ML20078P634
| ML20078P634 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/08/1994 |
| From: | Kohn M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | |
| References | |
| CON-#494-16070 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9412190118 | |
| Download: ML20078P634 (83) | |
Text
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!60 NTED CORRESPONDENCE 00CKETED USNRC
'94 DEC -8 P3 :43 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION .
ATOMIC SAFETY AND LICENSING BO .
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. . .C;f.9.
Before Administrative Judges: N Peter B. Bloch, Chair Dr. James H. Carpenter Thomas D. Murphy
)
In the Matter of )
) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 c1 L , )
) Re: License Amendment (Vogtle Electric Generating ) .( transfer to Southern Nuclear)
Plant, Unit 1 and Unit 2) )
) ASLBP No. 93-671-01-OLA-3 EXHIBITS TO INTERVENQR ' S PREFILED TESTIMONY Michael D. Kohn Kohn, Kohn and Colapinto, P.C.
517 Florida Ave., N.W.
Washington, D.C. 20001 (202) 234-4663 Attorney for Intervenor C:\ FILES \301\covtR.TST 9412190118 941200 PDR ADDCK 05000424 0 PDR )$D3
1 e EXHIBIT 1 1
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VDGTLE PROJECT /V0GTLE DUTY MANAGER SCHEDULE Project On Call Vogtle Response D.ilt Protect Manaaer Duty Manaaer lgag 4/ 2-4/8 L. A. Ward J. E. Swartzwelder B 4/ 9-4/15 W. 9. Shipman W. F. Kitchens C 4/16-4/22 P. D. Rushton A. L. Mosbaugh D 4/23-4/29 C. K. McCoy G. Bockhold, Jr. A 4/30-5/6 L. A. Ward J. E. Swartzwelder 8 5/ 7-5/13 W. B. Shipman W. F. Kitchens C
__5/14-5/20_ P. D. Rushton A. L. Mosbaugh 0 5/21-5/27 C. K. McCoy G. Bockhold, Jr. A 5/28-6/3 L. A. Ward J. E. Swartzwelder B 6/ 4-6/10 W. B. Shipman W. F. Kitchens C 6/11-6/17 P. D. Rushton A. L. Mosbaugh D 6/18-6/24 C. K. McCoy G. Bockhold. Jr. A 6/25-7/1 L. A. Ward J. E. Swartzwelder 8 7/ 2-7/8 W. B. Shipman W. F. Kitchens C l 7/ 9-7/15 P. D. Rushton A. L. Mosbaugh D 7/16-7/22 C. K. McCoy G. Bockhold. Jr. A 7/23-7/29 L. A. Ward J. E. Swartzwelder B 7/30-8/5 W. B. Shipman W. F. Kitchens C 8/ 6-8/12 P. D. Rushton A. L. Mosbaugh D 8/13-8/19 C. K. McCoy G. Bockhold, Jr. A j 8/20-8/26 L. A. Ward J. E. Swartzwelder 8 8/27-9/2 W. 8. Shipman W. F. Kitchens C I 9/ 3-9/9 P. D. Rushton A. L. Mosbaugh D Project Response Teams: I Position Team A Team B Team C Team *D* Pacer # ,
Dir. Corp Resp. Bailey Ward Shipman Rushton
- GOOC Mgr. Walker Badgett Ajlunt Cobb 6034 4 Eng. Sves. Mgr. Miller Williams Bush Burr 6035 Admin / Log Ngr. Rollins Cardona Copeland Barker 6038 Rad Assess Mgr. As designated by Manager Environmental Services 6030 1 I
- Pager numbers: Bailey 7097; Ward 6047; Shipman 7104; Rushton 7103 1
xc: M. J. Aj1unt W. G. Copeland G. Bockhold, Jr. l J. J. Bad ett C. C. Miller, Jr. D. M. Hopper 1 J. A. Bai ey A. S. Rollins T. J. Kirkham J M. D. Barker P. D. Rushton W. F. Kitchens 1 K. S. Burr W. B. Shipman A. L. Mosbaugh l R. J. Bush H. P. Walker D. D. Rickertsen i A. E. Cardona L. A. Ward A. C. Stalker e !
E. F. Cobb J. A. Willtaes J.E.Swartzwelderj i43 Exhibit I ,page I of I j
_ - - - - - _ - _ _ - - . -_ - - )
6 EXHIBIT 2 i
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TELEP110NE LIST - ON-CALL PROJECT MANAGER M
Hase/ Title Work Phnag flome Phone Mobile Phone BeeoY-DIRECTOR OF CORPORATE RESPONSE *
- 1. W. B. Shipman, General Hanager 8-821-7104 1-205-991-8001 1-205-936-6760 Nuclear Support ** 54104 -
1-205-877-7104 q
- 2. P. D. Rushton, Manager B-821-7103 1-205-985-4879 Kuclear Engineering & Licensing 1-205-877-7103 -
- 540413 5
m
- 3. J. A. Bailey, Manager 8-821-7097 1-205-823-1125 Licensing ** 54043 1-205-877-7097
- 4. L. A. Ward, Manager 8-821-7802 1-205-995-4757 Huclear Haintenance Support ** 54049 1-205-877-7802 -
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GEORGIA POWER COMPANY CORPORATE MANAGEMENT
- 1. Joseph H. Farley B-821-5513 1-205-879-1572 1-205-531-0328 Executive Vice President-Nuclear 1-205-868-5513 1-205-868-5479 The Southern Company
- 2. R. P. Mcdonald Biminohan. AL Executive Vice President- 8-821-5540 1-205-879-9589 Huclear Operations l-205-936-2706 *** 5540 1-205-868-5540 Alabama 1 Georgia Power Companies ** 54090 Atlanta. GA 8-526-3848 1-404-526-3848 3
63 .
4th Quarter,1989 a
TELEPHONE LIST- ON-CALL PROJECT MANAGER (continued) tiame/ Title Work Phone Home Phone Mobile Phone Beener 4
GEORGIA P M FR COMPANY CORPORATE MANAGEMENT (continued) l 3.- W. G. Haltston, 111 8-821-5581 1-205-991-8188 1-205-936-2712 *** 5581 (Ala)
Senior Vice President 1-205-868-5581 1-205-991-7731 ** 55581 .
Nuclear Operations (unlisted) (Atlanta /Other Major Cities OutsideAla)
.4. A. W. Dahlberg, President & CEO B-526-6000 1-404-270-1832 1-404-697-1893 Georgia Power Company 1-404-526-6000
- 5. J. T. Beckham, Vice President 8-821-7279 l-205-995-4780 1-205-936-7299 ** 19636 Hatch Project 1-205-877-7279 -
- 6. C. K. McCoy, Vice President 8-821-7122 1-205-362-7113 1-205-936-6892 ** 83286
.Vogtle Project 1-205-877-7122 , *** 7122 y **** 304 PUBLIC INFORMATIi)N MANAGER *
- 1. G. K. Van Moi, Directer 8-526-7470 1-434-963-9848 1-404-281-2903 Corporate Communication 1-404-526-7470 1-404-467-2687 (Weekends)
- 2. N. R. Harris 8-695-3630 1-404-796-0151 1-404-828-6059 Public Affairs Coordinator (Vo9tle) 1-404-826-3630 (Both at Vogtle)
- 3. J. E. Varner B-526-7480 1-404-251-5516 1-404-898-4564 Communications Services Manager 1-404-526-7480 63 4th Quarter, 1908 f
N TELEPHONE LIST - ON-CALL PROJECT MANAGER l (continued)
Wi f Name/ Title Work Phone Home Phone Mobile Phone jagggt I
JOINT OW ERS q
- Contact one representative from each, starting from the top of each list.
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- 1. OGLETHORPE POWER CORPORATION 9
M E. J. Toupin. Superintendent 8-695-3401 1-404-863-7215 I Nuclear Operat1ons _h ****Vogtle/240 1-404-724-6221 D. H. Smith 1-404-621-3091 1-404-381-8951 Operator 1-404-496-7600 I
- 2. HUNICIPAL ELECTRIC AUTHORITY OF GEORGIA -
T. W. Loria 1-404-952-5445 1-404-452-7196 Manager of Generation Planning Ext. 206 f Mack Secord 1-404-952-5445 1-404-252-3861 Ext. 204
- 3. DALTON UTILIllES DeForrest Parrot, General Manager 1-404-278-1313 1-404-278-1561 V. D. Parrot, Jr., Consultant 1-404-278-1313 1-404-278-5395
-. 63 4th 4sarter, let r- -' -
8 e-EXHIBIT 3
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C e TAPE #259 side A, 5%
Daily OSI Damage Control Meeting 2nd floor Admin Bld., Plant Vogtle, Large Conference Room 8-17-90, Approximately 10:00am Bockhold, McCoy and GPC personnel assigned to OSI white paper responses Discussion of NRC OSI team comments to GPC regarding Tech Spec 3.0.3 and GPC actions to comply with TS 3.0.3 to shut down plant upon entering TS 3.0.3 (" Motherhood"). TS 3.0.3 applies to conditions where the status of plant safety equipment and margin of safety is even less than that addressed by normal Technical Specification action statements and requires immediate shutdown.
McCoy: The other thing is he got into this business about there's some examples and (inaudible) hear it now or hear it there and he got one example in particular where we went 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> into a 3.0.3 without taki:ig any action, power reducing. They ask George how long would you go without reducing power.
Bockhold: And George told them that depending upon the situation I might go as long as 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> before I had to shutdown. He didn't like that at all.
McCoy: He said, "Could you do a controlled shutdown?"
Bockhold: I said absolutely, no if, and's, or but's about it.
McCoy: We had lots of discussion on that.
Bockhold: I'd get power right down off the reactor and hell, trip at 20%. Manual trip.
McCoy: So anyway all of that--
Bockhold: I didn't bring up the manual trip because I think that would have ended up in non-conservative decision making, manual tripping--
McCoy: They're going to write this up (inaudible)
Bockhold: The uh, What set them off on this was is that i one individual said " don't have to do I anything." l l
McCoy: " Don't do anything for three hours." l I
Exhibit O ,page I Of d I
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Bockhold: For three hours. That's really got them, got their motor going.
McCoy: And they, and they went back and said when we started talking we tried to say we'll that's not true and we immediately call the Duty Manaaer and the Duty manaaer calls the Executive VP and he calls the President of the comoany when you cet into one of those situations if there's a threat of a shutdown, in addition to that, we notify the load dispatcher and all that, that's routine practice and everybody knows that and he said "that's just a lie" he didn't say it in those words, but he said we both sat there and this shift supervisor told us he'd do absolutely nothing for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Swartzwelder: They talked to they talked to many people.
Bockhold: The one the one--
McCoy: This is the one guy the one guy, anyway so we, we uh, we drew our battle lines.
C:\ FILES \301\fAPE.259 Exhibit 3 ,page 2 of d
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EXHIBIT 4
i E MOSBAUGH TAPE No. 260, SIDE A (Partial Transcript based on hand written corrections of Steve Chestnut)
Mosbaugh: Speaking of the duty manager, there was a funny comment made in the meeting down there this morning by McCoy about , uh, the shift supervisor calls the duty manager, the duty manager calls the corporate duty manager calls the president of the company.
Aufdenkampe: [ Inaudible]
Mosbaugh: He calls the VP? And the VP calls the president of the company?
Aufdenkampe: [ Inaudible] Yea, I thought that was interesting.
Chestnut: The president of the corporate company for Georgia Power or Alabama Power. Your talking about
[ inaudible).
Aufdenkampe: [ Inaudible)
Chestnut: Sure.
Mosbaugh: I just -- thought that -- I have been involved in the duty mauager and I never -- and I think I was aware of what the communications path, was and I just don't think that's what's happened -- what happens. I just -- that was just real interesting to me.
Chestnut: That seems kind of surprising to me, too.
Mosbaugh: Who are they calling? I mean, if I call --
if I call, you know -- if I call --
Aufdenkampe or Chestnut: [ Inaudible]... engineering duty... [ inaudible]
[ PHONE CALL INTERRUPTING CONVERSATION)
Aufdenkampe: [ Inaudible)
Mosbaugh: I mean, if I call Shipman --
Voice: [ Inaudible)
Mosbaugh: You know, if I call Shipman or something, then Shipman usually will say --
[ INTERRUPTING PHONE CALL ENDS]
Exhibit._S,page I of 2
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Mosbaugh: Okay. You know, I call, I call Shipman and then Shipman will sometimes talk to McCoy or to Hairston-Chestnut: Um hum.
I Mosbaugh: But that was the extent of --
Chestnut: There are a lot of calls to Farley. I know they called Farley a lot.
Mosbaugh: They who called Farley?
