ML20100B691
| ML20100B691 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/07/1995 |
| From: | AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| OLA-3-I-MOS-233, NUDOCS 9601190271 | |
| Download: ML20100B691 (7) | |
Text
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rn 00CKETED USERC Page 461 BEFORE THfS5 0CT 20 P3 :28 UNITED STATES DEPARTy NT OFcLABOR,iT(
D O CKi'. i !'Js i
.;c ALLEN L. MOSBAUGH, VOLUME JJ_T.
Complainant, Case Nos. 91-ERA-01 vs.
91-ERA-11 GEORGIA POWER COMPANY, l;
Respondent.
ll 3
a j
Hearing Room A, Suite 2400, 101 Marietta Tower, i
101 Marietta Street, N.W.,
Atlanta, Georgia i
i Thursday, March 12, 1992 It The above-entitled matter came on for hearing, i
pursuant to Adjournment, at 9:00 a.m.
I BEFORE:
i !
HON. ROBERT M. GLENNON, Administrative Law Judge J
APPEARANCES.
On behalf p_f the comolainant:
MICHAEL D. KOHN, Attorney, STEPHEN M. KOHN, Attorney, i
Kohn, Kohn & Colapinto, 517 Florida Avenue, N.W.,
Washington, D.C.
20001 SANDRA MICHAELS, Attorney, 142 Mitchell Street,-S.W., Suite 300, Atlanta, Georgia 30303 NUCLEAR REGULATORY COMMISSION Docket No. 50-42414P5-OLA 3 EX'HIBITNO _3 - T U in the matter of Geornia Power Co et al., Vootte Units 1 & 2 96 11 b h 0500 424 O Staff O Applicant [QAdervenor O Other PD PDR O ! dent;f Meceived O cted Reporter 5p l
Date h
~1 l9I Witness
@ 3*okl-sId
,a t
'Page 462 IEDEX WITNESSES:
DIRECT CROSS REDIRECT RECROSS A. W.
Dahlberg 465 479 512 513 Charles Kenneth McCoy 516 587 t
George Bockhold, Jr.
630 678 EXHIBITS:
IDENTIFIED RECEIVED Respondent's:
5 - Letter 6/13/90 Premarked 629 j
11 - Letter 7/24/89 14 - DOL Statement 629 i
22 - Statement read on site 595 27 - Ebnetter Letter 629 28 - Letter to Mosbaugh 629 29 - NRC Guidelines
)
32 - Bockhold Memo 629 31 - August Counseling Session 35 - Termination Statement 629 37 - 1989 Annual Review 629 40 - Business Ethics Policy 629 41 -
629 42 - Bockhold letter 44 - Bockhold letter 62 - Target Organization Package 629 71 - Bockhold Letter 629 78 - Organizational chart 629
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b Page 599 1
A.
Yes, he did.
4 2
Q.
And Mr. Greene reported to Mr. Bockhold?
3 A.
That's correct.
i 4
Q.
And when Mr. Mosbaugh became the acting general 5
manager, he no longer reported to Mr. Greene; correct?
4 i
6 A.
That's correct.
7 Q.
He reported directly to Mr. Bockhold?
8 A.
That's correct.
9 Q.
Did you know that Mr. Mosbaugh would be placed in 10 the acting general manager plant support position?
11 A.
Yes.
That was discussed with me prior to --
12 Q.
Did you agree with that placement?
13 A.
Yes, I did.
14 Q.
During your deposition did you state that over the i
15 period of '89 '90 that Mr. Mosbaugh's communication 16 capabilities had improved over that year?
17 A.
I don't recollect what I said in the deposition 18 about that subject.
19 Q.
If I may just read you a question and answer from 20 your deposition, maybe this would refresh your recollection.
j i
21 Question --
22 MR. JOINER:
Your Honor --
4 23 MR. STEPHEN KOHN:
I'll show the witness the 24 deposition.
25 MR. JOINER:
Yeah, I'd appreciate that.
l Page 600 1
BY MR. STEPHEN KOHN:
2 Q.
Could you please read on Page 47, please read Lines 3
11 through 147 4
A.
Line 11, question:
"So then it's fair to say that 5
Allen showed improvement in his ability to get along for 1989 6
to 1990; correct?"
