ML20129H522

Notice of Issuance of Directors Decision 96-16 Under 10CFR2.206 Re Aj Ross 950102 Petition

ML20129H522
Person / Time
Site:	Millstone
Issue date:	10/31/1996
From:	Thadani A NRC (Affiliation Not Assigned)
To:
Shared Package
ML20129H460	List: ML20129H457 ML20129H522
References
2.206, DD-96-16, NUDOCS 9611050272
Download: ML20129H522 (4)

Text

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4 7590-01 UNITED STATES NUCLEAR REGULATORY COMMISSION NORTHEAST UTILITIES MILLSTONE NUCLEAR POWER STATION. UNIT 1 DOCKET NO. 50-245 ISSUANCE OF DIRECTOR'S DECISION UNDER 10 CFR 2.206 Notice is hereby given that the Acting Director, Office of Nuclear Reactor Regulation, has taken action with regard to a Petition dated January 2, 1995, by Mr. Anthony J. Ross (Petition for action under 10 CFR 2.206). The Petition pertains to Millstone Nuclear Power Station, Unit 1.

In the Petition, the Petitioner asserted that (1) the Petitioner was

" unjustly chastised" by his first-line supervisor and department manager about absenteeism, and his department manager threatened him in a memorandum; (2) his first-line supervisor willfully falsified nuclear documents in that he signed-off on a surveillance of the gas turbine battery as having met acceptance criteria when the requirements had not been mo ; and (3) the Millstone Unit 1 organization failed to enter into a 2-Jay Limiting Condition for Operation as required by the Technical Specific; Lions when the Operations Department was notified of the failed surveillance, in violation of 10 CFR 50.5.

In addition, the Petitioner asserted that a number of violations have occurred in 1992 and 1993 related to the gas turbine battery, which have not I

been handled appropriately by the NRC and Northeast Utilities, and that the utility and NRC are engaged in an apparent " cover-up" of the problems.

9611050272 961031 PDR ADOCK 05000245 O

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• The Petitioner requested that the Nuclear Regulatory Commission (1) assess a Severity Level II violation and a Severity Level III violation against his department manager and his first-line supervisor for their apparent violations of 10 CFR 50.7; (2) institute sanctions against his l

first-line supervisor, Northeast Utilities, and the Millstone Unit 1 organization for engaging in deliberate misconduct in violation of 10 CFR 50.5; and (3) remove his first-line supervisor from his position until a

" satisfactory solution to the falsifying of nuclear documents" by this l

i individual can be achieved.

l The Acting Director of the Office of Nuclear Reactor Regulation has 1

determined to deny the Petition. The reasons for this denial are explained in the " Director's Decision Under 10 CFR 2.206" (DD-96 16

), the complete text of which follows this notice and is available for public inspection at the Commission's Public Document Room, the Gelman Building, 2120 L Street, NW.,

Washington, DC, and at the local public document room located at the Learning Resources Center, Three Rivers Community-Technical College, 574 New London Turnpike, Norwich, Connecticut, and at the temporary local public document room located at the Waterford Library, ATTN: Vince Juliano, 49 Rope Ferry Road, Waterford, Connecticut.

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_3 A copy of the Decision will be filed with the Secretary of the Commission for the Commission's review in accordance with 10 CFR 2.206(c) of the Commission's regulations. As provided by this regulation, the Decision i

will constitute the final action of the Commission 25 days after the date of issuance unless the Consission, on its own motion, institutes a review of the Decision in that time.

Dated at Rockville, Maryland, this 31st day of October 1996.

FOR THE NUCLEAR REGULATORY COMMISSION h

Asho C. Thadani, Acting Director Office of Nuclear Reactor Regulation

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l EDO Principal Correspondence Control FROM:

DUE: 02/09/95 EDO CONTROL: $00d016 l

DOC DT: 01/02/95 l

FINAL REPLY:

Anthony J. Ross Watsrford, Connecticut TO:

James Taylor j

FOR SIGNATURE OF :

• • GRN CRC NO:

DESC:

ROUTING:

?.206 PETITION REGARDING MILLSTONE (GAS TURBINE Taylor iTTERY)

Milhoan l

Thompson l

Blaha Lieberman, OE l

Russell, NRR DATE: 01/09/95 TTMartin, RI ASSIGNED TO:

CONTACT:

