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October 28, 1994 cm v. M MEMORANDUM T0:
James L. Milhoan, Deputy Executive Director f/.T for Nuclear Reactor Regulation p aa i ^-' Operat' =
- Research
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THRU:
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ector Office of Investigations WilliamJ.McNulty,FieldOfficeDirector(
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Offi of Invest a ions Field Office, Regi II s
FROM:
a ry
- nson, Investigator Office of Investigations Field Office, Region II
SUBJECT:
NRC 0FFICE OF INVESTIGATIONS ANALYSIS AND POSITION ON GEORGI.a POWER COMPANY'S RESPONSE TO ENFORCEMENT ACTION, V0GTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2
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By direction of your memorandum dated August 4, 1994, submitted herewith is the result of the Office of Investigations (01) analysis of the Georgia Power Company response to enforcement action (GPC Response), as it pertains to the conclusions in the OI Report of Investigation (ROI), Case No. 2-90-020R.
a BASIS FOR ANALYSIS 1
The GPC Response did not directly address the conclusions contained in the ROI. The Response addressed the violations that were issued as a result of the deliberations of the NRC Vogtle Coordinating Group. Therefore, the documentation and interpretations contained in the GPC Response were somewhat tangential as applied to the 01 conclusions.
RESULTS OF ANALYSIS The 51 conclusions, as stated in the ROI, are unchanged following our analysis of the GPC Response.
OI believes the preponderance of evidence continues to support the 01 conclusions regarding the actions of GPC personnel identified in the ROI and the degree of willfulness associated with those actions.
It is noted that NRC Agency conclusions regarding whether or not these actions constitute violations of NRC regulations or requirements falls under the purview of the NRC Office of Enforcement, in conjunction with the Office of General Counsel.
01 disagrees with many of the GPC statements and characterizations in the Response.
Because of the indirect application of the NOV Response to the 01 conclusions, this analysis will address only the major areas of 01 disagreement with issues e': pressed by GPC in their Response.
((
ea ooe m so 960 m PDR FOIA WILMOTH93-81 PDR
J. Milhoan The major areas of disagreement are:
1.
Page 2, Para.1, Line 4 of the letter, dated July 31, 1994, from C. K. McCoy to James Lieberman, captioned GEORGIA POWER COMPANY V0GTLE ELECTRIC GENERATING PLANT REPLY TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES; EA 93-304 (hereafter, the Transmittal Letter) states
- i Intent to comply with NRC rules, regulations or orders is not at issue here; GPC always intends to obey the law.
01 Comment: As it applies to the 01 conclusions, intent is a central issue.
From the evidence obtained in this case, it cannot be assumed that GPC always intends to obey the law.
2.
Page 2, Para. 2, Lines 4-6 of the Transmittal Letter states:
Inaccurate information resulting from personnel error was included in the April 9 presentation to Region II.
OI Comment: This is the cornerstone of the GPC response. GPC claims that the inaccurate diesel start numberc presented to NRC on April.9 were due to innocent oersonnel error.
If NRC focuses on the absolute numbers, and accents the assertion that a " mistake" by Cash was the cause of the l
numbers not being precise, the remainder of.the GPC claims regarding the April 19 LER, the June 29 Revision to the LER, and the August 30 letter seem to build logically on that foundation.
The basis for the OI conclusions regarding the April 9 diesel start data (both the oral presentation and the letter) is agi that the numbers were not exactly correct, but that the numbers presented to NRC by GPC depicted the diesel testing since'the March 20 event as being only
" successful" testing, with "no failures or problems."
The numbers that were obtained by Cash for Bockhold, regardless of their absolute value, were deliberately ordered by Bockhold not to contain any i
starts with problems or failures. To present this subset of diesel l
starts as " DIESEL TESTING" (the heading of the slide in the April 9 presentation) with "no failures or problems" since March 20 (the statement in the April 9 letter) is not innocent personnel error.
It is a presentation to NRC of deliberately incomplete data.
i If GPC wishes to present only successful test data, it is their responsibility to identify it as such.
It should not be presented as representing all the diesel testing between March 20 and April 9.
Regardless of what GPC thinks is the extent of NRC knowledge regarding the specifics of VEGP diesel testing between March 20 and April 9, 1990, if GPC presents " DIESEL TESTING," it is required to provide complete and accurate information regarding this testing in any communication to NRC.
