ML20304A063

Stakeholder Correspondence

ML20304A063
Person / Time
Site:	Turkey Point
Issue date:	09/14/2020
From:	Saporito T Florida Power & Light Co, Nextera Energy
To:	NRC/EDO
Brown E-NRR/DORL 301-415-2315
References
Download: ML20304A063 (11)

Text

September 14, 2020 Executive Director for Operations U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Sent via Email and U.S. Mail First Class REQUEST FOR NRC ENFORCEMENT ACTION AGAINST NEXTERA ENERGY AND FLORIDA POWER & LIGHT CO.

This Request for NRC Enforcement Action is submitted by Thomas Saporito (hereinafter "Petitioner") - a former employee at the NextEra Energy - Florida Power and Light Company (FPL) Turkey Point Nuclear Plant (TPN) - (hereinafter Licensee) in 1988.

§ 2.206 REQUESTS FOR ACTION UNDER THIS SUBPART.

(a) Any person may file a request to institute a proceeding pursuant to§ 2.202 to modify, suspend, or revoke a license, or for any other action as may be proper. Requests must be addressed to the Executive Director for Operations and must be filed either by hand delivery to the NRC's Offices at 11555 Rockville Pike, Rockville, Maryland; by mail or telegram addressed to the Executive Director for Operations, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; or by electronic submissions, for example, via facsimile, Electronic Information Exchange, e-mail, or CD-ROM. Electronic submissions must be made in a manner that enables the NRC to receive, read,. authenticate, distribute, and archive the submission, and process and retrieve it a single page at a time. Detailed guidance on making electronic submissions can be obtained by visiting the NRC's Web site at http://www.nrc.gov/site-help/e-submittals.html; by e-mail to MSHD.Resource@nrc.gov; or by writing the Office of the Chief Information Officer, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001. The request must specify the action requested and set forth the facts that constitute the basis for the request. The Executive Director for Operations will refer the request to the Director of the NRC office with responsibility for the subject matter of the request for appropriate action in accordance with paragraph (b) of this section.

(b) Within a reasonable time after a request pursuant to paragraph (a) of this section has been received, the Director of the NRC office with responsibility for the subject matter of the request shall either institute the requested proceeding in accordance with this subpart or shall advise the person who made the request in writing that no proceeding will be instituted in whole or in part, with respect to the request, and the reasons for the decision.

(c)(1) Director's decisions under this section will be filed with the Office of the Secretary.

Within twenty-five (25) days after the date of the Director's decision under this section that no proceeding will be instituted or other action taken in whole or in part, the Commission may on its own motion review that decision, in whole or in part, to determine if the Director has abused his discretion. This review power does not limit in any way either the Commission's supervisory power over delegated staff actions or the Commission's power to consult with the staff on a formal or informal basis regarding institution of proceedings under this section.

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(2) No petition or other request for Commission review of a Director's decision under this section will be entertained by the Commission.

(3) The Secretary is authorized to extend the time for Commission review on its own motion of a Director's denial under paragraph (c) of this section.

[39 FR 12353, Apr. 5, 1974, as amended at 42 FR 36240, July 14, 1977; 45 FR 73466, Nov.

5, 1980; 52 FR 31608, Aug. 21, 1987; 53 FR 43419, Oct. 27, 1988; 64 FR 48948, Sept. 9, 1999; 68 FR 58799, Oct. 10, 2003; 69 FR 2236, Jan. 14, 2004; 69 FR 41749, July 12, 2004; 70 FR 69421, Nov. 16, 2005; 72 FR 33386, Jun. 18, 2007; 74 FR 62679, Dec. 1, 2009; 80 FR 74978, Dec. 1,2015]

10 CFR 110.62 (a) In response to an alleged violation, described in 110.60, the Commission may institute a proceeding to revoke, suspend, or modify a license in issuing an order to show cause:

(1) Stating the alleged violation and proposed enforcement action; and (2) Informing the licensee of his right, within 20 days or other specified time, to file a written answer and demand a hearing.

(b) An answer consenting to the proposed enforcement action shall constitute a waiver by the licensee of a hearing and of all rights to seek further Commission or judicial review.

(c)The order to show cause may be omitted and an order issued to revoke, suspend, or modify the license in cases where the Commission determines that the violation is willful or that the public health, safety, or interest so requires.