OGC Cyr s

w SPECIAL INSTRUCTIONS OR REMARKS:

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9500082 4

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l Anthony J. Ross January 2,1995 16 Fulmore Drive File: TR-5-002 Waterford, Connecticut 06385 Cenified U.S. Mail # P 878 476 736 Mr. James Taylor Executive Director for Operations United States Nuclear Regulatory Commission Washington, D.C. 20555-0001 SUBJECT l

10 CFR 2.206 Petition Requesting Nuclear Regulatory Commission Action for Escalated Enforcement Per 10 CFR 2 App. C.. Implementation of 10 CFR 50.5 Deliberate Misconduct Rule, and Implementation of 10 CFR 50.7 Employee Protection Rule.

Dear Mr. Taylor,

In accordance with the above captioned references, I Anthony J. Ross, employed by Nonheast Utilities as a Station Electrician "A", in the Unit 1 Maintenance Depanment, l

at Millstone Nuclear Power Station located in Waterford, Connecticut request escalated enforcement action as outlined in 10 CFR 2 APP. C.

As a protected employee I un funher requesting that specific actions be l

unplemented against the individual outlined below under the provisions of 10 CFR 50.5 l

Deliberate Misconduct Rule, and 10 CFR 50.7 Employee Protection Rule.

BACKGROUND INFORMATION l

On 9/20/94, I was given the task of performing the annual Emergency Gas Turbine I

Battery Surveillance, by my first line supervisor. The Emergency Gas Turbine is a QA i

CAT 1 safety related system, designed and required to auto / stan under emergency conditions.

ALLEGED VIOLATIONS

1. Inadequate compliance with the provisions of 10 CFR 50.5 Deliberate Misconduct Rule, and 10 CFR 50.7 Employee Protection Rule.

On the day in question the Gas Turbine Battery failed the surveillance, because the resistance readmgs on some of the intercell bolted connections were greater than 65 micro ohms. The acceptance criteria per the procedure (SP 779.5), is less than or equal to 65 micro ohms. Additionally, per step 6.20 of SP 779.5, I notified the operations department, Shift Supervisor of the failed surveillance, and indicated the failed surveillance, by l

initiahng the appropriate block on the surveillance cover sheet (MF 779.5-1). At that point, I notified my first line supervisor of the failed surveillance, and funher indicated to him that I couldn't perform step 6.22 of the procedure, because we don't have access to the records to perform this step, which is to compare the readings with previous battery j

surveillance readings to determine if there is any deterioration of the battery system. At that point my first line supervisor told me that he would compare the readings for me. (we i

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now have copies of the previous battery readings to compare the readings per the procedure)

Furthermore, my first line supervisor signed the surveillance off as yes, referring to the " Acceptance Criteria Met" when clearly the requirements were not met per SP 779.5

& MF 779.5-1.

l I informed Mr. Paul Swetland of your agency, of this very serious nuclear safety concern in detail. I have also provided Mr. Thomas Martin of the NRC with this concern in writing on October 5,1994, including the applicable enclosures.

l Most importantly, Tm sure you are well aware that willfully falsifying nuclear I

documents is an extremely serious violation.

Clearly my first line supervisor is in violation of 10 CFR 50.5 for willfully falsifying nuclear documents as indicated above.

Additionally, my first line supervisor and my department manager are in violation of 10 CFR 50.7 for their escalated program of harassment, intimidation, and retaliation l

that's directed towards me since bringing the concerns contained in this 10 CFR 2.206 petition to light in September 1994. It's very important for the NRC to realize, I first l

l raised this allegation verbally in September 1994 to Mr. Paul Swetland ofyour agency, l

and to Mr. Thomas Martin in writing on October 5,1994. The chain of events are listed l

below; l

On October 7,1994 I was given a memorandum entitled absenteeism, dated October 6,1994 (copy enclosed) by my first line supervisor and my department j

manager.

l On October 23,1994, I provided my first line supervisor my detailed rebuttal to his above mentioned memorandum. (copy enclosed)

On October 27,1994, I had been unjustly chastised by my first line supervisor and my department manger about absenteeism (sick and personal time) in a meeting in my department manager's office. I truly believe, this action by my supervision is another example on how NU management harasses, intimidates, and retaliates, against those ofus who raise safety concerns with outside agencies. (this concern was provided to Mr. Thomas Martin in a letter to him dated November 3,1994)

In a letter to my department manager dated November 22,1994, I provided a detailed response to my management about the mendacious statements made by my management in their October 27,1994 meeting. (copy enclosed) l l

l In a memorandum from my department manger dated December 14,1994, (copy l

enclosed). Clearly indicated in the memo, my department manger has resorted to i

threatening me.

