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UNITED STATES I
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j NUCLEAR REGULATORY COMMISSION 2
WASHINoTON, D.C. 20666-0001 o
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FEB 2 31994 Note to:
S. Ebneter T. Murley B. Hayes K. Cyr J. Lieberman From:
J. Milhoan
Subject:
PROPOSED ENFORCEMENT ACTION - V0GTLE Enclosed for your review, evaluation and coment is the proposed enforcement action for the Georgia Power Company's (GPC) submission of inaccurate and incomplete information on the Vogtle diesel generator problem.
The enclosures include:
(1) a Commission paper, (2) a cover letter, NOV oro sed Civil a
and a Demand for Information to the licensee, he ask that you su it comments to OE by March 1, 1994 and plan. or a mee ing of Office Directors to discuss and resolve coments on March 2,1994 AT 2:00 P.M..
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Enclosures:
As stated V
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W. Russell
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L. Chandler c'
7' J. Goldberg
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D. Matthews (5)
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.l PREDECISIONAL ENFORCEMENT T FOR PU 1 DISCLOSUR ITHOUT T
.information in this record was deleted in accordance with the Jeedom of Inforrnation F
d' Act, exemppns 9610080019 960827 eM
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! l ThG Commissioners collected by OI on the allegations.
The Vogtle Coordinating Group (Group) was t
f also tasked with identifying any violations and developing a detailed analysis 1
l of the evidence in support of its conclusions.
In addition to this enforcement proceeding, there is an ongoing Atomic Safety f
and Licensing Board (ASLB) proceeding considering the transfer of the j
oporating license from GPC to Southern Nuclear.
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i DISCUSSION:
The OI investigation concluded that evidence uncovered by 01 supports a l
finding of deliberate failures on the part of GPC officials to provide the NRC OI with information that is complete and accurate in all material respects.
concluded that:
the VEGP General Manager'(George Bockhold, Jr.) deliberately presented (1) incomplete and inaccurate information regarding the testing of the VEGP l
Unit 1 DGs during an oral presentation to the NRC on April 9,1990, l
GPC submitted inaccurate and incomplete information regarding DG test l
(2) results in a letter to NRC dated April 9,1990, as a result of deliberate actions by Mr. Bockhold, i
t GPC submitted inaccurate and incomplete information regarding DG air 1
(3) quality in the April 9 letter to the NRC, as a result of deliberate actions by Mr. Bockhold, the Senior Vice President - Nuclear Operations (George W. Hairston, j
(4)
III), with, at a minimum, careless disregard, submitted a false statement of diesel test results to the NRC in Licensee Event Report l
(LER) No.90-006, dated April 19, 1990, as a direct result of deliberate actions by a group of senior managers including Mr. Hairston, the Vice President - Vogtle Project (C. Kenneth McCoy), the Corporate General l
Manger of Plant Support (William B. Shipman), and Mr. Bockhold,
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Mr. Hairston, with, at a minimum, careless disregard, submitted a false (S) statement to NRC in the letter of transmittal of a revision to LER 90-i l
006, dated June 29, 1990, Mr. McCoy, with, at a minimum, careless disregard, submitted both a false statement and a misleading statement in the GPC clarification of l
(6) 30, 1990, and Confirmation of Action response letter to NRC dated August j
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Licensee organizational charts are included in Enclosure 2.
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first start following completion of the CTP.
There were
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also different interpretations about what testing the term j
CTP encompassed.
The General Manager - Plant Support (Vogtle Project), the VEGP Technical Support Manager, and 2
i 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 l
Assistant General Manager stated thtt. hip., understanding of
([Ig'the CTP was that it would be a test program to determine root causes and restore operability.
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~Tcquired the/ data advised Mr. Mosbaugh and Mr. Aufdenkampe lk i
that he started his counts on March 20, prior to the time when a CTP could have been com leted.i i
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reported on April 19, 1990 (and earlier on April 9),
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part of the test program.
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h MEMD FOR: Lieberman, OE FRON:
Reyes 4
SUBJECT:
PROPOSED ENFORCEMENT ACTION - V0GTLE NRR has reviewed the proposed Vogtle enforcement action and provides the following comments.
The following observations were ma e uring our review o the ra pac age.
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NOV Cover letter. Daae 4: It would be helpful to the reader to explicitly point out, perhaps at the beginning of the second paragraph, that the LER data was based on the data for the April 9, 1990 presentation and letter. As currently written, the discussion of the LER violation refers to the April 9, 1990 data without making it clear why it is relavent to the April 19, 1990 LER.
Additional comments of an editorial nature have been provided informally to your staff.
Reyes cc:
J. Milhoan W. Russell F. Miraglia I ' /,
A. Thadani g a a in gnisrecad c n deMed l [/k' 7
in a.:coid3r,;e with thepeedom Dj Injom350n Act, exemptipns; F01A-7 '3 ~ '
2-S b ib S. Ebneter K. Cyr B. Hayes bec:
S. Varga, NRR G. Lainas, NRR L. Chandler, 0GC J. Goldberg, OGC E. Ries, OGC E. Merschoff, RII J. Gray, OE D. Murphy, 01 L. Robinson, OI L. P11sco, OED0 D. Matthews/ Coordinating Group, NRR (6 copies)
Concurrence Line: DWheeler, DHooo, DMatthews, LReyes i
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i March XX. 1994 k
SECY-94-XXX r0R:
The Commissioners FROM:
James M. Taylor Executive Director for Operations
SUBJECT:
PROPOSED ENFORCEMENT ACTION AGAINST GEORGIA POWER-COMPANY, V0GTLE ELECTRIC GFNERATING PLANT j
(EA 93-304, EA 94-036, EA 94-037, and EA 94-052)
PURPOSE:
To consult with the Commission regarding the issuance of a Notice of Violation i
l Contacts:
J. Gray, OE NOTE: ENFORCEMENT RELATED - LIMITED 504-2747 TO NRC UNLESS THE COMMISSION R. Pedersen, OE DETERMINES OTHERWISE 504-2742 Information in this r!cerd was de:eted in accordance with the f,_rgedom of Informatiori Act, exemptions i
EDIA -
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The Commissioners BACKGROUND:
On March 20, 1990, during a refueling outage at Vogtle Electric Generating Plant (VEGP) Unit 1, GPC declared a Site Area Emergency (SAE) when offsite power was_ lost concurrent with the failure of the only Unit 1 Diesel Generator (DG) that was available (IA).