PETITIIONER REQESTS THE FOLLOWING ENFORCEMENT ACTION AGAINST THE LICENSEE Petitioner requests that the NRC institute a show cause proceeding pursuant to 10 CFR 2.202 and 10 CFR 110.62 to modify, suspend, or revoke the Licensee's operational licenses for the Turkey Point Nuclear Plant and the St. Lucie Nuclear Plant.

Petitioner requests that the NRC take appropriate actions to cause the immediate shut down of the operating nuclear reactors at the Turkey Point Nuclear Plant and at the St.

Lucie Nuclear Plant Petitioner requests that the NRC take appropriate enforcement action against the Licensee and issue a civil monetary penalty against the Licensee in the amount of $5-Million Dollars.

Petitioner requests that the NRC issue an Order prohibiting J.H. Goldberg, President, Nuclear Division employed at the Licensee in May 20, 1994, from engaging or participating in any and all NRC licensed activities for a period of no less that 5-years; and that the NRC issue a monetary civil penalty against J.H. Goldberg in the amount of

$500,000.00.

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BASIS AND JUSTIFICATION

§ 50.5 Deliberate misconduct.

(a) Any licensee, applicant for a license, employee of a licensee or applicant; or any contractor (including a supplier or consultant), subcontractor, employee of a contractor or subcontractor of any licensee or applicant for a license, who knowingly provides to any licensee, applicant, contractor, or subcontractor, any components, equipment, materials, or other goods or services that relate to a licensee's or applicant's activities in this part, may not (1) Engage in deliberate misconduct that causes or would have caused, if not detected, a licensee or applicant to be in violation of any rule, regulation, or order; or any term, condition, or limitation of any license issued by the Commission; or (2) Deliberately submit to the NRC, a licensee, an applicant, or a licensee's or applicant's contractor or subcontractor, information that the person submitting the information knows to be incomplete or inaccurate in some respect material to the NRC.

(b) A person who violates paragraph (a)(1) or (a)(2) of this section may be subject to enforcement action in accordance with the procedures in 1 0 CFR part 2, subpart B.

(c) For the purposes of paragraph (a)(1) of this section, deliberate misconduct by a person means an intentional act or omission that the person knows:

(1) Would cause a licensee or applicant to be in violation of any rule, regulation, or order; or any term, condition, or limitation, of any license issued by the Commission; or (2) Constitutes a violation of a requirement, procedure, instruction, contract, purchase order, or policy of a licensee, applicant, contractor, or subcontractor.

[63 FR 1897, Jan 13, 1998]

§ 50.7 Employee protection.

(a) Discrimination by a Commission licensee, an applicant for a Commission license, or a contractor or subcontractor of a Commission licensee or applicant against an employee for engaging in certain protected activities is prohibited. Discrimination includes discharge and other actions that relate to compensation, terms, conditions, or privileges of employment. The protected activities are established in section 211 of the Energy Reorganization Act of 197 4, as amended, and in general are related to the administration or enforcement of a requirement imposed under the Atomic Energy Act or the Energy Reorganization Act.

(1) The protected activities include but are not limited to:

(i) Providing the Commission or his or her employer information about alleged violations of either of the statutes named in paragraph (a) introductory text of this section or possible violations of requirements imposed under either of those statutes; (ii) Refusing to engage in any practice made unlawful under either of the statutes named in paragraph (a) introductory text or under these requirements if the employee has identified the alleged illegality to the employer; (iii) Requesting the Commission to institute action against his or her employer for the administration or enforcement of these requirements; (iv) Testifying in any Commission proceeding, or before Congress, or at any Federal or State proceeding regarding any provision (or proposed provision) of either of the statutes named in paragraph (a) introductory text.

(v) Assisting or participating in, or is about to assist or participate in, these activities.

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(2) These activities are protected even if no formal proceeding is actually initiated as a result of the employee assistance or participation.

(3) This section has no application to any employee alleging discrimination prohibited by this section who, acting without direction from his or her employer (or the employer's agent),

deliberately causes a violation of any requirement of the Energy Reorganization Act of 1 97 4, as amended, or the Atomic Energy Act of 1954, as amended.