Chestnut: The VP. q i.
Mosbaugh: Oh. They're calling Farley? )
l Chestnut: Yeah. A good bit. I know they call Farley a lot.
[ But it wasn't until recently I started hearing this j thing about them calling --
about calling -- I I
can't imagine them calling Dahlberg because Dahlberg probably knows how many plants he has, but he doesn' t know which ones are running (inaudible) .
Jim M2.ller paid attention to which plants were running and,a nd the status of them, but I think Dahlberg is more concerned about the market.
l Mosbaugh: Yeah.
Chestnut: How much power we sold.
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Exhibit i ,page 2 of M
A 9 EXHIBIT 5
r-TAPE #236 side A, 50%
Bockhold Staff meeting (Ken McCoy also present) 2nd Floor Admin Bld., Plant Vogtle, Large conference Room 8-6-90, Approximately 11:30 A.M.
- Beasley: Next week we intend to issue Rev. O of the outage schedule (inaudible)
McCoy: Let me make a comment again and be sure that everybody understand this because uh, there's been some discussion in some of the other olants in SONOPCO that we're not adherina to this and uh, so we had some discussions at the hichest levels includina Mr. Farlev, Mcdonald, Hairston and uh, the three VP's about our schedulina philosochv for outaces. There was some discussion about what was meant by " optimum" you know, we say that we schedule everything to an optimum schedule and there was not a common understanding of what " optimum" means uh, and that was, that was the thrust of the discussion. And we all have to have confidence in each other that that's not going to be used against us or whatever and everybody understand what that means and so the conclusion of that discussion was that " optimum" means the basically.the shortest schedule that you are able to do something in.
Everything goes right. Everything falls into place right. That you do not put any contingency or extra time in there and uh, after lots of discussion everybody agreed that that was he right way to do the scheduling. So uh any comments or thoughts on that?
can usuoimmu6.4 1 1
1 Exhibit 5 ,page I Of I l
e O EXHIBIT 6
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i TAPE #259, side A, 75%
Daily OSI Damage Control Meeting 2nd floor Admin. B]d. Plant Vogtle, Large Conference Room 8-17-90, Approximate'v 10:45 A.M. l l
McCoy: The flavor there, is that there is devisiveness within the organization, the same thing is true between departments in the plant (inaudible) we are open and we talk about problems between corporate and the plant (inaudible)
Voice: (inaudible) they basically created a data base.
McCoy: And so what I'm getting to -- I agree with that, that's a good way to get things straightened out, and, but you need to grow to the point that we're just like a family and we may fight among ourselves but when external to -
- they go out, someone brings something up externally 4 or something like that (laughing) and uh, we uh, stand up for our reputation and we all pull together and we all are party to, that's the issue. I think that's the important thing. (inaudible) We would not, we would not, encourage you to talk at all about how you feel about our policies and uh, we can talk to each other about our problems and that sort of thing. But if, but if, somebody external to us says, uh: "what do you thing about those corporate guys?" or something like that, you tell them: "you got the best corporate uh, uh, organization in the world" that's what you tell them externally, then you get on the phone (laughing) and say: "you guys are not getting, or whatever the problem is." I think you all understand the context of what I'm talking about. I'm talking about (inaudible)
What led us into this situation is coming, is coming from divisiveness.
Horton: I would just say, Do we know very clearly why they came?
McCoy: Yes. There is two things, one is to investigate allegations.
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1 EXHIBIT 7
fl0V 16 '94 10:33PM ALLEf4 L MOSBAUGH p,1}
1990 "1 PPP Su W 'p[u
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loyees t Southern Company Nuclear fmp TO: Partif.ipating in the PPP RE: 1990 PPP SURVEY nt Program -
r Performance Managemecompleted look at its the first recently in implementing ouWe' ve take a harilThe Southern Cos-we (foing par Plan? we need to How well arvthe Performanceplan, now so d opintoes.
including pay d like to have your candiAs part of this ev under theand shortcomings.
and return payout attached questionnaireted in May 1989 %
strengthsManagementcomplete Council wovfthea sfallar study make in the pany minutes to d the we conducneeded
- r. to sanagem a f ew a follow up toeral improvements wesurvey made findings encourage Please take It's we've it promptly survey helped identify sev otentialwill tell us where That m Among aother the sitethings, of pthe surveyneed to t>e the ppP made.
Ar gra . to saweae The IP90 dut, we ask thatthss councilto eight percent. additional te ,povreents lly.
cent improve ments and where responses ntrational will be is listed treated confidentia code, whichareas onourtheformal back ofcan be e h ough you letter, so that employee s' opinions in variousbe communicated to y All employeewrite in your orga wt11 summary of the findings grams. rtant study.
A employee information prorticipation in this impo (h.nk yny for your pa -
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l tt 1 PPP Su yEire ions on the back of this sheese Exhibit 1 ,page I of 3
nov te w to: arm nun t mseam q 1990 Performance Pay Plan Survey instructions: For each item, fill in the circle corresponding to the number that best supreseos how much you agree or disagree with the statement. Answer according to how you see things NOW. Candor and honesty are very important.
Your answers will remain anonymous. To further ensure anonymity, if less than five people's responses fall into a particular job group in your organization, these responses will automatically be included in smother category.
For this survey, use the following definitions of key terms:
- Company - the company for which you work (e g., Georgia Power, Gulf Power SCS, etc.)
- Organization - the department in which you work (e.g., Power Delivery, Human Resourms, Southern Division, etc)
- Work Group - the group to which you are assigned and with whom you work the closest
= Customers - those people who receive the services and/or products you prmide, whether they are the ultimate customer or clients in your company, in other system companies, or external to The Southern Company. ,
IF AN ITEM DOES NOT APPLY TO YOU, LEAVE IT BLANKl Fill in the circle that corresponds to your choice using a # 2 pencil. Use the scale below as a gulde:
s=w w w s% w se- oe s= w m e. nnw .
O O O @ O O wa * .
- 1. Poople treat each other with mutual respect (AGREE) @$
- 2. The Strategic Plan is easy to understand (DON'TKNOW) @@
a I am inspired by having an opportunity to compete in difficult contests (STRONGLYDISAGREE)
}.I ORGANIZATION CODES SONOPCO PROJECT / NUCLEAR GENERATION PLACE APPROPRIATE NUMBER IN THE BOX ON THE BACK OF THE OUESTIONNAIRE.
p w 700 Officers, Genoral Managers' 740 Plant Hatch 710 Administrative Services 745 Hatch Supper 6irwerness 40
- and Strategic Analysis 750 Plant Voges . .
]
720 Technical Services 755 Vogtle Support 6twemese 40 ,
730 Plant Farley ..
735 Farley SupportInverness 40 .. ,
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- All offcers, General Managers, and Directors shouM use this code. These indtv6duate shouWnot use the other codes. 1
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- Exhibit 7 ,page O Of _d #: 4 l
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I NOV 16 '9410t38PM ALLDi L NOSBAUGH .
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. a sewer ages sessier esens, omey= se.# o ,a ss
" **"**" '=*" '"
00 NOT FOLD OR STAPLE THIS ANSWER SHEETI l
G G G G G O t - m-* y
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In General:
4? I am paid faith enmpared with other emplovees in rny Mpany who O EtIrie i M Emplo3eca are sen.o led 19 .u.pninig neu skilN @@@@
8*I @
l 1A Written inforenstinq on tbc PPP h.1* helpad me tn undersdind the p ,
' W I knou u ho my ru tomer are @@@s fil Employee = are afraid in inu an opininn that menacemed onesn't Mr 6 8I @
K! There use rl:n e ne ways i. r en pi"3 es to losinall> pattnipate in solving prnblems for the cottipeny @@@@
M There b e. .d 'esmuork betu*en en unrk gneup and othe work gmeY.. It is 4" @
.48 lb,ple m any neganuanon tru<t each other @@@8 Si l'nnecewry ch:inFe la ex marrimr nitbin nur cornpany I W II @
M The olin er of in3 ..inp.ui3 .ne an.ue of the problem. at m3 lewt @@@@
$7 When I make surpwtvina for imprm ement. I am ignored I 'W '
I W There W pioit up amt dou n ronnuano ation ihmughnut the company @@@@
I T W'I @
M I was gavn the f rninves I n.a..d d to make the PPP work 60 t u as visen tiaining in how t. wt ellw tne goals @@@@
61 Increasing competition repre ent* a MA MR threat to nur3 crimpany 'W*
II @
tM Manager, u cit ta,t s. ai - en w> it.ac.a in inipros e the operation of t he orgamtation '@@@@
63 The PPP sv.piire= r. . much P sperwnrtr T' 6W 9 ' @@
ti4 I u oulet hke t.. < onI aoc u..t k mg muter ..ome 3 pc of Itrfor rnance Pay Plan *
@@@@ t M l am afr1id en 6 aice w npour.a thM m3 manuenwnt doc $n't want to hd @
M i unelerstanit bou on ba-. . Gary ine st a-v u a de'ernnned @@@@
67 I undentsnd few mv incentne pm ment was determined l W' I I M i ain satistied w it h rity haw alar > @@@@
69 i am satisfied nIth rny PPP ine ntite pavment I W I The Performance Pa3 Plan has htiproved:
To any ydi xira. ion @@
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- 71. the quahtv of any work 7.! rn3 prmlurt n it.s @@@@
I E II @
71 rny or1rantzalson's perferrnance 74 m) i ontpans % pertoi niane e @@@@
Frvra the code kwested on the back of your letter, fill m your ottanization's code ORGANIZATION CODE Please indicate 3nur .HIH GRol P b3 fillists in the cirric oppo ite the one that applies. UM@
@q )
Ot )O O Nun esempt t es tier n al m tei.irui. iethmeal. etc.) G4 >O O Notrunet s e."r> rsemPt t et. ensineer. market rep. etc.) GI )G '
O rirst ime supors i-or @v 1e O '.la n iecr
@d >@ i Gi }@
61 10 -b.
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Rt.TL HN % SOON AS PO%lBIE IN A SEALED PRE-ADDRESSED ENVELOPE VIA CUEFANT HAIL
- OR l'SE l!A Company /kk6ess. US Mail Address 1990 PPP Survey 1990 PPP Survey Souciem Company Servces Bn e4000 SCS Bamingham PO. Box 2025 Ermingharn. AL 35202 Exhibit 1 ,page 3 or 3 _
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'r EXHIBIT 8
ROV 16 '94 102 34Ph ALLEti L f10SEMTiH
~1 1990 Performance Pay Play Survey .
Optional Comments Your responses may be typed or legibly written by hand.
l Plonco chw:k your company
( ) M.u.a sippi i suor ( ) Ronlinnn Cu, Servkas 1
( ) Alabamu INwue
( )Coorgia Thwor ( ) Savannah Electric ( ) SONOPGU Project
( ) Gulf Power Please indicate yotir JGB GAoVP by checking tim appiupuate blank
( ) Nun-vauingt (v.w. cl6ikal, saeretarial, technical, oto)
( ) Non-uupervicory Exempt (*.0. angineer, market rep. etc )
( ) First-line Supervisor e
( ) Munugur I
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Exhibit- T ,page I ofl l
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EXHIBIT 9
TAPE #236 side A, 25%
Bockhold Staff Meeting, with Ken McCoy present 2nd Floor Admin Bld., Plant Vogtle, Large Conference Room 8-6-90, Approximately 11:15 A.M.
McCoy: Uh, George I missed your previous discussion on this, you all may have already touched this but just so everybody is clearly aware uh, the survey has two purposes that was run on PPP, one is to determine for the southern company throughout whether or not the performance pay plan is really meeting its objective whether it is being accepted and whether it is working and whether changes need to be made to make it more effective. That's one objective.
The other objectives is that, you know, we're trying to change the culture, the way we do business in the Southern Company. Uh, to move into an era of, uh competitiveness and of uh each uh, operation like a plant being a profit center ar d those kind of things and to operate in that takes a different kind of business, a different kind of leadership. And so the other area is to determine whether the new leadership culture that the uh, Southern company is trying to get in place is taking place. I think you routed those books around for everybody to look at?
Bockhold: They gave -- I had a copy -- Everybody got a copy of those.
McCoy: You can make your own judgment of where you stand but uh, you know other people are looking at these instruments, these survey instruments uh, all the way up to Mr. Addison himself is looking at all of those and the various -- he looks at them in summarv form for each of the operatina comoanies. SONOPCO beino one of N tho.sg and uh, the CEO's of each of the coeratina companica have to answer to him cersonally on their oerformance iq these, these two areas. So what I'm saying is that these two objectives are both very important to the Southern Company. And George is taking an issue here to dig deeper in because uh when you look at those results we obviously aren't in good shape in either one of them. Try to dig in and try to find out more about what we need to do to change I'd be happy to answer any questions and talk about that George if you have time.