The other Unit 1 DG (IB) was unavailable due to i
1 maintenance activities.
The NRC immediately responded to the SAE at the VEGP site with an Augmented Inspection Team (AIT) which was subsequently upgraded to an Incident Investigation Team (IIT) on March 23, 1990.
On March 23, 1990, the NRC issued a Confirmation of Action Letter (CAL) to GPC l
that, among other things, confirmed that GPC had agreed not to return VEGP' Unit I to criticality until the Regional Administrator was satisfied that appropriate corrective actions had been taken, and that the plant could safely return to power operations.
On April 9, 1990, GPC maue a presentation to the NRC in the Region II offices in support of GPC's request to return VEGP Unit I to power operations. As part of this presentation, GPC provided information on DG starts in response to a specific NRC request that GPC address DG reliability in its April 9 presentation.
GPC submitted a written summary of its April 9 presentation in an April 9,1990 letter, "Vogtle Electric Generating Plant Confirmation of Action Letter." The NRC formally granted permission for VEGP Unit 1 to return to criticality and resume power operations on April 12, 1990.
On April 19, 1990, pursuant to 10 CFR 50.73, GPC' bmitted Licensee Event Report (LER) 50-424/90-006, " Loss of Offsite Power Leads to Site Area Emergency."
On June 29, 1990, GPC submitted a revised LER, 50-424/90-006-01.
The purpose of the submittal was to clarify information related to successful DG starts that were 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 (STI) at VEGP, as a result of NRC concerns about, and allegations related-to, VEGP operational activities.
This inspection examined the technical validity and safety significance of the allegations, but did not investigate alleged wrongdoing.
The Special Team informed GPC that the June 29, 1990 submittal f ailed to address the April 9,1990 data and requested ti.at GPC clarify DG starts reported on April 9, 1990.
On August 30, 1990, GPC submitted a letter, " Clarification of Response to Confirmation of Action Letter." The purcose of the submittal was to clarify the diesel start information that was addressed in the April 9. 1990 submittal.
On December 17, 1993, an investigation of licensed activities was completed by the NRC's Office of Investigations (01).
The investigation was initiated in response to allegations received in June 1990 by NRC Region 11 asserting, in
l The Commissioners part, that material false statements were made to the NRC by senior Licensee officials regarding the reliability of the DGs at VEGP as reflected in the series of communications on the issue described above.
The 01 Report of Investigation (Case No. 2-90-020R) is enclosed (Enclosure 1).
Because of the nature of Ol's preliminary conclusions, 01 discussed the matter with the Department of Justice (D0J) on January 9, 1992.
By memorandum dated April 12, 1993, D0J notified the NRC that it was closing its criminal investigation of the matter and recommended that the NRC continue its administrative proceeding.
00J also advised the NRC to contact D0J in the event subsequent j
NRC investigation identified additional evidence of criminal activity.
01 discussed the final results of its investigation with D0J on December 16, i
1993, and D0J verbally declined criminal prosecution of the matter.
j September 16, 1993, composed of representatives from the Office of Enforcement, Region 11, the Office of Nuclear Reactor Regulation and the i
I Offict of the General Cou..sel to conduct a detailed review of the evidence collected by 01 on the allegations.
The Vugtle Coordinating Group (Group) was also tasked with identifying any violations and developing a detailed analysis of the evidence in support of its conclusions.
Currently there is an ongoing Atomic Safety and Licensing Board (ASLB) proceeding considerin he transfer of operatin uthority from GPC to j
Southern Nuclear.
1 DISCUSSION:
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The 01 investigation concluded that the evidence supports a finding of j
deliberate failures on the part of GPC officials to provide the NRC with i
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Ine Commissioners information that is complete and accurate in all material respects.
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concluded that:
3 (1) the VEGP General Manager (George Bockhold, Jr.) deliberately presented incomplete and inaccurate information regarding the testing of the VEGP Unit 1 DGs during an oral presentation to the NRC on April 9, 1990, (2)
GPC submitted inaccurate and incomplete information regarding DG test results in a letter to NRC dated April 9, 1990, as a result of deliberate actions by Mr. Bockhold, (3)
GPC submitted inaccurate and incomplete information regarding DG air quality in the April 9 letter to the NRC, as a result of deliberate actions by Mr. Bockhold, i
(4) the Senior Vice President - Nuclear Operations (George W. Hairston, III), with, at a minimum, careless disregard,-submitted a falce statement 01 diesel test results to the NRC in Licensee Event' Report GER) No.90-006, dated April 19, 1990, as a direct result of deliberate actions by a group of senior managers including Mr. Hairston, the Vice President - Vogtle Project (C. Kenneth McCoy), the Corporate General Manger of Plant Support (William B. Shipman), and Mr. Bockhold, (5)
Mr. Hairston, with, at a minimum, careless disregard, submitted a false statement to NRC in the letter of transmittal of a revision to LER 90-006, dated June 29, 1990, (6)
Mr. McCoy, with, at a minimum, careless disregard, submitted both a false statement and a misleading statement in the GPC clarification of Confirmation of Action response latter to NRC dated August 30. 1990, and j
(7)
GPC provided inaccurate information in its response to a 10 CFR 2.206 petition, dated April 1, 1991.
01 could not conclude that these actions were deliberate.
01 also concluded from the combination of the above findings, and the oserall review of numerous audio tape recordings of internal GPC conversations regarding their communications with the NRC on a range of issues, that, at least in the March-August 1990 time frame, there was evidence of a closed, deceptive, adversarial attitude toward NRC on the part of GPC senior management.
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i Licensee organizanonal charts are ineluded in Enclosure 2.
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Finally, the Group reviewed numerous audio tapes and other evidentiary materials associated with DG testing during the March-August 1990 time frame.
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Tha enmmissioners 9_
s NOTE:
This paper and its issues shouto not. ue go...
matter involves sensitive as well as predecisional enforcement issues.