(b) Any employee who believes that he or she has been discharged or otherwise discriminated against by any person for engaging in protected activities specified in paragraph (a)(1) of this section may seek a remedy for the discharge or discrimination through an administrative proceeding in the Department of Labor. The administrative proceeding must be initiated within 180 days after an alleged violation occurs. The employee may do this by filing a complaint alleging the violation with the Department of Labor, Employment Standards Administration, Wage and Hour Division. The Department of Labor may order reinstatement, back pay, and compensatory damages.

(c) A violation of paragraph (a), (e), or (f) of this section by a Commission licensee, an applicant for a Commission license, or a contractor or subcontractor of a Commission licensee or applicant may be grounds for-(1) Denial, revocation, or suspension of the license.

(2) Imposition of a civil penalty on the licensee, applicant, or a contractor or subcontractor of the licensee or applicant.

(3) Other enforcement action.

(d) Actions taken by an employer, or others, which adversely affect an employee may be predicated upon nondiscriminatory grounds. The prohibition applies when the adverse action occurs because the employee has engaged in protected activities. An employee's engagement in protected activities does not automatically render him or her immune from discharge or discipline for legitimate reasons or from adverse action dictated by nonprohibited considerations.

(e)(1) Each licensee and each applicant for a license shall prominently post the revision of NRC Form 3, "Notice to Employees," referenced in 10 CFR 19.11(e)(1). This form must be posted at locations sufficient to permit employees protected by this section to observe a copy on the way to or from their place of work. Premises must be posted not later than 30 days after an application is docketed and remain posted while the application is pending before the Commission, during the term of the license, and for 30 days following license termination.

(2) Copies of NRC Form 3 may be obtained by writing to the Regional Administrator of the appropriate U.S. Nuclear Regulatory Commission Regional Office listed in appendix D to part 20 of this chapter, via email to Forms.Resource@nrc.gov, or by visiting the NRC's online library at http://www. nrc.gov/reading-rm/doc-collections/forms/.

(f) No agreement affecting the compensation, terms, conditions, or privileges of employment, including an agreement to settle a complaint filed by an employee with the Department of Labor pursuant to section 211 ofthe Energy Reorganization Act of 1974, as amended, may contain any provision which would prohibit, restrict, or otherwise discourage an employee from participating in protected activity as defined in paragraph (a)(1) of this section including, but not limited to, providing information to the NRC or to his or her employer on potential violations or other matters within NRC's regulatory responsibilities.

[58 FR 52410, Oct. 8, 1993, as amended at 60 FR 24551, May 9, 1995; 61 FR 6765, Feb. 22, 1996; 68 FR 58809, Oct. 10, 2003; 72 FR 63974, Nov. 14, 2007; 79 FR 66603, Nov. 10, 2014; 83 FR 58465, Dec. 12, 2018]

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LICENSEE'S DELIBERATE ACTS OF MISCONDUCT, WILLFULL WRONGDOING, AND DISCRIMINATION Petitioner avers here that during his employment at (TPN) as an Instrument and Control Technician in 1988-he notified the Licensee(s) about numerous nuclear safety concerns observed on the job at TPN. These nuclear safety concerns were made verbally to supervision and documented in Plant Work Orders (PWOs).

Notably in 1988 TPN was on the NRC's Watch List of Worst Performing Nuclear Plants. Moreover, the NRC was especially concerned about repetitive procedure violations at TPN. Strict adherence to procedures at TPN was mandated by the NRC through the issuance of operational licenses for the two nuclear reactors at TPN. The Licensee had been the subject of numerous enforcement actions by the NRC for failure to follow procedures at TPN.

Joe Kappes was the Maintenance Superintendent at TPN and had authority over the Instrument Control Dept. (I&C) where Petitioner worked. In approximately early March of 1988 - Kappes entered the I&C Dept. and stated to all employees that from that day forward "VERBATIM COMPUACE TO PROCEDURES WAS MANDATORY" and that there would be no exceptions Petitioner documented his concerns about procedure violations in his PWOs at TPN but the Licensee failed to engage Petitioner about [h]is nuclear safe concerns

-which entailed more than procedure violations.

