ML17311B035
| ML17311B035 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/11/1995 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Stewart W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| References | |
| EA-95-140, NUDOCS 9507170155 | |
| Download: ML17311B035 (22) | |
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NUCLEAR REGULATORY COMMISSION REGION IV 611 RYAN PLAZA ORIVE, SUITE 400 ARLINGTON,TEXAS 760114064 July 11 1995 EA 95-140 Arizona Public Service Company ATTN:
William L. Stewart Executive Vice President, Nuclear P.O.
Box 53999
- Phoenix, Arizona 85072-3999 SUBJECT'LLEGED DISCRIMINATION (DEPARTMENT OF LABOR CASE NO. 93-ERA-005)
This is in terence to a May 9, 1995 Decision and Order of Remand issued by the Secretary of Labor (SOL),
a copy of which is enclosed.
As a matter of background, on October 22,
- 1992, the U.S.
Department of Labor's Wage and Hour Division in Phoenix, Arizona received a complaint from an employee of Arizona Public Service Company's Palo Verde Nuclear Generating Station.
An amended complaint was received by the same Wage and Hour Division on October 27, 1992.
The employee alleged that eight adverse actions were taken against him between January 1990 and October 7, 1992.
These adverse actions were said to have been taken because of his having filed a previous Energy Reorganization Act (ERA) Section 210 complaint (90-ERA-6) and because he was the witness in another Section 210 case.
On April 15,
- 1993, an administrative law judge (ALJ) issued a Recommended Decision and Order that recommended the Secretary of Labor (SOL) dismiss the complaint.
On May 9,
- 1995, the SOL disagreed with the ALJ's decision and issued a Decision and Order of Remand.
The SOL's conclusion was that the complainant's claim of unlawful discrimination between the period 1990 - 1992 was timely and that the complainant has shown that the respondent's adverse actions likely were motivated by his protected activity.
The case was remanded back to the ALJ for further proceedings consistent with this decision.
The NRC is concerned that a violation of the employee protection provisions set forth in 10 CFR 50.7 may have occurred and that the actions taken against the employee may have had a chilling effect on other Arizona Public Service employees or its contractor personnel.
Accordingly, pursuant to sections
- 161c, 161o, 182 and 186 of the Atomic Energy Act of 1954, as
- amended, and the Commission's regulations in 10 CFR 2.204 and 10 CFR 50.54(f), in order for the Commission to determine whether your license should be modified, suspended or revoked, or other enforcement action taken to ensure compliance with NRC regulatory requirements, you are required to provide this office, within 30 days of the date of this letter, a response in writing and under oath or affirmation that:
9507170155 950711 PDR ADOCK 05000528 PDR
Arizona Public Service Company 1.
Provides the basis for the employment actions regarding the employee and includes a copy of any investigation reports.you have regarding the circumstances of the action; and 2.
Describes the actions, if any, taken or planned to assure that these employment actions did not have a chilling effect in discouraging other Arizona Public Service employees or its contractors from raising perceived safety concerns.
Your response should not, to the extent possible, include any personal privacy, proprietary, or safeguards information so that it can be released to the public and placed in the NRC Public Document Room.
If personal privacy information is necessary to provide an acceptable
- response, then please provide a bracketed copy of your response that identifies the personal privacy-reland information and a redacted copy of your response that deletes the personal privacy-related information.
Identify the particular portions of the response in question which, if disclosed, would create an unwarranted invasion of personal privacy, identify the individual whose privacy would be invaded in each
- instance, describe the nature of the privacy invasion, and indicate why, considering the public interest in the matter, the invasion of privacy is unwarranted.
I,f you request withholding on any other grounds, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,
provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information).
After reviewing your response, the NRC will determine whether enforcement action is necessary at this time to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice,"
a copy of this letter will be placed in the NRC Public Document Room.
The responses directed by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub.
L. No.96-511.
Sincerely, L.
, Callan, Regional Administrator Dockets:
50-528 50-529 50-530
Arizona Public Service Company Licenses:
Enclosure:
Secretary of Labor Decision and Order of Remand, dated Hay 9, 1995 CC:
Arizona Corporation Commission ATTN:
Nr. Steve Olea 1200 W. Washington Street
- Phoenix, Arizona 85007 Southern California Edison Company ATTN:
T.
