ML20214C885
| ML20214C885 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/25/1986 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| OL-S-026, OL-S-26, NUDOCS 8705210136 | |
| Download: ML20214C885 (12) | |
Text
, _ _ _ _ _ _ _ _ _____
00CMETED UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 87 fFR 24 P4 '45 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
- f.,
i In the Matter of,
)
)
COMMONWEALTH EDISON COMPANY
)
Docket Nos. 50-456 s
)
50-457 (Braidwood Sthtion, Units
- 1 and 2)
)
NRC STAFF (
SUMMARY
) TESTIMONY OF WILLIAM S. LI 'TLE REGARDING BRIDGET LITTLE ROREM, ET AL.
SUBCONTENTION 2 (OC INSPECTOR HAR~X55ETEN1)
Q1. Please state your name, position and business address.
A1. My name is William S. Little.
I am employed by the U. S. Nuclear I
Regulatory Commission as the Director, Braidwood Project.
My
).-
business address is United States Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, Illinois 60137.
l Q2. Please describe your responsibilities as Director, Braidwood Project A2. As Director, Draidwood Project I am responsible for managing the NRC inspection program at the Braidwood Station during all phases of construction, testing and operation to ensure that the station is constructed tested and operated in accordance with the provisions of NRC permits, licenses, rules and regulations.
I directly supervise the B raidwood Project Section Chief, two project inspectors and NUCtLA4 REGULATORY COMWiss!0N three resident inspectors.
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Q3. Have you prepared a statement of your professional qualift::ations?
A3. A copy of my professional qualifications is attached hereto as Exhibit 1.
- 04. What is the purpose of your testimony?
s A4. The purpose of my testimony is to state the Staff's position and conclusions concerning alleged harassment and intimidation of L. K. Comstock (LKC) QC inspectors with respect to the issues raised by Intervenors Bridget Little Rorem et. & in its ' QC Inspector Harassment Contention.
Q5. Mr. Little, are you familiar with the preamble to Intervenors' QC Inspector Harassment Contention?
A5. Yesi the preamble ~ summarizes the Intervenors' position that harassment and intimidation of Comstock QC inspectors was systematic and widespread, and discouraged the identification and correction of deficiencies in safety-related components and systems.
Q6. Mr. Little, has the Staff found any instance in which an LKC QC l
inspector knowingly accepted discrepant work or failed to identify a deficiency in a safety-related system, component, or structure at the l
Braidwood Station?
A6. The Staff looked in to each of the incidents described in Inter-venors' harassment contention and found no instances in which an LKC QC inspector was intimidated or harassed-by LKC QC_
management into knowingly approving deficient work or falsifying
o 3-quality records. The Applicant has taken effective steps to eliminate much,of the discontent that existed among the LKC QC inspectors, including the discharge of a QC supervisor who acted improperly and was the source of several QC inspector concerns.
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C Exhibit 1 1
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WILLIAM S. LITTLE Organization:
U. S. Nuclear Regulatory Comission Region III
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Title:
Director, Braidwood Project Grade:
GG-15 Birth Date:
August 22,# g30 1
Education:
B. S. Chemical Engineering Georgia Institute of Technology,1953 Professional Memberships:
Member of ASME Working Group on Duties and Responsibilities (SCIII) g, Experience:
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04/85 - Present Director, Braidwood Project - Manages the BraidWood inspection program. Supervises three resident inspectors and two project inspectors. (NRC,RegionIII) 11/84 - 04/85 -
Chief, Operations Branch - Managed a branch consisting of approximately 30 professionals with diverse engineering-(
backgrounds.. The branch is responsible for reactor operator licensing and for routine and reactive inspections primarily at operating facilities. (NRC,RegionIII) 1982 - 11/84 Chief Encineerino Branch 2 - Manages a branch consisting of tnree sections having a staff of approximately 35 professionals with diverse engineering backgrounds. The branch is responsible for routine and reactive inspections at facilities under construction, during preoperational testing and during operation. Manages the regional program for evaluation of matters regarding specialized engineering skills.
(NRC,RegionIII) i
+
1980 - 1931 Chief,' Reactor Projects Section - Supervised seven resioent inspectors and one project inspector responsible for the inspection program at the Duane Arnold Marble Hill, Monticello and Prairie Island sites.
