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f TROUTMAN SANDERS
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i NATION 8aANK PLA2.A 000 PEACHTREE STREET, N.E. SuffE 6200 i
ATLANTA. GEORGIA 30308 2216 TELEPHONE:404 885 3000
{ FACSIMILE:404 e86-3900 j JOHN LAMBERSKI DIRECT. 404 885-3300 Novembe.: 5,1993 i
i l l I
Mr. Larry L. Robinson
- Office of Investigations
! Nuclear Regulatory Commission j 101 Marietta Street i
i Suite 2900 '
l Atlanta, Georgia 30323 i
Dear Larry:
( .
! Pursuant to our di=~ ion on November 3,1993 at Plant Vogtle, I attach a transcript of that portion of the April 19,1990 tape during which hu. McCoy asks j about the number of diesel generator starts.
1 As you will see and hear, Mr. McCoy initially inquires as to how many starts i there were (after the cc-yhion of the cc-rAnsive control test program). He does not su t any specific numher at all. It is only after Mr. Ractrhald . n that the presenW at the April 9th co fw had been verified that
{ says "we ought to use these numbers." Even then, McCoy follows up with Rae
! to be sure that those starts occi.nM after the cc phion of the cc-prir.sive test of .
l the control system on each diesel.
j As I expressed to you the other day, I fail to see how anyone could reasonably _ ..
- conclude that McCcy's questions evidence anythin j determine how many starts ocem 4 after theyMion cc g but a straightfm..id of the co-rAnsive test ==9of to.
4 the control systems of the diesels.
l l You also a par to have concerns about who initially proposed that the starting
- j pomt of the diese. start count should be the cc-ybion of the co-runsive test of
- the control systems. As I -I=iaad to you d
- our discussion, it could very well
- have beenvivyc.d by McCoy based on his one. conversation with ICen i Brachnan that day. As you know, there are statements on the April 19,1990 tapes i (the portions of which have not been provided to Georgia Power to the effect that 2
McCoy said Brochnan understood what was meant by the come.)J.casive test i control systems.
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TRoumANSANDERS r.: w: =.u..am j Mr. Larn L. Robinson j November 5,1993 2 Page 2 I
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M Please give me a call if you would like to discuss this further or ifI can assist
! you in any other way.
Very y yours J. .- .
! John 12mherski 4
JL:svg l Enclosure i cc: Arthur H. Domby, Esq.
Bryan B. Iavine, Esq.
3 Bruce H. Morris, Esq.
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j Aufdenkampe: Allen Mosbaugh just walked in George so I'll put you.on the speaker. The way sy people came up with the greater than 20 starts is that they took
{ the 18 and 19 starts and, based on the April 9th letter and they went and checked and found out how
] many starts they had subsequent to April 9th. And l that's why you can say greater than 20.
! Bockhold: I think you can say greater than 20. You know, I we've even had more starts recently. We had a
} start last, the other night.
4 i
l McCoy: We need to be sure that we know the number of starts after we completed the comprehensive j control test program.
j Aufdenkampe: I do have people right now going out through - my j people going out through the RO's log.
l Sockhold: From my numbers that I presented at the conference they were verified correct by Jimsy Paul Cash who i
went through the operators' logs.
i j McCoy: We ought to use those numbers.
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! Sockhold: Olray so we will say greater than those numbers i
l that we used in the confer 3nce.
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! . McCoy: okay, those numbers you used in the conference
! were after they had completed the comprehensive j
tests of the control system on.,e,ach diesel' - . .
! Sockhold: 'That is correct. Those numbers were not before
. that time. -
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- M.fJby i TROUTMAN SANDERS r..r..o.
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Mr. Larry L. Robinson a en i I, ysgl Office of Investigations :' p wW !
Nuclear Regulatory Commission 101 Marietta Street Suite 2900
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't l Aufdenkampe: Allen Mosbaugh just walked in George so I'll put.
you.on the speaker. The way my people came up f with the greater than 20 starts is that they took the 18 and 19 starts and, based on the April 9th letter and they went and checked and found out how i many starts they had subsequent to April 9th. And i that's why you can say greater than 20.
)
l Sockhold: I think you can say greater than 20. You know, we've even had more starts recently. We had a start last, the other night.
McCoy: We need to be sure that we know the number of j
starts after we completed the comprehensive control test program.
. Aufdenkampe: I do have people right now going out through - my people going out through the RO's log.
l Bockhold: From my numbers that I presented at the conference i they were verified correct by Jimsy paul Cash who 3
went through the operators' logs.
i McCoy We ought to use those numbers.
i j Bockhold: Okay so we will say greater than those numbers that we used in the conference.
l McCoy: Okay, those numbers you used in the conference were after they had completed the comprehensive tests of the control system on._each diesel?
l Bockhold: That is correct. Those numbers were not before l that time.
