ML20054E650

Affidavit of Wc Gerstner Re Quality Rept Sys Functions. Confidentiality of Quality Repts Is Key to Effectiveness of Sys.Disclosure of Previously Submitted Repts Would Destroy Sys.Certificate of Svc Encl

ML20054E650
Person / Time
Site:	Clinton
Issue date:	06/04/1982
From:	Gerstner W ILLINOIS POWER CO.
To:
Shared Package
ML20054E649	List: ML20054E648 ML20054E650
References
ISSUANCES-OL, NUDOCS 8206140030
Download: ML20054E650 (10)

Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY C0hD!ISSION

'IN THE MATTER OF ILLINOIS )

POWER COMPANY, S0YLAND )

~ POWER COOPERATIVE, INC. and )

WESTERN ILLIN0IS POWER )

t COOPERATIVE, INC. )

) Docket No. 50-461 OL (Operating License for )

Clinton Power Station, Unit )

1) )

AFFIDAVIT e

STATE OF ILLINOIS )

) SS COUNTY OF MACON )

William C. Gerstner, being first duly sworn, upon oath deposes and says as follows:

1. I am an Executive Vice President of Illinois Power Company (" Illinois Power"), 500 South 27th Street, l Decatur, Illinois 62525.

2. My responsibilities as Executive Vice President of Illinois Power include the supervision of the construc-l tion and preparation for the future operation of the i

Clinton Power Station.

3. The management of Illinois Power believes that

.the most important factor in the construction of the 7

ClintonPowerStationistoinsurethataqualityplfnt is built. As part of Illinois Power's commitment to the EXHIBIT 1 8206140030 820600 PDR ADOCK 05000461 0 PDR

quality construction of the Clinton Power Station, I have assumed direct responsibility for Quality Assurance a,d n

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. Quality Control at the Clinton Power Station. Since; February,1982, for exampic, the Director of Quality Assurance for Illinois Power has reported to me alone.

lie has no intermediate superiors.

4. Direct communication between the Quality Control inspectors at the Clinton Power Station and Illinois Power management is a vital method by which 1

Illinois Power insures the quality construction of the Clinton Power Station. I want the Quality Control inspectors, who are the individuals most responsibic for the quality construction of the Clinton Power

Station since they perform the actual inspections, to feci free to come to me with any problems which they believe have not been adequately addressed.

5. To set up such direct communication, I met alone with Quality Control inspectors at the Clinton i

Power Station in February of this year. I told the l

Quality Control inspectors that all forms of direct l communication between themselves and me was to be in addition to,and not to supplant the other methods

,availabic for reporting problems to both management and

" to the Nuc1 car Regulatory Commission. I emphasized -

firmly to the Quality Control inspectors that they .

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feel free to report cor.cerns to the Nuc1 car Regulatory Commission through the on-site inspector or otherwise.

I gave the Quality Control inspectors both my home an,d

,officephonenumbersandtoldthemtocallatanytihe with any problem. During this meeting, we discussed a system for implementing direct written communications.

In setting up this system, their primary concern was the confidentiality of any communications. To assure confiden-tiality, a Quality Report system was developed with the following features:

a. Quality Control Report forms are

- available at various locations at the Clinton Power Station.

b. An employee fills out a Quality Report form (which he or she may sign or submit anonymously) and deposits it in one of two locked boxes which are located in the field office building and in the plant.

c. One particular Illinois Power employee unlocks the box and transmits the deposited Quality Reports to me. This employee was selected by the Quality

," Control inspectors.

d. I personally review the submitted Quality Reports, investigate the ,

concerns raised, and implement whatever

I action is called for. I am the only Illinois Power employee who sees the contents of the Quality Reports.

c. With respect to anonymously-submitted Quality Reports, where appropriate I prepare written responses to the reports which describe the actions taken and the reasons for such actions.

and have them posted at the Clinton Power Sc Ation. I respond in writing directly to the senders of signed reports.

6. Confidentiality of the Quality Reports is the key to the effectiveness of this reporting system. Any disclosure of the previously submitted Quality Reports and any required disclosure of future Quality Reports I believe would destroy this vital system. This is because the Quality Control inspectors would no longer feel secure that their comments were confidential.

7. One example of the paramount importance which the Qualicy Control inspectors place on confidenti-ality is that soon after the initiation of the Quality Reports, some Quality Control inspectors believed that there had been a leak in the system. This caused the submission of Quality Reports to cease. The submission

.of Quality Reports resumed only after my firm assurances that no leaks had occurred. _'

8. Quality Report forms are available to all employees at the Clinton Power Station. The employees arefreetoaddressanyconcerns,whetherrelatedtoI Consequently, many of ?

