRC, including corporate structure, responsibili-ties and interface with the plants. A summary of that meeting, prepared by the NRC on August 3, 1989, is attached as Exhibit 14.
- 17. On March 28, 1990, GPC submitted to NRC the initial Updated O FSAR pursuant to 10 C.F.R. S 50.71(e). That update included a revised organizational chart which showed that the Executive Vice President - Nuclear Operations, an officer of both APC and GPC, reported to the President and CEO of GPC. A copy of that organiza-tional chart and the GPC transmittal letter is attached as Exhibit 15.
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- 18. On November 9, 1990, the Vogtle Plant Review Board ( " P&' )
approved a proposed letter to the NRC describing the anticipated incorporation of Southern Nuclear Operating Company (" Phase II")
and including a safety evaluation of Phase II that no unreviewed safety question was involved with the change and that prior NRC
() approval was not required. A copy of that safety evaluation attached to a contemporaneous regulatory analysis is attached hereto as Exhibit 16. The letter to the NRC was sent on December 6, 1990 and is attached as Exhibit 17.
- 19. On December 17, 1990, following receipt of approval from the
=O Securities and Exchange Commission, Southern Nuclear Operating Company was incorporated. e S_eg Articles of Incorporation attached as Exhibit 18.
- 20. On January 1, 1991, the next step in the formation of Southern Nuclear went into effect. E_eg e Transcript of January 11, 1991 O Meeting between Southern system personnel and the NRC Staff attached as Exhibit 19, at pp. 6, 32-35, 47.
- 21. On January 11, 1991, GPC, AP" and Southern Nuclear personnel met with the NRC to discuss Phase II of the formation of Southern Nuclear. A copy of the transcript of that meeting, an attendance O list signed by the attendees, and a copy of GPC's errata sheet for the transcript are attached hereto as composite Exhibit 19. The organizational chart which was referred to throughout the meeting was the one provided by GPC to NRC along with its December 6, 1990 letter.
O 22. On March 28, 1991, GPC submitted to the NRC Revision No. 1 to the Plant Vogtle Updated FSAR, reflecting changes to the organiza-tion as of September 28, 1990. A copy of the transmittal letter and selected pages relevant to the organizational structure are attached hereto as Exhibit 20.
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- 23. On May 5, 1991, APC submitted to the NRC an application to U, amend the Plant Farley operating license to designate Southern Nuclear as the exclusive operating licensee of Plant Farley.
- 24. On May 21, 1991, Mr. R. P. Mcdonald became President of Southern Nuclear and remained Executive Vice President of GPC. Mr.
J. M. Farley, the CEO of Southern Nuclear, also became Chairman of the Board. A letter describing that change was sent by APC to the
'O NRC on June 20, 1991 and is attached hereto as Exhibit 21,
- 25. In early September,1991, the NRC Resident Inspector for Plant Vogtle performed an inspection of GPC's corporate offices in Birmingham for the purpose of gaining a "more detailed working knowledge of the numerous Vogtle support activities and to learn O more about how the support groups are organized, function, and interact." NRC Inspection Report No. 91-22, dated October 28, 1991, attached hereto as Exhibit 22, report " Details" at 13. The inspectors found, among other things, "throughout their discussions
[with corporate office support personnel) that virtually every individual placed emphasis on their role as primarily being a
- O support function to the site." Id_,.
- 26. On November 22, 1991 the NRC issued an amendment to the Plant Farley operating license designating Southern Nuclear as the ,
exclusive operating licensee of Plant Farley and a licensee in that capacity. APC employees at Plant Farley were transferred to
-O Southern Nuclear. A copy of the NRC cover letter and the NRC's Safety Evaluation for those license amendments are attached hereto as Exhibit 23.
- 27. In May, 1992, Mr. W. G. Hairston, III was promoted to Executive Vice President of Southern Nuclear and Mr. R. P.
.O McD nald, President of Southern Nuclear, replaced Mr. Farley as CEO. Mr. Farley continued to serve as the Chairman of the Board of Southern Nuclear. Ees e Southern Nuclear's letter to the NRC dated May 26, 1992, attached as Exhibit 24 and Southern Nuclear Board of Diractors Meeting Minutes dated May 11, 1992, attached as Exhibit 25.
- 28. On September 18, 1992, GPC submitted to the NRC an application to amend the Plant Vogtle Operating Licenses designating Southern Nuclear as the exclusive operating licensee of the plant (the
" Application").
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- 29. On September 28, 1992, GPC and Southern Nuclear personnel met with the NRC Staff to discuss the Application. A copy of the meeting transcript is attached hereto as Exhibit 26.
- 30. On October 14, 1992 NRC published in the Federal Register a proposed finding of "no significant ha c. ds consideration" with respect to GPC's Application.
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- 31. On October 23, 1992, GPC amended its application to reflect g the retirement of Mr. J. M. Farley. Mr. Farley retired effective November 1, 1992. A copy of GPC's letter to NRC is attached as Exhibit 27.
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- 32. Effective June 1, 1993, Mr. R. P. Mcdonald retired. Mr.
Hairston was elected President and Chief Operating Officer of ,
.O Southern Nuclear as well as Executive Vice President of GPC. Mr.
Allen Franklin, President and CEO of SCS, was elected Chairman and
. CEO of Southern Nuclear. A copy of GPC's May 21, 1993 letter notifying NRC of these changes is attached hereto as Exhibit 28.
Sag Southern Nuclear Board of Directors Meeting Minutes dated May 3, 1993 (attached as Exhibit 29) and GPC Minutes of Organizational Meeting of Directors dated May 19, 1993 (attached as Exhibit 30).
- 33. Effective June 4, 1993, Mr. J. D. Woodard was elected to succeed Mr. W. G. Hairston as Senior Vice President of GPC and Executive Vice President of Southern Nuclear. A copy of GPC's June 14, 1993 letter notifying NRC of this change is attached as Exhibit 31.
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- 34. Effective January 1, 1994, Mr. A. W. Dahlberg was elected President of The Southern Company; Mr. H. A. Franklin was elected to succeed Mr. Danlberg as President and CEO of GPC; Mr. W. G. i Hairston (while remaining President of Southern Nuclear and Executive Vice President of GPC) was elected to succeed Mr.
O Franklin as CEO of Southern Nuclear; and Mr. Paul DiNicola was elected President and CEO of SCS (and as such serves on the Board of Directors of Southern Nuclear). Sag Board Notification 94-01, dated January 3, 1994. E.ee also Southern Nuclear Board of Directors Meeting Minutes dated December 13, 199.3 (attached as Exhibit 32).
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The Hobby Allecationsi ;
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- 35. On April 26, 1989, Marvin Hobby, then GPC's General Manager of Nuclear Operations Contract Administration wrote a memorandum to O Mr. Fred Williams, then GPC Vice President -
Bulk Power. The memorandum, attached as Exhibit 33, (which was received into 1 evidence without objection and identified as Complainant's Exhibit 4 19 in Hobby v. GPC, DOL Case No. 90-ERA-30, Tr. 10) stated:
1 j At the April 19 Subcommittee for Power Generation meeting, Mr. ,
9 Dan Smith requested a response to the following. The wording !
is taken from the minutes exactly as Dan stated.
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" Dan Smith requested that Oglethorpe be provided an organiza-tion presentation by SONOPCO on the reporting chain up through the Board of Directors for Mr. George Hairston, Mr. R. P. !
g Mcdonald, Mr. Joe Farley. He specifically asked how Mr.
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Farley fits into the picture and who he reports to up through the Board."
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- 36. On April 27, 1989, Mr. Hobby prepared another memorandum to Mr. Williams. The memorandum, attached as Exhibit 34, (which was received into evidence without objection and identified as Complainant's Exhibit 21 in Hobby v. GPC, DOL Case No. 90-ERA-30, Tr. 10) was signed by Mr. Hobby and by Mr. George Head, GPC Senior O vice president. It stated in part:
A significant concern that a lot of people have is who does ;
Mr. Mcdonald work for. I have heard discussions on that at high levels in the Company. It is a very important question because the operating licenses for Hatch and Vogtle are in
.O GPC's name; for Farley, APC. I am not a lawyer or licensing specialist, but I believe both will tell you that it is essential that GPC and APC be in control of these plants.
Oglethorpe Power is so concerned that it has formally request-ed confirmation that Mr. Mcdonald receives his management ,
direction from and reports to Mr. Dahlberg. If that is not G the case, we are in violation of our license and could experience some significant repercussions from ' the NRC -- >
including the revocation of the licenses.
Oglethorpe is very concerned about this issue and they feel NRC is concerned. A Region II NRC employee soggested to O Oglethorpe that NRC was so concerned that they might seek to put a resident inspector in Birmingham to see what was going on.
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- 37. On May 15, 1989, Mr. Williams transmitted a memorandum to Mr.
Hobby. It stated:
O In response to your questions in your letter of April 26, 1989, I have the following reply.
Mr. R. P. Mcdonald reports to A. W. Dahlberg for operation and support activities of Plants Vogtle and Hatch. I have O attached a copy of the most recent published organization chart showing the reporting. Mr. George Hairston reports to Mr. Mcdonald.
Mr. J. M. Farley, Executive Vice President - Nuclear, provides ,
services relating to the anticipated transfer of nuclear O perating and support activities from Georgia Power Company to the Southern Nuclear Operating Company. These services l include the compliance with applicable regulatory requirements and for nuclear support on an industry basis.
A copy of this memorandum is attached as Exhibit 35 (which was
,0 received into evidence without objection and identified as l
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O Respondent's Exhibit 14 in Hobby v. GPC, DOL Case No. 90-ERA-30, n
%) Tr. 12).
- 38. As an employee of GPC in 1988, 1989, and 1990, Mr. Hobby's office and principal place of business were in Atlanta, Georgia.
In June, 1988, Mr. Hobby had been askLd if he wanted to be considered for a position in the SONOPCO Project in Birmingham, but U he did not want a position in the new organization. His employment with GPC terminated in January, 1990.
- 39. The corporate offices of the SONOPCO Project and Southern Nuclear have been located in Birmingham, Alabama since November 1, 1988. Mr. Hobby did not frequently visit the SONOPCO Project corporate office while an employee of GPL.
- 40. Mr. Hobby asserted in a complaint before the U.S.
Department of Labor (" DOL") that GPC discriminated against him in part because of the concerns expressed in the memoranda above.
After an evidentiary hearing, an administrative law judge rejected Mr. Hobby's allegations and recommended dismissal. Marvin B. Hobby O v. GPC, DOL Case No. 90-ERA-30, Recommended Decision and Order (Nov. 8, 1991). A copy of that Recommended Decision and Order was attached as Exhibit 5 to Georgia Power Company's Answer to the December 9, 1992 Amended Petition of Allen L. Mosbaugh, dated December 22, 1992. The Recommended Decision and Order is currently pending before the Secretary of Labor for a final decision.
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- 41. In the hearing on Mr. Hobby's DOL complaint, individuals testified as follows:
- a. Mr. Dahlberg testified that the operation of GPC's nuclear facilities is his direct responsibility, that Mr.
O Mcdonald takes his management direction from Mr. Dahlberg regarding the operation of GPC's nuclear plants, and that Mr.
Mcdonald reports to Mr. Dahlberg for management operations dealing with GPC's plants. Tr. 305, 307, and 309.
- b. Mr. Farley testified that he does not have any responsi-O bility for operating GPC's nuclear facilities and that Mr.
Mcdonald does not report to him with respect to the operation of Hatch and Vogtle. Tr. 547-68.
- c. Mr. Mcdonald testified that he reports to Mr. Dahlberg regarding the operation of GPC's nuclear facilities. Tr. 613-O 14-
- d. Mr. Hobby testified that his concern regarding Mr.
Mcdonald's reporting to Mr. Farley was not based on direct personal observation, and that he had no personal knowledge of a single instance that Mr. Mcdonald received his management O direction from Mr. Farley with respect to licensed activities.
Tr. 239.
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- e. Mr. Hobby testified that the believed that Mr. Mcdonald O
took his management direction from Mr. Farley in part because when interface problems arose between Mr. Hobby's Nuclear Operations Contract Administration group in Atlanta and Mr.
Mcdonald in Birmingham, Mr. Dahlberg did not seem able to straighten the problems out. Tr. 244.
- f. Mr. Hobby testified hr doas not remember any other GPC O officer, other than Hr. H e .s d , agreeing that his concern was '
meritorious. Tr. 244
- g. Mr. Head testified that he signed his name to Mr. Hobby's April 27,1989 memorandum only because he thought that his signature might help Mr. Hobby later on to get some of the
() issues addressed in the memorandum resolved. He did not view the memorandum as raising a regulatory concern because he was very well aware that Mr. Mcdonald reported to the President of GPC based on his personal experience. Tr. 648-49.
- h. Mr. Hobby testified that he never discussed tha issue of (j the SONOPCO Project reporting structure with any of the parties involved ( h , Mr. Dahlberg, Mr. Mcdonald, or Mr.
Farley). Tr. 250-51. He had the opportunity to file a corporate concern regarding the reporting structure of the SONOPCO Project but made the decision not to do so. Tr. 250.
He did not bring his concern to the NRC until after filing his O DOL e mplaint against GPC. Isl.
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- 42. In an August 22, 1990 deposition in Hobby v. GPC. DOL Case No.
90-ERA-30, Mr. Hobby testified as follows:
- a. Mr. Hobby testified he had told Vogtle co-owners in 1989 O that it was very clear that the organizational chart of the SONOPCO project showed that Mr. Mcdonald reported directly to Mr. Dahlberg and he had no reason to believe otherwise. Dep.
Tr. 301.
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- b. Mr. Hobby testified that he did not believe Mr. Mcdonald j O re elved his anagement direction solely from Mr. Dahlberg and was concerned that Mr. Mcdonald was getting a significant portion of his management direction from Mr. Farley. Dep. Tr.
302, 310, 353.
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- 43. In a May 7, 1990 deposition in Hobbv v. GPC. DOL Case No.
90-ERA-30, Tr. 12-15, 37-40, Mr. Joseph Farley responded to
.O questions from Michael Kohn as follows:
A. We have a close. relationship as we_ have had for many years b~ u. t our responsibilities are different and only in the sense of some administrative matters does he report
.O to me or work with me. Our relationship is more informal than simply reporting.
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J Q. Okay. The question was, in essence then, on paper Mr.
Mcdonald does not technically report to you but he does in an informal sense?
A. On some matters in an informal sense, b Q. Can you tell me which matter on an informal sense?
A. In an informal sense, he and I jointly are what we describe project.
as an office of the chief executive of the It is not a corporation. It is a project. In areas such as the selection of a candidate for an 0 accounting job or a job in the non-operating areas. When I say operating, I mean the operating of the power plants themselves. He does not report to mie and yet on the other areas, particularly administrative or in governmen-tal aff airs which is part of my responsibility, he would report to me in that [ informal) sense. If he were asked O about volunteering to be a witness in a congressional proceeding having to do with advanced light water reactors, he would ask me about it before he would accept that. That relationship, however, does not apply when it comes to Plant Vogtle, Plant Hatch or Plant Farley where he does not report to me but reports to the chief q" executive officer of Georgia Power Company or Alabama Power Company respectively.
Q. He reports to those individuals?
A. Yes.
o Q. But he discusses the operation of those facilities with you?
A. He keeps me informed.
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A. Yes, The Vice President of Administrative Services, that's Mr. McCrary. He is a Service Company employee.
He reports both to me and to Mr. Mcdonald. He reports to what I described earlier as a kind of an office of the
,, chief executive for the project on administrative
'J matters, not on technical matters.
Q. Mr. Long and Mr. McCrary report directly to Mr. Mcdonald and then through there they report directly to you?
, A. Mr. Long does not report to me. Now, Mr. McCrary - -
J l because this is a technical area with which I do not v
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exercise direct ' supervision, I work with that group.
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, They are, in essence, under me in the organization but .
they do not report to me. They report to Mr. Mcdonald. I In the case of Mr. McCrary, for purposes of this project, there are many things that Mr. McCrary reports to directly to me about and others he reports jointly to me and to Mr. Mcdonald or to whichever one of us happens to be there. Mr. Mcdonald and I undertake to be in this
-O transition period of sort of a joint office for the administrative side. I can furnish you the organization chart if you want. It's the same chart that's a record with the SEC....
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Q. (By Mr.Kohn) Was there a document presented to the
- Southern Company Board of Directors regarding the structure of SONOPCO and/or the SONOPCO Project? ;
A. I report to the Southern Board quarterly on the status of
- O the organization in what we're doing. Again, when we '
received or when they approved the concept they did not actually give - - they have no authority to actually
, approve anything other than the filing with the Securi-ties and Exchange Commission. The structure is that that
, filing has to precede their approval. But since that
- O time I do not think they have received a document other than just the current report from me quarterly on the
- progress and performance. ,
f Q. Quarterly report on the progress of formation of the SONOPCO Corporation?
O A. Of the performance of the units and the progress toward our ultimate organization and that's a verbal report.
Q. And where do you obtain 3 ar information to the Board of the statua?
O A. I know the information. I receive of course (as everyone else does) reports from the people with whom I work. I receive reports from Mr. Mcdonald, Mr. Hairston, Mr.
McCoy, Mr. Long, Mr. McCrary and I have put tcgether a i format, in my own mind, of what I think is important g which always includes "where are we" in our negotiations toward the creation of the corporate entity which then >
would be much easier for everyone to understand.
Q. And these are oral?
O ^- Y*8-l 1 0
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Q. Are the meetings transcribed?
0 A. The usual minutes simply include Mr. Farley reporting on nuclear performance and the status of SONOPCO. l
- 44. In Hobby v. GPC, DOL Case No. 90-ERA-30, Tr. 283-85, Mr. Tom McHenry testified as follows:
O Q. Nov,, were you familiar with how selections were made for staffing corporate positions in the SONOPCO project for the: Hatch and Vogtle sites?
A. Yes.
- O Q. And what was your role in that?
i A. Well, as part of the Phase 2 task force that I was on there were organizations, structures created for what the new organization would look like. -
- O Once those structures were created, then there was a l
process of -- there was a series of phases I guess as we referred to them, transitional phases to get from twc '
companies to one company, and toward the end of 1988 that ,
process had proceeded to the point where it actually came ;
, down to filling jobs, to selecting people to fill the !
.:0 organization that had been designed.
Q. And do you know how the positions were actually filled?
A. Well, the process was, the decision making process as I
, recall it was done over a period of a couple of days.
'O There was a meeting of senior management consisting of l Mr. Mcdonald, Mr. McCoy, Mr. Hairston, Mr. Beckham -- p that's the group -- and that group of individuals met L privately in a separate, in fact a separate building for i a couple of days and worked out the selection, and sort 1 of working through the organization picking the people
- O that would go into various slots in the new organization.
Q. And at some point during those two days were you called into that meeting?
A. Yes.
O Q. And can you tell us how they were filling the slots when
. you were in the meeting?
A. Well, my involvement in the meeting was to -- you know, I was asked to come into the meeting to provide some O insight I guess on some individuals that people in the ,
room were not familiar with, you know, about their '
O
}
qualifications, about their background, about their performance.
You know, basically there were organization charts, and there were names. You know, these were blank organiza-tion charts that were skeletons showing title, and the l-organizatien charts were being filled out, you know, names were being put in these slots.
Q. And how soon -- Well, after this two-day period where j this meeting was taking place with the senior management, did you have any further involvement in the selection process?
A. Well, I was heavily involved in the, not necessarily the selection process, but the continuation of the selection process in terms of actually working with salary adminis-tration developing the work sheets or whatever they were called to come up with the offers basically, the job offers.
O ,
- 45. Mr. McHenry further testified that he believed the selection process occurred in a two day meeting in the 270 Peachtree Building in Atlanta, that he was present for approximately two hours during the two day meeting, and the he knew of at least one instance in which Mr. Gucwa, the Plant Hatch licensing and engineering manager, O had conversations with Mr. Beckham (Vice President -
Hatch) concerning whom Mr. Gucwa wanted in his organization. Tr. 295-97.
- 46. Mr. McHenry testified that he was involved in the " cascading" of offers to selected employees. For example, Mr. Beckham offered a position to Mr. Gucwa, who in turn offered positions to employees ;
9 belcw him in the organization. Tr. 300.
- 47. Mr. Hobby testified that the only source of information concerning a SONOPCO Project staffing meeting in the 270 Building in Atlanta came from Mr. Tom McHenry. Tr. 227.
g 48. In a May 8, 1990 deposition in Hobby v. GPC, DOL Case No. 90- ,
ERA-30, Tr. 22, Mr. A. W. Dahlberg was asked whether Mr. Louis Long '
and Mr. Charles McCrary reported to Mr. R. Patrick Mcdonald as GPC employees or as APC employees or both and he responded: "I am not sure. I am just not sure whether they're officers of both companies or not. They may have (been). I just don't know."
G
- 49. In a May 23, 1990 deposition in Hobby v. GPC, DOL Case No. 90-ERA-30, Tr. 16-17, Mr. H. Grady Baker responded to questions from Michael Kohn as follows:
Q. Then the discussion was that Georgia Power needed to show g the SEC, NRC and PSC that appropriate administrative oversight existed for the SONOPCO project?
e 1
O A. Not really. The appropriate oversight of SONOPCO exists, n in that the chief operating officer, Pat Mcdonald and the V
CEO or -- not the CEO because it's not a corporation -
but Farley and Mcdonald are officers of Georgia Power Company, reporting to the president Bill Dahlberg.
Mcdonald particularly is a member of Georgia Power's management council and attends most of the meetings of the management counsel or many of the meetings of the O management counsel.
Mcdonald also reports to the Georgia Power board of directors every month, or either Hairston reports to the board of directors every month, and tra board of direc-tors nuclear operations committee meets quarterly, O usually at one of the plants, an<t goes into the opera-tions at great depth.
- 50. In Hobby v. GPC, DOL Case No. 90-E:lA-30, Tr. 690-91, Mr. H.
Grady Baker responded to questions from Michael Kohn as follows:
3 Q. And in that high level role that you played at Georgia Power Company, it was your understanding that Mr. Farley was an officer of Georgia Power Company; correct?
A. Well, I believe I said something to that effect in the deposition that you took, but I dcn't believe that that 9 is in fact true.
Mr. Mcdonald was the executive vice president, [and) the fellow that worked for him, George something or other, was the senior vice president of Georgia Power Company.
My understanding now is that Mr. Farley was not an 3 officer of Georgia Power Company, he was an executive vice president of Southern Company Services, I believe.
Q. Okay. So you believe that Mr. Mcdonald worked for Southern company Services?
3 A. He was an officer of Southern Company Services, as well as an officer of Georgia Power Company according to my recollection, and an officer of Alabama Power Company.
- 51. Mr. Baker further testified that he had relinquished control of the nuclear operations area on the same day that Mr. Mcdonald was elected Executive Vice President of GPC [i.e., in April 1988).
) Tr. 679. Mr. Baker retired from GPC on May 1, 1990.
- 52. In Hobby v. GPC, DOL Case No. 90-ERA-30, Tr. 303-04, Mr.
Dahlberg testified in response to questions as follows:
Q. Mr. Dahlberg, what is Mr. Pat Mcdonald's position with j Georgia Power Company?
)
()
A. He'c an executive vice president.
C) Q. And what are his dutibs and responsibilities?
A. He's responsible directly for the day-to-day operation of the nuclear facilities, the Vogtle facility in Waynesboro, Georgia and the Hatch facility in Baxley, Georgia.
O Q. Who does Mr. Mcdonald report to?
A. He reports to me directly.
Q. Is Mr. Mcdonald also an officer of Alabama Power Company?
O A. Yes, he is an executive vice president of Alabama Power Company, and I believe he is also an officer of Southern Company Services.
- 53. In Hobby v. GPC, DOL Case No. 90-ERA-30, Tr. 633 Mr. Mcdonald
() testified that he was not an officer of Southern Company Services, Inc.
- 54. In Hobbv v. GEg, DOL Case No. 90-ERA-30, Tr. 625-26, Mr. R. P.
Mcdonald testified as follows:
O Q. And d y u recall Mr. McHenry coming into the room where you were meeting with Mr. Hairston and Mr. Beckham and Mr. McCoy?
A. I don't remember it, but he might have.
'q Q. And were the meeting participants in the process of filling out organization charts?
A. Not part of the meeting that I was in, no.
Q. But you're aware that the other individuals were going to g do that, fill out organization charts?
A. The plan for selecting people for the various jobs was worked out ahead of time with the vice presidents and Mr. Hairston, and that plan was --
we had selected Mr. McCoy as a vice president, and then vice presidents were to select the next level under them, and then they C would participate and be the key person to make selec-tions in the organizations beneath them, so that each of the managers would select the people who worked for them.
Q. Isn't it true that people got job offers shortly after that meeting between Mr. Beckham, Mr. McCoy and I) Mr. Hairston?
O
A. I don't know which meeting you're referring to.
Q. The two-day planning session that I talked about earlier.
A. I was not part of the detailed planning and selection process. I don't hnow.
Q. But you did have knowledge of how the selections were
)1 going to occur, didn't you?
A. As I stated before, the process was to take place and we
.got it started by selecting the vice presidents. Then they would select the people who reported to them going kJ down the tier, so that each level would have a hand in selecting the people what was to work for him directly.
Q. And do you have firsthand knowledge of that, sir?
A. I gave the directions, and I had the reports back that that's what was done.
D
- 55. In a September 11, 1990 petition filed with the NRC jointly by Mr. Hobby and Mr. Mosbaugh pursuant to 10 C.F.R. S 2.206, the petitioners alleged inter alia that GPC had illegally transferred control of its nuclear plants to Southern Nuclear. The petitioners asserted that Mr. Farley was responsible for selecting persons to D fill GPC nuclear positions and that Mr. Mcdonald reported to Mr.
Farley administratively. The pstitioners also alleged that Vogtle project management assumed that Mr. Farley, and not Mr. Dahlberg, controlled Vogtle's operation, citini two reasons: (1) a statement by Mr. 'McCoy during a meeting on Vogtle Unit l's Cycle 4 refueling outage that the outage philosophy had been created by Mr. Farley
] and others; and (2) a taped comment by a former SONOPCO manager stGting his belief that, in the event of a significant event at a GFC facility, the corporate duty manager would call Mr. Farley ra ther than Mr. Dahlberg.
- 56. In a decision addressing the illegal transfer of licenses 3 allegation, the Staff concluded that there has been no illegal transfer of responsibility from GPC to SONOPCO for the Vogtle or Hatch facilities. The decision states in part:
(T]he DOL depositions and testimony do provide some support for the contention that Mr. Farley participated to some degree 3 in personnel decisions affecting both SONOPCO and GPC employ-ees, including some who were elected as GPC corporate offi-
> cers. Mr. Farley was Executive Vice President-Nuclear of The Southern Company (parent company of APC, GPC, and Southern Company Services) and was expected to become President and CEO of the SONOPCO project upon its formation. Therefore, his involvement in personnel decisions for employees transferring into or out of the SONOPCO project is not unreasonable.
D
D Further, Mr. Farley's consultation with GPC on other GPC q employees does not conflict with any NRC requirements. Both Mr. Farley and GPC have provided sworn statements and deposi-tions that the ultimate responsibility regarding decisions on assignment of GPC employees rested with the authorized management structure (i.e., Dahlberg, Mcdonald et al. ) . In fact, GPC vice presidents, as officers of GPC, were approved by the GPC Board of Directors. On the basis of this informa-tion, the NRC Staff concludes that the Petitioners' assertions about Mr. Farley's decision-making with respect to GPC employees constitute an insufficient basis for NRC action in this matter.
O I The NRC Staff has reviewed the Vogtle Final Safety Analysis Report, the Vogtle licenses, records of an NRC Special Inspection conducted to review the SONOPCO management organization, and testimony of key officials taken under oath.
The NRC staf f concludes that this information established that O the responsibility for decisions affecting the operation of the GPC plants rests with the GPC's Senior Vice President-Nuclear Operations, Mr. Hairston. While Messrs. Hobby and Mosbaugh express concerns in this area, these concerns do not warrant a conclusion that SONOPCO was in control. Rather, the NRC staff finds that throughout Phases 1 and 2 of the SONOPCO O project, the chain of command was from the respective vice presidents for the Vogtle and Hatch facilities to Mr. Hairston. Mr. Hairston reported to Mr. Mcdonald, who reported to Mr. Dahlberg, President of GPC. Each of these individuals is an elected officer of GPC, and the reporting chain progressed up to the President of GPC. Therefore, the D NRC staf f concludes that there has been no illegal transfer of i responsibility from GPC to SONOPCO for the Vogtle or Hatch facilities.
The Director's decision was subsequently vacated by the Commission.
Georaia Power h (Vogtle Electric Generating Plant, Units 1 and 2;
~
7 Hatch Nuclear Plant, Units 1 and 2), DD-93-08, 37 N.R.C. 314, 322 (1993), vacated, CLI-93-15, 38 N.R.C. 1 (1993).
- 57. As an employee of GPC in 1988, 1989, and 1990, Mr. Mosbaugh's !
office and principal place of business were Plant Vogtle, near Augusta, Georgia. His emplcyment terminated in October,1990. Mr.
9 Mosbaugh never traveled to the SONOPCO Project offices in Birming- i I ham as an employee of GPC. He never personally observed Mr.
Mcdonald receiving his direction from Mr. Farley; nor does he have personal knowledge of the historic relationship between Mr. Farley ,
and Mr. Mcdonald, or between Mr. Dahlberg and Mr. Mcdonald. I 0
l l
~
6L ,
- UMTED STATIES s NUCLEAR REGULATORY COMMISSION '
waswworom. o. c. noses March 9, 1988 socket Nos. 50-348/364 321/366 i 50 a24/425 LICENSES: Alabama Power Company and p Georgia Power Company UTILITIES: Farley Nuclear Plant, Units 1 and 2 Hatch Nuclear Plant, Units 1 and 2 Vogtle Nuclear Plant, tinits I and 2 3
SUBJECT:
SUMMARY
OF MEETING HELD ON PARCH 2,1988 IN ROCKVILLE, MARYLAN BETWEEN NRC AND REPRESENTATIVES OF ALARAMA POWER C GEORGIA POWER COMPANY TO DISCtlSS F09MATION OF A SEP OPERATING ORGANIZATION.
- 3 Discussion The meeting was recuested by Mr. R. P. Mcdonald, Senior Vice President, APC0 to discuss considerations for femation of a separate operating organization to :
operate for Vogtle theUnit APCO 2. and GPC nuclear plants and to complete licensing proceedings 3 A list of meeting attendees is enclosed.
After introductions of persons in attendance, Mr. Mcdonald led the discussion regarding formation of the Southern Nuclear Operating Company (SON 0PCO). !
Mr. L. Long of Southern Company Services continued the discussion of the licensing considerations involved.
3- discussion is enclosed, A copy of the viewgraphs used during the i
Sumary The NRC staff indicated that it was willing to support the effort. Additional D meetings will be required between the NRC staff and utility representatives to discuss details of the proposal to fom the new operating company. Contacts for this effort will be G. Lainas for the NRC (301-492-1453)and Louis B. Long j for the licensees (205-868-5403)
) Edward A. Reeves Sr. Pro act Manager g
Project Directorate II-1. DRPR:NRR awrence P. Crocker, Sr. Proje D anager Project Directorate II-3, DRPR:NRR t 6
) on'B. Hop ins, Project Manager Project Directorate II-3
Enclosure:
As stated
) cc w/encls:
See next page
I 1
Mr. R. P. Mcdonald O 1 Alabama Power Company Joseph M. Farley Nuclear Plant cc: .
1 Mr. Bill M. Guthrie D. Biard MacGuineas. Esquire !
O Executive Vice President Volpe, Boskey and Lyons Alabama Power Company 918 16th Street, N.W.
Post Office Box 2641 Washington, DC 20006 Birmingham, Alabama 35291-0400 Charles R: i.awman !
Mr. Louis B. Long, General Manager Alabama Electric Corporation O Southern Company Services. Inc. Post Office Box 550 i Post Office Box 2625 Andalusia, Alabama 36420 Birmingham, Alabama 35202 Chairman Regional Administrator, Region II Houston County Consissicn U.S. Nuclear Regulatory Connission .
O Dothan, Alabama 36301 101 Marietta Street, Suite 2900 .
Atlanta, Georgia 30303 Ernest L. Blake, Jr., Esquire ,
Shaw, Pittman, Potts and Trowbridge Claude Earl Fox, M.D. '
2300 N Street, N.W. State Health Officer Washington, DC 20037 State Department of Public Health O State Office Building Montgomery, Alabama 36130 ,
Robert A. Buettner Esquire i Balch, Bingham, Baker, Hawthorne, Mr. J. D. Woodard >
Williams and Ward General Manager - Nuclear Plant :
Post Office Box 306 Post Office Box 470 0 Birmingham, Alabama 35201 Ashford Alabama 36312 Resident Inspector U.S. Nuclear Regulatory Consission Post Office Box 24 - Route 2 Columbia, Alabama 36319 l
i
. i e' j o j i
9-
1
'O Mr. George F. Head Edwin I. Hatch Nuclear Plant.
'O Georgia Power Company Units Nos. I and 2 cc:
G. F. Trowbridge, Esq.
g' Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.
Washington, O.C. 20037 1 Mr. L. T. Gucwa Engineering Department Georgia Power Company 9' P. O. Box 4545 Atlanta, Georgia 30302 Nuclear Safety and Compliance Manager Edwin I. Hatch Nuclear Plant O Georgia Power Company P. O. Box 442 Baxley, Georgia 31513 Mr. Louis B. Long ,
Southern Company Services, Inc.
O P. O. Box'2625 Bimingham, Alabama 35202 ,
Resident Inspector '
U.S. Nuclear Regulatory Commission l Route 1 Box 725
~
O Bax!?v. Georgia 31513 Regional Administrator, Region II U.S. Nuclear Regulatory Comission 101 Marietta Street, Suite 2900 Atlanta, Georiga 30323 1 O
Mr. Charles H. Badger i Office of Planning and Budget Room 610 270 Washington Street, S,W. ,
Atlanta, Georgia 30334 - '
O Mr. J. Leonard Ledbetter, Comissioner Department of Natural Resources .
270 Washington Street, N.W.
t Atlanta, Georgia 30334 O Chairman i Appling County Comissioners County Courthouse Baxley, Georgia 31513 ;
l O
i
, Mr. George F. Head Georgia Power Company Vogtle Electric Generating Plant cc:
Mr. L. T. Gucwa Resident Inspector g Manager of Safety and Licensing Nuclear Regulatory Commission Georgia Power Company P. O. Box 572 P.O. Box 4545 Waynesboro, Georgia 30830 Atlanta, Georgia 30302 Mr. Ruble A. Thomas Deppish Kirkland, III, Counsel D Executive Consultant Office of the Consumers' Utility Southern Company Services, Inc. Council P. O. Box 2625 Suite 225 Birmingham, Alabama 35202 32 Peachtree Street, N.E.
Atlanta, Georgia 30302 e James E. Joiner Mr. Paul D. Rice Troutman, Sanders, Lockerman, Vice President & Project Director & Ashmore Georgia Power Company 1400 Candler Building Post Office Box 282 127 Peachtree Street, N.E.
Waynesboro, Georgia 30830 Atlanta, Georgia 30303 O
Danny Feig Mr. J. A. Bailey 1130 Alta Avenue Project Licensing Manager Atlanta, Georgia 30307 Southern Company Services Inc.
P.O. Box 2625 Carol Stangler D Birmingham, Alabama 35202 Georgians Against Nuclear Energy 425 Euclid Terrace Ernest L. Blake, Jr. Atlanta, Georgia 30307 Bruce W. Churchill, Esq.
Shaw, Pittman, Potts and Trowbridge
, 2300 N Street, N. W.
J Washington, D. C. 20037 Mr. G. Bockhold, Jr.
General Manager Nuclear Operations Georgia Power Company .
P. O. Box 1600 O Waynesboro, Georgia 30830 Regional Administrator, Region II U.S. Nuclear Regulatory Comission
, t a ta, eor a b33 D
g'. -
L-
- g-. ENCLSOURE 1 LIST OF ATTENDEES O
MARCH 2, 1988 IO NAME ORGANIZATION d
O R. P. Mcdonald APCo
~
L. Gucwa GPC L. Long SCS O N. Reynolds SCS R. Edwards GPC R. Buittner APCo 7
O T. M. Murley NRR ,
G. C. Lainas NRR l S. A. Varga NRR O J. Scinto OGC E. G. Adensam NRR E. A. Reeves , NRR
O-
- y. ,
ENCLOSURE i l
> 1 l
J l
l
}.
i l
~~
S: c -ER\ \1 : _. E A R :
J
- 3 ERA ~~ING :: V3A\Y :
i
)
P
)
39 l
) >
I
)
0-O SOUTHERN NUCLEAR OPERATING COMPANY c
(SONOPCO) OVERV!EW
'l O Phase Il Task Force
- o O Southern Company Subsidiary to Operate Hatch, Farley and Vogtle jo SG Hatch, Farley, Vogtle -Unit 1 -
Operating 4
io ## Vogtle Unit 2 -
l Load Fuel, March 1989 9 e Owners - Retain Assets and ;
Pbwer Output 1
~
O s
1 I d
r
u u u u u u. ~U U U cu v t
Ooerating - APCO Agreement ~ (Plant Farley)
Operating _ GPC/OPC/MEAG/DAL SONOPCO ~
Agreement" (Plant Hatch)
Operating _ GPC/OPC/MEAG/DAL Agreement" (Plant Vogtle)
o -
o p,rq,.gc'.DA.__,_2:TN;_..R.Tc:
... - .._ - - - = .. . . .- -.... .. - - = = .... .
U # Higher Levels of Performance by Pooling Expertise o -
O Retention and Recruitment of
, New Employees o
- Economies Through Consolidation o
@ Enhanced influence in Industry Matters o e Strategically Positioned for Future D
s
io -
l
!O ORGAN ZAT!ON t lO !
.g
- Onsite Organizational Structure Unchanged >
f Io # Offsite . Organizations Merged i l
et GPC lo ## APC j ## SCS Specialized Nuclear lO Services :
(
l 0 Project Concept jo i
ee Clear Lines of Authority :
O
- -Focused Goals l SS Ease of Project Assimilation ,
Se Competitive Environment i O ,
e O '
z
_ _ _ m m m m v m c Nuclear Operating Company Board of Directors President Technical Nuclear Administrative Services Operations Services Department Department Department Farley Hatch Vogtle Project Project Project Farley Hatch Vogtle Plant Plant Plant
e & u o o ' o' ~ ~ ~ ' o' o o o- O -
Project Organization Project Executive Project Project Corporata Support Quality Assurance Project Project Proj.ect Engineering Maintenance l Administrat.ive & Licensing & Outage Support Support Support On Site -
Project Plant Site Quality Assurance i
) -
I p
.y -.rrT
-- . .! N w: c'Uu R P ". : . ., _r d
l g
Confirm that NRC Management and Policies can support the proposed
)
SONOPCo Licensing Approach in these areas:
3 1. Coordinated Review of all Applications
- 2. "Sholly" Procedure for all Applications 3 ;
- 3. Early Establishment of Probable Review Completion Date l i
)
)
) ,
o .
O O
O O
o _.
C E\ Sl \ G O
O 3
e O
D I
D UK. QU E _. CENS.NG CO \ S J ERA ~~ ON S p . _ _ __ _ _ . . . . _
8 Five Operating Licenses (Hatch, 3 Farley, Vogtle-1) g 8 One Construction Permit (Vogtle-2)
- Two Operating Companies (GPC, APC)
D 8 Three Sites 3 8 Four Southern Licensing Contacts l e Three NRC Project Managers 3
l D
3 . . _ __. . . . . _ _ . _ _ .._.__ _ _
. u o o o o o u o o e-SO N O-)CO _CE\ S NG A3 3 ROAC-e Simultaneous Filing of License Amendment Applications Plant Operator License Owner ee Hatch, Units 1 & 2 GPC OL GPC, MEAG, Dalton ee Farley, Units 1 & 2 APC OL APC se Vogtle, Unit 1 GPC OL GPC, MEAG, s Dalton se Vogtle, Unit 2 GPC CP GPC, MEAG, Dalton i* Applications Essentially Some i e Applications Complete i
i)
O O O O O O O d O^ O SONOPCO PROJECT COORDINATOR FARLEY HATCH s
x VOGTLE PROJECT PROJECT PROJECT MANAGER MANAGER MANAGERS
/
l TECHNICAL BRANCHES l
a o 1 i
,, .\ RC REV!EW l 3
- Integrated Review of all Applications o # "Sholly" Process for all Applications
- Complete "NSHC" Determination a :
- Simultaneously Publish Notices of Proposed Action with "NSHC" 3 Determinations
- Simultaneously Publish Notices of 3 Issuance to be immediately Effective 3
- Early Establishment of Prob.able Review Completion Date _
e 4
O
\
[ o,,
n UNITED STATES I NUCLEAR REGULATORY COMMISSION !
O 2, WASHWG TON, D. C. 20S56 '
%, ...../
MAR 2 519W .
1 O Cocket Nos. 50-348/364 321/366 I 50-424/425 '
LICENSEES: Alabama Power Company anti Georgia Power Company FACILITIES: Farley Nuclear Plant, Units 1 and 2 O Hatch Nuclear Plant, Units 1 and 2 1 Vogtle Nuclear Plant, Units 1 and 2
SUBJECT:
1 MEETING
SUMMARY
FOR MEETING OF MARCH 18, 1988, WITH SOUTHERN COMPANY REPRESENTATIVES REGARDING THE ESTABLISHMENT OF AN .
OPERATING COMPANY FOR THE FARLEY, HATCH AND V0GTLE PLANTS '
O On March 18, 1988, the NRC staff met with representatives of Southern Company Services (SCS), Georgia Power Company (GPC) and Alabama Power Company (APC) in Rockville, Maryland to discuss the infonnation that would be required in a ,
O submittal for amendments to the licenses and construction pennit held by APC and GPC for the Farley, Hatch and Vogtle Nuclear Plants. Attendees are listed in Enclosure 1. The viewgraphs used by the SCS representative in his presentation are in Enclosure 2.
Mr. L. Long of SCS made the presentation. He emphasized that the companies I were still evaluating the idea and concept of an operating compaiy. His O presentation was to describe generally what the licensees propose to include in '
their applications. He covered previous actions that the agency has taken ;
regarding changes in plant operators. The changes in Technical Specifications i were also discussed, including the deletion of the organization charts from the specifications as was done for the Shearon Harris Station. The staff advised him that we anticipate the issuance of the generic letter on this issue in the 9 near future.
There was some discussion regarding the need to file the OL application amendment and the FSAR amendment concurrent with the CP amendment for Vogtle Unit 2. The licensees did not believe that the amendments needed to be sub-mitted concurrently and, in fact, should be done sequentially.
The licensees requested that the staff advise them on the level of detail that would be needed in the applications. The staff suggested to the licensees that they address the following points:
- 1. The responsibilities and authorities of the elements of the new
, organization.
- 2. Identify where tasks were in the old organization and where they will be !
.n the new organizatic:.
1 O
l
O
- 3. Address the corporate aspects of prograccatic areas, such as security and fire protection, in the transfer from the old offsite to the new offsite o organization.
The licensees expressed concerns that we were asking more of them than had been done for other licensees like GPU Nuclear. The staff offered to investigate the level of detail that was required in the change for GPU Nuclear and get back to the licensee.
The licensee indicated that their start date was indeteminate because of other factors, but that following a decision to proceed they would plan to have the amendment applications filed within two weeks. There would be amendment applications for the five operating licenses and the construction permit. The OL application amendment and the FSAR amendment for Vogtle Unit 2 would be
'g filed at a later date. They then requested that the staff conduct its review as expeditiously as possible, preferably within three months. x.
44b M 1" Elinor G. Adensam Director O Project Directorate 11-1 .
Division of Reactor Projects I/II
Enclosures:
As stated cc w/encls: See next page O .
O O
O ;
k O
O
l o
- O Mr. R. P. Mcdonald Alabama Power Company Joseph M. Farley Nuclear Plant O cc:
Mr. W. O. Whitt D. Biard MacGuineas. Esquire Executive Vice President Volpe, Boskey and Lyons Alabama Power Company 918 16th Street, N.W.
Post Office Box 2641 Washington, DC 20006 2,0 Birmingham, Alabama 35291-0400 Charles R. Low.an Mr. Louis B. Long, General Manager Alabama Electric Corporation Southern Company Services, Inc. Post Office Box 550 Post Office Box 2625 Andalusia, Alabama 36420 Birmingham, Alabama 35202 10 Chairman Regional Administrator, Region II Houston County Comission U.S. Nuclear Regulatory Commission Dothan, Alabama 36301 101 Marietta Street, Suite 2900 Atlanta, Georgia 30303 Ernest L. Blake, Jr., Esquire Shaw, Pittman, Potts and Trowbridge Claude Earl Fox, M.D.
!O 2300 N Street, N.W. State Health Officer Washington, DC 20037 f tate Department of Public health State Office Building Montgomery, Alabama 36130 Robert A. Buettner, Esquire Balch, Bingham, Baker, Hawthorne, Mr. J. D. Woodard O Williams and Ward General Manager - Nuclear Plant Post Office Box 306 Post Office Box 470 Binningham, Alabama 35201 Ashford, Alabama 36312 Resident Inspector U.S. Nuclear Regulatory Commission 1g Post Office Box 24 - Route 2 Columbia, Alabama 36319 O
O 4
0
f
). ,
Mr. George F. Head Edwin I. Hatch Nuclear' Plant, Georgia Power Company Units Nos. 1 and 2
).
cc: I G. F. Trowbridge, Esq. ;
Shaw, Pittman, Potts and Trowbridge .
I 2300 N Street, N. W.
) Washington. 0.C. 20037 Mr. L. T. Cucwa Engineering Department .
Georgia Power Company .;
P. O. Box 4545 l Atlanta, Georgia 30302 j Nuclear Safety and Compliance Manager ,
Edwin I. Hatch Nuclear Plant Georgia Power Company i P. O. Box 442 Baxley, Georgia 31513
) l Mr. Louis B. Long Southern Company Services, Inc.
P. O. Box 2625 ;
Binningham, Alabama 35202 .i
)
Resident Inspector U.S. Nuclear Regulatory Commission ,
Route 1, Box 725 .1 Baxley, Georgia 31513 Regional Administrator, Region II
) U.S. Nuclear Regulatory Conuission 101 Marietta Street, Suite 2900 Atlanta, Georiga 30323 !
Mr. Charles H. Badger Office of Planning and Budget '
) Room 610 -
270 Washington Street S.W.
Atlanta, Georgia 30334 ;
Mr. J. Leonard Ledbetter, Comissioner Department of Natural Resources l
) 270 Washington Street, N.W. i Atlanta, Georgia 30334 Chairman Appling County Comissioners County Courthouse Baxley, Georgia 31513
)
) !
3 Mr. George F. Head Georgia Power Company Vogtle Electric Generating Plant cc:
Mr. L. T. Gucwa Resident Inspector Manager of Safety and Licensing Nuclear Regulatory Comission '
Georgia Power Company P. O. Box 572 O P.O. Box 4545 Waynesboro, Georgia 30830 Atlanta, Georgia 30302 Mr. Ruble A. Thomas Deppish Kirkland, III, Counsel Executive Consultant Office of the Consumers' Utility Southern Company Services, Inc. Council O P. O. Box 2625 Suite 225 Binningham, Alabama 35202 32 Peachtree Street, N.E.
Atlanta, Georgia 30302 James E. Joiner Mr. Paul D. Rice Troutman, Sanders, Lockerman, O Vice President & Project Director & Ashmore Georgia Power Company 1400 Candler Building Post Office Box 282 127 Peachtree Street, N.E.
Waynesboro, Georgia 30830 Atlanta, Georgia 303U3 Danny Feig g Mr. J. A. Bailey 1130 Alta Avenue Project Licensing Manager Atlanta, Georgia 30307 '
Southern Company Services, Inc.
P.O. Box 2625 Carol Stangler Binningham, Alabama 35202 Georgians Against Nuclear Energy 425 Euclid Terrace Ernest L. Blake, Jr. Atlanta, Georgia 30307 O Bruce W. Churchill, Esq.
Shaw, Pittman, Potts and Trowbridge 2300 N Street, N. W.
Washington, D. C. 20037 Mr. G. Bockhold, Jr.
O General Manager Nuclear Operations Gecrgia Power Company P. O. Box 1600 Waynesboro, Georgia 30830 Regional Administrator, Region II O U.S. Nuclear Regulatory Comission 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323 O
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ENCLOSURE 1 LIST OF ATTENDEES March 18, 1988 i
NAME ORGANIZATION i r.
E. G. Adensam hRR 1:-
7
) E. A. Reeves NRR L. T. Gucwa GPC I L. B. Long SCS 3 F. Allenspach NRR J. E. Garlington APCo :
G. C. Lainas hRR ,
F.
) L. P. Crocker NRR f;
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J. A. Bailey SCS (i,
D. P. Allison AE00 J. Scinto OGC 3 {
J. Hopkins NRR D. B. MacGuineas Volpe, Boskey & Lyons (for AEC) 4 3 1. Schoenfeld -
NRR !
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O_ ENCLOSURE 2 V EE-~::\ 3 L P:SE O
P Confirm the general acceptability of a the proposed SONOPCO license application regarding: :
- o (i;) Topics included in application
[2:1 Completeness of discussion
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- Application Filed April 15, 1986 P
ee Technical Qualifications
[1-1/2 Pages;l p ee NSHC ee Technical Specification Changes
- Public Notice of Proposed Action with NSHC, August 13, 1986
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3 R4t\ : 3m_ i e Application Filed September 2, 1986 e h eo Technical Qualifications (2 Pages)
- oe NSHC '
b oe Technical Specification Changes
- 3
- Supplemental Information .
ee GDC October 13, 1986 ,
D e* Exclusion and Emergency Preparedness - October 24, 1986 p eo Emergency Plan Transition Plan -
1 November 20, 1986 1
- Consent Letter - November 21, 1986 p
! ee Emergency Plan Agreement - l December 11, 1986 D
ee Switchyard Agreement -
December 23, 1986
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e Granted December 20, 1986 ,
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b A3 PLICA ~IOb "O ANENJ FACI _ITY ,
OPERATING LICENSE h0S. l l
3 General License Revisions I. General Information 2
I' Specific Infarmation Regarding Substantive Issues -
3 III. No Significant Hazards Consideration Evaluation IV. Effective Date :
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V. Consent .l i
J Appendices:
) e License Conditions e Safety Technical Specifications e Environmental Technical
) Specifications
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e 10 CFR 5 0 . 5 4.1:q;I applies a
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EX:_. S:::\ AREA 5
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) e Includes switchyard, transmission lines
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3 III. NO SIGNIFICAN~~ -.AZARDS I CONSIDERATION EVALUATION o
e Proposed Change o e Background e Analysis o e- Conclusion O
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, SAFETY "ECFNICAL SPECIFICATION C-ANGES
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- 6.2.1 Onsite and Offsite Organization '
t ee Figure 6.2 Revised t
- Figure 6.2 Unchanged
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- Shearon Harris Option :
[ January 27, 1988?
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ee Figure 6.2 Deleted
- Figure 6.2 Deleted i
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[ 6.0 ADMINISTRATIVE CONTROLS g i 6.1 RESPONSIBILITY 6.1.1 The Plant General Manager shall be responsible for overall unit opera-tion and ing his shall delegate in writing the succession to this responsibility dur-absence.
y 6.1.? The Shif t Foreman (or, during his absence from the cor 71 rotm, a designated individual) shall be responsible for the control room command func-tion. A management l directive to this effect, signed by the Vice President-Harris basis.
Nuclear Project shall be reissued to all station personnel on an annual g 6. 2 ORGANIZATION l
6.2.1 Onsite and Offsite Orcanization An onsite and an offsite organization shall be established for unit operation l and corporate management. The onsite and offsite organization shall include O the positions for activities affecting the safety of the nuclear power plant.
- a. t.ines of authority, responsibility and communication shall be established -
and defined from the highest management levels through intermediate levels to and including all operating organization positions. Those re-1 lationships shall be documented and updated, as appropriate, in the form of organizational charts. These organizational charts will be documented O in the FsAR and updated in accordance with 10 CFR 50.71(e).
- b. There shall be an individual executive position (corporate officer) in the offsite organization having corporate responsibility for overall plant nuclear safety. This individual shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, anc providing technical support in the plant so that continued nuclear safety is assured.
- c. There shall be an individual management position in the onsite organiza-tion having responsibility for overall unit safe operation and shall have control over those onsite resources necessary for safe operation and O maintenance of the plant.
- d. Although the individuals who train the operating staff and those who carry out the quality assurance functions may report to the appropriate manager onsite, they shall have sufficient organizational freedom to be independent from operating pressures.
O e. i Although health physics individuals may report to any appropriate manager -
onsite, for matters relating to radiological health and safety of employees e and the public, the health physics manager shall have direct access to I '
that onsite individual having responsibility for overall unit management.
Health physics personnel shall have the authority to cease any work l g activity when worker safety is personnel radiation exposures. jeopardized or in the event of unnecessary
- SHEARON HARRIS - UNIT 1 6-1 Amen dme n t No . 3 0
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ADM1HISTRATIVE CONTROLS l
) 5.1 RESPONSIBILITY -
6.1.1 I The General Manager - Nuclear Plant shall be responsible for l overall unit operation this responsibility andhis during shall delegate in writing the succession to absence. t
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6.1.2 The Shift Supervisor or during his absence from the Control Room a designated individual shall be reponsible for the Coatrol Room comand function. ;
Senior Vice President responsible for Nuclear Generation, herea i referred to as Senior Vice President, shall be reissued on an annual basis.
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t 6.2 ORGAS*IATION i
OFFSITE ,
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) 6.2.1 The offsite organization for facility management and technical support shall be as shown on Figure 6.2-1. {
, FACILITY STAFF 4 i 6.2.2 The facility organization shall be as shown on Figure 6.2-2 and:
) a.
Each on-duty shift shall be composed of at least the minimum !
shift crew composition shown in Table 6.2-1. !
- b. At least one licensed Reactor Operator shall be in the I
Control Room when fuel is in the reactor. In addition, at !
3 teast one licensed Senior Reactor Operator shall be in the
- i Control Room while the unit is in MODE 1, 2, 3 or 4.
- c. A Health Physics. Technician i shall be on site when fuel is I in the reactor. ,
3 d. All CORE ALTERATIONS shall be directly supervised by either a i
licensed Senior Reactor Operator or Senior Reactor Operator '
l.imited to Fuel Handling who has no other concurrent responsibilities during this operation. *
- e. A site Fire Brigade of at least 5 members shall be maintained
) onsite at all times.# The Fire Brigade shall not. include 3 members of the minimum shift crew necessary for safe shutdown of the unit and any personnel required for other essential i functions during a fire emergency.
- The Healtn Physics Tecnnician and Fire Brigade composition may be less
) than the minimum requirements for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> t
in order to accomodate unexpected absence of the Health Physics l Technician and/or Fire Brigade members provided immediate action is taken to restore the Health Physics Technician and/or Fire Brigade to. !
within the minimum requirements. !
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- NORD Vice President
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Safety Audit and
- Nuclear Support Engineering Review *
- I Staff I Staff 3FFSITE OFFSITE 3NSITE ONSITE-Supervisor General Manager -
Safety Audit and Nuclear Plant Engineering Review Plant
___ ___ Staff Staff
- Corporate responsibili ty for fire protection
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d K.s. .. ELECTION OF OFFICER f The Chairman recommended that Mr. Robert P. Mcdonald be elected as a senior officer of the company and requested g that the chairman have discretionary authority to designate ii his position as either Senior Vice President (Nuclear Operations) or Executive Vice President (Nuclear Operations) ; l and the effective date of his appointment. EIEREUPON, On motion, duly made and seconded, the
- g following resolution was unanimously adopted
- .
! RESOLVED: That Mr. Robert P. Mcdonald be and hereby
- is elected as a senior officer of the Company an$ that the t Chairman of the Board be and hereby has discretionary ,
! authority to designate his position as, either Senior Vice : .O President (Nuclear Operations) or Executive Vice President i . (Nuclear Operations) and the effective date of his j appointment. i ................................ t i The undersigned officer of Georgia Power Company . J i does hereby certify that the foregoing is a true and correct copy of resolutions duly and regularly adopted at meeting of .
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- the Board of Directors of Georgia Power Company, duly held l i on April 20, 1988, at which a quorum was in attendance and l 4
voting throughout, and that said resolution has not since j i been rescinded but is still in full force and effect. i I I
'O Dated March 1, 1991 A11/%f -
Assistant Secr ary } 3 i
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As.vta Georo,a l')?*,3 Mid.~
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R. W. Scherer ...,,,,,,,,,,,
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O April 22, 1988
- O O I hereby designate Robert P. Mcdonald, Executive Vice President (Nuclear Operations) of Georgia Power Company, effective April 25, 1988.
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- Robert W. Scherer l
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{ THE SOUTHERN COMPANY l h Minutes of < Special Meeting of the Board of Directors Atlanta, Georgia May 18, 1988 At 9:30 a.m., Eastern Daylight Time, on the 18th day of May,1988, the board of directors of The Southern Company met at the offices of the Company, 64 Perimeter Center East, Atlanta, Georgia, pursuant to written , notice.