Clearly stated again my first line' supervisor and my department manager are in 4

severe violation of 10 CFR 50.7 for their escalated program of harassment, intimidation, i

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and retaliation that's directed towards me since bringing the concerns to light in September l

1994 as stated above.

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2. Inadequate compliance with the provisions of 10 CFR 50.5 Deliberate Misconduct Rule.

i Clearly as outlined above, when the operations department was noti 6ed of the l.

failed surveillance by me, the Unit 1 organization should have entered into a four day LCO as required by the technical specifications, section 4.9.B.I.a.

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Quite clearly when a LCO wasn't entered by the Unit 1 organization the main i

concern was not public safety but to keep the unit on the line to produce revenues.

i Accordingly, the Unit 1 organization is directly responsible for willfully violating i

the provisions of 10 CFR 50.5 as outlined above.

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3. Inadequate procedure compliance.

About a week after the alleged incident I received copies of the 1992 & 1993 l

annual Emergency Gas Turbine Battery Surveillance's, from Mr. Paul Swetland of the

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NRC. After I reviewed the 1992 & 1993 annual Emergency Gas Turbine Battery l

Surveillance's I had reahzed there were a number of problems with them. In my October 5, 1994, letter to Mr. Thomas Martin of the NRC, I provided the 1992 & 1993 annual Emergency Gas Turbine Battery Surveillance's, with highlighted sections of the procedure j

violations. Listed below are the 1992 violations; j

a) The surveillance failed, the Unit 1 organization should have enter into a four day LCO as required by the technical specifications, section 4.9.B.I.a., clearly the surveillance was completed on 9/25/92 and the operabilityjustification letter wasn't done j

until 9/28/92, some three days later, yet an LCO wasn't entered into.

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b) This surveillance was in nuclear records and the department head never i

signed for the approval as required by MF 779.5-1.

c) The schedule date wasn't indicated on MF 779.5-1.

Listed below are the 1993 violations; a) The surveillance failed, the Unit 1 organization should have enter into a 3

i four day LCO as required by the technical specifications, section 4.9.B.I.a.

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b) The prerequisites and the precautions on MF 779.5-1 were not initialed per step 6.1 of the procedure (SP 779.5) indicating the procedure wasn't followed or in j

my opinion even read.

c) Clearly indicated on MF 779.5-1 is the fact that the surveillance failed the acceptance criteria, yet SS in operations department wasn't notified and the applicable block on MF 779.5-1 wasn't signed off. Clearly a violation of step 6.20 of the procedure (SP 779.5) indicating the procedure wasn't followed or in my op'mion even read.

d) As indicated on the " Technical Evaluation", dated September 24,1993, the Engineer committed to change the procedure (SP 779.5) & the data sheet (MF 779.5-

1) and to this date the procedure change is still not completed.

e) This surveillance was in nuclear records and all levels of maintenance management accepted the surveillance without correcting the above problems. Clearly this 3

is an indication that maintenance management isn't concerned with following procedures butjust completing the task.

Furthermore, the procedure has not been followed since 1992 as far as I can tell.

Clearly, steps 6.17 through 6.17.14 can not be performed per the procedure. I told my first line supervisor of this problem and he agreed with me the procedure needed to be changed and he told me to continue with the procedure and he said he would get the procedure changed, and to date it isn't changed. The battery terminals are provided with

. only one hole in the terminal and if you tried to add a jumper you would inop the battery without the proper work control and tagging control. Additionally, the emergency gas turbine would be inoperable without Operations knowledge.

l I'm sure the NRC reahzes the last three annual Emergency Gas Turbine Battery Surveillance's, have all failed the requirements of the procedure (SP 779.5) & the data l

sheet (MF 779.5-1). Yet, in my opinion the extremely serious violations as indicated above l

are not being handled appropertly by the NRC and Northeast Utilities. Quite clearly, It appears to me the only thing that has happened since I brought these legitimate concerns forward in September 1994 to Nonheast Utilities and the NRC is an apparent cover-up by the both ofyou.

