ML20128F738
| ML20128F738 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/05/1993 |
| From: | Kohn M AFFILIATION NOT ASSIGNED, KOHN, KOHN & COLAPINTO, P.C. (FORMERLY KOHN & ASSOCIA |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#193-13609 93-671-01-OLA-3, 93-671-1-OLA-3, OLA-3, NUDOCS 9302120015 | |
| Download: ML20128F738 (22) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ _ _ - _ _ _ - _ _ - - _ _
/3%07 UNITED STATES OF AMERICA
' $1.f NUCLEAR REGULATORY COMMISSION ATOMIC GAFETY AND LICENSING DOARD Boforo Administrativo Judgost Potor D.
Bloch, Chair Dr. James H.
Carpontor Q.{
- Et, j']'
Thomas D.
Hurphy
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)
In the Matter of
)
)
Docket Nos. 50-424-OLA-3 GEOhGIA POWER COMPANY
)
50-425-OLA-3 e_t iL,
)
)
Ror License Amendment (Vogtle '" e ctric Generating
)
(transfer to Southern Nuclear)
Plant, t..it 1 and Unit 2)
)
)
ASLDP No. 93-671-01-OLA-3 PETITIONER'S DRIEF IN RESPONDE TO Tl!E_ DOARp' D REQUJST _ FOR__Uff_QIyihtISN On January 15, 1993 the Atomic Safety and Licensing Board innued a Memorandum and Order requesting the parties to cubmit briefs with the Board.
Petitioner, tillen L. Mosbaugh, through counsel, hereby responds.
Ouentions Prenented 1.
What is authorized by the current licenso or included in the updated safety analysis report, with respect to whether the organizational structure for the operation of Vogtle may includo, directly or indirootly, SONOPCO of Southern Nuclear?
A review of, updates to the Plant Vogtle cafety analysis report demonstrates that GPC failGd to adequately report changes to Plant Vogtle management structure.
Specifically, after a joint " office of the chief executive" was established in or about 1988 and commenced exercising direct management control over Plant Vogtle (as well as GPC's and Alabama Power's other nuclear power plants), GPC failed to incorporated this change into any of 1
PDR ADOCK 05000424 40 3 9302120015 930205 G
the annual updaten to the Plant Vogtle safety analysis report:u.1 2.
Ilow do NRC regulations and practicos affect the interpretation of the licenso and/or t4... vpdated safety analysis report?
Pursuant to 10 C.F.R. 550.54(c), GPC was prohibited from annigning control over Plant Vogtle to its parent company, The Southern Company, or to any other Southern Company entity, including the Southern Nuclear operating Company.
Petitioner contendo that GPC commenced transferring dominion and control over aspects of its management of Plant Vogtle in ordor to comply with a directive issued by The Southern Company to create a Southern Nuclear operating Company over all of the nuclear power plants in the Southern system.
A Southern Company executivo, Mr.
Joseph Faricy (Eco Attachment 1 at p. 11), established an " office of the chief executive" to exercise dominion and control over all of The Southern company nuclear units, including GPC's Plant Vogtle.
The creation of this office without obtaining written approval from the Commission constitutes a violation of 10 C.F.P.,
550.54(c).2 Evidenco demonstrating the existance of the creation of 1
l a joint office of the chief executive was unearthed during a May
(
7, 1990 deposition of Mr. Joseph Farley.
Mr. Farley testified at length over his management role and the establishment of the creation of a joint " office of the chief oxecutive."
Soo Farley i
Deposition Transcript at pp. 12-17, 37-39 (appended as Attachmont i hereto).
2 In rolovant part, 10 C.F.R. 650.54(c) states:
Neither the licenso, nor any right thorounder (i.e.,
the right to manage administrative functions over Plant Vogtle)...shall be transferred, assigned, or disposed (continued...)
2
i Purnuant to 10 C.F.R.
SSO.34 (b) (6) (1), GPC Was required to updato the Plant Vogtle safety analysis report to includo en accurate statement of its " organizational structure."
Yet, to thic date, GPC han failed to notify NRC of the existence of the
" office of the Chief Executivo" that was created in or about 1988.
The fact remains that requiremeretc set out in 10 C.F.R. 5 50. 3 4 (b) (6) (1) constituten " essential" safoty-related information.