(NRC, Region III) 1975 - 1979 Chief. Nuclear Senoort Section - Supervised seven inspectors anc one intern, providing specialists in support and the reactor operations inspection program; routinely inspectin thmmal hydraulics,g in areas of core physics, core refueling, preoperational and startup testing, training and recualification and containment leak rate tests; and responsible for research reactor inspection programs.
(NRC, Region -III)
o 1971 - 1975 Reactor Test and Startuo and Operations inspector -
Project inspector at Browns Ferry for three years and 1
Brunswick for six months. Assisted in 4nspections at other sites.
(AEC, Region II) 1
.i i
1965 - 1971 '
Licensino Suoervisor - Managed B&W licensi.ng activities l
for Crystal River, Davis-6 esse, Three Mile Island and Bellefonte plants. Supervised three-four licensing engineers. (B&W) 1966 - 1968 Supervisor, Emergency Core Coolino Test Section -
Developed and managea research and development programs in support of emergency core cooling systems for comercial nuclear power plants. Supervised four engineers.
(Phillips Petroleum Company) 1965 - 1966 Supervisor, Heat Transfer Hydraulics and Radioaraphy Section - Engineering support of test reactor operations in areas of fuel inspection and testing; hydraulic facility operation; safety analysjs. preoperation, startup and surveillance testing; core thermal-hydraulic's; *and nuclear engineering. Provided radiography service for NRTS. Supervised six-eight engineers and six radio-graphers and NDT technicians.
(Phillips Petroleum) 1959 - 1965 Plant Engineerino - Performed various engineering functions in support of test reactor operation.
(PhillipsPetroleumCompany) 1956 - 1959 Project Encineerino - Project engineering for liquid metal coolec and fueled experiments in test reactors.
(Phillips Petroleum Company) 1955 - 1956 Research Enaineerino - Development testing in the area of heat transfer and refrigeration systems.
(Trane Company) 1955 - 1955 Pilot Plant Enaineer - Organic chemical process oeveiopment. (Tennesee Corporation) s b
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UNITED STATES OF AMERICA
~
NUCLEAR REGULATORY COMMISSION'
- BEFORE THE ATOMIC SAFE'TY AND LICENSING BOARD
~
1.'
In the Matter of
)
)
s COMMONWEALTH EDISON. COMPANY
)
Docket Nos. 50-456
\\
)
50-457 (Braidwood Station, Units 1 and 2)
)-
P NRC STAFF TESTIMONY OF WILLIAM S. LITTLE REGARDING BRIDGET LITTLE ROREM, ET AL.
30BCONTENTION 2 Q1. Please state your name, position and business address.
A1. My name is William S. Little.
I am employed by the Nuclear Regulatory Commission as the Director, Braidwood Project.
My business address is United States Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, Illinois 60137.
Q2. Please describe your responsibilities as Senior Resident Inspector.
A2. As Director, Braidwood Project I am responsible for managing the l
NRC inspection program at the Braidwood Station during all phases l
of construction, testing and operation to ensure that the stat' ion is constructed tested and operated in accordance with the previsions of i
NRC permits, licenses, rules and regulations.
I directly supervise the Braidwood Project Section Chief, two project inspectors and three resident inspectors.
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L Q3. Have you prepared a statement of your professional qualifications?
A3. A statement of my professional qualifications is attached to this testimony as Exhibit 1.
g Q4. What is the purpose of your testimony?
, A4. The purpose of my testimony is to address that part of contention 2 (the QC Inspector Harassment Contention) relating to John D.
Seeders.
My testimony will describe the actions taken by the Staff in response to Mr. Seeder's harassment and' intimidation allegations.
Contention 2 states in part:
Contrary to Criterion 1,
" Organization" of 10 C.F.R. Part 50, Appendix B, and 10 C.F.R.
Section 50.7, Commonwealth Edison Company and its electrical contractor, L. K. Comstock Engineering Company have failed to provide sufficient authority and organizational freedom and independence from cost and schedule as opposed to safety considerations to permit the effective identification of and correction of quality and i
safety significant deficiencies.