E. ~bre, Esq.
P.O.
Box 800
- Rosemead, California 91770 Arizona Radiation Regulatory Agency ATTN:
Aubrey V. Godwin, Director 4814 South 40 Street
- Phoenix, Arizona 85040 Haricopa County Board of Supervisors ATTN:
Chairman 111 South Third Avenue
- Phoenix, Arizona 85003 Palo Verde Services ATTN:
Curtis Hoskins, Executive Vice President and Chief Operating Officer 2025 N. 3rd Street, Suite 220
- Phoenix, Arizona 85004 Akin, Gump, Strauss, Hauer and Feld El Paso Electric Company ATTN:
Roy P.
Lessey, Jr.,
Esq.
1333 New Hampshire Avenue, Suite 400 Washington, D.C.
20036 Arizona Public Service Company ATTN:
Angela K. Krainik, Nanager Nuclear Licensing P.O.
Box 52034
- Phoenix, Arizona 85072-2034
Arizona Public Service Company Susan P.
Nern Assistant District Director 3221.North 16th Street,
¹301
- Phoenix, Arizona 85016
Arizona Public Service Company E-Mail report to D. Sullivan (DJS)
E-Hail report to NRR Event Tracking System
( IPAS) bcc to DHB (IE01)
ORS,
- ORP, and Decommissioning bcc distrib.
by RIV:
L. J. Callan Branch Chief (DRP/F)
HIS System RIV File Project Engineer (DRP/F)
Branch Chief (ORP/TSS)
J.
Lieberman, OE W.
Brown J.
- Goldberg, OGC R.
Zimmerman, NRR Resident Inspector (2)
Leah Tremper (OC/LFDCB, HS:
TWFN 9E10)
R.
- Rosano, OE G.
F.
Sanborn R. Wise E.
L. Williamson, OI DOCUMENT NAME:g: geagea95140. dft To receive copy of document, indicate in bo: "C" ~ Copy without enclosures E" ~ Cop
'th enclosures N" "-No copy ES WBJones 07/
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ICIAL R CORD COPY 07/
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U.S. DEPARTMENT OF LABOR SECRETARY OF LASOR WASHINGTON. D.C.
DATE:
May 9, 1995 CASE NO. 93-ERA-5 IN THE MATTER OF WILLIAMDAVID SIMMONS, COMPLAINANT, vo ARIZONA PUBLIC SERVICE CO./
ARIZONA NQCLEAR POWER PROJECT, RESPONDENT.
BEFORE:
THE SECRETARY OF LABOR DECISION AND ORDER OF REMAND Before me for review is the Recommended Decision and Order (R.D.
and 0.)
issued on April 15,
- 1993, by the Administrative Law Judge (ALJ) in this case arising under the employee protection provision of the Energy Reorganization Act of 1974 (ERA),
42 U.S.C.
$ 5851 (1988). -'he ALJ has recommended that the complaint of unlawful discrimination should be dismissed.
I disagree.
Accordingly, the ALJ's decision is rejected.
The amendments to the ERA contained in the National Energy Policy Act of 1992, Pub.
L. No. 102-486, 106 Stat.
2776 (Oct.
24, 1992),
do not apply to this case in which the complaint was filed prior to the effective date of that Act.
For purposes of this case, I will continue to refer to the provision as codified in 1988.
FACTUAL B CKGROUN Complainant William David Simmons began work for Respondent Arizona Public Service Company (APS) at its Palo Verde Nuclear Generating Station in 1982 and by 1986 had advanced to the position of lead radiation (rad) waste operator which entails first line supervision.
Simmons essentially functioned as a
foreman who monitored and performed alignments on the equipment in the power plant.
APS requires its operators to be "respirator fit" which means that they must remain clean-shaven in order to achieve a proper facial seal.
In 1986 Simmons sustained a
degloving injury in a severe motor vehicle accident, that is to say that he was thrown into the windshield and the fleshy tissue of his face was separated from his head.
He also suffered multiple facial lacerations.
As a result, glass and other objects are embedded in his facial tissue.
His doctors advised him not to shave, and he did not do so following the accident.
Upon returning to work after the accident, Simmons was informed that he would be discharged under APS's fitness for duty policy.