)
The following directors were present: Edward L. Addison L. G. Hardman, III Alan R. 8arton Douglas L. McCrary William J. Cabaniss, Jr. John M. McIntosh Charles H. Chapman, Jr. Earl D. McLean, Jr. ) William P. Copenhaver William A. Parger, Jr. A. W. Dahlberg H. G. Pattillo Virginia A. Dwyer William J. Rushton, III Jack Edwards Robert W. Scherer Joseph M. Farley Gloria M. Shatto
)' Arthur M. Gignilliat, Jr. Vincent J. Whibbs, Sr. , constituting a quorum of the board. Messrs. Edwards, McCrary, and Rushton participated by telephone.
Tomy Chisholm, Secretary, was also present.
) Alvin W. Vogtle, Jr., advisory director, and John D. McLanahan were present by invitation.
Mr. Edward L. Addison, President, presided and Mr. Tonny Chishol.a acted as secretary.
) Report on Plant Hatch Mr. Scherer presented a report on Plant Hatch.
Report on Matters of Interest Mr. Addison presented a report on matters of interest. (Ms. Dwyer entered the meeting.) Report on Formation of New Subsidiary
) Mr. Addison made a presentation on the formation of a subsidiary to operate the nuclear plants of the Southern electric system. Authority to form a new subsidiary was sought.
A 92 PRCUECT 060490
l q . May 18, 1988 The S:uth:rn Company } The proposal was discussed at length before a vote was taken. Upon motion duly made and seconded, the following resolutions were thereupon unanimously adopted (Ms. Dwyer and Messrs. Copenhaver and Whibbs , abstaining): RESOLVED: That the formation of a new subsidiary of the Company to operate the nuclear generating J facilities owned by subsidiaries of the Company be and it hereby is authorized; and RESOLVED FURTHER: That the officers of the Company be and they hereby are authorized to take, in their discretion, any and all actions necessary or rJ desirable to carry out the foregoing resolution, including without limitation executing and filing any and all documents required by regulatory agencies, in-cluding a statement on Fonn U-1 and any necessary or appropriate amendments thereto with the Securities and Exchange Commission.
)
The meeting thereupon adjourned.
~~ -
cretary 3 J e f 4 92 PROJECT o60491 9 1 i
!, , _ GEORGIA POWER COMPANY I MINUTES OF ORGANIZATIONAL MEETING OF DIRECTORS MAY 18, 1988 The regular monthly meeting of the Company's Board of Directors was held, at the offico of the Company, 333 3-Piedmont Avenue, N.E., Atlanta, Georgia, at 12:00 noon, 4
local time on Wednesday, May 18, 1988, being the time and date for the organizational meeting of the newly elected h Board of Directors as specified in the resolution adopted at the meeting of stockholders of the Company held at 8:30 a.m., local time, May 18, 1988, at The Southern Company, 64
)
Perimeter Center East, Atlanta, Georgia. Announcement re Organizational Meeting The Chairman of the Board announced that this was
) - the organizational meeting of the newly elected Board of Directors which had been elected at the annual meeting of stockholders of the Company held at 8:30 a.m., local time, )
May 18, 1988, at The Southern Company, 64 Perimeter Center East, Atisnca, Georgia. Artendance
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The following directors were present: Edward L. Addison H. G. Baker, Jr. Bennett A. Brown 3 William P. Copenhaver ( Virginia A. Dwyer William A. Fickling, Jr. L. G. Hardman, III Elmer B. Harris
' Warren Y. Jobe ) iiilliam A. Parker, Jr.
i 2 1
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Formation of Southern Nuclear Operatina Company g.- I Mr. Robert P. Mcdonald, Executive Vice President-i Nuclear Operations, reported on formation by The Southern company of a nuclear operating management subsidiary to operate system nuclear plants. The Chairman recommended that the Board approve in principle the transfer of nuclear : management to such subsidiary, authorize the filing of all l i documents required by regulatory agencies and approve the .O i form of agreement for shared employment to pool nuclear management resources with those of affiliated companies. ' WHEREUPON, On motion, duly made and seconded, the ,'O following resolutions were adopted with William F. Copenhaver, 1
- l l
Virginia A. Dwyer and Vincent J. khibbs, Sr. abstaining: . i,
- RESOL 7ED: That the Company hereby approves in io.
~ principle the concept of using a new nuclear management i I subsidiary of The Southern Company formed for the purpose of i operating (but not assuming ownership control over) the O respective nuclear generating facilities of the Company and of Alabama Power Company, which mbsidiary would consolidata
)
l into a single organization the personnel of the Southern O Electric System engaged in nuclear operations: and RESOLVED FURTHER: That the Company hereby approves the Agreement for Shared Employment of nuclear operating O management personnel, in the form presented to this meeting, with such further changes or amendments thereto as the officers of the Company may deem appropriates and O 5/18/88 O
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,i {. RESOLVED FURTHER: That the appropriate officers of [> the Company be and they hereby are authorized to take, in
- 9. . their discretion, any and all actions necessary or desirable to carry out the intent of the foregoing resolutions, includ-ing without limitation executing and filing any and all O
- documents required by regulatory agencies, including filing
! with the Securities and Exchange Consnission a statement on i Form U-l and any necessary or appropriate amendments thereto,
- O and executing and delivering one or more Agreements for
' Shared Employment with Alabama Power Company of Company ] i nuclear management operating personnel. l - r
- 9 i Election of William G. Hairston. III, as Senior Vice President-Nuclear Operations l The Chairman recommended that William G. Hairston, III be elected Senior Vice President-Nuclear Operations of o
Georgia Power Company, effective May 18, 1988. WHEREUPON, On motion, duly made and seconded, the following resolution was unanimously adopted: O RESOLVED: That William G. Hairston, III be and ! I hereby is elected Senior Vice President-Nuclear Operations of Georgia Power Company, effective May 18, 1988. 9 Election of Charles K. McCoy, as Vice President-Nuclear The Chairman recommended that Charles K. McCoy be j elected Vice President-Nuclear of Georgia Power Company, g effective May 18, 1988. WHEREUPON, On motion, duly made and seconded, the following resolution was unanimously adopted: 5/18/88 O! I i e !
w RESOLVED: That Charles K. McCoy be and hereby is elected Vice President-Nuclear of Georgia Power Company, O effective May 18, 1988. Report on Nuclear Operations Mr. Robert P. Mcdonald, Executive Vice President- ~) Nuclear Operations reported on Nuclear Operations. At this time, Mr. Mcdonald left the mekting. Dates of Monthly Directors Meetings O The Chairman recommended that the dates of the regular monthly meetings of the Board of Directors be fixed for the third Wednesday of each month at 12:00 noon during D the ensuing year, with the exception of the June 22 and December 14 meetings or unless fixed otherwise by this Board. On motion, duly seconded and adopted, it was 3 VOTED: That the regular monthly meetings of the Board be held on the third Wednesday of each month at 12:00 noon during the ensuing year, with the exception of the June O 22 and December 14 meetings or unless fixed otherwise by the Board. Employment of Arthur Andersen & Co. to Audit 3 Company's Books for the Ypar 1988 The Chairman recommended that the Board authorize employment of Arthur Andersen & Co. , Accountants and Audi-tors, to audit the Company's books for the year 1988. 3 WHEREUPON, On cotion, duly made and seconded, the following resolution was unanimously adopted: RESOLVED: That the firm of Arthur Andersen & Co., g 5/18/88 D i i
O' .- O File No. 70-7530 SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM U-l O APPLICATION OR DECLARATION under The Public Utility Holding Company Act of 1935 O The Southern Company 64 Perimeter Center East Atlanta, Georgia 30346 Alabama Power Company Georgia Power Company 600 North 18th Street 333 Piedmont Ave., N.E. O Birmingham, Alabama 35291 Atlanta, Georgia 30308 (Name of company or companies filing this statement and addresses of principal executive offices) THE SOUTiiERN COMPANY O (Name of top registered holding company parent of each applicant or declarant) Tomy Chisholm, Secretary The Southern Company 0 64 Perimeter Center East 1 Atlanta, Georgia 30346 Richard A. Bowron, Secretary Alabama Power Company Judy M. Anderson, Secretary ? 600 North 18th Street Georgia Power Company O Birmingham, Alabama 35291 333 Piedmont Ave., N.E. Atlanta, Georgia 30308 (Names and addresses of agents for service) The Comission is requested to mail signed copies of all orders, notices and communications to: ' O W. 1.. Westbrook, Financial Vice President J. R. Harris, The Southern Company Vice President Southern Company Services, Inc. 64 Perimeter Center East One Wall Street, 42nd Floor Atlanta, Georgia 30346 New York, New York 10005 O Walter M. Beale, Jr., Esq. John D. McLanahan, Esq. Balch & Bingham Troutman, Sanders, teckerman 700 Financial Center & Ashmore 505 North 20th Street Birmingham, Alabama 35203 1400 Candler Building O Atlanta, Georgia 30043 i
b O Item 1. Description of Proposed Transactions. O A. The Southern Company (" Southern") is a registered holding company under the Public Utility Holding Company Act of 1935 (the "Act"). i Southern proposes to form, organize and acquire the capital stock of another C direct wholly-owned subsidiary to be incorporated in Delaware and called Southern Nuclear Operating Company, Inc. (sometimes referred to hereinafter as "SONOPC0"), which will provide nuclear operation "arvices, technical 9 services and administrative services (sometimes referred to hereinafter collectively as " nuclear services") to affiliates of the Southern electric system. In the final phase of its implementation, SONOPC0 may also provide g nuclear services to unaffiliated co-cwners of Southern electric system nuclear plants. To the extent feasible and as an incident to its provision of nuclear services to the Southern electric system, SONOPCO may also provide g nuclear services to owners of nuclear fscilities which are not part of the Southern electric system. It is proposed thec, upon obtaining all requisite regulatory 3 authorizations and efter evaluation during a transition period, SONOPC0 will provide nuclear services with respect to the nuclear electric generating facilities owned by the Southern electric system. Presently, two of the e operating companies of the Southern electric system have responsibility for nuclear operations. Alabama Power Company ("APC") owns and is licensed to operate the Farley Nuclear Plant Units 1 and 2 ("Farley"). Georgia Power e Company ("GPC") is a co-owner of and S
O= .Q is licensed to operate the Hatch Nuclear Plant Units 1 and 2 (" Hatch") and g Vogtle Nuclear Plant Unit 1. GPC is also a co-owner of Unit 2 of the Vogtle plant which is scheduled for comercial operation by June,1989 (Units 1 and 2 of the Vogtle Plant are collectively referred to herein as "Vogtle"), g The objective of establishing SONOPCO is to develop an organization that will consolidate personnel of the Southern electric system engaged in ' nuclear operations into a single, integrated group that can pursue, as its O s le Purpose, higher degrees of performance in nuclear operations. Ownership of the plants will continue to reside with APC, GPC and the co-owners of the GPC plants. By consolidating and focusing the management g of its nuclear operations, the Southern electric system will benefit from the availability of specialized management and technical personnel in an area where safety and efficiency are critical concerns. g Salary structures, career path policies and procedures for nuclear employees of SONOPCO are intended to be separate and distinct from the non-nuclear employees of the other Southern system operating companies. g This will permit nuclear management to focus on the qualifications and i requirements of nuclear employees. Human resources and compensation policies tailored to nuclear operations will allow SONOPCO to be competitive O in the market for skilled nuclear professionals without directly influencing, or being restrict'ed by, personnel policies and procedures governing Southern electric system O O
3 non-nuclear personnel. The ability to attract superior nuclear talent and g retain quality individuals once recruited will benefit the Southern electric system and its customers and investors. B. Southern anticipates implementing the SONOPCO operating g structure in a transitional process involving three phases, with each phase being designed to improve the safety and efficiency of the nuclear operations over that obtained in the previous phase. Southern anticipates that each phase of this project will have benefits for system operations independent of the benefits derived from subsequent phases and will evaluate each phase prior to implementation. J The initial phase will be to form a matrix organization in which key management personnel will be shared between APC and GPC pursuant to shared employee agreements in substantially the form attached as Exhibit B-1 ,.s hereto. a No changes in corporate structures will be needed to accomplish this pooling of management resources. Exhibit B-2 hereto presents the matrix organizational structure during phase one. g The second phase, to commence upon approval by the Commission of this Application / Declaration, will entail creation of the nuclear operating company as a service company providing nuclear services to APC and GPC. , Authorization is hereby requested for SONOPC0 to perform a wide range of nuclear services, including without limitation plant operating services, fuel procurement services, engineering services, administrative services , O
0, l O and technical services. Exhibit B-3 hereto presents the anticipated SONOPC0 organizational structure during phase two. Since certain executive management will continue to be en,ployees of both APC and GPC, as is shown in this exhibit, APC and GPC will have direct input into SONOPCO operations through established g management reporting relationships. In the third phase, SONOPCO will become the licensed operator for the nuclear plants and will enter into contracts for the actual operation of the plants. It is contemplated that the nuclear operating company will become the licensee under licenses issued by the Nuclear Regulatory Comission ("NRC") o during this final stage. Exhibit B-4 hereto presents the anticipated SONOPC0 organizational structure during phase three. It is expected that the owners will retain approval authority over budgets for operations and maintenance, fuel procurement and capital additions. In addition, owner management will be kept informed on a current basis as to the status of plant operations through periodic briefings and reports by responsible SONOPC0 officers. Since the nuclear. functions now existing within APC and GPC are separate and distinct, it is anticipated that the formation and operation of SONOPCO will not have any detrimental effect on the fossil, hydroelectric or other corporate functions remaining in these companies. With few exceptions, the operating personnel who will be transferred to SONOPCO are currently dedicated to nuclear operations at APC and GPC. C. Farley is owned by APC and is currently operated by APC pursuant O to an operating license granted by the NRC and its predecessor. O . -S-
lo; O , Hatch and Unit 1 of Yogtle are currently operated by GPC pursuant to an
- g. operating agreement between it and Oglethorpe Power Corporation .
("Oglethorpe"), the Municipal Electrical Authority of Georgia ("MEAG"), and ; City of Dalton, Georgia (" Dalton") and operating licenses granted to the i -O wners of Hatch and Yogtle Unit 1 by the NRC which specify GPC as the ' operator. Hatch is owned as tenants-in-common by GPC (50.1% undivided interest), Oglethorpe (30.0% undivided interest), MEAG (17.7% undivided g interest) and Dalton (2.2% undivided interest). Vogtle is owned as tenants-in-comon by GPC (45.7% undivided interest), Oglethorpe (30.0% undivided interest), MEAG (22.7% undivided interest) and Dalton (1.6% ! O undivided interest). Y gtle Unit 2 is subject to the same ownership i interests, operating agreement and license arrangements as Vogtle Unit 1. The proposed transactions will not change the ownership of Farley, Hatch or O V gtle. In c nnecti n with implementing the third phase, SONOPC0 would become the licensed operator of Farley, Hatch and Vogtle. , D. SONOPCO will follow the uniform system of accounts for mutual i O and subsidiary service companies as prescribed by the Commission from time ! to time in accordance with Rule 93 and 17 CFR Part 256. To the extent that i costs incurred by SONOPC0 can be identified to a particular plant, O d i O i O i i
O 4 O, those costs will be directly assigned to APC or GPC as appropriate. It is anticipated that 50NOPC0 will directly assign substantially all of its costs. Costs which cannot be directly assigned will be allocated to APC or GPC as . provided in service agreements or operating agreements, the forms of which are attached hereto as Exhibits B-5 through B-9, respectively. In this regard, :, SONOPC0 will utilize an Annual Report on Form U-13-60 to comply with periodic ! reporting requirements in accordance with Rule 94. The initial agreements between SONOPC0 and APC and GPC will provide for the furnishing of nuclear services by SONOPCO to APC and GPC, the licensed operators of the nuclear plants. i O These services will be furnished by 50N0PC0 at : cost. The costs of SONOPCO thus to be taken into account will include all costs : of doing t,ainess, including reasonable compensation for necessary capital as ! permitted by Rule 91. O In the case of SONOPCO services rendered for Hatch and , Vogtle, these costs will be determined and accumulated and allocated among the owners of Hatch and Vogtle in proportion to their respective ownership interests ; O in such plants in the manner provided in the participation and operating i agreements rmong the owners. The service agreements will provide for indemnification of SONOPC0 by APC and GPC with respect to liability for personal injuries, property damage or other damages arising out of or in connection with the performance of work pursuant to the service agreements. At the time SONOPC0 assumes responsibility for the nuclear plant operations, operating contracts will be executed by SONOPCO for each plant. Under these operating agreements. SONOPC0 will submit for review and a O i i
O :
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approval, with respect to each plant, annual budget estimates of costs of nuclear services, and the anticipated fuel and capital costs that are expected to be incurred. It is presently anticipated that under these g operating agreements, SONOPCO would receive payment for the costs of its nuclear services by drawing upon reserve accounts for monthly cost; and expenses as they are incurred and that SONOPCO will submit monthly billing : 3 statements for such amounts after the end of the month. This monthly payment and billing procedure is expected to minimize the need for substantial working capital for SONOPCO. Any nuclear services which may be rendered by SONOPCO with respect to nuclear plants which are not owned in whole or in part by affiliates of the Southern electric system will be effected pursuant to service or 3, operating agreements which provide for billing at negotiated rates. l SONOPCO may provide a wide range of nuclear services to nonaffiliated companies, such as plant operating services, engineering services, technical services and administrative services. SONOPCO will account and report separately in its books and records the cost of providing such services to ensure that such costs are properly segregated ! g between affiliated companies and nonaffiliated companies. The Commission is hereby requested to reserve jur.isdiction with respect to this matter until contracts are negotiated for such transactions. E. g Accounting, treasury and other support services, as well as personnel, may be furnished to SONOPC0 at cost by Southern Company Services, Inc. ("SCS"), APC and GPC. iG 0 l
O g F. Southern will capitalize SONOPC0 by purchasing for cash all of the shares of SONOPCO's comon stock for an aggregate consideration of up to
$10,000,000. In addition, Southern proposes to make open account advances O to SONOPC0 from time to time, which at the option of Southern could be converted into capital contributions or shares of romon stock of SON 0PCO.
The rate of return on SONOPCO's comon equity capital will not exceed the g average of the most recent rates of return allowed by the Alabama Public F Service Comission ("APSC") and the Georgia Public Service Comission ("GPSC") on the common equity capital of APC and GPC, respectively. Open 0 acc unt advances from Southern will accrue interest at a rate not to exceed the prime rate in effect at a bank to be designated by Southern. Southern , also seeks authority for a period of five years for 50NOPC0 to borrow from O lenders other than Southern. The aggregate principal amount of any advances to SONOPCO by Southern or lenders other than Southern will not exceed
$50,000,000 at any one time outstanding. Unless authorized by the O Comission, loans obtained from lenders other than Southern will have maturities not to exceed 10 years and will accrue interest at a rate not to exceed the prime rate plus 25 for variable rate loans and the prime rate at O the time of borrowing plus 35 for fixed rate loans. Such loans may be secured or unsecured and may be guaranteed by Southern, APC and/or GPC.
G. The salaries and other costs of present Southern system O employees who will be transferred to SONOPC0 as discussed above, including provision of appropriate pension and Other employee benefits for such O 9 i O l l l
i ): ; I i Q i employees, will be included in SONOPCO's operating costs. The directors and l )- officers of SONOPCO will be selected without regard to whether interlocking 4 i positions between SONOPCO, Southern or other system companies or affiliates l will result. t ). H. It is expected that consolidation of nuclear operations for I the Southern electric system into SONOPC0 will create the potential for ;
.i significant long term benefits in three principal areas. First, nuclear j!
J staffing requirements should be reduced through sharing of information and personnel, elimination of duplication, enhanced motivation of employees, and !
,greater management focus. Second, it is expected that higher levels of i
3 nuclear unit availability and performance will be achieved. Third, 50NOPC0 i I will seek to reduce the cost of purchased materials and services through i
.i integrated planning and coordinated purchasing. !
) It is recognized that certain start-up costs will be incurred in ! forming SONOPCO. However, these one time costs are expected to be small I when compared to the potential long term benefits. ) . Item 2. Fees, Comissions and Expenses, i The estimated fees, comissions and expenses to be incurred in * ) connection herewith will be filed by amendment. ! [ i 10 - , l ) .i
-s - - - - - . ________ _ ___ ____________ _ _ _
y ). Item 3. Applicable Statutory Provisions. ' r ) A. The issuance and sale by SONOPC0 of shares of its capital stock are subject to the provisions of Sections 6(a) and 7 of the Act. They are not subject to the provisions of Rule 50 thereunder by reason of the . ) exemption provided by subparagraph (a)(3) thereof. B. The acquisition by Southern of shares of the capital stock of SONOPCO is subject to Sections 9(a) and 10 of the Act. ) C. The making of open account advances by Southern to SONOPC0 is subject to Section 12(b) of the Act and Rule 45 thereunder. O. The organization of SONOPCO and the conduct of its business ) are subject to Section 13(b) of the Act and Rules 86-95 thereunder. E. The indemnification of SONOPCO by APC and GPC pursuant to the i service or operating agreements described in Item 1.0 above, and the j guarantees of SONOPCO indebtedness described in Item 1.F above, are subject to Section 12(b) of the Act and Rule 45 thereunder. F. The conversion by Southern of open account advances into h capital contributions or equity of $0NOPC0 is subject to Section 9(a)(2) of ' the Act and Rule 44(a) thereunder. G. ! Since the regulatory authorizations to carry out the proposed ) transactions may be forthcoming at different times, authorization is requested from the Commission to implement the proposed transactions in stages. Applicants believe that since the SONOPCO program will be a l ) .
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^) continuing one, the provisions of paragraph (c)(1) and of the second clause of the first sentence of paragraph (a) of Rule 24 should not be applicable to the proposed transactions. Applicants propose to report their progress 3 and activities under Rule 24 as their authority to undertake the proposed transactions is exercised. Any significant variations in the proposed transactions, including significant changes in SONOPCO's organizational J structure, services to be rendered, character of companies to be serviced or method of cost allocation, would be reported under a 60-day letter procedure prescribed by the Comission.
O Item 1. Regulatory Approval. l The execution and carrying out of the proposed agreements between
^ ,; the owners of the subject nuclear facilities and SONOPC0 will not limit in any way the existing or further authority of either the APSC or GPSC, or any successor agency or agencies, with respect to such nuclear facilities, d Such agreements will not involve any abandonment or surrender of any service or any sale, lease, encumbrance or transfer of the possession or use of any tangible or intangible property, franchises, privileges or rights of the 3 owners of such property, all of which will remain vested in such owners.
Moreover, the proposed operating agreements will require that SONOPCO furnish to the owners certain data or other information requested by them in 3 addition to the~ regular reports. required by such agreements and that each operating agreement may be terminated at any time upon reasonable notice, provided that such termination rights may not be exercised without first 3 taking such action as may be necessary to protect the public health and safety. O i .,
e ). t a l )I SONOPC0 anticipates that it will in the future apply to the NRC for an amendment to the facility licenses or permits of the six nuclear units of the Southern electric system. - APC anticipates that approval of the AP5C will be required if an operating contract between SONOPCO and APC is ultimately antered into. GPC believes that entering into the proposed service or operating agreements for Hatch and Vogtle does not require approval of the GPSC. Item 5. Procedure. , The applicants request that the Comission's order herein be issued as soon as the rules will allow and that there be no 30-day waiting period between the issuance of the Comission's order and the date on which it is [ to become effective. It is submitted that a recomended decision by a hearing or other responsible officer of the Comission is not needed with respect to the proposed transaction. The appitcants hereby consent that the Division of Investment Management may assist with the preparation of the Comission's decision and/or order in this matter unless such Division opposes the ' matters covered hereby. Item 6. Exhibits and Financial Statements. The following exhibits and financial statements are filed as a part ) of this Application / Declaration: )
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I . k. - J
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3 l (a) Exhibits A-1 - Proposed Certificate of Incorporation of SONOPCO. (Filed under Form SE.) A-2 - Proposed By-Laws of SONOPCO. (Filed under Form SE.) B-1 - Form of shared employee agreement. (Filed under Form SE.) B-2 - Phase one matrix organizational structure. (Filed under D Form SE.) B-3 - SONOPCO Phase two organizational structure. (Filed under Form SE.) B-4 - SONOPCO Phase three organizational structure. (Filed under D Form SE.) B-5 - Form of proposed services agreement between APC and 50NOPCO. (Filed under Form SE.) B-6 - Form of proposed services agreement between GPC and 3 SONOPCO. (Filed under Firm SE.) B7 - Form of proposed operating agreement for Plant Farley. (To be filed by amendment.) B-8 - Form of proposed operating agreement for Plant Hatch. (To O be filed by amendment.) B-9 - Form of proposed operating agreement for Plant Vogtle. (To be filed by amendment.) B Form of proposed services agreement between SCS and O SONOPCO. (Filed under Form SE.) B Form of proposed services / operating agreement between nonaffiliated company and SONOPCO. (To be filed by amendment.) O C - Not applicable. 0-1 - Copy of petition to APSC. (To be filed by amendment.) D-2 - Copy of order of APSC. (To be filed by amendment.) 3 E - Not applicable. F - Opinions of counsel. (To be filed by amendment.) G - Form of Notice. 3
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1 D'. , 1 1 O (b) Financial Statements. Financial statements of Southern and subsidiary companies have been omitted since they are not deemed to be material to or necessary for a proper disposition of the proposed transactions. C Item 7. Information as to Environmental Effects. The issuance of an order by the Comission with respect to the subject transactions is not a major federal O action significantly affecting the quality of the human environment. No federal agency has prepared or is preparing an O environmental impact statement with respect to the subject transactions. The NRC is the federal agency with principal federal jurisdiction with respect to Farley, Hatch and Vogtle. O including, but not limited to, environmental matters. O e S e
y a 3~ SIGNATURES 3 Pursuant to the requirements of the Public Utility Holding Company Act of 1935, the undersigned companies have duly caused this statement to be signed on theis' behalf by the O undersigned thereunto duly authorized. Dated June 22, 1988 THE SOUTHERN COMPANY By $4.EAbA W W V William A. Maner III Assistant Secretary ALABAMA POWER COMP Y 4 By Wayne Boston istant Secretary O GEORGIA POWER COMPA By aynt Boston O' istant Secretary Note: SONOPC0 has not been formed yet and consequently has not joined in the execution of this Application / 'O Declaration. wever, when the formation and ceganization of SONOPCO is. authorized, that corporation will join in an amendment to this Application / Declaration whereby it will adopt such Application / O Declaration, as previously amended.
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EXHIBIT B-1 )- AGREEhENT FOR SHARED EMPLOYMENTOF
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THIS AGREEMENT, made and entered into as of the Erst day of June, 1988 by and among Alabama Power Company (APC), Georgia Power Company (GPC), and (Employee). ) WITNESSETH: WHEREAS, Employee is an employee of APC having experience and expertise in the Seld of nuclear operations; and WHEREAS, GPC wishes to employ Employee as an employee of GPC to provide services in his area of experience and expertise; and
' WHEREAS, APC continues to need Employee in its employ to provide such services, and is willing for Employee to be employed by GPC at times when he is not employed by and providing service to APC; and WHEREAS, Employee is willing to perform as an employee of APC
) and of GPC from time to time on the terms and conditions set fo berein; NOW, THEREFORE, in consideration of the premises and the mutual terms and conditions set forth berein, the parties bereto agree as follows: 1. Basis for Emolovment of Emolovee: APC shall continue to pay and provide Employee the total compensation, pension, savings plans, insurance, company ar ished vehicle, and other benefits agreed to between APC and Employee as of the date of this Agreement, or such
)
Oi 7 other or additional compensation, pension, savings plans, insurance, or other benefits as would, at any future point in time during the term : i hereof, be paid and provided to Employee as an employee of APC in th '. ordinary course of business. ! 'o In addition, APC shall pay all expenses Y incurred by Employee in his employment by either APC or GPC as wou , be reimbursable to Employee as an employee of APC in the ordin t course of business.
'O Notwithstanding Employee's agreement bereunder to become an employee of GPC from time to time, the resulting breaks in!!
j cmployment vith APC during the times he is employed by GPC pursuant [ to this Agreement shall be disregarded for all purposes in connection with "O ( the compensation and benefits, including retirement benefits, that would i
- be due him from APC. t Employee agrees that he shall have no claim, right or cause of action against GPC for any compensation, benefitt, or t l
expense reimbursement that he might earn under this Agreement and that APC shall exclusively be responsible and liable for all such payments and 'o contributions; provided, however, nothing herein shall be construed to
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affect any rights of Employee to i t indemni5 cation or other protection from l liability afforded by GPC to its officers or employees that would norm i be available to Employee. {' lO ! t , 2. r Basis for Sharine Employment of Emolevcc: GPC agrees to
- j. !
!O i employ Employee, and Employee agrees to be employed by GPC for such j periods of time during each month mutually acceptable to GPC, APC and < t Employee. i; During the time Employee is employed by GPC, he shall ! ( devote his time, attention, and energies in the performance of the duties "O { 1 designated by GPC, and will, during such time, be under the sole supe! i l ! - 2. - l lO l
i D vision, direction and control of GPC O Employee shall, during the retnain-der of each month, be employed by APC' and shall ' devote his time, attention, and energies in the performance of the duties designated by J APC and will, during such time be under the sole supervision, direction and control of APC
- 3. Reimbursement of APC Costs:
r 0 GPC agrees to reimburse APC I two-thirds of APC's full costs associated with the compensation and l benefits paid and provided to Employee each month, such share being { O based on the estimated percentage of time during the month Employee will be employed by GPC Each month, Employee shall consult with APC and GPC to determine whether events have occurred to cause adjustment in the reimbursement percentage. GPC also agrees to pay APC the i O reasonable pro rata cost incurred by APC with respect to the payroll, pension, savings, tax withholding, unemployment, bookkeeping and other O personnel support and administrative services utilized by APC in connec-tion with the provisica of compensation and beneSts to Employee, and shall pay APC for all expenses incurred by Employee in the course of his O employment for GPC that have been reimbtused by AFC It is acknow. ledged by the parties that, in some instances, expenses may be incurred that must be allocated between APC and GPC, and APC and GPC agree to O such allocation on the basis ::asonably recommended by Employee. GPC shall , reimburse APC any other costs of any nature that APC may incur arising out of GPC's employment of Employee. APC shall reimburse GPC any other costs of any nature that GPC may incur arising out of APC's employment of Employee. e
)
4 Resoonsibility for Woric Umitatici of 'Uability: APC shall have no responsibility whatsoever to GPC or anyone (other than Employee) !
) claiming by or on behalf of GPC for any claims, liabilities, injuries, f
damages or other consequences under any theory of liability, whether in . contract, in tort (including negligence and strict liability) or otherwise, arising out of or related to the work or other act or omission of - Employee during any time Employee is employed by GPC, it being understood and agreed that GPC has sole authority and responsibility for the work of Employee during the period of employment with GPC GPC shall have no responsibility whatsoever to APC or anyone ciniming by or on behalf of APC for any claims, liabilities, injuries, damages or other consequences under any theory of liability, whether in contract, in tort 1 (includin c ,egligence and strict liability) or otherwise, 2 rising out of or i l related to the work or other act or omission of Employee during any time Employee is employed by APC, it being understood and agreed that APC has sole authority and responsibility for the work of Employee during the 1 period of employment with APC 4 h
- 5. Term:
. This Agreement shall become effective as of the date I first set forth above and shall continue until terminated in writing by l 1 Employee, APC, or GPC, without any necessity for demonstration of cause, at the will of the party giving notice of termination.
- 6. Governing 12w: His Agreement is governed by the law of l
l i 4. ) i
9 - r
- g. the State of Alabama. l IN WITNESS WHEREOF, the parties have executed or caused this
# Agreement to be executed as of the date Srst written above.
ALABAMA POWER COMPANY ' D By . GEORGIA POWER COMPANY D By EMPLOYEE ; l 1
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D 1
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v v v -m u m C - -- u v: u --
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Exhibit B-2 Phase One Matrix' Organization
///////// .
Axx\\\\\N ALABAMA GEORGIA POWER POWER l - 1 I I W// ANN 4 NUCLEAR OPERATING EXECUTIVE VP CODE:
/ '///1\xY NUCLEAR k\\\N GPC OPEllATING SENIOR VP I
I 7ss/m NNxx\W Nxxx\xxv 4 FAfE.EY HATCH V06TLE PROJECT PROJECT PROJECT
o o o o o o o o o o- o ExhibitB-3 SONOPCO Phase Two Organization 7//////// , h\\\\\\N ALABAMA SONOPCO GEORGIA POWER CEO POWER l . 1 I I f/A b55 SONOPCO C00 CODE: I I
//A r///A APc ANX
' TECH NUCLEAR ADMIN SPC SERVICES OPERATING SERVICES OFFICER OFFICER OFFICER I _I SONOPC0 Z7//> . t\\\X h\N FAR.EY HATCH YOGTLE PROJECT PROJECT PROJECT OFFICER OFFICER OFFICER i i-____._____.__---__.___.________ __._-____.--.__m-m__
- . - _- - - - . - + , _ _ _ _ _ _ _ _ _ . , _ - y,_ . . .--m . ._.,c-_.-. se , , , , _ . , .,._e _.,_m _ _ y , ,
o e o o o o o u o o m Exhibit B-4 SONOPCO Phase Three Organization SONOPCO CEO SONOPCO C00 CODE: I l SDNOPCO ADMIN TECH NUCLEAR SERVICES SERVICES OPERATING OFFICER OFFICER OFFICER I V0GTLE HATCH FAlt.EY PROJECT PROJECT PROJECT OFFICER csTICER OFFICER
C? k i Ol AGREEMENT FOR SHARED EMPLOYMENT OF R. P. MCDONALD O. THIS AGREEMENT, made and entered into as of the first day of June, 1988 by and among Alabama Power Company (APC), Georgia Power ! Company (GPC), and R. P. Mcdonald (Employee). O . WITNESSETH: , WHEREAS, Employee is an employee of APC having experience and ,
- O j expertise in the field of nuclear operations; and WHEREAS, GPC wishes to employ Employee as an employee of GPC i
to provide services in his area of experience and expertise; and O WHEREAS, APC continues to need Employee in its employ to provide such services, and is willing for Employee to be employed by GPC at times when he is not employed by and providing service to APC; and , O WHEREAS, Employee is willing to perform as an employee of APC ; and of GPC from time to time on the terms and conditions set forth
+
l herein; O NOW, THEREFORE, in consideration of the premises and the mutual terms and conditions set forth herein, the parties hereto agree as follows: [ O- APC shall continue to pay
- 1. Basis for Emolovment of Employee: -
and provide Employee the total compensation, pension, savings plans, , insurance, company furnished vehicle, and other benefits agreed to
.O between APC and Employee as of the date of this Agreement, or such O! -
l' L. other or additional compensation, pension, savings plans, insurance, or . 1 other bener'its as ' would, at any future point in time during the term )! i hereof, be paid and provided to Employee as an employee of APC in the i ordinary course of business. In addition, APC shall pay all expenses incurred by Employee' in his employment by either APC or GPC as would ! )_ .- : be reimbursable to Employee as an employee of APC in the ordinary ! Notwithstanding Employee's agreement hereunder to course of business. ; become an employee of GPC from time to time, the resulting breaks in ) i employment with APC during the times he is employed by GPC pursuant ; to this Agreement shall be disregarded for all purposes in connection with i the compensation and benefits, including retirement benefits, that would ; be due him from APC. Employee agrees that he shall have no <:laim, right or cause of action against GPC for any compensation, benefits, or ! expense reimbursement that he might earn under this Agreement and that ) APC shall exclusively be responsible and liable for all such payments and contributions; provided, however, nothing herein shall be construed to affect any rights of Employee to indemnification or other protection from ) liability afforded by GPC to its officers or employees that would normally f be available to Employee. ] I
- 2. Basis for Sharine Emniovment of Emolovee: GPC agrees to employ Employee, and Employee agrees to be employed by GPC for such periods of time during each month mutually acceptable to GPC, APC and ;
) Employee. During the time Employee is employed by . GPC, he shall devote his time, attention, and energies in the performance of the duties designated by GPC, and will, during such time, be under the sole super- )
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l )f
O {- . i vision, direction and control of GPC. Employee shall, during the remain-g der of each month, be employed by APC and shall devote his time, attention, and energies in the performance of the duties designated by APC and will, during such time be under the sole supervision, . direction- , and control of APC. J ;
- 3. Reimbursement of APC Costs: GPC agrees to reimburse APC two-thirds of APC's full costs associated with the compensation and :
g benefits paid and provided to Employee each month, such share being based on the estimated percentage of time during the month Employee
; will be employed by GPC. Each month, Employee shall consult with APC ]
and GPC to determine whether events have occurred to cause adjustment
; in the reimbursement percentage. GPC also agrees to pay APC the ! reasonable pro rata cost incurred by APC with respect to the payroll, pension, savings, tax withholding, unemployment, bookkeeping and other a
personnel support and administrative services utilized by APC in connec-tion with the provision of compensation and benefits to Employee, and O . shall pay APC for all expenses incurred by Employee in the course of his ! employment for GPC that have been reimbursed by APC. It is acknow-ledged by the parties that, in some instances, expenses may be in::urred 3 that must be allocated between APC and GPC, and APC and GPC agree to t such allocation on 'the basis reasonably recommended by Employee. GPC shall reimbun,e APC any other costs of any nature that APC may incur , 3 arising out of GPC's employment of Employee. APC shall reimburse GPC any other costs of any nature that GPC may incur arising out of APC's employment of Employee. O 3-
3 . y 4. Resnonsibility for Work- Umitation of Unhilitv: APC shall have no responsibility whatsoever to GPC or anyone (other than Employee) claiming by or on behalf of GPC for any claims, liabilities, injuries, i damages or other consequences under any theory of liability, whether in 3 contract, in tort (including negligence and strict liability) or otherwise, i arising out of or related to the work or other act or omission of Employee during any time Employee is employed by GPC, it being understood and agreed that GPC has sole authority and responsibility for
- , the work of Employee during the period of employment with GPC. GPC shall have no responsibility whatsoever to APC or anyone claiming by or '
on behalf of APC for any claims, liabilities, injuries, damages or other ; consequences under any theory of liability, whether in contract, in tort (including negligence and strict liability) or otherwise, arising out of or related to the work or other act or omission of Employee during anyisime Employee is employed by APC, it being understood and agreed that APC f has sole authority and responsibility for the work of Employee during the l 0 period of employment with APC. j o 5l Term: This Agreement shall become effective as of the date O first set forth above and shall continue until terminated in writing by . Employee, APC, or GPC, without any necessity for demonstration of cause, at the will of the party giving notice of termination. D. t
- 6. Governine Law: This Agreement is governed by the laws of D
.4 i
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0 O the State of Alabama. t O- ; IN WITNESS WHEREOF, the parties have executed or caused this Agreement to be executed as of the dat: first written above. O ALAB R CO hNY l
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By -
,( -
O GEORGIA POWER COMPANY By_ O R. P. MCDONALD O O O i O o 5 t Ol l
D
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SECURITIES AND EXCHANGE COMMISSION D (Release No. 3 5 - 24694 ) Filings Under the Public Utility Holding Company Act of 1935 ("Act") LD August 12, 1988 l l Notice is hereby given that the following filing (s) has/have l been made with the Commission pursuant to provisions of the Act l3 and rules promulgated thereunder. All interested persons are I j referred to the application (s) and/or declaration (s) for complete statements of the proposed transaction (s) summarized below. The l EJ application (s) and/or declaration (s) and any amendment (s) thereto is/are available for public ' inspection through the Commission's office of Public Reference. O Interested persons wishing to comment or request a hearing on the applicatAon(s) and/or declaration (s) should submit their views in writing by September 6, 1988 to the Secretary, O Securities and Exchange Commission, Washington, D.C. 20549, and serve a copy on the relevant applicant (s) and/or declarant (s) at the address (es) specified below. Proof of service (by affidavit 3 or, in case of an attorney at law, by certificate) should be filed with the request. Any request for hearing shall identify specifically the issues of fact or law that are disputed. A 3 person who so requests will be notified of.any hearing, if ordered, and will receive p copy of any notice or order issued in the matter. After said date,.the application (s) and/or 3 declaration (s), as filed or as amended, may be granted and/or permitted to become effective. i
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l l The Southern comoany (70-7530) The Southern Company (" Southern"), 64 Perimeter Center East,
)
Atlanta, Georgia 30346, a registered holding company, and its electric utility subsidiaries, Alabama Power Company ("APC"), 600 g North 18th Street, Birmingham, Alabama 35291, and Georgia Power Company ("GPC"), 333 Piedmont Avenue, N.E., Atlanta, Georgia 30308, have filed an application-declaration pursuant to Sections g 6(a), 7, 9(a), 10, 12(b) and 13(b) of the Act and Rules 45 and 86-95 thereunder. Southern proposes to organize a new wholly owned Delaware g subsidiary to be known as Southern Nuclear Operating Company, Inc., ("SONOPCO") , to consolidate the personnel of the Southern system companies involved in nuclear services into a single j organization. SONOPCO's operating structure will be implemented in three phasec. Initially, key nuclear operations management I personnel will be shared between APC and GPC. In the second i gi phase, which would begin upon approval by the Commission of the present application-declaration, SONOPCO will be organized as a service company that will provide APC and GPC with nuclear q , services, including plant operating services, fuel procurement services, administrative services and technical services, but , will not own, finance or operate any nuc, lear or other utility O assets In the third phase, SONOPCO will become responsible, on behalf of the owners and through contract with them, for the 4'
O : !. . e l j e
, l
'OI l operation and maintenance of all nuclear generating facilities l' owned by Southern electric system companies. i .O SONOPCO may apply to the Nuclear Regulatory Commission ("NRC") or its successor for facility license or, permits for the i Farley Nuclear Plant ("Farley"), owned and operated by APC, and l I 0 for the Hatch Nuclear Plant (" Hatch") and Vogtle, Nuclear Plant ("Vogtle"), each of which is jointly owned by GPC, the Hunicipal l i Electric Authority of Georgia, Oglethorpe Power Corporation, and . O the City of Dalton, caergia, and for which GPC is the present i licensee and operator under an existing operating agreement. Nuclear services rendereil by SONOPCO to nuclear plants not wholly O owned by associates of the Southern system will be pursuant to i service or operating agreements that provide for billing at l negotiated rates. O Accounting, treastiry, and other support services, as well as l personnel, may be furnished to SONOPCO at cost by Southern { Company Services, Inc., APC, and GPC. SONOPCO will render j i O service to associated companies at cost, pursuant to Section 13(b) of the Act. The costs will be accounted for and billed to the owners of the subject facilities as prescribed by Rules 91 , O and 93 and the uniform system of accounts prescribed thereunder. In the case of SONOPCO's services rendered for the Vogtla and ' I Hatch units, these costs will b.e deterni,ned, accumulated, and O allocated among the owners of Vogtle and Hatch in proportion to their ownership interests. l O i i b
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I o l 4 O l SONOPCO will issue, and Southern will purchase for cash,, all of the shares of SONOPCO's common stock for an aggregate
' consideration of up to $10 million. Southern proposes to make open account advances to SONOPCO from time to time, which may be converted into capital contributions or shares of common stock of SONOPCO. The rate of return on SONOPCO's equity capital will not exceed the average of the most recent rates of return allowed by
( the Alabama Public Service Commission and the Georgia Public Service Commission on the equity capital of APC and GPC, respectively. SONOPCO also proposes to obtain funds from third party lenders. The aggregate principal amount of advances to j SONOPCO by Souchern or lenders other than Southern will not exceed $50 million at any time outstanding. Interest on open f: account advances by Southern will accrue at a rate not to exceed the prime rate at a bank designated by Southern. Unless authorized by the Commission, loans by parties other than Southern will have maturities not to exceed ten years and will g , accrue interest at a rate not to exceed the lender's prime rate plus 2% for variable rate loans and the prime rate at the time of borrowing plus 3% for fixed rate loans. Loans by parties other q , than Southern may be secured or unsecured and may be guaranteed by Southern, APC and/or GPC. With respect to the initial , capitalization of $10 million and to open account advances from q , Southern, it is requested that the Commission reserve jurisdiction over amounts in excess of $5,000,000 and i 4 f1
.O 5
O S15,000,000, respectively, and over all advances from lenders other than Southern. Southern requests this financing authority through December 31, 1990. For the Commission, by the Division of Investment Management, pursuant to delegated authority. O
- O l Jonathan G. Katz Secretary ,
O W l].,.. O .M .
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E b: Chir 1cy E. Hollis Amtant Secutary l O i O i i l O . .
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~ .[p nacgDo NUCt. EAR REGULATORY COMMISSION t y ,
o REGION il [
< 101 MARIETTA STREET, N.W.
I f ATLANTA, GEORGIA 30323 ; O %,
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AUG 11 iss8 Docket Nos. 50-321, 50-366 ,
- 50-424, 50-425
.O License Nos. DPR-57, NPF-5 NPF-68, CPPR-109 ! ! I r Georgia Power Company ATTN: Mr. W. G. Hairston, III O Senior Vice President - ! Nuclear Operations ; P. O. Box 4545 ! Atlanta, GA 30302 Gentlemen: O
SUBJECT:
MEETING SIM4ARY - NUCLEAR OPERATIONS - TRANSITION ORGANIZATION l This refers to the information meeting conducted in the NRC Region II Office on ; July 25, 1988. This meeting was held at your request to discuss your current ' O transitional nuclear operations organization for the corporate office, Vogtle i facility and Hatch facility. A list of attendees, a brief sumary and a copy l of your handout are enclosed. l It is our opinion that this meeting was beneficial and has kept us apprised - of your nuclear operations organization. l O In accordance with Section 2.790 of NRC's " Rules of Practice,". Part 2, ! Title 10, Code of Federal Regulations, a copy of this letter and its enclosures i will be placed in the NRC Public Document Room. Should you have any questions concerning this letter, we will be pleased to O discuss them. Sincerely. O ./ J. Nelson Grace i Regional Administrator i
Enclosures:
- 1. Meeting .Sumary 0- 2. List of Attendees
- 3. Georgia Power Company Presentation cc w/encis: (Seepage 2)
O. .
$l Georgia Power Company 2 AUG 1 1 jggg ) cc w/encls:
. R. P. Mcdonald, Executive Vice President, Nuclear Operations P. D. Rice, Vice President, Project
) Director C. W. Hayes, Vogtle Quality Assurance Manager G. Bockhold, Jr., General Manager, Nuclear Operations L. Gucwa, Manager, Nuclear Safety ) and Licensing J. A. Bailey, Project Licensing Manager B. W. Churchill, Esq., Shaw, Pittman, Potts and Trowbridge D. Kirkland, III, Counsel, 3 Office of the Consumer's Utility Council D. Feig, Georgians Against Nuclear Energy 3-J J J J J
i ) 1 ENCLOSURE 1 MEETING
SUMMARY
)' On July 25, 1988, representatives of Georgia Power Company (GPC) met with the NRC in the Region II office in Atlanta, Georgia to discuss the Corporate office, Vogtle facility, and Hatch facility nuclear operations organization. A list of meeting attendees is in Enclosure 2. ) GPC gave a presentation which provided an organization status. An outline of GPC's presentation is given in Enclosure 3. After approval by the Securities and Exchange Commission, a nuclear operating company consisting of the nuclear plants in the Southern Company (Hatch, ) Farley, Vogtle) will be formed. The corporate office location will be decided once approval for the company is obtained. A project organization has been established for each plant. J ) t
I!' 4 i hh
- ENCLOSURE 2 i LIST OF ATTENDEES f
ID 3 U. S. Nuclear Regulatory Commission - Region II L. A. Reyes, Director, Division of Reactor Projects (DRP) V. L. Brownlee, Chief. Branch 3, DRP H. C. Dance, Chief. Section 18 DRP GD M. V. Sinkule, Chief. Section 3B, DRP i D. M. Verrelli, Chief Branch 1, DRP C. Patterson, Project Engineer, DRP i NRC - Office of Nuclear Reactor Regulation C) D. B. Matthews, Project Directorate II-3 c Georgia Power Company i W.. G. Hairston, III, Senior Vice President, Nuclear Operations i C. K. McCoy, Vice President, Nuclear Operations C) J. T. Beckham, Vice President, Nuclear Operations l T. J. McHenry, Manager, General Support ! O
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U O L,- U U U Y U ') $ ,.,$ ENCLOSURE 3 l NUCLEAR OPdRATIONS - TRANSITION ORGANIZATION l l R. P. MCDONALD EXEC VP - NUC OPS i P. H. BRITT - - C. T. H00RC l EXECUTIVE SECRETARY GEN HGR QUALITY ASSURANCE I W. G. HAIRSTON SR VP - SaK OPS T. J. HOEmYu -- ASST TO EVP G SVP NUC OPS SAFETY REVIEW BOARD J. T. BECKHAM C. K. HCC0Y T. J. HQiE m Yu VP - NUCt EAR DIATDil VP - NUCLEAR (V0GTLE) HGR GENERAL SUPPORT B. L. MINTZ - L. C. BEAZLEY - H. E. Loin SENIOR SECRETARY EXECUTIVE SECRETARY SEDETARY IV L. T. GUCWAm - J. P. KANEu - J. J. BADGETTm MGR LIC C ENG - HATCH j MGR LIC E ENG - V0GTLE HGR TANG G EMER PREP B. K. MCLEODu - H. P. WALKERu - S. C. EWALD MGR HNT SUPPORT HGR MNT SUPPORT / NUCLEAR MGR RAD 10 LOGICAL SAFETY H. C. NIX - G. DOCKHOLD - H. B. HOBBYu GEN HGR - NUCLEAR PLANT GEN HGR - NUCLEAR PLANT HGR ADHIN SUPPORT Indicct';s a transitional position 07/21/88 ith incumbent serving in an acting spectY.
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F Asema.o.o ,. mnaa w ,4o4 m osso 3 SouthemCompany am.we Ade m m, ,,,,,, cme ,y,,, DATE: September 21,1988 TO: Employees of Alabama Power Georgia Pcwer Southern Company Services As you know, this past May we announced plans to form a new subsidiary - 3_ Southern Nuclear Operating Company (SONOPCO) - to provide management and technical services for the nuclear power plants in our system. I want to briefly update you on the progress we've made toward combining our nuclear operations. p In June, we filed an application with the Securities and Exchange Commission for 1 , approval to create the new company. We are awaiting final commission action. However, i Oglethorpe Power Corporation, which owns 30 percent of Plant Vogtle and 30 percent. 4 of Plant Hatch, has intervened in the matter and asked the commission to delay its i ruimg until several of Oglethorpe's concerns are addressed. We are continuing to hold D discussions with Oglethorpe officials. We've also taken the first step in merging the nuclear management professionals of
- Alabama Power and Georgia Power. Pat Mcdonald is serving as executive vice president of both companies and is responsible for the operation of Plants Vogtle, Hatch, and Farley. He is being assisted by George Hairston, who is serving as a senior vice president of both companies.
Also, I recently asked Alabama Power President Joe Farley to devote a portion of his i time to guiding the formation of our new nuclear company. His leadership and insight will be of immeasurable value. Finally, we have decided to move the off site nuclear management and support functions of both Mah=== Power and Georgia Power to a single location. While each company - as the licensee - will be responsible for operating its respective plants, i a common location will better facilitate exchange of information and integrated i nuclear planning. We will locate these functions in Building 40 of the Inverness office park near Birmingham - adjacent to the nuclear support and engineering support groups of Southern Company Services. This relocation should be completed by the end of 1988. As we continue this process, some of you certainly will be called upon to assist in , 3 various aspects of SONOPCO's creation. I would ask each of you perscnally to do all ' you can to help make this exciting promise a reality. 3
i l 1 * *' 4 r i*' UNITED STATES
* }
NUCLEAR REGULATORY COMMISSION
. REGION 11 jE' 101 MARIETTA ST., N.W.
, ,, g ATLANTA. GEORGIA 30323 l i O. FEB 0 7 1989 I Docket Nos. 50-321, 50-366, 50-424, ! 50-425, 50-348, 50-364 License Nos. OPR-57,'NPF-5, NPF-68, l CPPR-109, NPF-2, NPF-8 l D
- Georgia Power Company
~ ATTN: Mr. W. G. Hairston, III ' Senior Vice President - Nuclear Operations P. O. Box 1295 O. Birmingham, AL 35201 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NOS. 50-321/88-41, 50-366/88-41, 50-424/88-60, . 50-425/88-77, 50-348/88-33, AND 50-364/88-33 O This refers to a Nuclear Regulatory Comission (NRC) inspection of corporate organization, responsibilities, and functions conducted by Messrs.
. M. V. Sinkule, J. F. Rogge, J. E. Menning, F. Allenspach, L. R. Moore, H. C. Dance, and G. Maxwell on December 19 - 21, 1988. The inspection included ;
O a review of activities authorized for your Corporate Office in Birmingham, ~ Alabama. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed Inspection Report. A , managewnt meeting to discuss nuclear plant oversight responsibilities, technical support responsibilities, and activities of the corporate organiza-tion was also conducted on December 19, 1988. Meeting attendees and a brief O sumary of this meeting are included in the enclosed Inspection Report. The , meeting handouts utilized during this presentation have also been provided as . Enclosure 2. Areas examined during the inspection are identified in the report. Within these areas, the insoection consisted of selective examinations of procedures
# and representative records, interviews with personnel, and observation of activities in progress.
Within the scope of the inspection, no violations or deviations were identified. 3 In accordance -with Section 2.790 of the NRC's " Rules of Practice," Part 2 Title 10, Code of Federal Regulations, a copy of this letter and its enclosures, will be placed in the NRC Public Document Room. Should you have any questions concerning this letter, please contact us. S Sincerely, A Luis A. Reyes, Direct a-
, Division of Reactor Projects rncinturas: D;.. nan. n
E ) i Georgia Power Company 2 FEB 0i N69 j'- ;
Enclosures:
- 1. NRC Inspection Report '
- 2. Meeting Handouts cc w/encis:
}' R. P. Mcdonald, Executive Vice President, Nuclear Operations J. T. Beckham, Vice President, Plant Hatch H. C. Nix, General Manager, Plant Hatch
.0. M. Fraser, Site Quality Assurance Manager 1
) L. T. Gucwa, Manager, Nuclear Engineering and Licensing, Plant Hatch S. B. Tipps, Manager of Nuclear Safety and Compliance B. M. Guthrie, Executive Vice President D. N. Morey, General. Manager - ) Nuclear Plant
'J. D. Woodard, Vice President -
Nuclear Generation J. W. McGowan, Manager-Safety Audit and. Engineering Review S.- Fulmer, Supervisor-Safety ) Audit and Engineering Review R. P. Mcdonald, Executive Vice l President, Nuclear Operations P. D. Rice, Vice President, Project Director C. W. Hayes, Vogtle Quality ) Assurance Manager G. Bockhold, Jr., General Manager, Nuclear Operations J. P. Kane, Manager Licensing and Engineering J. A. Bailey, Project Licensing ) Manager B. W.-Churchill, Esq., Shaw, Pittman, Potts and Trowbridge D. Kirkland. III, Counsel, Office of the Consumer's Utility Council ). D. Feig, Georgians Against-Nuclear Energy State of Georgia State of Alabama )
j UNITED STATES j NUCLEAR REGULATORY COMMISSION o ! REGION 11 g j a 101 MARIETTA ST., N W. e.,,, ATLANTA. GEORGIA 30323
) Report Nos.: 50-424/88-60, 50-425/88-77, 50-348 and 50-364/88-33, 50-321 and '
50-366/88-41. Licensees: Georgia Power Company Alabama Power Company
) P. O. Box 1295 Birmingham, AL 35201 Docket Nos.: 50-424, 50-425, 50-348, 50-364, 50-321, 50-366 License Nos.: NPF-68, CPPR-109, NPF-2, NPF-8, DPR-57, NPF-5 f Facility Names: Vogtle 1 and 2, Farley 1 and 2, Hatch 1 and 2 Inspection Conducted: Decemb 19-21, 1988 Inspectors: A uIL 2 7 ) M. V. Sinkule, Region 11, Team Leader pateSigneo Team Members: H. C. Dance, Region II J. F. Rogge, Region II J. E. Menning, Region II G. F. Maxwell, Region II ) L. R. Moore, Region II F. R. Allenspach, Office of clear Reactor Regulation Approved by:
A. R. Herdt, Branch Chief Dltte Signea Reactor Projects Branch 3
) Division of Reactor Projects
SUMMARY
)
Scope: This special, announced inspection was conducted at the Corporate Office in Birmingham, Alabama, in the areas of corporate organiza-tion, responsibilities, and functions. A management meeting to discuss nuclear plant oversight responsibilities, technical support responsibilities, and activities of the corporate organization was also conducted on December 19, 1988.
