ML20102A409
| ML20102A409 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 02/04/1985 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Bright G, Carpenter J, Kelley J Atomic Safety and Licensing Board Panel |
| References | |
| CON-#185-464 82-468-01-OL, 82-468-1-OL, ALAB-527, ALAB-740, ALAB-770, OL, NUDOCS 8502080349 | |
| Download: ML20102A409 (11) | |
Text
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UNITED STATES OF AMERICA w
NUCLEAR BEGULATOBY COMMISSION k p* "nEn"""7 19051
'85 FEB -7 P1 :09
BEFORE THE ATOMIC SAFETY AND LICENSING BOABD Glenn O. Bright r 1;E : HCM Dr. James H. Carpenter MWR " .^? '
James L. Kelley, Chairman " " "
- In the Matter.of-
-CAROLINA POWER AND LIGHT CO. et al. )
(Shearon Harris Nuclear Power Plant, Unit ~ 1 ) A3LBP No. 82-h68-01
) OL Motion for Reconsideration of Order Served 1-15-85 (klo)
." Wells Eddleman now moves the Board to reconsider its Order
' served 1-15-85 admitting Contention 41-0, and notifying workers
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concerning their' ability to contact the Board privately concerning retailiation
,possible harassment or' intimidation. In view of both legal and A
practical difficulties known to be associated with cases of harassment, 4
-retailiation or intimidation, one must.go beyond a narrow inter-lpretation of that Order in order to obtain any.useful results.
l In the event that the problems to be detailed below can be resolved by clarification of that Order, such clarification is requested. .
In. order to litigate the harassment issue usefully, (1) ygg; a pattern of harassment, intimidation, retaliation, etc. must be-64a.
p - dealt with (Callaway, ALAB 7h0,18 NRC 3h3, 346,(1983)); (2) and-even to prove. discrimination" against' Chan Van Vo for protected fox s . .
- p. _
activities, circumstantial _ evidence concerning treatment of other
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1 persons._.in both similar and dissimilar situations to Van Vo's must o"
'1 Applicants and Staff were consulted by t'elephone when I came down' po) x, with the flu-and extended had no ob ection to-4 February-198 The to all due
, Board dates was before informed Feb. 4'bein of this.
g ._
d y be produced and investigated; finally (3) the desirable action by the Board to notify workers concerning their ability to bring forwand information concerning hamrassment, intimidation, retaliation, etc.
is practically inadequate where such harassment or initimidation may 5 exist, and simply does not go x far enough or allow enough time to T develop information concerning the full extent of harassment, _3 intimidation, retaliation, etc. at the Shearon Harris plant. d
's" Further, additional resources are now available to me as an intervenor
- to assist in investigation of these matters, such that the Board's }r
" limited resource" discussion (Order, pp 2-3) is less valid, t These main points are developed further below.
L1) Contribution to record (Order , pp 2-3): The Order appears to presume that I could not redirect resources to this contention --
the only other work going on right now is resnonses to summary disposition -- nor obtain additional assistance. The Order concedes f that no "particular" expertise is required to rursue such a QA con- g tention. _
The importance of the issue argues for special effort -- a -i 4
" pattern" of QA flaws (e.g. Harassment, intimidation of those 2 with safety concerns) would undermine the safety finding required 3 for an operating license. Os11away, supra, at 346. )
5 Similarly, in Byron (ALAB-770, 19 NRC 1163 (1984)) on appeal. -
from an operating license denial, the Anpeal Board agreed with the j.
licensing board that " doubt" as to "whether construction defects }
of potential safety significance have gone undetected ..." precludes j the granting of a license. Obviously, hamrassment or intimidation of
- persons bringing up safety concerns could prevent safety-significant .
uroblems from being corrected, and could and would chill the likelihood !
A that others would raise such issues. Freedom from cost and schedule j-pressure (a likely reason for harassment of those bringing up safety g
Cb-concerns, since such concerns take time and money to insnect and fix) is obviously necessary to a proper 10 CPR 50 Anpendix B quality assurance program, and without freedom from harassnent and indtimida-tion of. inspectors, the finding required by the Appeal Board in Byron
-(see above) cannot be made.