"Emergency response" comprised five percent of his duties as a rad waste lead which he could not perform because of his inability to use APS's self-contained breathing apparatus In 1992,
- however, Ron Flood, APS's plant manager, approached Simmons about being respirator fit tested, a procedure which would require him to shave his beard.
This offer was made in an effort to conciliate claims filed by Simmons with the Office of Federal Contract Compliance Programs.
Simmons at first objected, but later reconsidered.
He shaved, reported to the APS plant, and passed the fit test.
His face became painful and irritated, he developed ulcerations, and upon reporting for work immediately after the test, he suffered a heart attack.
(SCBA) type of respirator.
Although APS ultimately reconsidered its discharge decision, it denied Simmons access to the "protected area" of the plant because he was not SCBA qualified and between January and the fall of 1987 assigned him clerical duties.
In late 1987 APS granted Simmons an exception permitting him access to the protected area and assigned him the job of work control evaluator.
As an evaluator Simmons processed maintenance work requests.
While he was compensated at a level commensurate to that of a rad waste lead, he was ineligible for the compulsory overtime that is incorporated into the scheduling for that position.
In 1988 Simmons learned that more than half the members of the rad waste staff were not required to maintain respiratory qualifications either they never had qualified or their qualifications had lapsed.
As a result, they were not qualified to use the SCBAs, yet their employment was not restricted.
Simmons complained to APS management, but was ignored.
In August 1988 he contacted the Nuclear Regulatory Commission (NRC).
Simmons'ontact resulted in an investigation, and the NRC ultimately disclosed to APS that Simmons had been the complainant.
In October 1989 APS discharged Simmons who thereafter filed a complaint of unlawful discrimination under ERA section 210.
In December 1989 Simmons was reinstated as the result of settlements reached in the section 210 action and in Office of Federal Contract Compliance Programs (OFCCP) proceedings.
Although Simmons had understood that he would be
reinstated to his former rad waste lead position,
-" APS instead assigned him to work control.
Thereafter, Simmons was warned by a co-worker to "be very careful because
[Gene]
Eimar was out to get [him]. "
Hearing Transcript (T. ) 356.
- Eimar, APS '
Unit II shift supervisor, was supervising Simmons at the time.
In July or August 1990 Simmons was transferred from work
- control, an air-conditioned area, to the demineralizer
("demin")
area in the turbine building and was assigned to operate the secondary chemistry system.
The demin area is not air-conditioned and proved uncomfortable in the Arizona heat.
From August 1990 until April 1991 Simmons was the only employee assigned to the turbine building work station for the entire workday.
All others worked out of the control room in the control building, monitoring the equipment on their rounds.
Simmons was not permitted to work overtime while assigned to the demin area.
OFCCP had determined that APS could accommodate Simmons in the rad waste lead position by assigning him duties that would not require him to use a SCBA.
Another co-worker, Sarah Thomas, testified that following Simmons'einstatement Eimar told her and APS employee Linda Mitchell that he planned to "get rid of Simmons,"
"document and fire" him, T. 240,
- 248, and that the documented reason for discharge would be "performance problems."
T. 253.
Co-worker Charlie Allen testified that in early 1990 Eimar stated.that Simmons "was a troublemaker out to make something out of nothing on the company's part."
T. 293.
As a demin operator Simmons worked eight hours a day, five days a week.
In contrast, rad waste or auxiliary operators alternated between 12-hour shifts, a day shift from 6:30 a.m. to 6:30 p.m.
and a night shift from 6:30 p.m. to 6:30 a.m.
This (continued...)
In August 1990 the qualification (qual) card issued to Simmons in July was put on hold.
While all other operators were encouraged to qualify for work in all eight areas of the plant, Simmons was denied the opportunity to obtain signatures toward qualification until January 1992.
The applicable APS posting read:
"On day shift, Dave Simmons should be operating demins while the on-shift person works on quals."
Exh. C-12.
In late 1990 APS declined to promote Simmons to the position of Water Process System Supervisor.
Simmons believed that his isolated assignment to the demin area had hurt his chances of being promoted to the supervisory position.
T. 360-361.
In November or December 1991 Simmons requested to be transferred out of the demin area.