Additionally, I truly believe the emergency gas turbine is still inoperable and the NRC Region 1, is doing little or nothing to correct the problem. I truly believe the emergency gas tuttine is still inoperable because of the battery problems that have been l

identified since 1992, and the NRC excepts th: bogus explanations and evaluations of l

Northeast Utilities.

I REOUESTED ACTION Issue a severity level 2 violation and a severity level 3 violation against my department manager and my first line supervisor for their apparent violations of the provisions of 10 CFR 50.7 as outlined above.

Institute sanctions against my first line supervisor for engaging in deliberate l

misconduct regarding the above situations as outlined in 10 CFR 50.5, and Institute I

sanctions against Northeast Utilities and the Unit 1 organization for engaging in deliberate misconduct regarding the above situations as outlined in 10 CFR 50.5.

As verified by the Inspector General and the dccumented history ofWhistleblower complaints, the program of harassment, intimation, retaliation, and discrimination practiced by Northeast Utilities against those of us raising legitimate safety concerns is l

alive and well, and clearly the chilling effect is alive and well at the Millstone Station.

Moreover, in my opinion this shows the neglect demonstrated by many NU managers and NU employees as stated above with regards to procedure non compliance.

In addition to the requested aforementioned sanctions, I request under the provisions of 10 CFR 50.5 that my first line supervisor be removed from his position until a satisfactory solution to the falsifying ofnuclear documents by my first line supervisor problem can be achieved.

s cer j

cc:

Senator Joseph Lieberman l

Mr. David Williams - OIG Ernest C. Hadley, Esquire Anthony J. Ross John R. Williams, Esquire (203) 442-4244 i

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Anthony J. Ross October 23, 1994 l

Unit 1 Maintenance

" Confidential" "A" Station Electrician Millstone Station 1

3 John Kiskunes Unit 1 Maintenance Maintenance Supervisor Millstone Station i

l RE: Your meno to me about absenteeism, dated October 6, 1994.

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The purpose of this memorandum is to explain my absenteeism from j

work. In your meno, I am being attacked for uncontrolled absence i

during illness, and my personal time. For the record, I'm l

attending a program that was recommended by Mr. Bergh.

j Moreover, as far as personal time goes, on several occasions in l

1993, Mr. Bergh recommended the use of counseling in the l

company's Employee Assistance Program. Due to privacy l

considerations I elected counseling with a private psychiatrist.

j I am being chastised for personnel time usage for a program which was recossended by my management. This accounts for approximately

-36 hours of the 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> mentioned in 1993, and approximately 54 l

hours of the 63 hours7.291667e-4 days <br />0.0175 hours <br />1.041667e-4 weeks <br />2.39715e-5 months <br /> mentioned in 1994. My psychiatrist keeps no abnormal visiting hours. I have told you and Mr. Dick Peterson, more than once, that I have weekly counseling meetings with my l

psychiatrist.

i Furthermore, as far as sicktime goes, I have provided you with doctor's notes, for 136 hours0.00157 days <br />0.0378 hours <br />2.248677e-4 weeks <br />5.1748e-5 months <br /> of the 158.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> mentioned in l

1994, and for 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> of the 96.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> mentioned in 1993.

i Accordingly, I feel that ones illness is beyond ones control.

Clearly, as indicated in your meno, I do understand that I hold a "important position" in the department. I truly believe, if you were sincerely concerned about the " serious negative impact on the efficiency and effectiveness of our department" you would do something about the Mork control Group, only giving us enough work for approximately 2 or 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> daily. As you know, there are days, we constantly wait for work. I have spoken to several managers, including yourself, about the Mork Control Group, and this situation is still the same.

Additionally, I have contacted the Medical Department, per your request, and as soon as I get on the day shift, I will see Dr.

Graves. Also as I indicated above, I have my own doctor that I see on a weekly basis verses' the EAP, I will continue to see him.