)'
Results: The new corporate organization, which was established in anticipation of the formulation of the operating company for Vogtle, Hatch, and Farley, had been in place since November 1, 1988, and was functioning at the time of this inspection. The majority of the management and technical staffing was complete; however, some administrative posi-
) tions were'not yet filled. Most positions were being filled by personnel with experience obtained in the plants, and the personnel interviewed during this inspection were knowledgeable of their duties and responsibilities. Existing Georgia Power Company and Alabama )
e 2 Power Company procedures were in effect; however, they were still in the process of being modified to reflect the corporate organizational change:, and responsibilities. Additionally, it was determined trst although the new operating philosophy of the corporate staff in a support role as opposed to an overview role was sound, the Vogtle Final Safety Analysis Report needed to be revised to reflect this philosophy change. Within the areas inspected, no violations or deviations were identified. D J D 0 D e D
D REPORT DETAILS
- 1. Persons Contacted g Licensee Employees
#J. Badgett, Emergency Planning Coordinator, Vogtle, Georgia Power Company (GPC) #*J. Baily, Manager of Licensing, Vogtle, GPC #*T. Beckham, Vice President, Hatch Project, GPC B. Burns, Manager of Engineering Services, Southern Company Services (SCS) 3 5. Burns, Senior Project Engineer, Farley, Alabama Power Company (APC) #5. Chesnut Vogtle Engineering Manager, GPC #E. Cobb, Supervisor of Planning and Performance, Vogtle, GPC J. Davis, Senior Engineer, Vogtle Safety Audit and Engineering Review, GPC B. Epps, Manager, Inspection and Testing Services, SCS
- 5. Ewald, Manager, Environmental Services, SCS 3 R. Fucich, Manager, Nuclear Administration, Farley, APC G. Grove, Manager, Corporate Quality Services, SCS L. Gucwa, Manager, Engineering and Licensing, Hatch, GPC
#*W. Hairston, III, Senior Vice President, GPC/APC J. Heidt, Manager of Licensing, Hatch, GPC F. Jessup, Emergency Planning Coordinator, Farley, APC 3 D. Jones, Manager of Engineering, Farley, APC #J. Kane, Manager, Engineering and Licensing, Vogtle, GPC
- 0. Kennamer, Project Engineer, Farley, APC J. Leamon, Vogtle Project Licensing Engineer, GPC
#L. Long, Technical Services, SCS 3 D. Mansfield, Manager, Nuclear Maintenance and Support, Farley, APC #K. McCoy, Vice President, Vogtle Project, GPC *R. Mcdonald, Executive Vice President, GPC/APC E. McDougal, Supervisor, Administrative Support, Farley, APC J. McGowan, Manager, Farley Safety Audit and Engineering Review, APC B. McKinney, Manager, Nuclear Engineering and Licensing, Farley, APC g T. Mitchel, Senior Engineer, Hatch Safety Audit and Engineering Review, GPC M. Rickels, Coordinator, Nuclear Fuels and Contracts, Farley, APC #P. Rushton, Manager, Vogtle Safety Audit and Engineering Review, GPC #*B. Shipman, General Manager, Support, Vogtle, GPC #C. Stinespring, Manager, Nuclear Administration, Vogtle, GPC e J. Stringfellow, Project Engineer, Vogtle Licensing, GPC #H. Walker, Manager, Maintenance and Support, Vogtle, GPC #J. Woodard, Vice President, Nuclear, Farley, APC Other licensee employees contacted during this inspection included supervisors and engineers.
B B
I 2 D NRC Region II Personnel
#V. Brownlee, Chief, Reactor Projects Branch 3, Division of Reactor Projects #H. Dance, Chief, Reactor Projects Section 1A, Divisicn of Reactor Projects 3 #M. Ernst, Acting Regional Administrator #*L. Moore, Reactor Engineer Division of Reactor Safety #L. Reyes, Director, Division of Reactor Projects #*M. Sinkule, Chief, Reactor Projects Section 3B, Division of Reactor Projects 3 NRC Office of Nuclear Reactor Regulation Personnel #*F. Allenspach, Operations Jngineer, Performance and Quality Evaluation Branch, Division of Licensee Performance and Quality Evaluation #G. Lainas, Assistant Director for Region II Reactors #D. Matthews, Director, Project Directorate 11-3 D NRC Resident Inspectors #G. Maxwell, Senior Resident Inspector, Farley #*J. Menning, Senior Resident Inspector, Hatch #*J. Rogge, Senior Resident Inspector, Vogtle O
- Attended exit interview
# Attended management meeting #* Attended both management meeting and exit interview
- 2. NRC/GPC/APC/SCS Management Meeting D
A management meeting concerning GPC/APC/SCS corporate responsibilities was conducted at our request on December 19, 1988. This meeting was held at the GPC/APC/SCS Corporate Office in Birmingham, Alabama to discuss nuclear plant oversight responsibilities, technical support responsibilities, and activities of the corporate organization. D The meeting provided infonna?n to NRC management regarding organiza-tional changes that were maw. 'n anticipation of the formulation of the operating company for management of Vogtle Hatch, and Farley and also assisted in providing the NRC an understanding of how the new organi-zation functions. The meeting also served as the starting point for the D team inspection to verify that the organization was in place and was functioning. Copies of the handouts provided during your presentation are included in Enclosure 2. D 3. GPC/APC Corporate Organization In preparation for combining the management of Vogtle, Hatch, and Farley into one organization, GPC has reorganized and moved the corporate nuclear e I l
t
- 3) l
?
3 i '3 i operations functions to Birmingham, Alabama. The combined organization ! consists of personnel from three companies, GPC, APC, and SCS. Currt.ntly, ' the Executive V4 9e President and Senior Vice President for Nuclear Opera- ! tions are offict rs of both GPC and APC. All other project positions are ! specific to either GPC or APC. Support functions reporting to the Execu-9 tive Vice President currently are in SCS. Upon fonnation of the operating l company, all of the nuclear operations and the support group will be under i the new operating company. i The corporate organization which is referred to as the SONOPCO Project is l headed by the Executive Vice President. The Vice President of Technical ; "A Services and Vice President of Administration report to the Executive vice > President of Nuclear Operations. j The Vice Presidents for each of the three projects (Vogtle, Hatch, and f Farley) report to the Senior Vice President of Nuclear Operations. Each ! Project Vice President has repo_rting to him a corporate staff headed by j g' the General Manager of Nuclear Support, the Safety Review Board, the ; Manager of the Safety Audit and Engineering Review Group, and the nuclear : plant Gefieral Manager. j The inspectors participated in a meeting with corporate management which is semmarized in Section 2 of this report and conducted interviews with ! g corporate management to determine if the organization was in place and ! functioning as described in Amendment No. 39 to the Vogtle Final Safety l Analysis Report (FSAR). J The inspectors determined the organization was in place. The majority of technical positions had been filled with qualified personnel; however, a ! 9 number of administrative positions were yet to be filled. Management : appears to be aggressively active in fully staffing the organization with i many of the positions being filled by personnel with experience at nuclear l plants. Operational Procedures were in the ptocess of being revised and l are due to be completed in February 1989. In the meantime, the existing ! corporate procedures for GPC and APC were in effect. Training classes i 3 were being planned to start in January 1989 for managers that did not have ! actual experience on their assigned plant, j The managers interviewed were knowledgeable of their responsibilities; l however, the philosophy'of operations of. the corporate staff has changed : from an overview function to that of support to the site organization. In l 3 general, corporate line management has the responsibility for overviewing l and directing the site organization. The corporate staff provides and/or ; obains technical support from the Technical Services Organization. This l philosophy of operation was not reflected in Amendment 39 to the Vogtle- ! FSAR. In a letter to the NRC dated December 29, 1988, the licensee l committed to update the FSAR to reflect this new philosophy in a future l 9 change to the FSAR. The inspectors concluded that philosophy of corporate operation was sound, ; and although full staffing was not complete, most of the key positions ; had been' filled and the organization was functioning, q O ; i
) i ) 4. Technical Services > The Technical Services Organization reports to the Executive Vice : President of Nuclear Operations and consists of a Nuclear Fuel group; an Inspection and Testing Services group; a Regulatory, Engineering, and Environmental Services group; and a Quality Services group. The Nuclear Fuel group and the Inspection and Testing Services group were transferred from SCS, are fully staffed, and perform the same functions as prior to the reorganization. The Regulatory, Engineering, and Environment Services group has been newly ' ) formed to provide support in the areas of environmental issues, chemistry, health physics, emergency planning,10 CFR Part 21 evaluations, generic engineering issues, specialized engineering services, probabilistic risk analysis, and plant licensing issues. At the time of this inspection, the ! different areas of this group were at various levels of staffing; however, j management appeared to be aggressively pursuing staffing with well ) qualified individuals. The Manager of Environmental Serv 1ces reports to the Manager of Regulatory Engineering and Environmental Services. The functional support responsi-bilities that SCS provides is listed in FSAR Chapter 13.1.1.1.3 but is not fully described. This key manager's resume was deleted from the FSAR as ) part of recent FSAR amendment. The inspector referenced the deleted resume in reviewhig the individual's qualifications. In discussion with this manager, the inspector was informed that his duties had essentially not changed from those he was performing prior to the establishment of the new corporate structure except that he now had responsibilities for support of the Farley project. In general, this manager's function is to ) provide support for environmental, health physics, and plant chemistry support. The inspector concluded that this manager had the necessary qualifications and experience necessary for the development and implementation at this support function. ) The Quality Services group is discussed in Section 9 of this report.
- 5. Vogtle Project Staffing of the Vogtle Project Corporate organization was approximately
) 80 percent complete with all key positions filled with well qualified individuals. Management was aggressively pursuing the filling of the - remaining positions with personnel from the site. Personnel were knowledgeabic of their responsibilities, and the organization was functioning. ) a. Nuclear Engineering and Licensing (Vogtle) The Manager of Nuclear Engineering and Licensing reports directly to the General Manager of Nuclear Support. The inspector met separatel* with the Manager of Nuclear Engineering and Licensing, Manager of )
I 4 - 5 D Engineering, Manager of Licensing, Emergency Planning Coordinator, and Nuclear Fuels Coordinator. Each manager's functions and role with respect to the plant staff, SCS, and Bechtel support were discussed as well as the implementation of the new organization. O The overall philosophy of the support for Plant Vogtle was discussed with the Manager of Engineering and was verified by each of the other managers. This philosophy is to provide support as requested by the - plant and to act as middleman between the plant staff and SCS and Bechtel support, providing project management and control of needed ! technical support. It is intended that the plant staff be freed of 3 noncritical operational responsibilities and have these responsibi-lities picked up by Plant Vogtle technical support, thereby allowing the plant staff to focus on the operations and maintenance of the plant. The staffing for the support organization under the Manager of O Nuclear Engineering and Licensing is essentially complete. The individuals presently assigned to the position appear to be well qualified. The Manager of Engineering provHes support in the area of engineering. He provides an interface between plant engineering, O SCS, and Bechtel; provides project management functions for design changes and modifications; and exercises controls and assistance in meeting the needs of the plant staff. At present, a Plant Field Engineer Organization group comprised of about 80 SCS and Bechtel personnel are assigned to meet the needs of the plant during the preoperational and startup phases. At the completion of Vogtle O Unit 2 Construction, this group will be disbanded and most of the Engineers will go to either SCS, Bechtel, or the 50NOPC0 Project. Project control over these dedicated groups will be provided by the Manager of Engineering. O The Manager of Licensing provides licensing support for both Vogtle units. This is a change from the past when the licensing effort for , a plant under construction (Vogtle 2) was done by SCS. The licensing group has also relieved the plant staff of the management function with respect to NRC Bulletins, Generic Letters, and NRC requests for information. 3 The Emergency Planning Coordinator provides for the coordination of the Corporate Emergency Plan with respect to Plant Vogtle. There has been little change in the function of this position except that in the near term, corporate support is to be provided by a joint Vogtle-Hatch group. This support function will eventually be split so that g separate groups will provide support for Vogtle and Hatch. Addi-tionally, Technical Services will provide support of a generic nature with respect to contacts and agreements with state agencies. A memorandum dated October 1988 revised the titles to reflect the new organization, and a change in the corporate plan to reflect the new titles and responsibilities is in preparation. Since the corporate O
) ' 6 ! 1 plan for Vogtle is an appendix to the site plan, these changes require approval of plant management. The Nuclear Fuel Coordinator is a new function for both Plant Vogtle and Plant Hatch. The coordinator provides support to the plants in ) the implementation of the fuel management program and provides management and coordination between the plants' needs and the Fuel Design Group of Technical Services. The organization described above has been implemented and is opera- . tional. The development of new procedures has not been completed for ) the implementation of the organization, and the licensee is currently ! operating under GPC corporate procedures. It is anticipated that the new procedures will be completed in February 1989.
- b. Nuclear Administration (Vogtle) '
) The Manager of Nuclear Administration reports directly to the General Manager of Nuclear Support. Responsibilities of the Administration Manager are delineated in FSAR Chapter 13.1.1.2.2.6 and the manager's resume is presented in Table 13.1.1-1. Reporting to this manager are four supervisors with the following - ) titles: Supervisor Planning & Performance Supervisor Material Support Supervisor Document Control Supervisor Admin Support ) The inspector reviewed the responsibilities and staffing levels of the manager's dema.'t. As each of the eight FSAR responsibilities were discussed, tv e ;csev. tor determined that the FSAR requirements were not reflective 9 the new corporate support role concept. The licensee is currently .3 a teansition period to this new concept. ) While the original Georgib Nr Corporate Policy and Instructions are being implemented, new policy and instructions are being drafted. The procedure development schedule was reviewed. These procedures have been prioritized with critical procedures targeted for comple- ! tion in January 1989. ) The overall staffing of the department was 50 percent (12 of 24 positions) complete. Plans for completion of staffing were discussed , with the Vice President of the Vogtle Project. The corporate plans ' project full staffing by June 1989 with the majority of positions to be filled by current Vogtle site personnel. The inspector determined that the staffing would be performed consistent with the establish-
) ment of corporate procedures and the assumption of site support requests.
) l
[ ; I p In general, the inspector concluded that the department was in the l process of transitioning to a fully staffed support department consistent with the support responsibilities currently in piace.
- c. Nuclear Maintenance and Support ;
)1 . The Manager of Nuclear Maintenance reports to the General Manager of I Nuclear Support. Responsibilities of the Maintenance Manager are ! delineated in FSAR Chapter 13.1.1.2.2.6. j i The inspector conducted an interview of the Manager of Nuclear l ) Maintenance to determine the staffing levels, the Manager's ! perception of his responsibilities, and whether the group was ; functional. This group appeared to be in the initial stages of implementation with approximately one half of the positions filled. ; The Manager was filling the positions with well qualified personnel ; from the plant. Full staffing is expected by June 1989. ) ' ine Manager's perception of the responsibilities were in line with ; the philosophy that the group would support the site organization in the areas of maintenance program evaluation, . maintenance trend ; evaluation, planning and scheduling, outage management, maintenance ! plars and budgets, and inservice testing programs. Although all ' )^ functional areas described in the FSAR were included. .the FSAR did not reflect the new corporate support role concept. The licensee is l currently in a transition period to this new concept. While the original Corporate Policy and Instructions are being implemented, new l policy and instructions are being developed. These procedures are ' scheduled to be complete by February 1989. ) 6. Farley Project Organization The inspectors met with members of the Farley corporate staff and received l an overview of the organizational and functional responsibilities of each , component of the Farley corporate staff. Specific questions were answered ) satisfactorily. Although the organization is consistent with Technical Specification 6.2.1.a. b, and c; FSAR Figures 13.14 and 17.2-1 do not , reflect the new position of Vice President-Nuclear inserted in the line organization reporting to the Senior Vice President. The next FSAR update i will reflect this change. A dedicated mission to support the plant was : comunicated to the inspectors. Overall qualifications and experience i ) levels of the staff were satisfactory.
- 7. Hatch Project' Organization The inspectors met with members of the Hatch corporate staff and received I an overview of the organizational and functional responsibilities of each
) component of the Hatch corporate staff. The managerial positions are fully staffed except for the General Manager Nuclear Support position. i ) > l
O 8 O There were approximately ten other vacancies that had not yet been filled. These positions were mostly clerical in nature. Management was ' aggressively pursuing the filling of the remaining positions. The , organization was staffed with well qualified personnel and in many cases 4 with personnel who performed similar functions in the old organization or ' O personnel obtained from Plant Hatch. The activities were being performed utilizing the existing GPC procedures until the procedures are revised. This is expected to be accomplished by February 1989. . .O 8. Corporate Safety Review Activities Activities of the Safety Review Board (SRB) for Hatch and Vogtle were reviewed to determined how the Board's review and audit functions deline-ated in Sections 6.0 of the Hatch and Vogtle technical specifications are addressed. This effort involved discussions with the Nuclear Safety O Review Manager, the review of licensee policies and instructions relating to SRB operations, and the review of SRB and SRB subcomittee meeting minutes. - The inspector confirmed that the licensee's SRB continues to be comon to both the Hatch and Vogtle Projects. The SRB currently consists of nine O voting members plus the chairman. The SRB subcommittee is relied upon heavily to conduct the more routine reviews for which the SRB is respon- l sible. The subcomittee currently consists of fourteen members plus the chairman. Twelve of the subcomittee members are consultants, and the remaining two are GPC employees. The size and composition of the subcom-mittee for any given meeting varies depending on the technical expertise [ J required for the particular matters under consideration. The licensee has ' selected SRB and SRB subcomittee membert to provide technical expertise in the areas specified in Section 6.5.2.1 of the Hatch technical specifi-cations and Section 6.4.2.1 of the Vogtle technical specifications. The inspector also determined that the SRB continues to function under D written GPC policies and instructions. Policy NOP-10-400, " Safety Review Board," defines the authority, organization, responsibility, and method of operation of the SRB. Instruction NOI-10-401, " Conduct of Nuclear Safety Review Board Meeting," describes the necessary steps required to schedule, conduct, and document SRB meetings. Instruction NOI-10-402, " Safety ; Review Board Review .of Documentary Material," provides instructions to 3 ensure a consistent, minimum standard of review for the review of SRB ; documentary material. Instruction N01-10-403, " Process of SRB Mater.ial," describes steps to ensure the proper receipt, initial screening, trans-mittal, and documentation of SRB review material. Instruction N01-10-404,
" SRB Records Retention and Handling," specifies SRB documents to be O
retained, the location of retention, and durt. tion of retention. Instruc-tion NOI-10-405, " SRB Subcomittees," defines the authority and method of i i 9
O 9 e operation of SRB subcomittees and establishes a minimum standard of review; and Instruction NOI-10-406, " SRB Conduct of Onsite Reviews and Audits," describes steps to be accomplished to ensure proper performance, preparation, and reporting of onsite reviews and audits conducted by or under the cognizance of the SRB. The inspector reviewed these policies e and instructions and noted that the technical specification requirements related to SRB composition, the use of alternates, meeting frequency, minimum quorum, authority, and records had been incorporated into these documents. Based on discussions with the Nuclear Operations Review Board (NORB) O chaiman for Farley and review of the material noted below, the inspectors determined that Farley Technical Specification 6.5.2 requirements were being met. Material reviewed included: minutes of NORB Meeting No. 88-3 held on September 21, 1988; meeting agenda and agenda items for March 16, 1988, NORB meeting O dated March 1, 1988; meeting agenda and agenda items for December 15, 1988, NORB meeting dated November 30, 1988; Plant (AugustOperating 4, 1988 ) Review through Comittee minutes for 1930 (September 29, meetings Nos.1908 1988) dispatched for NORB review by letter dated November 30, 1988; and p
- Safety Evaluation (35) for NORB Review transmitted by letter dated November 23, 1988.
- 9. Quality Organization The realignment of the GPC corporate organizational structure to provide O
development of the 50NOPC0 Project management organization included changes in the GPC quality organization. Section 17, Amendment 39 of the Vogtle FSAR described the present Vogtle (plant and corporate) cuality organizations implemented on October 31, 1988. Generally, this amendment provided a renaming of the quality organization and a separation in the corporate reporting chains for the GPC plants (Vogtle and Hatch). The O operational quality organization, previously the Quality Assurance Depart-ment, is now titled, Safety Audit and Engineering Review (SAER) organiza-tion. The Vogtle Unit 2 construction organization remains the Quality Assurance Department with its previous reporting line through the Vogtle Project organization. O The quality organization corporate realignment basically separates the two GPC plants and provides a direct reporting chain from the site quality organization (site-SAER) via the corporate quality organization (SAER-GO) to the Vice President of Nuclear Operations, which is the highest line manager directly responsible for plant activities. This chain is unique
# to each plant site in the SONOPC0 Project (Vogtle, Hatch, and Farley).
Prior to Amendment 39, the Vogtle and Hatch quality organizations reported through a common general manager to the Senior Executive Vice President. O
O 10 0 Continuity of previous GPC corporate quality organization experience has been maintained. The previous GPC staff of four audit / engineers has been divided between the Vogtle SAER-GO, Hatc' SAER-G0, and a corporate tech-nical services quality organization, the Quality Services group. The SAER-G0 staffs will each consist of one manager, two audit / engineers, and 3 one clerical person. Currently, the only vacancies in the SAER organiza-tions are one audit / engineer in each of the Hatch and Vogtle SAER-G0 staffs. All management positions are occupied, and the vacancies do not impede the scheduled SAER-G0 du? es or responsibilities. Additional changes implemented by the 50NOPC0 project organization 3 included the formation of another quality organization group and the addition of the Independent Safety Engineering Group (ISEG) to the quality organization reporting chain. The new corporate quality group, Quality Services, maintains the Qua'ity Suppliers List (QSL), audits and reviews vendors / suppliers, and audits various corporate non-design, non-plant specific, engineering functions. This group relieves the individual plant 3 SAER organizations of the responsibility for vendor audit activity. The ISEG previously reported to the Vice President of Nuclear Operations via the corporate maintenance manager. As a result of Amendment 39, the ISEG will utilize the independent reporting chain of the SAER organization, reporting to the site Vice President of Nuclear Operations via the SAER Manager. This rertrting realignment does not impact the independence of 3 eithsr the quality organization or the ISEG. No quality program changes or comitment reductions have occurred due to the reorganization of the GPC quality organizations. %eview of the Vogtle 1988 schedule of audit activity in conjunction with the projected 1989 schedule indicated no reduction in corporate quality assurance activity or 3 responsibili+1es. At present, the resources are available to fulfill all previous and current audit, review, and oversight activities that were required prior to the reorganization. In summary, the corporate reorganization indicated in Vogtle FSAR Section 17 with respect to the quality organization management has been e :nplementen since November 1,1988. All management positions are filled. The major ::hanges occurred on the corporate level with no changes at the site other than a name change. The following summarizes the corporate level changes:
- a. GPC quality organization reporting responsibilities have been
$ separated to provide independent reporting chains for each plant (Vogtle, Hatch) to the respective plant specific nuclear Vice President.
- b. The above reporting line has dropped one functional level from the Senior Executive Vice President.
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- c. Vendor / surveillance audit and QSL maintenance activity has been transferred entirely to the corporate Quality Services group.
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- d. The ISEG reporting chain to the Vice President of Nuclear Operations utilizes the SAER reporting chain. -'
- e. The operations cuality organization is now called the Safety Audit i and Engineering Review organization. ;
This review provided no indication that the implementation of the quality organization described in Vogtle FSAR Amendment 39, Section 17. has resulted in an adverse impact on previous or present quality organization : activity or comitments at Plant Vogtle. - Based on discussion with the SAER group Manager and review of documented ). - material, the inspector determined that Farley Technical Specification 6.2.3 requirements were being met. The SAER group technical staff is + composed of senior engineers with varied nuclear background with emphasis ! on operating experience. Several senior managers have worked in this ( group. Thus, it is utilized as one technique of job progression. Audit ) findings reviewed indicate an indepth review is being performed with j followup perfomed of corrective actions 'of audit findings. The resident i inspectors have periodic interface with this group. ! l
- 10. Exit Interview (30703) !
I An exit meeting was conducted on December 21, 1988, where the scope and ; ) findings were sumarized with those persons indicated in paragraph 1, I above. The inspector described the areas inspected and discussed in detail the results listed below. Proprietary information is not contained ; in this report. Dissenting comments were not received from the licensee. ' ) The organization is in place and functioning. l Some vacancies do exist, but management is aggressively pursuing the I filling of these positions with personnel from the plants. i The philosophy of operations of the corporate staff functioning in a ) support role as opposed to an overview role appears sound. : Procedures are being revised to reflect the reorganization and responsibilities. 1.icensee management stated that this will be i accomplished by February 1989, i ) The Vogtle FSAR needed to be upgraded to reflect the philosophy of - the corporate staff functioning in a support role. Subsequent to the inspection, the licensee comitted in a letter to the NRC dated December 29, 1988, to revise the Vogtle FSAR when the organiztional interfaces were fully established. )- The inspection team concluded that the corporate organizations were sufficiently established and functioning to adequately support Vogtle Unit 2 licensing. ' )
, , , __. , ~ _ - - - - - - - -
AGENDA NRC ORGANIZATIONAL MEETING BIRMINGHAM, ALABAMA MONDAY, DECEMBER 19, 1988
- INTRODUCTION W.G. HAIRSTON, III - OVERALL ORGANIZATION W.G. HAIRSTON, III - HATCH J.T. BECKHAM - FARLEY J.D. WOODARD R - TECHNICAL SERVICES L.B. LONG 5 - V0GTLE ORGANIZATION C.K. MCC0Y $ - QUALITY ASSURANCE P.D. RUSHTON , - PLANT SUPPORT W.B. SHIPMAN l - ENGINEERING AND LICENSING J.P. KANE ; - EMERGENCY PLANNING J.J. BADGETT - MAINTENANCE AND SUPPORT H.P. WALKER - ADMINISTRATION- C.P. STINESPRING T - SAFETY REVIEW BOARD E.F. COBB - DISCUSS AGENDA FOR TUESDAY - CONCLUSION
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O U O- 0 0 O U U U U U LXCUTNE VICE PRESDENT SENIOR VICE PRESDENT I WCE PRESSENT VICE PRESDENT VICE PRESDENT MCE PRESIDENT TECHNICAL SERVICES VEGP HNP FNP MANAGER MANAGER SAER GENERAL MANAGER GENERAL MANAGER QUALITY SERVICES VEGP NUCLEAR SUPPORT VEGP l VEGP I l STAFF STAFF SUPERVISOR l SAER QUALITY ASSURANCE ORGANIZATIONS i AS OF OCTOBER 31,1988 STAFF 1 {
3 t 3 GUALITY ASSURANCE ORGANIZATIONAL CHANGES : i i L t O SEPARATED HNP, VEGP OPERATIONS AND VEGP ; CONSTRUCTION QA ORGANIZATIONS. O QUALITY ASSURANCE DEPARTMENT RENAMED SAFETY AUDIT & ENGINEERING REVIEW. O RESPECTIVE MANAGERS REPORT TO RESPONSIBLE g VICE PRESIDENTS. l 0 VEGP CONSTRUCTION QA IS WINDING DOWN, SOME : PERSONNEL ARE ROLLING OVER TO OPERATIONS QA. O O CORPORATE QUALITY SERVICES HAS RESPONSIBILITf i FOR SUPPLIER QUALIFICATIONS FOR ALL 3 PROJECTS. O QA MANUALS SPECIFIC TO EACH FUNCTION WILL 0 BE ISSUED. EXISTING QA MANUAL HAS BEEN ENDORSED BY PROJECT VP AND CONTINUES IN EFFECT. O l o l o
O O O O O O ,O O O O O V0GTLE PROJECT MGR MUC ENGR AND LICENSING J.P. KANE
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NUCLEAR SUPPORT ENGINEERING FUNCTIONS AND RESPONSIBILITIES D o Provide Dedicated Technical Engineering to support the safe and reliable operations of Plant Yogtle. l o Direct and control A/E support. O i o Manage Engineering projects as requested by the Plant staff. D o Conduct special Engineering studies and analyses to support Plant , Operations. ! O o Independently respond to designated NRC, Yendor INPO and Industry , issues. O o Ensure that a configuration control system is maintained. o , Ensure proper contractor controls for contracted engineering services. O o Ensure appropriate design interface controls between organizations performing engineering work affecting design. i O o Help resolve Plant problems to help the Plant mitigate emergency ; conditions. O O l
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O November 23, 1998 U.S. Nuclear Regulatory Commission File: X7N00.0-39 Aten.: D cument Control Desk Log: G4-1502 j O ~4ashington, D.C. 20555 l NRC DOCKET NUMBERS 50-424 AND 50-425 OPERATING LICENSE NPF-68 l CONSTRUCTION PERMIT NUMBER CPPR-109 j O YOGTLE ELECTRIC GENERATING PIANI - UNITS 1 AND 2 FSAR AMENDMENT NUMBER 39 : Gentlemen: Georgia Power Company, acting on its own behalf and as agent for Oglethorpe 0, Power Corporation, Municipal Electric Authority of Georgia, and the City of 4 Dalton, Georgia, hereby submits Amendment 39 to the Vogtle Electric Generating h Plant (YEGP) Final Safety Analysis Report (FSAR). The changes resulting from this amendment are identified in the Attachment. i These chanses are applicable to both Units 1 and 2. All substantive changen, l 0 for Unit 1, were evaluated as required by Title 10 CFR 50.59. This amendment contains all the known processed changes for Unit 2 as of October 31, 1988. Due to the time lag associated with the as-built notification process, not all of the FSAR figures have been updated in this amendment. Our submittals to the staff, as noted in the Attachment, do contain the information on drawing modification sheets and provide the appropriate cross references to the g affected FSAR figures. Your staff will be notified should the final drawings i materially differ from what was previously provided. In accordance with the requirements of Title 10 CFR 50.30(f) and ! Title 10 CFR 50.4(b), one (1) signed original and thirty-seven (37) copies of ; Amendment 39 are submitted for your use. Also in accordance with the O requirements of Title 10 CFR 50.4(b), copies of Amendment 39 are being sent to the NRC Regional Office and the NRC Resident Inspector. O 0; .
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1. 4 4 - U.S. Nuclear Regulatory Commission File: I7N00.0-39 ' November 23, 1988 Log: GN-1502 Page 2 . h I Should you have any questions on the enclosed submittal, do not hesitate to l contact me. Yours truly, D " & . l P. D. Rice : SWORN AND SUBSCRIBED BEFORE ME, THIS h DAY OF November , 1988. J bhO 'Nogazeif Public Alabama State at Large ) My commission expires N M' M l PDR/sm Attachment xc: NRC Regional Administrator NRC Resident Inspector U FSAR Distribution List f D J D ? 1 15487 1
M i VEGP-FSAR-13
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l l l l O O 13.1.1.2.2 Nuclear Operations Organization The nuclear operations organization, under the supervision of the executive vice president-nuclear operations, has direct responsibility for the operation and maintenance of GPC's nuclear h) plants. The nuclear operations organization consists of the plant operating staffs, the safety audit and engineering review organization, and the nuclear support (Vogtle) organization which provides support in the areas of engineering, licensing, maintenance, and administration.
) Engineering support during plant operation will be provided primarily by the SCS Nuclear Plant Support Department. The SCS Technical Services-Nuclear Department will provide nuclear fuel contract administrative services, reload licensing, and operating licensing support. The structure of the General Office organization is shown in figures 13.1.1-2 and 13.1.1-3 and is O described in the following paragraphs.
D 13.1.1.2.2.1 Executive Vice President-Nuclear Operations. The executive vice president-nuclear operations, an officer of both Georgia Power Company (GPC) and Alabama Power Company (APC), is responsible to the chairman and CEOs of each company for all O aspects of operation of the nuclear generating plants in the GPC and APC systems, as well as technical and administrative support activities provided by SCS. The executive vice president-nuclear operations directs the senior vice president-nuclear operations in fulfillment of his responsibility. O Amend. 16 4/85 Amend. 24 6/86 Amend. 25 9/86 Amend. 26 10/86 Amend. 29 11/86 O Amend. 35 3/88
' 13.1.1-7 Amend. 39 11/88
A m VEGP-ESAR-13
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i O 13.1.1.2.2.2 Senior Vice President-Nuclear Operations. The senior vice president-nuclear operations, an officer of both Georgia Power Company (GPC) and Alabama Power. Company (APC), reports to the executive vice president-nuclear operations. This individual is responsible for the safe, reliable, and efficient operation of Plants Vogtle, Hatch, and Farley. The senior vice () president-nuclear operations directs the efforts of the vice president-nuclear (Vogtle), the vice president-nuclear (Hatch), and the vice president-nuclear (Farley). 13.1.1.2.2.3 Vice President-Nuclear (Vogtle). The vice o president-nuclear (Vogtle) reports to the senior vice president-nuclear operations and is responsible for operation and maintenance of Plant Vogtle as well as licensing, engineering, maintenance, and administrative support activities. The vice president-nuclear (Vogtle) directs the general manager-nuclear plant (Vogtle), the general manager-nuclear support (Vogtle), and () the manager-safety audit and engineering raview (Vogtle). 13.1.1.2.2.4 General Manager - Nuclear Support (Vogtle). The general manager-nuclear support (Vogtle) reports to the vice president-nuclear (Vogtle) and is responsible for corporate O supp rt in the areas of engineering, licensing, maintenance, and administration. The general manager-nuclear support (Vogtle) directs the manager-nuclear engineering and licensing (Vogtle), the manager-nuclear maintenance and support (Vogtle), and the manager-nuclear administration (Vogtle). 13.1.1.2.2.5 Manager-Safety Audit and Engineering Review (Vogtle). The responsibilities of the manager-safety audit and engineering review (Vogtle) are described in section 17.2.
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Amend. 16 4/85 g Amend. 24 6/86 Amend. 25 9/86 Amend. 26 10/86 Amend. 29 11/86 Amend. 35 3/88 13.1.1-8 Amend. 39 11/88 O
1 I CNAIRMAN AND
]
CEO J-PRESIDENT
) EXECUTIVE VICE PRESIDENT SENIOR EXECUTIVE NUCLEAR OPERATIONS YlCE PRESIDENT J
SENIOR VICE PR S DENT V T P CT E " "" NUCLEAR OPERATIONS
& FUEL E DIRECTOR POWER unnom
'D D J Amend. 3 1/84 Amend. 16 4/85
- Amend. 24 6/86 Amend. 25 9/86 ) Amend. 26 Amend. 39 10/86 11/88 vooTLE CORPORATE ORGANIZATION Georgia Power d MT ,"ANo s"*"""'*"' VEGP UNITS 1 AND 2 ] ,
FIGURE 13.1.1-1 m.,
v v v v- v v -C v .v
.v ._ _u \
EXECUTIVE VICE PRESIDENT NUCLEAR OPERATIONS G. A SENIOR VICE PRESIDENT NUCLEAR OPERATIONS G. A I I VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT NUCLEAR NUCLEAR NUCLEAR (Vogue) (Farley) (Hetch) G A G fF0068t02013 LEGEND Amend. 16 4/85 Amend. 24 6/86 A = APC Amend. 25 9/86 G = GPC Amend. 26 10/86 Amend. 29 11/86 Amend. 35 3/88 Amend. 39 11/88 mygg NUCLEAR OPERATIONS ORGANIZATION
c"c a'"a**"'a= VEGP UNITS 1 AND 2 GeoreiaIbwer 08 A Ufelf 1 AND USHT 2 FIGURE 13.1.1-2i
f LL_ U U U U . U U U M V. ,,-L) - l
- VICE PRESIDENT MUCLEAR
\
(Vogine) SAFET's REVIEW BOARD I GENERAL MANAGER GENERAL MANAGER NUCLEAR SUPPORT NUCLEAR PLANT (Vog#el (Vogtle) I I MANAGER - NUCLEAR MANAGER - NUCLEAR MANAGER - NUCLEAR MANAGER - SAFETY mesNe64WFFORT ADtMNISTRATION STAFF AUDIT & ENG. ENG. & LICENSING (Vogtle) (Vogtle) (Vogtie) REVIEW (Vogtle) l I I I I I STAFF STAFF STAFF ONSITE SUPERVISOR
- SAFETY AUDIT & STAFF ,
t ENG. REVIEW I i INDEPE9WENT
- ON$tTE STAFF SAFTTV ENGs0EERING E GROurONSnE g
Asnend. 15 3/85 Amend. 16 4/85 Amend. 24 6/86 Amend. 26 10/96 Amend. 29 11/86 Amend. 35 3/88 Amend. 39 11/88 TECHNICAL SUPPORT ORGANIZATION
" " " " " * ^ " '
ceo ia lbwer A Ucc a="^"= *"' UNIT 1 ANO UNIT 2 FIGURE 13.1.1-3 : _ _ - - - _ __ _ _ ___._______m__- _ _ _ _ . _ _ - - .
k y
- . ..~ .
i w: , D ~ ELV- 00128 X7GJ17-Y200 0890D December 29, 1988 U. S. Nuclear Regulatory Comission ATTN: Document Control Desk Washington, D. C. 20555 PLANT YOGTLE - UNITS 1, and 2 NRC DOCKET 50-424, 50-425 OPERATING LICENSE NPF-68, CONSTRUCTION PERMIT CPPR-109 p FSAR CHAPTER 13 DESCRIPTION Gentlemen: During the NRC visit at our Birmingham offices on December 19-21, 1988, M, you discussed a concern about potential differences between the FSAR Chapter j 13 description of our corporate responsibilities and that which we verbally described to you at the meeting. We want to assure you that the information r.4 conveyed to you at the meeting is the way we are operating and the way we plan to operate in the future. That is, the Nuclear Support Departments in the (j ' corporate office are organized as a staff function to support the plant L O operation and not as a line function to direct the operation of the lant. However, as shown on FSAR Figures 13.1.1-2 and 13.1.1-3, the Executi e Vice President, the Senior Vice President-Nuclear Operations and the Vice President-Nuclear, do provide lihe management direction for the operation of the Plant. O As you are aware, the application to form the Southern Nuclear Operating Company (SONOPCO) has been submitted to the Security Exchange Comission (SEC) for approval. Once this application has been approved and implemented, we will be submitting an appropriate application to the NRC to amend the licenses for the Vogtle Units. At this time, we will thoroughly review and revise Chapter 13 of the FSAR as appropriate, to resolve any ambiguities that may exist. Should you have any questions concerning the above, please inquire. Sincerely. . s.J. Asr-W. G. Hairston, III JAB /ijb c: See next page 6 i
,a . r; 4g I Georgia Power n U. S. Nuclear Regulatory Commission ELV-00128 December 29, 1988
, Page Two J
c: Georgia Power Company Mr. P. D. Rice _ Hr. C. K. McCoy J Mr. G. Beckhold, Jr. Hr. J. E. Swartzweider GO-NORMS Yogtle-NORMS
-, U. S. Nuclear Regulatory Commission J
Mr. H. L. Ernst. Acting Regional Administrator Mr. J. B. Hopkins, Licensing Project Manager, NRR (2 copies) Mr. J. F. Rogge, Senior Resident Inspector-Operations, Yogtle O O g O e O i
g/" e,' 8s UNITED STATES {,( [ }, ;}, NUCLEAR REGULATORY COMMISSION W A SHIN GTO N, D. C. 20555 h
/ August 3, 1989 Docket Nos. 50-321, 50-366 50-424, 50-425 LICENSEE: Georgia Power Company FACILITY: Plant Vogtle, Units 1 and 2 Plant Hatch, Units 1 and 2
SUBJECT:
SUMMARY
OF JULY 25, 1989 GPC/NRC INTERFACE MEETING On July 25, 1989, the NRC staff (including NRR Project Vanagers, Region II personnel, and resident inspectors for both Hatch and Vogtle plants) met with representatives of the Georgia Power Company (GPC) in Birmingham, Alabama to _J discuss the 50NOPC0/GPC corporate organization including generic activities and initiatives involving the Vogtle and Hatch plants. This interface meeting was proposed by the NRC staff and was the first of its kind with GPC. Subsequent meetings are expected to be held on a bimonthly basis to discuss issues that have potential for impacting both NRC and GPC organizations. The intent of _ these meetings is to foster an open communication and information exchange and J in this regard the sneeting was a success. Messrs. G. Hairston, T. Beckham, K. McCoy, L. Long, and K. McCracken provided an overview of the current SONOPC0 (still pending SEC approval) corporate structure, responsibilities, and interface with the Hatch and Vogtle plants. Essentially, the 50NOPC0 organization including its support role for the Hatch J and Vogtle plants remains unchanged from previous GPC presentations to the staff. The afternoon session consisted of separate breakout meetings for the Patch and Vogtle projects wherein upcoming priority issues were discussed. Meeting
, participants are listed in Enclosure 1. The slides presented by GPC are o provided in Enclosure 2. The next GPC/NRC interface meeting is tentatively scheduled for October at the Vogtle plant.
J Timothy A. Reed, Project Manager Project Directorate 11-3 Division of Reactor Projects I/II Office of Nuclear Reactor Regulation l
Enclosures:
As stated cc w/ encl: See next page l l
4 )' .. l
. l
) cC' G. F. Trewbridge, Esq. Mr. R. P. Mcdonald Shaw, Pittman, Potts and Trowbridge Executive Vice President - 2300 N Street, N. W. Nuclear Operations Washington, D.C. 20037 Georgia Power Company ) P.O. Box 1295 , Mr. L. T. Gucwa Birmingham, Alabama 35201 . Engineering Department Georgia Power Company Mr. Alan R. Herdt, Chief P. O. Box 1295 Project Branch f 3 Birmingham, Alabama 35201 U.S. Nuclear Regulatory Comission ) 101 Marietta Street, NW, Suite 2900 Huclear Safety and Compliance Manager Atlanta, Georgia 30323 Edwin I. Hatch fbclear Plant Georgia Power Company J. A. Bailey P. O. Ecx 442 Manager - Licensing Baxley , Georgia 31513 Georgia Power Company ) Mr. Louis B. Long P.O. Box 1295 Birmingham, Alabama 35201 Southern Company Services, Inc. P. O. Box 1295 Bruce W. Churchill, Esq. Birmingham, Alabama 35201 Shaw, Pittman, Potts and Trewbridge 2300 N Street, N.W. ) r Resident Inspector Washington, D.C. 20037 U.S. Nuclear Regulatory Commission Route 1, Box 725 Mr. G. Bockhold, Jr. Baxley, Georgia 31513 : General Manager, Nuclear Operations ! Georgia Power Company Fegional Administrator, Region II P.O. Box 1600 ) U.S. Nuclear Regulatory Commission Waynesboro, Georgia 30830 101 Marietta Street, Suite 2900 Atlanta, Georgia 30323 Office cf the County Comissioner Burke County Comission ! Mr. Charles H. Badger Waynesboro, Georgia 30830 Office of Planning and Budget ) Room 610 270 Washington Street, S.W. Office of Planning and Budget Room 615B Atlanta, Georgia 30334 270 Washington Street, S.W. Atlanta, Georgia 30334 Mr. J. Leonard Ledbetter, Director Environmental Protection Division Mr. C. K. McCoy ) Department of Natural Resources Vice President - Nuclear 105 Butler Street, S.E. , Suite 1252 Georgia Power Company Atlanta, Georgia 30334 P.O. Box 1295 Birmingham, Alabama 35201 Chairman Appling County Comissioners
) County Courthouse i Baxley, Georgia 31513 :
F
g >1 h h l
=cc- :
Resident Inspector ! Nuclear Regulatory Commission ): P.O. Box 572 ! Waynesboro, Georgia 30830 James E. Joiner, Esq. > Troutmen, Sanders, Lockerran, t
& Ashmore '
). 1400 Candler Building 127 Peachtree Street, N.E. Atlanta, Georgia 3C303 r Attorney General , Law Department * ) 132 Judicial Building ; Atlanta, Georgia 30323 ! ) ' j ) i ) I t [ i
\
?
i Enclosure I ) . ATTENDEES NAME ORGANIZATION ' Tim Reed ' NRR/PD Ill3 Jon Hopkins ' NRR/PD 11-3 y Jim Meidt GPC Ken McCracken Southern Company Services > Louis Long Southern Company Services Jim Eailey GPC/ Manager - Licensing ) J.T. Beckham, Jr. L'ayne Scott GPC NRR/PQEB David Matthews NRR/D:PD II-3 RA fu er ) Leigh Trocine i C/RII NRC/RII ; John Rogge. NRC/RII/ SRI Vogtle - Steve Bethay GPC Steve Tipps 3 GPC C. Ken McCoy GPC/Vice President - Huclear 1 L.P. Crocker NRR/PD 11-3 J.P. Kane GPC
)
) . l D
. l l
l ) L J
0. Enclosure 2 O Georgia Power /NRC Regulatory Compliance Interface Meeting JULY 25,1989 Yogtle and Hatch Nuclear Plants O AGENDA O
.8:30 AM Opening Remarks W. G. Hairston, III 8:45 AM SONOPCO/GPC Organization J. T. Beckham/
n and Interface with Plants C. K. McCoy/ L. B. Long 10:15 AM Break O 10:30 AM GPC Generic Activities and K. W. McCracken Initiatives for Yogtle and Hatch - 12:00 Noon Lunch 0 1:00 PM GPC/NRC Regulatory Activities J. D. Heidt/ Status for Vogtle and Hatch J. A. Bailey 3:00 PM Summary O O 1
g ,, g
._ .y. _ _ .
_g . . . _ g - . _ .
" HORIZON ISSUES" ACTIVITIES O MONITOR AND ADVISE PROJECTS QUARTERLY ON SPECIFIC EMERGING NRC REGULATORY ISSUES.
O DEVELOP DRAFT COMMENTS ON SELECTED PROPOSED RULES AND COORDINATE DEVELOPMENT OF OWNER COMPANY COMMENTS SOsMITTALS. , 1 O COORDINATE SON 0PC0 PROJECT PARTICIPATION IN REVIEW / DEVELOPMENT OF NUMARC COMMENTS REGARDING PROPOSED RULES. O REPRESENT PROJECTS AS REQUESTED IN INDUSTRY GROUPS. i Y
O l . b TABLE of CONTENTS PEiE Intreduction . . . . . . . . . . . . . . . . . . . . . . . . . . . I NUMARC Priority Issees . . . . . . . . . . . . . . . . . . . . . . 3 Ext e rnal E v ent s ' . . . . . . . . . . . . . . . . . . .' . . . . . . 4 5 P1 ant Life Extension and License Renewal . . . . . . . . . . . . . 10CFR50.59 Safety Evaluations .................. 8 O S e vere A c c i d e n t s . . . . . . . . . . . . . . . . . . . . . . . . . 10 Standardization and Licensing Reform . . . . . . . . . . . . . . . 12 14 Seismic Issues . . . . . . . . . . . . . . . . . . . . . . . . . . O Anticipated Regulatory Issues . . . . . . . . . . . . . . . . . . . . 16 Safety Implications of Control Systems . . . . . . . . . . . . . . 17 Radiation Effects on Reactor Yessel Supports . . . . . . . . . . . 19 . O Inservice Inspection of Fressure Retaining Welds 21 in the Reactor Vessel ...................... Eolting Degradation or Failure . . . . . . . . . . . . . . . . . . 23 0 l 1 I l l O d
< I l
O O
u u - u u u u o---' u u- --u-- o~- FUNCTIONS O PROVIDE TECHNICAL SUPPORT UPON REQUEST
. CONSULTING . SPECIAL STUDIES 1 . PROJECT MANAGEMENT oNyN.ITORLONG-TERMGENERICISSUESANDC0 ORDINATE SON 0PC0 PROJECT OWNER COMPANY ACTIONS i
0 ACT AS CONTRACTUAL INTERFACE POINT FOR GOVERNMENT l AGENCIES REGARDING EMERGENCY PLANNING l ____ ___.__._ _ _______. _ _ __ _ _ ____ _ _ _ _ _ _ _ _ ________________._ _____ ___ _ - _ -. ~ . . _ . -
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j j; YOGTLE PROJECT
, LICENSING SUBMITTALS AWAITING NRC ACTION REQUESTED GPC LETTER GPC LETTER RESPONSE SU8 JECT NO. DATE DATE ).
- 1. Tech Spec Change Request - YL-76 11/7/88 None Containment Hydrogen Monitors ELY-00041 12/8/88
) ELY-00516 5/19/89
- 2. Tech Spec Change Request - Diesel YL-110 11/7/88 None Action Requirements ELY-00517 5/19/89
- 3. Tech Spec Change Request - Deletion ELY-00302 4/5/89 None D- of Temporarty Footnotes 4 Tech Spec Change Request - Unit 1 ELY-00390 4/6/89 None CCP Flow l S. Tech Spec Change Request - Low PRZ ELY-00284 5/8/89 None !
K3 Pressure TA,Z
- 6. Tech Spec Change Request - ELY-00400 5/9/89 7/14/89 Containment Structural Integrity '
- 7. Revision 3 to Unit i ISI Program MSY-00033 5/10/89 None J
- 8. Q. A. Changes ELY-00518 5/18/89 None ELY-00594 6/8/89
- 9. Tech Spec Change Request - Control ELY-00491 5/19/89 None Room HYAC Exception to 3.0.4 j
) 10. Tech Spec Change Request - Reload ELY-00511 6/12/89 10/1/89 Fuel Enrichment ,
- 11. Settlement Monitoring Program ELY-00650 6/23/89 None 3 l 3
J
O O YOGTLE PROJECT LICENSING SUBMllTALS ANTICIPATED IN NEXT 12 MOVTHS ESTIMATED ESTIMATED SUBMITTAL NEED p SUBJECT DATE DATE 1 Revision of VEGP-1 IST Program 07/21/89 09/29/89
- 2. Revision of VEGP-2 IST Program 07/24/89 10/02/89
- 3. Revised Tech Spec Change Request Containment Structural Integrity 07/28/89 08/15/89 4 Tech Spec Change to Heat Up and 07/31/89 N. A.
Cool Down Curves
- 5. RAI on Proposed 08/01/89 N. A.
Change To RTB Maintenance Frequency
- 6. Revision of YEGP-2 ISI Program 08/04/89 11/03/89 O 7. Tech Spec Changes to Mitigate 08/05/89 N. A.
Control Rod Wear
~
- 8. Security Plan Amendment 13 - 10 CFR 50.54(p) 08/25/89 N.A.
Change Incorporating Alternate PESB. O 9. GMR-1 Cannister Exemption Request; also 09/15/89 12/01/89 Request to Change Circuit A to Circuit C Storage
- 10. Tech Spec Change to Unit 2 Unit 2 g Moderator Temperature Coefficient 09/15/89 Cycle 2
- 11. Mild Environmental Qualification Position 11/01/89 Before Paper Refueling
- 12. Results of First Yessel Capsule 11/10/89 Surveillance g
- 13. Tech Spec Change to End-of-Life 11/15/89 N. A.
MTC O O
1 YOGTLE PROJECT LICENSING SUBMITTALS ANTICIPATED IN NEXT 12 MONTHS (CONTINUED) ESTIMATED ESTIMATED SUBMITTAL )- SUBJECT DATE NEED DATE
- 14. Tech Spec Change to Incorporate 12/15/89 N. A.
Standard Westinghouse Precaution for Fuel Assembly Reconstitution ) 15 Response to Generic Letter on MOV's 01 /01 /9 0 03/01/90
- 16. Tech Spec Change to Base Shutdown Unavailable N.' A.
Margin Curves on Critical Boron ) Concentration
- 17. Tech Spec Change to Remove Specific Unavailable N. A.
References to Grid Locations for Fxy Surveillance Exclusion ) 18. Tech Spec Change Concerning Temporary Opening of Locked Unavailable Spring 1990 Valves in Mode 6
- 19. RTD Bypass Removal 01/15/90 06/15/90
) LICENSING SUBMITTALS ANTICIPATED BEYOND NEXT YEAR )
- 1. Re-analyses and Tech Spec Changes 09/15/90 10/15/90 Associated With YANTAGE 5 Fuel
) 2. Request for Power Level Increase 06/15/91 N. A. ) b
Ge: ; a 5:,e.v' cc 4 , 323 P e: :~ be e ea a ce:;a 2',20! Te e-*:te 44 $2C 3'!! 8/a M; A3:'ets C . ..e est cem e Pa ...6, ). P:r 0":e B:,.
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- Te es,:re 2C5 666 558' March 28, 1990 , ,,,,,,,
W. G. Hatrston, til sen.o, vee e,,, :,,: ELV-01291 )- w ei ar oce a:: 0222 Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission ) ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen: V0GTLE ELECTRIC GENERATING PLANT ) INITIAL UPDATED FINAL SAFETY ANALYSIS REPORT In accordance with 10 CFR 50.4(b)(6) and 50.71(e) including the exemption to 50.71(e)(3)(1) published in the Federal Register, Volume 53, Number 86, dated May 4,1988 Georgia Power Company (GPC) hereby submits one signed original and ten copies of the initial Updated Vogtle Electric Generating Plant Final Safety I ) ' Analysis Report. This initial Updated FSAR accurately presents changes made i since the November 23, 1988 submittal of Amendment 39 to the FSAR. Revisions i include changes to reflect information and analyses submitted to the NRC as well as changes that have been made under the provisions of 10 CFR 50.59 through ) September 30, 1989. ) Mr. W. G. Hairston, III states that he is a Senior Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company and that, to the best of his knowledge and belief, the facts set forth in this letter and enclosures are true. GEORGIA POWER COMPANY ) , By: iM M //ceD AC W. G. Hairston, III Sworn to and subscribed before me this day of /l>L/ , 1990. ) OwAM!d NQtary Pdblic
- m;;c.;;,7.:a tvi? :' 111?*1 WGH,III/JLL/gm xc (see next page)
)
O GeorgiaPower A O U. S. Nuclear Regulatory Comission ELV-01291 Etae Two O
Enclosures:
FSAR Update xc: Georaia Power Comoany Mr. C. K. McCoy Mr. G. Bockhold, Jr. Mr. P. D. Rushton O Mr. R. M. Odom NORMS U. S. Nuclear Reaulatory Comi1 sign Mr. S. D. Ebneter, Regional Administrator Mr. T. A. Reed, Licensing Project Manager, NRR O Mr. R. F. Aiello, Senior Resident Inspector, Vogtle O O O 3
v v v v v v v v' v v V- - s PRESIDENT AND CHEF EXECUTNE OFFICER G EXEGRNE VICE PRESSENT p rm rAR OPERATIONS G.A VICE PRESWENT SENIOR VICE PRESIDENT ADMINISTRATNE vtCE PPFNNT TECHNICAL SEMICES NUCLEAR OPERATIONS SERVICES S GA S vtCE PRFwMT VICE PRESIDENT VICE PRESIDENT NUCLEAR NUCLEAR NUCLEAR M (Fasley) (Head $ G A G LEGEND A=APC G=GPC S=SCS SEV E 1/90 NUCLEAR OPERATIONS ORGANIZATION vE e units 1 AN 2 l Ge ialbwer d c'a'c a'"*"^= " ^"' UNIT 1 ANO 1280T 2 FIGURE 13.1.1- 1
~O-f i Revision 1 ,O Regulatory Analysis SONOPC0 Formation Adherence to NRC Regulations
Background:
Early next year, The Southern Company plans to form a wholly owned subsidiary named the Southern Nuclear Operating Company, Inc. (SON 0PCO). n v Under the initial formation, SONOPCO will be integrated into the overall line management organization by providing specific support functions previously supplied by the owner companies. These support functions shall not include any activity which is required by the NRC operating licenses to be performed directly by the licensee. Organizational structure and line reporting of those corporate functions which support O site operations will generally not be changed. This will be accomplished by specific executive management being made employees of multiple companies as shown on the attached organization chart. The owner companies and licensee holders will continue to be Georgia Power Company, Oglethorpe, MEAG, and the City of Dalton for Plants Hatch and Vogtle and Alabama Power Company for Plant Farley. Georgia Power Company and Alabama g Power Company will continue to operate their respective plants. Discussion: The following regulatory evaluations have been made in conjunction with the initial formation of SONOPCO: ;
- 1. Consistent with the requirements of 10CFR 50.59, a safety evaluation O for the the Vogtle Project has been performed which concluoes that the formation of SONOPCO is not an unreviewed safety question.
- 2. Consistent with the requirements of 10CFR 50.54(a)(3), the Vogtle QA program and the QA program of Technical and Administrative Services O have been reviewed. Although revisions are necessary in these manuals to incorporate the proper corporate designations for the SONOPCO organization, the transition to SONOPCO will not reduce existing commitments. The reason is that this change will not change the overall nuclear organization structure nor will it significantly change the responsibilities of any of the individuals within the 3 overall nuclear organization who directly support the design and operation of the plant. The only change in QA responsibility will be a reassignment of the reponsibility for of the QA program from the General Manager - Plant Vogtle to the Vice President - Vogtle Project.
There will continue to be established and well-defined lines of authority, responsibility, and communication from the highest , management levels through intermediate levels to and including all onsite operating organization positions involved with activities which affect plant safety.