In January 1992 APS restored him to an "on-shift" auxiliary operator position. -'t this
- point, Simmons was qualified to work only in areas seven (work control) and eight (demin/turbine building) of the plant.
His
-"(...continued) scheduling was referred to as working "on-shift."
Toward the end of Simmons'our in the demin area, APS scheduled him for a four day/12 hour rotation, concomitantly assigning two other permanent demin operators to the area.
Exhibit (Exh.) R-52.
Jamie Mintz, an APS senior instructor for training, testified that the selection process was irregular, that Simmons exceeded qualifications for the position, and that the position was awarded to a less experienced employee who previously had erred procedurally causing tanks to become chemically contaminated.
T. 189-193, 198-200, 211-215.
Under an October 1987 reorganization, APS's rad waste department had been placed in the operations group and rad waste operators had been redesignated auxiliary operators.
Auxiliary operators are one step below reactor operators on the career ladder.
duties as an operator required him to qualify in the remaining six plant areas.
All of Simmons'eers had been granted a waiver from new, more onerous qual card requirements applicable to operators hired after August 1, 1990.
APS training coordinator Danny Ensign insisted, however, that Simmons not only comply with these new requirements, but that he do so within an abbreviated time period. -'immons complained that Ensign harassed him about qualifying and badgered him and his supervisors about his progress.
T. 377-380, 384; Exh. R-58.
Xn October 1992 APS issued a revised Occupational Safety and Health Manual which required the presence of two operators when transferring hazardous chemicals, one of whom would act as the safety person remaining out of the area of immediate hazard and assisting in the event of an accident.
Exh. R-35 at 101.
Although Simmons had been "allowed to do those transfers for years,"
T. 435, APS restricted him from acting as the safety person.
APS lifted this restriction after Simmons filed the instant section 210 complaint.
At the time of the February 1993 hearing in the case, Simmons was permitted to qualify in all eight areas of the plant, but was restricted from standing independent watch in Whereas other operators had been accorded a period of four years in which to qualify, Simmons was required to complete his qualifications within six months of being permitted to use his qual card.
radiologically controlled areas 3, 4, and 7.
Simmons testified that this restriction inhibits career progression.
To prevail on whistleblower complaints, complainants must establish that the respondents took adverse action against them because they engaged in activity protected under the ERA.
Section 210(a) of the ERA provides:
No employer may discharge any employee or otharvise discriminate against any employee with respect to his compensation, terms, conditions, or privileges of employment because the employee (1) commenced, caused to be commenced, or is about to commence or cause to be commenced a proceeding under this chapter or the Atomic Energy Act of 1954
. or a proceeding for the administration or enforcement of any requirement imposed under this chapter or the Atomic Energy Act of 1954 (2) testified or is about to testify in any such proceeding or; (3) assisted or participated or is about to assist or participate in any manner in such a proceeding or in any other manner in such a proceeding or in any other action to carry out the purposes of this chapter or the Atomic Energy Act of 1954 42 U.S.C.
g 5851(a).
Accordingly, Simmons engaged in protected activity in late 1988 when he complained to APS management and contacted the NRC about SCBA qualifications and in late 1989 when he filed an ERA section 210 complaint after being discharged.
He now alleges that APS engaged in the adverse employment Standing watch entails signing logs detailing equipment
- checks, temperatures, and pressure readings; generally assuming responsibility for an area; and assisting in the event of an emergency.
Simmons testified that when he came back "on-shift" he was told that he would be permitted to qualify in all eight areas but would not be permitted to run the equipment.
Then he encountered some "back and forth
. [r]estrictions added, restrictions lifted."
T. 373.
- Finally, APS decided that the only restriction would involve standing watch.
restrictions and assignments described above because of this protected activity.
Under the
- ERA, a complainant must file a discrimination complaint "within 30 days after such violation occurs 42 U.S.C.
5 5851(b)(1).
Since Simmons waited until October 1992 to file his section 210 complaint, all of APS's actions fall outside the limitations period, with the exception of the October 1992 duties restrictions.
The ALJ found Simmons'omplaint to be untimely with respect to the earlier actions.
I disagree.
In discussing the concept of a "continuing violation" in OFCCP v.
CSX Transportation, Inc.,
Case No. 88-0FC-24, Sec.
Remand Dec.,
Oct.