Bockhold: Anybody have any questions?
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h'l6T 1 l
Eaton .
l cho s & Pritchett COURT REPORTER 1 THE UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE 4 ATOMIC SAFETY AND LICENSING BOARD 5
6 DOCKET NOS. 50-424-OLA-3 and 50-425-OLA-3 8 IN THE MATTER OF:
9 GEORGIA POWER COMPANY, et al, 10 (VOGTLE ELECTRIC GENERATING PLANT, ,.
11 UNITS 1 and 2),
la C
13 , i 14 ,
15 DEPOSITION 16 of 17 WILLIAM B. SHIPMAN 18 AUGUST 5, 1994 19 20 21 TAKEN BEFORE: Laura H. Nichols 22 Registered Professional 23 Reporter and Notary Public i
( Shibit l0.oana l n' b/
l 575 Wrk Place Tower 2001 Park Place . Birmingham, Alabama 35203-2793 (205) 252 9152 NAMONAl, wars 1-800-458 6031
- FAX 252-0196
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Eaton 11 1 I l ob & Pritchett COURT REPORTEFl 1 A. --
as opposed to a daily 2 meeting?
3 Q. Correct.
l 4 A. No.
< 5 Q. Do you recall typically that a 6 Monday morning staff meeting was held?
7 A. Yes.
8 Q. And this was a Monday morning l 9 staff meeting of the SONOPCO Project?
10 A. It was a Monday morning staff 11 meeting --
if I understand the one you i
12 are referring to, it was a Monday morning i
- 13 staff meeting of the vice-presidents and 14 the senior executive officers.
15 Q. Okay. And this would be the 16 vice-presidents of all three nuclear 17 plants?
- l 18 A. Yes.
, 19 Q. And in addition to yourself and i
20 the vice-presidents, who else attended?
21 A. I did not attend.
22 Q. Is there any reason you did not l
23 attend?
j Exhibit iO ,page d of_E I 575 lbrk Place Tower 2001 Park Place . Birmingharn. Alabama 35203 2793
) (205) 252 9152.NanoNALwars 1-800-458-6031. fax 252-0196
\ .
. _ _ _ - _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ - - _ _ _ __ _ _ - - _ - _ - - - ------a
( . _ . _ _ -
, . v? .
Tyler 1 l l Eaton l $c$o s & Pritchett COURT REPORTER 1 A. I was not invited. It was a 2 meeting for the vice-presidents and the 3 senior executives, senior executives 4 staff meeting.
5 Q. Now, there would also be a i
6 morning call; is that correct?
l 7 A. Yes.
8 Q. And were you typically in 9 attendance at the morning calls from the 10 plant?
11 A. There was a morning call each 12 morning, and, yes, I was typically in 13 attendance.
14 Q. Can you tell me in the last 15 thirty days how many of those days you 16 have been into work?
17 A. In the last thirty days?
18 Counting today, probably eight or nine 19 days; I am not sure --
I would have to 20 look at the calendar --
at least part of 21 the day.
22 Q. Are you still performing your 23 job function, or is there someone else Exhibit IO ,page 3 cf 6
\_ )
575 Park Place Tower 2001 Park Place Birmingham Alabama 35203 2793 (205) 252-9152
- N.TIlONAL wMS l-800-458-6031 FAX 252 0196 j
f
I Tyler 181 1
+. Eaton c of & Pritchett \
.? COURT 4 REPORTER!
$ 1 day, correct, briefing Mr. Farley?
tr 2 A. This is my short-term memory 3 jogger and --
- u. s
' ).
's 4 Q. Okay. And why would Mr. Farley
>p
. 5 be briefed at the end of the day on April
.V .
19th?
- - 6 l
- ,Q 7 A. I don't have the faintest idea
- 1 -
8 now. I read this note probably different
- . 9 than you do. I read this note that Mr.
10 Hairston is going to brief Mr. Farley and 11 that Mr. McCoy wants to have an employee l
12 meeting after that. What the subject l l
13 was, I don't know.
l 14 Q. And why would Mr. Hairston want l 15 to brief Mr. Farley?
16 A. Mr. Hairston reported to Mr.
17 Farley.
18 Q. At this time frame?
19 A. Through Mr. Mcdonald.
20 Q. Excuse me?
21 A. Through Mr. Mcdonald.
22 Q. On April 19, 1990?
23 A. I believe that is correct.
! Exhibit _10 ,page V of A l .
'b-if, N )
575 Park Place her 2001 Park Place Birmingham, Alabama 35203 2793 (205) 252 9152
- NAMONAL wits 1800 458-6031
- FAX 252-0196 e
I <
l Tyler -
Eaton c ol & Pritcliert
- COURT '
1 REPORTERE Q. I am going to ask you to look g 2 at page 15160. And if you see, the date 3 is 5/21/90, and then on 15161, it picks g 4 up on 5/24/90.
5 e [',.
7[ Do you recall whether your J)] 6 notes would have included the days that
- E 7 were missing?
?
', 8 A. This note pad is a thing that I 9 attempt to carry with me wherever I 10 went. Sometimes it got lost. You know, 11 I don't know what happened between 5/21 12 and 5/25. That may be a weekend. I 13 don't know. Do you know?
14 MR. KOHN: Not off the top of 15 my head.
16 MR. HENDRIX: It is not in 17 there. There's not a calendar in there.
18 A. But it is not unusual, you will 19 find, I think, throughout that thing 20 missing days, sometimes several, while my l 21 notebook is missing and I am looking for l
22 it.
23 Q. All right. I am going to ask
'\- Exhibit _lR_ , page.I_ of 6 575 Park Place her 2001 Park Pisce Birmingham, Alabama 35203 2793 *
(205) 252 9152
- NAnONAL Mrs 1-800-458 6031
- FAX 252-0196 g4 .
l 183 Esaton
? $cho s & Pritchett COUFW REPORTER 5 1 you to turn to 15168. And you see
't 2 there's the last entry is Hatch unit 8..
,, 3 one. Do you see that?
J. 1 x
fik 4 A. Yes. l 3 '
j{s 5 Q. On the last hand column and on W l
- .? - 6 top it says Mr. Farley's staff meeting? ,
- .% l
-f 7 A. Yes.
.d 8 Q. What staff meeting are you it 9 referring to?
10 A. That should have been A Monday 11 morning staff meeting that we discussed 12 carlier that Mr. Farley holds.
13 Q. Okay. And then underneath 14 this, it says NOUE declared at 1:38 P.M.
15 Notice of unusual event, is that what 16 that stands for?
17 A. Yes.
18 Q. Do you recollect that this 19 refers to a fire that occurred --
20 A. I don't --
l 21 Q. -- or that there was smoking?
22 A. --
recollect the event at all.
23 I can reconstruct from what is written Exhibit )D ,page b of k
\
.p 575 Park Place Tower 2001 Park Place Birmingham, Alabama 35203-2793 r
~.- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
(205) 252 9152
- NAMONAL W4151800 458 6031 fax 252 0196
F, . 7 EXHIBIT 11 t
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r 77 ;.- --
6,1990
$ .8L II' N8' 7 ,
- Synopsis For nuclear employees in the Southern electric system Emergency plan ...
activated after f~
Ti p@wer failure ,
at Plant Vogtle S Investigations continue into
. the incidents that led to a declaration of a site area emer-gency at Plant VogtJe on March
- 20. The emergency was declared '
at 9:40 a.m. EST because of a ,e , , , . . , , .
loss of on- and off-site power to '
Unit 1 for about 36 minutes. *
' ,'m i Power was restored to essential '
equipment in the plant, and the ,
\,
situation was downgraded to an
- alert status at 10:15 a.m. De
- l emergency was canceled at 1:47 l p.m., acconiing to Ken McCoy, vice president of the Vogtle i Project.
l There was no release of radia-j tion nor any danger to the public. !
All non-essential personnel were assembled and accounted for fol- l lowing notification of the emer-
, gency, ' '
l A site area emergency is -
declared whenever both on- and off-site power are lost for more than 15 minutes. nat condition ,
~
was met after a truck delivering fuel to a portable welding .
l machine backed into a switchyard l pole, breaking an insulator, i causing a cable short circuit.
l which knocked out a transformer supplying electricity to the unit.
l McCoy said that Unit I was I
already shut down for normal refueling operations, which were I about 50 percent complete.
I During such shutdowns, other I
equipment can also be taken out Addison visits Inverness Building 40 of service for maintenance. Under Ed Addison, president of T? Southern Company, prepares to normal circumstances, a second *dd'*** SONOPCO Project magers and supervisors during a recent visit to Birmingham.
l transformer would supply needed I power, but it was out of service to have its oil replaced. W Exhibit ig ,page l - of Q l See POWER, page 3 s ,
ee, 2 Nuclear energy's environmental benefits Growing awareness that by 9 percent; worldwide. nuclear now paying major environmental nuclear energy generates electric- energy offset these emissions by dividends. Nuclear energy now ity without alTecting the atmos- more than 7 percent. generates more than 70 percent of phere is prompting renewed inter- + America's 113 nuclear power that country's electricity.
est in its contributions to units already offset U.S. emis- USCEA reports that France's America's environmental goals. stons of sulfur oxides by 5 million nuclear plants have virtually elim-According to the U.S. Council on tons a year.
Energy Awareness IUSCEA). inated utility emissions of carbon
- Nuclear-generated electricity dioxide. sulfur dioxide and nitro-nuclear energy's role yields envi- now offsets U.S. emissions of ronmental benellts that include; gen oxide: reduced partjeulate nitrogen oxides by 2 million tons emissions of utilities by almost 98
+1n 1989. nuclear generated a year.
electricity offset utility emissions percent; and cut overall utility France's success story See COMMITTED page 4 of carbon dioxide by 20 percent. France's decision. following the Nuclear energy plants of fset total U.S. emissions of carbon dioxide 1973 oil embargo. to start a large scale nuclear energy program is Hatch outage g
, job action Outage work on Hatch Unit 1
- begun Feb.17 - continues uninterrupted. despite a job action by contract employees of 4
Applied Radiological Controls (ARC).
Most of the health physics technicians, hired by ARC to
' , Il assist with the outage work. failed to report to work on March 26.
Their Job action is part of an t.
attempt by the International Brotherhood of Electrical Workers (IBEW) to affiliate health physics technicians across the country.
By early this week, some of the ii health physics technicians who had participated in the job action had returned to work, according
' to Tom Beckham, vice president i of the liatch Project.
Pickets near the plant gate 3 ! have been limited to four, in l accordance with a temporary
, ,' restraining order obtained by
/{ .
Georgia Power last week. Support i for the job action - among plant contract employees who belong to i
l Visitors tour Plant Farley various craft unions - had all
- (From left) Ed Allison American Nuclear Energy Council (ANEC) con * , but ended earlier this week after sultant on high level nuclear waste issues, and Ed Davis, president craft union business managers of ANEC. hear from Chaille Nesbitt, technical manager at Ptant reportedly indicated support for d l Farley, about the plant's Radjonctive Wa.ste Processing Building. the outage work in progress and Allison and Davis toured the plant in March. Photo by Wes Morgan. asked their members to return to ggg
,page Z Exhibit h ofM
Page 3 )
i 1
i l
Power loss causes alert at Plant Vogtle
-- continued from page I responsibility for timely notinca- tions occur," Al Chaffee. NRC One of two diesel generators uons in the future." he added. deputy director, told reporters.
that are normally available to Unit 2, which was operating at Georgia Power is cooperating supply back-up electricity to the normal power, was automatically fully with the investigation, while unit was out of service for mainte- shut down because of power Duc- also conducting its own probe.
nance. The second one started tuations in the switchyard. It did The company has agreed not to brie 0y and then automatically not, however, experience a loss of restart Unit I without the NRC's shut down. Plant operators were power. Unit 2 was restarted approval, unable to restart it frorn the within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> following the trip. As to when the investigation control room and had to start it Unit l's refueling outage, would conclude. Cha1 Tee said. "I locally, originally scheduled to be hope that the outside criteria will McCoy explained that the completed on April 9, will proba- be completed by the end of this concern when power is lost is bly be delayed several days by week, but that might change."
heat build-up in the reactor. With this event and the subsequent The NRC upgraded its investi-Unit 1 out of service, the tempera- investigations. gation into the incident on March ture of the cooling water in the NRC upgrades investigation. 25 to a "high-level inquiry into reactor was about 100 degrees F holds news conference basic operational procedures" at the beginning of the emergency An NRC inspection team on that could affect plants nation-and had increased to only 118 site at Plant Vogtle is looking into wide. The team reportedly will degrees F by the time the site three areas in regard to the emer- investigate the incident and emergency ended. lie said that it gency-the loss of on- and off site review NRC regulauons that allow would have taken several hours power the potential loss of one of two emergency generators for the water in the reactor vessel cooling and the Emergency and one of two transfonners at to reach the boiling point. Had Nottflcation Network, each nuclear reactor to be out of boiling begun in the reactor. The extent of the investigation service during refueling. The regu-steam could have been vented was announced at a news confer- lations apply to all 113 operating into containment. ence at the plant on March 26. nuclear units in the United There was sufncient make up "Our mission is simply to States.
water in a gravity feed tank determine the facts and make The 10 person team is com-nearby to keep the reactor cooled them available to the industry so posed of seven NRC employees to a safe level for an indefinite the NRC can use them to deter- and three industry representa-period of time. That tank has mine what changes might be tives.
manual valves that can be oper- necessary when shut-down opera-ated to start the water flow to the
'""O'o!","A'n' "n"""'u>e Vogtle construction program length of time it took to complete receives induStrV award the notifications required by v emergency operating procedures.