In Catawba (partial initial decision, June 2h,1984) at 159,
' it_is stated that a " pattern" of retaliation could be the basis for license denial. In this case, Duke Power QA management discrinination against welding QEC inspector " Beau" Ross fow his and his crew's strict adherence to QA procedures and exnression of safety concerns.
- Thus the broader contention, 41-G as draf ted, is more anpropriate to consideration here. a " pattern" per the Callaway desision (ALAB 740, I 18'NRC 343, 346) cannot be shown by what hannened to chan Van Vo alone.
L The " pattern of harassment" issue is critical to the safety of the p
Harris plant and . development of a sound record reauires it be investigated. As will be shown below, p"oner investigation of the 4
case of Chan Van Vo by himself requires noct of the same issues to
, be dealt with,'and much evidence assenbled that would be required for the broader contention. By forcing the single-worker _ issue to be heard first, the Order appears to make delay more likely in dealing with-the ultimate issue of a pattern of harassment, intimidation, etc. .
Chan Van Vo specifically alleged that other persons were also being discriminated against :for safety concerns at Harris.
For example, in-a 3-126-81 meno revelded in 1984 under FOIA 83-413 (p.2) (copy attached) it is stated " Finally after meeting with
- -the inspector in the NRC trailer,-which is in~ full view of the site I manager's 'and the resident engineer's offices, the alleger stated that he was sumnoned to the QA Director's office where he was instructed, L by the QA . Director not to talk to NRC unless he cleaved it first with -
unless
' him og the - NRC. inspector asked him a question. In this case the w , . , . - - . , . , .- - - . - - - , -
t a.
-4 alleger stated that he was instructed to answer in short and to the point. The alleger stcted that the QA Director informed him that unless he follows these instructions he would be in trouble."
The same FOIA file does not appear to reveal NFC followup to prevent M
such intimidation from recurring.
In addition to the above legal and factual reasons to pursue the harassment / intimidation issue as drafted in 41-G, I have also gained additional assistance since the Board order issued. Specifically I have the cooperation of the Government Accountability Project and Robert Guild (representative of GAP who also representa Chan Van Vo). -
GAP represented Chan Van Vo (and continues to) and is available to .
assist intervenors and the Board in developing a record on the I pattern of harassment issue at Shearon Harris.
Guild was councel in Catawba where a similar issue was developed through welding insuectors (Ross et a1 ), _n_ camera witnesses (Welder B et al), the foreman override issue, etc. The Board there received " pattern" evidence (though it ultimately rejected its significance in approving a license fcr the Catawba plants). GAP was involved in the investigations at Catawba. GAP's contribution elsewhere is well documented, eg. in Zimmer (order suspending construc-tion, CLI-82-33, 16 NRC 1h89 (1982) which credits GAP for wo rk in showing a QA breakdnonwn at that plant.
In conclusion, with this assitance I am able to devote most of my time and effort, and additional GAP resources, to the nattern of harassment issue -- this effort will be greater than went into any pas e contention, in terms of time devoted to it over the period avalle ble .
.- a
e
.4 1 - 4 ' '
_g.
(B) -Delay - . issue broadening.
The Catawba board has ruled that late filing" criteria are inappropriate for apnlication to a contention that is ' late' for reasons wholly beyond the intervenors control. For example, the last criterion concerns the extent it will broaden the issues or delay the proceeding. An_ issue based on new information will almost necessarily broaden the issues and it may well delay the uroceeding."
(Catawba, memorandum and Order March 5,1982). The production of Chan Van Vo's affidavit was in no way under my control -- nor have any of his other actions been. As soon as I had the information in hand, I brought it to ~ the hearings, and promptly nrepared contentions.
The delay issue here is less significant because the fuel load was delayed.by the Applicants until March,1986. However, the Board's approach will likely complicate this issue by increas!ng delay -- see
- below. In any event, the' issue has only been "beoadened" to encompass
- the critical- Callaway standard cited above. Assurance the niant is. properly built is absolutely critical to the required safety finding for-any overating license. .The innortarce of the issue to
. safety' justifies the " broadening".