7 Line 14, Answer:
"Yes, that's correct."
8 Q.
And do you stand by that testimony today?
9 A.
Yes.
10 Q.
Thank you.
You can just leave that up there.
We 11 may be needing it.
12 You testified that teamwork and cooperation was a 13 major concern of yours coming into the year 1990 at Plant 14 Vogtle?
15 A.
I believe my testimony was that from the time that 16 I arrived there that it was a concern of mine.
17 Q.
Do you believe that if one manager accused another 18 manager of criminal action and filed a criminal charge that 19 that act may hurt teamwork between those two managers?
20 A.
Certainly.
21 Q.
And it could interfere with the cooperation between 22 those two managers?
23 A.
Certainly.
24 Q.
Yet under your policies that you orally enunciated, 25 and the law, it would be the obligation of that manager who
i Page 690 1
A.
His annual review?
2 Q.
His 1989 annual review was filled out after the OI 3
investigation into the opening of the valves, dilution 4
valves?
5 A.
Wasn't the OI investigation about the same time 6
frame?
I have a set of notes as far as time goes for that OI 7
investigation.
8 I have February of '90 was the -- some time in 9
February was the OI investigation into the mid-loop, and the 10 annual evaluation was signed in February of
'90, so it was 11 about the same time.
It was not necessarily after or before.
12 I don't remember the exact dates.
13 Q.
Okay.
That's fine.
14 So prior to the --
15 A.
And that evaluation was a good evaluation.
16 Q.
And prior to the OI investigators coming on site, 17 you had heard that there was going to be an investigation; 18 isn't that correct?
19 A.
Yes.
20 Q.
And is it fair to say that management was 21 speculating as to the source of the investigation prior to 22 the OI investigators coming on site?
23 A.
I had asked Allen --
24 JUDGE GLENNON:
I'm sorry.
May you could try to 25 respond to the kernel of the question, and then --
i
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Page 691 1
THE WITNESS:
Would you repeat your question so I 2
can try to respond better?
3 BY MR. MICHAEL KOHN:
4 Q.
Management was speculating --
t 5
A.
Management, sir, is who?
6 Q.
You and above, and your immediate -- anyone with a l
7 manager title at Plant Vogtle and SONOPCO, there was some l
8 form of discussion concerning who could have originated that 9
OI investigation, wasn't there?
10 A.
Yes, there was some sort of discussion because we 11 wanted to improve communications.
12 Q.
And during the course of that discussion who did 13 you limit -- I mean didn't you try to focus on who that could 14 be?
15 A.
I did not.
I was not interested in the individual, 16 I was interested in if there was an area to try to 17 communicate better with a particular organization.
18 Q.
And you concluded that it had come from Mr.
19 Mosbaugh's side of the plant?
20 A.
I didn't conclude that it came from any particular 21 side of the plant.
I thought that it might have come out of 22 engineering.
23 Q.
That reports to Mr. Mosbaugh?
24 A.
It does report to Mr. Mosbaugh.
25' Q.
Now, isn't it true that as the NRC OI investigation
' sy....
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4' i
Page 697
[
i 4
1 A.
I didn't evaluate the status of the plant at that j
2
.particular.
3 Q.
But~ eventually you learned it was at mid-loop; is 4-that correct?
l 5
A.
I learned that the plant was at reduced inventory,
[
]
6 but I didn't know the exact sequence or the exact timing in 7
relationship to this memo.
8 Q.
Now, after September 15th Mr. Mosbaugh told you 9
point-blank that the plant was at mid-loop; correct?
10 A.
Yes.
f 11 Q.
Okay.
And weren't you somewhat concerned that such 12 an expert as Mr. Kitchens would make such a fundamental error i
13 in not realizing whether the plant was at mid-loop or not?
1 2
14 A.
Mr. Kitchens evaluated the situation at this point.
15 I believe that he told me in this memo the truth as he 16 believed it at this point.
17 When a deficiency card is written people 18 investigate further what went into the situation, and when a 19 concern is written it's investigated further and other facts j
I i
20 may come out.
r 21 Q.
And that deficiency card was written at Mr.
22 Mosbaugh's insistence?
23 A.
Mr. Mosbaugh was responsible support manager 24 responsible for identifying potential licensing event 25-reports.
It should have been written at his or anybody I
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