The Business Roundtable an designed to improve construcuon rganization ofleaders from top industry safety performance.
co rt ct I we at r otined of the problem for up to an hour U.S. corporations, has recognized The Vogtle construction because the automatic phone Georgia Power s construction program was also recognized by systems didn't work and each pr gram at Plant Vogtle for the Occupational Safety and agency had to be notified one at a excellence in c ostruction Health Administration (OSHA) for industry safety. safety excellence. The plant was time Ti $e delay was caused in part Georgia Power received the chosen for OSHA's STAR by a loss of electrical power to the aw rd for its entry in the program. which exempted the Emergency Nouncation Network, r undtable s annual Construcuon project from routine OSHA McCoy said. "We will thoroughly Industry Safety Excellence inspections.
review our equipment and proce- Aw rds Program, which is dures for emergency notification to ensure we can meet our of y Exhibit gI ,page 3
Page 4 Committed to environmental principles
-continued from page 2 mental principles, which will be uphold, said Southern Cornpany emissions to between one-sixth ofilcially approved at the April President Ed Addison. "We've and one tenth of their 1980 meeting of The Southern adopted a set of environmental levels. Company's board of directors. principles to reinforce that long-Southern Company's ~Ihroughout The Southern standing commitment."
environmental principles Company, we view environmental A copy of the statement has The Southern Company responsibility as a commitment been distributed to all Southern Management Council has adopted that each of us has a duty to Company employees, a formal statement of environ-ecEC36G5XDB" ocean am STPRTCET A LETTER l
m enwne een m.m x HARtest N .' Y
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O n g
^
C . I h &- Am0 m MY0 -a l
1 i
G kN Synopsis is published twice rnonthly by the Public AfTairs Department of the SONOPCO Project, Jane Henry, editor.
Address correspondence to Bin U.032 Birmingham. ,
l l
l l
l l
l 1
l Exhibit U ,page 9 of 4
l l
l EXHIBIT 12 i
'crformance Appraisal-Individual Development Georgia Power d imployee Name (Last, First, Middle initial) Emp. No. Current Job NoJTitle Hobby, Marvin B. 42784 1232/ Assistant to the Pres./Sr. Exec. VP
> vision / Department Annual Merit Review Date Location General Office / Executive 01/01/88 24/333 Piedmont Avenue
- l. Job Content (To be completed at beginning of review year.) b'l' ',he ddaonaI c "" r jej.' '8 $ ' ""
Accountability Assist the President and Senior Executive Vice President as they Number 1. provide executive direction to the Senior Vice Presidents to ensure that the design and construction, of generating plants are accomplished in an efficient, ef fective, economical, and timely manner.
Accountability Assist the President and Senior Executive Vice President as they Numbtr 2. provide executive direction to the Senior Vice Presidents in maintaining that nuclear and fossil plants are operated and maintained to obtain the highest degree of functional integrity, safety, and reliability.
Accountability Assist the President and Senior Executive Vice President as Number 3. they actively participate in programs that promote company policios and operations to the customers and to confer with other top management of Georgia Power and the Southern SEE ATTACHED Electric System to plan and establish corporate goals, develop SHEET corporate strategy, establish major policies, and make other
- decisions recuired for manufacturina and antivnring n1ncevic .
- nrvien j Accountability Assist the President and Senior Executive Vice President as Number 4. they actively participato appropriately in activities of industry initiatives, such as NUMARC and INPO.
1 Accountability I Number l
l Accountability Number j Accountability Numbr W6th Habits (optional)
?xhibitM , page I Od l
l 1
- 11. Goals with Measurable Performance Standards (To be completed at ti W iginning of review year.) .
Describe how the employee is expected to fulfill each accountability. State the behavior or standard which would describe desired performance.
. Accountability a) Achieve a commercial operation date for Unit I at Plant, Number 1. Vogtle as follows.*
Excellent: By June 1,1987 and within budget of $4.20 billion.
b) Achieve a commercial operation date for Plant Scherer, Unit 3, on January 1, 1987.
Accountability a) Achieve capacity factor at Plant Hatch of 70% or greater. '
Nurnber 2. b) Achieve average equivalent availability at fossil plants of 80.2%
Accountability Number 3, Accountability Number 4, f
Accountability Number Accountability Number .
1 Accountability ,
Number I
Exhibit I1,page 1 ofS i
I til. Performance Evaluation First describe how the employee Is fulfilling or f alling to fulfill each accountability in comparison with the Performance Standards outlined in Section 11. Then rate the employee on each accountability using the definitions below.
EXCELLENT COMMENDABLE FULLY ACCEPTABLE NEEDS UNSATISFACTORY l P rformance exceeds Performance exceeds Performance meets IMPROVEMENT Performance faits to job r:quirements job requirements. job requirements. Performance approaches meet job requirements.
to a significant degree. Job requirements.
Accountability a) Plant Vogtle achieved commercial operation on May _
Number 1. 31, 1987, and within budget. -
X Excellent b) Plant Scherer achieved commercial operation on ^
Commendable January 1, 1987. _
Fully Acceptable Needs improvement Unsatisfactory Accountability a) Through 10/87, Plant Hatch's capacity factor was _
Number 2. 80.43%. At that time, Plant Hatch had the highest -
X Excellent operational availability of any multiple unit -
Commendable BWR site in the world. -
Fully Acceptable b) Through 10/87, fossil equivalent availability -
Needs improvement was 87.8%. Unsatisfactory Accountability Participated in Phase I of Southern Electric System _
Number 3. Task Force on establishing a Southern Nuclear Operat- Excellent l
ing Company and had concept approved by all CEO's ] Commendable of Southern System. Provided concept for proceeding _
Fully Acceptable with Phase II. _
Needs improvement Unsatisfactory l Accountability Intt.3:ted extensively with industry leaders in the _
Number 4. for!!C. ion of NUMARC including structure of the Excellent orga ization, selection of Board of Directors, and eleccion of Senior Staff.
[ Commendaele Fully Acceptable i _
l Needs irnprovement l _
Unsatisfactory l Accountabillty _
Number Excellent l
] Commendaole Fully Acceptable l _
Needs Irnprovemeri Unsatisfactory Accountability _
Number Excellent l Commendable
] Fully Acceptable Needs improvement Unsatisfactory i Accountability _
l Number Excellent Commendable Fully Acceptable Needs improvement Unsatisfactory ELibit i 2 ,page 3 ofl E. l J
IV. Overzit P rf:rm:nca R: ting.
O Excellent @ Commendable O Fully Acceptable O Needs Improvement C Unsatisf actory V. Employeo Development. Describe the employee's strengths, developmental needs, and future growth possibilities.
You may refer to the Skills Inventory in the Performance Appraisal Guide.Then,with the employee, jointly arrive at a developmental action plan outlining steps the employee can take to enhance job performance and personal crreer objectives.
A. Describe the employee's strengths as demonstrated during this review period.
Marvin has an usually broad knowledge of the nuclear industry and key personnel.
B. Describe the employee's developmental needs.
- 1. Management of resources and personnel
- 2. External and internal formal management training.
C. At the present time what are the employee's future growth possibilities? l.a.: within current assignment,in other positions within the department and/or other areas within the Company.
No known limit.
D. Development Action Plan: List Activities which will help the employee irrprove present performance and grow with the company.
Target Person Developmental Goals Action Steps Completion Date Responsible
- 1. Continuation of present assignment.
- 2. Other line assignment in General Office or Plant.
- 3. Formal management training.
VI. Employeo Comments.
t Emp. No. Date ImphiyJN9frlfn
/ 4 2,2 r,a nhIr 7
- % 7 2 7 3 M 8&, 'hM 7 42 # Tiffo incot ' ve upervisor) Emp. N6. Date' ' ~
(
4_ D MSllW }2*$'Vi MY//nn/C&/ NdS-
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EXHIBIT 13
- *. Georgd Power Cornpiny 333 Piedmont A%nue .
Atlanta, Georgia 30308 v y Telephons 404 526 6000 -
Mailing Address:
Post Off ce Box 4545 Atlanta, Georgia 30302
";, y * 'e une uwen ewric s,ue-Chief Executive Othcer ,
December 27, 1988 EXECUTIVE OFFICERS DIVISION VICE PRESIDENTS GENERAL OFFICE DEPARTMENT HEADS DIVISION MANAGERS As you know, Georgia Power Company's nuclear operations group has been relocated to Birmingham, Alabama. We are in the process of working out the agreements with our joint owners to establish Southern Nuclear Operating Company which, when finalized, will contract with us to operate our nuclear plants.
It is important for us to realize that while our nuclear operations may be managed in Birmingham and ultimately will be managed by a separate Southern subsidiary, Georgia Power will be held accountable by our regulatory groups, our stockholders, and the public for the operation and performance of our nuclear units. It is essential that Georgia Power Company be involved in the operations of our units, monitor their performance and integrate nuclear operations goals, accountabilities, and financial planning into Georgia Power Corporate Plan.
Effective immediately, a Nuclear Operations Contract Administration Group is formed to interface with our nuclear operations group in Birmingham. This group will report to Mr. G. F. Head, Senior Vice President, who will be responsible for all nuclear operations interactions.
Mr. M. B. Hobby, Assistant to the Senior Executive Vice President, currently on loan to Nuclear Operations, is named General Manager Nuclear Operations Contract Administration and will report to Mr. Head.
Your support as we move to restructure our nuclear operations group is appreciated.
Sincere' ,
A. W. Dahlberg
/dt !
c: Mr. E. L. Addison Mr. J. M. Farley ,
Mr. H. A. Franklin l l
" -^ Exhibit I3,pagel of I l
4 #
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1 1
14 EXHIBIT l
AFFADAVIT QE THOMAS d. MCHENRY l
The following facts are true and correct to the best of my l
knowledge:
l l
l 1. My name is Thomas J. McHenry and I reside at 3580 Garrards l I am employed by the Institute of Crossing in Roswell, Georgia.
Nuclear Power Operations (INPO) in Atlanta, Georgia.
l 2. After serving in the U. S. Navy, I was employed in I
i September, 1972, by Alabama Power Company at the Farley Nuclear Power j I
Plant where I served in various positions including Assistant j I
Operations Supervisor. In February, 1978, I went to work for the U. i l
I S. Nuclear Regulatory Commission as Reactor Operations Project I
In February, 1980, I joined the Institute of Nuclear Power i I Inspector. l Over the next l Operations in the Evaluation and Assistance Division.
five years, I held the positions of Manager, Evaluation Support; Assistant to the Vice President-Operations: Assistant to the Executive Vice President; Assistant to the President; and Assistant to the Prosident and Secretary of the Corporation. l
- 3. In 1985, I was employed by Georgia Power Company as Manager.
Exhibit I Y ,page I of b
- /$tY l _ _ _ _ _ - _ _ _ _ - _ - _ - _ _ _ __ _ _ _ _ _ _ _ _ _ _
l
~
E L.' ,
Nuclear Support, reporting to the Senior Vice President - Nuclear
. Operations. In 1987, I was requested to serve as Georgia Power's representative on a Task Force to investigate further the establishment of a sys' tem-wide, Southern Nuclear Operating Company (Phase II). In accepting this assignment, I was offered a job ,
rotation with Mr. M. B. Hobby, Assistant to the President and i Assistant to the Senior Executive Vice President. I became, temporarily, Assistant.to the Senior Executive Vice President and Mr.
Hobby became, temporarily, Manager, Nuclear Support.
'4. While serving on the Task Force, I reported to Mr. R. P.