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j? 11 19-1993 15:08 841 5510 US f4C O :1 P.02 u
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j DRAFT SYNOPSIS DRAFT j On November 1, 1990, the Regional Administrator, NRC Region II, 1 1
rcquested that an investigation be initiated by the NRC Office of '
l Investigations (0I) concerning alleged material false statements
- made to the NRC by Senior officials of Georgia Power Company (GPC) l i rcgarding the reliability of the , Emergency Diesel Generators (EDG) l l ce the vogtle Electric Generating Plant (VEGP) , Waynesboro, GA. l 1 ,
! OI investigation substantiated that, on April 9, 1990, the j,g neral Manager, VEGP, deliberately presented incomplete and
- , naccurate information to NRC regarding the testing of the VEGP S,
- Unit 1~ EDGa^ conducted subsequent to a March 20, 1990 Site Area j j Emergency (SAE) at VEGP. This occurred at NRC Region II offices, 73 j 1 Atlanta, GA during a GPC oral presentatim2 in support of their 55 l j rsquest to return VEGP Unit 1 to power operations. 4 'B me l The investigation Also substantiated that, also en April 9,1994,-- f$, f<
in a letter to A C captioned vocTLE ELECTRIC GENERATING PLANT g.q g CONFIRMATION OP ACTION LETTER, the Senior Vice President of Nuclear eA i j operations, frPC, presented a misleading, incornplete, and inaccurate ji ctatement #f diesel emati fa a mt =, which was bases unen ene
- iy =h,
{ I . incomplete', inaccurate information % The s'forementT6ned aql_
l ypresentafilon. Tne Generaa nanager, VauP, feviewed tYe ktatismant in 3 g 8y j ihls Aetter and approved it for signature by the Senior V-P. ggy,,
smas )
The investigation substantiated that, on April 19, 1990, the Senior 55#2 l}'
I j Vice President of Nuclear Operations, GPC, with, at a minimum, __
i careless disregard, submitted a f alse statement.pf Maa=1 test iCiuliito the NRC in Licanseii~ Event Repbrt (LER) No.90-006, which
~ ~
j i pertained to the SAE. This falso statement was submitted as a . 1 j
direct result of deliberate actions, o @#ril 19, 1990, by a group M of~GFG Meniot Mansp re, to include theLSenior V P of Nuc Opsg the wg )
{
j h vogtle Project V-PU4he Corporate GM of Plant Support, and the VEGP g I
, GM. These Senior Managers re-worded an existing statement of diesel testing in a draf t LER, af terP--'r been told by VEGP Site fg' g #
personnel. that this draft LER statement and the corresponding sta_tement in the Acril 9th letter) (upon which the craft LER statement was based) were false.) However, the GPC Senior Management offorts to make the re woriing similar to the April 9th
- statement, plus their knowledge that the new statement could not 1 h ve been definitively verified prior to the issuance of the LER.,
3 resulted in the re-worded statement being 1se l The OI investigation substantiated that t,h
-%v r Vice President
/c) i of Nuclear Operations, GPC, again, with, at a minimum, careless 3 ( disregard, submitted a false statement to NRC in the letter of
- tran mitta t M l i
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y .s DRAFT The investigation substkntiated that the Vice President, Vogtle
- Project, GPC, with, at a minimum, careless disregard, submitted i
/both a false and a misleading statement in the GPC Clarification of dh Confirmation 19'# 0. These of Action Response letter to NRC dated August 30, falso and misleading statements pertained to reasons !
l why the statement of diesel testing in the GPC Confirmation of l Action Response letter, dated April 9, 1990 was inaccurate. l i
The 01 investigation substantiated that VEGP General Manager had 1 knowledge, at the eine of his oral crementation te wac' an anrf1 o, 1990, that there continued to be out of tolerance dowooint readings
- o Lthe controA air of the VEGD nnit 2 EGa as recentiv as the day I/g before nas presentation. Yet, he also knew that GPC, as part of p
J their Justincation ror restart of Unit 1, was claiming that EDG air quality was satisfactory, and that GPC 'was attributing bad i i dowpoint readings to faulty instrumentation. The VEGP General- l l
Manager withheld, from NRC, his knowledge of the rei-v- : = = rial information regarding bad cowpoint readings, and pgImittad tM GPC
- l. claims of satisfgj;Ltig_ry air ernailey and faulty inntrenentien to be i i_Rsued in the GPC April 9, 1990 letter of response to the~ NRC l ~ConTirmatioM W 109
! The OI investigation substantiated that the GPC Executive Vice President of Nuclear Operations, as the sworn signatory of the GPC l
- Response to 2.206, dated April 1, 1991, provided inaccurate f information to NRC when the Response stated that the GPC Senior i
Vice President of Nuclear Operations was not a participant in the late af tornoon conference call on April 19, 1990, in which the wording of LER 90-006 was revised by corporate and site j
- representatives. The audio tape of that conference call l establishes that the Senior V-P of Nuc Ops was not only a j participant in a portion of that call, but that he addressed the issue of EDG starts and " trips".
It is also concluded from the combination of the above findings, and the overall review, by,the office of Investigations, NRC, of the numerous audio tape recordings of internal GPC conversations regarding their communications with the NRC on a range of issues,
,;0 (/
j that, at 1.ase in the waren-August, 1990 time frame, there was evidence of a closed, deceptive, adversarial attitude toward NRC on the part of GPC Senior Management. This attitude fostered a noticeable degree of frustration on the part of various GPC Technical Support and Engineering personnel with respect to the GPC provision of information, not known to NRC, that had the potential of resulting in NRC enforcement action.
I DRAFT l
C _. -
h
--EREDECISIONAL INFORMATION -
NOT FOR RELEASEMIMPPROVAIAFTHE DIRECTOR, NRR -
)
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f VOGTLE REVIEW STATUS BRIEFING by the VOGTLE COORDINATING GROUP H Elif
' ! _E [. November 22,1993
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Slide 1 E- , B' '
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4REDECisioNAL INFoRMATioN - .
NoT p FokELEASE WITHOUT-APPROVAL,0fF 0 THE DIREgEORrNRR~ ~
BRIEFING OUTLINE
- Purpose of Briefing .
- Coordinating Group Schedule
> Group Progress vis-d-vis the Group Charter
- Discussion of Preliminary Conclusions Provided by OI to Date
> > Background / Licensee Key Management Structure (Early-Mid 1990)
> > Discussion of Each Preliminary OI Conclusion -
slide 2
- PREDECTSIONAL INFOJMA%
NOT FoR RELEASE'WrrHOUT 1PPROVAL OF THE DIRECTOR, ERR PURPOSE OF BRIEFING
- Inform senior management of status of Coordinating Group progress.
> Provide overview of Coordinating Group discussions.
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i Slide 3 b
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[ - PREDyCISIONAL INFORMATION -
N0'T FOR RELUASE-WITHOUT APNOVAMIRECTO l
i COORDINATING GROUP SCHEDULE .
> 9/16/93 Coordinating Group established via Charter.
> 10/25/93 Periodic meetings and initial review of exhibits completed.
Daily meetings begin. :
> 11/22/93 Daily meetings in progress.
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5 slide 4 l
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1 NOT EATE IT VA o TH R,NRR PROGRESS ON THE PROVISIONS OF THE CHARTER i
Status: Initial review and evaluation of evidence in progress.
I Note: Review also encompasses information becoming available through discovery in the ASLB proceedmg.
- 2. Identify any violations and determine appropriate enforcement actions.
Status: Work in pro \gress. Estimated to be half completed. g
- 3. Develop recommended actions for management consideration and prepare draft enforcement package.
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Status: To be initiated.
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- 4. Prepare draft Commission paper to forward any enforcement recommendations.'
l Status: To be initiated. I Slide 5 [
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( /m NoTFoR RELEASgDECgoUT i loNA N-APPR L OF T E-DfRECroR CHARTER PROGRESS (continued)
- 5. Identify any additional required OI field work.
Status: Additional field work / questions identified. OI field work complete.
Review of additional field work is in progress.