^ i o-l l
J. Milhoan -
4 3.
GPC claims that it has always been Bockhold's understanding, since before the time he first sent Cash to obtain the successful diesel start data, l
that the data would contain only consecutive successful starts, and that 1
the start count would-not begin until after the Calcon switches had all
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been recalibrated or replaced.
01 Comment: Despite Bockhold's statements to that effect in his 1993 OI interview and in his communications with the NRC IIT prior to April 9, the key issues are:
(1) his actions at the time of actually obtaining i
the data, and (2) how this data was presented to NRC in support of a j
restart request.
l At those critical junctures,.the evidence shows that he did not instruct-l Cash that the successful starts be consecutive, or that they begin after the Calcon switches had been corrected. Based upon his limited i
instructions to Cash, Bockhold had no leaitimate basis to assume or l
believe that Cash's count of successful starts was consecutive, or that i
it beaan after the switches were fixed.
Both the April 9 presentation i
slide and the April 9 letter portrayed this data as being the diesel testing done since the event (the March 20, 1990, Site Area Emergency).
i Neither of these documents portrayed the data as being a consecutive number of successful starts after the Calcon switches were fixed.
j!
Although the NRC assumed the starts to be consecutive, there is no evidence that Bockhold told the NRC that they were, in fact, consecutive.
7 l_.
Both NRC and GPC agree that, although GPC's presentation of diesel testing did not consist of all valid tests,'and was not a formal. Rea i
Guide reliability reaualification of the diesels, the data presented on April 9 pertained to a key restart issue, namely a measure of diesel reliability. So, in the gathering and presenting of this key information....if Bockhold has always thought of these successful starts
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as being consecutive, and only started after the switches were fixed, why L
didn't he specifically instruct Cash to that effect? Why didn't he actually tell NRC, on April 9, that'the successful starts on his presentation slide were bounded by that criteria? Why didn't the April 9 j
letter mention anything about those limitations?
GPC would have NRC believe that Cash was of such the same mind as Bockhold that such detailed instructions were unnecessary. 01 disagrees.
GPC would have NRC believe-that the NRC assumotion, on April 9, that the starts were consecutive was the only logical assumption, and that it didn't need to be expressly stated in either the presentation or the letter. 01 disagrees.
j
'01 notes that Bockhold stated,-in his 1993 01 interview, that he knew he had to i; ave a significant number of successful starts for the April 9 presentation, and that if Cash had not come back with enough, Bockhold l
would have " started the engine a bunch more" before the presentation.
It is 01's vtew that the more logical reason that Bockhold did not instruct Cash to get consecutive successful starts, was that an instruction to 4
f.
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J. Milhoan that effect would never increase, but would probably serve to decrease, the number of successful starts obtained by Cash.- Instructing Cash to start his count after the switches were-fixed would probably further decrease the potential number of successful starts.
Bockhold did not want to decrease that number.
It is also 0!'s view that the more _ logical reason that Bockhold did not expressly tell NRC, on April 9, that the starts were consecutive was that he knew that he had no real basis for making that-statement, and was content to let NRC assume that they were consecutive.
OI has noted that the GPC Response presents testimonial evidence from the VEGP secretary that assisted-in the preparation of the slides for the April 9 presentation. This secretary was not interviewed by 01. GPC asserts that Cash had a draft of the slide before he prepa. red his list of starts, and that this secretary observed Cash making adjustments to the numbers on the draft of the " DIESEL TESTING" slide. Cash's testimony of August 1990 conflicts somewhat with his testimony of June,-1993 regarding his provision of specific numbers to Bockhold for the " DIESEL TESTING" slide.
In 1990, when Cash was being interviewed during an insoection, primarily by an'insoector, and the issue was presented to him as being a-matter of the mere accuracy of an absolute number of successful diesel starts, he said he gave the 18 and 19 numbers to Bockhold.