- 3. Consistent with the requirements of 10CFR 50.54(p), the Security plans ,
and programs of the Vogtle Project have been reviewed. Although l
, revisions are necessary in these documents to incorporate the proper corporate designations, these revisions are only administrative in nature such that the transition to SONOPCO will not decrease the effectiveness of the existing Security plans and programs. There will 9
i
h ' j l Pag's 2 . Regulatory Analysis ! )' ! continue to be established and well-defined lines of authority, [
. responsibility, and communication from the highest management levels through intermediate levels to 'and including all onsite operating :
3 -.. organization positions involved with activities which might affect ! security. ;
- 4. Consistent with the requirements of 10CFR 50.54(q), the Emergency I plans and programs of the.Vogtle Project have been reviewed. Although '
revisions are necessary in these documents to incorporate the proper' 3l corporate designations, the transition to SONOPCO will not' decrease . the effectiveness of the existing Emergency plans and programs.- All ! functions of the existing programs will continue. There will continue ' to be established and well-defined lines of authority, responsibility, i and communication from the highest management levels through , intermediate levels to and including all onsite organization positions : 3 involved with activities which might affect the Emergency plans or ! programs. ;
Conclusion:
Based on the evaluations performed and the provision that Georgia Power )_ Power Company will continue to hold the operating license for their plant, it is concluded that NRC approval is not required for the scope of ; the current 50NOPC0 formation scheduled for early next year. - However, the ' regulations do require that the NRC be notified of changes made to the QA, ; Security, and Emergency Planning programs within specific time periods ! after implementation. The Vogtle Project should review their policies and ; 3 commitments to assure that the NRC is properly informed. j Charles Pierce
# /0bth, 3
Project Engineer Licensing Services Approved: ' 3[ / IhO ' BenGegge / Licensing Services Manager I i Attachment
). .
D
ATTACHMENT ) SONOPCO ORGANIZATION - INITIAL FORMATION AaC ' I SONO *CO I orc AtasauA sowo*Co power i PAS $10ENT ANO *' ,' esonou POWER ,-. CEO : C80 CSO l l . SONO *CO AeCK.PC l . e } EXECUffv5 VICE#AtslOENT :
...................................... ...... l , em, 08tGAN@TCN i ! l SONO *CO . 50NOPCoiAPCC.PC SONOpCO '
s4N604 VICE.PEtEstOGNT ' YbCE#AtslD$NT TECMNICAL i VCE #R$s3 DENT
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SONOPCOCo*C i i SONOPCO
- e. ,, e comeonary j VICE# RESIDENT f VCE#AlslOENT YlC84REs40 TNT '
sacattant PAAL8Y - M4TCM VOoTLS oossPmowt* I l PROJECT , 'g PROJECT PROJECT l l l J . i l I
! SONO *CO a ' SONO *CO ' 50NOPCO i SONOPCOi SONOPCOe SONOPCO .
supposef saan suePonT saan supPo=7 saan b d i i......................................I..................... ................................ . . . . . . . . . ...............
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- ORGANOT'0'* Spe i lg m cec i
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PROCEDUME NO. REVl540N PAGE No.
, VIGP 00402-C 7 12 of 13 ) LICENSING DOCUMENT CRANCE REQUEST IDCE No.
l 4.1 Originator: l.. P. Daniels / 10-10-94riority Level , Print Name Date - p Affected Document: Final Safety Impacted Document (s): Various , , Analysis Reoort Update (FSAR) Chapters Changer Administrative chances to Chacters 13 & 17 ( Actual markuo of FSAR to , Justification: To reflect proposed organization of finalizeo at a latt ' SONOPCO Does this change: (1) Constitutes an Unreviewed Safety Question? TES [ ] NO [ )) {J (2) Constitutes a reduction in QA Program Commitment? TES [ ] NO [ y) (3) Constitutes a change in Technical Specifications? TES [ ] NO [ X) If change affects Emergency Plan, answer (4) otherwise; N/A N/A[ X) ! (4) Reduces effectiveness of the Emergency Plan? YES [ ] No [ X) If change affects Security, answer (5) otherwiseg N/A N/A[ X] 3 (5) Reduce effectiveness of the Security Plan or TES [ ] No [ X] Guard Training and Qualification Plan? NRC Approval is Required prior to implementation if any of the above are TIS.
) Originating Dept. Manager Approval /
Signature Date l Concurrence: , Mgr. Tech. 4.2 LDCR Coordinator: /
) Signature /
Date Supp Signature Date 4.3 FRS Meeting No. Date FRS Chairman: Signature Date (BIEF Approval: Signature Date cosaants: 4.4 Document Change Review Change Aa Requested [ ] Not Aa Requested [ i .
) Follow-Up Action: .
Change Implemented: Dociment no. & Rev. LDCR Coordinator: Signature Date J
ra w w vane.o r:Evisic.S PAGE No. VECP 00056-C 10 30 of $1
) ,
10CFR50.59 EVALUATION Sheet 1 of 5 DOCUMENT ID NO.: LULR F5 REVISION NO.! l DESCRIPTION OF PROPOSED CHANGE, TEST, OR EXPERIMENT: UNITt 1&2
)'
Revise various FSAR sections 13.1 and 17.2 to incorocrate various orcanizational and title changes to reflect the 50NOPC0 oroanization (See Attachments 1 & 2 for explanatior.).
) SECTION A. 10CTR50.59 APPLICABILTTY THE ACTIVITY To WHICH THIS EVALUATION APPLIES REPRESENTS:
- 1. (X) YES; ()No A* CHANGE TO THE PLANT AS DESCRIBED IN THE FSAR (I.E., WILL THIS CHANGE REQUIRE A REVISION TO SOME PORTION OF TME FSAR)?
BASIS FOR ANSWER: Chaoters 13 & 17 of the FSAR are being revised to reflect ,. oraanizational chances as a result of the formation of 50NOPCO. h 2. () YES; (X) NO A CHANGE TO PROCEDURES DESCRIBED IN THE FSAR? BASIS FOR ANSWER: The orocosed chances do not imDact any orocedure described in the FSAR. ) 3. ( ) YES; (X) No A TEST OR EXPERIMENT NOT DESCRIBED IN THE FSAR? BASIS FOR ANSWER: _The crocosed chances do not involve a test or exoeriment.
- 4. ( ) YES; (X) No A CHANGE TO THE TECHNICAL SPECIFICATIONS AND/OR ENVIRONMENTAL PROTECTION PLAN INCORPORATED IN THE OPERATING LICENSE?
BASIS FOR ANSWER: The oroDosed changes are administrative in nature arid
) do not affect the Technical Soecifications and/or Environmental Protection Plan.
IF THE ANSWER TO ANY QUESTION IN SECTION A IS "YES", COMPLETE SECTION B. SECTION B SHALL BE COMPLETED FOR ALL DESIGN CHANGES.
~ PREPARER'S SIGNATURE [ M DhTE /0-//- 90 /I REVIEWER'S SIGNA -
DATE: fj-/y - 90
) $ t.pffZ/ *M/n g$,4 rI= ORE I (Ex,M nE)
V7/
,__. - ._- . .a. .. a m on noaso -
VEGP 00056-C i : 10 31 og $1 * 'O - 10CFR50.59 EVALUATION Sheet 1 og 5 L SECTION B. SAFETY EVAWATION:
- 1. ( ) YES; (X) No MAY THE PROPOSED ACTIVITY INCREASE THE l
.O
- PROBABILITY OF OCCURRENCE OF AN ACCIDENT PREVIOUSLY See Sheet 4 EVAWATED IN THE FSAR?
BASIS FOR ANSWER: O 2. () YES; i (X) NO MAY THE PROPOSED ACTIVITY INCREASE THE CONSEQUENCES OF AN ACCIDENT PREVIOUSLY EVAWATED IN THE FSAR? . BASIS FOR ANSWER: See Sheet 4 lO
- 3. ( ) YES; (X) NO MAY THE PROPOSED ACTIVITY INCREASE THE PROBABILITY OF OCCURRENCE OF A j
MALTUNCTION OF EQUIPMENT IMPORTANT TO SAFETY PREVIOUSLY EVALDATED IN THE TSAR? O BASIS FOR ANSWER: Since the pr000 sed changes are administrative in nature and will affect no couioment, tne potential of increasino tne orocaoility of i a malfunction of eouipment does not exist. - )[ i
- 4. ( ) YES; (X) NO MAY THE PROPOSED ACTIVITY INCREASE THE CONSEQUENCES OF A MALFUNCTION OF
! EQUIPMENT IMPORTANT TO SAFETY PREVIOUSLY O EVAwATED IN THE FSAR7 BASIS FOR ANSWER: Since the prooosed :hances are addnistrative in nature, the ootential of increasino tne consecuences of eouiom nt malfunction does not exist. r
- 5. ( ) YES; (X) NO MAY THE PROPOSED ACTIVITY CREATE THE O
POSSIBILITY OF AN ACCIDENT OF A
. DIFFERENT TYPE THAN ANY PREVIOUS EVA WATED IN THE FSAR7 BASIS FOR ANSWER: Since the proposed changes are administrative in nature ,
and no chanQe is bei n made to tie design, operation, maintenance or testing of ' tne olant, a new mode of failure is not created. Inerefore the possibility of O creatino a different type of accident tnan any previously evaluated does not exist.
- 6. ( ) YES; (X) No MAY THE PROPOSED ACTIVITY CREATE THE POSSIBILITY OF A MALFUNCTION OF ;
EQUIPMENT IMPORTANT TO SAFETY OF A i DIFFERENT TYPE THAN ANY PREVIOUSLY O EVAMATED IN THE FSAR?
. BASIS FOR ANSWER: The proposed changes are administrative in nature, and so l .the possibility of a ma ttunction.ot eaulcrnent important to saf ety of a ditterent ;
type inan any previously evaluated does not exist. O FIGURE 1 (CONT'D.) (EEAMPI5) ms O
ihw.uwat av. REvillON PAGE NO-VEGP 00056-C 10 32 of 51
), . -
l 10CFR50.59 EVALUATION Sheet 1 og S SECTION 3. - SAFETY EVALUATION: -
- 7. ( )- YES; (X ) N o
) DOEs THE PROPOSED ACTIVITY REDUCE THE MARGIN OF SAFETY A5 DEFINED IN THE basis FOR ANY TECHNICAL SPECIFICATION?
- BASIS FOR ANSWER: See Sheet 5
~). IF THE ANSNER TO ANY OF THE QUESTIONS IN SECTION B IS "YES", AN UNREVIEWED SAFETY QUESTION IS INDICATED. APPROVAL FROM THE NRC IS REQUIRED BEFORE THE DOCUMENT / ACTIVITY MAY BE IMPLIXENTED.
) PREPARER'.S SIGNATURE:
[ DATE: /C -// -90 REVIEWER'S SIGNATURE / - DATE: /O -/g.3 MANAGER'S SIGNATURE:
,, DATE: /p /g" [O /
p - I Revision: 1 Change: Abstract / Continuation Sheet, Sheet 4 & 5 PREPARER'S SIGNATURE: M4dLF[14tdh.u DATE: /0//P/90 REVIEWER'S SIGNATURE: M DATE: nIf/9, D MANAGER'S SIGNATURE: b! j r r DATE: /*
/![4 D - ) -
FIGURE 1 (CONT'D.) (EXAMPLE) J
not wc. VEGP 00056-C 10 33 of 51 ) 10CTR50.59 EVAIDATION Sheet 4~-og 5 ABSTRACT / CONTINUATION' SHEET , l UNIT NUMBER: ( ) ONE : ( ) TWO t (X) ONE AND TWO DOCUMENT TYPE: DOCUMENT No. DOCUMENT TITLE: REVISION No.: y ) Section S. SAFETY EVALUATION
- 1. The proposed changes are administrative in nature and involve no physical alteration of the plant or changes to setooints or operating parameters. The operation, maintenance, or testing of the plant will not be changed, nor will any changes be made to any current procedures that deal with plant operations.
For these reasons, the response of the plant to previously evaluated accidents will remain unchanged.
. 2. The accident analysis in the FSAR remains unchanged. Since the changes to be made are strictly administrative in nature, no change will be made to the basic organizational structure that currently exists, in that the responsibility of the individuals that orovide support services for plant operation will not d chance. No changes will be made to the design, operation, maintenance, or testing of the olant. There will be no degradation in the current Quality Assurance program. Quality Assurance personnel currently reporting to SAER at the plant will be incorporated into the 50N0PC0 organizational structure. Clear reporting
) lines of communication within the system will be maintained. For any accident, . the responses of the Corporate staff and plant management would not change. The proposed changes do not increase the potential for a dose increase above 10 CFR 100 ) limits. In fact, since the accident analyses remain unchanged, there is no dose increase. Therefore, the proposed changes do not increase the consequences of an accident previously evaluated in the FSAR. - J - FIGURE 1 (CONT'D.) (EXAMPLE) . J
* ^ _ - - . nw.sswas av. navision j PaGa No.
- VEGP 00056-C 10
- y. 23 of $1 10CDt50.59 EVAIDATION Sheet 5~ og 5 ABSTRACT / CONTINUATION EMEET
) UNIT NUMBER: ( ) ONE ( ) TNO ; (X ) ONE AND TWO i
DOCUMENT TYPE: DOCUMENT No.s DOCUMENT TITLE: RZvIsION NO.: y l Section B. SAFETY EVALUATION ,
- 7. The orocosed activity does not reduce the margin of safety as defined in ,
the basis for any Technical Specification, because the proposed administrative d chances beina added will assure that those operational fu'nctions necessery for i 1 safe olant oneration will continue to be maintained. The current Ouality Assurance (0A) crocram will not be altered as a result of the proposed changes exceot that the existino OA crocram will be made applicable to SONOPCO. The d j channes will result in more efficient cross-communication as well as greater consistency amonc the Southern Company Nuclear Plants. & a i i i . b .
~ ) -
FIOURE 1 (CONT'D.) (EXAMPLE).
)
ATTACHMENT 1 r b ABSTRACT 4 Early next year, the Southern Compsny plans to form a wholly owned subsidiary named the Southern Nuclear Operating Company, Inc. (50NOPCO). At
) this time, all lines of authority, responsibility, and communication will be established and defined for the highest management leveh through intermediate levels to and including all opersting organization lors) positions. The changes to be accomplished at this time will be strictly admimstrative in nature.
There will be no changes made to the basic organizational structure that currently exists, in that the responsibility of the individuals that provide
)
support services for plant operation will not change. No changes will be made to the design, operation, maintenance, or testing of the three operating nuclear plants. All activities necessary to maintain safe plant operation will continue l to be maintained. Quality Assurance personnel currently reporting to Safety Audit and
) Engineering Review (SAER) at the plant sites will be incorporated into the 50NOPC0 organizational structure. This will assure that clear reporting lines of co=unication are established and maintained. There will be no degradation in the Quality Assurance programs currently in existence.
{ In order to provide for clear reporting lines of comunication within the ) syste'i and to ensure the licensee roles (since the operating licenses are remaining with Georgia Power Company and Alabama Power Company under the initial SONOPC0 formation) are properly fulfilled, several members of executive i management will continue to belong to multiple companies. This is described as follows: h Alabama Power Company - Executive Vice President Senior Vice President Vice President - Farley Project Georgia Power Company - Executive Vice President Senior Vice President
) Vice President - Hatch Project - Vogtle Project SONOPCO - Executive Vice Presi~ent d
Senior Vice President Vice President - Farley Project
) - Hatch Project - Vogtle Project Note: Refer to the organizational chart in Attachment 2 for more detail.
Correspondence letters to the Nuclear Regulatory Consission and other agencies b important in fulfilling license responsibilities will be officially signed as required by one of the levels of management described above.
~
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ATTACHMENT 2 D SONOPCO ORGANIZATION - INITIAL FORMATION APC i SONOPCO I OPC ALASAMA . sONOPCO 080A01A ., POWER . PRESJOENT ANO , PowtA s.- J CSO C80 {- j CEO l l SONOPCO/APCSPC l ') a CGCUTWE VCE#RESJOENT CORPO8uTE i g
, 08CANLZATION i ;
m SONOPCO . SONOPCO/APCGPC 1 SONOPCO e d ** EE"*"
- VCE#RES!OENT VIC8# RESIDENT VCE N
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- ADMINISTRATNE NUCLEAR N EI OctMATONS l
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) SONOPCO J SONOPCOiAPC l SONOPCO4PC
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. mig YCE* RESIDENT l VCE# RESIDENT , VICE*RESJOENT '
sacarTAPT FAALSY HATCN YOOTLE ccesP?nouza
,f l PROJECT l PROJECT PROJEC d' l
, I I I J 6 f' i l SONOPCOg ISONOPCO. SONOPCO I SONOPCOi SONOPCO SONOPCO 6 sup*Ont I d sup*Omf .Aan sArn suppo=7 sAsa l ' .J k k j O w nONs ,,e 2 E o,e a a,e E g i w m PLANT m Puurf m m
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) s oCEDU.-.E No.
LEvisioN vast No. VEGP 00056-C 10 34 og gi c ENVIRONMINTAL EVALUATION DETERMINATION Document ID: Revision No.:
- 1. Could implementation of this document pose adverse h environ = ental effects of any type either directly or indirectly"I (Unit 1 and Unit 2 Operating License, Appendix B) Check a or b
[ ] a. Possibly. (Explain): [ X) b. No. The nature of this document is such that it will 3 not resic.t in a condition which significantly altert the it.~:act of the station on the environment. EvnLut.cor 3*R' a @hd. AIL l1 GC^ /Y? Data /o/4/90 Supervisor Ar/u Date /rd. 3 2. If an environ = ental question is posed (item la is r.hseked) the docu=ent will not be approved until evaluated. Forward the package to the Health Physics / Chemistry Dopartment for an environ = ental review. ~)
- 3. Attach completed environmental review and return to the evaluator (item 1) for continued processing.
D = J se FIGURE 2 . O mm
t '. if k t* , , W. G. Maester. fu
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t..e r . December 6,19??0
~
Docket Nos. 50-321 50-424 HL-1346 50-366 50-425 ELV-02209 Mr. Samuel J. Chilk Secretary of the Commission U.S. Nuclear Regulatory Comission Washington, D.C. 20555 - ) t ATTN: Docketing and Service Branch Southern Nuclear Ooeratina Comoany. Inc.
Dear Mr. Chilk:
The purpose of this letter is to advise the NRC that within the next few weeks. The Southern Company plans to form a wholly-owned subsidiary named the Southern Nuclear Operating Company, Inc. (SONOPC0 or Southern Nuclear). , An application to this effect was filed with the Securities and Exchange Commission in June of 1988, and it is anticipated that approval of this
)
application will be forthcoming shortly. Upon formation, Southern Nuclear will be assigned responsibility to perform certain functions which were previously performed by Alabama Power Company, Georgia Power Company and Southern Company Services organizations including, but not limited to, fuel procurement services, engineering services, and administrative and technical services. The functions assigned to the Southern Nuclear subsidiary at this time will not include any right under the license, and Georgia Power retains
}
responsibility for compliance with its regulatory obligations. Organizational structure and line reporting of those corporate functions ' which support site operations will generally not be changed by Southern Nuclear formation. Specific management personnel will be employees of both Southern Nuclear and Alabama Power Company and/or Georgia Power Company in
) order to maintain continuity of reporting within each licensed operator's organization, and also to consolidate other functions within Southern Nuclear. An organizational chart indicating the anticipated structure of Southern Nuclear is attached. Georgia Power Company, Oglethorpe, MEAG and the City of Dalton will cov.aue to be the owners of Plants Hatch and Vogtle, and Georgia Power Company will continue to be the licensed operator. ; Alabama Power Company will continue to be the owner and licensed operator of Plant Farley.
O ' l 1 O l Mr. Samuel J. Chilk Page 2 O Safety evaluations for the organizational change have been performed under 10 CFR 50.59 concerning the formation of Southern Nuclear. The safety evaluations assume that Georgia Power Company contracts with Southern Nuclear for many of its delegable duties under licenses numbered DPR-57 and l NPF-5 (Hatch) and NPF-68 and NPF-81 (Vogtle). The conclusion of the safety ; evaluations is that no unreviewed safety question exists or change to the l plant technical specifications is required as a result of this contract and l l resulting organizational change. Reporting and communication lines will i i remain essentially the same as before the change. In addition, Georgia Power Company's Quality Assurance, Security, and Emergency Planning programs were also reviewed. Evaluations were performed in accordance with 10 CFR 50.54(a), and they determined that no reduction to any commitments of the h Quality Assurance programs will occur. Evaluations conducted pursuant to 30 CFR 50.54(p) determined that there will be no decrease in the , effectiveness of the Security Plans and programs. Moreover, evaluations a l conducted in accordance with 10 CFR 50.54(q) demonstrated that there will be no decrease in the effectiveness of the Emergency Plans. I Georgia Power Company submits this letter to the NRC for informational purposes only. Based on the above conclusions, no action is requested. l Should you have any questions, please advise. , I Respectfully submitted, p . u ). b. /s.. ,. A - n l
- W. G. Hairston, III '
WGH,III/LPD Attachment l l J I J i _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ _ . _ _ _ _ e
) ) Mr. Samuel J. Chilk Page 3 ) cc: ,Georoia Power Comoany Mr. J. T. Beckham, Jr., Vice President - Nuclear, Plant Hatch Mr. C. K. McCoy, Vice President - Nuclear, Plant Vogtle . Mr. W. B. Shipman, Acting General Manager - Plant Vogtle )' Mr. H. L. Sumner, Jr., General Manager - Plant Hatch NORMS U. S. Nuclear Reculatery Comission. Washincton. D.C. Mr. K. N. Jabbour, Licensing Project Manager - Hatch Mr. D. S. Hood, Licensing Project Manager - Vogtle ] U. S. Nuclear Reoulatory Commission. Recion II Mr. S. D. Ebneter, Regional Administrator Mr. L. D. Wert, Senior Resident Inspector - Hatch Mr. B. R. Bonser, Senior Resident Inspector - Vogtle ) J ) J I.
) )
1
f3 is .O P ATTACHMENT SONOPCO ORGANIZATION .z 7.--------.--- APC eONOPe0 ope ALAAAMA
- 90es0PCO escama POWEA PHESIDENT AND P0wgA C80 CSC CSO 4
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TECMMICAL # l 8 ADesaN.TRATIVE .. 841WeCES OPEA&7tetes SENVICSS l 4 , t SONO *CO SONOPCO,APC SONO *COCPC 3ONOPC04PC SONOPCO , e e e e comonays VICS SRESIDSNT VICS#RESIDSNT VICE PRESIDENT
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- I, etICHAEL. HA M INS, SECRETARY OF GTATE GF THE CTATE OF M M ,' ;
$ '~ DELAWARE 00 HEREn CERT 2FY THE ATTACMED IS A TRUE AND CORRECT - 00PY OF rHI C.Ed.TrF1; ATE OF It'C JRFOR ATION OF SOUTHERN NUCLEAR S I E 8 O P " R A T I N G C a tlF t.N 4 , If3C . FILED iy 2'HIS OFFICE Ce4 THE 5EVENTEENTH OO !. ,
d DAY 07 CECEFLCR. # 0. 1890, c. ~ 1.t : M d' CLOCK .; . .M . . . .d ! I : i : 1 : : i 'l . en D .3 RI .. v
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? AL HENTICATtON: 2671594
- '30s?,1014 DATE: :?/17/1990 l.
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- T 1.22f J1.L30 AM '2/17/1990
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1 CAR'17FICATE OF INCORPORATION D OF f SOLTHERN M1 CLEAR OF5 RATING COMPANY, INC. e i j 4RT1cLE f b - The nams ci 1.14 =crocratica (herela the 'Carrarattan") ist Southern Nefear Operaties Company, Inc.
' ARTICLE Il
- Realsta'ad Offica and Aaunt j
- The address of d e Corporation's reaktated office la the $mse of Delaware is 1209 Oranse Street, City of WDrels ston. Couary of New Cast!s, Delaware 190C1. Im res! stored egent at such sodress is no Corporatisa Trust Company.
1 ARTICLE pl Oblac's and'Poween
] The estare of Q Corporation't husinaw sad l#4 nhjanti, enerwe., and powers are as follows; ; 3.01 To essa::e is the ope::tica of nuclear power plants, se provide associated tochaient and adslaistrative ser* Ices, and to provide support serk.es la coa.section wink the operation P
3.02 To pur ta<t. subscrDe for, aceulre, own, hold, call, anchange. assign, traasfer, mortgage, pledge, tytothecate or oestwbo tramsfer et dispose of stock, scrap, warraana, rights, bonds, seestities or e% aces of irdabtedness crossed by' may other g,.j;ian or corporacons 6 ormas.1:ed under the ises of eqv susta. ne saw hearta ce avam.- er ind awea ar % f r.p a , j - 5tatas or any same, distrie:, tarratory, deoecds scy or county or subdivision or m==Haal!ty ths sof. and to hsne and suhs.sg) therefor :ssh, capital stock bonds, notes or other securities, evideacts of indebtedness, or obi!gn:icas of the Corpcration and while the owner thereof to saarcise au rights, powers, and ::rivileges cf :usershh,laclucias the right to sete es any shares of stock, voting trtst certificates or o$er it :tr:ments se tweed; nad D 3.03 To tns:2t may busin*.ss, to antage la any lawful set or activity, and to exercise a!! powers portaitted to corpJratical by the Gescral Corporatica Law of Delawa.*s. l
, The entreeration here a :f the objets and gurposes cf the Cor: oration shall not be deemed to i esclude or in any ny tirait by infe:coce say powers, objects, or purposes which the Corporttien ,
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1 .. DEC 17 '5811'2*. C" C3WAATION STCat FW: .
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5 f . bemoowered laware or anysaseassettle asarein, whoshar espreenly onestrwetion of suchbylaws. rwerwa or by ear of the laws of the Smie of
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AR'f1CLE fY Camisal Sanck
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4.01 The natal susber of shares of an cismes of espim! seosk '
'which the Corporation shan have she anatharhy to hsee is one thousand (1,000), of one thoestad (1,000) Shares of $10.00 par value oossmos stock. .
4.02 Dtvidende upea 5 hares shall be se la caly whea, as and if declared by the Board of Directors from fuads lawfWly avaIlable er, which funds shsE incinde, without limitation,
) the Corporadca's espioJ sarplus. Dividends usea Corporation Shares may be paid la cash, properry, or Shares of msy otmas or wries of ca ocher securidae or evidences of indebtedness of the Corporatica or any other isoner, as may be determined by resctttloa or resolutions of the Board of Directors.
4.03 The Corpcratica may from time so time amar lato say sgreement to which &D, or less than all, holders of recori of the Corporation's lassed and ousmu'ing Shares an parties, restrictag
) the taasfer or resisitsiion of treaster'ef any or a.1 of the Cctperation's Shares, upos such reasonable terms and =cadithms as iney be approved by resoluties er reeclutions' adopted by *.he Corporation's Board cf Directors.
4.04 No holder of any Ccrporat'en skarse of any kind, elass, or series shall have, as a metter of right, any peumedve or preferential right to subscrb for, purchase or receive any shares of the Corpornticn's Shares of any klad, cines or aerles or say Carperstica securities or obligsticas, whether sov or harsafter authodsed.
)
4.04 Each bekht of Carperation Shares of say class or series of a class thereof shatt have the preemptive right 12 subscribe to any or all addiccaal issues of stock by the Corperstloa of say
- or all classer or settes th,rreof, or 1c any securides of the Corporatica convertible into scoh stock, M
Incornarators i i ne asase and aidlias addrsas of ea:h lacorporator 1s: i l Mama , MalHam Ad$aes
'rhe Southern coinpany 44 Perhaeter Center East Adnam, Georgia 30344 ARTICLE _YI- .
i Di!IGlatl
) ne fotoving perscas shat! serve se 11 rectors of the Corporarlos untu their successors are du!y elected sad gusilfied:
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I L O ! Ngag Madina Addgman
- i. E. L. Addison i 64 Perimeter censer East Atissen. Georgia 30344 i.
A. W. Dahlhers 333 Piedmont Avesse - O 4 At'rsa, Georgis 30308 . Elmer B. Barris 400 North Issh street Eradagham, Alabama 35291 i, Joseph Ad. Farfey e Interases Center Drive
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- Innefit Prw(nises In furthesare and not la limitatlos of the powers conferred by law, the ren 1 e mass t., ressa.d .t iw ce,p., i.., tw es,e d ishetd a are hereby estrblebest
@ 7.01 Thu Corposesion shall have the right to purchase, redeem, receive, J taka, or othewise acauste, own and held. asil, Isad, s2 change, truasfer er otherwies ass and other.Ise dont in sad with is own shares to the fun dispees extent of, piedy,d of undivute prouts, earned, capial or other surphs or any other fund 1swfally ava!!able theretur. s
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2 ' ' 7.02 A director sha:1 set be be:d panonady liable to the Corportalos or its 3 saadhafdare for a et.etary damages for breach of fiduciary duty as a direesor, eacept ? this provision s'aal act eliminate the liability of a director (i} for any breach of the direems's dsty of loyalry to the Corporation or ins seekholdes, (iO for aos or omis-sions not la 3o0:1 faith or which Invohe lainational misocaduct or a knowing
- violation of law. (110 for uniswful en e.d.mmi ses., mt a c.psyteent of divideed L..,
e.ed cerpe,sas.= or aslawful seenesstock punchese N, w Gv ter any tramanecios from which the director derived na improper personal benefi). t It la the lassation of the stockholders taist the direezes of the Corporatiot be proteced free perenmal iisbuity to t?.e fullest estear permitted by P.e Delawee Gaastal Corporation Law as it now or hereaf.ar exism. If at any tas in the (ofure the Delswere Ocasts.' Corporatica Law is modified to permit further or additicaa! ' lirainstices on the extsat to which due: tors may be held personally liable to the Corporatloa, the proaction affordec by Ltd:Sectos 7.02 shat! be expanded to afforc the maximum pro ection pencirted under such law. Any rereal or modificatiert of this Sectiot 7.02 i+y the stockhciders of the Corporation sha.! be prospective ca!y, L . 3 t
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h and shak act dheinish she rishes, or expsad the personst usbittty of s directer of . the Corporedea with respect to say set or em.ss;oa cecurring prior se the tjme of l j
. such repeal or aodificaties.
I 1.03 Wishout Ihmitados, the Corporation shan indemalfy say person who was or is a party or 1r threatened to te made a party to any threasseed, psading or i completed action, sak or proceedlag,,whether civil, criminal, adelaistrative or i O lavestigative, by ressoa of the fact that he is or was a discaer or officer of the Corporation, or :s or was servias at tt.e ro6est of the Corpersaios as a director or officer of anothe r oorporatisa, partMrship, joint senture, trast or osbar enterprise. ' against orpenas (including attorney's fees), judgmens, fines and amousta paid in settlement actr.al y and reasonal:!y accurred by him is conMctica with such action, + sait or proceedia a to the full esseet permitted ty the Delaware General Corporation Iaw spot such deerrainarlos havlagt.c.., been made as to his th and .u.4 conduct
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director or offio:r la defending a civd or critr.imal action, suit or proceedlag shan be paid by the Corporation la advears of the final disposidos of such actica, suit or proceedi:.g u;on receipt of an sedertaklag by er on behalf of slach director or i officer to regny such stoo&st if is st.si! v!tD=stely se determined that he is not ! entitled to b - ndemnified *ay the Corporatica. It le the intention of the , stockholders that the directors and sfficers of the Corporatica be indemnified to the : fuuast antest pe*altted by the Delaware Gezers! Cerporttica Law as it acw or i O hereafter ts.isu. If at say ti.te is the future the Delaware Genera! Corporation Law i la modified ta :ermit further or sdditional I. damsificatiott for the directcrs or i officers of die Corpcration the prettetica afforded by this Section 7.03 sha!! be l
; expanded to affo:d the max'. mum pror.ection permitted ander such law. Any repeal i or modificatio4 i;f this Sectica 7.03 by the stockt. ciders cf the Corporation sha!! be !
i prospective or:!y. and tha!! set dirricish the r.Jats of a director or officer of the l
! Corporatics w.th respect to any set or omission c<sufring prier :s the time of such l p repeal cr mod fkstion.
l 1.04 Le Corpora.!ca reserves the rig:ar to asacad. aber, shaage or repeal any provisioc cou:aloed la this Cert;ficate of Inccrporation, la the manner now ce l hereof ter petacril ed by statute, and ajl rights cc afstred upon stockholders hersia are ! praated subject ts this reservatloa. ' 7.05 Tu Corpora:1on's Betrd cf Ditteters is authorized sad empowere O to ameno, alter :haats or tspeal the Corporation's By-Laws and adopt new Ry(. Laws. ARTICLE YUI I2li!Ill4& D The Ccrpsrstion shall have perpetual darallos and existence. a I d
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' formiss a corsession parrasar to che Ostent Carperarica Law of' tate of i Delaware, dass a ske thu Certificate, hereW de:1 arias and cot-ihiag that this is sty set and deed and the faso hirein :s:td are true, and secordiegly have hereunto set i cut hands as of fils 14*L day of December,1990. :
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D O R G ,\'A._ o OFFICIAL TRANSCRIFT OF PROCEEDINGS O I e geng*. Nuclear Regulatory Commission Office of Nuclear Reactor Regulations O
Title:
Implementation of Southern Nuclear Operating Company Docket No. 50-348, 50-364, 50-425, 50-321, so-3ss D unBON: Rockville, Maryland P j dam Friday, January 11, 1991 PAGE 1 - 49 l D 3 ANN RILEY & ASSOCIATES, LTD. 1612 K St. N.W, Suite 300 Washington, D.C 20006 (202) 293-3950 D
2 1 PARTICIPANTS: [ continued) ) 2- M. Kohn Kohn, Kohn & Culapinto 3 S. Varga NRR 4 G. Holler NRC 5 D. Nash NRR/NRC ' 6 F. Allenspach NRR/NRC ) 7 E. Merschoff NRC/ Region II B E. McKenna NRC/NRR 9 L. Robinson NRC/OI 10 E. G. Adensam NRR/NRC 11 D. Spaulding NRR/NRC 12 L. Long Southern Nuclear Operating Co. ) 13 D. Smith Oglethorpe Power Corp. 14 D. Hood NRR/ PD2-3 g 15 J.P. Schaudies Troutman, Sanders, et al 16 Georgia Power Company 17 A. Demby Troutman, Sanders, et al ) 18 Georgia Power Company 19 J. S. Wermiel NRR/DLPQ/LPFB 20 E.W. Brach NRR/DLPQ/LPEB ) 21 C. Thomas NRR/DLPQ 22 K.J. Jabbour NRC/NRR 23 24 25 )
1 3 ! 1 D PROCEEDINGS 2 (10:40 a.m.] 3 MR. LAINAS: Maybe I can start the meeting with a f 4 few brief, introductory remarks. I think that first I want 5 to thank you very much for coming today. I know it wasn't 6 easy, and I want you to know that we didn't have anything to
) 7 do with the weather out there. You made it, and thank you 8 very much for coming today.
9 The purpose of the meeting is to discuss the D 10 ir.,rmation that you provided us in your letters of December 11 6 ,a . I guess it was put on the docket for the Farley 12 Station, Vogtle and Hatch, and you are going to give us some 13 additional clarification of what you said there. I might 14 say that this was a noticed meeting and an open meeting. J 15 However, participation will be limited to the licensee and 16 NRC. What I am going to do a little later is go around the
, 17 room and everybody can identify themselves and their ) 18 organization.
19 As you can see, the meeting is being transcribed. 20 I guess the purpose of this was to give us a good record of 21 the meeting for possible future reference. With that, what ' 22 I think I would like to do is just start around the room. 23 MR. VARGA: Varga, NRR. 24 MR. KOHN: Michael Kohn, representing Mr. Hobbe 25 and Allen Mosbach.
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l l D l 4 , 1 1 O MR. HOFrMAN: Steve Hoffman, NRR project manager ) 2 for Farley. 3 i MR. MATTHEWS: Dave Matthews, Project Director () 4 responsible for the George Power Company. 5 MR. MCDONALD: Pat Mcdonald, Executive Vice 6 President, Alabama Power Company and Executive Vice n v 7 President, Georgia Power Company. i 8 MR. WOODARD: Jack Woodard, Vice President, 9 Alabama Power Company. Q . 10 MR. BECKHAM: Tom Beckham, Vice President of plant 11 Hatch, Georgia Power Company. 12 MR. MCCOY: Ken McCoy, Vice President of Plant 13 Vogtle, Georgia Power Company. , 14 MR. LAINAS: Gus Lainas, NRR, Assistant Director , () 15 for Region II reactors. , t 16 MR. JABBOUR: K. J. Jabbour, Hatch Project I 17 Manager, NRR. O 18 MR. THOMAS: Cecil Thomas, Deputy Director, 19 Division of Licensing, Performance and Quality Evaluation. I 20 (). MR. BRACH: Bill Brach, Chief of Performance and 21 Quality 2 Valuation Branch, NRR.' , 22 MR. WERMIEL: , Jerry Wermiel, Chief, Reactor 9 23 Assessment Branch, NRR. 24 MR. DOMBY: Art Domby with the law firm of 25 Troutman, Sanders, Atlanta, Georgia, representing Georgia O
J 5 1 Power Company. 2 MR. SCMAUDIES: Jesse Schaudies, with Troutman, 3 Sanders, Lockerman, Ashmore, representing Georgia Power ] 4 Company. 5 MR. HOOD: Darl Hood, NRC Project Manager for 6 Vogtle. ) 7 MR. SMITH: Dan Smith, oglethorpe Power 8 Corporation. 9 MR. LONG: Louis Long, Southern Nuclear Operating D 10 Company. 11 MS. SPAULDING: Deidra Spaulding, Engineering L 12 Intern, NRR. D 13 MS. ADENSAM: Eleanor Adensam, Project Director, 14 NRR. D 15 MR. ROBINSON: Larry Robinson, Office of 16 Investigation, NRC. 17 MS. MCKENNA: Eileen McKenna, Section Chief, D 18 Performance Quality Evaluation Branch, NRR. 19 MR. MERSCHOFF: Ellis Merschoff, Deputy Director 20 Projects, Region II. 21 MR. ALLENSPACH: Fred Allenspach, Performance and 22 Quality Evaluation Branch.
) 23 MR. NASH: Darryl Nash, Policy Development, URR.
24 MR. HOLLER: Gene Holler, Office of General 25 Counsel, NRC,
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b 6 1 MR. LAINAS: Thank you very much. I guess with 2 that I will turn it over to you, Pat. 3 MR. MCDONALD: The organization diagram really [) 4 summarizes the material that I want to cover today, and as ' 5 vell to talk around that. However, first let us consider a 6 little history. The Southern Nuclear Operating Company is ) 7 intended to be a wholly owned subsidiary of the Southern 8 Company. In June 22, 1988 the Southern Company filed to 9 incorporate with the SEC to perform the Southern Nuclear D 10 Operating Company. That was June 22, 1988. 11 The SEC provided approval for that on December 14, 12 1990. On December 17, the Southern Nuclear Operating 13 Company was incorporated. On December 18, the officers were 14 elected. On January 1, 1991 there were employees that were [) 15 transferred and double-hatted from the Georgia and Alabama 16 Power Company to the Southern Nuclear Operating Company as 17 well as from Southern Company Services to the Southern l D 18 Nuclear Operating Company. When I refer to Southern 19 Nuclear Company and SONOPCO, both of those should be , 20 considered to be synonymous. 21 The functions of the Southern Nuclear Operating 22 Company at this time are to provide support services to y 23 Alabama Power Company and Georgia Power Company for their 24 operation of the nuclear plants. These support services 25 involve the corporate level support for engineering and D
J t l 7 1 licensing and maintenance, the technical support for nuclear )- , 2 fuel, generic licensing, vendor QA and some NDE services, > t 3 and administrative support involving such things as ) 4 management, budgets, document control, procurement, l 5 performance matters and insurance. 6 The relationship among Alabama Power Company, ) 7 Georgia Power Company and Southern Nuclear is one where the i 8 licensees who are Georgia and Alabama Power Company, 9 maintain their licenses. They continue to have their 10 licenses. I am here speaking to you today as an officer of I 11 Alabama Power Company and Georgia Power Company. We P 12 maintain those licenses. ' ) 13 The services that Southern Nuclear provides is an !' 14 administrative type of service, and it has the management of-y 15 the personnel who are providing those services to those two i 16; companies. The operating lines for licensed activities 17 remain the same, they are unchanged. Let me go over~that ) 18 and get right into the organization, and I am sure that we 19 will have some questions after going through this i 20 organization. r )' 21 First, let's consider on the left-hand side the 22 Alabama Power Company organization. It's a hard line. This . 23 Alabama Power Company CEO is the Chief Executive Officer at 24 this time who is Elmer Harris. I report directly to him. I 25 also report directly to Mr. Bill Dahlberg, who is CEO of - i \
l 8 1 Georgia Power. I administratively report in my Southern ) 2 ! Nuclear at to Mr. Joe Farley, who is President and CEO of 3 the Southern Nuclear Company. g 4 Reporting to me are the corporate secretary of 5 Southern Nuclear Company, the senior vice president of 6 Alabama Power and the senior vice president of Georgia 3 7 Power, who is George Harriston. The Vice President of 8 technical services of Southern Nuclear, who is Mr. Lou Long 9 over there. A presently vacant position, vice president of O 10 administrative services for Southern Nuclear. Notice the 11 annotations where you see the double or triple hatting, and 12 we will go into some discussion on that. 13 Going down the line from there, from Mr. 14 Harriston, reporting to him is Jack Woodard, Vice President g 15 of Farley, Alabama Power Company; Tom Beckham, Vice 16 President of Hatch, Georgia Power Company; Ken McCoy, Vice 17 President of Vogtle, Vogtle Project. Going back over here 18 to Mr. Jack Woodard, here is our reporting chain to Jack 19 Woodard. He has reporting to him three people; the plant 20 manager reports directly to him who is and remains -- the 9 21 plant staff remains a totally Alabama Power Company 22 organization. He also has reporting to him a corporate g 23 level support organization which provides the engineering 24 and licensing, project work, the administr:ative personnel 25 matters, nuclear fuel liaison and that type of services. O
9 1 The support organization has no line authority 2 whatsoever over the plant. It is strictly a staff support 3 organization. Also reporting to Mr. Woodard is the manager ~ 4 of safety audit and engineering review who, in the case of 5 Farley and only in the case of Farley, is double-hatted. He 6 remains an Alabama Power Company employee and functions in 7 that role, and he is also a Southern Nuclear employee. He is 8 in that role, whereas the other two QA groups are not, 9 q because we had a specification in the tech specs that J 10 designated that position as an Alabama Power Company 11 position. We did not see any need to change that. 12 The people working for him are Southern Nuclear 13 people. That is the QA organization that is on-site at 14 Farley. Similar is the case for Hatch and Vogtle, except D 15 for Hatch and Vogtle their corporate level manager is not 16 double-hatted. That same organization exists for the two 17 other projects. 18 Let us look now and see what this functionally 19 means. First, in the services that are provided, the only 20 people who are Southern Nuclear employees are those who have
.21 hats as indicated here including this one, plus these 22 organizations -- these support organizations in each of g 23 these projects, off-site support organizations. The 24 administrative department is the technical department in the 25 corporate sector. The plants remain totally in Alabama 9
) 10 1 Power Company and Georgia Power Company, strictly a line of accountability. 3 We had conducted assessments of this beforehand, ) 4 after we had talked with you before and before doing this, 5 we updated assessments. We did 10 CFR 50.54 A, QA 6 considerations, and it is noticed that the lines of ) 7 reporting are unchanged. We have no reduction of any type 8 of commitments. We had 10 CFR 50.54 P security 9 considerations, there is no decrease in security; 10 CFR ) 10 50.54 Q, emergency plan, no decrease in emergency plan. At 11 10 CFR 50.59 safety evaluation there were no technical 12 specifications and no un-reviewed safety questions. 13 What we have is something that is essentially an 14 administrative support organization. These people now ] 15 provide --all the ones that have a double-hat or Southern i 16 Nuclear title, now obtain their paychecks from Southern ' 17 Nuclear. Their pay is paid to them, their health benefits D 18 and what have you. ; 19 In the case of the double-hatted people, let's 20 talk a minute about the double-hatting. ) We will talk about : 21 myself, which will be typical of the others. I work for l 22 three distinct different organizations. I work for Alabama 23 Power Company, Georgia Power Company and Southern Nuclear. } l 24 In that, in my Southern Nuclear hat, we have a contract with 25 each of these companies to provide administrative and these J l
11 1 other type of services. We have a written contract. 2 My being an employee and reporting here, my 3 performance evaluations, my salary levels, my performance 4 evaluations, are performed by these three entities 5 individually. Any changes in salary and what-have you are 6 performed independently by those three and then are sent to ,; 7 Southern Nuclear to combine into a white paycheck. That is 8 a matter of the written agreements which we have, so that at 9 any one time there was a continuous complete line of 3 10 responsibility for all licensed operations. 11 You will see that I made some rough notes here. 12 O Let's see if there is anything else that I forgot. At this 13 point, I would like to ask for questions. It is really as 14 simple, I believe, as I have stated here. 15 MR. VARGA: -) May I? 16 MR. MCDONALD: Yes. 17 MR. VARGA: It is purely hypothetical, and I an 3 18 somewhat confused. Ist me give you a hypothetical scenario. 19 Alabama Power at Plant Farley, let's say the plant manager 20 who is an Alabama Power employee, he wants to have a 21 maintenance supervisor, a new one. He decides he is going 22 to hire that man. He goes up to Vice president of Farley, 23 who is now SONOPCO as well as Alabama Power, and that person 24 could say no, I don't think you need that. I think maybe you 25 need somebody else or I have somebody in mind. J
r ) 12 1 The plant manager there says gee, I don't agree 2 with that. The next step up is going to the vice president 3 of Nuclear which is now a triple-hatted man who does have
) 4 Alabama Power, but his loyalties are somewhat divided. It 5
seems to me that before this plant manager can get somebody 6 up there that is only Alabama Power and that might support ) 7 his position would be up there to APC, the CEO. 8 MR. MCDONALD:
. Let me address that in a real live 9 case and not a hypothetical. We had been having Mr. Bill 10 Shipman at the Vogtle plant serving as the acting general 11 manager at Vogtle.
12 MR. VARGA- ) He would be below that -- 13 MR. MCDONALD: He was serving over here for Ken 14 McCoy. It was acting. He was acting, because we had an 3 15 abrupt departure. We then had a personnel selection 16 committee, as is the rule in the Southern system. The rule 17 in the Southern system that had jobs at those levels, you i l ) 18 get candidates from other companies and you have l 19 representatives from those other companies sit on a 20 selection committee. That selection committee makes ) 21 recommendations of who they think can best fill that job.* i 22 We went through the Southern Company process for 23 selecting people and got candidates for that. We also I 24 formed a selection group for that. Now, as soon as those 25 candidates were selected and that selection committee was )
33 t 13 i 1 named, I called my boss at Georgir and said Mr. Dahlberg ! D-. 2 here is where we are. We have gone through the Southern i i 3 system.in the normal fashion and filled all the ! 4' requirements. Here are who are the candidates and here'are ! 5 who the selection team is, and here-is where it is meeting. 6 I That selection team met and it met yesterday, and. j 7-
} I called Mr. Dahlberg in Phoenix, Arizona and said Mr.
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Dahlberg, they have met and here is their recommendation but 9 we want your final approval for this job. That is how it [) . 10 actually happened. i 11 MR. VARGA: In that case, would there be any -- ! 12 \ MR. MCDONALD: Let me go ahead and add, this man C l 13 i and this man were neither involved. They neither yet know i i 14 how that thing has come out. I 15 MR. VARGA:
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Would it be possible, even after that 16 selection committee, would it be possible for a voice from 17 down at the plant even though you have the selection , [) 18 committee and all that, would it be possible for a voice to { 19 be heard up there at the GPC level. ! 20 MR. MCDONALD: He has call-ins all the time. 3 21 People can call him-from the plant at set dates. We have a i 22 program. These people are in constant communication and
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i 23 he's here all the time. D- He can call here, they can call up i 24 here, they can call up here. They have the same employee i 25 relationships that they have always had. It is completely ' D s l
14 1 unchanged. There has been no change whatsoever for this ) 2 plant. 3 MS. ADENSAM: Pat, I have a question with a little 4 different twist. How would you resolve a conflict between 5 what the plant, as Georgia Power and Alabama Power might 6 want and what the technical staff at SONOPCO felt was j ) 7 appropriate? Does the Vice President at Farley simply sit 8 down -- how are you assured that there is no conflict of 9 interest there? D 10 MR. MCDONALD: Let me respond to that. Each of i 11 these double-hatted employees are shared employees. I will 12 explain to you that they work for two companies and they get I- 13 performance reviews by two. companies. Jack Woodard is 14 always in charge of the Farley plant, always in charge. 15 Let's say that George Harriston or I, let's say 16 that Jack comes up and Jack works for both of us. He says I 17 vant to make Joe maintenance manager. Well, generally, who 18 he selects as maintenance manager, Jack Woodard, he has the 19 authority to do that without referring to us but he confers 20 with us. If he comes and says Jay Jones, I want him as D-21 plant manager and we might talk to him and say who is your 22 other candidates. We will talk about it and say well, all l j 23 right, if that's why you want him that's fine. If not, we 24 will give some reason, just as though we are with no other 25 company in the whole world.
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Now, if he was talking about selecting another 2 person within that company, if he wants to select another 3 person in another company, then we have to follow the normal ) 4 Southern company processes where you request permission to 5 interview and consider somec' ody for a job and have a 6 selection process. Did I answer you directly? ) 7 MS. ADENSAM: Actually, I don't think you 8 understood ,1y question. I don't think I characterized it 9 right. ) 10 MR. MCDONALD: I answered the wrong question. 11 MS. ADENSAM: That's correct. 12 [ Laughter.] 13 MS. ADENSAM: What I was more interested in was a 14 technical conflict; whether or not a technical specification 3 15 needs to be met; whether or not safety modifications need to 16 be done; where the plants comes in and says we see a need 17 for this and the SONOPCO staff support staff supposedly says ) 18 you guys are all wet, we don't think so. How would that 19 kind of conflict be resolved? 20 MR. MCDONALD: Let's see if I can pose this 21 question in the right way and you help me. Jack Woodard is 22 here. Let's say his plant manager, lec's say that we are 23 going to change the timing in the motor operated valve a 24 little bit, and let's assume that there's some spec about 25 the allowances on it. That's not a good example, but let's )
1 D 16 1 use that. D 2 Dave sayn we have had trouble with that valve and 3 we have a problem in the timing of it, and we would like to
- 7) 4 change it and make it better and open it just a little bit 5 faster.
Jack just goes on and does business like he always 6 has. They talk back and forth. If there's a question about 3 7 it, Jack may turn to his corporate support and say let's 8 look into this. Let's get Westinghouse or Bechtel and see 9 what they say about it, get a stront technical position, ) l 10 have an engineering study and engineering findings. We put 11 it down here after it's decided and proposed and it may be 12 sent through the on-site review committee and off-site 13 review committee. 14 There is no change whatsoever than what he has 3 15 been doing and what we will be doing now. 3G MS. ADENSAM: Let me take something that I think 17 might be a little more significant from an organizational 18 standpoint. Let's say you need to make a decision regarding 19 your steam generators, and whether you are going to need to 20 replace them or not. D 21 MR. MCDONALD: That's a good question. That's a 22 good question. 23 MS. ADENSAM: Your staff at your site has been 24 working with the steam generators. They have been looking 25 at the results also of all kinds of testing. They are right J l
3 17 1 there, and if one of those tubes fail they are going to have 2 to mop it. They have a view in timing and scheduling and 3 the safety significance of when you make those changes, what 3; 4 you do to those steam generators. 5 Your SONOPCO support staff says no,'you are all 6 wet. You have four more years, five more yonrs, another ten O 7 years and they are good for this, V- con aat- I them, we can i 8 patch them. How would you resolve those differences? 9 i MR. MCDONALD: You asked the right question. This i O. 10
- so-called SONOPCO staff, Jack Woodard, he has working for .
11 him a man named John Garlington who you know. John g 12 Garlington is a general manager in charge of this thing. 13 John Carlington has a Southern Nuclear hat, but he is ' ! i
- 14 fulfilling exactly the same position as he was filling d) 15 before. He is carrying out the same procedures, the same i
16 review process. 17 The only difference about that is that he is i 4" 18 actually being paid by Southern Nuclear. He is doing all i 19 the programs that he was doing before with no change. He 20 has no alternate authority to challenge any decision made by
'21 that change. He is a contract' employee filling the same job )
22 that he did before. Intellectually, there has been no ; p 23 change at all. t 24 MS. ADENSAM: What I am hearing you say is that ; ) 25 from a technical work aspect this change is transparent to l ((
O 18 1 the corporate staff supporting the plant? O 2 MR. MCDONALD: That's right. Absolutely no 3 change. 4 MR. WOODARD: For example, the steam generator one 5 is ongoing right now. The way I view that particular 6 decision-making is the Southern Nuclear support general [) 7 Manager, John Garlington, his role -- we all know that we 8 need to replace steam generators. What we don't know is I 9 when. Dave, the plant manager, wants them replaced six l
) 10 months ago so he doesn't have the pain he just went through.
11 What John's role is, and he is actively doing this 12 today for a meeting next week is, is to put together all of ) 13 the alternatives that he can think of, the different options 14 that you have; maintenance type options and replacement g 15 cptions and attach economic significance to them. He does 16 that as a service to all of us. The decision on which 17 option is picked will be made jointly by myself, George 18 Harriston, Pat Mcdonald and Dave Morrey. 19 With John, he's the guy that is giving us the 20 input on what his cngineering shows as options. He is 21 providing a service so that decision can be made by line 22 management. 23 MS. ADENSAM: Okay. 24 MR. WOODARD: That's no different from before. 25 MS. ADENSAM: Let me ask you a question now.
) 19 r 1 Things are now different for you because you now have two I 2 bosses. Your performance in evaluating these options and 3 makinct a recommendation -- s 4 ) MR. MCDONALD: No, he does not have two bosses. 5 He has no boss except one when it comes to matters of safety ' 6 and carrying out the direction, supervision of those ' ) 7 matters. He only has one. 8 MS. ADENSAM: Okay. 9 MR. MCDONALD: Only one. ) 10 MS. ADENSAM: His performance is that of the 11 SONOPCO organization as you show it right here. 12 , ) MR. MCDONALD: The SONOPCO organization, all that 13 does it puts John Garlington there and pays him to do the 14 job he was doing before. ) 15 MS. ADENSAM: Jack's performance in this 16 particular matter is moot, because this issue is not before ' 17 them for decision; is that right? Am I understanding you ! ) 18 correctly? 19 MR. MCDONALD: That's right. That example is a 20 good example. It's a good example. As Jack said, Dave would ) 21 like to get rid of those things and get some that he doesn't 22 have to spend a long outage for. Jack is a little closer to 23 reality in terms of dollars, in realizing that you can do a
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24 lot to steam generators to operate them quite safely. 25 Come over here, and George and I have an opinion
) 4 1
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-O ! 20 1 1 and I have an opinion. O I have discussed this on several 2 occasions lately with Mr. Elmer Harris, including the day 3 before yesterday morning at 6:00 o' clock. He says, what do ,g 4 you think about those steam generators? I said, we are 4 5 going to have some meetings but it's going to'come down to a 6 financial tradeoff analysis. It's not a matter of safety, O 7 it's a matter of how much money you want to spend each year 8 and maintain them because they are safe.
- It's going to come ;
i 9 down to a financial decision. ' O 10 MR. MERSCHOFF: Pat, it looks like you are in an 11 interesting spot. What would happen if Mr. Dahlberg at 12 Georgia Power was dissatisfied with your performance but Mr. D 13 Farley and Mr. Harris were just as pleased as punch? 14 MR. MCDONALD: There has been an occasion or two 3 15 that he has been dissatisfied. 16 MR. MERSCHOFF: Do they have veto power? Would 17 you then be fired if one of the three felt that your 3 18 performance wasn't inclined -- 19 MR. MCDONALD: I don't want to find out. 20 (Laughter.) 3 21 MR. MCDONALD: Let me jur discuss this. I did 22 have a disagreement with Mr. Dahlberg on one occasion, and I
, 23 was sitting in my office in Birmingham where we are co-24 located and he was sitting over in Georgia. We didn't see 25 things eye to eye. So, being the subservient person that I G
^
CV y 21 1
) am, I said look,-I will be in the car and be over there in 2 two and one-half hours. I went over there and had a meeting 3 with him and resolved it.
[) 4 The point is, is this is a direct link at all
- 5 times. Every day on the day there are calls made from the 6
plant to a representative on this corporate staff. Jack has , D 7 thrte people who stand duties and calls. He has him as one 8 of them, he has two people in this organization that does 9 it. George or I, every day the plant gives us a status of 3 10 what has happened overnight, what the problems are, what the { 11 projected schedules for the day is for each plant. These : g 12 are phoned in and passed up to me. : i 13 Then, I call if there is something significant at l 14 all. I will call or George will call Elmer Harris if it's D 15
~
his, or Bill Dahlberg if it's his. 16 MR. MERSCHOFF: Pat, there may come a day when ! 17 there's someone in that Executive Vice President's position b 18 that is not as easy to work with as you are. One of those 19 three may wish to terminate the person in the next spot. My 20 question is, does the CEO have that authority to remove the l 21 person in that spot in his chain of command when the other 22 two wish it to not occur?