James M. Taylor Executive Director for Operations
Enclosures:
1.
01 Panort 2-90-020R 2.
Licensee Organization Charts 3.
Vogtle Coordinating Group Analysis 4.
The Commissioners DISTRIBUTION:
Commissioners OGC OCA NRR Region II 01 E00 SECY DE OE DD:0E NRR AD:NRR D:NRR 01 RPedersen JGray DMatthews LReyes WRussell BHayes RA:RII D:0E OGC OGC DEDR ED0 SEbneter JLieberman JGoldberg KCyr JMilhoan JTaylor G:\\0ECASES\\V0GPAPER.R10
Docket No.
50-424 License No.
NPF-68 EA 93-304, EA 94-036, EA 94-037, and EA 94-052 Georgia Power Company ATTN:
Mr. H. Allen Franklin President and Chief Executive Officer Post Office Box 1295 Birmingham, Alabama 35201
SUBJECT:
T INVESTIGATIONS REPORT NO. 2-90-020 AND NRC INSPECTION REPORT N0. 50-424,425/90-19, SUPPLEMENT 1)
This refers to the investigation conducted by the Nuclear Regulatory Commission's Office of Investigations (01) at Georgia Power Company's (GPC or Licensee) 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 11 alleging, in part, that material false statements were made to the NRC by senior officials of GPC regarding the rei.cility of the Diesel Generators (DGs).
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 (lA).
The other Unit 1 DG (18) 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 i
Investigation Team (IIT) on March 23, 1990.
The llT 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 System During Mid-loop Operations at Vogtle Unit 1 on i
March 20, 1990."
On March 23, 1990, the NRC issued a Confirmation of Action Letter (CAL) to GPC that, amorg other things, confirmed that GPC had agreed not to return VEGP Unit 1 to criticality until the Regional Administrator was satisfied that appropriate corrective actions had been taken, and that the plant could safely return to power operations.
Georgia Power Company 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.
As part of this presentation, GPC provided information on DG starts in response to a specific NRC request that GPC address DG reliability in its April 9 presentation.
GPC submitted a written summary of its April 9 presentation in an April 9, 1990 letter, "Vogtle Electric Generating Plant Confirmation of Action Letter."
On April 12, 1990, the NRC formally granted permission for VEGP Unit I to return to criticality and resume power operations.
On April 19, 1990, pursuant to 10 CFR 50.73, GPC submitted Licensee Event Report (LER) 50-424/90-006, " Loss of Offsite Power Leads to Site Area Emergency."
On June 29, 1990, GP: submitted a revised LER, 50-424/90-006 ^1.
The purpose of the suLmittal was to clarify information related to successful DG starts that were 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.
This inspection examined the technical validity and safety significance of the allegations, but 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.
Results of this inspection are documented, in part, in NRC Inspection Report No. 50-424,425/90-19, Supplement 1, dated November 1, 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 infnrmation that was addressed in the April 9, 1990 submittal.
The NRC has carefully reviewed the evidence associated with these everts, submittals, and representations to the NRC.
Specifically, the NRC reviewed information gathered as part of the 01 investigation, information gathered during the llT, NUREG-1410, Supplement 1 of NRC Inspection Report 90-19, discovery responses in the Vogtle operating license amendment proceeding (Docket Nos. 50-424 OLA-3, 50-425 OLA-3), and other related information.
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2 The VEGP General Manager was narsonally "olved in the preparation of the data regarding the DG reliability and tasked the Unit Superintendent with collecting the numoer of auccessful DJ starts for the 1A and 18 DGs.
i in fact, the VEGP General Manager stated no criteria for successful starts, a term not formally defined, when he directed the Unit Superintendent to gather successful DG starts.
The Unit Superintendent collected DG start dat om the Control Room
'and the Shift Supervisor's Lo an ora y convey e ra Manager for the lA and 18 diesels.
4 was then presented to the NRC in an April 9, 1990 oral presentation by the VEGP General Manager and in an April 9, 1990 letter that since March 20, 1990, there were 18 and 19 successful consecutive starts on the 1A and IB DGs, respectively, without problems or failures,agglBk i
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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 I
trip on March 23, 1990; and a failure to trip on a high jacket water 5
temperature alarm occurring on March 24, 1990).
The correct number of consecutive successful starts was 12 for the IB DG--a number 1
6 less than that reported ty GPC to the NRC on April 9.
1990.
4 fr. considering a restart decision.
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the NRC was especially interested in the reliability of the DGs and spec.fically asked that GPC address the matter in its presentation on restart.
The NRC relied, i n part, upon this information presented by
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GPC on April 9, 1990 in the oral presentation and in the GPC letter in reaching the NRC decision to allow Vogtle Unit 1 to return to power f,
operation.
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. The air for s arting a DG and operating its instruments and controls is derived from the starting air system.
The starting air system contains dryers designed to maintain moisture content (i.e., dew point) at acceptable levels.
A review of maintenance records and deficiency cards associated with Unit I would have revealed that high dew points were also attributable to system air dryers occasionally being out of service i
for extended periods and to system repressurization following maintenance, as documented in NRC Inspection R ort No. 50-424.425/
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'9, Supplement 1, dated November 1, 1991.
In considering a restart decision, the NRC was especially interested in the reliability of the DGs and specifically asked that GPC l
address the matter in its presentation on restart.
The NRC relied, in l
part, upon this information presented by GPC in its letter of April 9, i
1990 in reaching the decision to allow Vogtle Unit 1 to return to power
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operation.
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l LER 90-006, submitted to the NRC on April 19, 1990, was based, in part, j
on information presented to the NRC on April 9, 1990.
During the j
preparation af the LER, the Acting VEGP Assistant General Manager -
Plant Support questioned the accuracy of the April 9.
4 1990 letter given
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that there were trips on the IB DG after March 20, 1990.
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l In later discussions regarding the draft LER, the General Manager, Technical Support Manager and Acting VEGP Assistant General Manager - Plant Support acknowledged that they could not identify the specific DG start that represented the starting point for the count presented to the NRC, i.e., the first start following completion of the j
CTP.