Systematic and widespread harassment, intimidation, retaliation i
and other discrimination has been directed against Comstock QC inspectors and other employees who express safety and quality concerns by Comstock management.
Such miconduct discourages the identification and correction of deficiencies in safety-related components and systems at the Braidwood Station.
Instances of harassment and intimidation include at least the following:
1.
At various times since at least August 1984, including in March 1985, more than twenty-five (25)
Comstock QC inspectors have complained to the NRC about harassment and intimidation by Comstock supervisors..
Such harassment and intimidation has been cairied out or participated in by QC Manager. Irv DeWald,
Assistant QC Manager Larry Seese, - QC, Manager Bob Seltman and QC Supervisor R. M. Sakalac.
1
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Former Level II QC inspector John D. Seeders has knowledge of these widespread instances of harassment.
By letter of August 17, 1984, Seeders complained to the NRC, Edison and Comstock management regarding instarices of harassment directed against him.
Subsequently, Mr. Seeders was involuntarily transferred to the. position of Engineering Clerk in
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s retaliation for his expression of quality concerns.
Such assignment was intended by Comstock to keep Mr. Seeders away from sensitite work areas.
Although QC Supervisor R. M. Sakalac was finally terminated in 1985 for his mistreatment of QC inspectors and other misconduct, the effects of his harassment remain uncorrected and. systematic harassmbnt continues at Comstock to the present.
The existence of widespread harassment impugns the integrity and effectiveness of on-going corrective action programs designed only to address other widespread QA failures at Comstock.
I QS. How did the Staff first become aware of Mr. Seeder's allegations?
On August 20, 1984, Robert Schulz, the Senior Resident -Inspector AS.
for Construction at Braidwood, received a copy of a letter dated August 17, 1984 from Mr. Seeders to Mr. Irv DeWald of L. K.
Comstock Co.
In this letter, Mr. Seeders discussed a number of his concerns involving working conditions, compensation, and relations with LKC management personnel.
Mr. Seeders' letter also indicated that he had been asked to falsify documentation and otherwise harassed and intimidated by his supervisors.
Mr. Seeders stated in his letter that he had not compromised the quality of his work because of this alleged harassment and intimidation.
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Q6. What actions did the Staff take?
A6. Mr. S,chulz forwarded Mr. Seeders' letter to Region II,I where it was turned over to Charles Well, the Region III Allegation Coordinator.
Mr. Weil discussed Mr. Seeders' allegations with. Eugene Pawlik, the Director of the NRC bffice of Investigation,(OI) Region III Field
- Office, who determined that an investigation by I was not warranted at that time since no wrong ' doing was alleged by Mr. Seeders.
On August 27, 1984, Mr. Weil assigned the Division of Reactor Projects (DRP) the responsibility for following ups on Mr. Seeders's allegations.
That follow-up was conducted by Mr. Schulz and is documented in NRC Inspection Report Nos. 50-457/84034; 50-457/84032.
Q7. What were the inspection results?
A7. Mr. Schulz met with Mr. Seeders and four other LKC quality control inspectors on September 21, 1984.
During that meeting none of the inspectors provided Mr. Schulz any specific examples of harassment and intimidation.
Their main concern was a morale problem which appeared to be related to monetary matters and their disenchantment with LKC management.
Mr. Schulz met with Commonwealth Edison Co. management to discuss this issue and Applicant subsequantly met with LKC's site management to emphasize that harassment or intimidation in any form would.not be tolerated.
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,. s Q8. What additional action,. if any, has the Staff taken regarding Mr. S,eeders' allegations?
A8. The Staff closed this issue on December 31, 1985 based on Inspection Report Nos. 50-456/84034/ 50-457/84032.
A copy of that report was
~
s sent to OI for its review and to Mr. Seeders for his information.
i OI concluded that an OI investigation was not warranted. Region III s
did not receive any follow-up questions or comments from Mr. Seeders.
t In September 1985, while reviewing documents received from the U.S. Department of Laber relating to Worley O.
Puckett, another LKC employee at Braidwood, Mr. Weil found a statement given by Mr. Seeders to a DOL investigator on October 18, 1984, in which he i
stated that he had been asked to falsify documents by L. K.