) 23 MR. MCDONALD: You always want tO ensure that the
( [ 24 ! authority to pay and authority to hire and fire, that's part 25 of the test of who you are working for. Yes, I think he has
) '
P
O 22 1 D every authority to say you are not going to work for me 2 anymore and I am going to replace you in the Georgia plant. 3 He will tell this guy and this guy that I am unsatisfied g 4 with him end going to replace him. Absolutely. 5 Let me go on and add that from an intellectual 6 point of view all of this is transparent, because it really 3 7 doesn't -- there aren't conflicts that do develop. This 8 gentleman, this gentleman and this one and the President of 9 Southern Company and the President of Southern Company 0 i 10 Services are members of the board of the Southern Nuclear 11 Company. Part of the job is trying to manage people. 12 0 If he's unhappy with who is here, that we have the 13 best chance of getting the best guy to get in that job out 14 of the Southern system or elsewhere, g 15 MS. ADENSAM: Pat, where do you go from here? 16 MR. MCDONALD: We just got here, Eleanor. We 17 expect to be in this condition for a while, until such time 18 as we move toward the transfer of license. 19 MS. ADENSAM: You are not in a position to say 20 when you think that might be? 21 MR. MCDONALD: Not today, no. 22 MR. VARGA: What does the dotted line between the 23
, President and CEO of SONOPCO and your position; what does 24 that mean?
25 MR. MCDONALD: That means that it's an D
3 ? i 23 1 administrative, non-operational. 3 2 MR. VARGA: He can't voice on you any particular ; 3 desires that he might have, having to do with one of the g 4 plants? 5 MR. MCDONALD: No. He has no authority over these 6 license-related type operations nor over the Alabama Power 3 7 Company people and Georgia Power Company people. 8 MR. LAINAS: I think what you are saying Pat is 9 that what you are doing here is, you are completely 3 10 consistent in requirements of the license and there's been 11 no change in ownership; that, as far as the tech specs are ' 12 concerned, 3 as far as those people that have been identified 13 in the tech specs; that, that remains the same? The lines 14 of responsibility and authority are identified and everybody 3 15 knows who has what responsibility, and you are in complete 16 conformance at this time with the license. 17 'AR. MCDONALD: I would go even beyond that. We i
- 5) 18 have made it so simplistic that it doesn't encourage 19 conflicts as you were asking about. It is a very simple 20 i type of an organization, because these people only have two l 3
21 hats. They have nothing to do with this plant over here, , 22 absolutely nothing, no responsibility of any type. 23 You started asking one question and you might have j 24 1 asked this question about what if they wanted to organize 25 their maintenance department one way. ! O
) 24 1 MS. ADENSAMr You ziean, at the site? 2 MR. MCDONALD: Yes, at the site. What if they 3 wanted to organize it? That organizing in that maintenance ) 4 department is still an Alabama Power problem. What we do as 5 a matter of Southern System Policy is, we try to keep them 6 somewhat the same so that we have comparative pay levels ) 7 between one company and the other and so that we work toward 8 the best type of organization. But we do not try to 9 standardize precisely the organizations because we want ) , 10 people to try things and we want to grow, and if we 11 standardize we would r. stably freeze at some level of 12 mediocrity in organizational. ) 13 MR. LAINAS: Pat, let me ask you something. Might 14 you say something about the advantages of this organization, ) 15 particularly in corporate. 16 MR. MCDONALD: Yes. There are lots of advantages, 17 and I guess we realize more advantages and we can see them ! ) 18 more clearly than we ever have. It is amazing what all of 19 us learn virtually day by day by the ability to compare 20 plants and what is happening in plants. If you have one I 21 thing happening to one plant you can immediately ask the ' 22 people what is happening there. That is such a tremendous ) 23 advantage. 24 The problem with it is, in all these schemes that 25 we have in our industry and that NRC takes to send out ) J
[ 25 i 1 notices and bulletins and what have you, there is a 2 frequency of things that are more prompt, that are more you 3 3 might say out of the mainstream that never come up in those.
} 4 Yet, we can learn those within the system and they are more 5 valtebir than we ever thought they would be. How does a 6
certain valve work, or have you had this problem with a
) 7 leak, or how does that get repaired.
t 8 The other thing that is important is in terms of - 9 financial management; how much is it costing you to do this
)
10 job. This is more than that and why is it more than that. I 11 We can go back and try to find out, again, things that are f 12 not that transparent. Another example, we just had one. We l 13 had this matter of selection of personnel. Before we got : 14 into this and toward this arrangement we have very poor ! 15 exchange of any people between the plant. We have not had 16 very many to date because we haven't wanted to change 17 people. People like where they grow up, they like to 18 promote within. They are still project oriented within. s
)
19 We have tried to do that. By promoting within we . 20 have a stronger spirited n~.ps, and yet we have some 21 exchange. We have, for example, Bill Shipman who was at 22
?
Farley. He then came over to vice president of this general - /' ' p 23 manager working up here, and now he's been acting down at 1 24 Plant Vogtle. We have also another advantage, is the l 25 propensity for various functions at these plants to work l
) \
26 1 together like in maintenance. Our maintenance managers meet 2 together now and lay out some plans that they then bring up 3 to these managers. D 4 Another thing which we have done which I think has 5 been particularly beneficial, we have had an analysis group 6 going on, three licensed operators, one from each project 7 who take on a given area to do a comparative analysis 8 between the plants. In that comparative analysis they might 9 look at things like control room manning or maintenance D 10 administration or outage management, or various things. 11 Then they go and do an analysis or comparative analysis of , 12 how that is done at one site versus another. There are some 13 odd rules about it. 14 They are not allowed to make any recommendations D 15 nor any findings. They just assemble the data, and then 16 that data is turned over to these three gentlemen. They 17 take that data and decide what could I learn from the other 1 0 18 plants to do to improve my plant. I could go on. 19 I think that we feel that it has been a very 20 positive thing in terms of career potentials, the future. j 21 As you all know the whole industry is not talking about l 22 future plants. Doing this and getting people together gives g 23 people the feeling that there is going to be a future in , 24 nuclear power, and they feel like they have teamed up with 25 some people that they will be better prepared to handle O
27 1 that. 2 MR. VARGA: Pat, you mentioned this transparent -- 3 MR. MCDONALD: You haven't thought that -- 4 } MR. VARGA: I haven't thought that yet. First, - 5 there's a CEO up there at SONOPCO who has administrative 6 functions only. ; What does he do then? ) 7 MR. MCDONALD: Let me tell you what they do. He 8 is currently the president of ANEC. You know what ANEC is, 9 American Nuclear Energy Council. ) He is the Chairman of it, 10 one of the industry organizations. 1 1 He is on the IMPOC 11 , Committee, he's on the ECI Committee. He is deeply involved 12 in uranium handling and that type of thing. He is deeply , 13 involved in Southern Company matters of a general systems 14 nature. ) 15 MR. VARGA: In terms of all of that, that is 16 encompassed by that kind of a trapezoidal -- 17 MR. MCDONALD: He represents you might say the 18 flow of individualized type leadership. Are those people 19 who are manning those jobs, are they trained well enough. 20 What are we looking for, for building people in the future. 21 He gets on administrative things. When we get to budget and 22 i compare all these budgets what we do is, we get the Alaba.na 23 ) budget and Georgia budget and we get all these peYple Yao 24 are on the board together and have one big neut;ag und 25 present the budget all at one time. ) _. l
f 1 28 1 Each of them can see what is happening. We had 2 one of those meetings here about two months ago, and he gave 3 us some pointed comments and he gave some pointed comments, ; y 4 and the Southern Company President gave us some pointed 5 comments. They can each see what is happening in the others , 6 and they can visually compare then. s We think and they think ' k 7 that it's promoting management all the way around. 8 MR. VARGA:
, From your position down, everything is 9 solid line. So now, there's a SONOPCO executive who has 10 solid line control. What things can you do on the plants 11 that you don't need Alabama Power CEO or the Georgia Power 12 CEO input; what kinds of things can you do? .
13 MR. MCDONALD: I can do those things that might be 14 contained in the contract. Through my Southern Nuclear hat, 15 I can go down here and have a guy who is giving us trouble - 16
- a Southern Nuclear employee who is not performing that job 17 well -- I, through the organization, can impose discipline
) la on him. I can hire him, I can fire him, I can get somebody e new. 20 It's just that like we have in many other nuclear 21 plants, where the plants have people doing staff work under 22 contract. 23 MR. VARGA: ) You can do that to somebody who has 24 double hat, like Woodard on SONOPCO APC? 25 MR. MCDONALD: A double-hatted, an officer?
= )I 29 1 MR. VARGA: Yes. ) 2 MR. MCDONALD: Yes, I could do that. 3 MR. VARGA: You could do that independent of the 4 Georgia Power? 5 MR. MCDONALD: No, I couldn't do that independant 6 of the Georgia Power. } 7 MR. VARGA: That was my question. What is that 8 you do independently? 9 MR. MCDONALD: When you have a double-hatted- ) 10 person I could not do that independently. I would have to 11 work with those two. 12 MR. VARGA: ) You couldn't do anything independent 13 down at the site organization except through the related 14 CEO. 15 Mh. MCDONALD: That's right. 16 MR. WOODARD: Pat, I think there's a confusing 17 point. MR. MCDONALD: Did I say something wrong? ) 18 MR. WOODARD: No , I think there's a perception 19 that isn't correct or I have a wrong perception. He can do 20 anything -- )- 21 MR. VARGA: , He, who?
- 22 MR. WOODARD: Pat, in that example with Georgia 23 Power.
) 24 MR. VARGA: Right. 25 MR. WOODARD: Or Alabama Power, that he could have )-
D . 30 F 1 done before that he can do by himself. In other words,'if 2 he wanted to fire me -- i 3 MR. MCDONALD: There is one example. Let me 1 3 4 follow up on that. Now, if I have this guy who is Jack 5 Woodard -- since he's talking about this -- Jack Woodard, I , 6 become unhappy with him. Now,-why do I become unhappy with 3 7 him? Here is where I have to choose how I handle it. If I t 8 become unhappy with him because I don't think he's looking 9 over the day to day business and things get away and he O 10 drops a head and runs water on the floor and things like 11 that, then I am going to say from my Alabama Power Coppany 12 hat, you are not performing your safety-related duties t 13 properly and I am unhappy with them. 14 When I mark his appraisal sheet down for safety-0 15 related duties, I am going to mark him down on that bad i 16 enough that we are going to have to do something else. On 17 the other hand if I say hey, you got a bunch of guys and you 3 18 got a bad morale down there in that support group by the 19 Southern Nuclear people and they now decided that they are 20
- 3. wearing white hats and Alabama Power is wearing green hats, 21 and they are ganging up on us. You are not doing anything 22 about us.
gp 23 From my Southern Nuclear hat I have to make those 24 guys realize that they are just like a contract employee and 25 knock that stuff off, gp_ l J
) I 31 1 ! MR. VARGA: 'In the example if you stick with the j 2 SONOPCO APC Vice President and you became unhappy with him 3- I and wanted to get rid of him, you could do that independent j 4 of any further consideration up above. 5 MR. MCDONALD: I could get rid of him as an APC [ 6 Vice President, you bet. I could'say you are not doing your i ) 7 safety-related -- you are fired from being an APC Vice ! i i 8 President from Farley Nuclear. ' 9 MR. VARGA: ! But before all of this you had certain ) 10 { forcing functions on you, certain pressures. Now you have ! 11 another. Now, to act like that now, you have another -- I ! 12 don't know what the pressure might be, but you have another 13 pressure on you now. '
)
14 MR. MCDONALD: Then, instead of going to Elmer f 15 ) ' Harris and saying Elmer look, I have to get rid of Jack. He ! t 16 broke his -- it bothers his work all the time and that sort 17 ! of thing and he's just not doing his job. I have to go up i )' 18 here to Farley and say hey,, we got a problem. We got a guy 19 who is about not to have a job. i When he gets laid off from 20 ; Alabama Power Company job we don't have any other jobs for ) i 21 him, so it seems like we are going to have to lay him off f
. 22 from Southern Nuclear also.
23 MR. VARGA: You can't do it independently? I t 24 MR. MCDONALD: I can fire him from Alabama Power ! 25 Compsny, sure. ! )
-. . . _ _ _ _ _ _ _ ___ a
32 1 MR. VARGA: My only point is, and it may not be a 2 valid point. My only point is that when you are acting as 3 nPC, when you are wearing two hats, somehow that other hat 4 doesn't disappear necessarily. You may have some other 5 people, you may have some other thinking behind you about 6 maybe somebody up there at the higher level in SONOPCO might 'f, 7 have said something or done something or given you some 8 influe.?ce. That's my question. 9 MR. MCDONALD; I think what we are really here 10 looking at is to make stre that there is the sanctity of the 11 3 operation, responsibility and control for safety-related 12 O activities. The sanctity goes right along with that hard 13 line. That's the sync part, and that is by far the 14 overwhelming percentage. g 15 For example, if you had to divide up what 16 percentage is this guy, an Alabama Power Company versus a 17 Southern Nuclear you might say it's 95-5. Again, from an O 18 intellectual point of view there is no difference. It's 19 only when we get down to the what if question like you asked 20 that you have to stop and think, D 21 MR. MATTHEWS: Pat, I have two questions. It may 22 be my faulty memory, but when you have discussed your plans 23 in previous meetings with Steve and myself and the EDO, I 24 did not recall this phase being as it appears to be now, on 25 extended in time. I recall this phase as being a brief
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O 33 1 D transition between Security and Exchange Commission approval 2 and transfer of license ownership. Am I correct in that? 3 MR. MCDONALD: I have not represented it as an g 4 extension in time. 5 MR. MATTHEWS: Neither did I deem it by my memory 6 as being indeterminate. D 7 MR. MCDONALD: Well, you -- 8 MR. MATTHEWS: As I said, it may be my faulty 9 memory. D 10 MR. MCDONALD: In order to make these things 11 happen we have a number of things to do. We have our co-12 J owners to ensure that all their board agreements -- to go 13 another step. We have any problems that they might have i 14 with them. You also have to do the bread and butter type of b 15 thing of when you get down this road you have to brief 16 people and have them make selections on going to a new 17 company. A thing like health benefits, that's complicated. 18 There has to be some step-wise action to do this, 19 because to try to do it all at once would be pretty chaotic. 20 MR. MATTHEWS: J I don't disagree with that. I guess 21 what I am saying is that in your earlier representations to 22 us, did they incorporate and envision this organization D 23 operating as it is right now? 24 MR. MCDONALD: I think it's virtually identical, 25 the way that we represented this before; that this is a so-5
) . 34 1 called phase II where we provide services and in phase III 2 there would be a transfer of license. 3 MR. VARGA: Dave, what did you think was the final 9 4 phase? I don't recall that. What was the final phase, in 5 your perception? 6 MR. MATTHEWS: My recollection was that there m J 7 might be a transition period between SEC approval and a 8 r; quest for amendment to us for transfer of license. 9 MR. MCDONALD: That's what this is. 3 ' 10 MR. MATTHEWS: But honestly, I viewed it in terms 11 of weeks if not months. 12 MR. MCDONALD: It may be. , 13 MR. MATTHEWS: Okay. If there was anything that 14 surprised me on receipt of your letter it was that I heard
) 15 about this phase and not the latter phase.
16 MR. MCDONALD: All right. 17 MR. MATTHEWS: To be honest, the letter that I 18 thought I was getting was going to announce transfer of 19 ownership and submittal of a license amendment. 20 MR. MCDONALD: O Ownership never changes. 21 MR. MATTHEWS: I'm sorry, I meant transfer of ' b 22 licenses. g 23 MR. MCDONALD: When I submitted the letter to you 24 or we submitted the letter to you, I think it was on the 25 December 6th. O
Q. l J 35 ! 1 MR. MATTHEWS: Yes. I 2 MR. MCDONALD: We said that we expect to. At that 3 time we didn't even have SEC approval, and we didn't have 4 the co-owners approval and all of that. So, we expected to s 5
~
and we did it after the Southern Nuclear was formed on the 6 18th by the first quite rapidly. The reason that we did it ' 3 7 quite rapidly at that time for this group of people -- it's ; 8
, very complicated if you don't switch somebody's company over !
9 the first of the year and have all FICA deductions and all : 10 of that. ff
, 11 MR. MATTHEWS: My perception was that I would be 12
.O . processing a license amendment very shortly after your SEC 13 approval. & 14 MR. MCDONALD: We hope you will. 15 9 MR. HATTHEWS: That was what impression I was left 16 with. t r 17 MR. VARGA: What is the final step? O 18 MR. MCDONALD: The final step, if we are able to 19 take it all at one time is that you will basically erase 20 these from here and it will only be Southern Nuclear, and we i O 21 will be operating license plant as the licensee under i 22 operating contracts. 23
~s >J MR. VARGA: Transfer of license.
- t 24 MR. MCDONALD: Transfer of license.
25 MR. MATTHEWS: Basically I don't wart to put words O 1
I I C) l I 36 ! i () 1 in your mouth, but that center line would become solid and 2 the other two lines potentially would become dotted. 3 MR. MCDONALD: Yes, and the double-hatting would () 4 all disappear. 5 MR. MATTHEWS: All disappear, and it's a SONOPCO ' 6 operated company. ' O 7 MR. MCDONALD: Yes. 8 MR. MATTHEWS: My second question was budget 9 authority. Does Joe Farley have budget authority with i 10 regard to expenditures affecting the plants, directly 11 affecting the plants? g 12 MR. MCDONALD: These two men are budget authority. 13 MS. ADENSAM: What about the support services 14 though? O 15 MR. MCDONALD: He has budget authority in the 16 support. He has budget authority for the various services, 17 for example, the building we have. The building, the 0 18 administrative department, and all the sundry type of 19 things, stationary and all that, we handle through Southern g 20 Nuclear. 21 MS. ADENSAM: Mr. Garlington decides that he needs 22 ten more engineers and another $2.5 million in contracts to 9 23 properly support Farley. He goes up and he's convinced 24 everybody and gets to Mr. Farley, and Mr. Farley -- ; 25 MR. MCDONALD: Mr. Farley has nothing to do with 3 i
f
.. I ?
1. 37 !
- 11 that.
)- " +' 2 MS. ADENSAM: Okay, where is'that slot? 1
,3 MR. MCDONALD: Jack Woodard in Alabama Power l
) 4 Company hat is responsible for assuring that the work is I i. 5 done, that Alabama Power Company work is done. > At that time J 1 6 if he says look, I have to have some more manpower because ! ) 7 the manpower can't do it and I want another man, then he's B first got to get an authorization from Alabama Power Company 9 i to put another man on. Then he hires a contract employee to j ) 10 fill that staff position, and that contract employee is a ! i f 11 Southern Nuclear employee. i
. l 12 MR. VARGA:
t Finally, is this correct? Finally, ! ). . 13 ; the two wings will disappear, the dotted line becomes solid, i 14 e and all the double and triple hats disappear? j ) 15 MR. MCDONALD: Right. I 16 MR. VARGA: When will that happen, you don't know? ! 17 MR. MCDONALD: ! As soon as practical. ) 18 MR. NASH: You are saying that there will be no 19 more Georgia Power Company and Alabama Power Company? i 20 ). MR. MCDONALD: No. I mean that we will perform j
'21 the entire scope of services under a contract to Alabama 22 <
Power Company and to a group of owners including Georgia 23 7 Power Company and three co-owners, of which Mr. Dan Smith is 24 the representative here today from oglethorpe. 25 MR. VARGA: ! Who will be the license holder then? i ) l i
k r i 38 l
'l-MR. MCDONALD: The license holder will be Southern ,
T. 2 Nuclear. : l 3 MR. ROBINSON: Two questions under that current' 4 organization structure. ) One, referring back to your ! 5 original remarks with respect to the composition of your j 6 salary. Does Alabama Power, Georgia Power and SONOPCO ). 7 contribute equally to your salary? ! l 8 ' MR. MCDONALD: No. 9 MR. ROBINSON: What is the breakdown of that 6 ) 10 contribution, percentage-wise? - 11 MR. MCDONALD: The contribution to salary is an 12 allocated number, but within that allocated number they set ) l 13 the level. I 14 MR. ROBINSON: Do you have a rough idea l 15 ! ) percentage-wise? 16 MR. MCDONALD: Yes, but I think that's not a ! 17 matter for discussion here. I ) 18 MR. ROBINSON: That wouldn't affect your , 19 performance with respect to who you would rather do a better i i 20 job for? 8 ). 21 . MR. MCDONALD: No. i 22 MR. ROBINSON: The second question is, if Elner 23 Harris wants Mr. Woodard to remain on the job and Joe Farley 24 wants him fired, what has happened? f ; 25 MR. MCDONALD: Today? ' I- !
) 39 , 1 MR. ROBINSON: Right now. J 2 MR. MCDONALO: He's an Alabama' Power Company 3 employee. Mr. Farley wants him fired? 4 MR. ROBINSON: Yes. ]. Mr. Harris wants to keep him 5 and Mr. Farley wants him fired, and they can't resolve it. 6- MR. MCDONALD: Mr. Farley can fire him as a ) 7 Southern Nuclear employee if he wants to. The fact is, you 8 see, these people are all sitting on the Board of Directors. 9 The reason they have that Board of Directors is to try to D 10 make sure that those problems like that get ironed out. 11 MR. ROBINSON: If it can't get ironed out? 12 MR. MCDONALD: If it can't be ironed out, 13 obviously, the stronger hand in this is Alabama Power , 14 Company. That's completely -- the sanctity of the license t } 15 and responsibility is absolute. There can never be a 16 dilution, eruption or whatsoever in the sanctity of that 17 operational responsibility. ) 18 MR. LAINAS: Pat, I have a question I want to ask. 19 You mentioned a lot of the advantages I think, the pattern 20 of the organization and I can understand that. But you 21 know, there is sort-of a disadvantage in a way, because now 22 there are three facilities involved and a lot of those lines ) 23 meet to George Harriston and yourself. 24 The question is, if a problem is happening at 25 Hatch and Hatch is down for a length of time let's say and )
40 1 then there's a question as to why -- a safety question, will 2 you be influenced by your overall power production from both 3 Georgia Power and Alabama Power in trying to make safety 4 } decisions with respect to Farley in considering -- how would 5 you face that? P 6 MR. MCDONALD: Can you state that again? ) 7 MR. LAINAS: Suppose you are having problems with 8 a plant that is running and the other plants are down, and 9 there's e power demand on the system -- D 10 , MR. MCDONALD: There's a power to man on the 11 N system and there's a safety concern at one plant that is 12 down. i f 13 MR. LAINAS: No, that's operating. 14 MR. MCDONALD: That is operating. 1 ) 15 MR. LAINAS: In other words, would you stretch the 16 safety decision on that being influenced by the other plants 17 being down and the demands on the system? ) 18 MR. MCDONALD: That's absolutely no different than j 19 what we have had before this occur. ! i 20 MR. LAINAS: Or other types of -- i l 21 MR. MCDONALD: As a officer of those two 22 companies, my immediate responsibility is nuclear. I am an p 23 officer of that company. If the fossil plants are down and l 24 we are trying to provide a load in any single company, I 25 have to do all I can to meet that load. . j l ) i
41 1 MR. LAINAS: It's really no different then from 2 any other utility that has multiple units. 3 MR. MCDONALD: Ns, not at all. We like to think 4 we have a better, more direct arrangement because we chose 5 in order to strengthen the leadership in management. Witn 6 this arrangement, with these three gentlemen, we chose that. J 7 We have ail arrangement like this to where we port and 8 starboard it ycu might say. We try to coordinate the 9 reports, and George is the one that is directly responsible 10 for it but I fill in when he's gone. 11 Mhen we get into a problem, one of us will 12 g probably go off with that problem and the other one would 13 pay attention to the rest of the business. For example, in 14 steam generators I spent almost all my time on steam g 15 generators and wasn't really too much involved in several 16 things at Georgia Power for a while because there was 17 nothing going on. Something happens at Georgia Power and 3 18 one of us will shift over there to give that attention. 19 MR. VARGA: What are the general delays that are 20 prohibiting an immediate implementation of the SONOPCO -- 3 21 MR. MCDONALD: It's the formality of signatures. 22 We could not -- it's formalities. We could not get some of 23 the co-owner board approvals and things like that and other 1 1 24 approvals that they had to have, so we couldn't go forward 25 until we had Southern Nuclear. So then, there's timing of j D l
i l Q V 42 1 meetings and timing of reviews. It has nothing to do at I) 2 this time that I know of, of anything -- ' l 3 MR. VARGA: Are you experiencing resistance from 4 the other owners? 5 MR. MCDONALD: We have experienced encouragement 6 from others. Dan's company for example, has encouraged us [) 7 to proceed on as efficiently as we can. 8 MS. ADENSAM: Do you have any contingency if these 9 issues don't get resolved and jou are not in a position to b) 10 transfer licenses? 11 MR. MCDONALD: Well, any contingency if they don't 12 get resolved? O 13 MS. ADENSAM: Would you -- 14 MR. MCDONALD: A month ago today we were sitting 15 here, and the only difference a month ago today is we would 16 erase that line and erase everywhere SONOPCO appears, 17 everywhere SONOPCO appears you would erass it. For all 3 18 practical purposes there is no difference in the day-to-day 19 operation of the plants. 20 MS. ADENSAM: You are continuing as of a month ago D 21 then? 22 MR. MCDONALD: Yes. A month ago there was no line 23 here. Mr. Farley was performing his job as a Vice President 24 of the Southern Company. He had no responsibilities for 25 this administrative support. That administrative support 9
43 1 that we had basically was being done, and he was a part of a 2 contract -- it was a contract to me from Southern Serv!.ces 3 for providing essentially much the same support we have here 3 4 now. 5 This group, for example, uas a Southern Company ,- 6
?services organization that was under contract -- inter-O 7 company contract essentially by me -- providing the same B
thing that they are doing after the company is formed. It 9 is no different. 10 MS. ADENSAM: I have one other question, a little 11 different shift. I heard you earlier say that Mr. 12 Garlington in the support organization was working with the i D 13 same procedures and pract!.ces and so forth that he did 14 before. g 15 MR. MCDONALD: Yes. 16 MS. ADENSAM: Now, I would assume that the 17 gentlemen for the Hatch Project -- or ladies, as the case 3 18 may be -- for the Hatch Project and Vogtle project are doing 19 the same thing. My question is, are they working with the 20 same procedures as each other, or the same procedures as D 21 they had before? 22 MR. MCDONALD: The business in each of these g 23 projects is being carried on under the name of Georgia or 24 Alabama Power Company. The communications that you will 25 see, the internal and external, will be in the name of O
1 44 1 Georgia or Alabama Power Company. ) 2 MS. ADENSAM: If Mr. Garlington, who went to Hatch 3 Project, he would have to deal with a different set of 4 procedures to conduct his business than he had when he was 5 working for Alabama Power?
- 6 MR. MCDONALD: Absolutel'y, because they are
)_ 7 different already. They had been different. 8 MS. ADENSAM: That's what I was trying to " 9 understand. If Mr. Farley said what kind of proceduras and i
) 10 support organization is my company using he is going to get 11 three different sets?
17 MR. MCDONALD: Right. That was the way it was ) 13 before and that's the way it will be after. Right now, we 14 see ne difference in that for the operating procedures. 15 ) Each of them will probably remain fairly unique maybe over 16 time. 17 MS. ADENSAM: : Even when you transfer licenses you ' ) 18 might still have unique sets of operating -- " 19 MR. MCDONALD: Probably unique sets. 20 MS. ADENSAM: Okay, thank you. ,
) 21 MR. HOFFMAN: In that case, if the NRC is using 22 their communication that requires a program be developed and .
23 implemented at the site, are you saying that we might see 24 three different approaches? 25 MR. MCDONALD: Yes, indeed.
)
k -. - < , - , , - . .
v. l. 45 , l 1 MR. HOFFMAN: Even though,-let's say, it's f 2 developed by your SONOPCO organization? ' 3 - MR . MCDONALD: Wait a minute. ' 4 j MR. HOFFMAN: I guess I am trying to find out -- 5 MR. MCDONALD: Wait. We don't have'a SONOPCO i 6 organization developed. We have contract employees working ! )[ 7 within an Alabama or Georgia organization. They are just ' 8 like IMPEL. We have hired people when we didn't have people i 9 to fill slots. We have. hired from a body shop, IMPEL, send J 10 me a contractor. He would come in and do all the work. All 11 the utilities have had people in staff jobs. 12 We have people in staff jobs 'in essence doing 13 that, and they are called Southern Nuclear people. t 14 MR. VARGA: That would be GE -- SONO;e8 c r 3 15 MR. MCDONALD: Yes. 16 MR. HOFFMAN: I guess what I am looking for is ; 17 whether there is going to be any cross-polynization where ) 18 the goods from one site gets filtered into the others and 19 the bad from the others. 20 MR. MCDONALD: It is -- i ) l 21 MR. HOFFMAN: Joint development, like in new 22 programs, new procedures -- 23 ) MR. MCDONALD: To the extent we can, we want to do 24 as much joint stuff as we can, where we can cut down on the 25 cost and increase the quality of the work. )
'i ?
k) I I 46 ' l 1
- o. MS. ADENSAM: That only comes to a head in Mr.
l 2 Harriston's -- > 3 MR. MCDCNALD: No. I ()L 4 MR. MCCOY: Could I give you an example of that, l 5 Pat? That is no different now than it was last year. Once 6 we formed our first organization, when we got a generic t 7 letter saying that we.were preparing c response to each of 8 us, our projects would prepare that response. Then, since we 7 9 i O are co-located in the same location we would talk about how 10 we are responding to that and try and see if we could ' l 11 benefit from the work that each of the groups have done. . 12
) Then, we each have an independent position for our plan in ,
13 the end. 14 MR. MCDONALD: Dave, you probably noticed that you ! O 15 get two letters. You get two letters that are virtually 16 identical but different letterhead. I 17 MR. WOODARD: I will give you an example that O 18 _ illustrates the principle that you are trying to get across. i 19 Various disciplines from each plant meet periodically, like ! 20 health physics. The plant health physicist at each plant, , 21 they will often get together say st a given plant and , 22 discuss.certain issues ano share problems and share i O. 23 successes, and then tour that facility. ' 24 They are a very close group. I mean, they pick up i 25 the phone and they talk to each other. In the process of i i O ! w- ,w... I
) t 47 1 discussing issues and sharing information, sharing problems ' 1 , 2 and successes -- by the way, regulatory compliance is a !
~
P 3 major thing they talk about, what kind of compliance 4 problems have you had and what kind of problems have you had I 5 in being successful with INPO. When it comes'down to 6 l decision-making and policy-making, they don't set policy. ) 7 That comes back to the line organization and they know that B full well that they must do that. 9 What happens is that they are able to function ! ) 10 like an industry group, only on a much closer knit and 11 continuous basis by being part of the same company. That's i 12 ) one of the major successes that I have seen in the past ; 13 year, are these discipline meetings and sharing information 14 and staying away from policy. Let the policy decision be I 15 made back through the line organization. 16 MR. HOFFMAN: I guess during this phase II, and it 17 sounds like even when you change over the licenses, that in I I ) 18 response to some requirement we may see three responses. 19 One plant will say I am going to go out and test, one plant 20 will say I am not going to test but do it by analysis, and ) 21 the other plant is going to say I'm not going to do anything 22 at all. 23 MR. MCDONALD: I would expect that you would 24 probably see basically three responses on a lot of issues. l 25 MR. VARGA: l As I understand it, as a conscious l ) i l
) 48 1 decision after coordination. ) 2 MR. MCDONALD: Yes. That's right. 6 3 MR. WOODARD: When you say that, it sounds -- it ) 4 doesn't sound right. In those cases we are usually very 5 knowledgeable about what the other person has' submitted, and 6 we have a reason why we are different. 7 MR. LAINAS: Are there any other questions from 8 the staff? 9 MR. NASH: How about marketing decisions, ) 10 marketing power decisions being made. I guess when you come 11 in for a license I guess that's the relevant -- 12 MR. WCDONALD: The marketing power has nothing 13 whatsoever to do now or in the future. The transfer of the 14 license, the same owners will continue to own the plant and 15 will receive the output. Southern is a very narrow scope 16 organization aimed solely at operating the plant. 17 MR. LAINAS: Any other questions from the staff? 18 [No response.) 19 MR. LAINAS: Steve, would you like to make a 20 comment? 21 MR. VARGA:. Thank yott very much for coming in. 22 MR. LAINAS: We have been so efficient we 23 ) circulated two attendance lists. So, if you haven't signed 24 in, would you mind. With that, I would like to thank you 25 very much, Pat. I know it was very difficult for you to )
3- t l i 49 l 1 come here today. Thank you for coming and thank you f'or 2.- your assistance. i 3 [Whereupon, at 11:50 a.m., the meeting concluded.) i 4 3: 5 6 , 6 D 7' ? 8 9 10 l. 11 5
- b 12 O , i 13 .
14 l c 3 15 16 17 ! l ) 18 l l 19 ! t i 20 ! O \ 21 . 22 , g 23 24 25 3
\
REPORTER'S CERTIFICATE This is to certify that the attached proceed-ings before the United States Nuclear
, Regulatory Commission i
J in the matter of: NAME OF PROCEEDING: T.mplementation of Southern Nuclear Operating Company
, _ , DOCKET NUMBER:
s PLACE OF PROCEEDING: Rockville, Maryland were heid as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Conmission 3 taken by me and thereafter reduced to typewriting by me or under the direction of the court report-ing company, and that the transcript is a true and accurate record of the foregoing proceedings.
)
O
$. i Official Reporter Ann Riley & Associates, Ltd.
wI O e l
' MEETING WITH ALABAMA POWER COMPANY AND GEORGIA POWER COMPANY REGARDING THE FORMATION OF SONOPCO JANUARY 11, 1991 NAME ORGANI2ATION g; p /IUff b l ga flS&y ks . k*. 00 % hxwm devaa Em O. $g Q yo._\ '\'*%Itau h o M. w. bah 4A b" i C-mp L.u. /.i -h 6 //anMpS ~.
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O EEs-05-1991 05:23 FPGt 5:r-VCGILE Et& LIC TO 9140465E5500 P.04 picf31 15:46 ;gs 252 0420 P.04 DLCH BIN 34*fi B'M114 ;, I .
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( A. P. *Donsed tie < ,v vo resem February 5,1991 l { Docket Hos. 50 424, 50 425; D } t 50-348, 50 364: 50 321, 50 366 U. 5. Nuclear Regulatory Comission Attention Darl Hood, Project Manager
,'. Office of Nuclear Reactor Regulation Washington, D. C. 20$55 O l TRAliSCRIPT OF JANUARY ll.1991. HEETING REGARDING SOUTHERN NUCLEAR OPERATING COMPANY
Dear Mr. Hood:
O Please find enclosed the Errata Sheet of the January 11, 1991, resting between NRC staff and Alabar:a Power Company and Georgit Power Company held in Acckville Marylan typographicalarrers,d.omissions The Errata andSheet containserrors transcription corrections as wellofas rephrasing and reorganization of some verbiage for clearer explanation. g : Sincerely, , 8 j 'k.js x R. P. Mc0cnald C ; RPN/ge
! Enclosure I
C i e , i 9 9 :
I O' SE -0T-1991 03:23 FRCM StC-T.GTLE EtG4.!C TO 914046555900 F.0T i i 09 @ 1931 15:47 BCLCH BIKiH:r' B'W414.. 205W M P5
' i 1 QY P'9 .,'
1 lC , ERRATA 5HELT TO MEETING CONCERNING IMPLEMENTATION OF 4 SOUTHERN NUCLEAR OPERATING COMPANY DATE OF MEETING: JANUARY 11, 1991 EME LIRE CORRECTI0li$ !O ' Cover Add "50-424" to the list of Docket Numbers ! 3 24 Strike "Hobbe" and replace with " Hobby" 3 25 Strike 'Mosbach" and replace with "Mosbaugh" O 7 14 strike " administrative type of service," and replace with " administrative and technical types of support services"
- 8 2 Strike "at" and replace with " hat" :
i 8 3, 5 Add " Operating" between " Nuclear" and " Company" O i 8 7, 14 i Strike "Harriston" and replace with *Hairston"- ! 2 9 10 Add "SAER Manager's" after "that" and before
" position" g 9 24 Strike "is" and replace with "and" !
10 14 Insert"and"between" administrative"and" support' , a 11 1 Strike type" and replace with " types" 11 9 Strike "Was" and replace with "!s" O 14 15 Strike "Harriston" and replace with "Hairston" 18 18 Strike "Harriston" and replace with "Hairston" 25 14 Strike "have" and insert "had* . 3
- 25 20 Strike " spirited corps" and replace with
' esprit de corps' -
27 10 Strike "lMPOC" and replace with "NPOC" 27 11 Strike "EDl" and replace with " eel" O e
) SEF-CT-1991 08 24 FPCf1 5t < '.CGT:.E Et G 'L IC TO 914046;&!:00 c.cs ecp1iw1991 15:47 EA CN B! toft 1 B'H^r1 R., ,~.2 252 043 P.06 7,p g 7m A- ?::< } . -
, .f
) , I i ) 31 16 Strike "- " and replace with " hand," ! 32 13 Strike " syne" ard replace with "significant"
! 33 12-13 i Strike and re lace with "Who want to ensure that all thei boards agree to go another
) - step. We have to address any problems that i they might have" 35 21 Strike " license" and replace with "the licensed" 38 1 Clarification: The Southern Nuclear Operating ) Company would be added to the licenses of the three
- plants . Since the owners of the facilities wquid not change, they would remain as licensees. ,
! 39 16 Strike " eruption" and replace with " disruption" 39 23 Strike "Harriston" and replace with "Hairston" 40 10 Strike "to man" and replace with " demand" 41 24 Strike "had" and replace with "have" ! 45 6 Strike " developed" and replace with " developmd program"
) < 45 8, 9 Strike "!MPEL" and replace with "!NPELL"
! 45 17 Strike " cross-polynization" and replace with l "c.ross pollination"
) 46 2 Strike "Harriston's" and replace with "Hairston's" , I 46 7-13 Strike and replace with ".. letter requirin a response from each of us, our projects wou d each
' prepare a draft response. Then, since we are co-located in the same location we would talk about
) - how we are responding and see if we could benefit from the work that each of the other projects have
. done. However, we each have an independent
- position for our plant in the end.
) . l
c- v . 24 r r-vi s s.c.4 u s vvu i ce ci w u m eu r.~ u- o.-s a v . . . W rad /1991 19:48 B:LCH Elt{Nt1 B'WI1 R . 205 252 M P.M j L. .. I' *
\ . .s : /.l ,{ '
I- ) ; 47 11 Strike ' company" and replace with ' organization *
! 48 12-16 Strike and replace with "the marketing of power and sale of power has nothii:9 whatscover to do now or in th. .uture with Southern Nuclear. After the transfer of the license in the future, the sama owners will continue to own the plant and will receive the output. Southern Nuclear will have a
) - very narrow sco e e anization aimed solely at operating the p ant ) ) ) i ) TOTR_ P.07 rnra e c- )
a l L v,.o. m l ?,7;L"id'.'Wl,ll* k E e, y,tclJ, m,, GeorgiaPower veseci March 28, 1991 ELV-02649 u s 0898 s Docket Hos. 50-424 50-425 U. S. Nuclear Regulatory Comission O ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen: V0GTLE ELECTRIC GENERATING PLANT UPDATED FINAL SAFETY ANALYSIS REPORT 3 In accordrince with 10 CFR 50.4(b) and 50.71(e) Georgia Power Company (GPC) hereby submits one signed original and ten copies of P.evisinn 1 to the Vogtle Electric Generating Plant Updated Final Safety Analysis Report. This submittal is provided on a replacement page basis and is accompanied by an effective page list that identifies the current pages of the UfSAR. This Revision 1 reflects
;3 changes through September 28, 1990.
P C. K. McCoy states that he is a vice president of Georgia Power Company and
- i. Juthorized to execute this oath on Lehalf of Georgia Power Company and that, to the best of his knowledge and belief, the information contained in the enclosed UFSAR Revision 1 accurately presents changes made since the previous ,
submittal, necessary to reflect information and analyses submitted to the ' 3 Comission or prepared pursuant to Comission requircments. GEORGIA POWER COMPANY 3 By: _ C. K. McCoy Sworn to and subscribed before me this J.,8. day of M/M , 1991.
' M nso d NotardPublic WY CON 11t?N (W($ JANUAtf !!.1993 CKH/JLL/gmb xe(seenextpage) . i. . ; .9...-
1 1 y . 02-03-1994 2a:49- aas 877 7149 ses vooTLE pac.ec7 P.es
)
l VEGP-F8AR-13 Q 13.0 CONDUCT OF OPERATIONS U 13.1 ORGANIZATIONAL STRUCTURE OF APPLICANT O-13.1.1 MANAGENINT AND TECHNICAL SUPPORT ORGANIZATION i This section provides information concerning corporate organisation, functions, and responsibilities; participation in , the facility design; design review; design approval; construction management; testing; and operation of the plant. The corporate nuclear operations organisation and the GPC plant organization are responsible for directing activities at VEGP. The organizations described in chapter 13 support and report to nuclear operations for assigned activities. i 13.1.1.1 Desion and ODeratina Resoonsibilities The following paragraphs summarise the degree to which design, construction, and preoperational activities were accomplished and describe the specific responsibilities and activities relative to technical support for operations. 13.1.1.1.1 Design and Construction Activities l 13.1.1.1.1.1 Prineinal Site-Related Encineerine Work.
) Principal site-related work (such as meteorology, geology, seismology, hydrology, and demography) is described in chapter
- 2. The VEGP preoperational monitoring program is described in the environmental report; this program established a preoperational baseline from which to evaluate future monitoring of environmental effects.
)
13.1.1.1.1.2 Desian of Plant and Auxiliary Systems. Units 1 and 2 engineering sad construction are complete. 13.1.1.1.1.3 Sito Layout with ResDect to Environmental Effects and Security Provusions. Site layout with respect to
) environmental effects is described in chapter 2. Site security with. respect to plant geographical layout and equipment is described in the security plan. )
13.1.1-1 REV 1 3/91
) -
O ca-os-iss4 to:so aos e77 ,1,9 ses voo u eaa:e:r g oe O VEGP-PsAn-13 13.1.1.1.3 Technical Support for Operations SNC Nuclear Support (Vogtle) has overall authority and O responsibility for assuring the availability of, for providing, or for securing adequate technical support for.the VEGP. This capability is administered through SNC's Corporate Nuclear Engineering and Licensing (Vogtle) (NEL) . SNC NEL may use the services of SNC Technical Services, SCS, Bechtel, Westinghouse, I and others as appropriate, portions of the technical support n U f rom these organia ations may be fulfilled through the use of outside contractors. To fulfill these responsibilities, SNC NEL interfaces directly , with and holds SCS and others accountable for various assigned , support activities, which normally include the following' O A. Architect-engineering services'of SCs and others as required for the design-engineering of plant l modifications, including maintenance-related design changes, plant improvement-related design changes, and design changes or major plant additions as a result of new regulatory requirements and commitmencs. { These O services include both conceptusi and detailed design, i isst;e and maintenance of design drawings and specifications, incorporation of as-built notices, procurement, related quality assurance functions, etc. B. Design-related safety evaluation and analysis. O C. bite assistance as required on safety evaluations and analyses which are not directly related to design; i.e., operational requirements, technical specification changes, etc. Nuclear Engineering and Licensing (Vogtle) also interfaces O directly with SMC Technical services for various support l activities, including the following: A. Nuclear fuel procurement and contract management. l B. Nuclear fuel support, including core analysis and O quality assurance. ; C. Licensing and engineering support for selected generic issues and projects, j l l
'O i 13'l'l~4 "'" l 1 O
_. ._. ._ _ ~ -- - t C2-o3-1994 10:51' 205 877 7149 SCS VOOTLE PAC.;ECT 1 p,og VEGP-FSAR-13 ,O j D. Environmental, health physics, and plant chemistry { support. ' I SCS provided an organization for its " project phase" (Standard ' Review Plan terminology) scope of responsibility in support of l 3 the design, construction, and licensing of the VEGP. This l organisation had both home office and onsite responsibilities and capabilities, and it has been converted into a long-term i operational support organization to provide the type support - l noted above. This new organisation includes all major design disciplines, and contracts for outside specialty technical { 1 l3 - support when additional expertise is needed and when major ! surges in manpower needs occur.
]
- 13.1.1.1.3.1 Nitclear. Mechanical, Structural, Electrical.
Thermal-Hydraul uc, Meta 11urcy and Mater:,als. and Instrumentation 3 . 3 and Control Inanneerina.- SCS is the pt:. mary source of 1 engineering in thess, disciplines. Nuclear Engineering and I Licensing (Vogtle) is responsible for the interface with SC5. The duties of the manager-nuclear engineering and licensing (Vogtle) are described in paragraph 13.1.1.2.1.9. ' j O 13.1.1.1.3.2 Plant Chemistry. Plant chemistry support is the responsibility of SNC Technical Services, as discussed in .
- paragraph 13.1.1.1.3. l l
I j 13.1.1.1.3.3 Mealth Physics. Health physics support is
- g provided by ENC Technical Services, as discussed in paragraph 13.1.1.1.3. l
- l I
13.1.1.1.3.4 Fueline and Refuelino Operations Support. Nuclear : Engineering and Licensing (Vogtle) of Nuclear Support (Vogtle) I g is responsible for procuring support in this area from SNC l Technical Services and others, as discussed in paragraph 13.1.1.2.1.9. 1 13.1.1.1.3.5 Maintenance Succort. SNC Nuclear Maintenance and ; Support (Vogtle) in SNC Nuclear Support (Vogtle) provides this j O support, as discussed in paragraph 13.1.1.2.1.10. , I O 13.1.1-5 REV 1 3/91 O l
' _ .. - - __ - J
a2-s-iss4 20:s1 aos 877 m e ses voorte pqo;e:7 P.te f VEGP-FSAR-13 13.1.1.2 Oreanisational Arranoement 13.1.1.2.1 Muclear Operations Organization The nuclear operations organisation, under the supervision of the executive vice president-nuclear operations, has direct responsibility for the operation and maintenance of GPC's (and APC's) nuclear plants. The nuclear operations organization consists of the GPC plant operating staffs and SNC Safety Audit and Engineering Review. It also includes SNC Nuclear Support t (Vogtle), which provides support in the areas of engineering, licensing, v.aintenance, and administration. ! Engineering support is provided primarily by the SC8 Nuclear plant Support (Vogtle). SNC Technical Services provides nuclear fuel contract administrative services, reload licensing, and l h operating licensing support. l ! The structures of the nuclear operations organization and the ! i Vogtle organisation are shown in figures 13.1.1-1 and 13.1.1-2 i
- and is described in the following paragraphs.
13.1.1.2.1.1 Executive Vice president-Nuclear Overstions. The ! executive vice president-nuclear operations (an officer of SNC, 1 Opc, and APC) is responsibis for all aspects of operation of the j i nuclear generating plants in the GPC and APC systems, as well as for technical and administrative support activities provided by ) SNC, SCS, and nonaffiliate contractors. The executive vice president-nuclear operations reports to the president and CEO of GPC with respect to all GPC matters including, but not limited i
)
to, rights granted under any NRC operating or materials license ! for VEGP, budget matters respecting VEGP, and GPC personnel matters. The executive vice president-nuclear operations also
) reports to the CEO of APC with respect to all APC matters concerning Plant Farley, and to the CEO of $NC with respect to all SNC matters, such as SNC personnel matters. SNC matters are currently limited to operational support activities. (See paragraph 1.4.6.3.) The executive vice president-nuclear operations directs the senf or vice president-nuclear operations. ) The vice president-administr.3tive services and the vice president-technical services also report to the executive vice president. -
13.1.1.2.1.2 Senior Vice president-Nuclear Ocerations. The senior vice president-nuclear operations (an officer of SNC, GPC,
) and APC) reports to the executive vice president-nuclear operations. This individual is responsible for the safe, reliable, and efficient operation of plants Vogtle, Hatch, and 13.1.1-6 REV 1 3/91 J
e2-e3-1ss4 20:52 2as 877 7149 scs voon.E mc.:ECT P.11 VEGP-FSAR-13 Farley. The senior vice president-nuclear operations direces the vice president-nuclear (Vogtle), the vice president-nuclear (Hatch), and the vice president-nuclear (Farley). '
) 13.1.1.2.1.3 Vice president-Technical services. The vice president-technical services, an officer of SNC, provides unique expertise in areas that perform best when functionally grouped and provides an in-focus response to generic regulatory or industry issues. Organizations contained within Technical Services are Nuclear Fuel; Inspection and Testing Services; Corporate Quality Services; and Regulatory, Engineering, and Environmental Services.
13.1.1.2.1.4 V:,ce prosident-Administrative Services. The vice i president-admin:.strat:,ve services, an officer of SNC, reports l
- directly to the executive vice president-nuclear operations. The L vice president administrative services is responsible for providing
) corporate administrative services including financial services, public affairs, security (corporate), human resources, and corporate services. Reporting directly to the vice president-administrative services are the controller and treasurer; general manager-human resources; manager-corporate services; manager-public affairs; and manager-security. )
13.1.1.2.1.5 Vice President-Nuclear (voutle). The vice president-nuclear (Vogtle), an officer of GPC and SNC, reports to l the senior vice president-nuclear operations and is responsible for operation and maintenance of VEGF, as well as for licensing, l
) engineering, maintenance, and administrative support activities.
The vice president-nuclear (Vogtle) directs the GPC general manager-nuclear plant (Vogtle), the SNC general manager-nuclear support (Vogtle), and the SNC manager-safety audit and engineering review (Vogtle).
) 13.1.1.2.1.6 SNC General Manager-Nuclear Support (Voctie). The SNC general manager-nuclear support (Vogtle) reports to the vice president-nuclear (Vogtle) and la responsible for corporate support in the areas of engineering, licensing, maintenance, and administration. The SNC general manager-nuclear support (Vogtle) directs the SNC manager-nuclear engineering and licensing (Vogtle), ) the SNC manager-nuclear maintenance and support (Vogtle), and the SNC manager-nuclear administration (Vogtle).
13.1.1.2.1.7 SNC Manager-Safety Audit and Encineerina Review , (Vogtle). The responsibilities of the SNC manager-safety audit and engineering review (Vogtle) are described in section 17.2.
)
13.1.1-7 REV 1 3/91
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)
13.1.2 OPERATING ORGANIZATION 13.1.2.1 Plant organization i
) The VEGP consists of two nearly identical nuclear generating units. The applicable plant org anization is shown in figure 13.1.2-1.
13.1.2.2 Plant personnel ResDonsibilities and Authorities , 13.1.2.2.1 overall Plant Management The GPC general manager-nuclear plant (Vogtle) (GMNP) is l responsible for direct management of the plant, including
) industrial relations, planning, coordination, direction of operation, training, maintenance, refueling, and technical activities. The GMMP is responsible for compliance with the requirements of the operating license, Technical Specifications, and quality assurance program. In the GMMP's abeence, the assistant general manager-plant operations assumes , ) responsibility for the plant. The GMNP will designate in writing other qualified personnel to assume overall plant responsibility in'his absence. (see paragraph 13.1.2.2.2 for succession of responsibility for overall plant operation.)
The GMNP reports to the vice president-nuclear (Vogtle). The GMNP has access to the advice and services of technical specialists within Georgia Power Company (GPC), SNC Nuclear i Support (Vogtle), and outside expertise as necessary. : ' The line organizations reporting to the GMNP are: ; A. ! The assistant general manager-plant operations is responsible for the operation of Units 1 and 2. ! Reporting to the assistant general manager-plant operations are the manager-operations, the manager-maintenance, the manager-outage and planning, i and the manager-health physics and chemistry. B. The assistant general manager-plant support is
) responsible for supporting Units 1 and 2 Reporting to this assistant general manager are the manager-technical support, the manager-engineering support, the manager-training and emergency preparedness, the manager-administration, and the sseurity manager.
1 . 13.1.2-1 REV 1 3/91 !
'o- ((gcq,a.,*-., g, mig +am Awoama 35201
,,..wea ros au soes k, k Ran i
AlabamaPower !
;O j,*,"f;'u,,, June 20, 1991 fne sournem e.ecuc sac-l i Farwy Pro,eCI Docket Nos. 50-348 l 50-364
- O i
U. S. Nuclear Regulatory Consnission ' l ATTH: Document Control Desk ' Washington, DC 20555 i
- j. ,
Joseph M. Farley Nuclear Plant j O. Southern Nuclear Orcanizational Chance ' '.; i Gentlemen: I On May 6,1991, Alabama Power Company, as holder of the licenses for the ! jo Joseph M.' Farley Nuclear Plant (FNP), Units 1 and 2, submitted to the NRC :
- its Application to Amend Facility Operating License Nos. NPF-2 and NPF-8 to !
j add Southern Nuclear Operating Company (Southern Nuclear) as a licensee. ! Upon amendment of the licenses, Southern Nuclear will become the operator of FNP and Alabama Power Company will continue to retain ownership of FNP. The May 6, 1991 Application presented the Southern Nuclear organization '
- O itructure as it existed on May 6, 1991. On May 21, 1991, the Board of ;
- Directors of Southern Nuclear named Joseph M. Farley, the President and !
Chief Executive Officer of Southern Nuclear, as Chairman.of _the_ Board and i Chief _ Exec _utive Officer of Southern _ Nuclear _. The Board of Directors of i Southern Nuclear further acted by naming R. P. Mcdonald, the Executive Vice , i President of Southern Nuclear, as President of Southern Nuclear. - O Mr. Mcdonald will continue to serve as Executive Vice President of Alabama The !' Power Company and Executive Vice President of Georgia Power Company. l ' position of Executive Vice President within Southern Nuclear no longer ! appears as a result of this organizational structure modification. The . personnel who previously reported to the Executive Vice President of i Southern Nuclear now report to the President. No other management changes
.O were made and all other reporting lines specified in the Application to Amend Facility Operating License Nos. NPF-2 and NPF-8 remain the same.
As a result of these changes, there is no impact on the significant hazards
- consideration evaluation or the conclusions made in the May 6,1991 .
Application to Amend Facility Operating License Nos. NPF-2 and NPF-8. lO j Should additional infonsation be necessary,.please advise. 4 Respectfully submitted, 4 0. i Mdd
. Woodard JDW/JHG l
O
UNITED STATES 9/ 074 r
/pm Cicgo, NUCLEAR REGULATORY COMMISSION )
3 's
- REGION 81 l
[ .), #' 101 MARIETTA STREET. N.W.
, .t ATLANTA, GEORGIA 30323 *N'Wi4 b g 7}#
Docket flos.: 50-424, 50-425 OCT 2 B 1331 . License Nos.: NPF-68, NPF-81 l Georgia Power Company ATTN: Mr. W. G. Hairston, III 1 Senior Vice President - Nuclear Operations P.O. Box 1295 O Birmingnam, AL 35201 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NOS.: 50-424/91-22 AND 50-425/91-22 a This refers to the inspection conducted by Brian Bonser of this office on August 25 - September 28, 1991. This inspection included a review of activities authorized for your Vogtle facility. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report. O Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress. The enclosed Inspection Report identifies activities that appeared to violate O NRC requirements that are not cited; therefore, a response is not required. In accordance with Section 2.790 of the NRC's " Rules of Practice," a copy of this letter and the enclosure will be placed in the NRC Public Document Room. Should you have any questions concerning this letter, please contact us. ! D Sincerely, el>7 A 'll O Alan R. Herdt, Chief Reactor Projects Branch 3 Division of Reactor Projects
Enclosure:
NRC Inspection Reoort O u cc w/ encl: (See page 2) , of b
Georgia Power Company 2 OCT 2 8139y cc w/ encl: R. P. Mcdonald Executive Vice President-Nuclear Operations Georgia Power Company P. O. Box 1295 Birmingham, AL 35201 C. K. McCoy Vice President-Nuclear D Georgia Power Company P. O. 1295 Birmingham, AL 35201 W. B. Shipman General Manager, Nuclear Operations O Georgia Power Company P. O. 1600 Waynesboro, GA 30830 J. A. Bailey Manager-Licensing O Georgia Power Company P. O. Box 1295 Birmingham, AL 35201 D. Kirkland, III, Counsel Office of the Consumer's O Utility Council Suite 225, 32 Peachtree Street, NE Atlanta, GA 30302 Office of Planning and Budget Room 615B O 270 Washington Street, SW Atlanta, GA 30334 Office of the County Commissioner Burke County Commission Waynesboro, GA 30830 0 Joe D. Tanner, Comissioner Department of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334 O (cc w/enci cont'd - see page 3) O
Georgia Power Company 3 y GCT 2 8 gy cc w/ encl: (Continued) Thomas Hill, Manager Radioactive Materials Program I
- . - Department of Natural Resources 4244 International Parkway D-Suite 114
- Atlanta, GA 30354 Attorney General
. Law Department 3: '
132 Judicial Building l Atlanta, GA 30334 Dan Smith, Program Director of Power Production Oglethorpe Power Corporation D 2100 East Exchange Place P. O. Box 1349 Tucker, GA 30085-1349
~
Charles A. Patrizia, Esq. Paul. Hastings, Janofsky & Walker 3 12th Floor 1050 Connecticut Avenue, fM Washington, D. C. 20036 1 i i J D J-
.- ~- . = _ . - - - . .