In 1993, when Cash was being interviewed under subpoena, by an investiaator, in the conduct of an investiaation of a potential deliberate false statement, he did not recall giving any specific numbers to Bockhold and said that if he had, the numbers would have been greater than 18 and 19. Cash said that he assisted the secretary with only the format of the slide and did not have anything to do with the actual numbers on the slide.
j If GPC's characterization of this secretary's testimony is accurate, and the secretary's testimony is.the truth, it is logical to conclude that Cash may well have adjusted the " successful start" numbers below the lines under the columns of test descriptions on the slide. This conclusion would be based not solely upon the secretary's testimony, but upon her testimony combined with the testimony of Bockhold, Eckert, and Cash's 1990 testimony.
i However, even if Cash returned from his research with numbers greater than 18 and 19, and then adjusted the numbers on the slide to 18 and 19, based upon the numbers in the columns above the line, OI's conclusions regarding Bockhold's presentation of this data to NRC remain unchanged for the previously stated reason that in the limited instruction that Bockhold did give to Cash, he specifically excluded any problem starts.
4.
Page 2, Para. 2, lines 11-13 of the Transmittal Letter states:
Concern had been expressed within the organization about the erroneous information on multiple occasions during i
4 J. Milhoan period of time, and two opportunities (April 19 and June 29) to identify the error were missed.
01 Ccament: The incompleteness and inaccuracy of that information was specifically identified by Mosbaugh and Aufdenkampe to Shipman and Stringfellow on April 19, 1990, prior to the issuance of the April 19, LER. There Marg failures and problems in the diesel testing since March 20. The opportunity to identify "the error" was not missed.
It was identified and covered up in the April 19 LER, and then attributed to false causes in the June 29 LER Revision and the August 30 letter.
The events of April 19, 1990, are the most significant in the series of inaccurate and incomplete statements given to NRC by GPC.
It is at this point in tirae that the Senior Management of GPC has it's best opportunity to correct any possible misconceptions, if in fact they existed, in the minds of NRC regarding whether or not there were any diesel test failures between March 20 and April 9.
At the same time, GPC Senior Management could properly resolve the expressed concerns, real or perceived, of
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Mosbaugh and Aufdenkampe regarding this issue. All that was needed was for someone from GPC to say to NRC something to the effect of: As a result of some expressed concerns from two of our employees, we (GPC) wanted to make sure you (NRC) didn't get the wrong impression from our April 9 presentation and letter that there weren't any diesel test failures between March 20 and April 9.
As you may be aware, we had some early failures and problems on the 8 machine while returning it to service after maintenance, but we've had eno. ugh consecutive successful starts since then to convince us of its reliability.
However, GPC had just received approval to restart the plant on April 12, and had just recently ascended, or started the ascent, to full power.
Drawing NRC's attention to potential false statements, real or perceived,
-could again jeopardize restart.
So, when'McCoy called Brockman on
. April.19, there is no evidence that he told him about failures or problems after March 20, but rather he told him what the LER was going to say and confirmed that he (Brockman) understood that basis.
Certainly Brockman understood that basis.
It was a ngM basis, but Brockman understood it.
Mosbaugh, at that time the Vogtle Acting Assistant General Manager, Plant Support; and Aufdenkampe, the Technical Support Manager; express their concern to Shipman and Stringfellow about what appears to them to be a false statement in the April 9 letter and an impending false statement in the April 19 LER. At this point in time, their concern was ng.t that the 18 and 19 numbers were not absolutely correct. Their concern was that the April 9 letter and the impending LER were saying that there had been no failures or problems since March 20. Mosbaugh specified the' diesel test failures that occurred after March 20.
Both Shipman and Stringfellow recognized this as a problem and tell Mosbaugh that they will discuss LER issues with Hairston.
Since Mosbaugh was a participant
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l J. Milhoan H in these conversations, and was taping at the time, the content of these i
conversations is a matter of record (Tape 57, Exhibit 34).
4 i
i Shipman, Stringfellow, McCoy, and Hairston did not have any specific recollection of the content of any conversations among themselves, or with Bockhold,.regarding these expressed concerns. McCoy recalled Shipman mentioning something about it to him at some point.
4 l
The next taped conversation regarding this issue is. Tape 58 (Exhibit 36).
In this tape, Mosbaugh enters an ongoing confe'rence call with l
. Aufdenkampe, Bockhold, Shipman, McCoy, and Stringfellow specifically identified as participants.