- 6. If preliminary ~ determination is that enforcement is appropriate, have a draft enforcement package (Item 3) and Commission paper (Item 4) ready for management review by October 22,1993.
Status:'
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- 7. Notify management as soon as possible if additional-OI field work (Item 5) is required.
i Status: Completed. No additional field work currently anticipated.
Slide 6 i
- - PILEDECISIONAL INFORMATION -
wNOT-FOR REl NSE WDOUT-APPROVALy LICENSEE ORGANIZATION - MARCH 1990 CORPORATE OFFICE R. P. Mcdonald
- Exec. V.P.
t W. G. Hairston, III !
, Senior V.P.
C. K. McCoy PLANT TOGTLE V.P. Plant Vogtle i
I W. B. Shipur.n G. Bockhold j General Manager General Manager Plant Support g }
I
- 7. L. Mosbaugh W. F. Kitchens ,
J. Bailey Actil *- Asst. Gen. Mgr. Asst. Gen. Mgr. i Licensing Manager u. ant Support Plant Operations !
I J. Aufdenkampe N. J. Stringfellow Manager '
Licensing Engineer Technical Support J. P. Cash !
Unit I Superir.tendant Rick Odon Supervisor I ,
I Tom Webb Engineer Slide 7 i
._..._m.. .. __ . . _ . _ _ . . . ._ _ _._ _ __.. . . . .._. _ .. . _ .. _ __ _ . . . . . . _ . . . _ _ . _ _ _ . _ . _ _.-_ _ __.
- PREDECISIOblA INI ORMATQ-p.
MJOhotrf AP(PROVAL'OF Tile DIRECTOR, N,RR _
GPC RESTART PRESENTATION - SLIDE'10 pl(KL R$fl4
==. x ani et.a its, tai.
i
- $PECIM. EstING M 18 3n0 [vtat in Ovtannut 5 stants, Teovnesnootins
$tason ( n essaries Losse itstems
[-tm Svent instems Ibtierte Staats (IM ,
W tw inst E lbara R m Suaveettaart Dieset Ortaant W Ra inst Sensen C = eention tosic instens E-Rm Buent itstems test 0 . DCP Run flutterte stants (5) DCP W Rm Functionat j W Run itst 6 flentu Soestettanct Oststt (>teant N Jacutt Vatta Runs (3)
DC, W Rm itst ,
l 18 $UCCts7 R SJ u t$ 19 ssCE55FR simTS to Slide 8
r q - PRED ION RMATION -
i NOT FQR RE EASE WIT ET' PPROV Ly OI PRELIMINARY CONCLUSION 1
Conclusion:
i t
- Coordinating Group Discussion:
The group looked to the 4/9/90 letter as representing the information that GPC presented in the restart briefing. The group conclusions _regarding the 4/9/90 presentation are included within its conclusions on the 4/9/90 letter.
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i Slide 9
PREDQCISIONAiriNFQRMATION -
NOT FOR RELEASE WITilOUT' APPROVAL!OF-THED RR'~
^
- CAL RESPONSE (4/9/90)
Georgianmes d U. S. Nuclear Regulatory Comission Region II i ELV-01516 Page Three
- g. Since March 20, 1990, GPC has performed numerous sensor calibrations (including Jacket water temperatures), extensive logic testing, special pneumatic leak testing, and multiple engine starts and runs under various conditions. Since March 20, the lA DG has been started 18 times, and the .
18 DG has been started 19 times. No failures or problems have occurred .
during any of these starts. In addition, an undervoltage start test i without air roll was conducted on April 6,1990 and the lA D/G started and loaded properly.
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= . . . - . . . . - . - - - . _ - _ . . . - . . .. . . - . .. . . - . . _ _ .
- PREDECISIONAL INE RMATION - ~~
NOT FOR RELEAS5 WITHODT-APPliOVAL ILTHE-DI NRR/
OI PRELIMINARY CONCLUSION 2
> OI
Conclusion:
- Coordinating Group Discussion:
I e
onde 11 l
- OEDECISION%INFORMATION - !
NMOR RELEASE WITIIOUT APPROVAL'OF DIRECTpR,'h D TITEs 4 LER (4/19/90)
Numerous sensor calibrations (including jacket water temperatures).
special pneumatic leak testing, and multiple engine starts and runs were performed under various conditions. After the 3-20-90 event, the l control systems of both engines have been subjected to a comprehensive test program. Subsequent to this test program, DGIA and DGIB have been '
started at least 18 times each and no failures or problems have occurred during any of these starts. In addition, an undervoltage start test without air roll was conducted on 4-6-90 and DGIA started and'ioaded properly.
Slide 12
3 NO r FOR'R T PR F OI PRELIMINARY CONCLUSION 3
> OI
Conclusion:
p LER 90-06, i
~ dated 4/19/90, states that, subsequent to "a comprehensive test program," EDGs IA and IB were started at least 1)Liimes each with = Droblems or failures during apy of those starts.
L r
> Coordinating Group Discussion: -
i In fact, as of j 4/19/90, the numbers of consecutive successful starts for EDUs I A and IB would have been no more that 10 and 12 respectivelv.
Slide 13 i
N ? W PR OI PRELIMINARY CONCLUSION 4
> OI
Conclusion:
- Coordinating Group Discussion:
6 4
1 Slide 14
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- PREDECfSidN4L INfFKf5TiDt(- '
h0T FORDIJiASrrNITilOllT APPif0 VAL OF Tile'DIRECTOM
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LER REVISION (6/29/90)
The number of successful starts included in the original LER included some of the starts that were part of the test program. The difference is attributed to 1
diesel start record keeping practices and the definition of the end of the test program.
CORRECTION TO 4/9/90 CAL RESPONSE (8/30/90)
The confesten in the April 9th letter and the original LER appear to be-the result of two factors. First, there was confusion in the distinction between a i successful start and a valid test. For the purpose of this letter, a start was considered successful when the DG was started and either ran or was intention-ally shut down due to testing in progress, as identified on the attached tables.
Our use of the term ' successful" was never intended to imply a " valid successful test
- in the context of Regulatory Guide 1.108. Man start attempts were made to test the OG's IA and 18 using applicable operating procedures. These procedures and data sheets do not contain criteria for determining if a start is ,
successful which resulted in determinations of success which were inconsistent wtth the above definition. Second, an error was made by the it;dividual who performed the count of DG starts for the NRC April'9th letter.