Having lost all confidence in the Licensee to address his nuclear safety concerns, Petitioner hand delivered a letter to a representative of the Institute of Nuclear Plant Operators (INPO) outlining his nuclear safety concerns Shortly thereafter the Licensee began a Witch Hunt and Search and Destroy mission to get rid of Petitioner.

Petitioner observed an NRC Form 3 Notice displayed at TPN and contacted Oscar Demiranda, Region II Senior Allegations Coordinator about his nuclear safety concerns. Demiranda maintained continuous contact with Petitioner via the telephone and regularly called Petitioner at his home in Florida to discuss his nuclear safety concerns and retaliatory actions taken against Petitioner by the Licensee. Notably, Petitioner advised DeMiranda that many of his nuclear safety concerns were documented in his PWOs at TPN and that the licensee was fully aware.

Petitioner became the focus of retaliatory conduct by the Licensee shortly after raising nuclear safety concerns. Jerry Harley was the I&C Supervisor at TPN in 1988. He singled out Petitioner for a job that required entry in the the nuclear reactor containment building - while the nuclear reactor was fully operational at power. Notably - this was a HIGH RADIATION EXPOSURE job. Notably, NRC requirements mandate that the Licensee assign such High Radiation Exposure jobs to employees who have the "least amount of accumulated" radiation at TPN. In this case, there were many other employees in the I&C Dept. with far lower 5 of 10

accumulated radiation exposure than Petitioner. Clearly - this act by the Licensee was a violation of NRC requirements under 10 CFR Part 50 and under other NRC authority and a violation of the two nuclear reactor NRC licenses. Moreover, this was yet another violation of the Licensee's technical specifications to verbatim comply with procedures at TPN. Not only did the licensee violate NRC requirements in this instance - but the Licensee jeopardized Petitioner's very life and well-being - and the Licensee failed to self-identify this violation to the NRC as required under NRC regulations.

The job required protective clothing and a full face respirator. Shortly after completing the job assignment - Petitioner suffered from extreme heat exhaustion and went home sick. Harley - the Licensee manager who singled Petitioner out for this job - held the PWO in his hand - high in the air - and walked around the I&C Dept. laughing and stating "I got him, I got him, I sent him home sick". This conduct by Harley demonstrates a significant animus against the Petitioner following [h]is raising nuclear safety concerns to the Licensee and to INPO and to the NRC. The conduct by the Licensee by a Department Manager is particularly concerning because is develops a Hostile Work Environment at TPN and a Chilling Effect to other employees at TPN to dissuade them from raising nuclear safety concerns.

There were numerous other acts of retaliation taken against Petitioner due to his raising nuclear safety concerns at TPN. For example, Petitioner was assigned demeaning jobs such as arranging books on book shelves. Petitioner was removed from a quality group which was formed by Petitioner to address procedure adherence. The Licensee dissolved the group entirely. Petitioner was banished to work outside the plant in an exterior building to rebuild huge valve actuators -

because other employees were using Petitioner as a conduit to raise nuclear safety concerns to NRC DeMiranda as a Chilling Effect was in full force at TPN.

During a telephone conversation between Petitioner and NRC DeMiranda in the latter part of November 1988 - DeMiranda told Petitioner that John Odom, Senior Vice President at TPN called him to inquire about Petitioner's nuclear safety concerns. DeMiranda stated that he told Odom that Petitioner had documented other safety concerns in his PWOs at TPN and that Odom should provide the PWOs to Petitioner for review. DeMiranda instructed Petitioner NOT to disclose his nuclear safety concerns about "Willful Wrongdoing" by the Licensee because the NRC Office of Investigation (01) was conducting an investigation and did not want their investigation compromised.

The Licensee fired Petitioner in late December 1988 - for three stated reasons of insubordination -

all related -

to Petitioner's raising nuclear safety concerns.

Petitioner filed a discrimination complaint under the Energy Reorganization Act (ERA). A hearing* was held in January 1989 before an Administrative Law Judge (ALJ) with the Department of Labor. Judge lacoba was assigned. Years later the Secretary of Labor issued a Remand Order and found FPL had violated the ERA.

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Notably - the Secretary of Labor found Odom's testimony under oath to be disingenuous.

During the hearing - witness testimony under oath was taken and affirmed that Harley - the I&C Dept manager pranced around the I&C Dept. exclaiming "I got him, I got him, I sent him home sick". Harley testified in open court that [h]e wished Petitioner had died on that job.