The General Manager - Plant Support (Vogtle Project), the VEGP Technical Support Manager, and the Acting VEGP Assistant General Manager
- Plant Support were aware that the VEGP General Manager had earlier stated that his April 9 count began after instrument recalibration.
The Acting VEGP Assistant General Manager - Plant Support stated that his i
understanding of the CTP was that it would be a test program to i
determine root causes and restore operability.
In fact, the Unit uperio en en wio co ecte the original April 9th data adviseu the Acting VEGP Assistant General Manager - Plant Support a.id the VEGP Technical Support Manager that he started his counts on March 20, prior to the time when a CTP could have been completed.
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the lA and 18 DG start counts reported on April 19, 1990 overstated the j
actual counts by including starts that were part of the test ram.
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the DGs--the failure of one of which was t e very issue that caused an extended shutdown.
GPC was clearly aware of the NRC's interest in the DGs, in that the NRC specifically asked GPC to address DG reliability as part of ite restart presentation for April 9, 1990.
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On April 30, 1990, the Acting vt.w ass inant Manager - Plant Support gave the VEGP General Manager a listing of IB DG uci c.
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After being informed that the April 19 DG start counts were in error, j
the Senior Vice President - Nuclear Operations informed the Regional l
Administrator that a revision to the April 19 LER would be submitted, in l
part, to correct the DG start counts.
After being provided conflicting data for the second time, the Senior Vice President - Nuclear Operations j
again notified the Regional Administrator.
He also requested that an i
audit be conducted by GPC's Safety Audit and Engineering Review (SAER) group to establish the correct data and to determine & the errors were j
made.
The audit, completed June 29, narrowly focused on a review of diesel records (Test Data Sheets, 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 number reported in l
the LER.
The audit stated, however, that the error appeared to result l
from encomplete documentation.
The audit also noted that there j
appa,ently was some confusion about the specific point at which the test proaram was completed. -
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On June 29, 1990, the draft cover letteF for the LER revision was being reviewed at the site.
The draft had originated in GPC corporate l
headquarters and included language personally developed by the Senior Vice President - Nuclear Operations and the Vice President - Vogtle Project.
During the site review, a VEGP Technical Assistant (TA)
(formerly the Acting VEGP Assistant General Manager - Plant Support) noted that the letter whs incomplete and challenged the accuracy of the reasons stated in the draft cover letter in conversations with the Supervisor - SAER, the VEGP Assistant General Manager - Plant Support, l
the VEGP Manager - Engineering Support, and a Li 1 sing 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 difference in the DG starts reported in the April 19 LER because adequate information was available when the i
counting errors were made, and (3) the erron s counts resulted from personnel errors in develo in the count.
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The Licensing Engineer - Vogtle Project had staff responsibility for preparing the cover letter for the LER revision and was specifically instructed oy the Senior Vice President - Nuclear Operations to work closely with the site to ensure that the submittal was accurate and
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The VEGP Manager - Engineering Support was responsible for the Diesel j
Start Logs and agreed with the audit report findings regarding i
deficiencies in their condition.
Given that his logs had not been used to collect the DG start data, he pointed out that it was wrong to state that the condition of his iogs caused errors in the information 1
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h the Supervisor - SAER was made awara by the VEGP TA on June 12, 1990 that, to identify the root cause of the error in the April 19, 1990 LER (i.e., personnel errors), the audit scope would need to include an assessment of the performance of the Unit Superintendent and the VEGP General Manager, the individuals that developed the initial count.
- Yet, the audit report did not include either of these individuals in the list of persons contacted during the audit.
On June 29, 1990, the Supervisor
- SAER was again made aware by the VEGP TA that the root cause for the difference was personnel error.
l The VEGP Assistant Oeneral Manager was apprised of concerns regarding the June 29, 1990 ielter by the VEGP TA (an individual who had been involved in preparing the April 19, 1990 LER and had been involved in developing an accurate DG start count).
The VEGP TA identified to him the failure of the June 29, 1990 draft cover letter to address the inaccuracies in the April 9. 1990 letter that it reference 1
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President - Nuclear Operations were actively involved in the preparation j
of the June 29 cover letter.
The VEGP General Manager and Vice President - Vogtle Project reviewed, and the Senior Vice President -
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its purpose was, in part, to clarify information provided to the NRC on Anril o
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i letter and presentation and the April 19 LER were caused, in part, by confusion in the distinction between a successful start and a valid I
test.
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During the August 29, 1990 Plant Review Board (PRB) i meeting, the VEGP Manager - Technical Support questioned if the Unit j
Superintendent (the individual who originally collected the DG start data) was :onfused in the distinction between a successful start and a i
i valid test.
The VEGP General Manager admitted that the Unit i
Superintendent was not confused about the distinction when he collected the data which was used to prepare the April 9 letter, but stated that i
the sentence was not in error because other people were confused.
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VEGP General Manager acknowledged that there was confusion among individuals after April 9, but admitted that the Unit Superintendent was mnotconfused the inf i
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il The August 30 letter states that the j
error in t e Apri etter an presentation and the April 19 LER were caused, in part, by an error made by the individual erformed count of DG starts.
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l The Senior Vice President - Nuclear Operations ano the Vice President - Vogtle Project were direct) involved in the development of the Jrle 29 letter.
Subsequently, the NRC requested that GPC make a submittal addressin the ril 9 letter i
The Vice Pres 11ent - Vogtle Project committed during the August 17 meeting with the MAC special inspection team to provide clarification to the NRC regt.rding the April 9 letter.
GPC forwarded a submittal regarding the April 9 letter on August 30 that was drafted at corporate headquarters under the mdirect;cnoftheV l
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Georgia Power Company !