See In_r_o Public Service Co. gf New Hamprdilhph gl (Seabrook Station Units 1 and 2) CLI-90-02, 31 NRC 197 (March 1, 1990), and GPC's failure to accurately report the management changen over Plant Vogtic is of direct significance to the naio-operation of Plant Vogtle, Whether CPC has, in fact, failed to amend its safety analynic report to reflect management changea prior to tho request to trannfor opetation to Southern Nuclear is not essential to the determination of whether GPC's amendment requoct should be granted.3 What in essential is that Southern Nuclear 2(... continued) of in any manner, either voluntarily or involuntarily, directly or indirectly, through transfer of control of the license to any person, unless the Commission shall, after securing full information, find that the transfer is in accordanco with the provicions of the act and give its consent in writing.-
3 Pot'itioner contends that GPC's replacement of management over Plant Vogtle.was dono as a result of control exercised by GPC's parent company, The Southern Company.
Petitioner further contends that The Southern Company's exerciso of such control'over its subsidiary to re-align its nuclear management was. improper and that this Board cannot ratify past impropor control exercised by Tho: Southern. company over GPC when this resulted in replacing the management over Plant Vogtle'with' (continued...)
3
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have the requisite character and integrity to operato a nuclear facility.
5 Pursuant to 10 C. I'.It.
%SO.90, the proposed amendment muut comply with all applicable requiremento of the originni licence.
It is therefore incumbent upon this Board to consider the -entire alignment of Southern 11uclear'n Gir_rf.Rt management structure '
l If the menagenent alignment of Southern llucicar cannot comply with the requiremento imposed when the original licence wac innued, then it in incumbent upon this Board to deny the.
amendment.
Enn, 0 9., lint 1911Rlitiin_12dson Compnuy (Throo 1411e Island 11uclear Station, Unit 1), CLI-85-9, 21 111tC 1118, 1136-1137 (1985).
3(... continued) managers lacking the requisito charactor and integrity to operate a nuclear facility.
Petitioner is of the' opinion that at the timo GPC.
applied for its licenso in 1987_its managemont-did have the requisito charactor and competence to operato a nuoloar power plant.
-Dut, over timo, GPC's management team was.ro-configured to accommodato The Southern company's establishmont PC 00NOPCO.
-As a result-of this transition all.of GPC's lino manugers over the plant manager have boon replaced.
This now management alignment chosen to staff DONOPCO no longer maintains the requis'.'.o charactor and integrity to operate GPC's nucioar-facilitios.
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To what extent, i f any, is the charactor ot competence of individuals already jointly employod by Georgia Power and southern Nucioar in the management of Vogtle relevant to the approval of the requested licenso amendmont?
Currently, there are two on-going parallel proceedingo; one concerna the charactor and cor potence of GPC'n management (heroinafter referred to au the "2.206 proconding")S t the other concerna the character and competence of Southern Nuclear'c management (horoinafter " intervention proconding").6 Where the 2.206 procooding directly challongan the management integrity of Off, the intervention proceeding does not.
The intervention j
proceeding in limited to whether Southern Nuclear's management han the requinito charactor and competence to becomo the licenced operator of Plant Vogtle.7 5
The first procooding concerns a 10 C.P.R.
02.206 petition beforo NRC Staf f sooking that GPC's licenso be revokod, suspended or modified becauso its current management does not embody the requisito charactor and integritV to operato-a r.uclear facility.
Under Inw, 2.206 Petitioners _aro prohibitod from taking any further action 14nd must await _the outcomo of NRC Staff's investigation.
It is significant that the 2.206 Potition was filed on Doptember 11, 1990 and that, as of this dato, NRC ataff is unproparud to state whether GPC is op9 rating Plant Vogtle in accordanco with its licenso.
This proccoding atoms from GPC's September 10, 1992 6
filing of an application to amend the license of Plant Vogtle to include Southern Nuclear as the operator of Plant Vogtle.
Thereafter,-Petitioner Allen Mosbaugh intervened in this proceeding and claimed that the managers in control over. Southern Nuclear do not havo the charactor, integrity or~compotonco to becomo the licensed operator of Plant Vogtle.