Later in this~ same call, Hairston becomes a j.
participant. During this call, in which the issue of diesel failures is i
directly, albeit quickly, addressed by Hairston and dismissed by Shipman
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i and McCoy, there is no evidence of any activity toward correcting a possible misconception in the April 9 letter by bringing it to the attention of NRC. The activity is directed toward not repeating, in the
-April 19 LER, a statement similar to the April 9 statement. So, for some reason unexplained by McCoy in his 01 interview, instead of asking Bockhold when he started his count of diesel starts, McCoy seeks confirmation from Bockhold that the count was not started until the-completion of the comprehensive control test program. Where did McCoy get that idea? Most logically, from Shipman and/or Stringfellow in the effort to address the " problem" of failures after March 20. Bockhold, of course, confirms his immediate superior's suggested starting point. At this point, Bockhold knows that no one else.on that phone call knows what specific criteria, if any, he gave to Cash when he directed Cash to obtain the start count.
Bockhold also knows that, in all' likelihood, Cash, if questioned at all, will support his (Bockhold's) statements regarding the criteria for the count.
So, without knowing specifically when the " comprehensive control test program" ended, by using that point as the starting point of the diesel start count in the LER, the failures that Mosbaugh and Aufdenkampe were concerned about were eliminated, in all probability, from the count.
So, having that problem solved, the participants move on to deal with the problem of Hairston's question about the " greater than 20" starts that was approved in the draft LER by the Vogtle PRB, based upon the 18 and 19 numbers in the statement in the April 9 letter. Of course, the " greater than 20" was approved by the PRB using March 20 as the starting point of the count, assumina that the count was correct in the April 9 letter, and adding starts that had been accomplished after April 9.
Now that the starting point had been changed to some point not specifically known to any of the participants, including Bockhold, the verification of " greater than 20" became more problematic. McCoy and Shipman had a solution to that problem. What were the numbers that Bockhold used in his April 9 presentation to NRC? "We ought to use those numbers." We'll say "at least" that many numbers.
Bockhold chimed in with his support for that idea.
So the LER statement, " Subsequent to this test program, DGIA and
J. Milhoan-DGIB have been started at least 18 times each and no failures or problems have occurred during any of these starts." was created. Stringfellow asked, "Do we want to say... (the above statement)?" And Bockhold said, "Yes, you can say that." It was decided.
At some point, either during or after, the participants decision on the wording of the diesel test statement in the LER, Hairstnn became a participant on this call.- He asked, "So we got the starts...we didn't have no trips?" Shipman started to respond,."No...not..not..." and McCoy interrupted and said, "Let me,...I'll testify to that." At which point Shipman immediately said, "Just disavow. What else have we got Jack?"
The only logical interpretation of those comments is that, at the very.
least McCoy, if not McCoy, Shipman, and Bockhold had designed LER wording
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that he (they) thought would eliminate the " trips" that Hairston was asking about, and McCoy did not want to get into a detailed explanation to Hairston about how they did that. So, McCoy volunteered to be the one that would answer any NRC questions about that issue, thereby protecting Hairston from having any detailed knowledge about how that problem was handled. Shipman advised McCoy to "Just disavow." That probably meant -
for McCoy to di'savow any personal knowledge of the trips after March 20, but.it could also have meant to disavow the fact that there were any trips after the completion of the comprehensive control test program.
All McCoy's subsequent phone call to Brockman did was to tell Brockman what was going to be said in the LER, and the basis for it. The call did not address " trips" after Marc.' 20, or that.there was the possibility of an " inaccurate" statement in tae April 9 letter.
This is the context of the GPC failure to identify "the error" on April 19.
5.
Page 3, Last Para., Lines 1-4 of the Transmittal! Letter states:
GPC continues to believe that the absence of a single source document.for DG starts and runs, containing timely and correct data, using commonly defined
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terminology, and reviewed by qualified personnel, was pivotal in the underlying difficulty in providing i
accurate diesel start data.
OI Comment: With Bockhold's instructions to Cash not to count any starts with significant problems, even if an updated diesel start log would have been available, inaccurate and incomplete " DIESEL TESTING" data would have been presented to NRC.. Problem starts and tests were deliberately omitted from the data. A " timely" " correct" " single source document" would not have prevented the deliberate omission of that data. Ihg absolute number of successful starts is not the issuel m
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8 J. Milhoan,
t 6.