There is one thing that I am hoping you could help me with, that I don't understand. On October 7, 1994 at 4:50am, I asked you what you and Neil wanted to see me for, this was before Neil

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showed up, you told me that "you didn't know." Then at 5:00am Neil showed up and we proceeded to his office, Neil opened his desk and handed you the meno, that you gave me that day, and told j

you to sign it, you signed the meno and then made copies. That's i

what I don't understand. Is this your meno or Neil's? If the meno is not intended for my personnel file or disciplinary action, why did a copy go to V.G. Fleming - Nuclear Personnel?

j My upcoming weekly doctors appointments, are as follows:

Thursday, October 27, 1994 at 3pm i

Thursday, November 3, 1994 at 3pm 1

Thursday, November 10, 1994 at 2:30pm

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Wednesday, November 16, 1994 at 3:15pm 4

Wednesday, November 23, 1994 at 3:45pm Wednesday, November 30, 1994 at 3pm In closing, I'm sure you are well aware of the fact, that I have raised many undisputed Nuclear and Personnel Safety Concerns, since May of 1993, both with the company and the Nuclear i

Regulatory Commission. Clearly, as indicated in your meno, NU management is continuing to subject me to their program of harassment, intimidation, discrimination, and retaliation. Which is directly related to me raising Nuclear and Personnel Safety Concerns, as a protected employee, as outlined in 10 CFR 50.7.

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i Arthony J. Ross

CONFIDENTIAL" Unit 1, Mamtenance November 22,1994

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Station Elodrkian "A" Mastone Station f

Mr. Neil Bergh Unit 1. Maintenance Manager j

MRelone Station 1

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j RE: Your meeting with rne and John Kiskunes on Odober 27,1994 about absenteelsm j

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Dear Mr. Bergh,

l Several issues were brought up in your meeting by you and John, and quite frankly the j

double talk by you and John, in your meeting, has me baffled In your meeting we discussed the letter I received, dated October 6,1994, signed by Mr.

Kiskunes. In the beginning of our meeting, John told me he composed the letter, teter in our conversation John told me he had help composing the letter, and later in our conversation you indcoted to me, you had written the letter. Clearly indcated by you, in your meeting, the letter was written by you, and John reaNy wasn't sure if he wrote the letter or had input into wrlhng the letter. Clearly the trMardar*= statements are baffling to me, when a simple question asked by me on who reaty wtole the letter, tums into a veristy of answers by you and John.

Additionety, in your meeting, John told me, while I was assigned to Unt 2 from Monday, October 3,1994 to Saturday, October 22,1994, I asked for Saturday, October 8,1994 off for no reason, and didn't ten Mike PettengN!. John also told me on Sunday, October 16,1994, I asked for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> off and took 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. First of all, I did supply Mr. Kurt Anderson, Unit 2 First t.ine Supennsor, with a reason for not working ovettime on Saturday, Odober 8,1994, the reason was a family reunion in New Jersey, and Kurt did in fact excuse me from work on the doy in quashon Secondly, John was certamly correct, when he stated, I took 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> off on Sunday, Odober 16, 1994. I explemed to Kurt, I would be agiggl 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> late, but the fact of the metter is I had Kurt's permission. Aw,,G,W, I am sure you are well aware the above mentioned time, is overtime. I can remember the moming of August 30,1994, et your department meeting, you spoke about refused overtime. You explained to the entire department, refused overtime wnuld not be held agemst you, and you further indcated, spending time with you family is very important. I truly believe you are continuing with your program of harassment, intimidation, and retallabon against me, for raising serious legitimate nudeer safety concems as a protected employee. Cleerty, you have e double standard one for protected employees and another for as other employees.

1 Furthermore, John had explained to me he didn't ceE Unt 2 dieddng up on me, John emplemed Kurt Anderson had called him and told him about the hours I had missed because he was concemed Accordingly, I wlR supply you with a Ittle information, Kurt emplemed to me. Unit 1 managemert had cated to check on me, and further explained he didn't ceE over to Unit 1. At that point in the meeting, both of you began to unfustly chastise and intenogste me about my lost time while on assignment et Unit 2. Your adions were dearty uncelled for considering the lost time both of you were chestasing me for was overtwne Moreover, I asked you twice in your meeting N I could speak wth Virgina Fleming, to find out why a copy of the Odober 6,1994 letter was sent to her, when cleerty the letter was not intended for my personnel fue or decipinary adion. I explained to you, I wanted to find out what Virgina did with the letter. You indicated to me, you would cou Virgine today and setup an appointment. Weg, for the record, the promme of an appointment to speak to Ms. Fleming, about the letter, just appears to be another promme that you never fotow through on, hke the many others you haven't fotowed through on over the years.