Mcdonald . Senior Vice President of Alabama Power. When Mr. Mcdonald F was named Executive Vice President of Georgia Power Company in April, 1988, and Mr. George Hairston, Vice President of Alabama Power Company, was named Senior Vice President of Georgia Power Company in May, 1988, I returned to Atlanta and became Assistant to the Executive Vice President and Assistant to the Senior Vice President.
- 5. In November, 1988, I returned to the Institute of Nuclear Power Operations as Assistant to the Vice President -
)
Administration. I was subsequently promoted to Manager. Industry and Government Relations.
- 6. While at Georgia Power, I was acquainted with Messrs. Gary Yunker and John Fuchko and knew, in detail, some of the problems they
.were having at the Company. I also became aware that Messrs. Yunker ,
I and Fuchko had filed a lawsuit against the Company with the U. S.
Department of Labor. In fact, I was contacted by Georgia Power Company and was asked to be a witness for the Company in this ExhibitN ,page.$_ of b p//sM; 7
1
' __~,-e -.~. , - - - . _
. ~ . - _ . - - - - - . . . . - . _. _. . . - , - - . .-
hi ..
Im s t t e r'.
- 7. Onl January 3, 1989, I received a telephone call from Mr.
Marvin' Hobby in which he relayed to me that the Company had held a session on January 2, 1989, to prepare for the upcoming trial in the'Yunker-Fuchko case. He' questioned why'I.had not attended the meeting.
- 8. He informed me that the attorneys had passed out a discussion paper at the meeting in which it was suggested that he
- (Mr. Hobby) had attempted to terminate Mr. Fuchko and Mr. Yunker in August, 1988. Mr. Hobby stated that he took exception to the statement and explained to the entire group that when Mr. Mcdonald t had become Executive Vice President of Georgia Power in April, 1988, Mr. Mcdonald had changed the oversight role of the nuclear corporate organization. He stated'that he informed the group that during the period April - June, 1988, the corporate nuclear security group's role changed so drastically that Mr. Hobby had no meaningful work for Mr. Fuchko and Mr. Yunker. Mr. Hobby said he i stated to the group that during the period April - June, he had made the recommendation to Mr. Mcdonald on several occasions that the Company should find meaningful work for Mr. Fuchko and Mr.
Yunker in Nuclear Operations, transfer them to other areas of the Company, or outplace them. Mr. Hobby stated that he informed the j group that he could not have attempted to terminate Mr. Fuchko and Mr, Yunker in August, 1988, because they did not report to him at L
that time. ,
- 9. Mr. Hobby stated to me that the attorneys asked him why he Mr. Hobby told -
didn't terminate Messrs. Fuchko and Yunker earlier.
ma he told the attorneys that Mr. Mcdonald would not let him.
- 10. Mr. Hobby said to me that Mr. Mcdonald said in the meeting Exhibit N ,page1 of E- f
_ . _ 1
. ~..
'thaththat was not'true and.that.he.had never had a conversation
'sith Mr. Hobby on the subject of terminating Messrs. Fuchko and Yunker. Mr. Hobby asked me what my recollection of the facts was.
- 11. I was very surprised by what Mr. Hobby said to me. I personally sat in at least one meeting, possibly others, in which Mr. Hobb'y discussed with Mr. Mcdonald the fact that, with the ,
changed emphasis in Corporate's oversight role, he had no real job for Mr. Fuchko and Mr. Yunker. I personally sat in one or more meetings in which Mr. Hobby asked permission from Mr. Mcdonald to either seek other jobs for Messrs. Fuchko and Yunker in Nuclear Operations, to seek jobs for them in other organisations within i
Georgia Power Company, or to terminate them. Mr. Mcdonald refused to allow Mr. Hobby to take any personnel action with regard to .
Messrs. Fuchko and Yunker. I relayed this recollection to Mr.
Hobby.
1
- 12. Mr. Hobby stated to me that Mr. Mcdonald discussed at the ,
meeting how people were selected for the SONOPCO Project. In essence, Mr. Hobby stated that Mr. Mcdonald told the group .
i assembled that management picked the Vice Presidents, then the Vice Presidents picked the General Managers, then the General Managers picked'their own Managers, then the Managers picked their .
Supervisors, etc. Mr. Hobby described it to me that each level of management picked the next lower level of management - - from top to bottom.
- 13. I could not believe what Mr. Hobby was stating. I know that, for the Hatch and Vogtle Corporate Support Groups, the l
l Exhibit N ,page N of b m
dscisions as to steffing were made by Messrs. George Hairston, Tom Dackham, and Ken McCoy. They met for two days at the 270 Peachtree Street Building, took en organization chart, and filled in names from the top of the organization to the bottom. I know this because I was invited to sit in on one of these sessions when none of the people involved knew the individuals being considered. Since I participated in the selection of the people for the SONOPCO Project, I know what Mr. Hobby had relayed to me as Mr. Mcdonald's explanation was inaccurate.
- 14. Mr. Hobby stated to me that, at the conclusion of this planning meeting, an attorney from Troutman/ Sanders had told him that his explanation of trying to terminate Messrs. Fuchko and Yunker in the April - June, 1988 time period did not square with Mr. Mcdonald's recollection and that the Company had a problem with this conflict in testimony. Mr. Hobby told me that he told the attorney that the Company had bigger problems in that Mr. Mcdonald's statements related to the selection of personnel were incorrect. Mr. Hobby said he explained the discrepancies to the attorney and the attorney responded that he would listen to what Mr. Mcdonald said on the stand so that Mr. Hobby could change his testimony to agree with Mr. Mcdonald's. Mr. Hobby said he refused.
i
- 15. Mr. Hobby stated to me one of the reasons he called me was to check his recollection of the facts. He said he was very worried that his testimony would conflict with that of senior management of the Company and he wanted to make absolutely sure that his recollection of the facts was correct. The second, he said, was that I was scheduled to appear as a witness for Georgia Power and Mr. Hobby wanted me to know that I could be placed in the position of contradicting Mr. Mcdonald on two possibly major points.
Exhibit N ,page 6 of E
jf,n .,
- 6. :I' replied to Mr. Hobby that I didn't want'to know what Mr.
' Mcdonald said on the stand. I told him I was going to tell the truth period - - regardless of what anyone else testified to.
$ 17. I was never called as a witness so I do not know if the
-Company.ever resolved the conflicts in. testimony.
.18. I make the foregoing. statements under the rain and penalties of perjury.
< [m . /s .
Thomas J . Mc V~ Henry /
Atlanta, Georgia July 16, 1990 Signed before me this the /b day of July, 1990:
Notary Public. Forsyth County, Georgia My Commission Esperes Sept. 13,1990 Exhibit W ,page b_ of h 7//4
_6- . - . . . . .
a g EXHIBIT 15 l
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Georgia Power d Psi 9on Cupstionnaire PosticN TITLE Administration Gen ral Manager Nuclear Operations Contract REPORTS 70 (POSITION UTLE)
- EMPLO(EE Senior Vice President Fossil & Hydro M. B. Hobby PERSON'S NAME COMPLETING PQ
' DEPARTMENT Nuclear Operations REVIEWED BY ( PL EE)
DEPARTMENT NQ MR V a / DAT!ttM D4E t APPROVEo BY (IMMEOfTE SUPERVISOR)
Oi,GANIZAT50NAL UNIT (VP'S oEPARTMENf nTLE) u
' Fossil & Hydro DATE APPROVEo BY WORK LOCATION L14/333
- 1. POSITION
SUMMARY
Desence the pnmary reason this position exists in the company.
To manage the contract for'the operation of the Company's. nuclear power plant's including establishing performance goals, accountabilities, long range nuclear planning, and budgets; to be responsible to the Joint Owners for the operation of the Company's nuclear power plants.
- 11. POSITION REQUIREMENTSKNOWLEDGE: List the areas of special knowtedge;(e g., engineering, acc thsy are used in this position.
law and the obligations of Contractual obligations - understanding of contract the contracting firm to Georgia Power Company and CPC's obligations to the Joint Owners, comprehensive knowledge of nuclear plant operations in' regard to A detailed knowledge of engineering principles, accounting, budgeting, etc.
joint agreement between the Joint Owners (OPC, MEAG, and theknowledge A detailed City of Dalton) and GPC regarding the operation of the nuclear plants.
of the nuclear utility industry and of the operations of INPO and the NRC.
1 l
SKILLS: List the vanous skills needed in the position. loclude technical, administrative and clerical skills, communication skills, managerial and interpersonal skills. Also, indicate how these skills are used in the position.
Technical and analytical skills to determine performance trends of the Company and industry; significant managerial and interpersonaI skills to maintain
- positive interaction with contractor (SONOPCO), other Southern Company subsidiaries and the Joint Owndrs of the nuclear facilities, (OPC, MEAG, and the City of Dalton).
Exhibit 1,page I of 9
4 _ . .
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EMPLCNEE Posna mLa M. B. Hobby G:ncrei Manager N.O. Contract Admin. i t
C. POSITION RESPONSIBlUTIES -List this position's & Responsibilities in their order of im '
annually on each responsibility. % OF TIME MAJOR RESPONSIBILITIES
, 90%
1._
To manage' all aspects of the contract with SONOPCO to achieve the safe, dependable, and cost effective operation of our-nuclear power. plants.
30%
.2. To establish reasonable goals, accountabilities, and budgets for nuclear operations that. support Georgia Power Company's Business Management Plan.
15%
- 3. To monitor nuclear operations to ensure performance is supportive of GPC's Business Management Plan.
15%
- 4. To serve as the primary interface between Georgia Power Company and SONOPCO and between Georgia Power and Joint Owners in nuclear operation matters.
10%
- 5. To be the primary interface with other Company functions including top management and with the Public Service Commission on matters related to nuclear operations including budget, financial planning, prudency and performance.
k Y
Exhibit 16 ,page d of._Y Page 2
._. . . . ~ . _ . . _ , - ___ ._ . _
s' ,
, s' -
EMPLCTrEE PosmoN TITLE M. B. Hobby Gr.n rsl M:ntg2r N.O. Contreet Admin.
f IV. POSITION ACTIVITIES COMPLEXITY / DIVERSITY: Ust the most difficult or challenging aspects of this position. Also,if this position is responsible for coordinatin managing a variety of activities of functions, please list these management tasks.
The most challenging aspect of the job involves the relationship between GPC and SONOPCO.
It will be most important for this position to ensure that
'SONOPC0 management understands and incorporates the goals and the in
.cecountabilities that GPC develops for them and that SONOPCO operates a m:nner that supports the accomplishment of GPC's corporate objectives and Business Plan.
JUDGEMENT / DECISION MAKING: Ust examples of the types of judgements this position requires and the frequency (daily, weekly, monthly, etc.
Budgeting Process
- Ap.putve the Nuclear Operations annua _l_ l budget - annually
- gonient bu_dget - daily Plant Monitoring
- Approve annual goals - annually
- Monitor goals' achievement - daily Information Resource
- PSC hearings on prudency - monthly
- Top management requests - daily
- Board of Directors - monthly RISK: Ust examples of risk taking that may be required of this position,(i.e., taking action where the eventual outcome is not clearly known.)
The primary risks are to ensure GPC's interests are protected while main-taining a professional and cooperative relationship with SON 0PCO.
CREATIVITY / INNOVATION: Ust examples of new methods, procedures or concepts the position may develop.
Since this agreement is rather different, there will be opportunities available to develcp alternative budgeting methods. The uniqueness of tha agreement .tiso offers the chance to develop more meaningful parformance indicators. New communf:ative methods could be developed to disseminate information on SONOPC0 to interested parties.
V. RESULTS OF ACTION CONTRIBUTION: Ust the direct and/or shared responsibilities of this position that cor(tributa to the success of the company and/or organization.
Th2 ability of this position to influence the management of SONOPCO to opsrate in a manner that best meets the interest of CPC would be significant.
Alco, this position has the responsibility for coordinating all the cdninistrative activities between the two Companies. Another area of l concern would be the position's ability to determine che budece needs' of l SONOPCO based on operating goals that are established through this position's direction.
i Exhibit 6,page 3 Of1 l Page 3 mus ucsm
EMPLOYEE Tds&^6N TITLE M. B. Hobby G n'e-a l M.ma n e r N . O . Contract Admin.
VI. SCOPE Provide annual statistick that convey the scope and volume of this position. (Revenue, customers, megawatts, capital O & M. contracts etc.)
Plant Hatch 1630 MV $250 MM Operting Budget Hatch and Vogtle Plant Vogtle 2320 MW $73 MM Capital Budget Hatch and Vogtle Vll. ORGANIZATION Complete the organization chart below. Identify the two positions above this position, peer positions reporting to the immediate super.
visor / manager and subordinate positions reporting directly to this position (use titles only).