Slide 15
/CPREDECf3TOMAL INF'3RMATION -
- !' )NMFOR REL'dASE WITHOUT APMVAOD@ ,
OI PRELIMINARY CONCLUSIONS 5 AND 6 l
> OI Conclusion 5: .
> OI Conclusion 6: '
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> Coordinating Group Discussion:
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- Rev.1 (11-30-93)
DRAFT ANALYSIS
- 1. APRIL 9. 1990 LETTER AND PRESENTATION RE DIESEL STARTS l
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i Informatian in tNs reccrd was deleted in a0CDidance with (ne freedom Of Information' Act, exempt ns j i FOIA- 0V tv'dence On or about Friday, April 6,1990, a meeting was arranged for the folle 1 Monday, April 9, 1990, for GPC to review its corrective actions since N Vogtle Unit 1 incident of March 20, 1990. The meeting was in accordance with the NRC's Confirmation of Action letter of March 22, 1990, which reflected GPC's previous agreement that " Unit I will not be taken critical until the Regional Administrator is satisfied that appropriate corrective action has been taken and the plant can safely return to operation." GPC had scheduled Unit 1 to achieve criticality and resume power operation about April 10, 1990.
Mr. K. Brockman of RIl informed Mr. K. McCoy that he (McCoy) should be prepared to show the NRC the reliability of the EDGs and to show how the EDGs had performed (01 Report of Interview with Kenneth E. Brockman, September 5, .
1991, p. 1). Mr. McCoy assigned this portion of the presentation to the Vogtle General Manager, Mr. George Bockhold (McCoy Transcript---).
In preparation for the meeting during the weekend of April 6, 1990, Mr. G.
Bockhold asked the Unit Superintendent, Mr. J. Cash, "to get from the logs the information associated with the number of successful starts" (Exhibit 10: NRC Special Inspection Interview of George Bockhold, August 14, 1990, p. 4). Mr.
Cash recalls that the General Manager told him to " review the log books and determine how many starts we had had with no significant problems" (Exhibit 7:
j NRC Special Inspection Interview of Jimmy Paul Cash, August 14, 1990, p. 3).
Neither Messrs. Bockhold nor Cash recall any discussions at the time of this /
l request concerning the meaning of a " successful start" or when the count G
v
should begin or end. Rather, both believe that no such discussion occurred: l Q: Could you give us your definition of a successful start?
Bockhold: A successful start would have been any start that didn't show a significant problem that would have caused the engine to trip or cause the engine not to meet its intended purpose.
The term " successful start" was a term that I think I came up with without a great deal of thought. Okay. But it was a term that is -- at that point I knew was very different than a valid test or a -- or a -- and there are a Reg. Guide series of -
terminologies that are used associated with diesel generators.
And so I didn't want this term to relate to that Reg. Guide, because there are certain requirements on each one of those. And I just wanted this term to represent as I had stated before the l fact,that (we] didn't have any major problems with the engine; it i ran; ... l l
Q: ... Deas the term " successful start" indicate that the engine rah .or a given amount of time or was that a criteria?
Bockhold: I didn't tell Jimmy (Paul Cash] any -- any criteria. I l used the term " successful start", and he went off and counted '
them. You know, I assumed that he has some criteria when he came back with the number. But I didn't -- we didn't go into a .
discussion about what the criteria was on the successful starts as ,
far as I remember. !
Q: And you didn't ask him what his criteria was in making his count?
Bockhold: Didn't ask him what his criteria -- you know, hindsight being 20/20 I wish I had because we, you know, wouldn't '
have this discussion today. (Transcript of 01's Investigative Interview of George Bockhold, Jr., June 22, 1993, pp 18-19).
To Mr. J. Cash, the appropriate data to gather for Mr. Bockhold was "All starts that it appeared from the log entry that the diesel would have ran during an emergency" (OI Investigative Interview of Jimmy Paul Cash, June 14, 1993, p. 12).
Mr. J. Cash obtained his data from the Unit control logs and the shift supervisor's logs (Special Inspection Interview of Jimmy Paul Cash, August 14, 1990, p. 4). He began his count of diesel starts with the troubleshooting starts on March 20, 1990:
Q: And when did you start your diesel counts in this data that you were obtaining for Mr. Bockhold' A: That's -- I assume that I started with the troubleshooting starts that we did, I think it was late that afternoon or that night on 3/20 --
Q: On 3/20/907
A: Yes Q: And so your count for both the A machine and the B machine ,
would have started on 3/20/907 l
A: That is my belief; yes sir. (01 Investigative Interview of '
Jimmy Paul Cash, June 14, 1993, p. 13) i Thus, the time frame reviewed by Mr. J. Cash included testing on the days of March 22 and 24, 1990 -- days during which three problems occurred during the tests on EDG-1B. -
l Based upon Mr. J. Cash's understanding of " successful starts", two trips in l the log on March 22, 1990, for EDG-1B were not problems, and therefore, were apparently included in his count: I Q: I'll direct your attention to page number 5289 of that [ Unit 1 l control] log, which is headed March 22, 1990, and proceed down to the entry at 12:43. It reads, and I quote, "DGlB tripped on DG high lube oil temperature." l And I'll just ask you, when you went to obtain the diesel l generator'information for Mr. Bockhold, did you count that diesel ;
i test or that diesel run?
A: While I don't remember the specifics of doing this, I would have counted that by my criteria.
Q: You would have counted that?
A: Yes, sir.
Q: Why would you have counted that -- is that -- why would you have counted that? !
1 A: A diesel generator high lube oil temperature trip is a nonessential trip. It is a trip that is bypassed during an emergency, therefore [it] would not have prevented this diesel i from performing its function during an emergency.
Q: Okay.
l A: There's nothing to indicate that's a problem (Transcript: 01 Investigative Interview of Jimmy Paul Cash, June 14, 1993, pp 15-16)...
1 Q: I'll direct your attention to page 5292 of the log. The entry at 17:31, and I quote, "DG1B tripped on low jacket water pressure / turbo lube oil pressure low." Would you have counted this test of the DGlB as being a test.without any significant problem?
l A: Once again, this trip would be a nonessential trip. There is nothing from this log entry to indicate that this diesel would not have performed during an emergency. So I would -- yes. The answer
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1 is yes.
Q: You would have counted that one as being a successful start?
A: Yes, sir. (Ik. pp 18-19). l i
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4 I 2. APRIL 9, 1990 LETTER RE AIR QUALITY i _ ^
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i GPC has reviewed air quality of the D/G air system, including dewpoint control, and has concluded that air quality is satisfactory. Initial reports of higher than expected dewpoints
- we.e later attributed to faulty instrumentation.
