ML20078P519
| ML20078P519 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/01/1995 |
| From: | Bockhold G SOUTHERN NUCLEAR OPERATING CO. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| EA-94-037, EA-94-37, NUDOCS 9502170105 | |
| Download: ML20078P519 (4) | |
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>*3 Taliphona (205) 877 7437 Southern Nudear Operating Company o.org. aocanoia General Manager Nuclear Technscal Services I'C '.outtom ekv.: tic systern February 1,1995 Mr. James Lieberman Director, Office of Enforcement i
U. S. Nuclear Regulatory Commission Washington, D. C. 20555 RE:
Georgia Power Company, Vogtle Electric Generating Company Units 1 and 2; NRC Demand for Information Regarding George Bockhold, Jr. (EA 94-037)
Supplement j
Dear Mr. Lieberman:
t On August 5,1994, I submitted to you my personal response to the Demand for f
Information sent to Georgia Power which concerned my actiou un several occasions in April through August,1990, in providing information to the NRC. As indicated in my prior response, I met with the Senior Vice President of Georgia Power and my immediate supervisor at Southern Nuclear and we collectively reviewed my actions and responsibilities with respect to these events. We discussed my personal performance failures to assure that I carried out my responsibilities. Those responsibilities as a mzaager included a responsibility l
to assure that I understood the factual basis of the informanon which is communicated to the NRC. In my personal response to the Demand for Information I did my level best to explain the facts and circumstances surrounding these events and to convey to the NRC the reliance which I placed on others because of my position as General Manager. I also concluded that i
I did not believe that I could have reasonably been expected to have foreseen the inaccurate i
or incomplete information provided to the NRC. As a result of settlement discussions between counsel for the licensee and counsel for the NRC Staff I understand that the Staff, after additional review of my response to the Demand for Information and other information, remains concerned with a perceived unwillingness on my part to accept responsibility for my I
role in these events.
The events since 1990 have had a profound impact on me. Aside from the purely personal impact, the events of the last several months have helped me identify my capabilities and weaknesses. I am more appreciative of your perspective now than I was when my DFI Response was filed. Indeed, that filing was my ficst opportunity to state my views to you in writing and it is clear to me that I did not convey uy heartfelt realizations that certain of my traits - which in 1990 I viewed as only strengths -- can be perceived as major weaknesses.
Why have I apparently failed once again to commmdcate my intended message to the NRC7 I
D 9502170105 950201 PDR ADOCK 05000424 p
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Mr. James Lieberman Feb;uary 1,1995 Page Apparently by focusing in my DFI response on the actions which I considered reasonabic at the time, my perspective appears defensive, self-serving, and, to some, may border on being arrogant. Let me state plainly that I accept personal accountability and responsibility for my actions and regret any perception of arrogance. I was the Plant Manager and both the benefits and burdens of that office are mine to shoulder. This letter emphasizes my awareness and acceptance of my performance weaknesses and failures which, in the context of providing information and fulfilling legitimate expectations of the NRC, contributed to Georgia Power's noncompliances in 1990. I hope diat it unequivocally shows that my DFI response was not intended to justify my performance in 1990, or treat lightly the importance of accurate communications with the NRC.
Even though a general manager must delegate specific tasks in the gathering and collating ofinformation to be provided to the NRC, he or she has an overriding obligation to understand the factual basis of that information. In retrospect, I failed to ensure that the data provided to me was the information which I asked for and intended to present. I did not have an adequate understanding of the numbers, and I cannot recall obtaining a detailed explanation of what the numbers specifically represented. I also realize that while it was not significant to me whether there were 19 or 12 stans on the IB diesel generator, the difference of those two numbers, in the context of a decision on the restan of a nuclear power plant, had the capability ofinfluencing the agency. Viewed from the NRC's perspective, while I would have been satisfied with 12, the controlling issue is whether such a number would have satisfied the NRC.
With respect to the April 19,1990 LER, I relied upon the prior count used on April 9.