The responses directed by this letter and the enclosed Notice are not subject j
to the clearance procedures of the Office of Management and Budget as required 1
by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
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Sincerely, l
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James L. Milhoan j
Deputy Executive Director I
for Nuclear Reactor Regulation, Regional Operations,and Research
Enclosures:
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Demand For Information 1
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Georgia Power Company 01STRIBUT10ft:
PDR SECY CA JTaylor, EDO JMilhoan, DEDR JLieberman, OE SEbneter, RII LChandler, OGC JGoldberg, OGC WRussell, NRR EReis, OGC Enforcement Coordinators RI, RII, Rill, RIV, RV Fingram, GPA/PA EJordan, AE00 BHayes, 01 EA file DCS Vogtle Coordinating Group:
D. Matthews, Chairman R. Pedersen, OE P. Skinner, RIl D. Hood, NRR D. Wheeler, NRR D. Hoefling, OGC M. Young, OGC
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Georgia Power Company Docket No. 50-424
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Vogtle Electric Generating Plant License No. NPF-68 EA 93-304 i
l During an NRC inspection conducted from August 6, 1990 to August 17, 1990 and on NRC investigation completed on December 17, 1993, violations of NRC j
requirements were identified.
In accordance with the " General Statement of i
Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, endix C, j
the Nuclear Regulatory Commission proposes to imposu ursuant to Section 234 of the Atomic Energy Act of 1954, as a d (Act),
U.S.C.
i j
2282, and 10 CFR 2.205.
The particular violations
{ g re set forth below:
10 CFR 50.9(a) requires that information provided to the NRC by a licen ee shall be complete and accurate in all material respects.
DG has been started 18 times, and the 18 DG has been started 19 times.
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No failures or problems have occurred during any of these starts."
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ijh temperature lube oil, Start 134 tripped on low pressure jacket water and Start 136 had a high temperature jacket water trip alarm.
As of April 9, 1990, the IB DG had only 12 consecutive successful starts without problems or failures rather than the 19 represented by GPC.
The same inaccuracy was presented to the NRC at its Region II Office during an oral presentation j
by GPC on April 9, 1990.
1 In considering a restart decision, the NRC 1
was especially interested in the reliability of the DGs and specifically j
asked that GPC address the matter in its presentation on restart.
The j
NRC relied, in part, upon this information presented by GPC on April 9, j
1990 in the oral presentation and in the GPC letter in reaching the NRC l
decision to allow Vogtle Unit I to return to power operation.
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Notice i
]4 an April 9, 1990 letter states, when discussing the air quality of the DG starting air system at the Vogtie facility, that:
"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 i
than expected dewpoints were later attributed to faulty j
instrumentation."
i actual high j
dew points had occurred at the Vogtle facility. 6 i
gglEllbthe causes of those high dew points included failure to use air dryers for extended periods of time and repressurization of the DG air j
start system receivers following maintenance.
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In considering a restart decision, the i
NRC was especially interested in the reliability of the DGs and i
specifically asked that GPC address the matter in its presentation on i
restart.
The NRC relied, in part, upon this information presented by GPC in its letter of April 9, 1990 in reaching the dec'sion to allow j
Vogtle Unit I to return to power operation.
A l
g states:
"iumerous sensor ca ibrations (inc Tu ing jacket water temperatures), special pneumatic t
1 leak testing, and multiple engine starts and runs were performed under j
various conditions.
After the 3-20-90 event, the control systems of j
both engines have been subjected to a comprehensive test program.
Subsequent to this test program, DGIA and DGl8 have been started at i
least 18 times each and no failures or problems have occurred during any j
of these starts."
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n LER j
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une ',
I states that:
"In accordance with 10 CFR 50.73, Georgia Power l
Company C) hereby submits the enclosed revised report related to an i
event which occurred on March 20, 1990.
This revision is necessary to clarify the information related to the number of successful diesel l
generator starts as discussed in the GPC letter dated April 9, 1990...."
4 l
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The letter states that:
"If the criteria for the completion of the test program is understood to be the first successful test in accordance with Vogtle Electric Generating Plant (VEGP) procedure 14980-1 " Diesel Generator Operability Test," then there were 10 successful starts of l
Diesel Generator IA and 12 successful starts of Diesel Generator 18 i
between the completion of the test program and the end of April 19, i
1990, the date the LER-424/1990-06 was submitted to the NRC.
The number of successful starts included in the original LER (at least 18) included some of the starts that were part of the test program.
The difference j
is attributed to diesel start record keeping practices and the i
definition of the end of the test program."
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l lI' Notice 1
c states that:
"The confusion in the April 9th letter and the origin R appear to be the 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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i Dated at (City, State)
I this day of (Month) 19(11) i J
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l UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of
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l
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l GEORGIA POWER COMPANY
)
(Vogtle Electric Generating
)
Docket Nos. 50-425/50-425 Plant, Units 1 & 2)
)
License Nos. NPF-68/NPF-81
)
EA 94-052 DEMAND FOR INFORMATION REGARDING C. KENNETH McC0Y I
Georgia Power Company (Licensee) is the holder of Facility License Nos.
NPF-68, and NPF-81 (Licenses) issued by the Nuclear Regulatory Commission (NRC or Commission) pursuant to 10 CFR Part 50.
The Licenses authorize the operation of the Vogtle Electric Generating Plant (VEGP) Units 1 and 2, in accordance with conditions specified therein.
II 1
On December 17, 1993, an investigation of licensed activities was completed by the NRC's Office of Investigations (01) at Licensee's VEGP facility. The investigation was initiated in response to information received in June 1990 by NRC Region II alleging, in part, that material false statements were made to the NRC by senior Licensee officials regarding the reliability of the Diesel Generators (DGs).
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 i
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Site Area Emergency (SAE) when offsite power was lost concurrent with the failure of the only Unit 1 DG that was available (IA).
The other Unit 1 DG (IB) was unavailable due to maintenance activities.
l
. The NRC innediately 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 System 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 had agreed not to return VEGP Unit 1 to criticality until the Regional Administrator was satisfied that appropriate corrective actions had been taken, ard that the plant could safely return to power operations.
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. As part of this presentation, GPC provided information on DG starts in response to a specific NRC request that GPC address DG reliability in its April 9 presentation.
GPC submitted a written summary of its April 9 presentation in an April 9,1990 letter, "Vogtle Electric Generating Plant Confirmation of Action Letter."
On April 12, 1990, the NRC formally granted permission for VEGP Unit 1 to return to criticality and resume power operations.
i
. On April 19, 1990, pursuant to 10 CFR 50.73, GPC submitted Licensee Event Report (LER) 50-424/90-006, " Loss of Offsite Power Leads to Site Area Emergency."