However, the Board's 2-step auproach increases the likelihood Lof delay. Under it, a rushed hearing on- the question of Chan Ven Vo s
by himaself (including _some document falsification issues)fwill happen before the scheduled emergency planning hearing. A second Thearingf on the beoader issue ~ of a pattern of harassment would l presumably come later --. i.e. closer to the fuel load date, which prejudices the situation againr,t later constsntions.-
Moreover, the existence of discriminat$on against Van Vo will frequire broadsr evidence:to prove anyway (see below), and could better-be developed'on a schedule.for a hearing in' summer 1985--
, a schedule ithat;would allow a pattern of harassment contention.
b + . . _.,._. ,, _ .,
'6 v.
Under the Board's present schedule, if GAP and I prove Van Vo's
- ,ase by itself, we lose several months of discovery time, and then delay of fuel load by the time adequate further discovery can be completed (and summary disnosition motions, etc. dealt with) will be _
M a reason to deny or limit the" pattern" contention. This is axt best inefficient and at worst will effectively deny the timely-filed a
" pattern" contention which alone can affect the result of the case --
But uroof of even a "narrKow" contention concerning Chan Van Vo himself requires discovery and uroof of retailiatory notive through j circumstantial evidence of a " pattern" of harassment by CP&L (et al) at the Harris plant, or of disparate treatment of Van Vo compared to others similarly situated. In order to know if V'an Vo was discriminated against because of his safety concerns, I must be allowed to develop evidence concerning other versons with safety concerns, other employees' treatment by CP&L (a) when they had safety concerns, and (b) when they evidently did not, but wete otherwise in sinilar situations to those CKhan Van Vo was in.
What is to be proved under k1-0 as admitted is essentially violation of ennloyee protection provisions of the Energy Reorganiza-tion Act, 42 USC 5851 as imulemented by NRC regulations 10 CF4 50.7.
To do that, I must show Van Vo (1) engaged in nrotected i activity -- which includes making internal safety complaints.
Mackowiak V. University Nuclear Systems 735 F. 2d.1159,1163 2
(9th Circuit 1984 ). It is admitted Van Vo made safety complaints about pump / pipe fitup, hanger reinspection, void purchase order, etc. 51 al it is not clear if his having made safety complaints to senior [
CP&L officials (Utley, MacDuffie) is being directly denied.
d 2The Fifth Circuit disagrees and says you must unrticipate k
--a in an URC proceeding to be protected. Brown and Root V. Donovan F 2d 1225, 5th Circuit, 1984)
. . . y' In any_ event, some protected activity is shown.
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(2) That Van Vo was discriminated against. Action taken against
-him included paclacing him on probation, and later firing him.
(3).'That these actions against him (see (2) above) were taken because-o_f f protected activity.
- 3. requires proof of " retaliatory motive" (unless there is u.
" written evidence or a confession that 'we fired him for complaining' a - or-sonething to that effect -- information CP&L already claims does
.not exist). .
You can prove the retailiatory motive by circumstantial
' evidence (approved in Ellis Fischel State Cancer Hosnital V. Marshall, 629 F 2d 563, 566, 8th Circuit, 1980). There is no requirement that
'the complainant-have " personal" or " direct knowledge of retaliatory motivation" (El Therefore I'and those assiting me must be free to show motive e
circumstantial 17 by discovering " pattern" and" disparate treatment"
' evidence -- such as, how did CP&L resnond to safety complaints by others; who else may CP&L have harassed; how has CP&L treated other employees similarly situated to Van-Vo,.who did not raise safety concerns? etc.
!- This is a " dual motive" or pretext . case, that is, CP&L aays -
- Van Vo was fired for poor performance, he says it.was discrimination for his' raising safety concerns.- CP&L must prove that the same action would have._ been taken against- Van Vo even if he didn't engage in i
. protected activity - (i.'e.. raising safety concerns ) . CP&L bears the-
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risk. that " influence of legal ~ and illegal motives cannot be. separated"
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iMackowiak, 735 P. 2d at 1164.