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1 enera Manager an other site personnel l knew before , , t there had been valid high dew point measurements of Vogtle' starting air due to the air dryers being out of service and the air receivers being repressurized.
Evidence
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.fnfoWl3n in this record W3s deleted te f n
"* CI Infurination I
- Folk. --_- ?_>CG7~
.___ e-l Bockhold asked Cash to count " successful l
! starts" of the emergency diesel generators (EDGs) M Cash collected start data from the Control Room Log and the Shift Supervisor's Log and conveyed totals to Bockhold for the 1A and IB diesels.
the information reported to
- the NRC in the 4/9 oral presentation and the 4/9 letter to NRC, was that there l were 18 and 19 successful sequential starts on the 1A and IB, respectively, i
without problems or failures.
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j GPC did not identify that the count reported i included three EDG-1B starts with problems (a high lube oil temperature trip, a low jacket water pressure / turbo lube oil pressure low trip and a failure to trip on a high jacket water temperature alarm) that had occurred on 3/22 and 1
j 3/24. The correct number of sequential successful starts should have been 12 i
)Av for EDG-1B. [
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a review of maintenance records deficiency cards associated with Unit I wou17 ~ '^**1' have revealed that high dewpoints were also attributable to system air dryers
[ occasionally] being out of service for extended periods and to system repressurization following maintenance, as documented in NRC Inspection Report
~
No. 50-424/425 90-19, Supplement 1, dated November 1, 1991.
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On April 19, 1990, during the corporate and site review of the draft LER, George Bockhold stated that the start counts i
reported on April 9 began after completion of the CTP. He also told Shipman that his count began after instrumentation recalibration, but Shipman could j not define that point nor did site personnel establish this reference point prior to issuance of the LER.
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a the EDG-1B start counts reported on 4/19 over stated the actual counts by including starts that were part of the test program.
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l Docket No. 50-424 License No. NPF-68 EA 93-304 idormMi7nID!% r Georgia Power Company in accorCar,ce cgjg g,,u .
_ .. W ATTN: Mr. C. K. McCoy Act, eAemptions, IU fmah00 F0l4527 Vice President -
Vogtle Project % '
Post Office Box 1295 Birmingham, Alabama 35201
SUBJECT:
OF VIOL NV TIGATIONS REPORT NO. 2-90-020 AND NRC INSPECTION REPORT NO. 50-424,425/90-19, SUPPLEMENT 1)
This reters to the investigation conducted by the Nuclear Regulatory Commission's Office of Investigations (OI) at Georgia Power Company's (GPC) Vogtle Electric Generating Plant (VEGP) which was completed on December 17, 1993. The investigation was initiated as a result of information received in June 1990 by Region II alleging, in part, that material false statements were made to the NRC by senior officials of GPC regarding the reliability of the Diesel Generators (DGs). The purpose of DGs at a nuclear power plant is to power the loads that are needed to mitigate accidents, safely shut down the reactor and maintain a safe shutdown condition in the event normal power is lost. The pertinent events involved in this matter are described below.
On March 20, 1990, during a refueling outage at VEGP Unit 1, GPC declared a Site Area Emergency (SAE) when offsite power was lost concurrent with the failure of the only Unit 1 DG that was available (1A). The other Unit 1 DG (1B) was unavailable due to maintenance activities.
The NRC immediately responded to the SAE at the VEGP site with an Augmented Inspection Team (AIT). The NRC effort was upgraded to
, an Incident Investigation Team (IIT) on March 23, 1990. The IIT
- was composed of NRC Headquarters technical staff and industry personnel. The results of this investigation are documented in NUREG-1410, " Loss of Vital AC Power and the Residual Heat Removal Si stem During Mid-Loop Operations at Vogtle Unit 1 on March 20, 1990."
On March 23, 1990, the NRC issued a Confirmation of Action Letter (CAL) to GPC that, among other things, confirmed that GPC agreed not to return VEGP Unit 1 to criticality until the Regional Administrator was satisfied that appropriate corrective actions l ;'
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4 l had been taken, and that the plant could safely return to power i
operations. )
l On April 9, 1990, GPC made a presentation to the NRC in the Region II offices in support of GPC's request to return VEGP Unit 1 to power operations. GPC also submitted a written summary of its April 9 presentatio'n in'an April 9, 1990 letter, "Vogtle
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j Electric Generating Plant Confirmation of Action Letter."
l On April 12, 1990, the NRC formally granted permission for VEGP l
Unit 1 to return to criticality and resume power operations.
On April 19, 1990, pursuant to 10 CFR 50.73, GPC submitted l Licensee Event Report (LER) 50-424/90-06, " Loss of Offsite Power Leads to Site Area Emergency."
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On June 29, 1990, GPC submitted a revised LER, 50-424/90-06-01.
The purpose of the submittal was to clarify information related to successful DG starts, as discussed in the April 9, 1990 letter and the April 19, 1990 LER, and to update the status of corrective actions in the original LER.
From August 6 through August 17, 1990, the NRC conducted a Special Team Inspection at VEGP, as a result of NRC concerns about, and allegations related to, VEGP operational activities.
The objectives of the inspection were to (1) assess the operational philosophy, policy, procedures and practices of the facility's operating staff and management.regarding operational safety and (2) determine the technical validity and safety significance of each allegation and their impact on safe operation of the facility. This inspection did not investigate alleged wrongdoing. The Special Team informed GPC that the June 29, 1990 submittal failed to address the April 9, 1990 data and requested that GPC clarify DG starts reported on April 9, 1990. This results of this inspection are documented, in part, in NRC Inspection Report No. 50-424,425/90-19, Supplement I, dated November 1991.
On August 30, 1990, GPC submitted a letter, " Clarification of Response to Confirmation of Action Letter." The purpose of the submittal was to clarify the diesel start information that was addressed in the April 9, 1990 submittal.
The NRC has carefully reviewed the evidence associated with the these events. Specifically, the NRC reviewed information gathered as part of the OI investigation, information gathered during the IIT, NUREG-1410, Supplement I of NRC Inspection Report 90-19, discovery responses in the Vogtle operating license amendment proceeding (Docket Nos. 50-424 OLA-3, 50-425 OL -
an a e o-
7 formation was then presented to the ~
al presentation by the VEGP General Manager and in an April 9, 1990 letter that there were 18 and 19 successful consecutive starts on th DGs ' vel or failures.
e 19 trou e- ree s or tne 18 OG that GPC reported in e presentation and letter included three starts with problems that occurred during DG overhaul / maintenance activities (a high lube oil temperature trip on March 22, 1990; a low jacket water pressure / turbo lube oil pressure low trip on March 23, 1990; and a failure to trip on a high jacket water temperature alarm occurring on March 24, 1990).
