ML20083C978

Applicant Exhibit A-19A,consisting of 940511 Internal Memo Re Recent NOV & Proposed Imposition of $200,000

ML20083C978
Person / Time
Site:	Vogtle
Issue date:	04/20/1995
From:	Hairston W GEORGIA POWER CO.
To:
References
OLA-3-A-019A, OLA-3-A-19A, NUDOCS 9505230191
Download: ML20083C978 (8)

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u m a,co.<anoas May 11,~ 1994 0FflCE OF $ECRETARY 00CKE TING A SERVICE

. BRANCH TO ALL GEORGIA POWER EMPLOYEES By now each of you have been made aware of the recent Notice of Violation and proposed imposition of a S200,000 civil penalty against Georgia Power Company.

The Company is still evaluating this document, both its factual conclusions and the legal options, and will prepare an appropriate response. The purpose of this letter, though, is to assure all of our employees that Georgia Power Company remains firmly committed to a full, open, complete and accurate communications policy with the Nuclear Regulatory Commission, any of the Company's regulatory authorities, and with each other. Regardless of the outcome of the Notice of Violation, all of us should consider it our personal responsibility that when called upon to communicate with the Nuclear Regulatory Commission or its staff, whether orally or in writing, we will do our best to ensure that the information provided is complete and accurate in all material respects. This is our obligation by law, this is our obligation by the terms of our licenses, but more importantly, it is the right thing to do.

We should all remember, and take seriously, that the policy of Georgia Power Company is to conduct its business affairs in an honest, ethical manner and to -

comply with all laws and regulations affecting the Company. Important to our success as a company is our success at compliance with our legal obligations.

If you have a concem which you wish to raise, then you are encouraged to do so.

Georgia Power Company's policy is to encourage its employees, and employees of.

its contractors, to communicate their concems to their supervisors, which they are free to do at any time. If an employee concem cannot be resolved through this traditional channel, or if the employee wishes to pursue the matters through the concems program, then use of that program is encouraged. In short, the Company wants you to feel free to raise any concem which you may have and has provided 9505230191 950420 PDR ADOCK 05000424 O PDR

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A'! Georgia Power Employees i May 11,1994 mu!tiple ways for you to do so. You will'e treated with respect, you will be '  :

treated with courtesy, and a fair and reasonable response will be provided  :

i promptly and completely. Of course, you may always go directly to the Nuclear Regulatory Commission if you wish and the way to do this, as well as the relevant phone numbers, is posted on numerous bulletin boards throughout the work areas. Rest assured that you may raise your concerns without any fear of penalty or retaliation.

Let's all work together as a team, and dedicate ourselves to safe and efficient nuclear plant operations. We all have a community ofinterest in the success of our company, we all have a community ofinterest in full, open, complete and accurate communication with ourselves and with our regulatory authorities. Let's pursue these goals to the best of our individual abilities.

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I. DISCUSSION OF POLICY OF OPEN COMMUNICATION AND THE LETTER TO ALL EMPLOYEES By now each of you have been made aware of the recent Notice of Violation and proposed imposition of a $200,000 civil penalty against Georgia Power Company. The Company is still evaluating this document, both its factual conclusions and the legal l options, and it will prepare an appropriate response. The purpose of this meeting, though,-

is to ensure you all that Georgia Power Company remains firmly cornmitted to a full,

.O ege=. ce-viete a=4 acc= rate ce-===icat>o goiicx 4th tse xecicar aes interr Commission, any of the Company's regulatory authorities, and with each other.

Regardless eithe outcome of the Notice of Violation, all of us should consider it our personal responsibility that when called upon to communicate with the Nuclear Regulatory Commission or its staff, whether orally or in writing, we will do our best to ensure that the information provided is complete and accurate in all material respects.

This is our obligation by law, this our obligation by the terms of our licenses, but more ,

importantly, it is the right thing to do. I encourage you to read the Notice of Violation and read 10 CFR 50.9 which are posted on the plant bulletin board.

We should all remember and t.de seriously, that the policy of Georgia Power Cornpany is to conduct its business affai:s in an honest, ethical manner and to comply with ail laws and regulations affecting the Company. Important to our success as a coropany is our success at compliance with our legal obligations.

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O If you have a concem which you wish to raise, then you are encourager v s so.