Odom testified that Petitioner had been fired for three specific reasons:

Failure of Petitioner to tell Odom his nuclear safety concerns Failure of Petitioner to attend a meeting with Odom about his nuclear safety concerns Failure of Petitioner to be examined by the company doctor.

Odom testified under oath that the NRC was not technically competent to determine what a nuclear safety concern was at TPN.

Odom admitted that [h]e gave Petitioner a direct order to tell the NRC his nuclear safety concerns and that Petitioner agreed to do so - although NRC had been made fully aware of Petitioner's nuclear safety concerns prior.

Odom admitted at the (first of two hearings before the DOL) that a job steward who attended Petitioner's visit to the company doctor - told [h]im Odom - that Petitioner did NOT REFUSE to be examined by the company doctor.

At the second hearing - Odom testified that [h]e made the decision to fire Petitioner

- before Petitioner went to the doctor's office. Therefore-this reason for firing Petitioner by the Licensee was a pretext and simply not true.

Petitioner did contact NRC DeMiranda again about his nuclear safety concerns as ordered by Odom and Odom was fully aware via his contact with NRC DeMiranda.

Moreover, prior to the meeting where Odom ordered Petitioner to tell the NRC his nuclear safety concerns - Petitioner was summoned to a meeting with Joe Kappes where Petitioner fully explained generally about his nuclear safety concerns but needed his PWOs to write a report to give to the NRC. Kappes complemented Petitioner about his general nuclear safety concerns - but told Petitioner - that "Odom and others just wanted to get rid of you". Kappes never provided any PWOs to the Petitioner.

Petitioner told Kappes in November 1988 that he could not attend a meeting with Odom where Odom again wanted to ask about Petitioner's nuclear safety concerns because he was sick.

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At the second hearing Kappes admitted under oath that Petitioner was paid for his sick leave - and that Petitioner's sick leave was valid. Petitioner provided FPL with a doctor's note excusing his absence from work.

Moreover, Kappes admitted at the first hearing that he gave another employee numerous direct orders and that the other employee refused to obey the director orders. Kappes further testified that the other employee was NOT fired -

but instead - Kappes treated the other employee to lunch.

Odom further testified under oath at the second hearing that if Petitioner had NOT raised any nuclear safety concerns - that [h]e Odom would NOT have fired Petitioner.

WILLFULL AND INTENTIONAL MISCONDUCT BY J.H. GOLDBERG TO MISILE AND MISLEAD THE NRC FROM TAKING ENFORCEMENT ACTION AGAINST THE LICENSEE In a letter dated May 20, 1994- J.H. Goldberg, President, Nuclear Division for the Licensee-authored and constructed a letter and "Memorandum In Response To March 7, 1994 10 CFR 2.206 Petition and March 23, 1994 Supplement Thereto Filed By Thomas J. Saporito, Jr.

(See, NRC ADAMS ML17352A612)- Mr. Goldberg states in relevant part that:

"... FPL's policy is to direct employees to report safety concerns to their immediate supervisor or to a higher management individual, or to report them through the company's employee concern program. As an alternative, employees are also advised that they can report any concerns to the NRC.

In this case, Mr. Saporito, in November, 1988, openly announced that he had safety concerns, but refused to tell licensee management the nature of those concerns. Therefore, licensee management specifically directed Mr. Saporito to immediately report his concerns to the NRC. Despite his present assertions, the fact is that Mr. Saporito did not report his claimed safety concerns to either FPL or the NRC at the time FPL directed him to do so. He therefore effectively precluded either FPL or the NRC from evaluating the significance of those concerns from an operational safety perspective in a timely way.... "(See, May 20, 1994 letter a p.2.

Petitioner avers he that J.H. Goldberg's statements to the NRC as described above and in

[h]is May 20, 1994 letter to Mr. James Lieberman, Director, Office of Enforcement, United States Nuclear Regulatory Commission - are false fabrications and not based on facts -

but rather intended by Mr. Goldberg and the Licensee to missile and to mislead the NRC from taking significant enforcement action requested by the Petitioner in 1994 via 2.206 Petitions submitted by Petitioner at that time.

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Indeed, two evidentiary hearings were held before the U.S. Department of Labor codified as 89-ERA-7/17. In those proceedings, numerous exhibits were accepted in the record of which said documents were nuclear safety concerns that Petitioner provided to the Licensee senior Management and to the NRC during Petitioner's employment at the Turkey Point Nuclear Plant. Those documents included a letter to the Institute of Nuclear Power Operations (INPO),

a letter to Joe Kappes, the Turkey Point Nuclear Plant Maintenance Superintendent, and numerous other safety concerns sent to the Licensee's senior management. As stated earlier, NRC Oscar DeMiranda called Petitioner at his home in November 1988, and told Petitioner that John Odom had called [h]im DeMiranda-requesting to know about Petitioner1s safety concerns. DeMiranda told Odom to provide Petitioner with the Plant Work Orders (PWOs) that Petitioner had completed on the job - so that Petitioner could report additional safety concerns. Subsequently, the licensee NEVER provided the PWOs. None-the-less, Odom and other high level senior management were FULLY AWARE of Petitioners documented safety concerns as they were copied those safety concerns during Petitioner's employment at the Turkey Point Nuclear Plant in 1988. Moreover, at a meeting in November 1988, Odom stood up at the meeting and gave Petitioner a direct order to tell the NRC his safety concerns.

Odom knew full well that Petitioner had already given the NRC all of his safety concerns.

None-the-less, Petitioner did call NRC DeMiranda soon after that meeting and again expressed his safety concerns for which DeMiranda was already aware. Notably, as stated earlier, NRC DeMiranda specifically instructed Petitioner NOT to tell the Licensee about certain safety concerns that the NRC Office of Investigations (01) were investigating so as not to compromise the NRC Ol investigation. Odom was fully aware that the NRC 01 was on-site at the Turkey Point Nuclear Plant-and Odom wanted those safety concerns. Notably, Odom testified in open court under oath-that [h]e Ordered Petitioner to tell the NRC about Petitioner's safety concerns during the November 1988 meeting.

NRC DeMiranda was recently copied on a NRC September 11, 2020 letter sent to the Petitioner related to other 2.206 Petitions-therefore Mr. DeMiranda can attest to Petitioner's statements described herein as to their factual validity and accuracy.

Thus, Mr. Goldberg's letter dated May 20, 1994 to the NRC James Lieberman is a pure fabrication and totally false and intended to missile and mislead the NRC from taking significant enforcement action against the Licensee as requested by the Petitioner at that time via 2.206 Petitions.

SUMMARY

NRC regulations and requirements under 10 CFR Part 50 and under numerous other implementing NRC regulations and authority prohibit wrongdoing, harassment, retaliation, and firing of employees -

like Petitioner - who raise nuclear safety concerns. Moreover, NRC regulations require their licensees to be truthful and factual when they communicate to the NRC about licensed activities and operations at their nuclear facilities.

In this instance -

Petitioner avers that the Licensee via Mr. Goldberg intentionally and willfully misiled and misled the NRC in fabrication of mis-statements and lies in a May 20, 1994-letter to NRC James Lieberman as described herein.

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The NRC is mandated by Congress to protect public health and safety by taking significant enforcement actions against licensees - like NextEra Energy and FPL - for intentionally mis-leading the NRC about licensed activities which could impact the health and safety of the public. Thus, the NRC cannot have any measure of reasonable certainty that any statements or assertions made by the named Licensee herein are accurate or factual.

The specific wrongdoing issues brought in the instant enforcement Petition have NOT previously been addressed by the NRC Petition Review Board (PRB) and are therefore properly brought at this time - as there is NO time limit which prevents the NRC from taking enforcement action against a licensee in such matters.

Respectfully submitted, d

/~

Thomas Saporito 9995 SE Federal Hwy UNIT 1763 Hobe Sound FL, 33475 Phone: 772-206-2489 Email: saporito@gmx.com Administrative Review Board Secretary of Labor U.S. Department of Labor 200 Constitution Ave. NW C-2318 Washington, D.C. 20210 SERVICE SHEET Sent via email: executivesecretariat@dol.gov Director of Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sent via email: NRCExecSec@nrc.gov Board of Directors NextEra Energy 700 Universe Boulevard Juno Beach, FL 33408 10 of 10