The fact that GPC's management structure is identical to the Southern Nucioar management structure (with allogod exception that GPC's Prosident, Mr. -Dahlberg currently-sorvos as the CEo) is an outgrowth of the powor'and control The Douthern company exercisos over its subsidiarios.
Petitioner socks to admit a contention challonging The Douthern Company's charactor (continued...)-
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usc's dec!nion to go forward with its requent to amend Ato l
license necessarily imposos a duty upon. thia Board to determino that the cittrxtli; Southern Nuclear management satisfica tho charactor nud competence requiremont overy operator need octabbah bofere they nav be grantro a liconnu to operato a nuclear r&uility.
In num, it in invultbott upon GpC to show that the proponed Dedt management of Scottorrt Nuclear -- not the 91d management of GPC -- han the requisito charJCtor and integrity to operato a nuclear facility.
Petitioner has the right to inniot before thin Board that nny management has the requinito charactor and competence to operato Plant Vogtle.
Finally, this Board should be awaro that by ignoring the managoment and integrity incue of all of the current Southern Nuclear managers, Southern Nuclear management will be encourage to engage in the similar type of misconduct Petitioner rollos-upon to demonstrate that Southern Nuclear management does not have the requisito charactor and competence to operato a-nuclear facility.
If this Board-approven the transfer Mr. Mosbaugh will be in.a far worso position becauco it would encourage Southern Nuclear management tu engago in the very type of micconduct Mr.
T(... continued) and intogrity because it is capable of influencing,. and had influenced, tho charactor-and competence of the-management structure over Plant Vogtle.; In this respect, the fact-that all of Tho Douthern company nuclear power stations are currently managed by Southern Nuclear indicates.that a flaw in Tho Southern.
Company management'e assessment of charactor and integrity has filtorod'down to the management over Plant Vogtle.
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!!anbaugh fearn could result in a nuclear accident.
On the n til a r hand, if thin Board denien the trannfer, Mr. Monbaugh will be in a bet.ter pocition beenune future potential management minconduct would be chilled."
GPc's argument that this Doard must only considor the 8
integrity and charactor of memborn of management not already apart of GPC's nuclear operation is illogical.
For examplo, assuming GPC altered the design of a critical safety feature of Plant Vogtle without notifying tho 11RC and then operated the It does plant for a period of years without adverso consequence.
not stand to reason that, should GPC nook to amend its technical specifications to accommodato this chango, that Mr. Mosbaugh would not have standing to challongo the potential safety consequence because NRC did not immediately act to shut down the plant after learning of the chango.
Just as Mr. Mosbaugh would have standing to challongo the chango in technical specifications, ho in equally ontitled to standing to challengo the amendment to GPC;o licenso which socks to install an entirely now management over the plant.
The fact that the final management configuration was assimilated into-0PC's current management structuro does not offect the nafety significance of that chango.
7
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CQllcluluipf) j The Board muut treat the amendment to the licenno in the f
came manner an if Southern 11ucicar van necking before the Board an operating licenno.
Thin Board munt grant lir. Monbaugh ntanding if the propocod nny management over Plat.4 Vogtle could adversely offect hio health and nafety.
C1carly, if, no fir.
f lionbaugh allegen, the management of Plant Vogtle dooo not_ havo-
[
the charactor and integrity to operato a nuclear facility, then allouing Gouthern lluclear to operato Plant Vogtle can result in adverse of fects to 14r. tionbaugh's and the entiro local community's health and cafety.
An auch,14r.-.tionbaugh han standing.
nonpoctfu13y_ submitted,
],^g, W Michael D. Kohn Koll!!, KO!!!! b COIAPl!1TO, P.C.
517 Florida Avo., li. W. -
Washington,.D.C.
20001 (202) 234-4663 Dated:
February 5, 1993 054\\brief.gpc 4
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1 U t11 T E D STATES OF AMERICA DEPORE Tile U.S.
DEPARTME!1T OF LABOR 2
3 M A R V I !J H.
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4 C o in n l a i n a n t,
) CIVIL ACTION l
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) FILE NO.
S vs.
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6 GEORGIA POWER C O M P A !1 Y',
) 90-ERA-30 7
R e n p o li d e n t.
