ML20215H658
| ML20215H658 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 10/23/1986 |
| From: | Simile A COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20215H642 | List: |
| References | |
| OL, NUDOCS 8610240077 | |
| Download: ML20215H658 (9) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSI%rEnCORRESM 00CKETED BEFORE THE ATOMIC SAFETY AND LICENSING BOARD USNRC
'86 0CT 23 R2:17
.In the Matter of:
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CFFKE Gr " r:c Ac.v COMMONWEALTH EDISON COMPANY
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I CCHLIM J 1
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Docket Nos. 50-456~'"
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50-457 (Braidwood Nuclear Power
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Station, Units 1 and 2)
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ROREM/ARCHAMBEAULT CONTENTION TESTIMONY OF ANTHONY T. SIMILE Q.l.
State your full name, employer and your present.
position.
A.l.
My name is Anthony T.
Simile.
I am employed by Comstock Engineering, Inc. ("Comstock").
I currently serve as its General QC Supervisor at Commonwealth Edison's Braidwood Station.
Q.2.
Have au testified previously in this proceeding?
A.2.
Yes.
My professional qualifications and work responsibilities are set forth in my prepared testimony which appears in the transcript immediately following page 3305.
Q.3.
What is the purpose of your testimony?
A.3.
The purpose of my testimony is to explain why Gregory Archambeault's assignment to the second shift as a cable pull inspector ren.ained unchanged from the time he was hired in January 1986 through the summer of 1986.
8610240077 861021-PDR ADOCK 05000456 Q
PDR O.4.
Who within the LKC QC department bears the responsibility for making decisions concerning the staffing of each shift?
A.4.
I do, normally.
Although I discuss my decisions with my superiors, it is my responsibility to ensure that each of our three shifts is staffed with enough inspectors to accommodate the craft activities-requiring in-process inspections on each shift and to accommodate other inspection activities.
This responsibility includes making.
recommendations to Mr. Seltmann when I find it necessary for us to obtain additional QC inspectors.
Although he makes the official arrangements through Bestco, and now GE-MCIS, I am responsible for assessing our staffing needs on each shift for each inspection area.
Q.5.
How long have you had this responsibility?
A.5.
I have had this responsibility since March of 1985, when I became general QC supervisor.
Q.6.
Please describe what your assessment was in the latter part of 1985 and early 1986 with respect to Comstock's second shift needs for inspectors.
l A.6.
In the latter part of 1985 our second shift QC l
inspector needs were increasing because the i
s craft were adding additional welding crews and additional cable pulling crews to that shift.
In fact, the cable pulling work was being transferred exclusively to the second shift to avoid interference with other work crews.
As the second shift craft increased its manpower, QC neaded to provide additional inspectors to support that ef5brt.
I made recommendations to Mr. Seltmann and Mr.
DeWald to hire additional electrical inspectors for the second shift.
I made these requests at different times beginning in late 1985.
Q.7.
Did you inform BestCo, GE-MCIS and Union Local 306 of these staffing needs?
A.7.
Yes.
Several times since the latter part of 1985, I made it clear to representatives of BESTCo, GE-MCIS and Local Unit 306 that new inspectors hired for Comstock would be working second shift.
I requested those representatives to tell the new i
inspectors this before they arrived on site.
l After a third shift was added in April 1986, I l
made it clear that new inspectors might also be assigned to this shift.
l Q.8.
Were you able to satisfy your second shift QC manpower needs in late 1985 and 19867 l
e A.8.
Yes. Additional inspectors were hired, and inspectors already on the job were transferred from first i
shift to second shift.
For example, Dennis Loos was transferred from first shift to second shift in August 1985.
Ken Willoughby was transferred to second shift:in December.
Ron Nelson, who was hired in December 1985, was transferred to second shift in January 1986.
Beginning in January 1986, when other inspectors were hired, they were sent straight to second shift.
Greg Archambeault was one of them.- They were trained in cable pulling on the second shift and remained on that shift after receiving their certifications.
This approach was different from our previous practice.
Prior to 1986 we attempted l
to train and certify all of our electrical inspectors in both cable pulling and terminations.
0.9.
When did you first learn that Mr. Archambeault wished to be transferred to the first shift?
A.9.
In June 1986, I asked Harry Revels, the second shift supervisor, to provide me with the names of 3 second shift inspectors who were interested in i
being transferred to first shift.
He brought me the names of Ron Nelson, Ken Willoughby and Greg l
l Archambeault.
I transferred Mr. Willoughby and Mr. Nelson to the first shift.
I made these transfers on June 18, 1986 and they were effective l
June 23, 1986.