The correct number consecutive successful starts was 12 for 1B DG--a number less than that r ted GPC l tha NDP tm Anri une air ror statt.ing a DG and operating its instruments and controls is derived from the starting air system. The starting air system contains dryers designed to control moisture (i.e., dew point) at acceptable
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levels. '
a review of maintenance records and deficiency cards associa with Unit 1 would have revealed that high dew points were also attributable to system air dryers occasionally being out of service for l l
extended periods and to system repressurization following I l
i maintenance, as documented in NRC Inspection. Report
,No. 50-424,425/90-19, Supplement _1, dated November 1, 1991.jl hb i
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--J During the preparation of the LER, the Acting VEGP Assistant General Manager questioned the accuracy of the April 9 letter t we r s on the 1B DG afte Ma Niventhat i
er 1scussions regarding the dr the General Manager, Technical Support Manager and Acting VEGP
} Assistant General Manager acknowledged that they did not l understand the starting point that the term CTP was supposed to i
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Georgia Power Company identify. There were also different interpretations about what testing the term CTP encorpassed. The General Manager - Plant Support (Vogtle Project), ti.? VEGP Technical Support Manager, and the Acting VEGP Assistant General Manager were aware that the VEGP General Manager had earlier stated that his April 9 count began after instrument recalibration. The Acting VEGP Assistant ta .- + n n
'the 1A and IB DG start counts reported on Apr11 1v, Assu, -
overstated the actual counts b including starts that were part -
of the test Drogram.
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j On Apri , 990, tle Acting VEGP
! ssistant General Manager or Plant Support ave the VEGP General I Mana .stin f 1A and 1B DG starts o
ter eing in ormed that i the April 19 DG start counts were error, the Senior Vice
! President - Nuclear Operations informed the Regional
! Administrator that a revision to the April 19 LER would be j submitted, in part, to correct the DC start counts.
1 J After being provided conflicting data about the actual number of l DG starts as of April 19, the Senior Vice President - Nuclear
! Operations requested (on or about May 24, 1990) that an audit be 4 i conducted to establish the correct data and'to determine why the '
errors were made. The audit completed June 29 narrowly focused l on a review of diesel records (Shift Supervisor's Log and Diesel j Generator Start Log) to verify the number of DG starts. The
- audit did not identify any specific cause for the error in the i number reported in the LER. The audit stated, however, that the
! error appeared to result from incomplete documentation. The j audit a1so noted it appears confusion exists ab ut the '
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! point at whi-h +ha +==t nrogram was com e
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On June 29, 1990, the draf t cover letter for the LER revision was' ~'"~""
being reviewed at the site. The draft had originated in GPC
- corporate headquarters and included language personally developed j by the Senior Vice President - Nuclear Operations and the Vice i President - Vogtle Project. During this review, a VEGP Technical l Assistant (TA) (formerly the Acting VEGP Assistant General
! Manager - Plant Support) noted that the letter was incomplete and i j challenged the accuracy of the reasons stated in the draft cover l l
letter in conversations with the Supervisor - Safety Audit and
- Engineering Review (SAER), the VEGP Assistant General Manager -
Plant Support, the VEGP Manager - Engineering Support, and a Licensing Engineer - Vogtle Project. The VEGP TA stated that:
(1) the letter failed to clarify the DG starts reported on April 9, (2) DG record keeping practices were not a cause of the j difference in the DG starts reported in the April 19 LER because j adequate information was available when the counting errors were jj l made, and (3) the erroneo unts resulted fr ner rrors i i
in develo ina the count.
l The Licensing Engineer - Vogtle Project was instructed by the i Senior Vice President - Nuclear Operations to work closely with '
the site to ensure that the submittal was accurate and complete.
j _.__
La The Supervisor - SAER was aware that the audit (that formed the basis for the reasons stated in the June 29 letter) was narrow in j scope and did not identify a specific cause for the error in the a
number of 18 starts reported in the April 19 LER. The Supervisor I - SAER was als servations stated in the audit
! report were being used to identify the root l causes for t e errors in the April 19 LER. The VEGP TA and VEGP Manager - Engine in Su rt made the Supervisor SA aware of
- this inaccurac j upervisor SAER 1
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} was made aware on June 12 that, to identify the root cause of the j
error in the April 19 LER (i.e., personnel errors), the audit j scope would need to include an assessment of the performance of i the Unit Superintendent and the VEGP General Manager, the
- individuals that developed the initial count. Yet, the audit did 5
not include these individuals. The Supervisor SAER was again made aware by the TA that the root cause rso -
I The VEGP Assistant General Manager - Plant Support was apprised l of concerns regarding the June 29 letter by the TA (an individual had been involved in preparing the April 19 LER and b'd been I
involved in daualnninn an accurate Dc etar* ' cant) .
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j the April 9, 1990 letter. The lett t '
r.gpe . ated that the erroro in the April 9 letter and presentation ou,fand the April 19 LER) were caused, in part, by confusion in the I dis _t_inction between a successful start and a valid test. 6 f
The August 36 lettet -_ _.,g. , '
states that the error in the April 9 letter and presentation (and the April 19 LER) were caused, in part, by an error made by the individual who performed the count of DG starts.
...64= orv unsuet tuvA eIIorts to correct the April 19 ~~
~L ER , it narrowly focused only on that submittal. For example, GPC conducted an audit, the scope of which was limited to review of DG records in an attempt to correct the start count reported in the April 19 LER. Furthermore, in its June 29 submittal, while GPC referred to both the April 9 letter and the April 19 LER, it attempted to explain only the reasons for the error in the April 19 LER. The Senior Vice Presdent - Nuclear Operations and the Vice President - Vogtle Project were directl involved in the devel ment of the June 29 letter.
sequent y, the NRC requested that GPC make a submittal addressing the April 9 letter. As of August 17, 1990, the VEGP General Manager and the Vice President
- Vogtle Project were aware of NRC concerns regarding the errors in, and the misleading nature of, the April 9 letter.