On June 29, 1990, GPC submitted a revised LER, 50-424/90-006-01.
The purpose of the submittal was to clarify information related to successful DG starts that were 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 Augu n 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. This inspection examined the technical validity and safety significance of the allegations, but did not invesi" te
' alleged wrongdoing. The Special Team informed GPC that the June 29, 1990 submittal fa; led to address the April 9, 1990 data and requested that GPC clarify DG starts reported on April 9, 1990.
Results of this inspection are documented, in part, in NRC Inspection Report No. 50-424,425/90-19, i
Supplement 1, dated November 1, 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.
.M' J i III i
j The NRC has reviewed the evidence associated with these events, submittals, j
and representations to the NRC.
Specifically, the NRC reviewed information I
gathered as part of the 01 investigation, information gathered during the IIT, NUREG-1410, Supplement 1 of NRC Inspection Report 90-19, discovery responses 1
i in the Vogtle operating license amendment proceeding (Docket Nos. 50-424 OLA-3, 50-425 OLA-3), and other related information.
Nr, McCoy was actively involved in the preparation of the June 29, 1990 cover letter for an LER revision that was being submitted to the NRC and reviewed it prior to forwarding it to the Senior Vice President - Nuclear Operations for signature and issuance.
The June 29, 1990 cover letter stated that its purpose was, in part, to clarify information provided to the NRC cn April 9,
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I i i 1990.
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l Mr. McCoy committed during the August 17, 1990 meeting with the NRC f
Special Inspection Team to provide clarification to the NRC regarding the April 9, 1990 letter.
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a FOR THE NUCLEAR REGULATORY COMMISSION i
l James L. Milhoan j
Deputy Executive Director j
for Nuclear Reactor Regulation, l
Regional Operations, and Research i
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Dated at Rockville, Maryland this day of (Month) 19(11) i.,
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UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
GEORGIA POWER COMPANY
)
(Vogtle Electric Generating
)
Docket Nos. 50-425/50-425 Plant, Units 1 & 2)
)
License Nos. NPF-68/NPF-81
)
EA 94-037 DEMAND FOR INFORMATION i
REGARDING GEORGE 80CKHOLD, JR.
I 8
I Georgia Power Company (Licensee) is the holder of Facility License Nos.
I NPF-68, and NPF-81 (Licenses) issued by the Nuclear Regulatory Commission (NRC or Commission) pursuant to 10 CFR Part 50. The Licenses authorize the
~
operation of the Vogtle Electric Generating Plant (VEGP) Units 1 and 2, in accordance with conditions specified therein.
I II On December 17, 1993, an investigation of licensed activities was completed by the NRC's Office of Investigations (01) at Licensee's VEGP facility. The investigation was initiated in response to information received in June 1990 by NRC Region 11 alleging, in part, that material false statements were made to the NRC by senior Licensee officials regarding the reliability of the Diesel Generators (DGs).
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 (lA).
The other Unit 1 DG (IB) was unavailable due to maintenance activities.
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 i
investigation are documented in NUREG-1410, " Loss of Vital AC Power and the -
Residual Heat Removal System During Mid-loop Operat' ions at Vogtle Unit 1 on March 20, 1990."
l On March 23, 1990, the NRC issued a Confirmation of Action Letter (CAL) to GPC that, among other things, confirmed that GPC had agreed not to return VEGP 1
Unit 1 to criticality until the Regional Administrator was satisfied that appropriate corrective actions had been taken, and that the plant could safely return to power operations.
On April 9, 1990, GPC made a presentation to the NRC in the Region 11 offices in support of GPC's request to return VEGP Unit 1 to power operations.
As part of this presentation, GPC provided information on DG starts in response to a specific NRC request that GPC address DG reliability in its April 9 presentation.
GPC submitted a written summary of its April 9 presentation in an April 9,1990 letter, "Vogtle Electric Generating Plant Confirmation of Action Letter."
On April 12, 1990, the NRC formally granted permission for VEGP Unit I to return to criticality and resume power operations.
i I
I I On April 19, 1990, pursuant to 10 CFP 50.73, GPC submitted Licensee Event Report (LER) 50-424/90-006, " Loss of Offsite Power Leads to Site Area Emergency."
On June 29, 1990, GPC submitted a revised LER, 50-424/90-006-01.
The purpose of the submittal was to clarify information related to successful DG starts that were 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.
1 From Augu 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.
This inspection examined the technical validity and safety significance of the allegations, but 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.
Results of this inspection are documented, in part, in NRC Inspection Report No. 50-424,425/90-19, Supplement 1, dated November 1, 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.
i i
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The NRC has reviewed the evidence associated with these events, submittals, l
]
and representations to the NRC.
Specifically, the NRC reviewed information gathered as part of the OI investigation, information gathered during the IIT,
[
NUREG-1410, Supplement 1 of NRC Inspection Report 90-19, discovery responses in the Vogtle operating license amendment proceeding (Docket Nos. 50-424 OLA-3, 50-425 OLA-3), and other related information. M 4
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Prior to GPC briefing the Regional Administrator, Region 11, on VEGP's readiness for restart, the NRC asked GPC to address DG reliability as part of its restart presentation on April 9, 1990.
For that presentation, Mr. Bockhold was personally involved in the preparation of data regarding DG-
l 5-reliability and tasked the Unit Superintendent with collecting the number of successful DG starts for the 1A and 18 DGs.
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/ In fact, Mr. Bockhold stated no criteria for successful starts, a term not formally defined, when he directed the Unit i
Superintendeat to gather successful [G starts.
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g g Information was then presented to the NRC in the April 9,1990 oral presentation by l
Mr. Bockhold and the April 9,1990 letter submitted by GPC, after being t
reviewed by Mr. Bockhold, that there were 18 and 19 consecutive successful starts on the 1A and IB DGs, respectively, without problems or failures.