UNITED STATES
/p 288vg*o. * * ' ' ~*
- NUCLEAR REGULATORY COMMISSION mEcloNti-
'f 101 MAmlETTA STREET, N W.
e
, A TLANT A. cE cac A 30323 c
V \...../ t Report Nos.: 50-424/91-22 and 50-425/91-22 Licensee: Georgia Power Company n P.O. Box 1295 V Birmingham, AL 35201 i Docket Nos.: 50-424 and 50-425 License Nos.: NPF-6B and NPF-81 Facility Name: Vogtle Units 1 and 2 O Inspection Conducted: August 25 - September 28, 1991 Inspectors: $. .E % h Io/2S/ri B. R. Sonsqr, SeniorRestcent inspector Date Signeo O 5. 5 Y % o /zt/v. R. D. Starkey, Res Went inspector Da~te Signeo S.G. % % P. A. Balppin, Reedent inspector in/n/v. Date Sigriec Approved By: Mb -
/*/28/9/
P. Skinner, Chief Oate Signeo Reactor Projects Section 3B Division of Reactor Projects O
SUMMARY
Scope: This routine inspection entailed inspection in the following areas: I O plant operations, surnillance, an ESF system walkdown, review of licensee event reports, followup, and review of off-site engineering and technical support resources during a visit to the licensee's corporate offices. Results: Two ran-cited violatirra vare identified and reviewed during the inspection: Failure to perform a TS required emergency diesel fuel oil analysis for ash content resulted in a missed surveillance (paragraph 4b). O
31 i 2 : [)- A violation, with two examples of isolated cases of failure to - follow procedure by contract maintenance personnel.. One example involved incorrect installation of an RC5 temporary l level indication tygon tube. The second example involved
- )' incorrect installation of a reactor cavity ventilation port i
cover. This error resulted in a leak to the reactor cavity sump while the reactor cavity was being filled for defueling. Both- . examples exemplify procedural adherence maintenance personnel (paragraph Sb & Sd) problems with contract [). One Unresolved Item was' identified. The licensee has idratified 237 ; open terminal block links. The safety significance of the open links l requires furcher evaluation by the inspectors. The identification of ' this issue by the licensee is identified as a strength. The licensee . identified a trend in open terminal block links and pursued a broad ' inspection and evaluation program. . One Inspector Followup Item was identified for failure to follow long-term corrective action following two failures of the Containment Atmospnere Gaseous and Particulate Radioactivity Monitors,1RE-2562. Each of these failures placed Unit 1 in a six hour action statement. ! (paragraph 2d) - O A weakness was observed in procedural adherence by contract maintenance personnel. ' i () ; 1 [) ; e i i EI l
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.t OETAILS
- 1. Persens' Contacted
)" Licensee Employees
*J. Beasley, Assistatt General Manager Plant Operations *H. Beacher, Senior Plant Engineer S. Bradley, Reactor Engineering Supervisor *W. Bunneister, Manager Engineering Support
).. 'S. Chesnut Manager Engineerin>; *nical Support C. Christiansen, Safety Audit at.. agineering Group Supervisor C. Coursey, Maintenance Superintencent
*H. Grimes, Supervisor Nuclear Security - Lieutenant *W. Guthrie, Security Specialist 'H. Handfinger, Manager Maintenance
) M. Hobbs, I&C Superintendent K. Holmes, Manager Training and Emergency Preparedness
*D Huyck, Nuclear Security Manager *W. Jukes, Nuclear Security Supervisor - Operations *W. Kitchens, Assistant General Manager Plant Support *R. .LeGrand, Manager Operations
) *R. Moye, Plant Engineering Supervisor
*G. McCarley, ISEG Supervisor *N. Moseley, Senior Engineer ! - SAER *P. O'Neil, Supervisor Nuclear Security - Captain *A. Prestifilippo, Engineering Support *M. Sheibani, Nuclear Safety and Compliance Supervisor
) W. Shipman, General Manager Nuclear Plant
*C. atinespring, Manager Administration 'J. Swartzwelder, Manager Outage and Planning 'C. Tynan, Nuclear Proceoures Supervisor Other licensee employees contacted included technicians, supervisors,
) engineers, operators, maintenance personnel, quality centrol inspectors, and office personnel. NRC Resident Inspectors / Regional Inspectors
*B. Bonser
)_
*D. Starkey 'P. Balmain . 'W. Tobin *E. Clay
- Attended Exit Interview
)
An alphabetical list of abbreviations is located in the last paragraph of the inspection report.
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.O ' 2 'O ,
- 2. Plant Operations - (71707)
- a. General
'O The inspection staff reviewed plant operations throughout the reporting period to verify conformance with regulatory requirements, Technical Specifications, and administrative controls. Control logs, t 4 shift supervisors' logs, shift relief records, LCO status logs, night orders and standing orders, lifted wires and jumper logs, and clearance logs were routineiy reviewed. Discussions were conducted
'O with plant operations, maintenance, chemistry, health physics, engineering support and technical support personnel. Daily plant status meetings were routinely attended. 4 Activities within the control room were monitored during shifts and shift changes. Actions coserved were conducted as reouireo by the g licensee's procedures. The complement of licensed personnel on each s shift met or exceeded the minimum required by TS. Direct observations were conducted of control room panels, instrumentation and recorder traces important to safety. Operating parameters were + 4 observed to verify they were within TS limits. The inspectors also reviewed DCs to detennine whether the licensee was appropriately O documenting problems and implementing corrective actions. Plant tours were taken during the reporting period on a routine basis. They included, but were not limited to, the turbine building, the auxiliary building, electrical equipment rooms, cable spreading rooms, NSCW towers, DG buildirgs, AFW cnd the low voltage switchyard.
'o Tours were taken of the Unit 1 containment. The resident inspectors observed defueling and other activities. 2 During a review of refueling procedures located at the fuel Handling Building Spent Fuel Pool checkpoint desk, the inspector discovered '
three procedures that did not have the most current revision. The o procedures sampled did not indicate whether they were " working" or "information" copies. The Shift Superintendent was notified and prompt action was taken to remove the procedures from the area. l r During plant tours, housekeeping, security, equipment status and l radiological control practices were observed. 3 The inspectors verified that the licensee's health pnysics policies / procedures were followed. This included observation of HP ' practices and review of area surveys, radiation work permits, postings, and instrument calibration. l 9
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) 3 ) The inspectors verified that the security organization was properly manned and security personnel were capable of perfoming their assigned functions; persons and packages were cnected prinr to entry ) into the PA; vehicles were properly authorized, searchec, and escorted with the PA; persons within the PA displayed photo idencification badges; and personnel in vital areas were authorized. During this reporting period several management changes occurred. Mr. J. B. Beasley was named Assistant General Manager - Plant Operations. He had previously been Operations Manager. ) Mr. W. F. Ki tchen', moved to Assistant General Manager - Plant Support. He hd previously held the position of Assistant General Mange - Plant Operations. Mr. R. L. Legrand was named Operations Managt.. He had previously been the Health Physics and Chemistry Manager. ) o. Unit 1 Summary The unit began the period at approximately 94t pcwer in a coastdown for the IR3 refueling outage. On September 14, a pcwer descent from 79 percent power was initiated; the unit was manually trinped from ) 20 percent power and entered Mode 3 at 12:38 a.m. EDT on September
- 15. While the unit was in Mode 3 a pressurizer safety valve failed its surveillance test and was declared inoperable at 5:25 a.m. EDT.
RCS cooldown to Mode 4 was initiated at 6:30 a.m. EDT and the unit entered Mode 4 at 9:32 a.m., EDT. RCS cooldown du-ation ; mode 4 from the time the safety valve was declared inoperable was 6 hours and 7 minutes. This was within the 6 hour and 15 minute allowable ) time. Mode 5 was entered on September 15. The reactor vessel head studs were detensioned and the unit entered Mode 6 on Septemoer 22. Core offload commenced on September 26 and was completcd on Septemoer 28.
- c. Unit 2 Sumary
) Unit 2 began the period operating at 100t power. On September 13, power was reduced to approximately 85% power to isolate the B condenser east waterbox to identify and repair a potential condenser tube leak. Secondary sodium levels had been trending upward which ) indicated a small leak of circulating water into the condensate system. Twenty-two condenser tubes were plugged and power was returned to 100t by September 16. Sodium levels began trencing upward again. On September 19 power was reduced to 85t in order to isolate the B condenser east waterbox and continue troubleshooting the source of the elevated sodium levels. Power was increased on September 21 to 92t and remained at this level thrcugh the eM of this reporting period to continue troubleshooting c ncenser problems. )
) 4 ) d. Loss Of Two Unit 1. Reactor Coolant System Leakage Detection Systems. At 11:55 pm COT on August 29, Unit 1 entered the TS action statement 3.4.6.1, Reactor Coolant System Leakage Detection System, due to the 3 failure of the south Containment Sump Level Transmitter. The action statement allows for operation to continue for up to 30 days provided grab samoles are taken. Later that same shift, at 1:22 am on August ' 30, Chemistry notified the Control Room that the DPM for 1RE-2562, Containment Atmosphere Gaseous and Particulate Radioactivity monitor, had experienced a power surge and was inoperable. Unit 1 then ) entered TS 3.0.3 due to two RCS leakage detection systems being inoperable. At 3:05 am 1RE-2562 was repaired and declared operable and TS 3.0.3 was exited. However, again at 7:04 am 1RE-2562 expertenced another power spike and failed resulting in a second entry into TS 3.0.3. Following this second TS 3.0.3 entry, the licensee determined that TS 3.0.3 had baari ircorrectly entered and ) that the ccrrect action snould have been tc enter the action statement of TS 3.4.6.1 which required shutdown to at least hot standby within 6 hours and cold shutdown within the following 30 hours. TS 3.4.6.1 on previous occasions had resulted in interpretation ) difficulties regarding the mecning of "otherwise" in the action statement. Clarification was made by the NRC in a letter to GPC dated August 13, 1991, which stated that the loss of two RCS leakage detection systems is governed by the shutdown requirements of the action statement of TS 3.4.6.1, and that there was no requirement to enter TS 3.0.3. ) On the morning of August 30, the licensee initiated a conference call with NRC Region If to discuss a potential Waiver of Compliance from the six hour shutdown requirements of TS 3.4.6.1. During the call, the General Manager was notified by plant maintenance that the 1RE-2562 DPM had again been repaired. (a CPU board had been ) replaced), had been declared operable, and the action statement of TS { 3.4.6.1 exited. However, I&C had been unable to positively identify the failure mechanism and although RE-2562 was operating properly, the licensee was reluctant to assume that it would continue to do so. Therefore, discussions continued on the licensee's justification for a Waiver of Compliance. Later i. hat day, the proposed waiver was ) presented to the PRB for approval in the event that the waiver was
, needed. The PRB concurred with the wording of the proposed waiver.
A plan of action was developed to enter containment and repair the south Containmen; Sump Level Transniitter. The repair was completed at 8:45 a.m.. on Aucust 31 and the 30 day action associated with TS ) 3.4.6.1 was exited. During this time no further problems were identified with 1RE-2562. The licensee speculated that since the < 1RF-?562 DPM was located in a high temperature environment, near the i
l O 5 O SG Blowdown Heat-Exchanger piping, the cause of the CPU bcard failure was most probably temperature aging. Licensee discussions with Westinghouse confirmed ' temperature to be the likely cause of the CPU failure. To address tne temperature problem, the licensee has O installed temporary cooling under a temporary modification at the DPM. The licensee plans to move the DPM either to a cooler location or lower the temperature alarm setpoint inside the DPM cacinet to pemit earlier detection of high temperature conditions. This licensee correctise action will be identified for future inspector O review as IFI 424/91-22-01, " Review Corrective Action F0r High Temperature Induced Failure of IPE 2562." On September 13, 1RE-2562 failed again due to an electronics communication failure. Prior to the end of this reporting period two additional failures occurred; a paper drive failure ano utility boarc failure. None of these failures are celieved to have oeen causec by C excessive temperature. A vendor representative will be en site September 30 to review the failure history of 1RE-2562 anc suggest possible corrective actions,
- e. Unit 1 Loss Of Spent Fuel Pool Level O At 3:10 pm on September 19, with Unit 1 in Mode 5 and preparing to enter Mode 6, a HP technician in containment notified the control room of water flowing into C-level of the containment building through the containment spray reactor cavity drains. These drains are normally open, except during refueling operations when a cover is installed, to pemit a flow path from the reactor cavity to the i O containment sump if the containment spray system is actuated.
Operations dispatched a PE0 to containment who discovered that the flow into the reactor cavity was througn the fuel transfer tube gate valve. This valve should have been closed. l At 3:18 pm the Unit 1 Control Room received a Spent Fuel Pool Low O Level annunciator. Normal level in the SFP is 218 feet MSL. The low I level alarm is set at 217 feet. Operations later confirmec locally that the level had decreased to 216 feet 9 inches. At 3:29 pm operators determined that one of two inflatible seals arouno the "SFP to Transfer Canal Gate" was deflated and that the transfer canal
# contained approximately 3-4 feet (11 C00 gallons) of SFP water.
Operators also subsequently tightened down on the fuel transfer tute gate valve (operated .in the SFP) and flow through the valve was i stopped. Unit 1 SFP did not contain any irradiated fuel and the pool was isolated from the Unit 2 SFP. Sinca there was no irradiated fuel in 4 the Unit 1 SFP no TS action statement was entered. Also, the water which leaked from the SFP into the transfer canal and through tne transfer tube gate valvt into the containment samp was relatively 9
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j 6 clean water and as a result there were no personnel contaminations, tt 3: 46 pm operators began using a temporary pump to pumo the water in the transfer canal back into the SFP. At 4:38 pm tne SFP Low " Level Alarm cleared. Based on the original level in the SFP it was calculated that approximately 400 gallons had leaked to the containment sump. The licensee immediately began an investigation into the cause of this event. A criticue team was assigned to determine the root m cause. The cause of the deflated seal on the SFP to Transfer Canal Gate was a mispositioned air supply valve to the gate seal. The valve operating lever was found in an intermediate position between
" inflate" ano deflate" which resulted in the seal slowly deflating.
Everyone who entered the SFP area on the day of the event was interviewed, but no one rememberec bumping or touching the valve
- lever. This particular valve lever is located at floor level and would be easy to bump out of position by anyone working in the area.
The licensee has posted the area around the valve to require etrmission of the USS prior to entry. The licensee is also investigating methods of positively securing this valve to prevent recurrence of this event. 3 The licensee discovered that the leaking transfer canal gate valve, had been opened on September 17 during performance of a LLRT and was apparently not completely reseated following the LLRT. This gate valve, operated in the spent fuel pool room has a 20 foot reach rod and it is difficult to determine when it is fully seated. The J licensee is considering design changes to provied positive valve position determination.
- f. Activation Of Back-Up EOF Drill The inspector observed a backup EOF activation drill. The objectives 3
of the drill were to activate the back-up EOF in Waynesboro, Georgia; relocate the EOF staff; maintain the continuity of EOF functions which include dose assessment, public information, off-site coordination and notification, and security; and demonstrate the adequacy of the backup EOF. Overall, the drill was successful in achieving the objectives. This was the first time this type of drill , had been conducted. 90 minutes. Upon Relocation and activation of the EOF t:ok about arrival, general familiarity with the facility was low, however, the different groups were able to quickly set-up and restore their functions at the backup E0r.
- g. Reactor Coolant System Chemical Cleaning O
As Unit I was cooled dcwn to enter 1R3 the licensee initiated a RCS chemical cleaning evolution to reduce overall RCS activity and to increase RCS water clarity. This was the first time Vogtle had used this process. In the past chemical cleaning was conducted cnly at 9
s 7 ' midloop. The process provided cleaning of the entire RCS and was developed to provide two peaks of maximum activity removal. ' The licensee initiated the evolution with early boration and lithium ) reduction during Hot Standby followed by addition of hydrogen i peroxide later in the RCS cooldown. These additions produced two periods of increased solubility of undesirable corrosion products in the RCS (crud bursts) which could then be effectively removed through ion exchange resins. The licensee removed approximately 2500 curies of activity during the chemical cleaning evolutions. '
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The chemical cleaning process extentied the outage time by approximately 2.5 days, however, the licensee anticipates, that total radiation exposure during the outage will be reduced through this process. Preliminary results indicate that general area dose rates in containment have shown approximately a 25% to 50% reduction.
) aedition to lower exposure, the licensee exoects to reduce the nucer 'n of personnel contamination events due to reduced contamination '
levels. The cleaning process also resulted in increased water clarity eliminating the need for particulate filtration of the - reactor cavity which is normally needed following refueling cavity reflood. ;
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- h. ESF Actuation - Fuel Handling Building Ventilation Isolation l t
On September 25, during daily checks of Unit i radiation monitors, ! fuel building radiation monitor RE-2532B went into high alann and ' actuated the fuel handling building emergency filtration units.
) Following the actuation, the licensee surveyed the fuel handling building areas and detemined that radiation levels were normal. The licensee formed an event critique team to investigate the cause of this ESF actuation. This will be addressed in an LER.
No violations or deviations were identified. ) 3. ESF System Walkdown (71710) l During this inspection period, the inspector conducted a detailed walkdown i of- the accessible portions of the Unit 2 Auxiliary Feedwater System. The purpose of the walkdown was to independently verify the status of the Unit 2 AFW system. The walkdown was accomolished by verifying that the system )~ lineup procedure 11610-2. Aux;11ary Feedwater System Alignment, agreed )I with the system drawings, visually detennining the positions of valves and ! breakers, and inspecting ,for conditions that could degrade performance. The inspector ident1fied several minor equipment and housekeeping ; discrepancies v:hich were discussed with the licensee. These di:crepar.cies '
) included housekeeping in the main steam valve rooms and dif ferences between the lineup valve titles between the procedure and valve tags.
There was nothing observed that could affect the operability of the ) s system. I
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k i 8 y . No violations or deviations were identified. 4 Surveillance Observation (61726) I b a. General Surveillance tests were reviewed by the inspectors to verify procedural and performance adequacy. The completed tests reviewed were examined for necessary test prerequisites, . instructions, ' s / acceptance criteria, technical content, data collection, independent verification were reouired, handling of deficiencies noted, and review of completed work. The tests witnessed, in whole or in part, were inspected to determine that approved procedures were available, equipment . was calibrated, prerequisites were met, tests were conducted according to procedure, test results were acceptable and systems restoration was completed. Listed below are surveillances which were either reviewed or witnessed: Surveillance No. Title ' 1 14804-1 Safety Injection Pump Inservice Test 14806-1 Containment Spray Pump And Check Valves Inservice Test 24936-1 Containment Penetration No. 36 Train B ) RHR Encapsulation Vessel Local Rate Test 54820-1 Train A SI Pump Response Time Test i 54822-1 Train A CS Pump 1-1206P6-001 Response ) Time Test 84201-1 Containment Spray System Leakage l Assessment ' 84207-1 Safety Injection System Leakage ' ) Assessment
. b. Failure To Perform Diesel Fuel Oil Analysis Surveillance .
On September 23, the licensee identified that one of the 15 rcquired i chemical analyses for a diesel fuel oil shipment was not performed, i h TS 4.0.1.1.2.4.2 requires that new fuel must be sampled prior to addition to the storage tank and verified within 30 days of obtaining , the sample that certain properties specified in Table 1 of ASTM-D975-81 are met. In this instance the licensee failed to perform the analysis for weight percent ash content of the fuel. ) i
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The licensee sampled shipment number 10023 on August 13 and received analysis results from an offsite lab by telefax on Sectember 11. The surveillance was approved as satisfactory based on the licensee's I. initial review of the results. On Septemoer 23, the licensee reviewed an original copy of the fuel analysis, which was subsequently mailed to the site, and discovered the analysis for weight percent ash content was not performed. The licensee initiated immediate corrective action to have the offsite lab analyze a portion of the sample for ash content. The analysis was completed on 7 September 24 and v?rified to meet ASTM-0975-81 specifications. This event constitutes a missed TS surveillance. The cause of the missed surveillance was a personnel error due to an inacequate review of test results as required by step 4.1.2.3 of procedure 30080-C, Diesel Fuel Chemistry Control. Contributing to this event was a 3 change in the offsite lab contracted to perform the fuel analysis. This violation is not being cited because criteria specified in Section V.G.1 of the NRC Enforcement Policy were satisfied. Actions taken in response to this event are considered acceptable. The licensee will document their corrective actions in a LER. This.
) non-cited violation is identified as NCY 425/91-22-03: " Failure To Perform TS Required Of esel Fuel Oil Analysis Results In Missed Surveillance."
One non-cited violation was identified.
- 5. Maintenance Observation (62703) 3
- a. General The inspectors observed maintenance activities, interviewed personnel, and reviewed records to verify that work was conducted in
) accordance with approved procedures, TSs, and applicable industry codes and standards, The inspectors also verified that redundant components were operable, administrative controls were followed, clearances were adequate, personnel were qualified, correct replacement parts were used, radiological control were proper, fire protection was adequate, quality control holdpoints were adequate and observed, adequate post-maintensnce testing was performed, ano ).. independent verification requirements were implemented. The inspectors independently verified that selected equipment was properly returned to service Outstanding work requests were reviewed to ensure that the licensee gave priority to scfety-related maintenance activiths. ) .J
I h 1 1 10 ) The inspectors witnessed er reviewed the following maintenance ! activities b } MWO No. Work Descriotien ' 19102243 Containment Spray System Valve 11206U6015 18 Month - Inspection And Rework i 19102246 Auxiliary Feedwater System valve 11302U4118 18 Month { ) Inspection And Rework j 19104308 Replace Contactor 42B in Breakers For 1HV5119, CST-2 AFW Pump A Suction MOV 19104336 Install Single Cell Battery Charger On Cell 11 Of ) Battery 1C01B ,
- b. Low Battery Cell Voltage And Use Of Single Cell Charger
. On August 28, during a weekly surveillance on Unit 1 battery cell i voltage, cell 11 of the 'C' train battery failed to meet it's l
) reouired TS float voltage of 2.13 volts. The actual recorded voltage ! was 2.11 volts which was less than the TS Table 4.8-2 Category A value of 2.13 volts but greater than the Category B salue of 2.10 , volts. By TS criteria, cell 11 was considered to be operable ! provided that all TS Category B measurements were taken and found to ! be within their allowable values, and provided all Category A and B 3 parameters were restored to within acceptable limits within the next 6 days. These reouired measurements were taken and found to be ; within their allowable values. In addition, cell 11 was placed on a
" single-cell" charger for a period of 72 hours. After an_ additional 24 hour period, voltage readings were taken and were in the ,
act.eptable range. Cell 11 was also designated as a " pilot cell" ) which means that its voltage will be checked during each weekly battery surveillance until the cell is replaced during the IR3 refueling outage. The inspector witnessed the installation of the " single-cell" battery charger which was placed in service under MWO 19104336 and reviewed p the licensee's control of " single-cell" chargers as detailed in procedure 27915-C, General Battery Maintenanc8!, step 4.3. The procedure gives numerous " cautions" concerning " single cell" charge ' use. Observations by the inspector verified that these " cautions" , were being followed by maintenance personnel. The inspector had no concerns regarding the use of the " single-cell" battery charger ) duri.g this cvolution. ) F
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- c. RCS Tygon Installed Incorrectly On September 16, contract maintenance personnel incorrectly installed k D the tygon tube used for RCS temporary level indication during 1R3 for '
reduced RCS inventory level measurement. Procedure 54840-1, RCS Draindown Modification: RCS Sightglass, Tygon Tube, and Defeat of - RHR Suction Valve Auto Closure Interlock, was used during the installation. A contract maintenance supervisor, aware of the > correct method to install the tygon tube, failed to ensure that the ; 3- technicians understood the job task and to inspect their work upon ' completion of the task. Due to their misunderstanoing of the job , task, the technicians made unapproved pen and ink changes to : procedure 54840-1 and installed the tygon tube at the wrong valves. The valves the technicians used had been used during a previous ; outage. The technicians mistakenly understood that these same two ! ,9 connection points were to be used again during 1R3. The tygon tube l was incorrectly connected between valve 1-1201-U4-100 at the top of ; the pressuri:er and valve 1-1201-Ut-003 which is a drain valve off the RCS Loop 1 intermediate leg. 4 Following the installation error system engineers verified the ! routirig and elevation markings nf the tygon tube. However.-both O failed to detect the installation error. The incorrect installation was discovered on September 20 by a PE0 while performing a valve i lineup to initiate RCS loop drainage. The tygon tube was in a standby configuration and had not yet been placed in service. These actions by contract maintenance personnel represent a violation of + procedure 54840-1, Section 5.2, which clearly states the connection O points to be used for installing the tygon tube. Additionally, the technicians failed to follow procedure 00052-C, Temporary Changes To Proceoures, when they made changes to a plant procedure without going through the proper approval process. 3 The licensee took prompt corrective action by correctly installing the tygon tube and by informing all appropriate contract maintenance personnel of their responsibilities regarding procedural compliance. The licensee also evaluated outage tasks to determine if they should be performed by licensee personnel or contract perscanel. This-is ane of two examples of a failure to follow procedure by contract personnel. This violation is not being cited because criteria 'specified in Sect 1or V.G.1 of the NRC Enforcement Policy were satisfied. Licensee ; actions taken in response to this event are considered acceptable. t This violation is identified' as NCV 424/91-22-04, Procedural Viclation Leads To Incorrect Installation of RCS Temporary Level D Indication Tygon Tube and Reactor Cavity Ventilation Port Cover. A j previous problem with tygon tube installation occurred on April 7, , 1990 during 1R2 and was discussed in NRC Inspection Report 50-424, ' 425/90-10. )
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- d. IB Diesel Generator Outage Inspection On Septemoer 17. during the IR3 cutage inspection of the 13 DG, the diesel vendor, Cooper Industries, discovered two nozzle ring blades
) were missing from each of the two turbochargers. The missing blades are stationary blades and were apparently destroyed by the rotating ,
portion of the turbo charger which rotates at 15,000 RPM. The inspector discussed this failure with the Cooper Industries representative on site and was informed that failures of this type L have only been discovered during turbocharger inspections and that no engine operating parameters have ever given warning that such a failure had occurred. Cooper Industries has never considered the engine to be inoperable cue to such failures. The licensee has replaced the damaged turbocharger components on the IB DG and will also inspect the 1A DG later in the IR3 schedule.
) Also on September 17, during the 13 OG inspection, several fuel nozzle valves on the fuel injectors were identified as belonging to a potentially defective batch of valves. These defective valves could ,
potentially exhibit a small amount of leakage which would have an effect on fuel consumption and exhaust emissions. The vendor tested each of the suspect valves and none were found to leak. However, the ) licensee has ordered new valves and will replace the existing valves on the 1B DG during this diesel outage. The licensee is tracking ' this item under DC #1-91-228.
- e. Leaking Seal On Reactor Ventilation Port Cover
) At about 8:00 pm on September 23, 1991, while the reactor cavity was :
being filled (water level approximately 4 feet above the reactor ' vessel flange) Control Room operators noted on the reactor cavity sump chart recorder that the cavity sump was alternately filling and pumping down automatically. The leak rate into the sump was detemined to be about 3-4 gpm. The leakage into the reactor cavity ) sump was from a leaking seal on a ventilation port cover which is located on the circumference of the reactor vessel adjacent to the vessel flange. These covers are sealed when the reactor cavity is flooded for refueling. , t The licensee found a bolt missing and several bolts that had not been ) tightened on the ventilation cover. The cover is installed with a gasket, bolts and sealant. The cover was reinstalled and sealed. To perform the repair the reactor cavity had to be drained and the reactor vessel head was reset on the vessel (for shielding). The ' head was reset at 6:00 am on September 24. Head lift was completed ' again at 3:05 am en September 25 and reactor crcity filling was
) commenced, i )
. i t i 13 ); i The cause of this event was a failure to follow procedure. Procedure 93240-C, Reactor Vessel Assembly Disassembly Instructions, step 4.12.2.3, wnich requires proper installation of the cover bolts was b; not followed. The licansee took prompt corrective action by i informing contract maintenance of their responsibilities regarding procedural compliance. This is identified as a second example of NCY 424/91-22-04 , One non-cited violation was identified.
) 6.
Corporate Engineering And Technical Support Visit (40703, 37700, 40500) During this reporting period, the inspectors visited the Southern Nuclear Operating Company offices in Birmingham, Alabama. The primary purpose of this visit was to gain a more detailed working kncwledge of the numerous 3 Vogtle succort activities and to learn more about Mcw the suoport groups are organized, function, and interact. The inspectors held detailed discussions with the Vogtle 'Vice-President, the Vogtle Manager of Licensing, and the Vogtle Manager of Engineering as well as other personnel in the Nuclear Engineering and Licensing group, Nuclear Maintenance and Support group and the Nuclear Administration group. The ) discussions included day-to-day operations as well as several on going projects. The inspectors also met with the Southern Company Services Vogtle Engineering Manager and other SCS personnel that support the Vogtle project. Southern Company and Bechtel are used by SNC for most of the 3 engineering work that supports the Vogtle project. The inspectors toured the SCS facilities and discussed several current projects. Particularly noteworthy was the on-going conversion of Vogtle drawings to a CAD system. This will make drawings revisions more efficient. The inspectors also met with SNC Technical Services personnel. This
) support group provides assistance with licensing, engineering and environmental issues, nuclear fuel, and inspection and testing services.
Two particularly strong areas noted were the nuclear fuels group which provides core analysis and comercial services for fuel procurement, and the inspection and testing group which provides on site expertise in ISI i and IST. The inspectors also learned that Bechtel, and to some degree Westinghouse, have grauos dedicated to Vogtle support. ; The inspectors noted throughout their discussions that virtually every { individual placed emphasis on their role as primarily being a support ' function to the site. SNC provides dedicated support to each of the nuclear power s tations. The SNC Vogtle project office tasks the Vogtle
) dedinted SCS office and the Vogtle dedicated Bechtal organi:ation with specific support assignments. Both the SCS and Bechtel offices consider SNC to be a client for their engineering services. The inspectors noted , )
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that SNC sets priorities and hold:; SCS and Bechtel responsible for meeting - assignments. The inspectors also toured the SCS Power Coordination Center ano discussed operation of the facility. Particular emphasis was placed on Vogtle switchyard configuration and the effects on the electrical grid. The inspectors also while at the SNC offices discussed the functioning of the Vogtle SAER oroup and ISEG with the SAER manager. Both of these groups had been previously reviewed and observed tc be functioning effectively. The inspectors also reviewed Safety Review Board member , i qualifications and reviewed preparation of agenda items for the next SRB meeting. Both the SRB memoer qualifications and the agenda items meet the TS and ANSI requirements. No violations or deviations were identified. ) 7. Mid-loop / Reduced Inventory Activities (GL 88-17) The inspector reviewed the licensee's preparation for midloop/ activities - for the Unit I refueling outage (1R3). The inspector verified that appropriate procedures are in place which address the concerns of Generic Letter 88-17 (Loss of Decay Heat Removal) dated October 17, 1988. During
) 1R3, the licensee, as part of their Shutdown Risk Management, plans to maintain 3 out of 4 onsite and offsite power sources available when fuel is in the vessel. One exception to this strategy occurs during fuel offload when the 'B' RAT will be taken out of service for approximately 12 nours to perform a tap setting change at the same time the 'B' DG is out of service. Both DGs will remain operable until Mode 5 entry. Also, both ) RHR pumps will be available while fuel is in the reactor vessel and although the RCS will be at reduced inventory it will not be drained to midloop while fuel is the vessel. SG eddy current testing is not scheduled until the vessel is defueled.
Procedures are active and in use for the following requirements. , CONTAINMENT CLOSURE CAPABILITY FOR HITIGATION OF RADI0 ACTIVE RELEASES
- Procedure 14210-1, Containment Building Penetration Verification Refueling, Rev. 7, is used to verify containment ouilding penetration status prior to and during the refueling or core citeration or j movement of irradiated fuel within the containment. Procedure ; ) 18019-C Loss of Residual Heat Removal, Rev. 10, step A8, states that when RHR cooling can not be restored in a timely manner, and when RCS level is less than the 191 foot elevation, then initiate containment closure procedure 14210-1. Additionally, procedure 12008-C, Mid-loop Operations, Rev. 2, requires that while operating with the RCS level below 191 feet elevation the containment equipment hatch shall be 3 closed with a minimum of 4 bolts. This limitation ' ray be waived r provided that a method is provided for closing the containment equipment hatch without the use of -lectrically operated equipment )
).
15 for blackout concerns. The containment equipment hatch is capable of being closed with a minimum of 4 bolts within 25 minutes without using electrically operated ecuipment, and the containment equipment
) hatch is continuously manned with a hatch closure crew while operating the RCS level below 191 feet elevation. Maintenance procedure, 27505-C, Opening and Closing Containment Equipment Hatch, Rev. 4, gives direction for the actual closing of the equipment hatch.
RCS TEMPERATURE INDICATIONS - Procedure 12008-C, Mid-Loop Operations, Rev 2 step 4.1.5, requires a minimum of two incore thermocouples in opposite quadrants for use while the reactor head is installed. RCS LEVEL INDICATION - Procedure 12007-C, Refueling Operations, Rev.17, requires that when RCS level is below 15% oressurizer level that temporary RCS level indication must be installed. There are two
)- control room indicetors and a local tygon tube indicator which are used to meet this requirement. A tygon tube is required any time the RCS level is being changed while- the RCS level is below 15%
pressurizer level. With the Control Room temporary RCS level indicators in service, periodic comparison checks are made every 4 hours between the Control Room temporary RCS level indicators and the
). tygon tube. The Control Room indicators should agree within 7 percent of scale with the Tygon tube. If neither Control Room RCS level indicator is available, then a continuous tygon tube watch should be i established while RCS level is below 15% pressurizer level. Similar temporary level indication requirements are stated in Procedure 12006-C, Unit Cooldown to Cold Shutdown, Rev. 19, Section D. ) Procedure 23985-1, RCS Temporary Water Level System, Rev. 2, provides instructions for the installation, channel calibration and removal of the RCS Temporary Water Level System.
g - RCS PERTURBATIONS AVOIDANCE - Procedure 12008-C, Mid-Loop Operations, j Rev. 2, Step 2.1.7, states that with the RCS level below 191 feet elevation all work activities should Le closely scrutinized and any > work activity limited that has the potential for reducing RHR system capability.
- RCS INVENTORY ADDITION - Procedure 18019-C, Less of Residual Heat Removal (Mid-loop LOCA), Rev.10, Attachment A, provides instructions ' '). to operators on how to gravity drain the RWST to the RCS. Procedure 12007-C, Refueling Entry, Rev.15, step 2.2.9, describes two boron injection flow paths, one of which must be available while in Mode 5 or 6. One of these flow paths is from the Boric Acid Storage Tank via a Boric Acid Transfer Pump and a Charging pump to the RCS. The second flowpath is frcm the RWST via a chargir.g pump to the RCS. ( )
1 y 16 N0ZZLE DAMS / LOOP STOP VALVES - Procedure I2008-C, Mid-Loop ! Operations, Rev. 2, addresses the use of nozzle dams. This procedure , states that if SG nozzle dams are to be installed and no cold leg opening is to be established, a vent path is required from the } reactor vessel upper plenum. This vent path can be satisfied by: (a) removing a pressurizer manway, or (b) removing a SG manway on a het leg that will not be dammed, or (c) removing three pressurizer code safeties. If there is or will be a cold leg opening, then the only ' adequate' vent path is to remove a SG hot leg manway on a SG with no , dam installed. ) - REPOWER TO VITAL BUSSES FROM ALTERNATE SOURCE IF PRIMARY SOURCE IS LOST - Procedure 13427-1, 4160V AC IE Electrical Distribution System, i Rev.13, step 4.4.2, provides instructions on powering the 4160V IE Switchgear through the emergency incoming breaker. ! ) No violations or deviations were identified.
- 8. Axial Flux Difference Review On August 23, the licensee implemented a computer software design change to the plant process computer's method for alarming the Delta Flux
) Deviation alarm. The plant process computer provides an automatic means for monitoring AFD by determining the 1-minute average of each of the excore detector outputs and provioes a control room alarm immediately if AFD deviates outside the target band and thermal power is greater than 90%. TS 3.2.1 requires that AFD shall be maintained within the target band pecified in the core operating limits report. ) Between 50% and 90% power the AFD monitoring program generates an alann when indicated AFD is outside the target band for 60 minutes within a 24 hour period. The TS limit for accumulated penalty deviation time in this power range is also 60 minutes. During the previous Unit 2 coastdown, this alarm scheme contributed to a TS required power reduction when 60 ) minutes of penalty minutes occurred without the operator's awareness. The alarm actuated and the unit was simultaneously in the action statement requirements to reduce power. The revised monitoring process allows the control room alarm to actuate after 30 accumulated minutes within a 24 hour period. ). The inspector reviewed computer sof tware change request CR 91-0019 (Unit 1) and verified it was prepared in accordance with procedure 50010-C, Computer Software Change Package Control. The inspector reviewed the , safety evaluation and the functional test requirements and results. The inspector considers this change to be a positive enhancement and will aid contrcl rcem operators in identifying AFD deviati:ns prior to exceeding TS ) limits. ' No violations or deviations were identified. i
q 17 D
- 9. Open Links !ssue Earlier this year, the licensee identified througn severa'. deficiency a'
cards, a trend in the area of open terminal block links. As a result of this trend, an action plan was developed to investigate and detemine the root causes as well as to implement corrective actions. The licensee's Quality Control group performed an inspection /walkdown of safety and non-safety related panels. This included all Control Room panels (except for 4 inaccessible panels), MCCs, swithgear panels, annunciator racks and g auxiliary relay panels. A total of 237 open teminal block links were identified. Included in this number are partially opened links. The results of the walkdown were reviewed by the licensee's corporate engineering staff. Out of the 237 links,106 were found in the wrong position (found open, should have been closed). There were 121 links 3 founc open or partially open and were determined to remain open. The remaining links have not received a review. The 106 links fcuno to be in the wrotig position have been categorized as follows: 5 - Space heater 16 - Equipment operation m 26 - Grounding pro x tion 50 - Annunciator 4 - Data acquisition 5 - Connects to spare The open links in the area of equipment operation and annunciation 3 received further revies. The licensee determined that 10 of the 16 equipment operation open links were of more significance than operator / engineering information. One open link prevented the Unit I containment building nomal purge exhaust isolation valve 1HV-2628A, from closing during a containment isolation actuation. This could be significant in Mode 6 during core alterations or movement of irradiated 9' fuel within the containcent in that TS require the Containment Ventilation Isolation system to be operable. The normal purge exhaust valve is sealed closed in modes 1 througn 4 Three open iinks founo on Unit 2 disable RC circuits around relay contacts in MSIV circuitry. The RC circuits are used to prevent arcing during solenoid circuit interruption. Operation of an MSIV could be affected by having these links open. The 50 open g annunciation links received further licensee review. Six links were detemined to be of more significance. Each of the six links disables the annunciator actuation input for the trip or loss of control power for safety related breakers. There appear to be several reasons for the open links and lack of good g controls over the opening of links. Construction and startup activi+.iet may not have required documenting links. This was described in LER 50-425/89-14 as the cause of a MFP failure during a startup test on Unit
- 2. Lack of clarity, and inconsistencies in clearance and tagging procedures, and procedures governing temporary jumpers and lifted wires may have led to links being left open after the completion of work. As a 0
18 ) result of these procedural problems, the licensee has taken corrective action. Procedure 00304-C, Equipment Clearance and Tagging, was revised to specify how links will be tagged. Procedure 00307-C, Temporary . D' Modifications, jumpers and liftedwas wires. revised to include the requirements for temporary Opening links on terminal blocks are considered lifted wires. Procedure 20429-C, Short Term Documentation of Temporary Jumpers leads or opening and Lifted Wires, was clarified for personnel lifting links. Open links, lifted wires or temporary jumpers on out-of-services systems or equipment are controlled in accordance with procedures 00304-C and 20427-C. J-The licensee has also held briefings with the Maintenance and Operations departments on the issue of open links and the importance of tagging and or handling in accordance with plant procedures. Also, as part of their on-going work monitoring program, the licensee has stated that QC will continue to inspect /walkdown panels. The inspectors consider the D licensee's identification and pursuit of the open link issue as a strength. However, at the close of the inspection period, the safety significance evaluated. of the findings of this issue had not been completely This is identified as Unresolved Item 424,425/91-22-02, Assessment of Safety Significance on Open Links Findings. No violations or deviations identified.
- 10. Review of Licensee Reports (90712) (92700)
The below listed Licensee Event Reports were reviewed to determine if the D information provided met NRC requirements. The c'etemination included: adequacy of description, verification of compliance the TS and regulatory requirements, corrective action taken, existence of potential generic problems, significancereporting requirements satisfied, and the relative safety of each event. ' D a. (Closed) 50-424/90-23, Rev. O, " Transformer Failure Results In loss Of Steam Generator Level And Manual Reactor Trip." Installation of a replacement transfomer for 1NXB10X was completed on December 20, 1990 and emergency diesel generator 1B was restored to operable status. The replacement transformer has a Basic g Lightning-tmpulse Insulation Level rating of 30KV while the transformer which failed had a BIL rating of 25KV. A review was completed en December 21, 1990 which identified additional " critical" non-lE transformers. The licensee decided not to replace these transfomers but to complete certain modifications to improve i p relitbility and that any new transformar subsecuently purchased would have a 30KV Bil insulation rating. A replacement breaker was ; l 9
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19
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installed for following the the INA04 reactor trip.RATThetie breaker which failed to close i breaker which was removed from the INA04 RAT tie breaker cubicle was rebuilt and placed in storage as a 1- spare. The battery breaker for- the inverters which failed during the event was closed after it was found open. A procedure revision was developed for the performance of the battery service discharge test - which includes a sign-off for ensuring the battery breaker is closed af ter test completion. The procedure revision was issued January 30, 1991.
) b. (Closed) 50-425/91-05, Rev. O, " Main feedpumps Slowdown Leads To Reactor Trip."
1 The circuit board with the faulty component was replaced and proteoures 24204-1 and 24204-2, Feeowater Pump Speed Control l
) 1(2)P-509 Channel Calibration, were revised t: provide for periodic check of the signal memory function modules :: ensure that they will store information. Procedures 17015-1 & 2,.' Annunciator Response Procedures For ALB On Panel 181 (2B1) On MCB," were changed to direct t the operators to take manual control and bypass the normal speed controller when the control signal is lost. These manual actions ' ) were discussed during the nomal shift briefings following the event.
Additionally, licensed operator training was reviewed to ensure that the details for performing this task are included in the train *ing modules.
- 11. Followup (92701)(92702) h a. NRC Information Notice No. 88-48, Supplement 2: " Licensee Report Of Defective Refurbished Valve".
3 In September 1986, CMA International Incorporated supplied two counterfeit " Pacific" check valves to Midwest Valve and Supply, ; Detroit, Michigan. Midwest supplied the two ' Pacific" valves to Jay ; Instrument and Specialty Company, Norcross, Georgia, which then ! ! supplied the valves to VEGP. Vogtle later installed one valve in
- each unit on the condensate and feedwater system, a non-safety l related system. The two valves,1-1305-U4-654 and 2-1305-U4-654, i were installed in identical locations on bott unitu; in a normally
}- isolated line used only during plant shutdown for the purpose of ' condensate cleanup. Once the counterfeit valves were identified by ' VEGP they were subsequently replaced. The Unit i valve was replaced 1 on March 27, 1990 and the Unit 2 valve was replaced on October 8, ! 1989. i
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i 20 b t
- b. NRC Information Notice No. 90-77, " Inadvertent Removal of Fuel Assemolies From The Reactor Core". .
Prior to IR3 the inspectors reviewed the licensee's actions taken
)' associated with to NRC Information Notice No. 90-77 Several examples were cited in that IN of instances at other utilities where fuel assemblies had been inadvertently removed from the core during the lifting of the upper core support structure. Most recently an event of this kind occurred on October 4, 1990, at Indian Point Nuclear Generating Unit 3 when two peripheral fuel assemblies had ?
become 5ttached to the upper core plate due to bent fuel assembly guide pins. The inspectors reviewed procedure 93240-C, Reactor - Vessel Assembly / Disassembly Instructions Rev.12 to determine what procedural changes the licensee had made to preclude such an event occurring at Vogtle. The following is a summary of those procedural changes.
)
r Procedure 93240-C directs that no movement of the upper internals shall be attempted without continuous voice communication between the crane operator and the signalman directing the lift. A procedure
" Caution" has been added which requires a visual monitoring of the tops of all control rod drive shafts prior to commencement of ) ' lifting. All shafts should be level. A shaft setting lower would be an indication that the shaft is still connected to a red control cluster. The procedure directs the operator to monitor the lift load cell readout for any sudden + 5 percent change in (te load readout which would indicate binding or interference. One or more underwater video cameras should be positioned such that when the ,
) upper core plate breaks the plane of the reactor vessel flange a thorough inspection of the upper core plate may be conducted tc ensure no fuel assemblies have been inadvertently withdrawn with the upper internals assembly. Also, additional underwater lighting should be installed opposite the camera to allow for adequate siewing across the full diameter of the upper core plate. The procedure ) further directs that no lateral movement of the upper internals , package will be made until clearance of the fuel assemoly guide pins has been visually verified. At the earliest time in the refueling schedule camera inspection will be performed on the upper core plate guide pins. The inspector determined that the licensee had adequately addressed the concerns as stated in IN 90-77. On September 26, 1991, the upper intenvals were lifted from the Unit I reactor vessel. No abnormalities were observed during the lifting - evolution.
- c. (Closed) Violation 50-424/89-33-01 and 50-425/89-38-01, " Failure To implement Precedures 00101-C and 50009-C Ccncerning Legibility of Control Room Drawines and Violation 50-424,425/90-30-01, Violation of 10 CFR 50 %ppendix B, Criterion 16, Corrective Action - Failure To Fully Implement Corrective Actions on Control Room Drawings".
? 21 F Both of these violations involved the quality of control room drawings. Violation 424,425/90-30-01 resulted from the licensee's failure to adequately implement the corrective action from the violation cited in 1989. The inspectors reviewed the licensee's
)
letters of response dated January 23, 1990 and February 14, 1991. Corrective actions in the January 23, 1990 letter included replacement of all Control Room drawings with drawings reviewed for legibility, ensuring the preparation of legible ABNs, ensuring accountability for posting Control Room and Clearance and Tagging
) drawing and revisions, monthly audits of Control Room and C&T drawings procurement of improved reproduction equipment. All of the corrective action was completed by June 1, 1990 except for the monthly audits of Control Room and C&T drawings, and the method of posting Control Room drawings. The monthly audits were discontinued in May 1990 and the licensee f aitiated a process of sending drawings )
from the architect-engineer directly to the Control Room. This drawing distribution process was in conflict with procedure 00101-C, Drawing Control, and circumvented the normal methods of maintaining drawings, the posting of ABNs and drawing revisions. As a result of the failure to fully implement the corrective action comitted to in January 1990, more Control Room drawings deficiencies )' were identified in December 1990. These deficiencies consisted of incorrect drawing revisions and missing open ABNs. The inspectors cited the licensee with a second violation when it was determined the initial corrective action had not been fully completed. The licensee's letter of response dated February 14, 1991 documented ) corrective action which included a complete audit of Operations department drawings and correction of all discrepancies, resumption of responsibility by Document Control of Control Room drawing distribution, and resumption of monthly reviews on Control Room drawings. The inspector verified that the corrective action was complete. The inspector also noted from the results of the monthly ) Control Room drawing audits that the number of discrepancies had dropped significantly. This item is closed.
- 12. Exit Meeting The inspection scope and findings were summarized on September 27, 1991 with those persons indicated in paragraph 1. The inspector described the areas inspected and discussed in detail the inspection findings listed below. No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection.
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Item Number Descriotion And Reference IFI 424/91-22-01 Review Corrective Action For High Temperature ;
) Induced Failure Of 1RE-2562 .
URI 424,425/91-22-02 Assessment Of Safety Significance On Open Links Findings , NCY 425/91-22-03 Failure To Perform TS Required Diesel Fuel Oil Analysis Results In Missed Surveillance NCV 424/91-22-04 Procedural Violation Leads To Incorrect Installation Of RCS Temporary Level Indication i Tygon Tube & Reactor Cavity Ventilation Port Cover
) 13. Abbreviations ABN As Built Notice , AFD Axial Flux Difference AFW Auxiliary Feedwater System ALB Annunciator Light Board ) ANSI American National Standard Institute BIL Basic Lightning-Impulse Insulation Level C&T :
Clearance and Tagging CAO Computer Aided Drawing CDT Central Daylight Time 1
?
CFR Code of Federal Regulations
) CPU Central Processing DG Diesel Generator DPM Data Processing Module EOF Emergency Operations Facility ESF Engineering Safety Features GPC Georgia Power Company HP Health Physics I&C Instrumentation and Control IFI Inspector Followup Item IN Information Notice ISEG Independent Safety Engineering Group LCO Limiting Conditions for Operations LER Licensee Event Reports LLRT Local Leak Rate Test '
MCB Main Control Board MCC Motor Control Center MOV Motor Operated Valve
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MSIV Main Steam Isolation Valve < MSL Mean Sea Level i NCY Non-Cited Violation NPF Nuclear Power Facility 10~. i NRC Nuclear Regulatory Comission ' PA Protected Area PE0 Plant Equipment Operator } PRB Plant Review Board i RC Resistor - Capacitor ! RCS Reactor Coolant System
'O. RAT Reserve Auxiliary Transformer j
Rev Revision RHR Residual Heat Removal Tank i RWST Refueling Water Storage Tank , SAER Safety Audit.and Engineering Review
- SCS Southern Company Services
'O SFP Spent Fuel Pool , SG Steam Generator l SI Safety Injection System ' SNC Southern Nuclear Operating Company ; SRB Safety Review Board ! TS Technical Specification : O URI Unresolved Item VEGP Vogtle Electric Generating Plant O r t t IO ! l 0 : i )O r
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M' / *%,
^ UNITED STATES
[ 7. p, j NUCLEAR REGULATORY COMMISSION WASHINGTON. O, C. 20655 ((J.07 November 22, 1991 k ..... / Docket Nos. 50-348 and 50-364 Mb Mr. W. G. Hairston, III % N g Senior Vice President Alabama Power Comoany h @.[ 40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 ,
Dear Mr. Nairston:
O' S!:8dECT: ISSUANCE OF AMENDMENT N0. 90 TO FACILITY OPERATING LICENSE NC. NPF-2 AND AMENDMENT NO. 83 TO FACILITY OPERATING LICENSE NO. NPF-8 REGARDING ADDING SOUTHERN NUCLEAR OPERATING COMPANY INC., AS A LICENSEE - JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, (TAC NOS. 80371 AND 80372) O The Nuclear Regulatory Commission has issued the enclosed Amendment No. 90 to Facility Operating License No. NPF-2 and Amendment No. 83 te Facility Operating License No. NPF-8 for the Joseph M. Farley Nuclear Plant, Units 1 and 2. The amendments change the Facility Operating Licenses, Technical Specifications and the Environmental Protection Plans in response to your submittal dated May 6,1991, as supplementec June 18. June 20, September 27, 3 Cctober 14, and October 22, 1991. - The amendments change the Facility Operating Licenses Technical Specifications and the Environmental Protection Plans to add Souchern Nuclear Operating Company, Inc., as a Ifcensee with the responsibility to act as the licensed operator of the facility. A copy of the related Safety Evaluation is enclosed. A Notice of Issuance will be included in the Commission's bi-weekly Federal Register notice. Sincerely, 3 g .z . y= Stephen T. Hoffman, Project Nanager Project Directorate 11-1 Division of Reactor Projects - I/II J Office of Nuclear Reactor Regulation
Enclosures:
g
- 1. Amendment No. 90 to NPF-2
- 2. Amendrent No. 83 to NPF-8
- 3. Safety Evaluation 9
cc w/ enclosures: See next page O
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/ %, UNITED STATES ~! o NUCLEAR REGULATORY COMMISSION g !- wAsmwoTow, o. c. zones O
g***** SAFETY EVALUATION BY THE OFFTCE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0. 90 TO FACILITY OPERATING LTCENSE NO..NPF-2 , AND AMENDMEMT NO. 83 TO FACILITY OPERATING LICENSE N0. NPF-8 . ALABAMA POWER COMPANY - i JOSEPH M. FARLEY NUCLEAR PLANT. UNITS 1 AND 2 ; DOCKET NOS. 50-348 AND 50-364 0
1.0 INTRODUCTION
By letter dated May 6, 1991, as supplemented by letters dated June 18. June 20, iO September 27, October 14, and October 22, 1991, Alabama Power Company proposed amendments to Facility Operating License Nos. NPF-2 and NPF-8 for the Joseph H. l Farley Nuclear Plant, Units 1 and 2 (FNP). The amendments would add Southern i ! Nuclear Operating Company, Inc. (Southern Nuclear), as a licensee to the i Facility Operating Licenses with the exclusive responsibility to act as the , , licensed operator of FNP. Southern Nuclear would manage, use, operate and
- O -- maintain FNP, but would have no entitlement to power output from FNP and no authority to dispatch, broker, or market the energy generated. Alabama Power Company would continue to be the owner of FNP and would retain the authority to
dispatch, broker or market the electricity generated by FNPs ' . The Notice of Consideration of issuance of Amendment and Proposed No Significant jo Hazards Consideration Determination and Opportunity for Hearing in connection l with this action was published in the Federal Register on September 19,1991 (56 FR 47500). No request for hearing or petition for leave to intervene was filed following this notice. This proposed finding, based on the staff's i review of the May 6, 1991, application, is not changed by Alabama Power Company's supplemental submittals dated June 18, June 20, September 27, October 14 and . ! October 22,1991. The supplemental submittals pertained to (1) FNP compliance lO with 10 CFR 73.56 regulations concerning unrestricted access authorization; ' l (2) the naming of Joseph H. Farley as Chairman of the Board and Chief Executive ; l Officer, and R. P. Mcdonald as President of Southern Nuclear; (3) a request - l- that the amended license conditions be made effective within 90 days of the i date of issuance and upon the official assumption of responsibilities by i Southern Nuclear; (4) clarifying substitutions of " Southern Nuclear" for "the . .O licensee" in the proposed amended licenses; and (5) deletion of unnecessary , l information requested in the proposed amended licenses. ' , 2.0 DISCUS $ ION Alabama Power Company and Southern Nuclear are wholly owned subsidiaries of The
- O Southern Company. Southern Nuclear was formed in December 19C0 to consolidate i The Southern Company personnel engaged in nuclear operations into a single i
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integrated organization and is currently under contract with Alabama Power i Company to provide offsite technical support for FNP. These support services f- ' include admir.istrative, technical, and nuclear operations support. Under the proposed amendment, the present onsite organization responsible for the physical operation of FNP would be transferred intact to Southern Nuclear. These employees of Alabama Power Company would become employees of Southern Nuclear. Gains in operating efficiency are anticipated from the consolidation of onsite y and offsite personnel engagen in nuclear operations in the Southern Nuclear organization. 3.0 EVALUATION The Nuclear Regulatory Ccmmission (NRC) staff's review of Alabama Power Company's s proposed amendments included the following areas: management and technical / qualifications, financial and antitrust considerations, plant security and handitr.g of restricted data, offsite power availability, emergency planning, 4 i-quality assurance and personnel training, and environmental protection. The effect of the proposed amendments on each of these areas is evaluated below. Panagement and Technical Qualifications i The proposed amendments will cause no change in the onsite personnel operating ' FNP, nor in the offsite Southern Nuclear personnel now providing support services. The ensite Alabama Power Company employees would become employees < of Southern Nuclear. Alabama Power Company stated that although some position titles may change to reflect Southern Nuclear as the operator, there would be
)
no change in respensibilities. Southern Nuclear is ccas11tted to maintaining
' the level of technical qualifications by employing or contracting, as necessary, the technically qualified personnel needed to operate FNP.
I !- The supplemental letter of June 20, 1991, reported some organizational changes.
- i. On May 21, 1991, the Board of Directors of Southern Nuclear named Joseph M.
)' Farity, the President and Chief Executive Officer of Southern Nuclear, as Chairman of the Board and Chief Executive Officer of Southern Nuclear. The Board of Directors of Southern Nuclear further acted by naming R. P. Mcdonald, the Executive Vice President of Southern Nuclear, as President of Southern Nuclear. Mr. Mcdonald will continue to serve as Executive Vice President of Alabama Power Company and Executive Vice President of Georgia Power Company.
The position of Executive Vice President within Southern Nuclear no longer appears as a result of this organizational structure modification. The 4 personnel who previously reported to the Executive Vice President of Southern Nuclear now report to the President. No other management changes were made and all other reporting lines remain the same. j These organizational changes would have no adverse effect on the management of ! FNP; therefore, we find them acceptable. l On the basis of the above considerations, the NRC staff concludes that the proposed amendments would not result in significant changes to management or the technical qualifications of FNF onsite or offsite persont21. In these
) areas, therefore, the proposed amendments are acceptable. 1 I
i- ) 5
). . 3- Financial Considerations - Cost recovery for the operation of FNP will remain the same as before the license amendments. Alabama Power Company will continue to have entitlement to all electrical output from FNP. Alabama Power Company is regulated by the Alabama Public Service Cosaission and the Federal Energy Regulatory
) Commission. Rate regulation will continue as before the license amendments.