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1 13 14 DEPOSITION OF I
15 JOSEPil M.
FARLEY l
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.U U L L- &-ASSOCIATES COURT AND D E P O S I T I O11 REPORTERS f
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Deposition of J O S E l'!!
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- PAHLEY, l
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taken on behalf of the C o rn p l a i n a n t,
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for the purpono of discovery, upon i
J croun-examination, before Susan E.
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5 Reynoldo, Itegistered Professional 6
Hoporter, Certifiod Court Reporter
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7 and 11 o t a r y Public, at the Candler
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13 u i l d i n g,
127 P<nchtree Street, j
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13. E., Suite 1400, Atlanta, Georgia, li 10 commencing at approximately
!4 y'j 11-2:30 p.m.,
tin y 7,
1990.
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any e x e c u t. i v e on iny of t.h o n e ?
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No.
I do not beiieve they ore.
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who do you ieport to?
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Yen.
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O Who do you repott to there?
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The Pienident and the Chief 9
1:xecutive ottice2 of that company, ti r.
Alan 10 Franklin, and tof ce in purpocer, I report.
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Bauically, however, my reporting in to i
12 1 14 r. Edward L. Addinon who in Pre ident and C IC O i
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An I mentioned, I am l4 an oiiicer of the S o u t. h e t n Company b u t.
both ti r.
I 15
!Addinon and I are paid by Southern C o ta p a n y 16 IServiceu.
The SCC doen not banica11y a11ow ieparate lthe holding company to maintain a 17 18 payroll.
So we are employeen of
- t. h e Sesvice 19 Company i: o r pay purponen but my banic reporting 20 tenponsibility is to 14 r. Addinon.
?1 Q
At Southern Company you report ' t. o 22 i 11 1 Addinon?
i 23 i
A Yes.
24 Q
Doon 14 r. 11c D o n a l d report to you?
25 A
fi r. tic D o n a l d and I wotk
- t. o g e t h e r and 1
BULL & ASSOCIATES
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I have a c 1 o r. e worAiog ieIationuhip, we, in 4
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oc c O jiy
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til j o i fi t I f * !i])(a ll !i i b i.l i t. i e it ;
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1 with the pioject with which we'se involved but
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Iot mont porponen, re po r t t..
me.
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lj u t he doen 1 os n o rn e putponen9 i
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We have a close relat ionnhip on we j
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a te d on]y in 1he
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i administrative 1:ui t t e i n d o e t.
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nenne of some 10 report to me or wotk w i t< h me.
O ti r r e l a t. i o n u h i p_
11 i<. inore informal than nimply r e p o t t.1 n q.
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O So on paper he doen not necennatily 13 report to you but informally he does report. to 14
- you?
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16 MR.
G C il A U DI E S :
Exeuno in e,
17 Mr.
"arloy.
Let me just reginter an 10 objection hete and t h a t.
in
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thic deponition inn't 20 trying to i n <1 u i r e into the reporting 21 relationnhj p h e t.w e e n fi t fic Do n a l d of 22 Mr.
Parlev or whoever else which wan I
-23 part of the a l l e g a t. i o n n I realizo 24-that were rained by Mr.
Il o b b y.
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I 25 don't believe
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in rolovant
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to the innue of whether he was 2
retaliated against. for raising thonc 3
allegationn.
I would like to make a l
4 standing objection to thin line o f-5 inquiry and allow the wituens to go
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full disclonure and toward expediting 8
the deposition -but, if I may, it w i l'1 p
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entire line of i nquiry.-
j 11 MR. K O ll!1 :
You may cortainly p
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13 MR.
G Cll AU DI E S :
So 1i you can
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14-remember the question,.which I'm.
o 15 afraid I can't, you can'answor_it.
-1 16 T !!E W I T 11E S S t-I'm.norry.
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17 can't.
18 0
(By Mr.- Kohn)
Okay.
The quantion-19
- was, in esuence then, on paper.Mr. Mcdonald:
20 does not technically r e p o r t.
t o you but he doon t
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21 in an informal sonne?'
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O n.~ nome: matters in-:an informal
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Q-Can you tell.mo which matt. ora on: -an a
-2S informal sense?
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.In an i n f o r tn a } senne, he and 1
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jointly are what we describe an an atiice of 3
the chief executive of the p r o j e c t..
It in not project.
In arran uuch l 4
la corporation.
It in a i
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- au
- t. h e c e l e c t i. o n of a enndidate for an 6
Iaccounting job or a job in the non-operating 7
arean.
When I say operating, I mean the j
8 operating of the powe2 plantu themnelven.
He 1
9 l doe-not report to me and yet on the other 10 i areas, particularly administrative or in i
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11 j g o v e r n in e n t a l affairn which in part of my i
i 12 renponsibility, he would report to no in that 13 nense.
If he were asked about volunteering to 14 be a w i t. n e s s in a congreacional proceeding I
15 having to do with advanced 1.i g h t water l
16 lreactorn, he would nok me about it before he i
17 iwould accept that.
That relationnhip,
- however, i
la does n o t.
apply when i t.
c o m re s to Plant Vogtle, 19 Plant fl a t c h or Plant Farley where he does not 70 report to me but report.n to the chief executive i
21 officer of Georgia Power Company or Alabama 22 l Power Company respect.vely.
23 l
0 lic reports to thone individualn?
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A Yes.
25 Q
But doen he dit.cunn the operation of 1
BULL & ASSOCIATES i
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1 naybe three days week and I woul.d-usually n e r not 24-
,Oglethorpe Power has asked any questionc of 25
! anyone of the Southern System as to whom f4 r.
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report to him.
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Q Is that a Mr.
Long7 j
ws :
-pi A-Y e s,- Mr.
Lou L o n g ;-- Louis Long_,
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Q And he in'the Vice President 01.
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_k l Technical Servicos?
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7 A
Yes; and he.is a-. S o u t _h e r n Company
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- Services-employee.
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-Then there's also an administrative _
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A Yes.
The Vice Prenident of-
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- g pf 13 He in _a Service Company employee.
Hg reports
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.both to me and to Mr. Mcdonald -
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p fwhat I described earlier a s - a -- k i n d.o f-15 DM i
i 16 j of the chief executive-for_.the p r o j e c t:- o n -
i 17 administrati've matters, not on' technical 18 matters.
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Mr.
Long and Mr. McCrary report l direct-ly.
Mr.
Mcdonald and_-then throug'h there--j 20 to i
-21 lthey report directly t o :' y o u ?
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Mr.
Long'does not report to-me.
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because.this: is a technical.i 23-Now, Nr~
McCrary 24 area 'with which I do not-exercise direct-E '{
25 supervision, I work with that group._
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in essence, under me in'the organization-but 2
they do not report to me..
They report' toffr.'
3 f4cDonald.
In the case of fi r. - !4 c C r u r y,
for l.-
4 purposes of this project, there are many things: f 5
that Mr.
fic C r a r y reports to directly ti o me i
6 about and others he reports joi'ntly.to me' and I-7 to !4 r. 14cDonald or to whichever one of us 8
happens to be there.
fi r. - Mc D o n a l d and I 9
undertake to be in this transition period of-4 10 sort of a joint office inn. the--twim i n i s tI.a_tM.e,
11 siAc.
I can. furnish you that organization 12 chart if you want it, It's the same chart-13 that's a record with the SJC that we have 14 furnished.
15 Q
I would appreciato that.
16 A
- Fine, 17 (Brief pause,)-
18 Q
(-By 14 r. Kohn)
Is therefa document'
=
19 which -sets up-the structure and' function of t h o-l
.t-20 l S O f10 P C O Project?
l -.
I
'21 MR, SCHAUDIES:
At what point I
22-
-i n time?
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23 MR., F O H fJ :
C u r r e n't ly D o r one 24
'.t h a t i s' 's t i l l in effect.
t 25-A The. initial filing with theSEC y
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=1 describes-this to som6 extent.
We have -- I
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l wi11 be honesL with you, I am not aure-thal we-3 have such-a single document that describes j
i 4
this.
As you may know, we had anticipated that '
5 we would arrive at a corporate stage fairly 6
'soon which it has turned out not to be-the i
7 icase.
We havo had many descriptions given-of i
8
!what we are doing but as to a single document, 9
I would have to review it to find out if we 10 have such a document, i
11 0
(By Mr.
Kohn)
Was there a d o c u me.. t i
i 12
[ presented to the Southern Company Board of 13 Directors regarding the structure of SONOPCO i
l'and/or i
14 the SONOPCO Project?
l i
15 A
I report to the. Southern Board l
16
, quarterly on the status o f - t h e o r g a n i z a t i o'n i n 17 lwhat we're doing.
Again, wh~en we-received or 18 when they approved the concept they
'd i d not 19 actually give they have no authori-ty to 20 actually approve anything o t h e r. than-the filing.
21 with the Securities and E x c h a n _g e ' C o m m i s s i o n'.
22 The structure is that that Iiling has_to i
1 23 l precede their approval.
But since t h a t _.t ime I j
r 24 1 do.not think they have received a ' document l
1 25-other than just'the current report from me
._.i BULL & ASSOCIATES
4 40-1 h
on the progress and performance.
1
{ quarterly 2
Q Quarterly report on-the progreso of-3 formation of the SONOPCO C o r p o r a t. i o n ?
4 A
01 the performance of the units and i the progrecs toward our ultimate organization 5
4 6
and that's a verbal report.
7 O
And where do you o b.t a i n your 8
,information to advise the Roard of the statun?
9 A
I know the information.
I receive 10 of course (as everyone else does) reports from-the people with whom.I work.
I' receive-reports 11 4
12 from Mr.
- Mcdonald, Mr.
ll a i r s t o n,
Mr.
McCoy,_Mr.
i 13 i Long, Mr.
McCrary and I have put together-a i
14 l format, in my own mind, of what I think in 15 important which alwayn includes -"where are we" negotiations toward the creation of the 16 in our a
17 corporate entity which then would be much 18 easier t~ o r everyone to understand.
19 0
And these are oral?
20 A-Yes.
1 21 Q
Are the meetings transcribed?
22 A
The usual minutes simply include Mr.
23 Farley reporting on-nuclear-performance and the q
24 ntatus of.SONOPCO.
r
- 25 Q
Were you apprised of the l
L-BULL & ASSOCIATES
NUCLEAR' REGULATORY-COMMISSION _
khc
- UNITED STATES L OP.- AMERICA :
. ATOMIC SAFETY AND LICENSING BOARD
'93 FEB -8 P 4 L;21'
-Before AdministrativcfJudges:-
Peter B.
Bloch, Chair; Jgg' ),y{tgf-l g
Dr. James H.
carpenter:
Thomas D.
Murphy _
gagg.
=
)
In the Matter of
)
)
Docket Nos. 50-4 24-OLA GEORGIA POWER COMPANY
)
5 0-4 2 5-O LA-3 ~
nt'alz,
)
)
Re:-License Amendment (Vogtle Electric Generating
)
(transfer to Southern-Nuclear)-
Plant, Unit 1 and Unit 2)
-)
)
ASLBP No. 9 3 - 671-01-O LA-3 CERTIFICATE OF SERVICE' I hereby certify that on February:5, 1993. Petitioner's-Brief-in Response to the: Board's Requst for INformation was served by.
facsimile upon the following:
AdSinistrative Judge Peter B.
Bloch,_ Chair Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge
-Dr. James H.
Carpenter Atomic. Safety 1and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Thomas 06 Murphy Atomic Safety _and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 (continued on next page]-
1-i ha p-g
N, h
a:
m.
p,e*-
- Charles'A. Barth,- Esq.
Office of General 1 Counsel "U. S. - Nuclear-Regulatory Commission-Washington,:D.C.
20555.
- J ohn Lamberski, Esq.
Troutman Sanders Suite 5200 600 Peachtree Street, N.E.
Atlanta, GA 30308-2216 And, by first class mail, postage: prepaid,Lon February 5,_1993,-.
upon the persons listed on the following page:
- Office of the Secretary-(* Original and-two copies)
Attn: Docketing;and Service U.S.-Nuclear Regulatory Commission Washington, D.C.
20555 Office of-Commission 1 Appellate
-Adjudication-U.S. Nuclear ~ Regulatory Commission-Washington, D.C..
20555-1 i
- Michael D.
Kohn~
- t Kohn, Kohn'& Colapinto,=P.C.-
517 Florida" Ave.,
N.W.-
Washington,-TD.C..20001
.(202) 234-4663_-
?
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