PC forwar e a suomi a rega e pri 9 e er on August 30 that was drafted at corporate headquarters under the direction of the Vice President - Vogtle Project, without an assessment of the actions of the VEGP General Manager and the Unit i
Superintend I jl letter.
4 Georgia Power Company i i
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! The responses directed by this letter and the enclosed Notice are j not subject to the clearance procedures of the Office of Manage-
- ment and Budget as required by the Paperwork Reduction Act of
. 1980, Pub. L. No.96-511.
.i Sincerely, t
l l Regional Administrator i
l Enclosure (s):
Notice of Violation d
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- NOTICE OF VIOLATION i Georgia Power Company Docket No. 50-424 i
! Vogtle Electric Generating Plant License No. NPF-68 l EA 93-304 During an NRC inspection conducted from August 6, 1990 to August 17, 1990 and an NRC investigation conducted from i j June XX 1990 to December 17, 1993, violations of NRC requirements I i were 1. .tified. In accordance with the " General Statement of l Policy a.d Procedure for NRC Enforcement Actions," 10 CFR Part 2, l A ndix C Nuclear Regulatory Commission propoaes to impose
! pursuant to Section 234 of the Atomic Energy Act of l *, enaed (Act 42 U.S.C. a O CF 2.205. The particular violations are set forth below:
! I. 10 CFR S 50.9 (a) requires that information provided to the NRC by a licensee shall be complete and accurate in all material
! respects.
i states that: "In accordance with 10 CFR 50.73, Georgia Pcwer Company (GPC) hereby submits the enclosed revised report related to an event which occurred on March 20, 1990. This revision is necessary to clarify the information
. related to the number of successful diesel generator starts as l discussed in the GPC letter dated April 9, 1990...."
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1 In DCCordance c;;lh !
Acf. C Aemphons 2 3 hon FolA J S ,. T r - ~
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l 4 4 Notice The letter states that: "If the criteria for the completion
- of the test program is understood to be the first successful I test in accordance with Vogtle Electric Generating Plant (VEGP) procedure 14980-1 " Diesel Generator Operability Test,"
then there were 10 successful starts of Diesel Generator 1A l and 12 successful starts of Diesel Generator 1B between the completion of the test program and the end of April 19, 1990, the date the LER-424/1990-06 was submitted to the NRC. The number of successful starts included in the original LER (at l
least 18) included some of the starts that were part of the test program. The difference is attributed to diesel start a
record keeping practices and the definition of the end of the i test program."
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etTbr dated Aug __ -
i es : "The confusion in the April 9th the original LER oppear to be Line result of two factors. First, there was confusion in the distinction between a successful start and a valid test... Second, an
' error was made by the individual who performed the count of DG starts for the NRC April 9th letter." _.
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"Since March 20, the 1A DG has been started 18 timee, and the 1B DG has been started 19 times. No f ailures or " . lems have occurred during any of these starts."
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l Start dcart IJ2 tripped on high temperature lube oil, ripped on low pressure jacket water and Start 136
, had a high temperature Jacket water trip alarm.
j April 9, As of j
1990, the 1B DG had only 12 consecutive successful starts without proble r failures rather than the 19
- re sented GPC.
l ll t e in ormation presente The NRC relied, in part, upon 1990 in the oral y GPC on April 9,
{ presentation and in the GPC letter in reaching the NRC decision to allow Unit 1 to return to power operation. ,
t N .
s a 'es, w en . Ascussing the al .* A v -
-ousa ut system at the Vogtle facility, that:
"GPC ha.e.
reviewed air quality of the D/G air system including )
dewpoint control and has concluded that air quality is l i
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Notice satisfactory. Initial reports of higher than expected dewpoints were later attributed 1.o faulty instrumentation."
1 actu ew had occurred at the e . I he causes of those high dew poln s Inc allure to use air dryers for extended periods of time and repressurization of the DG air start system I receivers following maintenance. !
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i The NRC relied, in part, upon e information presented by GPC in its letter of April 9, 1990 in reaching the decision to allow Vogtle Unit 1 to return to power operation.
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Numerous sensor calibrations (including jacket water temperatures), special pneumatic leak testing, and multiple engine starts and runs were performed under various conditions. After the 3-20-90 event, the control systems of l both engines have been subjected to a comprehensive test l
program. Subsequent to this test program, DG1A and DG1B have i been started at least 18 times each and no failures or i problems have occurred during any of these starts."
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Dated at (City, State) this day of (Month) 19 (g)
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A. 4 SYN 0PSIS !
> l On November 1,1990, the Regional Administrator, U.S. Nuclear Regulato Commission (NRC), Region II, requested that anl investigation be initi the NRC Office of Investigations (01) concerning alleged material fa se statements made to the NRC by senior officials of Georgia Power Comp r:garding the reliability of the emergency diesel generators (EDGs) at the Vogtle Electric Generating Plant (VEGP), Waynesboro, GA.
The 01 investigation substantiated that, on April 9,1990, the general manager (GM), VEGP, deliberately presented incomplete and inaccurate information NRC regarding the testing of the VEGP Unit This1occurred EDGsatconducted NRC subsequent to ,
March 20, 1990, site area emergency (SAE) at VEGP.
- Region II offices. Atlanta, GA, during a GPC oral presentation in suppo their request to return VEGP Unit 1 to power operations. o The investigation also substantiated that, on April 9,1990, in a letter to l l
NRC captioned V0GTLE ELECTRIC GENERATING PLANT CONFIRMAT the senior vice prident (VD) of Nuclear Operations (Nuc Ops) GPC, presj a misleading, incomplete, and inaccurate statement of diesel test results, which was based upon the incomplete, inaccurate information in theThe su aforementioned oral presentation. considered deliberate, because the GM, l letter and approved it for' signature by the senior VP.
19, 1990, the senior VP, Nuc as The investigation substantiated that, on April Ops, GPC, with, at a minimum of careless disregard, M, No. 90 006, which pertained to the SAE. 19, 1990, by a group of GPC
$c a direct result of deliberate actions, Theseon Aprilsinior managers, inc Corporate GM of Plant Support, and the VEGP GH.
senior managers wad reworded an existing statement of diesel testing in a draft LER, after the f' of Plant Support had been However, told by the GPC VEGP senior site person the draft LER statement management efforts towasmakebased) were false. similar to the April 9 statemen the rewording combined with their knowledge that the new statement could not have been definitively verified prior to the issuance of the LER, resulted in the reworded statement being false.
- The 01 investigation substantiated that the senior V 29, 1990.
the letter of transmittr' of a revision to LER 90 006, dated June This false statement permned to the reasons for th diesel starts in the transmittal letter of the revision.