m Sorting,a111this out:will require discovery comarable to that'
~ required' for; the original ' contention 41-0 It will have to look at.the 1 treatment of other1peophe who' raised safety concerns, and at 'others r , _ _ . . _. _ . , _. . -
who did not, and at others who may have been discriminated against --
for raising safety concerns. The Board has not allowed enough time to do this ( I would have filed discEmery last week except for being incapactitated by the flum). Therefore the appropriate relief 7 ill is to admit the original contention hl-G and anow discovery to be filed G 4
-A through 1 April 1985, with hearing if necessary scheduled in the same 3 period now held for emergency planning contentions. ]
e 5
Restriction to "the reasons particular personnel actions were L taken against a particular individual" (Order, p.h) limited to "particular incidents" only still requires proof of circumstantial 3
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evidence for the retaliat6ry motive required to prove the cottention. }
To repeat, efficiency also supports the admission of iriginal 41-G 2 I
since the Board would consider a broader harassment (pattern) contention j d
if Van Vo's allegations are substantiated (Order, p.4) and since 3_
proof of Van Vo's allegations amounts to having proof of patterns -
of treatment of persons by CP&L, those with and those without safety concerns they raised. ]
m
-5 A similar problem affects the Board's treatment of contention j 41-C, falsification of documents (Order, p.6). Treat!ng this as within }
the Van Vo allegations limits it so much as to make ik not very useful: N If it deals with only documents Van Vo himself saw, so what? The real i
i question is whether other documents were falsified. Van Vo's affidavit ~]
provides enough basis to go into that -- to see if there are other f falsified documents (e.g. nonexistent purchase obder numbers, other 5 i
3 false references) on documents Van Vo did not see himself. To linit s
the question to just what Van Vo saw or was directly involved with j destroys the usefulness of the contention in developing a sound record. 2 We know a false purchase order number was put on some hanger packages-- j a violation of lo CPR 50 Appendix B. What we need to know is the extent ,
of such violations / falsification. h1-0 should therefore be admitted. ,
-9 (C) -Notice,to workers.
It is clearly ~a good idea to seek evidence of workers having been harassed, intimidated, or retaliated against at Harris. But exnerience shows that such notice as is provided is almost certain to fail to
. bring out most (if not all) of the workers who have such comolaints.
-(i) Evidence of harassment for raising safety concerns nust remain hidden'or the harassment has not been effective. Thus by its very naturC any harassment will include covering up the fact of harassment, e.g.
by intimidation. Harassment and intimidation work -- they chill the Tdiscovery of.not just safety problems, but also of their own existence.
Practices like . locating the NRC trailer in full view of senior site management certainly do.not help this situation.
(ii) it'is the absence of harassment or initimidation that must be shown for the plant to be OK. "If the NRC's regulatory scheme is to function. effectively, inspectors must be free from the threat of retaliatory discharge for identifying safety and quality problems.*
Mackowiak, suora, at 1163 Common sense tells us that a retaliatory discharge of an employee for : _ . . _w "vhistleblowing" is likely to discourage others from coming forward with information about annarent safety discrepancies." Callaway, ALAB-527, 9 N90 126,13k (1979)
This cannot be proved just by no one eagerly coming forward with evidence of harassment, becauce as noted under (1) above, atar harassment would discourage such persons from coming forward.
(iii) there are clear practical' dimafficulties with the Board's approach of posting a' notice ~in legalistic language:
in Catawba, because of_ feared retaliation, workers with safetyiconcerns:(including-harassmen+), i.e. foreman-override, etc.)
L ,c_ 'did not. heed Board. notice and come forward, even when they knew of
.'the; notice and. knew hearings were going on. For examnle, " Welder B" only voiced concerns when directly asked by NRC (or) other investigators.
'i., - . .,
_5 In order to accomplish its evident goal of bringing out any evidence h of harassment or intinidation at Harris, therefore, the Board must adopt k muEh more aggressive measures to inform Harris workers of their rights e
and bring forward evidence of any harassment. (
?
In particular, a new notice including the Board's information d g
and the facts that (a) harassnent, discrimination, retaliation, etc. 5 E
are against the law (b) complaints about such acts against workers can g be made to the Dept of Labor, which will investigate, headlined as aporopriate, e.g. We Seek Evidence of Harassment Against People ;
Raising Safety Concerns at Shearon Harris, should be very widely 4 E
distributed, e.g. by all of the following: s (i) NRC press release (ii) direct disztribution to all workers at the Harris site under Board order j (iii) upproval for intervenors to mail the notice to i 5
workers at hone addresses orovided unddr protective order.