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GPC's report of starts in the presentation and letter included three IB DG starts with prcblems that occurred during DG overhaul and maintenance activities (a high lube oil temperature trip on March 22, 1990; a 1cw jacket water pressure / turbo lube oil presstre 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 of consecutive successful starts without s
problems or failures was 12 for. ID DG--a number significantly less than that reported by GPC to the NRC on April 9,1990. M i
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4 LER 90-006, submitted to the NRC on April 19, 1990, was based, in part, on j
l information presented to the NRC on April 9, 1990. During review of the draft LER, site personnel questioned its accuracy. Given that there were trips in j
the IB DG after March 20, 1990, they did not think that the statement concerning "no problems or failures" was correct. A teleconference was subsequently held between site and corporate personnel I
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During the NRC's Special Team inspection exit interview on August 17, 1990, 1
j GPC was specifically notified by the NRC that the revised LER did not adequately clarify the DG start information contained in the April 9, 1990 letter, and NRC requested GPC to provide clarification of this submittal.
GPC forwarded a submittal to the NRC on August 30, 1990 regarding the April 9, 1990 letter.
-g During an August 29, 1990 Plant Review Board (PRB) meeting which, among other things; reviewed the proposed 4
August 30, 1990 submittal to the NRC, the VEGP Manager - Technical Support
~
l raised concerns about the accuracy of that statement. Mr. Bockhold admitted to the PRB that the Unit Superintendent (who originally collected the DG start 1
data at Mr. Bockhold's direction) was not confused about the distinction between successful starts and valid tests when the start data was collected for the April 9, 1990 letter, but stated that the sentence was not in error because other people were confused. Mr. Bockhold acknowledged that there was confusion among individuals after April 9, 1990, but admitted that the Unit Superintendent was not confused when he developed the information.
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information that GPC was providing to the NRC on this issue, e
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FOR THE NUCLEAR REGULATORY COMMISSION James L. Milhoan Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations, and Research Dated at Rockville, Maryland this day of (Month) 19(g)
UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
GEORGIA POWER COMPANY
)
(Vogtle Electric Generating
)
Docket Nos. 50-425/50-425 Plant, Units 1 & 2)
)
License Nos. NPF-68/NPF-81
)
EA 94-036 DEMAND FOR INFORMATION REGARDING THOMAS V. GREENE, GEORGIE R. FREDERICK, HARRY MAJORS, AND MICHAEL W. HORTON I
i Georgia Power Company (Licensee) is the holder of Facility License Nos. NPF-68 and NPF-81 (Licenses) issued by the Nuclear Regulatory Commission (NRC or Commission) pursuant to 10 CFR Part 50.
The Licenses authorize the operation of the Vogtle Electric Generating Plant (VEGP) Units 1 and 2, in accordance with conditions specified therein.
II On December 17, 1993, an investigation of licensed activities was completed by the NRC's Office of Investigations (01) at Licensee's VEGP facility.
The investigation was initiated in response to information received in June 1990 by NRC Region 11 alleging, in part, that material false statements were made to the NRC by senior Licensee officials regarding the reliability of the Diesel Generators (DGs).
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 j
Site Area Emergency (SAE) when offsite power was lost concurrent with the
~
2 1
. failure of the only Unit 1 DG that was available (lA). The other Unit 1 DG (IB) was unavailable due to maintenance activities.
l l
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 f
Residual Heat Removal System During Mid-Loop Operations at Vocjtle Unit 1 on March 20, 1990."
1 l
On March 23, 1990, the NRC issued a Confirmation of Action Letter (CAL) to GPC l
that, among other things, confirmed that GPC had agreed not to return VEGP Unit I to criticality until the Regional Administrator was satisfied that appropriate corrective actions had been taken, and that the plant could safely return to power operations.
i j
On April 9, 1990, GPC made a presentation to the NRC in the Region II offices 2
in support of GPC's request to return VEGP Unit 1 to power operations.
As part of this presentation, GPC provided information on DG starts in response to a specific NRC request that GPC address DG reliability in its April 9 presentation.
GPC submitted a written summary of its April 9 presentation in an April 9,1990 letter, "Vogtle Electric Generating Plant Confirmation of Action Letter."
J
i
. On April 12, 1990, the NRC formally granted permission for VEGP Unit I to return to criticality and resume power operations.
On April 19, 1990, pursuant to 10 CFR 50.73, GPC submitted Licensee Event Report (LER) 50-424/90-006, " Loss of Offsite Power Leads to Site Area Emergency."
On June ?9, 1990, GPC submittad a revised LER, 50-424/90-006-01.
The purpose of the submittal was to clarify information related to successful DG starts i
that were oiscusseo 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.
This inspection examined the technical validity and safety significance of the allegations, but 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.
Results of this inspection are documented, in part, in NRC Inspection Report No. 50-424,425/90-19, Supplement 1, dated November 1, 1991.
I 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 J;esel start information that was addressed in the April 9,1990 submittal.
l
. i III i
The NRC has reviewed the evidence associated with these events, submittals, and representations to the NRC.
Specifically, the NRC reviewed information gathered as part of the 01 investigation, information gathered during the IIT, NUREG-1410, Supplement 1 of NRC Inspection Report 90-19, discovery responses in the Vogtle operating license amendment proceeding (Docket Nos. 50-424 OLA-3, 50-425 OLA-3), and other related information.
1 On June 29, 1990, the draft cover letter for the LER revi: ion was being reviewed at the VEGP site.
The draft had originated in GPC corporate headquarters and included language personally developed by the Senior Vice President - Nuclear Operations (George W. Hairston, III) and the Vice
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President - Vogtle Project (C. Kenneth McCoy).
During this review, a VEGP l
Technical Assistant (TA) (formerly the Acting VEGP Assistant General Manager -
Plant Support) (Alan L. Mosbaugh) noted that the draft cover letter was i
incomplete and challenged the accuracy of the reasons stated in the draft cover letter in conveisations with the Supervisor - Safety Audit and Engineering Review (SAER) (Georgie R. Frederick), the VEGP Assistant General J
l Manager - Plant Support (Thomas V. Greene), the VEGP Manager - Engineering i
Support (Michael W. Horton), and a Licensing Engineer - Vogtle Project (Harry W. Majors).