The investigation substantiated that the VP, Vogtle Project, GPC, with, a minimum of careless disregard, submitted both a false and a misleading statement in the GPC clarification of Confirmation of Action resp to NRC dated August 30, 1990.
!*mation in tMs rnorg w3, gg7,,eg 1
[h**exemp*"ns N
_5 _h the Berdom
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" of infurn Case No. 2-90 020R fDi& .a{ ,D ~~ _
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- 9. i i tions to which he was a party. HOSBAUGH advised OI that he did this to obtain evidence of anticipated adverse action against him by GPC for ing safety concerns to NRC (he has a separate proceeding with the hrtment of Labor [ DOL) regarding discrimination issues), and to obtain gidence of anticipated wrongdoing on the part of GPC.
continued until early September 1990, when his taping became known to GPCHOSBAU during the course of a D0L proceeding between HOSBAUGH and GPC. l immediately suspended by GPC. On September 12, 1990. HOSBAUGH was attorney, made OI aware of the tapes and that they potentially containedHOSBAUGH, t evidence of wrongdoing on the part of GPC. i evidence on September 13, 1990. 01 took possession of the tapes as on October 8, 1990. HOSBAUGH's employment with GPC was terminated i
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In January 1990 HOSBAUGH had anonymously provided NRC with a written d
- allegation of a deliberate violation of a plant technical specification by GPC g 4 personnel at VEGP. This allegation was investigated by OI (Case No.
and substantiated. 2 90 001)
- On June 13, 1990 HOSBAUGH came forward, was granted l confidentiality by 01, and started providing additional written allegations v i
! that at VEGP were initially during addressed August 6 17, 1990. in an NRC Operational Special Inspection (OSI) !
In preparation for this OSI, on July 18 i additional details of his allegations. interviewed by 01 and RII NRC personnel regardin and 19, 1990. H05BAUGH was l l
In early September 1990, when MOSBAUGH's taping was revealed, and he was l l
suspended by GPC, he filed a 2.206 Petition with NRC, jointly with allegations.Harvin HOBBY another former GPC employee, in which he publicly restatedi agreement was subsequently rescinded.By mutual agreement between 01 and HO the results of the OSI, this Request for Investigation was prompted.As a res Interview of Alleoer (Allen L. HOSBAUGH) _
01 first contacted MOSBAUGH as a known alleger on June 13, 1990 (he had submitted his January 1990 allegation anonymously).
granted confidentiality, and he provided a detailed written documentAt this time, he was the results of EDG testing at VEGP after the SAE.(Exhibit 4) setting fo During the subsequent weeks HOSBAUGH provided additional written allegations to NRC recarding various other issues at VEGP.
be addressed in an OSI at VEGP.NRC staff decided that these allegdtions would inspector on July IB and HOSBAUGH was interviewed by OI and a RII vgarding these allegations. 19, 1990 (Exhibit 5), to obtain additional details August 6 17, 1990. The OSI was conducted during the period
~hroughout the conduct of this investigation, numerous contacts have occurred etween 01 t,nd H05BAUGH for purposes of identification of speakers on his tape ecordings, receipt of additional allegations, and further clarification of nown allegations. HOSBAUGH was again interviewed formally by OI on ovember nvestigation. 4, 1993 (Exhibit 6), specifically regarding the issues in this INVESTIGATOR'S NOTE:
allegations of Haterial False Statements by GPC senior manageme regarding EDG testing at VEGP after the SAE. However, HOSBAUGH's sse No. 2 90 020R 14
l
- g. 1 pilPMAN states that, everybody's gotten accustomed to seeing that data.
If we can use the data, we probably ought to. Certainly, if it's not a valid statement we would need to get it the heck out of here regardless of what George [HAIRSTON or BOCKHOLD] told Ebneter" (Exhibit 34, p.108).
- 21. SHIPMAN tells MOSBAUGH that he (SHIPMAN) and STRINGFELLOW are going to HAIRSTON's office to,
- finish beating out what he [HAIRSTON] wants to do with this thing" (Exhibit 34, pp. 108 109).
INVESTIGATOR'S NOTE: Persons identified as )ertici)ating in this call during this portion of the discussion are: 30CKHOL). AUFDENKAMPE, MOSBAUGH, McC0Y, SHIPMAN, and STRINGFELLOW. HAIRSTON is identified as being a participant at a later point in this same call, but it is possible that he, and others, were present on the Birmingham end of this call, without actively participating, from the beginning of the call. pA
- 22. AUFDENKAMPE describes to the articipants on the call that the way peo)le arrived at the termino ogy " greater than 20 starts" was that they #
toot the data from the April 9,1990, letter and added the starts that e had been done subsequent to April 9, 1990 (Exhibit 36, p. 8).
- 23. BOCKH:LD agreet. ,ch the ' greater than 20" terminology (Exhibit 36,
- p. 8).
- 24. McC0Y introduces terminology that is new to at least MOSBAUGH and AUFDENKAMPE, and new to the existing draft diesel start statement by saying. *We need to be sure that we know the number of starts after we've 4 completed the comprehensive control test program" (Exhibit 36, p. 8).
- 25. BOCKHOLD states that the numbers he presented to NRC on April 9, 1990, were verified correct by CASH (Exhibit 36, p. 8).
INVESTIGATOR'S NOTE: The count of these numbers was not started after the completion of any comprehensive control test program, and BOCKHOLD did not affirmatively know when the count was started, but he assumed it was somewhere around March 20, 1990.
- 26. McC0Y, the senior GPC official actively participating in the call at the time, affirmatively states that, "You ought to use those numbers." f (Meaning that in the April 19, 1990, LER, GPC ought to use the EDG start ~'
numbers that BOCKHOLD used in his April 9, 1990, presentation to NRC.)
(Exhibit 36, p. 8).
- 27. McC0Y, who is BOCKHOLD's immediate boss, then directly addresses B0CKHO and says, "Those numbers you used in the conference were after they had comleted the comprehensive test of the control systems on each diesel" (Ex11 bit 36, p. 9).
INVESTIGATOR *S NOTE: It is noted here that McC0Y does not gik BOCKHOLD when he started his count for the numbers in the conference. Instead, he tells BOCKHOLD when he (BOCKHOLD) started his count, looking for
' confirmation from his subordinate. And it appears that BOCKHOLD gives the response his superior wants.
- ase No. 2 90 020R 54