The Board must also allow the intervonors aporopri2te means g (including discovory under protective order) to seek the identification i
and location of nersons having information about harassment / intimidation a 5
and so on at Harris. The Board implicitly concedes such evidence from workers is relevant to the contention 141-0 but uses what nast exnerience has shown to be fatally. deficient means for obtaining it. 1 Also, the March 1 deadline should be eliminated -- it is f2
=
artibteary and canricious and fundamentally unfair to intervenors who can only be held responsible for raising timely claims based on evidence 5
-1 within the intervenors' knowledge. Further, if harassment exists and 2 that orevents workers from coming forward (as at Catawba) the intervenors j cannot be held responsible for that effect (nor can the utility or -
others 'be rewarded by a " statute of limitations" on illegal behavior). i 4
The March 1 deadline assumes 100% effectiveness of a notice (similar notice at Catawba appeared to be more like zero percent effective, and precludes proof of the clain I have raised (of a nattern of Harassment -- 41-G) unless persons who I have no constrol over will
. voluntarily come forward on their own and perhaps against intimidation.
Taus I am being prejudiced by the inaction of others under a condition
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(i.e. simple, legalistic-language notice) which is known to be not very effective -- which is arbitrarily established. In fact, there is no " statute of limitation" on violation of NRC regulations as far as I am aware.
21e March 1 deadline is thus inconsidtent with the Callaway (suora) decision requiring evidence of a pattern to affect an operating license. .
It is also against the Byron decision (stora) which requires supplementation of the Qt record with relevant new evidence (in that case, the licensee's evidence) and disapproves closing off the record arbitaravily. In view of this case law and the practical dium ' difficulties outline above in getting peoole who in fact allege they are victims of harassment or intimidation to come forward, the March 1 deadline is plainly arbitrary and capraicious, and evidence of harassment or discrimination before that date should be accepted when and as it becomes available.
CONCLUSION
/For the reasons given above, the Board should (1) admit contentions 41-0 and 41-0 as written (2) permit discovery on both until Anril 1,1985 (last day for filing reouests) (3) rescind its announced intent to ignore .
evidence of harassment pr!.or to 1 March 1985 where such harassment is not brought to the Board's attention prior to that date, and (4) take additional strong measures to inform Harris site workers of their rights to be free from harassment and intimidation and their rights to inform the Board, NRC Staff and intervenors about such har a nt lon.
Of counsel: Robert Guild h February 1985-- ells Eddleman
t
- t UNITED si All *
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e NUCLEAR REGULATORY COT,W.lSSION REGION 11
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%..*f m mAmerTA sv =w.sunr 3soo ATLANTA. GEORGIA Jo303 NAR 161981 SSINS 50-400, 50-401 50-402, 50-403 MEMORANDUM FOR:
C. Alderson, Director, Enforcement and Investigation THRU: .'l , RII
& (kVC. E. Murphy, Chief, Engineering Inspeection ,RII Branch FROM:
A. R. Herdt, Section Chief. Engineering Inspection ,RII Branch N.Branch, Economos, Reactor Ins ector, MpS, Engineering Inspectio
SUBJECT:
RI!
gW NUCLEAR PLANT (DOCKET NOS. ALLEGATIO 50-400, 50-c01 , 50-402 a sd 5C-403)
. During a routine inspection of the Shearon Harris Nuclear Plant .
February 18-20, 1981, allegations which they had made to the NRC rtwo of three certain individuals taterview description of these allegations were as follows:
esident inspector earlier. A
- 1. r Individual "A" alleged that: -- ..
a.
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Individuals without previous experience in hanger s are given inspection
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course they are given a 90-day temporary quali the hanger inspection crew. the *
- . gned te t
i these individuals and the adequacy of their workThe alleger questions t
~} b. .-
l j Certain welding inspector, candidates were given copies of .
1 examinations forwashome studp arfd then allowec proficiency take .the exami tonation un'til a passing grade attained.
- c. .
j The site reports (DDRsQA Director rewrites (sanitizes) all sposition def'iciency di for further ac) tion. by field QA personnel before approving them generated -f '
' d. The d
Supervisor problems identified bynfield QA personne many cases corrective action is taken without ger.erating NCRs or DDRs as r
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by site
- procedures. i i
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,lM e.