Mr. Msbaugh stated that: (1) the letter failed to clarify the DG starts reporteo on April 9, 1990 (2) DC ecord keeping practices were not a cause of the difference in the DG starts reported in the April 19, 1990 LER i
i because adequate information to formulate an accurate count was available when the counting errors were made, and (3) the erroneous counts resulted from personnel errors in developing the count.
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smum i
l Mr. Majors had staff responsibility for preparing the cover letter for the LER i
revision and was specifically instructed by the Senior Vice President -
Nuclear Operations to work closely with the site to ensure that the submittal
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was accurate and complete.
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Mr. Horton was responsible for the Diesel Start Logs and agreed with the audit t
l report findings regarding deficiencies in their condition.
Given that his i
j logs had not been used to collect the DG start data, he pointed out that it l
was wrong to state that the condition of his logs caused errors in the information initially provided to the NRC.
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i Mr. Frederick was made aware by Mr. Mosbaugh on June 12, 1990 that, to identify the root cause of the error in the April 19, 1990 LER (i.e., personnel errors), the audit scope would need to include an assessment of the performance of the Unit Superintendent and the VEGP General Manager, the individuals that developed the initial count.
- Yet, the audit report did not include either of these individuals in the list of
/
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j f persons contacted during the audit. On June 29, 1990, Mr. Frederick was again made aware by Mr. Mosbaugh that the root cause for the difference was personnel error.
l Mr. Greene was apprised of concerns regarding the June 29, 1990 letter by Mr. Mosbaugh (an individual who had been involved in preparing the April 19, 1990 LER and had been involved in developing an accurate DG start count).
Mr. Mosbaugh identified to him the failure of the June 29, 1990 draft cover letter to address the inaccuracies in the April 9, 1990 letter that it referenced and Mr. Mosbaugh pointed out the erroneous causes stated for the I
reasons for the difference in the June 29, 1990 OG start counts.
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I FOR THE NUCLEAR REGULATORY COMMISSION l
1 4
i James L. Milhoan l
Deputy Executive Director 1
for Nuclear Reactor Regulation, j
Regional Operations, and Research l
i Dated at Rockville, Maryland i
this day of (Month) 19(M)
)
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i EDECISION INFORMA ION -
R. ASE 'ITilO AP OV OF E DIRECaWIRR l
s l
i VOGTLE
SUMMARY
1 eE!i nai iiI:
- STAFF AND OI CONCLUSIONS ti S t
-m%
> ENFORCEMENT PROPOSAL i
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e i:
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.y March 1,1994
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Page 1
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- PREDECISIONAL INFORMATION -
i NOT IOR RELEASE WITIIOUT APPROVAL OF TIIE DIRECTOR, NRR COORDINATING GROUP AND OI CONCLUSIONS l
COORDINATING GROUP 4
EVENT CONCLUSIONS OI CONCLUSIONS April 9,1990 Acted with deliberate intent:
l Restart Briefing Bockhold j
i April 9,1990 CAL Acted with deliberate intent:
Response Letter Bockhold i
(DG Performance)
April 9,1990 CAL Acted with deliberate intent:
Response Letter Bockhold (DG Air Quality)
April 19,1990 Acted together with deliberate intent:
LER Hairston McCoy Shipman Bockhold f
Hairston acted with at least careless 7
disregard when he signed the LER f
cover letter to the NRC t
I f
Page 2 l
[
f a
1
- PREDECISIONAL INFORMATION -
NOT FOR RELEASE WIT 1 TOUT APPROVAL OF TIIE DIRECTOR, NRR COORDINATING GROUP AND OI CONCLUSIONS (Continued)
COORDINATING GROUP 4
i EVENT CONCLUSIONS OI CONCLUSIONS i
June 29,1990 Acted with at least careless di; regard:
LER Revision Hairston f
i i
Acted with at least careless disregard:
August 30,1990 Clarification Letter McCoy l
l t
Page 3 l
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- PREDECISIONAL INFORMATION -
NOT FOR REI, EASE WITilOUT APPROVAL OF TIIE DIRECTOR, NRR i
COORDINATING GROUP AND OI CONCLUSIONS (Continued)
COORDINATING GROUP l
EVENT CONCLUSIONS OI CONCLUSIONS l
April 1,1991 Insufficient evidence to support 2.206 Response wrongdoing by Mcdonald (re l
Hairston participation in conference call) l GPC Performance Closed, deceptive, adversarial attitude f
by GPC senior management, at least i
during March - August 1990 l
4 l-Page 4 1
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- - - - - - - - - - - - - - ~ ' ~ ~ - - - ^ - - ~ ~ ~ ' -
~~~
I
- PREDECISIONAL INFORMATION -
t NOT FOR RELEASE WITIIOUT APPROVAL OF THE DIRECTOR, NRR j
ENFORCEMENT PROPOSAL t
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Page 5 i
r LICENSEE MANAGEMENT STRUCTURE i,Mid-1990) 6 MCDONALD Exec VP SONOPCO/GPC HAIRSTON St VP - Nuc Ops SONOPCO/GPC McCOY VP - Vogtle Project SONOPCO/GPC t
I I
SHIPMAN BOCKHOLD GM - Plant Support Generet Meneger SONOPCO VEGP l
l l
RUSHTON FREDERICK MOS8AUGH/GREENE KITCHENS Mgr - Engr /Lic Supervisor - SAER Aset GM - Support Aset GM - Operatione i
SONOPCO VEOP VEGP VEGP f
I I
I SAILEY HORTON AUFDENKAMPE CASH Mgr - Licensing Mgr - Engr Spt Mgr - Tech Spt Unit Superintendent SONO?CO VEOP VEGP VEGP l
I STRINGFELLOW MAJORS L6c Enge Lie Engr SONOPCO SONOPCO 7
1 I
CURRENT POSITIONS OF KEY INDIVIDUALS i
l Southern Nuclear Operating Company l
l l
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HAIRSTON **
President and CEO m
LONG WOODARD Vice President Executive r
Technical Services Vice President m
i t
BOCKHOLD **
MOREY McCOY **
BECKHAM General Manager Vice President Vice President Vice President Nuc Tech Sycs Farley Project Vogtle Project Hatch Project l
l SHIPMAN **
i General Manager Nuclear Support I
i i
- Persons identified in O1 and Staff reports.
.