Georgia Power Compcay's policy is to encourage its employees, and emuyees ofits contractors, to communicate their concems to their supervisors, which they are free to do at any time. Rest assured that you may raise your concems without any fear of penalty or retaliation. If an employee concem cannot be resolved through this traditional channel, or if the employee wishes to pursue the matter through the concems program, then use of that program is encouraged. In short, the Company wants you to feel free to raise any concern which you may have and has provided multiple ways for you to do so. You will be treated with respect, you will be treated with courtesy, and a fair and reasonable response will be provided promptly and completely. Of course, you may always go directly to the Nuclear Regulatory Commission if you wish, and the way to do this, as well as the relevant phone numbers, is posted on numerous bulletin boards.

O II.

SUMMARY

OF EVENTS In March,1990 Vogtle Unit I was in a normal refueling outage with one emergency diesel generator and one offsite supply transformer tagged out of service for routine maintenance. While in this condition, a truck backed into a transmission line support for the other supply transformer for offsite power to the unit. When the remaining emergency diesel generator attempted to start, it tripped due to a false trip signal resulting in a loss of power to plant safety systems. The diesel generator was subsequently started manually to restore power until offsite power was restored.

In the investigation of the causes of this event, the issue of the reliability of the diesel generators un one of the issues which needed to be resolved prior to retuming the unit to

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• g operanon Our employees, often under the observation of NRC inspectors, conducted U extensise investgadons and testing of these diesels before the unit was restarted.

Subsequent to these investigations, a meeting was held with the NRC to discuss the event and all the correedve actions taken to prevem .ecurrence and ensure the unit was ready to return to service.

Dunng this meeting, informadon was provided regarding the ins estigation and testing of the diesel generators which included a summary of the number of succe.tsful test starts done on each of the diesels subsequent to the investigation to demonstrate reliability.

This infortnauon was gathered by plant employees and was later found by one of our employees to have been in error. His e: Tor was reported verbally to the NRC. It was several months before ad the confusion and errors were resolved.

O While we continue to believe that all employees honestly and diligently attempted to provide accurate and complete information to the NRC, and the Notice of Violation did not attnhne the error to willful conduct, clearly there are some lessons we should learn

f. orc, this expenence. He purpose of this discussion is not to debase the Notice of Violation that is still under evaluation.

III. LESSONS LEARNED in light of this event and the NRC enforcement action, I would like to reiterate two important policies that are key to our operation:

1. We must always provide complete, accurate information regarding our operation to the NRC. This open and proactive sharing of all relevant and sign!ficant infonnation

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P l <~. - - is essential -even ifit goes beyond the scope of an information request. It is ,

important to be precise, accurate and complete in information provided and to identify ihe bases and qualifications of data provided.

' 2. All employees have an obligation to raise any concerns they have to their supervisors, and to follow through to ensure the conccrns are addressed. Supenisors and 3 managers must be sensitive to concems raised, and must ensure the concern is l resolved and appropriate feedback is provided to the person who raised the concern. .

That includes any concems about the accuracy ofinformation. Even though we have particular employees and managers primarily responsible with developing and verifying letters, LERs and similar submittals to the NRC, each of us is responsible to call attention to any errors or inaccuracies in thern. We also should suggest additional j information which would assure that a complete and balanced message is being sent.  ;

Supervisors and managers, u well as co workers, have to be sensitive to concerns

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raised; they must ensure that the concem is understood and resolved; and they should provide appropriate feedback to the person who raised the concern. It is sometimes i

not enough to resolve an issue in y.om mind-you need to be sure that the issue has been resolved in the other person's mind too. Sometimes you know the reso!ution as a rnatter of common sense or past experience, but you need to share that common sense or experience with your co. workers, l I

IV. OUR OWN SELF INTEREST Following our policies will obviously provide assurance that we fulfill our legal obligations under our license. Following the policies will also serve our long-term best I

interests on a broader scale as well. We need to be aware of those self-interests ,

as we feel i

the various emotions that result from this case. Our natural, human reaction to a major proposed violation, as this one is, resulting from information which was provided to the er's * -t i-== eri r == <i 8-O s a c. - x 8 4 - 8 ca.'e18t x*8 <ir>

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- been provided, or if no concern has been raised, no problem would exist today. In other (V) words, "you can't get into trouble if you don't say nothin'."

That approach is totally at odds with our two policies. The best hopes for our industry, and the condnued success of this plant, are . itally dependent en the continued trust of the public in our actions. If we do not provide accurate and completem' formation to the NRC, we will lose that trust. If we fail to resolve concerns once raised, we will not provide complete and accurate information to the NRC. One of the most effective means  :

of building and keeping the trust of the public in us may well be in our communications with the NRC.

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