Alabama Power Company and Southern huclear will establish responsibility for plant costs. Southern Nuclear will be reimbursed for costs of direct operation of FNP by Alabama Power Company. Other expenses of Southern Nuclear which are not direct charges to FNP will be allocated to Alabama Power Company and ' others for whom the expenses are incurred. With Southern Nuclear as the licensed operator, Alabama Power Company will . commit to provide all funds necessary for expenses accrued by Southern Nuclear ! for the safe operation, construction, maintenance, repair, decontamination, and decomissioning of FNP. Because the owner and the sources of funds will remain , unchanged, cost recovery of operating, maintenance or decommissioning costs
) will remain the same as at present with Alabama Power Company as the operator.
The NRC staff believes that there will be no safety consequences from the proposed arrangements for funding of operating, maintenance, and decomissioning ' costs of FNP. Thus, the staff concludes that the financial arrangements of the proposed action will not adversely affect protection of the public health and
) safety. j Antitrust Considerations Several potential antitrust concerns were raised by the staff in response to !
[J Alabama Power Company's proposal to change the FNP operator from Alabama Power Company to Southern Nuclear. These concerns were resolved when Alebama Power Company and Southern Nuclear agreed to the addition of the following license condition to paragraph 2.F of the FNP licenses: j Southern Nuclear shall not market or broker power or energy from i Joseph 11. Farley Nuclear Plant, Units 1 and 2. Alabama Power ') Company shall continue to be responsible for compliance with the obligations imposed on it by the antitrust conditions contained in this paragraph 2.F. of the license. Alabama Power Company shall be responsible and accountable for the actions of its agent, , Southern Nuclear, to the extent said agent's actions may, in any way, contravene the antitrust conditions of this paragraph 2.F.
) This license condition is additive in that Alabama Power Company will continue ;
to be subject to the existing antitrust license conditions. Moreover, Alabama Power Company will now be responsible and accountable for tnc actions of Southern Nuclear relative to the antitrust license conditions. The NRC staff believes the addition of this license condition to the FNP licenses will effectively preclude Scuthern Nuclear from adversely impacting the competitive
) process in the relsent bulk power services market served by FNP.
i l J I i
l' O ( l By letter dated October 15, 1991, the Alabama Municipal Electric Authority 3 (AMEA), through its counsel, Goldberg, Fieldman and Letham, P.C., responded to the staff's 01 weekly Notice Applications and Amendments to Operating Licenses involving No S Qnificant Hazards Considerations which was published in the } Federal Register on September 19, 1991 (56 FR 47500). In its letter, AMEA expressed suppirt for the inclusion of the above antitrust license condition ! in the FNP operating licenses. ' Plant Security and Restricted Data The letter of June 18, 1991, provided infomation concerning unrestricted [ access authorization to the FNP site when the existing plant personnel cease being employees of Alabama Power Company and become employees of Southern 3 Nuclear. Alabama Power Company indicated that, in accordance with 10 CFR ' Part 73.56, existing plant personnel whose unescorten access authorization for FNP has been uninterred for at least 180 days prior to April 25, 1991, will ! continue to have suct uthorization without further evaluation. The NRC staff agrees that this meets the requirements of 10 CFR 73.56. There would be no other changes in regulations or practices related to plant security and the O handling of restricted data, since Southern Nuclear will accept responsibility for the implementation of the present programs in these areas and the same
- personnel would be involved. '
{ Offsite Pcwer l O The amendment application involves no change in the ownership or design of the i offsite power system for FNP, or in its operation, maintenance or testing. Alabama Power Company will continue to fulfill its current responsibilities l
- with respect to compliance with General Design Criterion (GDC) 17. Agreeeeents ,
between Southern Nuclear and Alabama Power company will specify arrangements ! I for controlling operation, maintenance, repair, and other activities with , respect to the transmission lines and the switchyard, so adequate independent 70 sources of offsite power will continue to be provided. i l The NRC staff concludes that the proposed license amendments will have no l l adverse effect with regard to meeting the requirements of GDC 17. '
-Emergency Planning 3 ,
Upon approval of the proposed license amendments, Southern Nuclear will become responsible and have the authority for all functions ntressar ; ! emergency planning requirements specified in 10 CFR 50.47(b) andyPart to fulfill 50, the . Appendix E. P1ar.s and service agreements will be established to ensure that ! all support described in the existing emergency plan will be maintained. - 'O Control over existing agreements for support from offsite organizations and j agencies would be assigned or delegated by Alabama Power Company to Southern i Nuclear prior to transfer of responsibility. - A significant amount of offsite emergency planning support will continue to be provided by Alabama Power Company. The required support will be assured by g service agreements between Southern Nuclear and Alabama PcNer Company. The NRC staff concludes that these provisions for meeting the emergency ; 1 planning requirements are acceptable. ; h
i 0 5 Cuality Assurance and Training O Upon approval of the proposed emendments, Scuthern Nuclear will become
)
responsible for the FNP quality assurance program and the existing personnel training programs. The function and structure of the quality assurance program will not be affected by the proposed amendments; and it will continue , to meet the requirestnts of 10 CFR Part 50, Appendix B. The training programs will continue to meet the operator requalification program requirements of O 10 CFR 50.54 and related sections, and to meet the requirements for maintenance of the Institute of Nuclear Power Operations L:creditation for licensed and non-licensed training. The NRC staff concludes that approval of the proposed amendments will not ; adversely affect the FNF quality assurance and training programs. D Environmental Protection Plan The proposed amendments provide for changes in organizational responsibility for some aspects of the Environmental Protection Plan (EPP) Appendix 3, to Operating License Nos. NPF-2 and NPF-8. The proposed amendments do not amend the obligations and responsibility for compilance with the elements of the approved EPP. Therefore, the staff concludes that the proposed changes are acceptable. !
3.0 STATE CONSULTATION
3 In accordance with the Comission's regulations, the State of Alabama official was notified of the prcposed issuance of the amendment. The State official had no coments.
\
4.0 ENVIR0nitENTAL CONSIDERATION ' 3 Pursuant to 10 CFR 51.21, 51.32, and 51.35, an Environmental Assessment and finding of No Significant Impact has been prepared and published in the Federal Register on November 15,1991(56FR58096). Accordingly, based upon the Environmental Assessment, the Comission has determined that the issuance of this amendment will not have a significant effect on the quality of the heman environment. 3
5.0 CONCLUSION
l The Comission has concluded, based on the considerations discussed above, ' that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such
) activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of the amendment wil? tot be inimical to the common defense and security or to the health and safety of the public. l Principal Contributors: S. S. Kirslis S. T. Hoffman D. A. Nash ) H. A. Blamonte !
Date: November 22, 1991
l e a w g g g..-. m ~ y,9 t'.%*.'Mirao#"'
, I s 4. o. w Southern Nuclear Operatirg Company N'$ May 26, 1992 IN acufMrn etctre sysem i t
Docket Nos. 50-348' 50-364 -
) ,
U.e 5. Nuclear Regulatory' Commistion ATTN: Document Control Desk Washington, DC 20,555 , Joseph M. Farley Nuclear Plant , O Channes in Manaaement Parsonnel , Gentlemen: . Ths purpose of this letter is to notify.the Nuclear Regulatory Comission of the following changes in Southern Nuclear Operating Company management O . personnel. . . Mr. R. P. Mcdonald, President of Southern Nuclear, has been elected to'the additional position of Chief Executive Officer, replacing Mr. J. M. Far16y who will continue to serve as Chairman of Southern Nuclear's Board of Directors. Mr. W. G. Hairston,111, formerly senior Vice President - Nuclear !' Operations, has been' elected Executive Vice President of southern Nuclear. -
~
! Mr. D. N. Moray, !!!, formerly General Manager of Farley Nuclear Plant, has assumed the position of General Manager of Huclear Support - Farley Project ! !g at the corporate office in Birmingham, Alabama, Mr. R. D. Hill, Jr., formerly Assistant General Manager of Plant Support,
.has assumed the' position of General Manager of Farley Nuclear Plant.
l
. Respectfully submitted, ,
I h Woodard l '
. J0W/EF8: map wp C cc: Mr. S. D. Ebneter i .. Nr.- S. T. Hoffman ,
Mr. G. F. Maxwell l l ~ s l l . i 9 i l vs eane su --_ w e, n '
SOUTHERN NUCLEAR OPERATING COMPANY, INC.
) BOARD OF DIRECTORS MEETING MAY 11,1992 MINUTES
) A meeting of the Board of Directors of Southern Nuclear Operating Company, Inc., was held in Atlanta, Georgin on May 11,1992. E. L Addison, A. W. Dahlberg, E. B. Harris, H. A. Franklin, J. M. Farley, R. P. Mcdonald and J. O. Meier attended. Mr. Farley served as Chairman and Mr. ) Meier served as Secretary. PJ. DeNicola and Tommy Chisholm also attended. The Chairman stated that it was necessary to approve the Minutes of the March 2,1992 meeting of the Board. Upon a motion duly made and seconded, the following resolution was adopted by unanimous vote: RESOLVED, that the Minutes of the me: ting of the Board of Directors of Southern Nuclear Operating Company, which was held in Birmingham, t Alabama on March 2,1992, are hereby approved and adopted. b The Chairman stated that it was necessary to approve the Minutes of the March 2,1992 meeting of the Audit Committee. Upon a motion duly made and seconded, the following resolution was adopted by unanimous vote: RESOLVED, that the Minutes of the meeting of the Audit Committee of : ) the Board of Directors of Southern Nuclear Operating Company, which l was held in Birmingham, Alabama on March 2,1992, are hereby approved and adopted. The Chairman noted that this is the first Board meeting following the annual 3 shareholder's meeting, and he stated that it was appropriate to hold an election of officers and to make certain changes in the, By-Laws of the Company in connection with the election of officers. Upon a motion duly made and seconded, the following resolutions were adopted by unanimous vote in executive session: ) RESOLVED, that the revisions to Article V, Section 2. of the By-Laws of the Company, Duties of the Chairman of the Board, which were adopted I I by resolution of the Board on May 21,1991 are hereby rescinded; RESOLVED FURTHER, that the revisions to Article V, Section 3. of the I ) By-Laws of the Company, Duties id the President, which were adopted by l resolution of the Board on May 21,1991 are hereby rescinded; i
N RESOLVED FURTHER, that J.M. Farley is hereby elected to serve as Chairman of the Board; and RESOLVED FURTHER, that the following persons are elected as officers of the Company in the positions set forth beside their respective names:
) NAME POSITION IL P. Mcdonald President and Chief Executive Officer W. G. Hairston, III Executive Vice President J. W. Averett Vice President D L B. Long Vice President J. D. Woodard Vice President J. T. Beckham Vice President C. K. McCoy Vice President J. O. Meier Vice President and Secretary 3 R. M. Gilbert, Jr. Comptroller and Treasurer W. E. Boston Assistant Secretary and Assistant Treasurer F. D. Kuester Assist mt Secretary and Assistant Treasurer , The Chairman stated that it was r.ecessary to appoint members of the Executive " Committee to serve until the next annual stockholder's meeting. Upon a motion duly made and seconded, the following resolutions were adopted by unanimous vote:
RESOLVED, that H.A. Franklin, A.W. Dahlberg and E.B. Harris are
- hereby appointed to serve as the Executive Committee of the Board for a J term of one year, or until their respective successors are appointed, with H.A. Franklin serving as Chairman of said Executive Committee; RESOLVED FURTHER, that, subject to the limitations set forth in the Company's By-Laws and at law, the Executive Committee shall have and O may exercise all of the powers and authority of the full Board of Directors in the management of the business and affairs of the Company and may authorize the seal of the Company to be affixed to all papers requiring it; RESOLVED FURTHER, that meetings of the Executive Committee may J be called at any time by the Chairman, President, any member of the Executive Committee, or by the Secretary of the Company at the request of any of them. Notice of any called meeting of the Executive Committee shall be given to each member at least one hour in advance of the meetinF.
and may be given by delivered letter, or by mail, or by telegram, or by
# facsimile, or by personal communication, either over the telephone or otherwise.
2 0
u jF p*
- s c ,*), UNITED STATES O '- 1 NUCLE AR REGULATORY COMMISSION 5'1 i e
W ASmNGTON. D. C. 20555
- k lu /
October 9, 1992 t,*v ...* 3 Docket Nos. 50-321, 50-366, and 50-424, 50-425 p I~ LICENSEES: Georgia Power Company, et al . FACILITIES: Edwin 1. Hatch Nuclear Plant, Units 1 and 2 Vogtle Electric Generator Plant, Units 1 and 2
SUBJECT:
SUMMARY
OF SEPTEMBER 28, 1992, MEETING REGARDING LICENSE J AMENDMENT APPLICATIONS FOR HATCH AND V0GTLE PLANTS On September 28, 1992, the NRC staff met in Rockville, Maryland, with Georgia Power Company to discuss the license amendment applications related to NRC approval for Southern Nuclear Operating Company, Inc., to become the operator (D for Hatch and Vogtle plants. The transcribed record of the meeting, including a list of attendees and the { viewgraphs used during the presentation, are provided in the enclosure. l 1 fh N. $$L W Kahtan N. Jabbour, Project Manager Project Directorate 11-3 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
]
Enclosure:
As stated cc w/ enclosure: 3 See next page 3 9 l l O
O' Edwin I. Hatch Nuclear Plant Georgia Power Company Vogtle Electric Generating Plant' 3; cc: Mr. Ernest L. Blake, Jr. Mr. R. P. Mcdonald Shaw, Pittman, Potts and Trowbridge Executive Vice President - 2300 N Street, NW. Nuclear Operatiens - Washington, DC 20037 Georgia Power Company 9 P. O. Box 1295 Mr. J. T. Beckham Birmingham, Alabama 35201 - Vice President - Plant Hatch Georgia Power Company Mr. Alan R. Herdt, Chief : P. O. Box 1295 Project Branch #3 Birmingham, Alabama 35201 U. S. Nuclear Regulatory Commission - 3 101 Marietta Street, NW, Suite 2900 Mr. S. J. Bethay Atlanta, Georgia 30323 Manager Licensing - Hatch Georgia Power Company Mr. Dan Smith - P. O. Box 1295 Power Supply Operations , Birmirgham, Alabama 35201 Oglethorpe Power Corporation g- 2100 East Exchange Place Mr. L. Sumner Turker, Georgia 30085-1349 General Manager, Nuclear Plant : Georgia Power Company Charles A. Patrizia. Esquire Route 1, Box 439 Paul, Hastings Janofsky & Walker r Baxley, Georgia 31513 12th Floor g 1050 Connecticut Avenue, NW. Resident inspector Washington, DC 20036 U. S. Nuclear Regulatory Commission Route 1, Box 725 ' Baxley, Georgia 31513 Regional Administrator, Region II U. S. Nuclear Regulatory Comission 101 Marietta Street, NW. Suite 2900 Atlanta, Georgia 30323 Mr. Charles H. Badger Office of Planning and Budget Room 610 270 Washington Street, SW. i Atlanta, Georgia 30334 i Harold Reheis, Director ! 3' Department of Natural Resources l 205 Butler Street, SE., Suite 1252 Atlanta, Georgia 30334 l
\
Chairman ' Appling County Commissioners 3 County Courthouse Baxley, Georgia 31513 D-
. . - . .. .. _. . .~ _
O Edwin I. Hatch Nuclear Plant Georgia Power Company Vogtle Generating Plant P CC: Mr., J. A. Bailey Office of the County Ccmmissioner Manager - Licensing Burke County Commission Georgia Power Company Waynesboro, Georgia 30830 3 P. O. Box 1295 Birmingham, Alabama 35201 Resident Inspector U. S. Nuclear Regulatory Commission Mr. W. B, Shipman P. O. Box 572 General Manager, Vogtle Electric Waynesboro, Georgia 30830 Generating Plant ' D P. O. Box 1600 Waynesboro, Georgii. 30830 Office of Planning and budget Room 6158 270 Washington Street, SW. O Atlanta, Georgia 30334 Mr. C. K. McCoy Vice President - Nuclear Vogtle Project Georgia Power Company - 3 P. O. Box 1295 Birmingham, Alabama 35201 Attorney General Law Department 132 Judicial Building g Atlanta, Georgi 3 30334 Art Domby, Esquire Troutman, Sanders 600 Peachtree Street Nations Bank Plaza : 3 Suite 5200 Atlanta, Georgia 30308-2210 Mr. W. G. Hairston, III !' Senior Vice President - Nuclear Operations ! Georgia Power Company 3 P. O. Box 1295 t Birmingham, Alabama 35201 D i l D i
OFFICIALTRANSCRIPT OF PROCEEDINGS
)' )
Agency: u.s. nuctear negutatory commission
Title:
ceorgia power company to unc staff
)
Docket No. , LOCATION: Rockville, Maryland Monday, September 28, 1992 , 1 - 46
)
T
) .
ANN RILEY & ASSOCIATES, LTD. I 1612 K St. N.W Suite 300 Mshington, D C 20006 , (202) 293-3950 l ?
REPORTER'S CERTIFICATE h /1 This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission I In the Matter of: ,
).
NAME OF PROCEEDING: Georgia Power Company DOCKET NUMBER:
) ,
PLACE OF PROCEEDING: Rockville, Maryland were held as herein appears, and that this is the 7 original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and thereafter reduced to typewriting by me or under the direction of the courti reporting company, and that the ; transcript is a true and accurate record of the , .) foregoing proceedings.
?? vf 0C h /
Official Reporter Ann Riley & Associates, Ltd.
) - ) ! i D
1 1 UNITED STATES OF AMERICA D 2 NUCLEAR REGULATORY COMMISSION 3 *** 4 Presentation by D 5 GEORGIA POWER COMPANY 6 To 7 NRC STAFF 8 *** D 9 Room 4-3-11 10 NRC Headquarters D 11 11555 Rockville Pike 12 Rockville, MaI7 land 13 Monday, September 28, 1992 D 14 The above-entitled proceedings commenced at 1:00 15 p.m., Kahtan N. Jabbour, NRC/NRR/PD2-3, presiding. 16 D 17 18 19 O 20 21 22 9 23 24 25 e ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street,N.W., Suite 300 Washington,D. C. 20006 (202)293-3950
O 2 , 1 PROCEEDINGS 7 g 2 MR. JABBOUR: Good afternoon. My name is Kahtan 3 Jabbour. I'm the Project Manager for Plant Hatch. 4 The purpose of this meeting today is for a O 5 presentation by Georgia Power Company regarding license l 6 amendment applications related to incorporating Southern 7 Nuclear Operating Company as a licensed operator for Hatch O 8 and vogtle plants. 9 This meeting will be transcribed. The transcript 10 of the meeting will be available in the Public Document Room a 11 as soon as we can make them after the meeting. 12 For the purpose of the recorder here, we would 13 appreciate your introducing yourself before you speak. g 14 A:.so, we would appreciate a clear introduction of yourselves 15 as we go around the room and introduce ourselves. 16 At this time I would like to go around the room 17 and introduce ourselves and the organization we belong to. 9 18 Again, I am Kahtan Jabbour. I am with NRC, NRR. 19 MR. MATTHEWS: Dave Matthews, NRR. l 3 20 MR. McCOY: Ken McCoy, Georgia Power Company. 21 MR. MCDONALD: Pat Mcdonald, Georgia Power 22 Company. ; -) 23 MR. HAIRSTON: George Hairston, Georgia Power 24 Company. 25 MR. BAILEY: Jim Bailey, Southern Nuclear. e ANN RILEY & ASSOCIATES, Ltd. ' Court Reporters 1612 K Street, N.W., Suite 300 Washington,D. C. 20006
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3 1 MR. HEIDT: Jim Heidt, Southern Nuclear. Charles Barth, NRC, OCC. y 2 MR. BARTH: 3 MR. DOMBY: Art Domby from Trautman, Sanders, 4 representing Georgia Power Company. . 5 MR. MEIER: John Meier from Southern Nuclear 6 Operating Company. 7 MR. SPENCER: Steve Spencer from Southern Nuclear
} 8 Operating Company.
9 MR. GEORGE: Ben George from Southe.rn Nuclear 10 Operating Company. MR. FOX: Ben Fox. I'm with the Office of Nuclear
) 11 12 Reactor Regulation.
13 MR. MARKLEY: Mike Markley, NRR. 14 MR. ALLENSPACH: Fred Allenspach, NRR.
)
15 MS. SALGADO: Nancy Salgado, NRR. 16 MR. HOFFMAN: Steve Hoffman, NRR. Gene Moller, NRC, Of fice of General ) 17 MR. HOLLER: 18 Counsel. 19 MR. O'BRIEN: Jim O'Brien, NRR. 20 MS. YOUNG: Mitzi Young, Office of General 21 Counsel. 22 MR. MANILI: Barry Manili, NRR. 25 MS. THOMPSON: Catherine Thompson, NRR. 24 MR. SWENSON: Marren Swanson, NRR. 25 MR. HOOD: Darl Hoed, NRR. 3 ANN RlLEY & ASSOCIATES, Ltd. Court Reporters c 1612 K Street,N.W., Suite 300 Washington.D. C. 20006 (202)293-3950 i
I 4 1 MR. JABBOUR: With that, I would like to ask Dave ; 1 2 Matthews, Project Director for PD2-3, NRR, if he has any V 3 comments. 4 MR. MATTHEWS: All I would say is, Pat, we met . ) 5 over a year ago in advance of the first submittal for a 6 license transfer, which was Farley. I recall a good portion 7 of that, but I presume you are going to bring us up to date ) 8 with what has transpired since and where you are with the 9 other owne.rs and what your schedule is. I would really like 10 to hear what your individual schedule is and when you expect ) 11 us to provide a response to your amendment request which we 12 have received. l 13 MR. MCDONALD: We are here, gentlemen, on behalf ) 14 of Georgis Power Company to discuss the addition of Southern 15 Nuclear to the operating licenses for Plants Hatch and l 16 Vogtle as the operator of those facilities. ! 4 ) 17 (Slide.) 18 MR. MCDONALD: I will review in this order various 19 aspects and overview of this request. I know we will have ) 20 some additional meetings to discuss details of the license l l change applications. I would like to give you a good 21 22 overview of the requests and respond to David Matthews' ) 23 comments on the implementation steps. 24 (Slide.) 25 MR. MCDONALD: Going back to where we first ) ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street,N.W., Suite 300 Washington,D. C. 20006 p (202)293-3950
i i i O 5 1 started talking about Southern Nuclear affiliation, Southern () 2 Nuclear had a filing in 1988, with the SEC approval in 1990. l 1 3 Southern Nuclear was incorporated as a company on 4 December 17, 1990, with the officers elected the next day. I (y 5 The first step was corporate employees such as you i 6 were introduced to today came from other companies to become 7 Southern Nuclear employees on that date. , l [] 8 We gave you that briefing that you referred to as ; 9 being over a year ago. They had the Farley license 10 applications on the part of Alabama Power Company at that 3 11 time. The Farley plant license was amended. Then Southern l l 12 Nuclear became the licensed operator for the Farley plant on 13 December 23. O 14 We of Georgia Power submitted a license 15 application on September 18 of this year. 16 When this went into effect, the Alabama Power
- O 17 Company employees became Southern Nuclear employees for tne 18 Farley plant, but in f act similar to what we will be 19 discussing here today, the onsite operating organization did O 20 not change at that time.
21 What I really want to say is that this date, when 22 the Farley employees became Southern Nuclear, was the date 3 23 that the actual thing went into effect. 24 MR. MATTHEWS: Was that reflected in the license 25 amendment that we granted in that its effectivity would take e ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington,D. C. 20006 (202)293-3950
Q[ ' 6 1 place at some date in the future, or was it in effect such 3 2 that you could implement it immediately upon its receipt? 3 Do you recall? l 4 MR. MCDONALD: We a' sd for it to be done sometime i
-5 within a 90-day period, I believe it was.
,3 6' MR. DOMBY: The short answer is it was effective. , 7 upon issuance. O 8 (Slide.] L 9 MR. MCDONALD: Concerning the benefits of change, ,
- 10. it's well to go over these again briefly. ,
9 11 Management under the same structure has quite a ! 12 bit of significance. The benefits will be one of 13 consolidation and unity. Southern Nuclear has been a support organization 3 14 15 for the Hatch and Vogtle plants for some time, but there are : 16 a lot of different things in running two different companies 17 that make for difficulties when you are tryir.g to pull a 9 18 team together. One of the problems'we had is that we wanted : 19 to have the same relationship for all the nuclear power l 20 people in Southern Company. That sort of is the figurehead 3 21 of where we are going. ! 22 We have a devotion to nuclear power operations. 3 23 .this is a focusing of all the Southern Company's attention, 24 focusing of its assets and the leadership on the good 25 performance'of nuclear plants. ( e ANN RILEY & ASSOCIATES, Ltd. ! CourtReporters 1612 K Street,N.W., Suite 300 Washington,D. C. 20006
* (202)293-3950 .l
} 7 1 We need to do this, as you will recognize, I'm ] 2 sure, because the company has to have a lot of leadership 3 that is directed at what its ultimate goals are and to 4 continue pursuit of those goals. This will help us to ] 5 consolidate that pursuit of the goals within our Southern 6 system and have management who are not diverted by many 7 other activities that an all-purpose utility organization ] 8 gets involved in. 9 The consolidations of talent is an important 10 thing. As you know, most companies change people around a ] 11 lot. When you are changing people around, you go from job 12 to job, various different types of jobs and utility 13 operations. By consolidating our talents in this job we 3 14 pick the very best people. We will be able to groom them 15 at.d to grow them over a long period of time within an 16 organization which we would not have the oppcrtunity to do ] 17 as part of a large all-purpose utility organization. 18 The thought of a common vision is a very important 19 one. In management of companies today people talk about a J 20 vision. Vision used to be something that was pretty much 21 restricted to the religious world or some other type of a 22 high purpose leadership. Today it's a common term used by D 23 most companies in a. changing world, trying to figure out 24 where everybody is going to go in the long term. 25 This is what we have, a common vision where we can ? ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street,N.W., Suite 300
\Vashington,D. C. 20006 3
(202)293-3950
) 8 1 pursue the performance of these plants in the best way ) 2 possible to have a common philosophy to get the best 3 results. The term " vision" really means a great deal in the 4 business world today. ) 5 A general purpose company has a much more 6 difficult time of having a clear vision applicable to all , 7 people than a single purpose company will have. ) 8 The one about more effective communication with . 9 plants, I'm sure many of you will recognize that this allows 10 us to be able to communicate those many different details ) 11 that happen on a day-to-day basis from license to license, 12 to, you might say, have a more effective operation. 13 I'm sure that you at NRC would like to have us al. 1 3 14 standardized in one company and have only one such meeting 15 for everybody in the country and it would be a much 16 different and in many ways a more efficient meeting. The 3 17 same applies to us. We can be more efficient in that 18 respect. 19 Corporate support more specialized toward nuclear. ) 20 That is a very important thing too. A specialized nuclear 21 company will have some things that it doesn't need to do as 22 much as a general purpose company would need to do. It's ) 23 really a part of the focus. A genera), purpose company has a 24 lot of things, like extensive customer relationships and 25 sther activities associated with it. In a specialized } ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street,N.W., Suite 300 Washington,D. C. 20006 3 (202)293-3950 l
p 9 1 support we would have those items pared down to really what b 2 is Dest for the plants. 3 Broader base to enhance motivation and career. As 4 you all know, people, particularly the engineers who have I 5 come into the nuclear business, become very narrow in their
.6 pursuit of their vision. A company with more than one plant 7 in it will be able to enjoy a broader field so that within I 8 that given company there are more places to rove people 9 around and to develop their careers and expertise.
10 The last item is a very interesting one. Many of
) 11 yf,u will recognize it from what you read in the papers today 12 about 611 companies. The Southern system is undergoing a 13 functionalization of the activities. ) 14 In five cent words, that means the streamlining of 15 some of the support functions like human resources, like 16 accounting, trying to streamline that so it does it the most 17 efficient way possible for all the affiliated companies.
18 That will allow us in the nuclear to be able to find our 19 niche in the functionalization of these activities in order
? 20 to again focus our attention on the operation of the plants 21 .in the best possible manner.
22 (Slide.) I' 23 MR. MCDONALD: The licensing package was put 24 together using as a model the licensing package used for the 25 Farley plant. This package does include the lessons learned h ANN RlLEY & ASSOCIATES, Ltd. Court Reporters l 1612 K Street, N.W., Suite 300 l
) Washington,D. C. 20006 (202)293 3950
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)1 i 10 1 from the review'of the Farley package. ( ) 2 For example, during that review the NRC requested 3 a wording change on the approach taken to issue the Farley l 4 package. Instead of issuing the safety evaluation , ) 5 separately from the amendment, you requested that Alabama 6 Power submit a letter with wording that the licensing 7 amendments-be made effective as of their date of issuance # ) 8 with provision that the license conditions be implemented j 9 within 90 day of the date of issuance and upon official j 10 transfer of responsibilities between Alabama Power Company. { l ) 11 and Southern Nuclear. 12 I think that is what you were getting at, wasn't ! t
'13 it, Dave?
). 14 MR. DOMBY: Yes. : 15 MR. MCDONALD: This was the approach taken on this 16 package. ] ) 17 The submittal also conforms with 10 CFR 50.90. , 18 This reassignment intact of an organization is considered to ! 19 be an amendment to the license under 10 CFR 50.90. We note ) 20 that this same approach has been used on several previous I 21 applications with NRC. ) 22 When I say that the operating organization will be 1 23 reassigned intact, that is not' meant to say that all people 'l
'24 will have the same job before and after the change..
25 Personnel changes are routinely made due to retirements,
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ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street,N.W., Suite 300 y Washington,D. C. 20006 (202)293-3950 l N y e- ee e erw-ww -- - w --w-. n---1 -w +-w- + , - - -*-------a-
k 11 1 terminations, promotions, and what have you. This type of j 2 thing will be taking place, but in a very general sense we 3 have no grand reorganization plan or anything like that 4 going on. We expect our plant staffs to be stable and 5 changes being made being made at each site for the 6 improvement of performance at that particular plant. 7 We think that this submittal represents all the 8 license changes that are needed for Southern Nuclear to 9 become a licensed operator. This includes the tech specs, 10 environmental protection plan for Vogtle, and the 11 environmental technical specifications for Hatch and the h 12 antitrust conditions. 13 With respect to the organizational criteria, j 14 Southern Nuclear is the exclusive operator in accordance 15 with provisions to be included in the operating agreement 16 between Georgia Power and Southern Nuclear. Of course it 17 will be the sole operator at that time. ) 18 The site nuclear organizations will be assigned 19 intact. On the effective date we just expect it to be an 20 overnight change; no switching of offices or anything like ) 21 that; people will be transferred in and out on a name basis. 22 The technical qualifications remain the same as 23 necessary to carry out the responsibility of the license. ) 24 These will be consistent with the tech specs and the 25 technical qualifications of Georgia Power Company itself. ) ANN RILEY & ASSOCIATES, Ltd.
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12 1 Again, there may be some organizational changes. 3 2 There's always a few being hired, retired, and what have 3 you. So we are not saying there won't be any changes in 4 that period, but they will be of a minimal, routice nature. ) 5 of course the one thing that we want to emphasize 6 is that Southern Nuclear will have no ownership interest 7 whatsoever. That is the fundamental part of the way 3- 8 Southern Nuclear operates within the Southern Company. 9 Absolutely no ownership interest of any kind. That's 10 financial ownership interest. 3- 11 With respect to the operating agressent, the 12 operating agreement will be between George Pcwer Company and 13 Southern Nuclear. In. turn, Georgia Power will have 3 14 agreements with the other owners with respect to a managing 15 board agreement. 16 I want to make sure that is clear. This agreement D 17 under which Southern Nuclear is expected to operate those 18 plants will be with Georgia Power Company. In turn, there 19 is a management board agreement between Georgia Power 3 20 Company and the other owners. 21 Is there any question on that point? 22 (No response.) ) 23 That managing board agreement will be revised in 24 order to make this all fit together. The operating 25 agreement, of course, will define the relaticnship between D ANN RlLEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 . VVashington,D. C. 20006 3 (202)293-3950
s 13 1 GPC and Soutborn Nuclear consistent with the license. 2 MR MATTHEWS: At this juncture, let me introduce 3 Bob Wood. E why don't you say what your organization is. 4 MR, 00D: I apologize for being late. I work in [3 5 the financial ( 'aluation section. So we are covering both 6 the antitrust review and the financial qualifications. 7 MR. MCDONALD: I just went over this one as you ,3 8 were walking in, which I think is of interest to you: no 9 ownership interest changing hands at all. 10 MR. MATTHEWS: Although we don't want to interfere 3 11 with your presentation, I think we are going to be getting 12 into details associated with implementation eventually. At 13 the time that a question needs to be to asked, let's go 3 14 ahead and ask it. 15 As long as it doesn't seem to get you too off 16 track and we don't get too extended in time, would that be 3 17 an acceptable way to approach it? 18 MR. MCDONALD: We will also have people here who 19 can meet with you separately. We will be happy to respond 3 20 to anything that you want to know. 21 Let's talk about the financial criteria. You got 22 here just about in time. 3 23 Southern Nuclear is to be reimbursed by Georgia 24 Power Company and then Georgia Power Company will bill the 25 owners. It works this way because the owners are entitled e ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington,D. C. 20006 0 (202)293-3950
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14 . i 1 to all of the power generated by Plants Hatch and Vogtle. 2 Southern Nuclear will not market or broker any power i O 3 whatsoever. Southern Nuclear will be expected to operate 4 the plant and all they do is put the power on the line and j I 5 from then on it's all Georgia Power Company's business. ; O: I 6 Also, the costs will not be rate subject. That
- i. ..
i- 7 is, there will not be a direct relationship where the y c 8 allowed cost is set by a rate-making matter. By that I mean IO. p . 9 within our agreements we expect that Southern Nuclear will
- 10 have the option of operating the plant in the best way l O 11 financially beneficial, but it is not limited by rate-12 making; it's limited by what it takes to run the plant and l 13 the rate-making will continue to be the endeavor of Georgia i i
O 14 Power Company and whatever other owners might be involved. , 15 This financial relationship will be established : 16 between Georgia Power Company and Southern Nuclear to very ; g 17 carefully fix the responsibility for the plant costs and to 18 have those costs reimbursed. The costs that Southern ) 19 Nuclear has will be reimbursed by Georgia Power Company. - j O 20 That responsibility is absolute. l 21 Let me say that another way. If it takes so much l 22 money to repair a plant component that needs to be repaired, ; 23 that component will be rapaired. It is not a matter of O 24 going back to Georgia Power Company to ask them if that cost j r 25 is adequate or not; Southern Nuclear will have the ; 1 O ANN RILEY & ASSOCIATES, Ltd.
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1 15 1 responsibility of deciding how, when and how much to be paid '1 2 for that repair. 3 You may say Georgia Power will then turn around, 4 as appropriate, and bill the other co-owners for their
; 5 portion of such expense.
6 Another key item which I am sure you look at is 7 the owners retain the authority to shut down or to reduce O 8 the plant output for economic reasons. You will recognize 9 that that is something that would be negotiated as a part of 10 any operating arrangements between partners and someone who a 11 is operating a plant. 12 Likewise, the owners will continue to fund the 13 decommissioning costs. Southern Nuclear will perform the g 14 studies or have them performed to determine the funding 15 levels necessary for decommissioning. This data will be 16 transmitted to Georgia Power company, who will internally 9 17 modify its funding levels as appropriate. Of course Georgia 18 Power will pass that on to its other co-owners as well. 19 The owners continue to be responsible for Price-0 20 Anderson insurance provisions since they will continue to 21 own all the assets. Rate regulation will continue as before 22 with no change at this time. O 23 [ Slide.) 24 MR. MCDONALD: The antitrust criteria. As you 25 will notice, we are going down the list of what we see as ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street,N.W., Suite 300 Washington,D. C. 20006 J (202)293-3950
ll } l O l 16 1 the topical things that you will be looking at. Southern O 2 Nuclear has no entitlement to electric power. Antitrust ! 3 provisions in the present licenses will remain applicable. 4 Technical criteria. There is no decrease in the .O 5 effectiveness of the security plan in accordance with 10 CFR 6 50.54(p). 7 There is no decrease in emergency plan or its O 8 procedures in accordance with 10 CFR 50 App. E, Sect. V. 9 No change in the scope of operating 10 requalification program in accordance witn 10 CFR 50.54 (i) . O 11 And no change in the QA program commitments in 12 accordance with 10 CFR 50.54(a). 13 Georgia Power is determined that changes can be 3 14 made to these programs in accordance with existing 15 regulations without specific NRC approval. Necessary 16 administrative program changes for Southern Nuclear to O 17 become the licensed operator will be made to coincide with i 18 Southern Nuclear's assumption of these resporsibilities. 19 Offsite power source to General Design Criteria 17 e 20 will be assured by Georgia Power Company. This will be done 21 in accordance with the operating agreement. It will be 22 defined in that agreement to assure that that commitment O 23 will be met. 24 This agreement will provide for arrangements for a 25 continuous source of onsite power, the arrangements for ? ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street,N.W., Suite 300 Washington,D. C. 20006 g (202)293-3950
) 17 1 controlling the activities in the switchyard and on the transmission lines within the exclusion area, and the ) 2 3 requirement that Southern Nuclear must approve major 4 switchyard changes. 5 Essentially, these arrangements are already in [ 6 place and will continue. 7 With respect to the exclusion area, Southern 8 Nuc. lear will have the authority under the agreement to 9 control all activities within the exclusion area. l- 10 The matter of existing personnel with unescorted 11 access authorization. When 10 CFR 73.56 became effective l l 12 last year provisions were included in the regulation that i 13 personnel who have previously been granted unescorted access 14 under a then existing licensee's program could be 15 grandfathered without any additional evaluation. 16 However, the guidance documents to 10 CFR 73.56
)
17 indicate that in general this grandfathering condition could l 18 not be transferred to another licensee. These guidance ) 19 documents only envisioned an employee moving from one
) 20 licensee to another, not an entire organization being 21 reassigned. ;
22 Since there is no net change in continuing with l the grandfathering provisions for these employees and the
) 23 24 burden of reevaluation is so significant, which was the 25 reason the grandfathering provision was included to begin ANN RlLEY & ASSOCIATES, Ltd.
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a OL 18 1 with, Geoigia Power has proposed to allow the employees () 2 which had been grandfathered at the time of the regulation 3 to continue to be grandfathered in Southern Nuclear. 4 Southern Nuclear will become the NPDES holder
- OL 5 under the existing program.
6 With respect to no significant hazards, since the 7 techr.ical qualifications of the company remaja equivalent to O 8 before and there are no physical changes to the facility, 9 Georgia Pover has concluded that there are no significant 10 hazards considerations. () 11 There are no changes being made which can affect 12 the environment. All obligations in the current 13 environmental protection plan for 'lant Vogtle and the Q 14 environmental tech specs for Hatch will continue to be met. 15 Therefore there is no unreviewed environmental qJestion. 16 In addition, since this change involves no () 17 significant hazards consideration, it involves no change in 18 any type or amount of effluent that may be released. 'nd 19 there is no change in individual or cumulative occupttsonal O 20 radiation exposure, this amendment qualifies as a 21 categorical exclusion for the need to perform an 22 environmental assessment for 10 CFR 51.22 (c) (9) . C) 23 I sort of valked down those. I think that hits 24 the high point of most of the things you will be looking at 25 in this application. O ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington,D. C. 20006 O (202)293-3950
O 19 1 (Slide.) l 2 MR. MCDONALD: Let's talk a little bit about the C 3 implementation. . 4 On September 18 we Federal expressed the license submittal to NRC and you stated that you had received it. g 5 6 This subnIttal requests that the NRC issue tha amendment 7 within,60 days, which is estimated to be November 17, 1992. 8 We are hoping to i=plement the license conditions
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9 on December 19, 1992. The reason that we could not send the 10 package to the NRC earlier than Seriember 18 is because we 11 only recently, on September 17, reached a stage with the
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12 Oglethorpe HEAG and the City of Dalton in which issues were 13 sufficiently resolved for submittal to be made, 14 From the employee perspective, December 19 is the g 15 favored date for Southern Nuclear to become the licensed 16 operator due to benefits, FICA payments and income tax 17 issues. 18 November 17 was determined internally to be an 19 acceptable date to allow an orderly transition and 3 20 completion of all the preconditions for a license 21 reassignment. Some of the preconditions are indicated in 22 this box here on the slide. 23 There is really a great deal of preparation that 3 24 is in process and must be brought to fruition for the change 25 to be madu. We feel it is important from the employee D ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street,N.W., Suite 300 Washington,D. C. 20006 8 (202)293-3950
D 20 1 benefit as rell as from the overall venture that this g 2 proceed exTeditiously. 3 [ Slide.] 4 MR. MCDONALD: In terms of the activities, this 5 gives a little idea of some of the examples that will be 3 6 going on. 7 of course you note that the schedule is pretty 8 well compressed. We know of no significant issues at this 3 9 time that we expect to come up during your licensing review 10 of it. 11 If we are to be able to make the December 19 date, g 12 we are going to have to work prttty fast. We really need to 13 have at least one week prior to that date to reassign the 14 security and emergency planning atreements o to make them 3 15 effective on the 19th. By that I mean once we get the go-16 ahead, we are going to have to put in place to county and 17 state officials the letters reassigning from Georgia Power g 18 to Southern Nuclear. In order to get those in place and 19 have them ready to be put into effect on the 19th, that 20 takes some preparation. We estimate about a week the way 21 business 2.s done in those areas. 22 Despite that, the critical path for us is generally the personnel and accounting departments ) 23 24 concerning the transfc.r. There are about 2,100 people to be { l 25 transferred. Each one of those people must be terminated by ANN RILEY & ASSOCIATES, Ltd. Court Reporters ; 1612 K Street, N.W., Suite 300 l Washington,D. C. 20006 (202)293-3950
l 21 1 Georgia Power and enrolled at Southern Nuclear with all the 2 enrollment forms. You guys think you got a lot of paperwork 3 so=etimes. There is a lot of paperwork in that. It has 1 4 each individual with selections they make indiv3 dually on l 3 5 certain types of benefits that have to occur. 6 In order to effectively handle the paperwork, a 7 clear decision to proceed with the 19th date must be 8 received by about the first week in December. That means
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9 that if we can't find out in the first week of December we 10 cannot carry this through to make it happen on the 19th. 11 However, let us say that you did hand a decision 9 12 down and said, okay, we're going to proceed, and then turn 13 around and say later that you couldn't. We would need to 3 14 know that pretty fast, by the second week, because once we 15 got started we couldn't stop it fast enough. This is 16 necessary to assure the quality of that transfer process. 3 17 (Slide.] , 18 MR. MCDONALD: Basically, that's what I have just 19 covered here. 20 KR. MATTHEWS: TLose are just details of the 3 21 implementation. 22 MR. MCDONALD: That's right. p 23 MR. MATTHEWS: They don't really bear on the 24 decision. Those changes can be made without our specific 25 approval, right? 9 ANN RlLEY & ASSOCIATES, Ltd. Court Repoders 1612 K Street,N.W., Suite 300 Washington,D. C. 20006
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m ) 22 l 1 MR. MCDONALD: It really doesn't. That's why I i
'2 didn't go through those. It seems a little tedious. j l
3 MR. MAliDEWS: Is it your plan at an early ) 4 juncture to start implementing some of those changes or at 5 least get in a position to be able to? ) 6 MR. MCDONALD: Yes. t 7 This seems_quite straightforward. I would be 8 happy to respond to any questions on what we have on this ) 9 matter. You can pick out any one of these things. Here's 10 one which we have to do on union issues. In order to 11 transfer those employees of the union we must transfer that ) : 12 labor contract over from Georgia Power to Southern Nuclear. 13 So that's the type of thing that needs to be done. 14 MR. MATTHEWS: I think I will have a couple of ; 15 questions on the process and schedule, but let me turn to 16 NRC staff before that. 8 17 Bob, do you have anything? 7 18 MR. WSOD: No, I don't. 19 I apologize also that the fellow who handles the 20 antitrust issues for us isn't here today. 21 MR. MATTHEWS: Are you aware of any antitrust ; 22 considerations that come to bear in this instant case that 23 are ani different than the discussions we had with regard to ) 24 the Farley license transfer? 25 MR. MCDONALD: No, I'm not aware of any that are l f-c ANN RlLEY & ASSOCIATES, Ltd. Court Reporters - 1612 K Street,N.W., Suite 300 Washington,D. C. 20006 i ) (202)293-3950
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1 any different at all from that transfer. Of course every [ 2 -license has some section on antitrust, and there is nothing 3 that is changing in.that license. The fact that Southern i
< 4 Nuclear has nothing to do with ownership and also the fact g' 5 -that Soutnern Nuclear is not a for-profit company simplifies 6 that antitrust aspect. ;
7 MR. JABBOUR: Pat,-how would you compare the i j 8 budget for Southern Nuclear Operating Company versus some of l 9 the budgets for Hatch and Vogtle over the next few years? l 10 MR. MCDONALD: We will continue to spend whatever I 11 is necessary to keep those plants operated well and in a ) 12 high safe condition. I can't really say much more than , i 13 that. As you know, we have had a lot of upgrading 14 activities on the material condition of Hatch over the past ) ; 15 few years. Of course we just completed Vogtle, and we think i 16 both plants' are in good shape. 17 You also know that operating expenses in general : g 18 continue to climb. 19 , MR. JABBOUR: Would there be any sort of ( 20 limitation on Southern Nuclear reducing, for instance, cost ! ) , I 21 of operations at both plants? 22 MR. MCDONALD: As a part of Georgia Power we are 23 now under pressure to reduce cost. As ycu saw in the ) . 24 Nucleonics Week, the competitive posture of nuclear is 25 closer now to that of coal than it has been in the past. ! ) ANN RILEY & ASSOCIATES, Ltd. Court Reporters : 1612 K Street, N.W., Suite 300 ! Washington,D. C. 20006 ?. (202)293-3950
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O 24 1 The utiliti6s in general are in a much more competitive 2 position. So within Georgia Power Company wo have been 3 trying to reduce co.sts. 4 You also know that over the past several years we g 5 have had fairly high expenditures levels. We have done both 6 expense items and capital items to bring plar.ts up and 7 assure they are in good operating condition. I think that's 8 evidence of dedication to that principle. 9 There is really no change in the ownership. The 10 ownership insists upon that type of performance and the 11 owners are the ones that have to pay for it ultimately. So 12 I would not see any basis for some sort of direct cost 13 pressure out of the normal ones that you have through the 14 business arrangement. g 15 Is that responsive? 16 MR. JABBOUR: Yes. g 17 MR. MATTHEWS: iform? 18 MR. SWENSON: I have one or two briet questions. l l 19 I note in the submittal it says that the license conditions 20 will be implemented within 180 days. In light of your 3 21 accelerated request for review and approval to meet these 22 deadlines, is there some reason for six months?
) 23 MR. MCDONALD: Yes, there is. We started this 24 vision of forming Southern Company about five years ago. As 25 meny of you nave reminded men, it has sure taken us a long ) ANN RILEY & ASSOCIATES, Ltd.
Court Reporters i ! 1612 K Street,N.W., Suite 300 i Washington,D. C. 20006 J (202)293-3950
3-25 1 time. So we can't be certain what can happen. We explain 2 here what we hope to do, but there might be something that } 3 comes up in terms of an ownership arrangenent that would 4 , delay that. I don't have any idea what that would be. 5 MR. HAIRSTON: Pat, excuse me. You said an 3 6 ownei' ship arrangement. You mean a problem may come up in 7 developing agreements with the owners, not the ownership 8 arrangement. } , 9 MR. MCDONALD: I was thinking more among the 10 owners than having anything to do with Southern Nuclear. There are four parties involved and they have to agree on ) 11 12 what is done at what time in the various types of business 13 enterprises which they have. 14 Part of the time it has taken for us to get to , 15 this point har involved the various pieces of each one of 16 those four partnerships with each rther. I am not saying : 17 that it's not impossible. As you know, we wouldn't be here } 18 today if we hadn't got their concurrence to proceed to this 19 step, but until it is done we want to give enough time for ; something else if it happens to come up. ) 20 l 21 Does that respond to your question? MR. SWENSON: I think so. Indirectly. 22 23 MR. MCDONALD: I would be happy to be more direct ) 24 if you can tell me what you mean. MR. SWENSCN: In the case of Farley, as you were k 25 ! ) ANN RlLEY & ASSOCIATES, Ltd. l CourtRepoders 1612 K Street,N.W., Suite 300 ; Washington,D. C. 20006 9 (202)293-3950
E' b 26 1 saying, you only required 90 days. This one seems to be on 2 the fast track. I'm not sure why you need more time for 3 something on the fast track. 4, MR. MCDONALD: Because with only one party 5 involved and that one party said go. There are other parts 3 6 to the implementation down the road. 7 MR. SWENSON: Let me ask this question then. Does 8 that mean that as of rfght now we do not know for sure that 9 all parties are go? 10 MR MCDONALD: No. 11 MR. SWENSON: I thought you had said earlier that 12 all parties were go.
'13 MR. MCDONALD: Let me be quite specific. All 14 parties have agreed with us to submit this application. All 3
15 parties have agreed to the concept of forming the company. 16 We have near final agreements, but they can't, you might 17 say, be ultimately signed until we get the go-ahead from 7 18 you. Until we can make these things come together, nobody 19 knows. ] 20 Let me ask my attorney. Can you respond to that 21 any better than I tried to? 22 MR. DOMBY: No. I think you covered the points. 3 23 The co-owners have agreed with the submission of the 24 amendment. There are preconditions to execution like any 25 other corporation. J. ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1812 K Street, N.W., Suite 300 Washington,D. C. 20006 ) (202)293 3950
k 27 1- MR. DOMBY: I missed that in your lier 2 explanation. 3 MR. MATTHEWS: Am I to understand that you 4 anticipate that the potential for thosa preconditions is 5 greater in this instance because of the number of parties 6 involved than there were on your previous submittal? 7 MR. MCDONALD: That's correct. I could have said 8 that ' ' I had thought of the words. ) 9 MR. HOOD: I'm a little ccnfused. Please 10 straighten me out. We have a submittal in front of us that 11 asks for 180 days of th2 date of issuance and upon the ) 12 official transfer of responsibility from Georgia Power. At 13 the time we approve it, according to the submittal you want y 14 180 days.for implementation, but your slide shows about one 15 month. 16 MR. MCDONALD: Let me see if I can' respond to 17 that. We are asking for your approval within about 60 days. 18 That's what we are asking for. 19 MR. HOOD: I understand that part. I'm asking 20 ahnt what time period do you need for implementatior, once 21 we approve it. 22 MR. MCDONALD: Once you tell us it's approved, we (- 23 need just about three and a hatf weeks. 24 Let me put it another way. We've got a lot of 25 things to dc to make this happen. If we can't get your i ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington,D. C. 20006 I- (202)293-3950
} 28 1 approval in about 60 days, we are going to have to cancel ) 2 and start over. By that I ::.ean we have briefings to 3 employees, for example, that will be going on all during 4 this time before December. We have this laid out and we are ) 5 planning co that we need your concurrence on this by about 6 November 17. 7 You may not get it to us on the 17th, but we are ) 8 going to be marching down that road. We really have to have 9 the final word by the first week in December. Then we start 10 another set of personnel-related critical path items to get ) 11 it done by the 19th. 12 Having said that, we would like to have it 13 somewhere between November 17 and the first week of ) 14 December. And we would like for you to give us the 180 days 15 as a fall-back position in case some party doesn't agree so 16 we will have tiaa to work that agreement out and restart the ) 17 process of transferring the people. 18 Not quite understood yet? 19 MR. HOOD: I think I got it. What you are asking , ) 20 me to do is when I issue the amendment it will be 180 days ! 21 thereafter. I i 22 MR. MCDONALD: No. ) 23 MR. HAIRSTON: Up to 180 days. 24 MR. MCDONALD: Yes. 25 MR. DOMBY: It would be effective upon issuance. ) l ANN RILEY & ASSOC!ATES, Ltd. l Court Reporters l 1612 K Street, N.W., Suite 300 Washington,D. C. 20006 ) ' (202)293-3950 l
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- i l' Not only the preconditions Pat talks about, but parallel to i y 2 the NRC governmental approval you will have things like 3 NPDES permits, environmental permits and other permits. You 4 don't, start that process until you have a pretty strong
- g. 5 indication from the NRC, which obviously has primary i
6 jurisdiction, before you file those environmental programs. I i 7 In other words, you are saying go do it, but some
- g. 8 period of time would elapse after that effective date of l 9 issuance of the license where Southern Nuclear could get ;
10 back to you and say the punch list is complete: we finished I g 11 everything. 12 MR. MCDONALD: Did that answer it? ; 13 MR. HOOD: Yes. I understand. My point of g 14 confusion was simple. I have a submittal that says 180 days l 15 and I see a slide in front of me that says the period of ! 16 time between NRC approval of the amendment and license . g 17 condition being effective is one' month. 18 MR. MCDONALD: Ye's understand now, though? ! 19 MR. HOOD: Yes. ; 20 MR. MCDONALD: I'm sorry we didn't make it clear. 21 MR. HOLLER: While ';s are on the subject of 180 ; 22 days for implementation, I believe it was mentioned earlier : 3- 23 with Alabama Power Company and Farley that the license f 24 r.mandmenc was issued with 90 days for implementation. Is l 25 there something that distinguishes Hatch and Vogtle?
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1 30 1 MR. MCDONALD: Yes, there is. Farley had a single -
)~ 2 owner and that meant that that dimension was easier to 3 predict. Also it was one plant. Here we have two plants 4 and fo,ur owners.
5 MR. HOLLER: This may be important as we look at
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6 it. If I understand it, 180 is the minimum time that you , 7 need for implementation. No. The minimum time we need for '
) 8 MR. MCDONALD:
9 implementation if everything goes right is December 19, 10 which is less than that. That's about three months from
) 11 today. If after you issue the document and we are in the 12 process of implementing and something happens between the 13 co-owners or something, we would prefer instead of having to 14 come back and reissue that, go through it, to say, look, you 15 have from this date to 180 days from now without any other 16 thing to implement it.
17 MR. HOLLER: Let me rephrase my question. I
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18 understood that from the first time through. Given as yet 19 unknown contingencies that may come up, it is your estimate
) 20 that you would need the 180 days to accommodate those yet 21 unknown contingencies.
22 MR. MCDONALD: Yes. It's just a contingency time. 23 You're right. That's the best way to put it.
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24 MR. HOLLER: Let me put it another way. In other i 25 words, it would be difficult if it was issued with, the same
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I 31 1 as Farley, 90 days, but it would be difficult if it was 2 issued at 120. You've calculated that 180 is tne time 3 needed to account for unknown contingencies. Is that fair? 4 MR. MCDONALD: That's correct. 5 MR. MARKLEY: Of that 180, how much is planned 6 slack time between what you are allowing and what you 7 targeted. 8 MR. MCDONALD: Our planned time is December 19, ) 9 which doesn't use that 180 up at all. December 19 is a very 10 important time to us, because we need to do it before the 11 year is out for employees. For example, if you get delayed ) 12 and we don't get this done until next year, then the 13 employees when you pay them they have to take the social 14 security out twice. So they will be paying basically double
)
15 social security and they don't get that money refunded until 16 the next tax year. 17 MR. HAIRSTON: For certain employees.