Senior Executive Vice President Senior Vice President Fossil & Hydro Operations EMPLOYEE Gen. Mgr.
Nuclear Operations Contract Admin.
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Senior Senior Senior Secretary Plant Accountant Engineer l
UNICN CONTRACT TOTAL EXEMPT NONEXEMPT 1 3 PERSONNEL SUPERVISED 2 Exhibit 16 ,page 4 of V Page 4 msa ucsm
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EXHIBIT 16 l
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.. . Persennel Rsquisition Georgia Power
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Job No (Tetle 01:3 Performance Engineer 3/2/89 DepanmenUSection Location
[ Nuclear Operations Contract Administration C.O. Atlanta Position is: GNew OReplacement for Whom $4704 mp Position Reports To: Name Title, Extensson Employee No. Position Auth. No.
M. B. Hobby, General Manager 3187 , 42784 THE FOLLOWING INFORMATION WILL BE USED IN IDENTIFYING CANDIDATES Corporate Requirements Candidates will be screened on these requirements.
Degree and Major (s) Required,if any BS Engineering _
Certificates Required, if any (Electronics, Data Processing, etc.) -
Other Requirements (Licenses, years experience) Computer experfence.
Skills Tests for: Clerical position O General Typing Test Secretarial position O Advanced Typing Test or O Shorthand Test Summary of Position Duties .
Coordinate and track Company's response to data requests from the PSC relative to nuclear performance and prudency matters. Coordinate CPC's response to continuing management and operational audits of nuclear facilities. Interface on goals and perf ormance mat ters with SONOPCO and Joint Owners.
(
Management Requirements Candidates may be screened on these requirements upon request by hiring manager.
Work Espenence Years Nuclear power plant Nuclear administration - C.O.
Description of Experience and6r Knowledge Needed to Perform this Function Knowledge of nuclear power plant operations. Knowledge of INPO, EPRI, and NRC.
Knowledge of regulatory structure in Georgia and interactions with PSC. Knowledge of Joint owners and contract with Joint Owners. ,
Approvals j Requestor Executive i r.VP- min. s. (For G.O. sons ordy)
. Sr l *
{'n.ase nd originw io num.n R. source. eannu,, o.p.,im.ni N \J y Position Filled By Date O New Employee O cornpany Transfer i mem ~' uw s*w recenc="r Exhibit d!L.,page \ 0f l
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- , - - - , --w - - . ,n, - . - , . - - - - - .
l EXHIBIT 17
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION DISCUSSION /POSSIBLE VOTE ON FULL POWER OPERATING LICENSE FOR VOGTLE, UNIT 2 PUBLIC HEETING Nuclear Regulatory Commission one White Flint North Rockville, Maryland Thursday, March 30, 1989
-C. '
The Commission met in open session, pursuant to notice, at 2:00 p.m., Lando W. Zech, Jr., Chairman, presiding.
COMMISSIONERS PRESENT*
l Lando W. Zech, Jr., Chairman of the Commission l
Thomas M. Roberts, Commissioner Kenneth M. Carr, Commissioner ]
Kenneth C. Rogers, Commissioner 1 James R. Curtiss, Commissioner I
HEAL R. GROSS Il ,page I cover spearias Ano TeaMscassens Exhibit of .L 1 1323 aMoOf ISLAMO AVtMut. M.W. ,
WASMewCToM. O.C. 2000$ (202) 232 4400 (202) 23m
g 3 2 STAFF SEATED AT THE COMMISSION TABLE:
SAMUEL J. CHILK, Secretary i 3".
. . WILLIAM C. PARLER, General Counsel ROBERT W. SCHERER, CEO and Chairman of the Board Georgia Power Company A. WILLIAM DAHLBERG, President Georgia Power Company PAUL D. RICE, Executive Vice President Georgia Power Company R. PATRICK MCDONALD, Executive Vice President Nuclear Operations, Georgia Power Company GEORGE BOCKHOLD , -P11rnt n ... gar S evm ' ' 'l ' *" r -
~
Vogtle Plant, Georgia Power Company C. KEN McCOY, Vice President for Nuclear Generation Vogtle Plant, Georgia Power Company MR. SNEZICK, Deputy Director, NRR
(-- JOHN HOPKINS, NRR Project Manager MEL ERNST, Deputy Regional Administrator, Region II JOHN ROGEY, Senior Resident Inspector DAVE MATTHEWS', Project Director, NRC MR. TAYLOR NEAL R. GROSS Exhibit M ,page 1 o-Count Re 0ana A=0 TRAM $CMtR$
/ 1323 RMOO4 ISLAMe AYINUt. M.W.
WA$MINGTOM. D.C. 2000S (2021 232-4000 (202) 234 4433
g ...
1 Gcnoral Mcnager for Support.
The Assistant General ~ Manager- for 2
3 Operations, he has reporting to him a Manager of 4- Operations because that Assistant General Manager has, 5 other things reporting to him. So, you go right down 6 'that line through his assistant general manager and 7 manager of operations. ,
8 COMMISSIONER CARR: So, the two plant is.one 9 plant as far as management is concerned.
That's right. That's exactly 10 .MR. MCDONALD: ,
i 11 right.
COMMISSIONER CARR: I had a management 12 ..
r 13 concern that looked to me like he was a long way from 14 the CEO. .
15 MR. MCDONALD: He's a 'ong way from the CEO7 f
16 COMMISSIONER CARR: Yes. Maybe I don't the hierarchy between
- j. ' 17 understand what Ken 's -- what 's 8' the CEO and the plant manager?
N',,4
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19 %M M . MCDONALD: Okay. That's what you mean.
( # Gv y- h* The 7% /' 20 N Eay. hierarchy between a CEO and a plant [
manager, I report to Mr. Dahlbere. Reporting to me is O / 21 ,
otAgl d Ap h Ken McCoy who is in charge of the entire Vogtle o .y q, 22 '
dDr Lobo 23 Project. He and I have a -- I have two Vice
'C- % 7 d5 4o The Vice President of \
. 24 Presidents reporting to me. f
' S o e.4 (
^ Hatch has a similar position to his. So, he is /
- 25
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- s @ C., NEAL R. GROSS -
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hoc., 5f tA. cover assoareas ano teamscassoas Qd} %6 4 r o Q PC to Mh '"'w"a"s*.a*'.,*o.*.".*.c^. ".".".'.s""- i => = ==
o =_ d c, I. tv c. p o,,e,,; V P)s Exhibit O ,page 3 of lp_ M c b. Mr.d 5d,-.
. .g. - (' 34 1 responciblo for all' the ' corperato support cc woll ac-
. .2' the plant. George reports directly to him.
3 CHAIRMAN ZECH: Both units he has. P 4 MR. MCDONALD: Both units.
5 CHAIFJiAN ZECH: Yes. All righ-6' MR. MCDONALD: Is that what you want to 7 know?
8 COMMISSIONER CARR: So, you'have a guy for 9 each, Vogtle and Hatch.
10 MR. MCDONALD: Yes.
11 COMMISSIONER CARR: But they don't have 12 anybody for the two plants.
13 MR. MCDONALD: They manage those two plants
.. ! as one plant, .those.two units *as one plant.
).. 14 15 COMMISSIONER CARR: And Ken has Vogtle and 16 Hatch.
17 MR. MCDONALD: No. No, Ken has reporting to 18 him three people. He has George reporting to him, he 19 has a QA nanager reporting to him . and he has the 20 corporate staff support reporting to him.
21 MR. BOCKHOLD: Only for Vogtle.
22 MR. MCDONALD: For Vogtle, for Plant Vogtle.
23 MR. RICE: Then there's a Vice President for 24 Hatch. . j
\
25 MR. MCDONALD: T h'a t has a similar
- ( .' =*
NEAL R. GROSS Covat 2020t7828 Ape faAMSCalgte p th 0 Q }7-1 1323 eMOetISLAMe AVgMug.M.w.
WASMessGTON.D.C. 2000S (2021 232 4600 (202) N 1
., g 35 l 1 crgcni:ction. . ,
1 l
m 2 COMMISSIONER CARR: Okay. I understand your
- i '
t i3 organization. I still have my concern, I guess.
,d,c. .-huoics .
O e. h a tr oC-6 MR. MCDONALD: May I be responsive to more?
' 4 EV L'c'- - 5
~
COMMISSIONER CARR: Oh, sure. I just say, c.". o<e LO Cf C -
' c.ec,wfT cc5 (. 6 if he's got a problem that needs the CEO's attention, ;
7 he goes a long way to get there, was my concern.
8 MR. DAHLBERG: I guess I should, add 9 something on that matter also. I guess one of the-10 things we have done well is while Pat is an Executive Vice President of Nuclear, it does mean that he is e\%\ 11i 9 Me vis4en the site. He is !
1 available to the site. __ ,
rs + ~
A *A~ 13 there. He talks to the people and he looks at the L . . '.N s- ' E
',,,,_y/ o!.ds 14 equipment. We've t=ied to use that philosophy for all 15 of our operations. It doesn't stop with Pat. I have 16 the same type of a relationship. I guess we could go 17 even further than that. We do have a Board of Directors committee for oversight of nuclear. They 18 19 even visit the site. So, it's not removed.
20 I think we have established the kind of a 21 relationship and the kind of a personal hands on with 22 management. George has access to anybody he needs 23 access to.
COMMISSIONER CARR: Let me -- are you -- is 24 1 1
25 Ken at the site?
HEAL R. GROSS count aspoenas Ano nanscareiasExhibit M 'Ea9e 6_. of l.L 1323 anoes estAno Avewus. w.w.
W AsHINGToM. O.C. 2000s (202) 232-66(o l (2021 234 4433 I l
. i f 36 1 MR. McCOY: No, I'm --
- 2 COMMISSIONER CARR: You're at the T
3 headquarters.
~ ~\_W.
~ ' "h c\\,\ cM
,. ;4 MR. MCDONALD: Let me expound on that just a g;" kM % J- '
5 moment. One of our major management techniques is 6 managing problems and we keep pretty comprehensive 7 lists of the top problems, top 10, 20, 30 problems.
8 Those problems are reviewed periodically by all levels of management including -d of Directors. We 9 ,
i i p 10 have a completely technical meeting with the Board of D o gve. eT 3 Directors describing such things as the PERM problem svec,scf6 { 11 12 and any other kind of a technical problem there is, so 13 that the entire management structure is involved in f 14 personnel matters, technical matters and what have you i_,
15 on a routine basis. All these facts which might 16 otherwise get lost are brought up to the top level of 17 the company.
18 On the Board of Directors committee, which 19 he takes part, we have some very capable people from 20 various walks of life, like almost any board. We have 21 a gentleman who is head of a big construction company and'another -- various types of things. So, I think 22 23 that we talk technical detail on a routine basis with 24 all levels of management very frequently.
CHAIRMAN ZECH: Commissioiler Rogers?
25 HEAL R. GROSS Covat asposita3 ANO TRAMSCalttRS ists anoot isLANo avtwus, p.w. Exhibit 17 ,page b of_6 l (2C21232 6600 j wASMINGToN. 0.C. 20005 (2C2) 23A.4433 l
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i EXHIBIT 18 l
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lla ,vfcr i AM'C ftYfe..d S /$ddau lo
. duan .*9 /d r/8 8a b May 1, 1989 n/ W Corporate concern No. 89E0086:
Plant Hatch site management denied a covered Utilityman the ability to transfer to a Vidalia District Customer Service Representative position which had been posted at Plant Hatch and for which twelve Plant Hatch employees interviewed.
Investicra. lion Results Transfer denial applies to all nuclear employees who wish to accept a position for which a job slot must be transferred from Nuclear Operations to fill an early retirement job opening. Slots may become available af ter finalization of SONOPCO staf fing plans.
Detailst.
Early retirements left the need but no available slots for two Customer Service" Representatives in Vidalia and Baxley. Vidalia District's historically close relationship with plant Hatch led David Cox, Vidalia District Manager, to explore options available with Harvey Nix and Larry McDaniel, the Hatch Plant Manager and Plant Administration Manager, respectively. Knowing that these two positions were likely to be attractive to a number of Hatch employees, and acknowledging that Hatch had a large number of unfilled slots, the Hatch managers suggested an exclusive posting of these two positions at-Plant Hatch, not-anticipating Senior Vice President opposition to transferring slots with successful candidates. Hatch management was also unaware that Mr. Dahlberg had directed that any slot which has remained unfilled for more than six months be abolished. This would apply to many of the slots they perceived to be available. Twelve employees for Baxley and fourteen employees for vidalia applied and were interviewed for the positions.