Instead of reinforcing my staff to complete their verification of diesel stan counts, I now realize based upon information not available to me in 1990, my statements contributed to a j
lax verification effon. More significant, however, was my reliance on my own analysis that since I believed only " successful starts" were included in the April 9 data and the data reflected activities after overhaul and sensor calibration and logic testing, any " problem" starts would be excluded from the count. This was an extrapolation from my understanding rather than a complete reexamination of the underlying facts. As a genent manager, knowing that the information was to be communicated to the NRC, I should have cpplied a higher standard of care. I agree with the licensee's judgment that I acted unreasonably whan I allowed the j
term " comprehensive test program" of the control systems and the earlim &t coud to be included in the LER knowing that my staff had not completed their verification effort.
Licensee Event Reports are important documents which must be verified correct by practices designed to assure that they are as accurate and complete as they possibly can be.
With respect to the June 29,1990 cover letter, I could have done more la this situation
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Mr. James Liebennan Fetyuary 1,1995 Page to assure a more complete document. I reviewed and approved this letter. The cover letter as I interpreted it was consistent with my personal knowledge. I do not recall a specific opportunity to step in and resolve the matter of the meaning of " comprehensive test program of the control systems" prior to June,1990. Nonetheless, given the normal LER approval process and the June effons of the SAER group, I conceivably missed an opportunity to rectify any misunderstanding associated with that phrase. I should have told the drafters, and the cover letter should have specifically indicated, what my original meaning of the phrase was at the time. Had I assured that their information was complete, we collectively might have recognized that the correction of June 29 did not address and correct the underlying problem in the April 9 letter.
Finally, in my personal Dil response, I stated that the language of the August 30,1990 letter cannot reasonably be constnied as identifying one of the causes of the error in the April 9,1990 letter as the counter's confusion in terminology. On reflection, it would be reasonable for the NRC to conclude otherwise. It is clear that I directed the modified wording in this letter. Unfortunately, the wording was subsequently interpreted by the NRC as stating that the start counter's confusion caused the error in the April 9 letter. Therefore, I, personally and solely, am responsible for this inaccuracy which the NRC has concluded is present in this letter. In this instance, I should have permitted greater care and a fuller aniculation of the matter by those who had takee the time to comprehensively review the issue. I had no greater ability than they in crafting a precise, clear and understandable letter.
It was an important matter and my actions should have been more cautious.
I appreciate that the NRC is dependent upon licensees for the accuracy and completeness ofinformation, and must have reasonable assurance of my willingness to conduct 1
my activities in accordance with all NRC requirements. Since providing you with my personal response, Georgia Power has concluded that I acted unreasonably when I allowed the term
" comprehensive test program of the control systems," to be associated with the diesel generator " start count" provided to me in early April to te included in an April 19, 1990 LER. I stated in my personal Demand for Information tesponse that I have learned a valuable lesson from this experience; it has been underscored. I also stated fut my performance over the past several years has reflected this lesson learned. My performance today, over four years after the underlying events, reflects a more mature person who is open to contrary views and cautious in formulating conclusions.
I recognize that I do not know as much as I sometimes used to think I did. I would like to continue to be employed in my present position providing support to the plants until such time as I have reacquired the confidence of the licensee and my employer. Based upon recent events, I understand that additional assurance is also required by the NRC.
c ::
Mr. James Lieberman Feb uaiy 1,1995 f
Page,
To provide this additional assurance, I have requested my employer to provide me with an opportunity for intensive training in two areas: a manager's obligations and responsibilities in the nuclear industry and as a communicator with co vorkers and regulatory agencies. I will notify you afler I have completed this effort. I have also requested that my immediate supervisor meet quarterly with me to review my prformance in the areas of communication effectiveness, attention to detail, accountability for actions, and any other standard which my employer identifies. I will not seek a line management position over licensed activities at any nuclear plant licensed by you until after satisfactory completion of this training. Thereafter, ifI am nominated hr a position in line management within three (3) years of this letter, I will inform you of that nomination at least sixty (60) days prior to assuming the position. With these additional steps on improving my management style, and reinforcement of my current sensitivity to the very high standard legitimately required of the NRC in communications, the NRC can have confidence in my involvement in licensed activities in the future.
Very truly yours,
/e/a k George Bockhold, Jr.
xc:
U.S. Nuclear Regulatory Commission Mr. S. D. Ebneter, Regional Administrator Assistant General Counsel for Hearings and Enforcement xc:
Georgia Power Company Mr. H. A. Franklin Mr. W. G. Hairston, Ill Mr. J. D. Woodard xc:
Southern Nuclear Mr. L. B. Long i
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