13, 1994, slip op. at 21-26, I cited the decision of Judge Larson in Elliott v. Sperry Rand Corp.,
79 F.R.D.
580 (D. Minn. 1978).
Judge Larson noted the difficulty in determining when a violation occurred in instances where employment practices cannot logically be viewed as discrete "incidents" occurring at a particular point in time and identified four situations where violations typically are considered continuing.
The second of these situations, which is applicable to this case, involves an employee who challenges a
series of allegedly discriminatory events only one of which occurred within the limitations period.
"An employee, for
- example, may be repeatedly denied a benefit; so long as the most recent denial occurred within the appropriate time period, no
'continuing violation'uestion really arises, for the recent event fully supports jurisdiction." Id.,
79 F.R.D. at 585-586.
See Gillilan v. Tennessee Valley Authority, Case Nos.
92-ERA-46, 92-ERA-50, Sec.
Dec., Apr. 20, 1995, slip op. at 4-5; Garn v.
Benchmark Technologies, Case No. 85-ERA-21, Sec.
Remand Dec.,
Sept.
25, 1990, slip op. at 6 (complaint is timely under continuing violation theory "where there is an allegation of a course of related discriminatory conduct and the charge is filed within thirty days of the last discriminatory act").
The adverse actions at issue here are not so much isolated employment decisions as they are recurring restrictions imposed on complainant's terms of employment which adversely affected his ability to advance.
In the words of one co-worker, the APS managers continuously "were setting up impediments, stumbling blocks [for Simmons) that other people just didn't face."
T.
196 (Training instructor Jamie Mintz).
This conduct,
- then, essentially created a pattern of discrimination.
Because APS s "actions" represented a "constant ongoing type process," id.,
including a duty restriction which occurred within the limitations period, I find that the entire complaint is timely.
I note that even if all but the last claim were held untimely and not actionable, evidence of all APS's actions properly could "be considered to 'shed light on the true character of the matters occurring within the limitations period. '"
Yellov Freight System, Inc. v. Reich, 27 F.3d 1133, 1141 (6th Cir. 1994).
See Malhotra v. Cotter 6 Co.,
885 F.2d
- 1305, 1310 (7th Cir.
1989)
("Evidence of past practices may illuminate
. present patterns of behavior.").
Accordingly,
10 Aps's earlier actions properly would bear on the issue of its later motivation.
With regard to APS's October 1992 restrictions on Simmons'uties, the ALJ found that Simmons failed to establish a prima facie case of unlawful discrimination.
R. D. and O. at 6-7.
I disagree.
A complainant initially must show that it was likely that an employer's adverse action was motivated by a protected activity (prima facie case)
Evaded v. Conunonwealth of Virginia, Case No.
89-SDW-1, Sec.
Remand Ord., APr. 20, 1995, sliP os at 11-14; Carroll v. Bech tel Power Corporation, Case. No.
9 1-ERA-4 6, Sec.
Dec.,
Feb.
15, 1995, slip op. at 8-10.
Zn particular, a
complainant must show that he engaged in protected activity, that he was subjected to adverse action, and that the respondent knew about the protected activity when it took the adverse action.
A complainant also must present evidence sufficient to raise the inference that the protected activity was the likely reason for the adverse action.
Causation may be established by showing that the respondent was aware of the protected activity and that adverse action followed closely thereafter.
Couty v. Dole, 886 F.2d 147, 148 (8th Cir. 1989).
As discussed
- above, Simmons engaged in protected activity in 1988 and 1989 and thereafter continuously was subjected to adverse job restrictions and assignments.
Numerous co-workers testified about management's hostility toward Simmons following his 1989 reinstatement, particularly on the part of Roger
Middleton, APS's operations supervisor, and Danny Ensign, the training coordinator who was responsible for scheduling overtime.
Training instructor Mintz testified that management consistently made derogatory comments about Simmons beginning in January 1990 and that Middleton made it very obvious that he was not "well intended" toward Simmons.
T. 218.
"It was along the general lines of [Simmons] is gonna mess up one of these days and I'm gonna get him."
T. 221.
Mintz believed that hostility was directed against Simmons "because
[he] went to not just the
- NRC, but the Department of Labor and
. generally had brought up concerns."
T. 228.
Mintz testified that "Roger Middleton was so angry during the process that he did not keep it a secret."