Comstock supervisory personnel.
The Staff reopened Mr. Seeders' allegation file and Mr. Weil, by certified letters dated September 13, 1985 and on March 6,1986, twice asked Mr. Seeders to contact the Staff so that the Staff could obtain more information regarding the possible falsification of documents.
Although Mr. Seeders received 4
both of these letters, he did not contact the Staff or otherwise, respond to the Staff's inquiry.
Based upon the information now available to it, the Staff has no basis upon which to conclude that Mr. Seeders failed to identify discrepancies because of harassment or intimidation from IKC super.visory personnel.
-~
. - =
s Exhibit 1
^
WILLIAM S. LITTLE
(~
Organization:
U. S. Nuclear Regulatory Comission, Region III
Title:
Director, Braidwood Project
~
Grade:
GG-15 Birth Date:
August 22,~1930
. Education:
B. S. Chemical Engineering Georgia Institute of Technology,1953 Professional Memberships:
Member of ASME Working Group on Duties and Responsibilities (SCIII)
Experience:
04/85 - Present Director, Braidwood Project - Manages the BraidWood inspection program. supervises three resident inspectors and two project inspectors.
(NRC,RegionIII) 11/84 - 04/85 -
Chief, Operations Branch - Managed a branch consisting of approximately 30 professionals with diverse engi6eering.
backgrounds. The branch is responsible for reactor operator licensing and for routine and reactive inspections primarily at operating facilities.
(NRC,RegionIII) 1982 - 11/84 Chief. Enoineerino Branch 2 - Manages a branch consisting of three sections having a staff of approximately 35 professionals with diverse engineering backgrounds. The branch is respons.ible for routine and reactive inspections at facilities under construction, during preoperational testing and during operation. Manages.the regional program for evaluation of matters regarding specialized engineering skills.
(NRC,RegionIII) 1980 - 1981 Chief,' Reactor Projects Section - Supervised seven resioent inspectors and one project inspector responsible for the inspection program at the Duane Arnold, Marble Hill, Monticello and Prairie Island sites.
(NRC,RegionIII) 1975 - 1979 Chief. Nuclear Support Section - Supervised seven inspectors ano one. intern, providing specialists in support and the reactor operations inspection program; routinely inspectin
- thermal hydraulics,g in areas of core physics, core refueling, preoperational and startup testing, training and recualification and containment
~
i leak rate tests; and responsible for research reactor inspection programs.
(NRC,RegionIII).
i
.~ -
4 b
'o 1971 1975 Reactor Test and Startuo and Ooerations inspector -
Project inspector at Browns Ferry for three years and Brunswick for six months. Assisted in 4nspections at other sites.
(AEC, Region II) 1965 - 1971 Licensino Suoervisor - Managed B&W licepsing activities for Crystal River, Davis-Besse, Three Mile' Island and Bellefonte plants. Supervised three-four licensing engineers.
(B&W) 1966 - 1968 Supervisor, Emergency Core Coolino Test Section -
Developed and manageo research and development programs in support of emergency core cooling systems for comnercial a
nuclear power plants. Supervised four engineers.
(Phillips Petroleum Company) 1965 - 1966 Supervisor, Heat Transfer Hydraulics and Radiooraohv Section - Engineering support of test reactor operations in areas of fuel inspection and testing; hydraulic facility operation; safety analysis, preoperation, startup and surveillance testing; core thermal-hydraulics;'and nuclear engineering. Provided radiography service for NRTS.
Supervised six-eight eng(ineers and six radio-graphers and NDT technicians.
Phillips Petroleum) 1959 - 1965 Plant Enoineerino - Perforned various engineering
' {I functions in support of test reactor operation.
h.
(Phillips Petroleum Company) 1956 - 1959 Project Enoineerino - Project engineering for liquid' metal coolec and fueled experiments in test reactors.
(Phillips PetroleumCompany)
~
1955 - 1956 Research Enoineerino - Development testing in the area of heat transfer and refrigeration systems.
(Trane Company) 1953 - 1955 Pilot Plant Enoineer - Organic chemical process oeveiopment.
(Tennesee Corporation)
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