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18 MR. MCDONALD: Yes. That is one of the problems. 19 The other thing is that you get it in time to 20 change over to a new calendar year. You've got budgets; ) 21 you've got all these things to do; and if you don't do it 22 right before the end of that calendar year, you have got 23 lots of different legalities and papers and administration,
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24 and that's a problem. That's why w'1en Alabama Power Company 25 did the Farley one it was a December time, just toward the ANN RlLEY & ASSOCIATES, Ltd. 3 Court Reporters 1612 K Street, N.W., Suite 300 Wash!ngton D. C. 20006
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l and of the year. 3- 2 MR. SWENSON: Is a copy of the operatiny agreement I 3 part of the submittal package? 4 , MR. MCDONALD: No, it isn't. O' 5 MR. SWENSON: Can we see a copy of that? Did we 6 see a copy of that last time? I was not in my current 7 position in reviewing the Farley plant. 3 8 MR. DOMBY: My understanding is there wasn't a , 9 review of the operating agreement with the Farley 10 application, a1.though I didn't represent Farley. In answer i D 11 to your question, can you see the agreement, yes, if you 12 want to see it. ~ ~ 13 MR. SWENSON: I would like to. 3 14 MR. FOX: When you transfer licensed operators to 15 Southern Nuclear how will they be integrated in the- , 16 emergency plan? Are they going to be trained prior to 3 17 implementation? Will they become the emergency directors, > 18 for example? 19 MR. MCDONALD: Let me address that. Right now I 3 20 don't know of a single person in the Match or Vogtle 21 programs that will change jobs. Those who are in emergency 22 planning have a role in it. It will stay the same before 3 23 and after. Sama person. 24 If I have a nuclear employee who is doing the job 25 with a Georgia Power hat today, when he changes to a s s-ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington,D. C. 20006 (202)293-3950
l i ) l 33 1 Southern Nuclear hat his job will not change. That's what I We have some people in Southern Nuclear who J .2 mean to say. 3 are involved already_in some emergency planning support, and ] 4 he or she vill simply stay Southern Nuclear. , )) 5 Ken, is that right? 6 MR. McCOY: I think that's accurate? 7 Does that answer ycur question? )- 8 MR. FOX: Yes. I was just concerned whether a 9 Georgia person who steps in and becomes an emergency 10 director at a remote facility is trained and cognizant of ) 11 all the stuff they have to do prior to the effective date. 12 MR. McCOY: The individuals that have the < 13 responsibilities for all the functions in emergency planning i ) 14 will be the same individuals that have those 15 responsibilities after. They may be workir:q for a different 16 company but they will already be trained and experienced ) 17 with those duties. , 18 KR. MCDONALD: General?y, the biggest change as 19 far as assignments like that is the simple substitution of ) 20 Southern Nuclear for Georgia Power Company in their position 21 titles and what have you. 22 MR. FOX: I noticed in your application that you ) 23 all had specified that except for certain functions that 24 were retained by Georgia Power those other functions would 25 be transferred to Southern Nuclear. ) ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street,N.W., Suite 300 VVashington,D. C. 20006 ) (202)293-3950 i
y< 34 1 MR. MCDONALD: Here is an important thing. I O 2 think this is what you are referring to. After this change 3 takes place Georgia Power Company will provide certain 4 support to Southern Nuclear for those plants. O 5 For example, we expect Georgia Power to continue , 6 to carry the health insurance. The health insurance will be 4 7 paid througn us and back to Georgia, because Georgia Power O 8 has a health insurance company that is unique to Georgia 9 Power. 10 Georgia Power will continue to provide services to O 11 maintain the switchyard. They will continue to provide 12 services in an environmental lab to analyze samples. . 13 Those things will continue. They won't change at O~ 14 all. It's not anything new. It's just that we will have ar. 15 accountability in terms of finances for that outside support . 16 that Georgia Power has been giving. ~O 17 MR. FOX: Will Southern Nuclear be able to obtain 18 all the resources if there was an accident or something like 19 that? O 20 MR. MCDONALD: They wculd be able to obtain the l 21 same resources as those plants now would obtain as a part of l 22 Georgia Power Company. 3 23 MR. MATTHEWS: Any additional questions from the 24 NRC staff? 25 Mitzi. e ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington,D. C. 20006 , (202)293-3950 l
O 35 1 MS. YOUNG: In preparing the submittal did you all 2 read the Commission's decision regarding the requirements 3 that transfers can be done by order and not necessarily be 1 4 done by amendment exclusively? 5 MR. DOMBY: I've read the decision. 6 MS. YOUNG: It said a transfer wasn't an 7 amend =en% for example. 8 MR. DOMBY: It's obvious that a transfer is not an 9 amendment. We believe that this is an amendment, in 10 effect. 11 MS. YOUNG: This is a transfer of control. 12 MR. DOMBY: This is not a transfer of any 13 ownership interest. 14 MS. YOUhd: This is a transfer of control of 15 operations, control of maintenance. 16 MR. DOMBY: The tasks of operating the plant are 17 going to be under a different corporate structure. That's 18 true. 19 MS. YOUNG: Did you look into Seabrook? That 20 ir.volved a transfer of ownership and a transfer of 21 managenent operations. Those two were done by order. 22 MR. DOMBY: As you point out, ownership was 23 involved in Seabrook. 24 MS. YOUNG: And management. There were two 25 ditferent entities. I think you really need to look at that e ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street,N.W., Suite 300 Washington,D. C. 20006 e (202)293-3950
O 36 1 decision. [] 2 I also notice in your submittal that you are 3 arguing that this qualifies you for a categorical exclusion 4 under 51.22(c).(9). Was Farley done with a categorical [] 5 exclusion? 6 MR. DOMBY: That's my understanding. 7 MR. HOFFMAN: No. l
) 8 MR. DOMBY: On the environmental?
9 MR. HOFFMAN: No, it was not. 10 MS. YOUNG: Do you know if there is anything [) 11 different about this proposed request in terms of what was 12 dono for Farley? 13 KR. DOMBY: No. Farley is the template for this. () 14 MS. YOUNG: That's why I raised the Commission's 15 decision, because if a transfer of control really is an 16 amendment, it needs some kind of environmental evaluation to
) 17 go with it even if you would argue that.
18 MR. MCDONALD: We have requested that in the 19 Farley transfer, I believe, which this was modeled after. D 20 MS. YOUNG: The Commission's decision postdates 21 Farley, I believe. So you have to be aware of what is going 22 on at the NRC. D 23 MR. MCDONALD: We asked you to consider the Farley 24 project as a precedent for this one. 25 MS. YOUNG: Farley was done with an environmental e ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 Washington,D. C. 20006 (202)293-3950
0^ 37 s 1 -assessment. 2 MR. DOMBY: EA rather than EIS. 00 3 MS. YOUNG: Yes. 4 MR. DOMBY: Right. 5 MS. YOUNG: I advise you to look at the 'O 6 commission's decision on Shoreham recently because it 7 illuminated some of the aspects of transfers that even most 8 of the staff hadn't been thinking about prior to that O 9 decision. 10 MR. MCDONALD: I'm sure we can work this out. The 11 NRC has stated that they are anxious for companies to form
- 0 12 up like we are. I'm sure you will assist us in doing that 13 within the requirements.
14 MR. MATTHEWS: Refresh my memory. Steve, when O 15 Farley made their applicosion did they claim a categorical 16 exclusion at that time? Do you remember? 17 MR. HOFFMAN: I'd have to go back and look. I O 18 think they did. 19 Ben. 2o MR. GEORGE: I believe we did. In any event, O 21 there is not an environmental issue here. . 22 MR. MATTHEWS: As the project director I am less O 23 concerned with the specific issues at hand that the 24 technical staff and the legal staff may have to review and 25 more concerned with process and schedule. I think you l l 0 l ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street,N.W., Suite 300 Washington,D. C. 20006 O (202)293-3950
O-38 1 appreciate the fact that the schedule you have requested of 2 us is a very tight one, or compressed, as you would put it. 3 MR MCDONALD: It is. Knowing that, we are 4 requesting this from you. I would like to say again that we , 5 were here and some of us were involved in the other ; V 6 transfer. I think that that went off quite smoothly. I 7 know thare may be other business taking place in the 8 meantime, but this is a process which NRC has supported for 9 the last several years, and I hope we can proceed in this 10 time frame.
)
11 MR. MATTHEWS: We will endeavor to do that. There 1 O l 12 are some mechanical limitations. I think you appreciate I 13 that even on a minor license amendment, barring emergency j 14 provisions, which this doesn't qualify for, probably an O \ 15 optimum license amendment review time is about 45 days. We 16 now have the possibility that an environmental assessment 17 will have to be done and published in that same time frame. 18 So that makes a 60-day time period for our review extremely 19 tight. 20 I haven't as yet heard back from each of the O 21 representative groups here, which I will be doing in the 22 next week, as to whether they could support this schedule or 23 not. g 24 I note the Farley review took about six months. l l 25 MR. MCDONALD: Yes, and I think most of that was I e ANN RlLEY & ASSOCIATES, Ltd. Cloud Repoders 1612 K Street, N.W., Suite 300 Washington,D. C. 20006 3 (202)293-3950 1 l
39 1 taken up by the decision to make an antitrust review. j 2 KR. MATTHEWS: It may have been. I'm not arguing 3 details. But the net. result is that it took about six 4 months from submittal. D 5 MR. MCDONALD: Again, Georgia Power Company 6 watched that very carefully, because that is time-consuming. 7 The decision was made at that time to do that antitrust 'O 8 review, and since that should be precedent setting, we 9 shouldn't count : hat time and how long it took that process 10 to go through. 11 KR. MATTHEWS: I'm not trying to debate the thing D 12 with you. I'm offering to you my observations on what we 13 are faced with. At this juncture, in comparison to Farley D 14 we are talking about a three-month schedule for NRC review. 15 The Farley implementation time was about three months and 16 that's how the license was reflected. In this instance you D 17 see some potential hurdles associated with the possibility 18 of agreements getting off track, et cetera. So you are 19 talking about six months. We have just about reversed those D 20 time frames. 21 What I would like to do is poll the representative 22 groups here within the next few days. We are going to D 23 endeavor to support your schedule. I would like to do it by 24 exception. If we presume that the representations you've 25 made are in agreement with our requirements, and we are e ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street,N.W., Suite 300 VVashington,D. C. 20006 (202)293-3950
7 40 1 talking primarily a process dictated schedule, and if we see
} 2 some aspect of that that would disturb this schedule of 3 yours, I'd give you a call as soon as I would see that and 4 follow that up with a letter that would indicate to you what 1 5 our estimated time of completion would be.
6 That's only if I see something that might dislodge 7 your schedule, because I appreciate just how significant
) 8 this date that you are working for is insofar as individual 9 implementation and personnel issues. It's not that I make 10 these comments in disregard of that, but at the same time we ) 11 have some limitations with regard to the formal noticing and 12 review process that I've got to consider.
13 Nothing jumps out at me at this juncture and says
) 14 this is a no-go. I'm just being cautious. I would hate to 15 sit here and tell you that I see no problem. I see a 16 potential for schedule-related problems just because I know 17 what's involved in one of these reviews, and this isn't what 18 I would put into the trivial or minor review category. Yet ,
l 19 the kind of time frame you have asked us for starts to ) 20 approach that time. 21 With that said, I don't have any more comments. I l 22 would look to within the next week or so to give you a call j I 23 and let you know what I see if I see any problems. If not, i 24 you can presume that we are moving along that path. 25 MR. PARTLOW: I'm sorry I'm late. I missed the
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ANN RILEY & ASSOCIATES, Ltd. Court Reporters l 1612 K Street, N.W., Suite 300 Washington,D. C. 20006 (202)293-3950 i
[ !: 41 1 -whole thing. 2 MR. MCDONALD: I will be happy to go over it all [
- 3 for you. ,
4 MR. PARTLOW: I'll get together with these folks' ) 5- right after this. 6 MS. YOUNG: Do you anticipate any latervention 7 with respect to this? ; y 8 MR.'DOMBY: Personally, no. 9 MR. MCDONALD: We don't know of anything. The 10 last one like this that Southern Company was involved in was j ) 11 Farley. The only issue that we knew of at that time was l 12 whether or not NRC was going to put it out for an antitrust , 13 review, and they put it out for review. Then they decided l y 14 that that wasn't going to be needed anymore. So we think ' 15 that the only issue here was basically resolved and put to 16 bed on the Farley amendment. ) '17 MR. MATTHEWS: I don't know what stage Jim came in 18 on my closing remarks. 19 MR. PARTLOW: I thought they were asking for y 20 January, and I take it now they are asking fcr November. 21 MR. MATTMEWS: That's my primary concern as the l l 22 project director. We didn't hear at this juncture that l p 23 there were any what I would call show stoppers. They did 24- submit it with a provision that it be treated as a
, 25 categorical exclusion under Part 51. That submittal was )<
ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 Washington,D. C. 20006 ) (202)293-3950
i e 42 1 also made under Farley and disagreed with and an 2 environmental assessment was prepared and published, which I rf e 3 just causes some small schedule changed provided that it's 4 routine. , 5 But we didn't see any show stoppers at this g3 6 juncture. I committed to them that I would poll the staff 7 and we would discuss it and if we did see something that we 8 would get to th.<a as soon as possible. () 9 MR. PARTICW: And what bad things happen if 10 everybody doesn't make December 19? g 11 MR. MCDONALD: I'm so glad you asked, Mr. Partlow. 12 Let me explain again. ; 1 13 (clide.) 14 MR. MCDONALD: We have one thing, which is a g 15 shared anxiety. I think a shared anxiety was the NRC. When 16 we first started talking to you about this the co-owners all ! ,, 17 thought it was a good idea and all we had to do was write it v 18 down and get it put together. Well, we had some other 19 business. Not nuclear. The co-owners have always been cy 20 supportive but they had other business matters that tended 21 to delay these activities. 22 We finally got this down to where all the co-g 23 owners agreed with this submittal and then we turned this 24 submittal in on September 18. 25 W3 are trying to get it done this calendar year. J ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street, N.W., Suite 300 ! Washington,D. C. 20006 3 (202)293-3950 .
i Oi l 43
'l The calendar year portion of it is very important from an g 2 employee and from an administrative point of view. It's not 3 hurry up now and jump in to do it. It's a matter, for 4 example, if you delay it into the,new year, then for some employees you collect twice for social security tax. You 3 5 6 have to have two different years for health plans and what 7 have you.
8 So it gets to he pretty complex. We're talking ] 9 about 2,100 people involved. So administratively it's a lot 10 of work for us to drag this out. We have to go through a 11 briefing process and an employee selection process in terms 9 12 of what each employee wants his benefits to be. 13 We have attempted to lay the groundwork. The I g 14 simplicity compared to what the previous one was with , 15 Southern Nuclear, the Farley one, we just hope that we can 16 do this one as a matter of routine, you might say. g 17 MR. PARTLOW: Do we know enough about the 18 application to say it's comelete yet? 19 MR. MATTHEWS: I didn't hear that there were any 3 20 concerns about lack of completeness, but we did ask for an 21 additional submittal, the operation agreement between 22 Georgia Power and Southern Nuclear. 23 MR. MCDONALD: We did not submit that type of an 3 24 agreement with the Farley project. Is that a necessary item 25 for the licensing? D ANN RILEY & ASSOCIATES. Ltd. Court Reporters 1612 K Street,N.W., Suite 300
. Washington,D. C. 2000S B
(202)293-3950
I i 9
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44 i l
- 1. MR. BARTn: I don't know about this one, but in 2 the past where we had a plant with co-owners we had these i 3 - ownership agreements to show who is responsible for what.
4 MS. YOUNG: Also, for Shoreham whers LILCo was , g 5 reimbursing LICO for their expenses, we saw those. 6 MR. SWINSCN: It defines who is responsible for i 7 which technical resources. 8 MR. DOMBY: The concern here is the docket aspects
)
9 of it? 10 MR. MATTHEWS: That's the only way we can lock at 11 it, as official correspondence. Whether the individual i C i 12 agreement is put in the PDR is, I think, what you are i 13 speaking to. 14 MR. DOMBY: Right. 15 MR. MATTHEWS: We will decide whether it's a 16 necessity in consultation with the staff. If it is, we will 17 make that known to you and then we will work out g 18 arrangements associated with how you need to submit it with 19 the appropriate affidavits to ensure withholding. Is that 20 agreeable? 3 21 KR. DOMBY: Yes. It will be a draft. 22 MR. MATTHEWS: I understand. 23 MR. MCDONALD: Lee me make sure my team is in g 24 agreement with what has been said. 25 Art, are you and John in agreement? e ANN RlLEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street, N.W., Suite 300 VVashington,D. C. 20006 J (202)293-3950
45 1 MR. DOMBY: Yes. 2 MR. MCDONALD: You are going to discuss the 3 submittal of this further? 4 MR. DOMBY: With the staff.,
) 5 MR. MATTHEWS: I would like that discussion to be 6 entered through Kah. I wanted to make known that although 7 it's two plants involved, Kah is going to be the lead 8 project manager with regard to coordination of the reviev 9 for both Hatch and Vogtle, and in Kah's absence Don will be 10 there. They work as a tear, as you well know.
3 11 MR. MATTHEWS: Is there anything else? 12 MR. JABBOUR: That's all. 13 MS. YOUNG: . Explain again why it's going to be a 14 draft. Are there a lot of agreements that are going to be 3 15 in draft. i 16 MR. DOMBY: The operating agreement between ' g 17 Georgia Power and Southern Nuclear will not be finalized and l 18 signed until requisite co-owner approval " formally" comes 19 through. There will be a closing, if you want to use that 3 20 term, at some point in the future. You obviously don't sign 21 the agreeuent before NRC approval. You don't want to 72 execute the agreement, which would be in contravention of 4 gp 23 law, until you get the NRC approval. 24 MS. YOUNG: You could sign it and not have it 25 effective until NRC approval. It just seems hard for the 9 ANN RILEY & ASSOCIATES, Ltd. Court Reporters 1612 K Street,N.W., Suits 300 Washington,D. C. 20006 8' (202)293-3950
3 46 1 agency to take a decision based on something that may never 3 2 be agreed to. 3 MR. DOMBY: I'll put it this way. We believe all 4 the essential elements associated with NRC approval are 3 5 addressed in the license amend =ent applications. 6 MR. Mc DONALD: That talks about the ownership in 7 there. ) 8 MR. PARTLOW: If it turns out that we need this 9 thing and you give it to us in draft, can you also.tell us 10 that if anything changes you will let us know? ) 11 MR. DOMBY: Absolutely. 12 MR. MATTHEWS: Then we can make our approval 13 conditional on there being no major differences. - 14 MR. MCDONALD: Certainly. There is no problem at 15 all. 16 MS. YOUNG: Is there any way you could have 3 17 submitted these changes earlier to give us more time? 18 MR. McD3NALD: We submitted those the day we got 19 the approval. O 20 MR. MATTHEWS: Thank you very much. 21 (Whereupon at 2:20 p.m. the meeting was 22 concluded.) 0 23 24 25 l l 0 l ANN RILEY & ASSOCIATES, Ltd. Coud Repoders 1612 K Street,N.W., Suite 300 e Washington,D. C. 20006 ; (202)293-3950 l
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y l 3 NRC Presentation ! l ? 4 Changes to Allow Southern Nuclear to f Become the Licensed Operator of ; Plants Hatch and Vogtle . P : l 1 3 September 28,1992 3 ! l
) l l ) !
3
o o Presentation Overview - o-History -o
- Benefits of Change ,
O
- Licensing Packages ,
i
- Implementation Schedule t
9 l
- Implementation Activities l
iO l i
'O l
4 ~0 o
.O
1 i - l D. Southern Nuclear History i
. l J
DATE ! i D' l
- SEC Filing June 22,1988 '
i e SEC Approval December 14,1990 J.
- Southern Nuclear Incorporated December 17,1990
]
- SNC Officers Elected December 18,1990 ;
e Corporate Employees Transferred January 1,1991 J e NRO Briefing on SNC Formation January 11,1991 e FNP License Application to NRC May 6,1991 i ) i e NRC Approval of FNP Amendment November 22,1991 ) e SNC is FNP Licensed Operator December 23,1991 e HNP/VEGP License Application September 18,1992 to NRC ? ]
a 1 1 'a Benefits of Change l l l D
- Nuclear Management Under Same Structure
- Management Devoted to Nuclear Power Operations D
- Consolidation of Nuclear Operations Talent i i
- Common Vision for Nuclear Plant Operations 7'
- More Effective Communication Between Plants
- Corporate Support More Specialized Toward Nuclear u ;
- Broader Base to Enhance Motivation and Career Potential 3
- Broad Administrative and Specialized Support From Other !
Southern System Companies Op'!mized for Nuclear 1 Management e l l e
O g Licensing Packages Submittal Approach 3
- NRC submitta!s developed consistent with APC package, e Submittal documentation pursuant to 10 CFR 50.90.
- Submittal contains all operating license changes for Southern 3 Nuclear to operate Plants Hatch and Vogtle.
Organizational Criteria b Southern Nuclear is exclusive operator and has authority over physical construction, maintenance and operation.
- Site nuclear operations organization will be reassigned intact to Southern Nuclear.
o
- Technical qualifications will remain the same.
- Southern Nuclear has no ownership interest.
- Operating Agreement will be between Southern Nuclear
> and Georgia Power Company. Financial Criteria , Southern Nuclear to be reimbursed for all HNP/VEGP costs by GPC (GPC will bill the other Owners pursuant to existing agreements.)
- Owners to retain authority to shutdown or to reduce plant 8 output for economic reasons.
- Owners to fund decommissioning costs.
- Owners continue to be responsible for Price-Anderson
' insurance provisions.
- Rate regulation will continue as oefore with GPC.
p
o .e , i l0.- Licensing Packages (continued) : ! Antitrust Criteria , !o_
- Southern Nuclear has no entitlement to electric power. l Antitrust provisions in license remain applicable.
l
\
'o Technical Criteria { e No decrease in effectiveness of Security Plan in accordance with 10CFR 50.54(p). 0
- No decrease in effectiveness of emergency plan or its procedures in accordance with 10CFR 50 App. E, Sect. V.
- No change in scope ~of Operator Requalification
') Progi;im in accordance with 10CFR 50.54(l).
- No change in QA program commitments in accordance with 10 CFR 50.54(a).
- Offsite power source to GDC 17 to be assured by GPC.
- Exclusion Area to be controlled by Southern Nu: : ear.
3
- Existing personnel with unescorted access authorization will be reassigned without further evaluation.
, 8 Southern Nuclear to be NPDES Permit holder.
- No significant hazards consideration, e
- No environmental assessment or impact statement required.
All elements and obligations of existing EPP to be maintained. ! e ____m- - - - - - _ - w- w-,-
O O O O O O O O .O O I O. l l l implementation Schedule Target Dates: September 18,1992 ilovember 17,1992 December 19,1992 (Actuaq About 4- 2 months - - >1 1 month > I I I I I m ense NR"4 Approval NRC Filing _
- > ,,, ---> Condesions Effecawe m ~> / m. . ]L Managing Board Agreement Revisions Southern Nuclear Becomes Operator Operating Agreement Approvals . _ _ _ _ _ . _ -
Emergency Plan Program Changes Sh.Ty Program Changes ' Procedure Changes Environmental Program Changes Employee Transfers _ y y -w m W -
.e 'mr --e --%.-
D g , implementation Activities Examples of activities which will be conducted to allow Southern Nuclear to operate HNP and VEGP are shown below. O Emergency Plan Program Changes
- Process necessary changes to Emergency Plans and o Emergency implementing Procedures and obtain necessary approvals to implement.
- Assign existing emergency planning agreements from GPC g to Southern Nuclear or execute new agreements.
- Define ongoing emergency planning activities where GPC is to provide future support (such as public communication).
o
- Transmit changes to Emergency Plans and Emergency implementing Procedures 30 days after changes are made.
Security Program Changes o
- Process necessary changes to Security Plans, Contingency Plans, and Guard Training and Requalification Plans and
.g obtain approvals to implement.
- Assign existing security support agreements from GPC to Southern Nuclear or execute new agreements.
- Define ongoing security activities where GPC is to provide g
future support.
- Transmit changes to above security documents 2 months after changes are made, i*
O
e
, implementation Activities (Continued) l Procedure Changes ;
3 e Process Corporate and site procedure changes as appropriate : to assure organizational reporting is clear and well defined. O Environmental Program Changes e Reassign necessary permits including NPDES permit;. O
' Define ongoing environmental program activities where GPC is to continue to provide support (such as lab analysis).
- Transmit changed NPDES permits to NRC within 30 days of b
approval. : I Employes Transfers e Conduct Information Meetings.
- Transfer employee information history such as performance P history, vacation, sickness allowance, other benefits, salary l and salary history, pension, etc. from GPC to Southern Nuclear. ,
- - i
>
- Transfer accounting information on employee company loans, t D cash advances, etc. )
(
- Address union issues. l
?
- Effect employee transfer on date Southern Nuclear becomes ,
the licensed operator of HNP and VEGP. l l J
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3....3 J., ,,we xs r :: . m 4 O., c.x.ucc., Georgia Power - {c7,y ['
..,.,,,.,m,,,.,.,,,,
October 23, 1992
-Docket Nos. 50-424 ELV-04099 .O 50-425 1
TAC M84531 l M84532 j
\
O' U. S. Nuclear Regulatory Commission i i ATTN: Document Control Desk Washington, DC 20555 ! .O Gentlemen: l V0GTLE ELECTRIC GENERATING PLANT SOUTHERN NUCLEAR ORGANIZATIONAL CHANGE , I
.O On September.18,1992, Georgia Power Company (GPC) submitted proposed amendments to facility Operating License Nos. NPF-68 and NPF-81 which would authorize Southern Nuclear Operating Company, Inc. (Southern Nuclear) to become the licensed operator and have exclusive responsibility and control over the physical construction, operation, and maintenance of Vogtle Electric Generating Plant, Units 1 and 2.
'o-The September 18, 1992 application presented a list of directors and officers for Southern Nuclear as it existed at that time. Effective November 1, 1992, Joseph M. Farley, Director and Chairman of the Board of Southern Nuclear and Executive Vice President and Corporate Counsel of The Southern Company, will retire after 40 years of loyal and dedicated service to The Southern Company iO and its subsidiaries. In addition to his present positions, Mr. Farley has served as the President and Chief Executive Officer of Alabama Power Company ~ and was the first President and Chief Executive Officer of Southern Nuclear. > In a similar manner, Nr. F. D. Kuester was identified in the September 18, 1992 application as being a Southern Nuclear officer with the. title of Assistant Secretary and Assistant Treasurer. On October 13, 1992, O Mr. Kuester was named to a position within Southern' Company Services, a separate subsidiary of The Southern Company. It is anticipated that an , individual will be selected in the normal course to fill Mr. Kuester's position.
.O i
O
O l Georgia Powerkh i U. S. Nuclear Regulatory Commission ELV-04099 Page 2 I i d- { These personnel changes have no affect on the organizational chart provided I in the application. No other management changes were made and all reporting ; lines specified in the Application to Amend Facility Operating License Nos. ' NPF-68 and NPF-81 remain the same. These changes have no impact on the significant hazards consideration evaluation or the conclusions made in the g- September 18, 1992 Application to Amend Factitty Operating License Nos. . NPF-68 and NPF-81. A copy of this letter will be sent to Mr. J. D. Tanner of the Environmental Protection Division of the Georgia Department of Natural Resources. O Sincerely,
- hb=Y C. K. McCoy 0 CKM/JMG cc
- Georcia Power Comoany f Mr. R. P. Mcdonald, Executive Vice President Mr. W. B. Shipman, General Manager - Plant Vogtle NORMS O
U. S. Nur, lear Reaulatory Commission. Washinaton. DC Mr. D. S. Hood, Licensing Project Manager - Vogtle U. S. Nuclear Reaulatory Commission. Reaion II Mr. S. D. Ebneter, Regional Administrator O Mr. B. R. Bonser, Senior Resident Inspector - Vogtle State of Georcia
- Mr. J. D. Tanner, Commissioner,tepartment of Natural Resources O
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- S May 21, 1993 W 8 "'+.:n r. rem Docket Nos. 50-424 LCV-0022
'O - 50-425 g ;.
f..**.* TAC Nos. M84531
>W4532 -s ~ ~~
LT. S. Nuclear Regulatory Commission ATTN:. Document Control Desk <., E H "O~ Washington, DC 20555 k%.,
- d.- s .J
- ,/
N.,,, Y Gentlemen: O Vngtle Electric Generating Plant Organizational Chanaes
- O On September 18, 1992, Georgia Power Company (GPC) submitted proposed
- amendments to Facility Operating Licen;e Nos. NPF-68 and NPF-81 which would authorize Southern Nuclear Operatin9 Company, Inc. (SNC) to become the licensed operator and have exclusive responsibility and control over the physical construction, operation, and maintenance of Vogtle Electric Generating Plant Nuclear Plant, Units 1 and 2. ,
- O The September 18, 1992 appilcation presented a list of SNC directors and officers as it existed at that time. Two separate letters, dated October 23, 1992 and March 5,1993, have been submitted reflecting
, _ organizational changes which have occurred since the September 18, 1992 submittal . On May 3,1993, the SNC Board of Directors elected Mr. W. G. Hairston, III President, Chief Operating Officer, and member of
- O the Board of Directors, effective immediately. As the company's president, Mr. Hairston succeeds Mr. R. P. Mcdonald, who retires June 1,1993, upon customary retirement. Mr. Mcdonald was named SNC Chairman of the Board and will remain SNC's Chief Executive Officer until his retirement. The SNC Board of Directors also announced that Mr. H. A. Franklin, President and
, Chief Executive Officer of Southern Company Services (SCS), will succeed O Mr. R. P. Mcdonald as SNC Chairman of the Board and Chief Executive Officer
.upon his retirement. Mr. Franklin will assume his new duties in addition to his responsibilities at SCS. ,
On May 19, 1993, the GPC Board of Directors elected Mr. Hairston to succeed Mr. Mcdonald as Executive Vice President of CPC, effective June 1,1993. As O Executive Vice President of GPC, Mr. Hairston will report to Mr. A. W. Dahlberg, III relative to the operation of the GPC nuclear facilities. Mr. Hairston's successors for his prior positions at GPC and SNC will be named in the normal course of business. ,O
.rm es '94 ee:27M SOUTFgRN PO^LEM 205 870 6103 P.3/3 .S Georgia Power A
) U. 5. Nuclear Regulatory Comission ' Page 2 These changes do not impact the significant hazards consideration evaluation or the conclusions made in the September 18, 1992 Application to Amend 3 Facility Operating License Nos. NPF-68 and NPF-81. A copy of this letter will be sent to Mr. J. D. Tanner of the Environmental Protection Division of the Georgia Department of Natural Resources. 3 Sincerely, W C. K. McCoy ) CKM/JDK , cc: Georain Power Comoany W. G. Hairston, !!!, Senior Vice President W. B. Shipman, General Manager - Plant Vogtle U. S. Nuclear Reaulatory Commission. Washinaton. DC 3 D. S. Hood, Licensing Project Manager - Vogtle U. S. Nuclear Reculatory Comission. Recion II S. D. Ebneter, Regional Administrator
- 8. R. Bonser,. Senior Resident Inspector - Vogtle 3 State of Ceoroia Hr. J. D. Tanner, Comissioner, Department of Natural Resources
) LCV-0022 )
d Q1 , SOUTHERN NUCLEAR OPERATING COMPANY, INC. BOARD OF DIRECTORS MEETINO O' May 3,1993 MINUTES i b A meeting of the Board of Directors of Southern Nuclear Operating Company, j Inc., was held by telephone conference on May 3,1993. Directors E. L. Addison, E. B. Harris, H. A. Franklin, A.W. Dahlberg, and R. P. ; O Mcdonald participated. Others in attendance were J. O. Meier, Secretary, J. D. McLanahan, and P. J. DeNicola. At the request of Mr. Mcdonald, Mr. Franklin chaired the meeting. I g The following actions were taken by the board during the meeting:
- 1. Mr. Franklin stated that it was appropriate to change the By-Laws of.the Company to provide that the Chainnan of the Board will also be designated as the Company's chief executive officer. Upon a motion duly made and seconded, the following resolution was adopted by unanimous vote:
RESOLVED, that. Article V, Section 2. of the By-Laws of the j Company is hereby revised to read as follows: i I Section 2. Duties of the Qiainnan of the 0- Board. The Chainnan of the Board shall be the Corporation's chief executive officer and shall have general authority over the business and affairs of the Corporation, subject to the control and direction of the board. He shall report to the board of directors O and shall see that all orders and resolutions of the board of directors and of the executive committee are j carried into effect. ' The Chairman of the Board shall preside at ali O meetings of the stockholders and board of directors. He shall have authority to execute bonds, mortgages, and other contracts requiring a seal, under the seal of the Corporation; he shall have power to endorse, when sold, assigned, transferred or otherwise disposed of by the Corporation, all certificates or shares of stock, O bonds, or other securities issued by other corporations, associations, trusts, whether public or private, or by O.
southern Nudcar operating Compenry Page 2 May 3,1973 3 any government or agency thereof, and owned or held by the Corporation, and to make, execute and deliver all instruments of assignment or transfer of any such stocks, bonds or other securities. He may, with the approval of the board, or shall, at the board's , discretion, delegate any or all of such duties to the President.
- 2. Mr. Franklin stated that it was appropriate to change the By-Laws of the Company to provide that the President will also be designated as the Company's
, chief operating omeer. Upon a motion duly made and seconded, the following J resolution was adopted by unanimous vote: RESOLVED, that Article V, Section 3. of the By-Laws of the Company is hereby revised to read as follows: ? Section 3. Duties of the President. The President shall be the Corporation's chief operating omeer and shall be responsible for all of the operations of the Corporation and shall report to the Chairman of the Board. J The President shall, under the direction of the Chairman of the Board, have general supervision and direction of the other omcers, employees and agents of the Corporation and shall see that their duties, as 3~ assigned by the board, are properly performed. He shall designate and assign the duties of the oMcers under his supervision, with the approval of the Chairman of the Board or at his direction. , The President shall have authority to execute bonds, mortgages and other contracts requiring a seal, under the seal of the Corporation; he shall have power to endorse, when sold, assigned, transferred or otherwise disposed of by the Corporation, all certificates for shares, bonds, or other securities or
- other evidences of indebtedness issued by other corporations, associations, trusts, whether public or ,
private, or by any government or agency thereof, and owned or held by the Corporation and to make, execute and deliver all instruments of assignment or 8 transfer of any such stocks, bonds, or other securities. In the absence of the Chairman of the Board, the e
Southern Nedcar opersung rn p..y page 3 y ,y 3,1993
) President shall have full authority to do any and all things delegated to the Chairman of the Board by the board of directors or by any committee of the board having authority.
y The President will perform all of the duties and have all of the authority of the Chairman of the Board 1 in the absence of the Chairman of the Board.
- 3. Mr. Franklin stated that it was appropriate to name Mr. Mcdonald to the newly defined position of Chairman of the Board and chief executive officer. Upon a 2- motion duly made and seconded, the following resolution was adopted by l unanimous vote:
RESOLVED, that R. P. Mcdonald is hereby elected to the position of Chairman of the Board and chief executive officer of the ' Company.
- 4. The board acknowledged and accepted the retirement of R. P. Mcdonald from I his positions as a director and as an officer of the Company, to become effective ,
on June 1,1993. l l S. Mr. Franklin stated that it was appropriate to name Mr. Hairston to the newly defined position of President and chief operating officer, and to elect Mr. Hairston as a director of the Company. Upon a motion duly made and seconded, , the following resolution was adopted by unanimous vote: l RESOLVED, that W. G. Hairston, III is hereby elected to the position of President and chief operating officer of the Company, to serve until the next annual meeting of the sole stockholder and until his successor is elected and qualified; and ) RESOLVED FURTHER, that W. G. Hairston, IIIis hereby elected as a director of the Company, to serve until the next annual meeting of the sole stockholder and until his successor is elected and 3 qualified. [ 6. Mr. Franklin stated that it was appropriate to name a replacement for Mr. Mcdonald as Chairman of the Board and chief executive officer, to become effective upon his retirement on June 1,1993. Upon a motion duly made and seconded, the following resolution was adopted by unanimous vote: ;
) RESOLVED, that H. A. Franklin is elected to the office of Chairman of the Board and chief executive officer of the Company, )
O. : Southern Nudear Operating Cornpeny Page 4 May 3,1993 g' to become effective on June 1,1993 upon the retirement of R. P. Mcdonald, to serve until the next election of officers or until his successor is duly elected and quali6cd. , i There being no further business to come before the Board, the meeting was O "di*"'"*d' P o h/ ; Secretary .O r O c 5 i f o l I I I O , l l 0 W O O __ \
9 GEORGIA POWER COMPANY MINUTES OF ORGANIZATIONAL MEETING OF DIRECTORS MAY 19. 1993 l 9 The regular meeting of the Company's Board of Directors was held at the office of the Company, 9- 333 Piedmont Avenue, N.E., Atlanta, Georgia, at 11:30 a.m., i local time on Wednesday, May 19, 1993, being the time and date for the organizational meeting of the newly elected ) O Board of Directors .a s specified in the written consent of ) Stockholders, effective this date, in lieu of the Annual Meeting of Stockholders. O Announcement re Orcanizational Meeting Mr. A. W. Dahlberg, President and Chief Executive Officer, announced that this was the organizational meeting O of the newly elected Board of Directors as specified in the written consent of Stockholders, effective this date, in lieu of the Annual Meeting of Stockholders. O Attendance The following directors were present: Edward L. Addison Bennett A. Brown ) William P. Copenhaver A. W. Dahlberg William A. Fickling, Jr. L. G. Hardman, III Warren Y. Jobe William A. Parker, Jr. H. G. Pattillo G. Joseph Prendergast Herman J. Russell Robert Strickland William Jerry Vereen Thomas R. Williams constituting a quorum of the Board.
) 05/19/93
j' 2 -- Gloria M. Shatto and Robert W. Scherer did not attend j the meeting. There were also present by invitation M. A. Carlton c Jr. (Troutman Sanders); Susan M. Carter (Assistant Corporate )l Secretary); Dwight H. Evans (Executive Vice President); C. B. Harreld (Vice President and Comptroller) ; and Robert P. Mcdonald (Executive Vice President). ) Mr. A. W. Dahlberg, President and Chief Executive Officer, presided, and Ms. Susan M. Carter, Assistant Corporate Secretary, acted as Secretary of the meeting. ) Prior to the appointment of the Temporary Chairman, Mr. A. W. Dahlberg, President and Chief Executive Officer, explained that the proposed slate of officers included the ) election of Mr. William G. Hairston, III as Executive Vice President of the Company, effective June 1, 1993. He stated that such election will coincide with the retirement of )- Mr. Robert P. Mcdonald and that, in his new position, Mr. Hairston will report directly to the President and Chief Executive Officer. ) Accointment of Temoorary Chairman Mr. William A. Parker, Jr. was appointed Temporary Chairman of the meeting to preside during the election of ) officers of the Company for the ensuing year. Election of Officers Mr. William A. Parker, Jr., acting as Chairman of the ) meeting, presented a slate of officers of the Company to be e'ected. ) 05/19/93
On motion, duly made and seconded, it was !
. VOTED: That the election..of officers to serve during
[ the ensuing year, in accordance with the Bylaws of the Company, and to hold office at tha will and subject to the y pleasure of the Board of Directors, be acted upon. WHEREUPON, The following persons were .placed in nomination for, and a ballot being- had thereon, were , unanimously elected to the offices set opposite their j i respective names:- Name Title l-s A. W. Dahlberg- President and Chief Executive L officer l Warren Y. Jobe Executive Vice President, Treasurer and Chief Financial Officer ) Dwight H. Evans Executive Vice President Bill M. Guthrie Executive Vice President John C. Hemby, Jr. Executive Vice President )- Gene R. Hodges Executive 71ce President Robert P. Mcdonald Executive Vice President (May 19, 1993 - May 31, 1993) } K. E. Adams Senior Vice President 1 Wayne T. Dahlke Senior Vice President William G. Hairston, III Senior Vice President (May 19, 1993 - May 31, 1993) Executive Vice President (Effective June 1, 1993) Robert H. Haubein Senior Vice President 3, Gale E. Klappa Senior Vice President Fred D. Williams Senior Vice President
) 05/19/93
I p Name Title j D. R. Altman Vice President Judy M. Anderson Vice President and Corporate Secretary J. T. Beckham, Jr. Vice President 0: Barbara Bowers Vice President W. P. Bowers Vice President Robert L. Boyer Vice President O- M. A. Brown Vice President Robert D. Carpenter Vice President l James L. Conn Vice President
) James K. Davis Vice President i Fred W. Dement, Jr. Vice President J. W. George Vice President 3 C. B. Harreld Vice President, Comptroller and Chief Accounting Officer Leonard J. Haynes Vice President .
Ronald E. Leggett Vice President Craig S. Lesser Vice President J. B. Manley Vice President J. L. Martin, Jr. Vice President Charles K. McCoy Vice President J. A. Parramore, Jr. Vice President Edward J. Turner Vice President M. Euel Wade, Jr. Vice President , Charles W. Whitney Vice President James A. Wilson Vice President W. R. Woodall, Jr. Vice President ) 2L 05/19/93
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Gt orgia Power
.' & X ~~ :ve m;>.3.n-June 14, 1993 Docket Ncs. 50-424 LCV-0040 50-425 TAC Nos. M64531 Q. ~
M84532
~
U. S. Nuclaar Regulatory Comission ATTN: Doce ant Control Desk Washington, DC 20555 O Gentlesien: Vogtle Electric Generating Plant -
, dreanizational Chanans O
On September 18, 1992, Georgia Power Company (GPC) substitted proposed amendments to Facility Operating License Nos. NPF-68 and NPF-81 which would authorize Southern Nuclear Operating Company, Inc. (SNC) to become the licensed operator and have exclusive responsibility and control over the O physical construction, cperation, and maintenance of Vogtle Electric Generating Plant, Units 1 and 2. The September 18, 1992 application presented a list of SNC directors and officers as it existed at that time. Three separate letters, dated October 23, 1992, March 5, 1993 and May 21, 1993 have been submitted 3 reflecting organizational or personnel changes which have occurred since the September 18, 1992 submittal relative to the list. On June 4, 1993, the GPC Board of Directors elected Mr. Woodard to succeed Mr. Hairston, III as Senior Vice President of GPC, effective immediately. As Senior Vice
- President of GPC, Mr. Woodard will report to Mr. W. G. Hairston, III and is . responsible for the operation of the GPC nuclear facilities. On June 3,1993, the SNC Soard of Directors elected Mr. J. D. Woodard Executive h Vice President, effective June 4,1993. As the comparty's Executive Vice i
President, Mr. Woodard succeeds Mr. W. G. Hairston, who was elected SNC President May 3, 1993. Prior to assuming these responsibilities, Mr. Wcodard served as SNC Vice President - Farley Project. D
i
. . .'n . :,-a n; .e : t.e - < 81 . ve.-a Le e,-a u .. . iu ia .s.
Georgia her d q U. S. Nuclear Regulatory Comission Page 2 7 i These changes do not impact the significant hazards consideration evaluation . or the conclusions made in the September 18, 1992 Application to Amend ' Facility Operating License Nos. NPF-68 and NPF-81. ) A copy of this letter will be sent to Mr. J. D. Tanner of the Environntental Protection Division of the Georgia Department of Natural Resources.
$1ncerely, ;
> C&t ' C. K. McCoy l
\
CKN/JDK cc: Georcia Power Cnmoany ) W. G. Hairston,11!, Eaacutive Vice President J. B. Beasley, G6neral Manager - Plant Vogtle l U. S. Nuclear Reculatory Comission. _Washincton. DC D. S. Hood, Licensing Project Manager - Vogtle
> U. S. Nuclear Reculatory Comission. Recion II .
S. D. Ebneter, Regional Administr4 tor B. R. Bonser, Senior Resident Inspector - Vogtle l State of Georcia
- Mr. J. D. Tanner, Comissioner, Department of Natural Resources i 1 k LCV-0040 1
f TOT 4. P.02
m 3 l ) ) t i SOUTHERN NUCLEAR OPERATING COMPANY, INC. l j BOARD OF DIRECTORS MEETIl4G ; December 13,1993 l MINUTES ) A meeting of the Board of Director 3 of Southern Nuclear Operating Company, ! Inc., was held in Birmingham, Alabama on December 13, 1993. Directors E. L Addison, H. A. Franklin, A. W. Dahlberg, E. B. Harris and W.G. Hairston participated. Mr. Franklm chaired the meeting, and J.O. Meier served as ) Secretary. ) The following actions were taken by the Board during the meeting:
- 1. Mr. Franklin tendered his resignation as Chairman of the Board and Chief '
3 Executive Officer, and it was accepted by the Board.
- 2. Mr. Franklin stated that it was appropriate to elect the Company's f President, Mr. Hairston, to the additional position of Chief Executive l Officer. Mr. Franklin further stated that certain revisions to the By-laws !
D of the Company are necessary to accommodate this change in l responsibilities. Upon a motion duly made and seconded, the following j resolutions were adopted. ; t i RESOLVED, that the revisions to Article V, Section 2. of the i By-laws of the Company, Duties of the Chairman of the ) Board, which were adopted by resolution of the Board on May 3,1993 are hereby rescinded; ; RESOLVED FURTHER, that the revisions to Article V, i Section 3. of the By-Laws of the Company, Duties of the ) President, which were adopted by resolution of the Board on l May 3,1993 are hereby rescinded; and l RESOLVED FURTHER, that W. G. Hairston, IIIis hereby elected l to the positions of President and Chief Executive Officer, effective ! )' immediately. !
- 3. Mr. Franklin stated that it was appropriate to increase the number of :
L Directors comprising the Board of Dirxtors from five to six. According . to the By-Laws of the Company, the sole stockholder will elect a Director ! ) to fill this newly created vacancy on the Board. Upon a motion duly made ; and seconded, the following resolution was adopted by unanimous vote: 5
i L Southern Nudear Operating Company Pays 2 h 13.1993 RESOLVED, that pursuant to the authority expressly granted by Article III of the Company's By Laws, the number of Directors comprising the Board of Directors shall be six (6) persons.
- 4. Mr. Dahlberg tendered his resignation as Chairman of the Audit
} Committee, and it was accepted by the Board. Mr. Franklin was nominated as an aJdition to the Audit Committee, and also to assume the role of Committee Chairman. Upon a motion duly made and seconded, and the following resolutions were adopted: ), RESOLVED, that H. A. Franklin is hereby appointed as a member of the Audit Committee of the Board; and RESOLVED FURTHER, that H. A. Franklin is hereby designated as the Chairman of said Audit Committee. } There being no further business to come before the Board, the meeting was adjourned. } Ist Secretary ) 3 ) ?
0 y Lo CONSENT OF THE SOUTHERN COMPANY.
); TO ADOPTION OF A RESOLUTION IN LIEU OF A SPECIAL MEETING OF STOCKHOLDERS OF SOUTHERN NUCLEAR OPERATING COMPANY, INC.
The undersigned, on behalf of The Southem Company, sole stockholder of Southern Nuclear Operating Company, Inc., a Delaware corporation, in accordance with Delaware Corporation Law, Section 228, does hereby consent to adoption of the following resolution in lieu of a Special Meeting of Stockholders ). of Southern Nuclear Operating Company, Inc.: RESOLVED, that Paul J. DeNicola is hereby elected a director of Southem Nuclear Operating Company, Inc., effective as of December 13,1993 and continuing until the next Annual Meeting of Stockholders or until his successor is elected and qualified ) In Witne:s Whereof, the undersigned has caused this consent to be duly signed and its corporate seal to be hereto affixed and duly attested this 94 day of /2 b /
,19 94.
THE SOUTHERN COMPANY ) By S - - ^ Its bes2eo C8d ATTEST: c Secretary
'O ,
O DATE: April 26, 1989 O TO: Mr. Fred D. Hilliams FRON: M. 8. He'f
- O At the April subcommittee for Power Generation meeting, Mr. Dan Smith requested a response to the following. The wording is taken from the minutes exactly as Dan stated.
" Dan Smith requested that Oglethorpe be provided an organization presentation by SONOPCO on the reporting chain up through the
- O Board of Directors for Mr. George Hairston, Mr. R. P. Mcdonald, Mr. Joe Farley. He specifically asked how Mr. Farley fits into the picture and who he reports to up through the Board."
As we discussed, I am forwarding the question to you for reply. .O
/ble c: Mr. G. F. Head *
'O 'O 'O
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.en-sa .z a- - _ . . . . . ys .
{3 . Interoffice Correspondence Georgialbver b O . .
,,,,, ,,. ,,,, CONFIDENTIAL ^
O 4 l Mr. Fred W1111 ass; Following is a list of probles areas in Nuclear Operations that you ,o requested. . ' 1. Rennentibility an Aaent: There is no clearly defined person
- I serve responsible for acting as agent for the Joint Owners.
,0 on the Joint Subcommtttee for Power Generation (and as currently , serving as Chairman) and deal with their Nuclear Operations 3 However, you are people probably more than anyone else. involved, several of your people are involved and others. ]O It was my understanding when we tried to negotiate a contract I between GPC and $0N0PC0 and amend the contract between GPC the Joint Owners, that I would act as CPC's (for example) agent. l working for George Head, and that all interactions on nuclear 'O the matters between GPC and CPC wo'11d come through as with exception of some specific, routine reports that would be ! I as prepared to provided directly fros $0N0PC0 to all owners. handle that. .O Yet, .on Friday, April 21 I received a call from John Meter Stating that the $0N0PCO Project was establishing a Quarterly Review Heeting with GPC's Joint Owners to discuss Nuclear John asked If that meeting could replace the Joint O Op,erations. Committee or Subcommittee. I said no. O 1.. e O W O
5 3 7 , J 2s;? n.. lg* -
.~ . ' on Tuesday, April 25. den Salth free CPC called to say they had I , been contacted by John Meter and OL. wanted to know who was setting up this' Quarterly Review Meeting. Its purpose, and why I 3 was not included. He said Oglethorpe was confused as to what is going on and who was in charge.
While I know that there are significant differences between GPC l3 and CPC on a number of matters, the relationship between us in nuclear is excellent. If GPC could get a handle on SONOPCO and, if nuclear could be separated from these other issues, ! believe Dan Smith and I could work out all of the problems in nuclear. 3
- 2. cmmunications: On January 19, Pat Mcdonald called to say he was developing an E nall systes to connect all Joint Owners -
including GPC. One of its purposes was to provide daily reports to each Joint Owner on the status of our plants. He asked se to i contact Roy Barron to work out details. I did. On Monday, March 13 (I believe that was the date), Roy Barron told me that the system was ready to do a test run and all he 3 needed was to get Pat Mcdonald's approval. I called Pat to ask for his approval but he was out of town in Florida. I asked his secretary to ask his if it were okay when he called in. She called back on March 15 to say she had been unable to ask him. 3 I talked with Pat on Tuesday March it, and he said the system wasn't ready. O O -t-I s= 0
' N ishd s g num m m m e ru s t u m
) .
.... 'L ..
Q;. j Me are still not connected. I get no information fres $0NOPCD ) ' on the status of our units. I get all of g information (except monthly suonaries three weeks after the end of the month) from OglethorpePower. I get dr.11y reports from thes. Secondly, we have been.11aited by Pat Mcdonald to talking to ) only one person at the 50N0PC0 project - first it was Sob Gilbert, who delegated it to Mery grown, who delegated it to Tim Marvin. This process has worked fairly well on routtne data requests but on non-routine 1 tees. It has been an tapedfaent. i As an exang,le. I was alerted that we were to receive an update of the draft TAC report on Nuclear Operations during the wec of April 10 - 14. The responsiblitty for that report. Its nview, Art Dooby had and rebuttal testimony had been assigned to me. h been helping me. Early during that week. Art called Toe 5eckhas the and Ken McCoy and had told thee that, when we received report, we would need technical assistance - In a short time frase - in reviewing the report and in preparing for a meeting
)
with the PSC. Friday, about noon. April 14 I received the report and Art asked as to call McCoy and Beckhas to alert them we needed the ) and the meeting with technical assistance on Monday, April 17
- 19. My PSC staff and consultants would be held on April discussions with Beck.has went well - he was very cooperative.
McCoy said he didn't know what ! sas talking about and said he
) hadn't talked to Domby in weeks. Donby reaeobers his call because he had to have McCoy tracked down at Plant Vogtle. ) 3
1 __ _ )
) .
. l
. j I : ; I don't know what happened in Stratagham. I received a call from fla Marvin raising hell that Art and I had called a Vice ) President. Mcdonald called a meeting. I received a call free Dwight , Evans who said Mcdonald was trate and I had been taken offthiTACreport. I was later told, though ! can't prove it
[j- ' i(( to be' 'true, that the Vice Presidents of Georgic Power on the
$0N0PCO Project were told they could not talk to es or Art Domby. )
In Mr. Dahlberg's meno of December 27 he stated that the interface at Georgia Power with the Nuclear Operations group in , , Birmingham would be George Head and as (see Attachment A). The
) interface we have had with thee, except for routine data requests, has been neg11gible. In fact It has been prohibited.
Yet, $0N0P00 Project personnel are not so inhibited. See meno
) (Attachment 5) from Sob Gilbert dated April 20, 1989. Note that George Head and I were not copied on the meno.
In discussing the establishment of Nuclear Operations Contract Administration, I was told that Mr. Head and I would review and
)
approve the $0N0PC0 Project budget. However, Grant Nitchell of Corporate and Financial Planning at $0N0PC0 doesn't agree. See { page 3 of aseo (Attachment C) from G. Mitchell dated April 20, 1989. Neither George Head or I received a copy but it is in '
)
direct conflict with what the President of GPC has stated. It is also in conflict with what 50N0PC0 agreed with the Joint Owners. I also found that first paragraph on page 1 of that - some interesting. Had Georgia Power personnel sent out these
) two meses, $0N0PC0 would have raised hell.
i
)
e i e I
~
1 meg [ ygg fjrst named to 3, faterfarf aa with other Cpc Fumettaan; this job, we had a meeting in which I was assigned by executive h management certain responsibilities.
$1 ace then, Mr. Mcdonald has objected to several of these assign'oents and I have been removed from poetings or rette not because GPC annagement agreed, but in responsihtllties.
order to get cooperation free 50N0P00. What we need is for $0N0PC0 to support us and cooperate with us and allow Georgia Power management the right to deterstne who
) does what.
Our management and other GPC people will be held accountable for our regulatory affairs effort. We need Unfortunately in
$0N0PCD's support and then 1&t us do our jobs.
several examples, Mr. Mcdonald has interjected himself into
) ,
directions of other company functions and support free $0N0PC0 appears to hinge on his getting his way. suffine: When we established NOCA, I told George Head we
- 4. accountants, and two a sanager, secretary, two
) needed engineers. He agreed to start out with one performance accountant and one performance engineer and revisit the staffing He later added another Isvel as the wort load increased.
accountant. , 3 kck in January, I called Ken McCoy to ask if I could talk to Mike had done a Mike Sarker about the performance engineer job. stellar job for se prior to going to 81rataghas and was well I said I had not
) quallfled. Ken asked if it were a prometton.
He said if 1t were a had the job evaluated yet and didn't know. promotion, $0N0PCD would not object.
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[ 1 . '
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i a 1 had a job description done by Personnel and it was deterstned to be a Level 13 job - one stop promotion for Mike Barker. Mr. Head approved the job descriptica at that level. D ,I told George Natrston about this la the GPC cafeteria later and relayed spy conversation with McCoy, but he would not give ne permission to talk to Mike Barker. I called the Administration , I people at SQM0PC0 and asked what the rules were. They said they were told 1f it were a promotion, management would give 1ts , l permission. ) After talking with George Head, we posted the job. I selected the best three candidates and they were all free 50N0PC0 - which is not surprising. Our Personnel department was told the request to interview had been approved all the way up to George Hairston. But, there it stopped. Later, our Personnel , 1 department *was told Mr. Mcdonald would not approve the request because he didn't agree that the job level should be a 131 O Although GPC Personnel department and a Senior Vice President at GPC had approved the position. Mr. Mcdonald has held up this request and I have not been allowed to interview these three gentlenes. 3 I need the expertise the performance engineer would bring and the lock of support from Mr. Mcdonald is tapacting my ability to . get the job done. O i 9 . O
,3 . i i ggggggilag: I served on Phase ! of the 50N0PC0 Task Force and was, and as, a real supporter of the Operating Company concept. p In our discussions, Bob Suettner, an attorney with Salsh and l tingham and now a Vice president at Alabasa, safd Mr. Farley was conce'rned that once th,ts operattug company was established, we would. wind up with a group of arrognat, technically trained b etttists that the operating companies would have no control over. I nov respect Mr. Farley's concern more than ! did two years ago. It takes one to operate - two to cooperate. I know that most people at Georgia power want to cooperate with $0N0PC0 and want it to be a success for GpC and the Systes. Sut, there are great ' concerns by many people. D
' A significant concern that a lot of people have is who does Mr.
Mcdonald work for. I have heard discussions on that at'high levels in the Company. It is a very taportant question because the operating licenses for Match and Vogtle are in GPC's name; g for Farley, ApC. ! am not a lawyer or licensing specialist, but I believe both will tell you that it is essential that GPC and APC be in control of these plants. Oglethorpe Power is so concerned that it has formally requested confirmation that Mr. ' Mcdonald receives his annagement direction from and reports to D If that is not the case, we are in violation of Mr. Dahlberg. l our license and could expertence some significant repercussions from the NRC - including the revocation of the licenses. D Oglethorpe is very concerned about this issue and they feet NAC l 1s concerned. A Region !! Mac employee suggested to Oglethorpe l that NAC was so concerned that they alght seek to put a resident taspector in Straingham to see what was going on. 7 D 3 . D
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h e ) p In establishing an Operating Company, the Systes, among other things, sought to open up the opportunity for us to run'other utt11 ties' power plants under contract. Ne shoeld now be operating in that mode - subject to meeting license
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condt tions. There are some possibilit16s la the Industry now and we ought to be giving serious considerations to how we
;,,, operate now so that, should we get through the legal hurdles and be given permission to expand outside our service area, we will be ready to aggressively pursue these opportunttles. Sut, I really doubt any utility would be interested in contracting with $0NOPC0 if .their expertence with the contractor was going to be similar to Georgia Power's. )
Fred, there are other issues relative to SON 0PCO, leprtant to the Systes, that needs to be addressed. I have asked repeatedly for an opportunity to discuss these with senior annagement. ! hope we wt11 get that opportunity soon and can work toward a
) more cooperative relationship with $0N0PCO.
' JYb,,:1hOL l
,.1.,oh.y %. % th.k G. f. Need Ibla
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say i.. i... 5 ,y, , M. 3. Hobby g, F. D. W1111ame f - p ga response to your questione in your letter of April 23, gggg, I have the following reply.- Mr. p. p. Mcdonald reports to A. W. Dahlberg i tionfor operat I have i and support activittee of Plante Vogtle and I chart showing the reporting. ) gr. Mcdonald. Mr. J. M. Farley, Executive Vice President - Nuclear, f i f provides services relating to the anticipated trans er o j nuclear operating and support activities from These Georg s Powe I
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Company to the Southern Nuclear Operating Company. L services include the compliance with applicable regulatory J requiremente and for nuclear support on an industry basis Jde Attseha*at 5 l ( 2- P
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