Id.
According to APS coordinator Ray King, Middleton was directly responsible for the August 1990 decision to put Simmons'ual card on hold.
T. 277.
See Exh. C-12.
Auxiliary operator Charlie Allen testified that in discussing Simmons'erit review, Middleton referred to Simmons as "his problem child [a]nd the voice it was done in such a
manner that uppity managerial attitude that was commonly held about Mr. Simmons."
T. 293-294.
He also testified:
[I]t's a well-known common fact at unit two, among operators at least, that
[Simmons]
has been subjected to a number of less than even-handed practices.
It' based on who's promoted and who's not. It's based on the general understanding that we have at Palo Verde that if you forgive my language, piss the wrong guy off you'e going to pay for it for years to come.
That's a well known fact.
T. 297-298.
Testimony by APS valve test technician Sarah Thomas
12 is consistent, T. 239-257, as is that by APS coordinator King.
T. 285-289.
Upon consideration of the evidence, I find that Simmons has shown that APS's ongoing adverse action following his 1989 reinstatement likely was motivated by his protected activity and thus has made a prima facie case of unlawful discrimination.
Because the ALJ summarily dismissed Simmons'omplaint at the conclusion of his case-in-chief, Respondent has not been accorded an opportunity to defend.
Accordingly, the case must be remanded to the ALJ for further proceedings.
In order to rebut Simmons'rima facie case, APS must produce evidence that its adverse action was motivated by a legitimate, nondiscriminatory reason.
Simmons then must prove that the proffered reason is pretextual and that the true reason for the adverse action was his protected activity.
In the event that Simmons demonstrates that APS took adverse action, in part, because he engaged in protected activity, the burden shifts to APS under a dual motive analysis to demonstrate that it would have taken action even if Simmons had not engaged in protected activity.
Simmons'omplaint of unlawful discrimination encompassing the period 1990-1992 is timely, and Simmons has shown that Thomas testified that she "knowfs]'or a fact" that there is a general threat of discharge and getting even with employees who file section 210 complaints.
After she prevailed in her own whistleblower case in 1989, "there has been continued retaliation and there have been NRC documentation to the fact that there has been continued retaliation."
T. 249.
I
13 Respondent's adverse action likely was motivated by his protected activity.
The case IS REMANDED to the ALZ for further proceedings consistent with this decision.
SO ORDERED.
Washington, D.C.
Secretary of Labor
Case Name:
Case No.
Document CERTIFICATE OF SERVICE hrilliam David Simmons v. Arizona Public Service Co./Arizona Nuclear Power Project 93-ERA-5 Decision and Order of Remand A copy of the above-referenced document was sent to the following persons on C RT FIED MAIL William D.
Simmons 6324 Beverly Lane
- Glendale, AZ 85306 Rebecca Winterscheidt, Esq.
Charles P. Keller, Esq.
Snell
& Wilmer One Arizona Center
- Phoenix, AZ 85004-0001 HAND DELIVERED Associate Solicitor for Fair Labor Standards U.S.
Department of Labor Room N-2716 200 Constitution Avenue, N.W.
Washington, DC 20210 REGULAR MAIL APS/Palo Verde Nuclear Generating Station P.O.
Box 52034
- Phoenix, AZ 85072 Maria Echaveste Administrator Wage and Hour Division/ESA U.S.
Department of Labor 200 Constitution Avenue, N.W.
Washington, DC 20210
Regional Solicitor U.S.
Department of Labor 71 Stevenson Street 10th Floor San Francisco, CA 94119-3495 Assistant District Director U.S.
Department of Labor Wage and Hour Division 3221 North 16th Street Suite 301
- Phoenix, AZ 85016 Director Office of Enforcement Nuclear Regulatory Commission Washington, DC 20555 Deputy Assistant General Counsel for Enforcement Office of the General Counsel Nuclear Regulatory Commission Washington, DC 20555 Hon. John M. Vittone Deputy Chief Administrative Law Judge Office of Administrative Law Judges 800 K Street, N.W.
Suite 400 Washington, DC 20001-8002 Hon. Aaron Silvermann Administrative Law Judge Office of Administrative Law Judges 800 K Street, N.W.
Suite 400 Washington, DC 20001-8002