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quality or not, on the forms.

'the submitted Quality Reports have not dealt with the quality of the construction of the Clinton Power Station.

Instead, they have dealt with personnel matters such as compensation for overtime. Some of the reports have contained personal allegations, not dealing with quality, against other employees. While Illinois Power is concerned with and investigates all allegations in such reports, to reveal these reports, however-restricted they might be, I believe would have not only a totally chilling effect on the system but potentially a serious adverse effect on individual employees.

9. Many of the submitted Quality Reports are almost indecipherable. This is because of the frequent use of acronyms specific to nuclear construction.

10. On behalf of the management of Illinois Power, I promised the Quality Control inspectors that submitted Quality Reports would be kept in strictest confidence.

This promise was made to assure the effectiveness of this tvital system of communication. I have permitted Sheldon

'LA . Zabel, counsel for Illinois Power, to examine the, Quality Reports in preparation for the Third Special: .

Prchearing Conference held in Champaign, Illinois on-May 4, 1982. Illinois Power will take whatever steps are necessary to insure the continued confidentiality of the s

Quality Reports. This would include discontinuing the

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Quality Report system instead of compromising the integrity

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of the system through disclosure of the Quality Reports already submitted.

11. The facts stated herein are within the personal knowledge of the affiant, who, if sworn as a witness, can and would testify competently to the facts herein set forth.

, .r. -:  :

'_s ,1 y 'A h% ,[,(t ti;r William C. Gerstner Subscribed and Sworn to before me this 4th day of June , 1982.

?dui n me. 7h /dt//

v Notary Public My Commission expires:

January 16, 1983

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me e

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e CERTIFICATE OF SERVICE s

I hereby certify that an original and two -

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conformed copies of the foregoing document were served upon the following:

Secretary of the C ommission United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Docketing and Service Branch and that one copy of the foregoing document was served upon each of the following:

Hugh K. Clark, Esq., Chairman P. O. Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson School of Engineering Howard University 2300 Sixth Street, N.W.

Washington, D.C. 20059 Dr. Oscar H. Paris Atomic Safety and Licensing Board U.Ss Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 Philip L. Willman Assistant Attorney General i Environmental Control Division 188 West Randolph Street Suite 2315 Chicag,, Illinois 60610

. Jan Kodner

. Tutt and Kodner _

173 W. Madison Street ,

Suite 1004 -

Chicago, Illinois 60602 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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4 4 Atomic Safety and Licensing Appeal Boafd Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 in each case by deposit in the United States Mail, pestage

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prepaid on June 8, 1982.

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nOne of the Atto s for Applicants

! Sheldon A. Zabel i William Van Susteran l Charles D. Fox, IV SCHIFF HARDIN 5 WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000 e

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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'IN THE MATTER OF ILLIN0IS )

POWER COMPANY, S0YLAND ) l ;a' POWER COOPERATIVE, INC. )  ;, p" and WESTERN ILLINOIS )

POWER COOPERATIVE, INC. ')

) Docket No. 50-461 OL (Operating License for )

Clinton Power Station )

Unit 1)

NOTICE 1

> TO:

i Hugh K. Clark, Esq., Cha'irman P. O. Box 127A Kennedyville, Maryland 21645 Dr. George A. Ferguson School of Engineering Howard University 2300 Sixth Street, N.W.

Washington, D.C. 20059 Dr. Oscar H, Paris Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Executive Legal Director United States Nuclear Regulatory Commission Washington, D.C. 20555 Philip L. Willman Assistant Attorney General Environmental Control Division 188 West Randolph Street Suite 2315 Chicago, Illinois 60610 f

Jan Kodner Tutt and Kodner hidd)

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173 W. Madison Street Suite 1004 Chicago, Illinois 60602

Atomic Safety and Licensing Board Panel-U.S. Nuclear Regulatory Commission Washington, D.C. 20555 =_

. Atomic Safety and Licensing 4 Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 PLEASE TAKE NOTICE that I have filed with the Secretary of the United States Nuclear Regulatory Commission Applicants' SUPPLEMENT TO MOTION FOR A PROTECTIVE ORDER in the above-captioned matter. A c opy of this - document is attached hereto and hereby served upon you.

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ne of the Att eys for Applicants c;-

Sheldon A. Zabel William Van Susteran Charles D. Fox IV SCHIFF HARDIN 6 WAITE 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 (312) 876-1000 Dated: June 8, 1982

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