'4 0A personnel are demoralized because the CAsupport Cirector does not t
,p- :nein in disputes with engineering and/or management.
I";1 L.-ei h s, verr I
his PDR Rr n .spf 4 5
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WA: .' r. 1...
- 4. E. M.:eran .
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- 2. ' Individual "B" alleged that:
! a.
' ! his discipline only.The QA Director has ordered him to confine hi y to areas within pull box or a cable tray, he identifies a welding and/oTha problem and finds that the electrical aspects are accept bl
-t r a mechanical restrict his comments to the electrical aspects a e,only he is to
-) .
comments on the other problems. and make no
- ~
b.
! Repeated items 1.d and 1.e above.
i I . c.
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The QA Director has instructed him reports found to contain discrepancies. or QCnot to issue NCR inspection J
bring the corrected. problem to the attention of thearty responsible and have it pInstead h Form No. TP-09 Concrete Emcedded Electrical Equ a i nspection Form,
! Pour No.1-ACSL-305-0051/14/81 and 1-ACSL-305
' Finally after meeting with the i h'
full view of the a site manager's and the resident neer's enginspector offices, the
- in the
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.t alleger stated th' t he was instructed, by the QA Director not to talk to NRC unl summoned to the QA Director's offi :
j ce where he was l
with him ole unless the NRC inspector asked him a questioness he clea alleger stated that he was instructed to answe
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L In this case the
, 3 . The alleger stated that the QA Director informr in short and to the point.
j
' these instructions he would be in ~ trouble . ed him that unless he follows-l i ;
hId l N. Economos l 4!![ -
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Contact:
N. Economos
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UNITED STATES OF AMERICA NUCLFAR REGUIATORY Co!9CSEION In the matter of CAROLIKA FOWER 4 LIGHT CO. It al. ) Docket 50-h00 Shearon Harris Nuclear Power Plant. Unit 1* 1 0.L.
CERTIFICAh' eof SERVICE Diesel Generator Contentions and Info n 2 hereby certify that copies of and of' Mntinn c= Mecos m - unn nc Order served 1-15-85 (410) , and of Discovery on 41-0 (1st set)+ b
^ -
HAVE been served this _ day of February 198,1,bydepositin the US Mail, first-class postage prepaid, upon all parties whose h or4r-)
names are listed below, except those whose nanes are parked with an asterisk, for whom service was accomplished by discovery on bi-G '
delivery by hand this date to CP&L legal dent in Raleigh NC c
- under agreement of counsel for Staff and Applicants of which the Board is awar JudEes James Kelley, Glenn Bright and Jame Cagenter (e.1 copy each)
Atomic Safety and Licensing Board US Nuclear Megulatory Commission Washington DC 20555
- George F. Trowbridge (attorney for Applicants)
Shaw, Pittman, Fotts & Trowbridge R.uthanne G. Miller 1600 M St. NW ASLB Panel Washington, DC 20o36 USNRC Washington DC 255 5 Spence W. Ferry Office of the Executive Ie 50-400/4o10.
[
L. gal Director piM
- Attn Docke ts
$ cst.S Washington DC Wa ngton DC 2o555 CN 20740 Dan Read Docketing and Service Section (3x) CEA!E/FLP Attn Dockets 50-koo/hol 0.L. .
Raleigh,F107 NC Waveross
< Office of the Secretary 276o6 ,
USNRC L
Washington DC 2o555 Dr. Linda W. Little j: (E plan only) Governor's Waste Mst. Bd.
I John Runkle 513 Albemarle B1dg.
l Steve Roch1 mis 325 N. Salisbu W St.
CCNC FEMA-Suite 70o Raleigh, NC 27611 3o7 Granville .Rd 137.1 Peachtree St.NE Chapel Hill Nc 2751h Atlanta GA 30309 Bradle7 W. Jones Robert Gruber USNRC Region II
'Travi s Fayne Exec. Director lol Marietta St.
Edelstein & Fayne Public Staff Atlanta GA 30303 Blox 12609 Box 991 Raleigh NC 276o5 maleish NC 27602 Richard Wilson, M.D. Certified by h
'729 Hunter St.
Apex NC 27502 I '