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j lt is quite clear to me upper management is deeply concemed about the morale at Mastone, and wintung the eT- "-:i::: trust, and you continue to tear at that fabric and corittnue your daily pervasive program of harassment, intimidahon, discriminshon, and retallation that's 1

directed towards me, as a protected employee, who's main conoom is truly the safety of co-d workers and the public, while co-workers egeet your program. Accordingly, the chEing effect you i

have created within the department is astounding l

In my opnon, the strong-arm tactics used by you gives the impression of a manager in l

doop and bitter dsarray, the department polpable, ugly and tsus-; %. Such tedics gives the unwelcome results of stalemate and acnmony and the substitution of innuendo and opportunism i

for vision and faimess 4

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cc-John R. Williams, Esquire i

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Northeast Utilities System Memo December 14.1994 TO:

Anthony Ross Unit 1 Electrician 'A' FROM: Neil G. Bergh Unit 1 Maintenan:e Manager This is to confirm the substance of the meeting with you, John Kiskunes and me on Monday December 12,1994 to discuss the importance ofyour returnmg a signed authorization so that the Company may obtain additional medical information from your physician regarding your repeated and recurring absences from work.

I At the meeting, you were again requested to sign a medical authorization which would I

allow the Company's physician to contact your physician to determine the medical necessity for your continuing absences from work and your medical prognosis.

We appreciate that a genuine illness is something that is beyond the control of any individual, and the Company's procedures take this into consideration. However, if for any reason, the employee is absent from work for frequent or extended periods of time, such absences creste serious problems for the Company. The Company's physician needs clarification of your medical status and the department needs to know when you can be counted on to work a full schedule on a regular basis. This lack ofinformation is negatively affecting the Company's ability to manage and schedule the department's work j

requirements.

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At our meeting on December 12,1994, you were requested to return a signed medical authorization by Friday, December 16,1994. Please be advised that ifyou do not return a I

signed authorization by close of 6*iam Friday, December 16,1994, any future absences l

due to illness will be coded " unexcused absence-no pay", code 393 and appropriate

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disciplinary action will be taken.

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cc: V. Fleming 1

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l t Northeast Utilities System

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i Memo October 6,1994 l

CONFIDENTIAL i

'ID:

Anthony Ross j

'A' Electrician i

I FROM:

John J. Kiskunes Unit 1 Maintenance pervisor SUBECT:

Absenteeism The purpose of this memorandum is to inform you about my concem for your attendance record. Your frequent absences from work are having a serious negative impact on the efficiency and effectiveness of our department. I am hopeful that you, as a long-term employee of the Company, can understand the problems associated with your frequent and extended absences which cannot continue in the important position that you hold. You should also understand that your absence is disruptive in that it requires reassignment of your work, changes to our normal schedules and a general loss of work flow continuity.

A review of your attendance record during 1992 indicates you were absent due to sickness for 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> or 12 days. During 1993 you were absent for 96.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> or 12 days. To date in 1994 you have been absent 158.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> or 19.8 days. Additionally your requests for personal time continue to increase and are further impacting your availability. You should be aware that the number of days you have been absent is far in excess of the company average.

A chart which sets forth your attendance record by payroll code is shown below:

1992 1993 1994 Payroll Code Description Hours 073 First Day Sickness - Personal 24 56.5 38.5 074 Sickness - Personal 72 40 120 070 Personal Time 22 46 63 Total 118 142 5 221.5 aro uv. s.

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i While I realize that illness is often beyond any individual's control, you must understand that your previous and ongoing record of absenteeism falls short of our expectations. It is important that you take action to gain control over your medical situation so that you can report to work regularly.

Our Medical Department and our Employee Assistance Program are available to assist you and suggest avenues which might help you improve your medical situation and attendance.

For any future absence for medical reasons you will be required to bring verifiable medical evidence from your physician explaining the reason for your absence and verifying that you are able to return to work.

I sincerely hope you are able to resolve your absenteeism problem in a positive way. ' Ibis memorandum is intended purely as counseling and will not become part of your personnel file. Likewise, it is not intended as a disciplinary action. If there is something additional that I can do to help you, please let me know.

cc: V.G. Fleming - Nuclear Personnel N.G. Bergh - Unit One Mr.intenance Manager 1

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