In the meantime, Robin Spivey, Plant Hatch Human Resources Coordinator, accepted an offer to be promoted to Soperton Local Manager. When Plant Hatch sent the 3351 to SONOPCO, Mr. Hairston approved the transfer of a slot to Macon Division for Spivey, but notified the plants that transfer of slots would be frozen until SONOPCO staffing pl3Ini~4ed fliialTziad.- ThTaifective J. eaves tha-"-' -
two Vidalia Customer Service Representative positions in question.
Other positions have been affected also, as noted on the attachment prepared by Human Resources Planning.
GPH 000338 Exhibit __l.2I. ,page I of 3
i Page Two. r Mr. Tom Beckham has been contacted to determine his position on the availability of slots from SONOPCO. He is understandably upset that he is being made to look like the villain in this situation.
He believes the Divisions are soliciting applicants for positions which do not exist and then blaming' SONOPCO for the denial of transfers. 'SONOPCO' may very well have slots available after staffing levels are finalized, but Mr. Beckham. feels it. ~ ~
inappropriate for him. to-determine which division or 16ca't'i'o'n' is- !
in greater need of the slots.
In a related situation, on Wednesday, April 26, Mr. Dahlberg interceded to obtain a slot on behalf of George Miss, a Plant Hatch employee desiring to transfer to Brunswick as a Senior Marketing Representative. !
The discussion below was provided by Marvin Hobby regarding difficulties he is having in securing an interview with SONOPCO employees for a position which already holds an approved slot: l "When we established Nuclear Operations contract Administration, I (MLrvin Hobby] told George Head we needed a manager,. secretary, i two accountants, and two performance engineers. He agreed to start ,
out with one accountant and one performance engineer and revisit ;
the staffing level as the work load increased. . We later added '
another accountant, t Back in January, I called Ken McCoy to ask if I could. talk to Mike Barker about the performance engineer job. . Mike had done a i similar job for me prior to going to Birmingham and was well qualified. Ken asked if it was a promotion. I said I had not had the job evaluated yet and didn't know. He said if it was a ,
promotion, SONOPCO vould not object. .
I had a job description done by Personnel and it was determined to i
.. be a Level 13 job, a one-step promotion for. Mike Barker. Mr. Head i approved the job description at that level.
e I told George Hairston about this in the GPC cafeteria later and i relayed my conversation with McCoy, but he would not give ,e i i
permission to talk to Mike Barker. I called the Administre ci n people at SONOPCO and asked what the rules were. They said &y :
were told if it was a promotion, management would give cs permission. ;
r"Fi 000339 !
Exhibit N ,page_b. of b
- , . 3 Page Three After talking with George Head, we posted the job. I selected the best three candidates, and they were all from SONOPCO, which is not surprising. Our Personnel Department was told the request to interview had been approved all the way up to George Hairston.
But s tra it stopped. Later, our Personnel Department was told Mr. ,. said would not approve the request because he didn't agree that . . .a job level should be a 131 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 gentlemen."
WRE:j1 GPH 000340 ;
Exhibit N ,page 3 of 3
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1 EXHIBIT 19 f
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June 8, 1989
. Dennis:
I promised you in the earlier letter that I woul,I discuss a little or what is going on at Georgia Power. You have read several accounts that I have sent you related to the IRS investigations, FBI investigations, political campaign contributions, etc. There is, to my knowledge, no progress in these areas and I am told that these investigntions will I. .
going on for years. There is a l o i: of speculation as to whether M:
Addison will be able to weather the storm - after all, he was t h. CEO at Gulf Power when many of these allegations eccurred. The situatton in th" company - - throughout Southern Company - - is horrible.
I will get more specific about my situation in a moment. Itut, I must admit that I am grateful to have worked at Georgia Power when Mr. h ller was President. He was a no nonsense guy, hard working, competent, inquisitive, honorable, and he worked for_the compt.ny. lie liv-d, breathed, and exited for Georgia Power. The man could lead. lie a st.. d questions. lie asked for input. When people disagreed with him, thut was fine. It seemed it was only an opportunity for him to ask more questions and he would admit when he learned something. Even though he was President, he was not afraid to learn something or hear a new iJ.- ile
.was not afraid to say he didn't know. lie wasn't area 1 to ca) h. tidn
understand something. He wasn't afraid to ask for udvice. Ib- didn't u; : !
people challenging him - - not personally but on an issue.
Mr. Miller had integrity. He gave us guidance and direction and his message to us was clear. He also held you accountable for your performance. As one lower level supervisor in building services said to '
me in lamenting Mr. Miller's retirement, "We are really going to miss him. You may not always agree with the direction he gives you, but you always know where you are going." She was right.
Mr. Miller also focused his attention on where the compan> nhould be headed and what was required to get there. li e really took an e ra o t i o n a l interest in the 15,000 employees we had and he wanted them to p e r f o r n. . 1 And, if they performed, he took care of them whet her he l i k_r d t h e ,n or not. It was not essential that Mr. Miller like you because he judged euch l employee on performance and what they were doing for Georgia Power. l i
Mr. Miller could make a decision. Sometimes he would ruake a snap i judgement based upon his technical knowledge, his experience, his j managerial ability, or Just his hunch. But, when a decision was made. ,
that was the end. Everybody Jumped. He also protected the company. l There were several examples where the System wanted Georgia pow.r to change what they were doing although what we were doing was turning out the profits. In u t , the bureaucrats at Southern, who wanted to increase i their power, demanded that all opernt ing companies abide by Ihe same set j of rules. Mr. Miller said no t, hat he was in charge of operating Georgia l Power and, although some people at Southern got bent out of shape, Mr.
Miller's decision ruled the day.
Exhibit Ik,pageI of l
. 9 A lot of people remember Mr. Miller as a tough, authoritarian figure.
I remember him as a great leader, someone to be admired, a role model, and a loving and caring man who dediented his life to Georgia Power and its employees.
Yet, Mr. Miller was a strong man. Several senior executives were glad to see him retire because he ruled firmly and would not let some of them put into effect their lunacy. I am convinced that several executives wanted their day in the sun and made suggestions just to make themselves look good. But, their suggestions died because they did not have the courage to bring them to Mr. Miller for approval.
What resulted was a small group of executives who wanted so desparately to be in charge that they looked for every. opportunity to
- their prasonal enhance their position - not the company's position position. Some of them would have sold their mother and the company outright if they could have positioned themselves better.
There was one exception. George Head. George was a technically H.
competent, hard headed, hard driving manager who did an exe"ption .; td, .
had a weakness in that he did not have as broad a perspective as d.dm.
Miller and George found it hard to listen and Icarn, lie f"It he kn"w his business sufficiently well to do his job andGeorge listening, learning, taking could not adapt. I advice, or changing was difficult for him.
don't mean he just didn't want to, he couldn't.
After Mr. Miller left (actually before Mr. Miller i"f t , Geore. has assigned to report to Grady Baker. The organization at th" tin" was Mr.
Scherer was chairman of the Boned and CEO, and Grady Haker and i I nn - ,
Grad 3 h.id planne !
Harris were t. h e two Senior Executive Vice Presidents.
his career such that when Mr. Miller retired, b.. would becom" P s . ". 4at.
Elmer was brought over from Alabama Power tu head External ATfairs and t h,<
word was that he could become chairman and CEO of Georgia Power. Grady even told everyone that would listen to him that he had picked Elmer to b.
CEO at Georgia because he (Grady) did not want the job - - he want"d to be President and C00.
Mr. Addison became President of Southern and said Georgia Power did not need both a President and a Chairman of the Board. He said that when Mr. Scherer retired, we would have a President and a CEO and no Chairman..
That crushed Grady. He had worked to become President all'the.% y-ars and now would not get the job. Then a horse race began to see whethv Flmer would become President or whether Bill Dahlberg, President of Southern Company Services and an ex-Senior Vice President of Georgin Pow"r who used to work for Grady, would become President of Georgia Power. Friction developed between Grady and Elmer. Grady was obviously pushing.8ill.
Bill won because, in part I think, Elmer got involved heavily in this campaign contributions fiasco.
Back to George. George and Grady did not get along. Grady is a Jekyll and Hyde. There are days when his thought process is brillant.
There are days when he acts like an idiot. And, you never know which person you are dealing with. I could go into a lot of examples whm e George and Grady disagreed but there is not need. I would pois.t out that for years Southern had been trying to tell Georgia how to do ite businos .
hhihit naand of)
,~ 3 'l n.
Mr. Miller would not let that happen and'Mr. Miller and George linad we re on the same side. After Mr. Miller left, Grady tried to get on Mr.
Addison's good side by agreeing to everything Southern Services wanted tu do. George disagreed but Southern is gradually taking over.
E lmer lia r r i ,
Now, however, we are left with another poor situation.
is named President of Alabama, Bill Dahlberg at Georgia, and Allen Franklin at Southern Company Services. Each one of thom is running for Addison's job. It appears that it is not so important that each one of
- them does his present Job properly as it is that each stays un good terms with Mr. Addison. Southern is now run by a management council of all _ t he CEOs. It is run by consensus. There are not disagreements. As a matter of fact, each CEO makes it his business to agree with what they think Mr. -
Addison wants to do. A rumor can start that Mr. Addison wants something done and all the CEOs break-their necks to agree to it even i f Mr. Addiso:
knows nothing about it. We are in a heavily political arena here ei n d right means little.
Into this situation enter one R. Patrick Mcdonald. This atmosphere .
rade for him; he excels in it. He is either 61 or 62, knows he is not going further in the Company, has retirement from the Navy, makes good money, and recognizes a vacuum in the leadership of the Company. Ile il o e s what he wants to do, regardless of what any one else says, explains it ,
without sticking to the truth, and, in general, is enjoying life. Ile gett along very well with Mr. Farley partly because he lies to Farley and partly because Mr. Farley hates Georgia Power Company. Pat can g .i t away with anything by badmouthing Georgia Power. Farley is Executive Vice President of Southern for Nuclear and reports to Mr. Addison.
When the decision was made to bring Pat into Georgin Power ha is Executive Vice President of Georgia Power and Alabama Power) un1 Iv mov" our nuclear operations group to Birmingham, f deetled after my experien m with him to not go. I went to Grady and told him that I didn't want to o and I recommended that we establish a contract administration group to protect Georgia Power - - not to manage SONOPCO - - but to a.lv i s e CPC's senior management on how our performance was. Grady agreed to that und said he would talk to Dahlberg. I specifically remember him saying that whoever got the job as General Manager of his group would have a tough time trying to deal with Mr. Farley and Mr. Mcdonald. (Incidentally, everyone in senior management at Georgia Power that I have talked to:
George Head, Grady, Elmer, Dwight Evans, and I have been tbid Dahlberg ,
hates Pat Mcdonald. They think he is bordering on crazy, and he doesn't tell the truth).
Grady took his proposal to Dahlberg and at some point Grady and Georgi Head talked to Dahlberg. They decided we did need such a group and it would be reporting to George Head. Dahlberg usked George who woulti head the group and George told him me. He said I was the only one in the Company left with nuclear experience, except George.
I was given the job on December 27. A copy of Dahlt. erg's memo ;
announcing the promotion is enclosed. Prior to the memo going out, Georm j asked me how I would structure the group. A copy of my memo to Georee on !
that subject is also enclosed.
Exhibit 19,page 3 of 7
}
o s Early in January, Pat Mcdonald came over to Georgin Power and told me to do something. I told him I would be glad to but that I needed to -
inform George llead since I now worked for him. Pat went livid. Ile asked what I was talking about and I went and got a copy of the memo for him.
He got very made and said he opposed the creution of such a group. !i e said when the time came for such a group, he would set up the group, decide what it would do, and he would pick the head of it. !! .- said hi would not have any of this. I reported this to George.
From January until the end of April when George retired, I worked ..
well as I could to do the Job assigned to me by the Presidint.
Unfortunately, Pat Mcdonald would not cooperate and would not Ict his people in Birmingham cooperate. I will not go into details except to say that Pat has refused to let his people in Birmingham even talk to me.
During this period, I told George we needed help from Dahlberg. I must have requested a meeting with Dahlberg 50 times. George asked for many, many meetings. He had maybe 4 or 5. Each time, Dahlberg would sa:
he supported us, wanted us to do our job, and was behind us. i: n i , he .!i J nothing. Pat still would not cooperate. Finally, George asked me to <a!
Mcdonald and set up a meeting between Mcdonald, !!e n d , and me Mc D o n a l i!
would not set up the meeting.
Then George announced he was retiring. Dahlberg aske.1 him to reconsider and remain with GPC but George refused. One of the r"asons George refused was that he felt we did not have a leader at Georgia Pow e s and that Bill would not make a decision and would not stand up for Georgi Power.