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s Q.10.
Why didn't you transfer Mr. Archambeault to the first shift at the time you transferred Nelson and Willoughby?
A.10.
After I discussed the matter with Mr. Revels, we concluded that the second shift cable pulling effort could'not afford to lose three inspectors,-
i so we decided to transfer only two.
Both Mr.
Willoughby and Mr. Nelson had previously spoken with me about being transferred to first shift.
Mr.'Willoughby had explained to me that his wife was very ill and that he wanted to be able to
-remain with her in the evenings. -He had explained this to me when'I transferred him to the second shift, and I had promised him I would give him early consideration for being transferred back to first.
Similarly, when I had transferred Mr.
Nelson to the second shift, he had expressed to me his dislike for working in the evenings, and I had made a similar: promise to him.
Other than Mr.
Revels' mention of Mr. Archambeault's name as one of three possible transferees, I did not have any knowledge of Mr. Archambeault's preference for the j
first shift.
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Q.11.
When did you learn that Mr. Archambeault had i
raised quality concerns with the NRC?
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A.ll.
Harry Revels told me sometime in the summer of 1986 that Mr. Archambeault had written a letter to the NRC.
I do not remember whether it was before or after June 18, 1986, the date I transferred i
Nelson and Willoughby to first shift.
I'do remember that after that date Mr. Westberg of the NRC contacted me about quality concerns that he said had been raised by a QC inspector.
From the context of our conversations, I assumed these concerns had been raised by Mr. Archambeault in a
his letter.
0.12.
Did you have a further occasion to consider Mr.
Archambeault's transfer to first shift?
t A.12.
Yes.
Sometime later in the summer, Revels told me that Archambeault still wanted to be transferred to first shift.
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Q.13.
What was your response to Mr. Revels?
i A.13.
Harry felt that at this time the cable pulling effort could not afford to lose any of the QC inspectors that were on the second shift.
I agreed with Harry.
I also mentiond that_trans-ferring Mr. Archambeault shortly after he had
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raised concerns to the NRC would place me in an awkward position.
I felt that if I transferred i
I
.. f him, the newspapers might misconstrue that action, l'
because of the ongoing harassment hearings, as an effort to remove him from an area in which he.had raised quality concerns.
On the other hand, I believed that if I did not transfer Mr. Archambeault, it would be interpreted as punishing him for having raised those concerns.
i Q.14.
Did this perceived predicament form the basis for your decision to transfer Willoughby and Nelson rather than Archambeault?
A.14.
No.
I have already explained why I transferred Willoughby and Nelson.
The awkward position I have described did not occur to me until my conversation with Mr. Westberg about the quality concerns raised by an inspector who I presumed was Archambeault.
This conversation'took place after I had transferred Willoughby and Nelson.
Q.15.
Did you ever meet with Mr. Archambeault about his desire to be transferred to the first shift?
A.15.
Yes. On August 19, 1985, I attended a meeting with i
Messrs. Gieseker, Dougherty, Westberg, Seltmann, Cartelli, Nemeth and Archambeault which was called at Archambeault's request to try to resolve his concerns.
During this meeting Mr. Archambeault brought up the fact that he wanted to be transferred to first shift.
I told him that a transfer was not possible at that time because of the continuing cable pull effort on second shift.
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O.16.
When did you first see the written' request Mr.
Archambeault made in August for transfer to the first shift?
(Intervenors' Exhibit 124.)
A.16.
On August 27 Mr. Cartelli, the GE-MCIS project manager, presented me with a memo written by Archambeault to him and Mr. Nemeth, the second shift union steward.
Archambeault stated that he had written two previous requests for shift change and asked if and when he could be trained i
in terminations.
I noted on the memo that a shift change would not be possible at this time because of the-continuing priority of the second shift cable-pulling effort.
I returned the memo to Cartelli.
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Q.17.
When did you first see the written requests Mr.
Archambeault made in June and July for transfer to the first shift?
(Intervenors' Exhibits 118 and s
123.)'
t A.17.
In September 1986, when counsel for CECO showed them to me.
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Q.18.
Mr. Archambeault has testified that when he was hired Mr. Bossong assured him he would be transferred to the 1st shift and trained in terminations.
Do you have'any personal knowledge of whether this in i
fact occurred?
A.18.
No.
h e
Q.19.
Did Mr. Bossong have any power or authority to make such assurances?
A.19.
No.
Mr. Bossong is the first shif t union stewa; 1.
The authority to assign inspectors to a given
' shift and provide them with training in additional areas of certification' rests exclusively with Comstock QC management.
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