Page 4, Para. 4, Lines 1-3 of the Transmittal Letter states, regarding
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Mosbaugh:
Despite opportunities to assure an accurate and complete information flow within GPC and, in turn, to the NRC, he did not do so. He clearly was not open and cooperative with his co-workers about resolving his own concerns.
01 Coment:
The GPC efforts to discredit Mosbaugh, and to go so far as to blame him for the issues at hand in this matter are very predictable.
After witnessing what Shipman, Stringfellow, Bockhold, McCoy and Hairston~
did, on April 19, with Mosbaugh's concerns about an apparent false statement in the April 9 letter being repeated in the LER, it is understandable that Mosbaugh was hesitant to continue to confront his management with these concerns.
7.
Page 1, Para. 6, Line 1 of the Executive Sumary Reply to Notice of Violation; EA 93-304 (hereafter, Summary) states:
i GPC denies this violation...
j 01 Coment: The GPC denial of this violation (Violation B, which pertains to Diesel Air Quality), relates indirectly to the 01 conclusion that, during his April 9 presentation to the NRC, Bockhold withheld his knowledge of a recent, out-of-specification dewpoint reading on the Unit 2, A Diesel.
i The OI conclusion regarding Bockhold's withholding of bad dewpoint information remains unchanged. However, the GPC evidence that i.h VEGP Asst. General Manager for Operations (Kitchens) made the NRC IIT leader (Chaffee) aware of that particular dewpoint reading on April 9, just prior to Chaffee's participation, via tel'econference, in the GPC April 9
. presentation to NRC at Region II, raises legitimate questions, for OGC and Enforcement consideration, regarding the materiality of Bockhold's withholding. This, of course, being dependent upon whether Chaffee was present, via teleconference, at the time GPC was presenting air quality issues in the April 9 presentation.
. 8.
The GPC explanation for their denial of Violation E is unreasonable.
01 Coment: The NRC statement of Violation E correctly characterizes l
GPC's inaccurate statement, in their letter of August 30, which blames a confusion between successful starts and valid starts as being one of the two causes for the " confusion in the April 9th letter and the original LER..."
However, in the NOV Response, GPC seems to be asserting that in their August 30 letter they are not proffering, as a root cause for this
" confusion", the claim that there was confusion between successful and valid. OI sees no basis for this assertion. The meaning of the first sentence of the third paragraph of the GPC letter of August 30, 1990, was definitely clouded when the second word in this sentence was changed from e
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w
.m.
1 J. Milhoan i
" errors" to " confusion." However, it is clear that GPC was offering two causes for this " confusion." One of the causes offered was that there was confusion between successful and valid. That is inaccurate.
'l 9.
GPC claims that the phone call from the Vogtle Project VP to the NRC Section Chief on April 19 clarified the inaccurate information provided on April 9.
i OI Comment: There is evidence that this phone call from McCoy to Brockman did not draw Brockman's attention to the possibility of an incomplete or inaccurate statement of diesel starts in the April 9 presentation or letter.
The call did not specify that there had been any
-failures or problems in the diesel starts since March 20.
There is evidence that all McCoy did in this phone call to Brockman was to state the basis for the diesel count that was forthcoming in the LER.
Since the LER statement changed the basis for the count as compared to I
the April.9 letter (regardless of what GPC claims was in the mind of Bockhold), there was no explanation in this phone call of any inaccuracies in the April 9 letter.
- 10. GPC claims that the April 19 LER statement was:
Fortuitously accurate.
I 01 Comment: The LER statement was not fortuitously accurate on April 19 or on June 29, 1990. At the time the statement was made there was no specific knowledge by the GPC preparers of that statement,_to include Bockhold, of when the comprehensive control test program ended. Then, in the June 29 Revision to the LER, when GPC represented to NRC a point in i
time when this comprehensive test program was completed, there were not at least 18 successful starts on each machine from that point to April 19. When the accuracy of the April 19 LER statement became the subject of scrutiny by 01, GPC redefined the end of the comprehensive test program and, fortuitously, were able to count at least 18 successful starts from this new point to April 19.
As a final note, 01 again points out that the GPC Response denies the existence of certain violations, and also addresses issues of materiality. Consideration of these aspects of the NRC Enforcement process is within the purview of the Offices of Enforcement and General Counsel.
e November 15, 1994 UNITED STATES OF AMERICA I
NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
) Docket Nos.
50-424-OLA-3 GEORGIA POWER COMPANY, et al.
)
50-425-OLA-3 i
)
(Vogtle Electric Generating Plant
) ' Re: Licensee Amendment Units 1 and 2)
)
(Transfer to Southem Nuclear) j
)
NRC STAFF SUPPLEMENT TO AMENDED RESPONSE TO INTERVENOR'S SECOND INTERROGATORIES AND REOUEST FOR PRODUCTION OF DOCUMENTS Pursuant to the Board's ruling in LBP-94-26,40 NRC 93 (1994), the Staffis filing this supplemental response to "Intervenor's Second Set ofInterrogatories and Request for Documents to the Staff of the Nuclear Regulatory Commission," dated May 17, 1994 (Second Interrogatories). Staff counsel hs.s now reviewed some of the documents held 1
in the Region II offices in Atlanta, Georgia (part of the file for the Office of Investigations (OI) Case No. 2-90-020R).
By responding herein, the Staff does not waive its right to req" ire that the appropriate procedures be followed and that the required findings be made, pursuant to 10 C.F.R. I 2.720(h)(2)(ii) and 10 C.F.R. { 2.744(c) and (d), before responding to future discovery requests. The Staff continues to object to Interrogatories and Document t
As indicated in the NRC Staff Amended Response To Intervenor's Second Interrogatories And Request For Production of Documents (September 22,1994) (Amended Response), all of the case-file documents were examined by the Office of Investigations (OI) at some point during the course of it's investigation, but not all contained information used in creating the f' mal report dated December 17, 1993.
O) v
, i
- Requests that call for disclosure of information that is available from another source, i
draft agency documents, enforcement materials, internal agency memoranda, attorney-client materials, attorney work-product materials, or other information that is exempt from disclosure under the Commission's regulations and NRC case law.
See 10 C.F.R. I 2.790.
Additional documents considered to be responsive to Interrogatory 4 ofIntervenor's Second Interrogatories, as modified by LBP-94-26, are itemized below and will be made available for inspection and copying at NRC Headquarters in Rockville, Maryland.
t Counsel should contact Staff Counsel to arrange for a specific time for document inspection. Pursuant to 10 C.F.R. I 9.35 (b)(1), charges for copies of documents will be assessed at the rate of 20 cents per page. As indicated below, some of the additional documents contain information of a predecisional nature and will be made available for inspection and copying in radetad form only.2 i
See LBP-94-26, 40 NRC at 99 (the scope of Interrogatory 4 does not include 2
I "predecisional non factual material reflecting the decision process used by OI in preparing its report").
3+
i i ANSWERS TO INTERROGATORTES Interroantarv 4:
Answer in detail the foHowing pertaining to the OI Report, Case No. 2-90-020R:
- b. produce aH documents used in its creation...
RESPONSE: (I2rry Robinson)
In addition to the documents identified in the Amended Response to the Second Interrogatories, the documents listed below were used by OI during August-December 1993 in creating the December 17,1993 OI Report, but were not cited in the Report.
The following documents will L de available for inspection and copying:.
1.
Ietter from GPC counsel Arthur Domby to Larry Robinson (three pages, and envelope) dated September 20,1993.
2.
Ixtter from GPC counsel John Lamberski to Larry Robinson (two pages, with envelope, and excerpt (one page) from Tape 58 transcript) dated November 5,1993.
3.
Fax (cover sheet and 4 pages) sent by GPC counsel John Lamberski to Larry Robinson on November 12,1993 (4/6/90 draft of Status of Corrective Actions following.
Site Area Emergency).
4.
Typed List of Exhibits (6 pages), with Robinson's handwritten insertions on l
pp. 5-6.
5.
Typed List of Exhibits (6 pages), with " Road Map" handwritten on p.1, and other writing and markings by Robinson.
6.
Note of telephone conversation with GPC counsel (Domby and Lavine) on October 27,1993.
The following (Items 7 - 8) documents contain material which reflects the OI
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1 :
decision process used in preparing the subject OI Report. Accordingly, these documents will be made available for inspection and copying in redacted form only.
7.
Typed document (1 page, untitled) beginning with "(Exhibit 9) presented to i
NRC by Bockhold on April 9."
i i
8.
Robinson handwritten notes (4 pages) regarding telephone conversation with j
GPC counsel John Lamberski on November 12, 1993.
The following item contains material which reflects the OI decision process used in i
preparing the subject OI Report, and contains no segregable factual ieformation.
A:cordingly, it will not be made available for inspection and copying.
i
- 9. Four pages of Larry Robinson's notes concerning the one-page tape transcript excerpt enclosed in the letter from GPC counsel John Lamberski to Larry Robinson, dated November 5,1993.
Respectfully submitted, j
,p
,)T. Hull i
n ounsel for NRC Staff Dated at Rockville, Maryland this 15th day of November 1994 i
)
0 i
UNITED STATES OF AMERICA NUCLEAR REGULA'IURY COMh0SSION BEFORE THR ATOMIC SAFETY AND LIr* WRING BOARD In the Matter cf
)
) Docket Nos.
50-424-OLA-3 GEORGIA POWER COMPANY
)
50425-OLA-3 et d
)
) Re: Yhr Amendment (Vogtle Electric Generating Plant,
) (Transfer to Southern Nuclear)
Units 1 and 2)
)
AFFIDAVIT I, Lan, u. Robinson, being duly sworn, state as follows:
1.
I am employed by the U.S. Nuclear Regulatory Commission, Office of Investigations.
I serve as a Senior Investigator in the Atlanta Field Office of Investigations.
- 2. I respdM to Interrogatory 4 contained 'in the 'NRC Staff Supplement To Amended Response To Intervenor's Second Interrogatories And Request For Production Of Documents," dated November /j,1994
- 3. The response to Interrogatory 4 is true and correct to the best of my knowledge and belief.
YN/ Y
/uB2 M L.dtobinson Sworn and abscribed to before me this# day of November 1994 A E kw" My comminnian expim _ *%Puencec%,%
Notary Public
- "***n Eghe ### 1,190s
7
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i.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
) Docket Nos.
50-424-OLA-3 GEORGIA POWER COMPANY, et al.
)
50-425-OLA-3
)
(Vogtle Electric Generating Plant
) Re: License Amendment Units 1 and 2)
)
(Transfer to Southern Nuclear)
)
CERTIFICATE OF SERVICE I her % certify that copies of "NRC STAFF SUPPLEMENT TO AMENDED RESPONSE TO INTERVENOR'S SECOND INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS" in the above-captioned proceeding have been served on the following by deposit in the United States rnail, first class, or as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system this 15th day of November 1994.
l Peter B. Bloch, Chairman
- Thomas D. Murphy
- Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop: T-3 F23 Mail Stop: T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 Fax: 301-415-5599 Fax: 301-415-5599 Judge James H. Carpenter James E. Joiner 933 Green Point Drive John Lamberski, Esq.
Oyster Point Arthur H. Domby, Esq.
Sunset Beach, North Carolina 28468 Troutman Sanders Fax: 910-579-3466 NationsBank B.uilding, Suite 5200 600 Peachtree Street, N. E.
Atlanta, Georgia 30308 Fax: 404-885-3900
' David R. Lewis, Esq.
Adjudicatory File * (2)
Shaw, Pittman, Potts and Trowbridge Atomic Safety and Licensing Board 2300 N Street, N. W.
Panel Washington, D. C. 20037 Mail Stop: T-3 F23 Fax: 202-663-8007 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Michael D. Kohn, Esq.
Stephen M. Kohn, Esq.
Atomic Safety and Licensing Board Kohn, Kohn and Colapinto, P.C.
Panel
- 517 Florida Avenue, N. W.
Mail Stop: T-3 F23 Washington, D. C. 20001 U.S. Nuclear Regulatory Commission Fax: 202-462-4145 Washington, D. C. 20555 Office of Commission Appellate Office of the Secretary * (16)
Adjudication
- Attn: Docketing and Service Ma 1 Stop: GWFN-16/G15 Mail Stop: OWFN-16/G15 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Washington, D. C. 20555 n
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Joh'n T.' Hull edounsel for NRC Staff 1
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