Throughout all of this, I have continued to remind peo p 1 - that Pat Mcdonald reported to Bill Dahlberg and, by Nlte r egu la t i ons , had I.. t t ':
told Grady, George, Dwight Evans (EVP o f Ex t ernal Affair. .i n d i ;;, , m d '
friend of Dahlberg's), Chuck Whitney (Asst to Dahlberg;, Fred Williamr of Bulk Power), and the attorneys that I thou8ht we had a protitem. I to:
them that, in my opinion, Pat Mcdonald worked only for Joe Farley, now EV of The Southern Company, and if that were true we were in violation of .ni license and the NRC could shut our plants down. Several people shared m3 concern but would not agree or disagree. George Head agreed. Fred Williams said all we had to do was show the NRC the organization chart.
said Fred that won't cut it.
I talked to the lawyers. They were concerned and even went so far as to tell Hairston that if he were ever asked who he reported to he was to say Mcdonald who reports to Dahlberg. For the license on Unit 2 at Vogtle, the people were coached as to how to answer that question.
Finally, George has decided to retire and he went to Dahlberg and sui there was one matter he wanted to get settled before he retired and that was our relationship with SONOPCO. Dahlberg responded thnt he knew thei was a problem and he was going to meet with Farley and see if they c o u l .'
straighten it out. . When George told me that, I said something lihu if Mcdonald report to Dahlberg why in the hell can't Bill Just tell him what to do and why does Dill have to go and straighten it out with Joe Farley" George said, "Well, I guess we have Just got the answer as to who McDona:
really reports to." George also said that Dahlberg said it wou a wast.
nf +4-- rne nnb1here in talk to Mcdonald.
PyNhit k n y. o h nr 7
~ _ _ . .
o e S \
l 1
l When we learned that Grady and Dahlberg were going to meet with Farley, I told George that they shouldn't go talk to Farley without
-talking to him and me first about what problems we were having. He agree and tried to set up a meeting with Dahlberg. Dahlberg wouldn't meet with us.
About this time, I was going up to George Head's office on the 24th floor and the Executive Vice President for External Affairs saw me and he starting talking. His name is Dwight Evans and he is pretty close to Dahlberg. Dwight said thut if he were me he would start looking for another Job in the c.ompany because he had henrd that Mcdonald and P a r t e :,
were out to get me fired or out of the Job I was in.
I reported this to George and he said be had to talk to Dahlbieg and Grady before they met with Farley. He tried but failed. He then suggested that I might go to Grady and tell him what we had heard and hh.,
our concerns were and try to get a meeting with Grady and Dahlberg. I went to see Grady and asked for a meeting. He said it was not necessary.
I said something like Grady, the rumor is going around that Mcdonald and Farley are after my job. Won't you ut least talk to George and me' !!o jumped up from his chair, threw his arms up high, laughed and continuing to laugh said, " Hobby, what can I say?" And, he then walkeel ou t of I h.-
room.
I told George. He got mad and said he was leaving the co m pa.0 , want-to get away from those people, and he basically apologized that Ihe Company did not have a backbone and would not stand up for what was right He said we did not.have anyone in senior management at GPC " worth a shit" and that Mcdonald would win because no one at GPC would dare tackle Farley.
About the same time, I got a call from Fred Williams, VP of Dulk Power. He is the guy that really deals with most with the joint owners.
He said he had been asked by Dahlberg and Grady to go to Birmingham to se if we could work out the problems between SONOPCO, GPC, and the joint owners. He asked me to write down the major problems I had in dealing with Mcdonald. He said he would not show it to Mcdonald but he would g i r-it to Grady and Dahlberg for their meeting with Farley.
I wrote the memo (which is enclosed) and before giving it to Fred I showed it George Head. George agreed with the memo and felt so strongly about what I had said, he said he wanted to sign the memo with me. I hasi .
the original memo at home with my and George's signature. I took the memi
, to Fred Williams. He read it. He told me to destroy the memo because we did not want something like that in our files. He said the joint owners had been fussing about Mcdonald and who Mcdonald reported to and he said that my memo showed that Mcdonald reported to Farley and we could not h u v.
this memo in our files because it would prove Oglethorpe's argument.
I told Fred that this was a regulatory concern. I told him that the
-- way he reacted indicated that we did have a problem and that we ought t <<
fix the problem before we got into trouble with the NRC. I told him we ought to concentrate on fixing the problem not worrying about some memo.
I further said if he did not have a problem, then b :n e notigi43 x ibit gg me an t,page0*
s' s
.O It only meant something if Mcdonald did not actually report to Dahlberg '
but to Farley. I told him I thought we were going to get in trouble w i t h'.
the NRC. He said there was not a problem that if the NRC ever asked at,ot.-
the issue we would Just show them an organization chnet. Then he said, you must destroy this memo. He also said he was going to keep a copy of
-the memo but he would not keep it and he would not let Grady and Dahlber.
see it. It was because of that that I went to see George and later to s.- .
Grady.
I talked to George and we agreed that I would not destroy the memo.
do not have a copy at the office. I do elsewhere.
In my conversation with Fred Williams, I. asked him why Dahlberg just didn't tell Pat Mcdonald what to do and the whole issue would be tiehind us. He said Bill did not have the clout to do that. He said McDonuld wa' very close to Farley and if Bill gave Pat Mcdonald an order and Parley di.
not agree with it, the matter could wind up before Ed Addison. I asked well, doesn't Dahlberg have enough clout with Addison to win the argument. Fred said that wasn't the issue. He said Addison did not has-enough clout to tell Parley what to do. He said the Southern Board was '
divided and that Addison did not have enough votes to do somethina if Farley disagreed and that Farley did not have enough votes if Addison disagreed. He said the Southern Board is at a stalemate and we have to make do the best we can. And, the one thing Dahlberg could not a f ford t v.
do was raise an issue between Dahlberg and Farley that would require Addison to make a decision because, if push came to shove, Addison was no-guaranteed tb9t the Board would support him over Farley. Therefore, nu major disagreements were to be brought to Addison.
Bottom line: Dahlberg wants to replace Addison. D a h l t.e r g is not going to make something an issue that will require Addison to decide between Dahlberg and Farley. No one is in control at Southern Farley lets it is McDonal shared responsibility. Farley can do what he likes.
do what he likes. And, nobody can stop him.
I shared what Fred told me with Paul Rice and Paul said that was pretty much the truth. He said Addison is working to gain a majority of t h-e Board's support but he does not have it now.
After George retired, Kerry Adams, who knows nothing about nuclear, was named to replace him. Grady told him he wes not s u re ,wru, I would eventually wind up reporting to, but that I was to hire no new people.
I believe that the outcome will be that my job *till be greatly reducci including a reduction in pay and I will be asked to reoort to Fred Williams. Or, I could be asked to resign. I don't k n o.' . But, I do know this, I have tried to do a good Job and have been prohibited from doing m>
Job by Pat Mcdonald. I got excellent support from George Head. I have received no support - - except lip service -- from Grady or Dahlberg.
Everybody is protecting their own position in the company.
I don't know what will happen. It is my opinion that Gl'c nnd Alabama Power Company are in violation of our NRC licenses. Mcdonald reports to Joe Farley, I don't care w ' hat the organization chart says. I have pointe. ,
out over and over to management that I wu concerned that we were Exhibit I { ,page_(c_ of 7
violating Federal law.
But, the answer show them an organization chart."
is time and time again, " h'. ' l l Maybe you and I can talk about this on Sunday.
Exhibit I $ ,page 7 of l t
r ;
.o e i I
l EXHIBIT 20
- 05PM i .a g "J'- 6. , ~ ,.' - .4 ' 7 '-
4ENT CY: Xerox Telecepier 'l02' 'l-25-89 : .
4 MEMORANDUM TO: Marvin Hobby FROM: Bob Edwards RE: Nuclear Operating Agreements DATE: October 25, 1989 You have requested my comments on the draf's t we are likely to see from OPC. Attached are the key comments.
I have not undertaken a line by line editorial, but have striven to provide notice of the key points.
I have also attached copies of the key pages.
Finally, as a separate memo I am enclosing my suggestion on the term of the Managing Board Agreement.
Enclosures I
Exhibit 1,page / of3 1
I 70; 0-25-89 i F A ! A
-.< - .o'SEN'T SY: Xerox Teleco:ler 1
I October 25, 1989 ;
)
i Manacina Board Acreement Draft Dated 10/19/99
- 1. Managing Board Agreement should be . entered into simultaneously with Nuclear Services Agreement with SONOPCO..
Strike last sentence of 1.23 and insert a reference to the Agreement, either citing it by date or as an Exhibit. ,
Otherwise, OPC will obtain greater authority to veto obtaining ;
nuclear operating services than it currently has.
- 2. GPC should preserve its authority to act in accordance with. prudent utility practice, including ability to apply to ,
transfer the License to SONOPCO without co-owner consent.
Strike last sentence of 1.21, 1.22. A fallback would be 85%
approval unless prudent utility practice or legal requirements a
~
required such a transfer. OPC would retain rights to' oppose transfer at the NRC. Under current situation OPC's agreement f
is a practical necessity.
- 3. Consistent with these comments, the last nine lines on page 14 (Section 4.0) should be deleted and a period placed after "Each Plant." Subpart (A) should be deleted.because Managing Board approval is not needed for the Nuclear Services I
Agreement. Subpart (b) should be deleted because GPC's authority is governed by existing Participation Agreements.
. Subpart (c) should be deleted because GPC's authority is Exhibit 1,page 2 of _1
u na on. m .4 . . . . . . . . . , '"' -* * " ' -
M*' ai a *
.. j governed by existing Participation Agreements. If we want to provide for the Managing Board to take some action with regard to applying to transfer the license to SONOPCO, a separate sentence describing that requirement could be addod here.
Nuclear Services Acreement Draft Dated 10/17/89
- 1. In order to distinguish the Nuclear Services Agreement and to avoid any accusation that SONOPCO is operating the plants without a license, we should insert the following as the second sentence of 2.01(a) at page six:
"Until SONOPCO is licensed to operate Plant Hatch and Plant Vogtle the scope of these Nuclear Operating Services shall be limited to such nuclear support services as GPC in its capacity as the licensee responsible' for plant"o'porations requests. Within the scope as established by GPC or an operating license issued by the NRC ....
- 2. OPC will probably object to the restrictive definition of " willful misconduct" in Section 7.02(b) (page 29-30). I think it can be stricken. This is likely to be controversial with the SONOPCO group. ,
I l
I 1
Exhibits O ,page 3. Of 3
- i
DOCHETED December 6, 199QHRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 94 0<rC -8 P 3 '43 ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SEcaf_[ARy
) DOCKEIlNG ; a T/4cr~
In the Matter of ) Bfi AHcil
) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 e_t;, a 1. , )
) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)
Plant, Unit 1 and Unit 2) )
) ASLBP No. 93-671-01-OLA-3 CERTIFICATE OF SERVIC_5 I hereby certify that EXHIBITS TO INTERVENOR'S PREFILED TESTIMONY have been served via first class mail, this December 6, 1994, upon the persons listed in the attached Service List, with the exception that is was served by overnight delivery as indicated by "*".1 v
By:
Michael D. Kohn '
KOHN, KOHN & COLAPINTO, P.C.
517 Florida Ave., N.W.
Washington, D.C. 20001 (202) 234-4663 2
Judge Bloch, Chair of the Board, authorized Intervenor to serve said exhibits by overnight delivery on the parties.
1 l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
) Docket Nos. 50-424-OLA-3 GEORGIA POWER COMPANY ) 50-425-OLA-3 g_t;. sLla.,, )
) Re: License Amendment (Vogtle Electric Generating ) (transfer to Southern Nuclear)
Plant, Unit 1 and Unit 2) )
) ASLBP No. 93-671-01-OLA-3 SERVICE LIST
- Administrative Judge
- Administrative Judge Peter B. Bloch, Chair James H. Carpenter Atomic. Safety and Licensing Board 933 Green Point Drive U.S. Nuclear Regulatory Commission Oyster Point Washington, D.C. 20555 Sunset Beach, NC 28468
- Administrative Judge
- Charles A. Barth, Esq.
Thomas D. Murphy Office of General Counsel Atomic Safety and Licensing Board U.S. N.R.C U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555
- John Lamberski, Esq.
- Ernest L. Blake, Jr.
Troutman Sanders David R. Lewis Suite 5200 SHAW, PITTMAN, POTTS &
600 Peachtree Street, N.E. TROWBRIDGE Atlanta, GA 30308-2216 2300 N Street, N.W.
Washington, D.C. 20037 1 Office of the Secretary I Attn: Docketing and Service U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Office of Commission Appellate Adjudication '
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 C:\ FILES \301\ CERT.LIS l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .