ML20138M802
| ML20138M802 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 07/17/1996 |
| From: | NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20138M747 | List: |
| References | |
| CON-NRC-779 NUDOCS 9702260216 | |
| Download: ML20138M802 (63) | |
Text
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@ffle101 Tran03ript of Pesoccdings
- NUCLEAR REGULATORY COMMISSION 4
Title:
Interview of William Raymond i
Docket Number: (not assigned) i
, Location: Haddam, Connecticut I
4 Date: Wednesday, July 17,1996 4
4 i
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- Work Order No.
- NRC-779 Pages 1-58 NEAL R. GROSS AND CO., INC.
1 Court Reporters and Transcribers
- 1323 Rhode Island Avenue, N.W.
! Washington, D.C. 20005 (202) 234-4433 i
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, 1 UNITED STATES OF AMERICA l
.o 2 NUCLEAR REGULATORY COMMISSION i
l 3 +++++ l s i l 4 OFFICE OF INVESTIGATIONS i i ;
5 INTERVIEW 1
6 ------------------------------X i
7 IN THE MATTER OF: + : l 8 INTERVIEW OF : Docket No.
9 WILLIAM RAYMOND : (not assigned) 10 :
11 ------------------------------X 12 Wednesday, July 17, 1996 13 14 Room 215 9
15 NRC Resident's Office 16 Haddam Neck Site 17 Haddam, Connecticut l
i
! 18 19 The above-entitled interview was conducted at 20 12:40 p.m.
21 BEFORE:
22 JOHN HANNON Team Leader 23 CARL MOHRWINKEL Investigator 24 25 NEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1823 RHoDE ISLAND AVE., N.W.
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1 P-R-O-C-E-E-D-I-N-G-S 2 (12:41 p.m.)
3 THE REPORTER: Would you raise your right hand 4 for me, please?
5 Do you swear or affirm under the penalty of 6 perjbry that the testimony you're about to give will be 7 the truth, the whole truth, and nothing but the truth? r 8 MR. RAYMOND: I do. '
l 9 THE REPORTER: Thank you, sir.
, 10 TEAM LEADER RANNON: Good afternoon. Today is i
11 July 17th, 1996. It is approximately 12:45 p.m.
12 My name is John Hannon. I'm here at the l
i 13 Connecticut Yankee plant in Haddam Neck, Connecticut, as 14 the leader of a NRC review team looking into the handling l
15 of employee concerns and allegations at Millstone during l
16 the last ten years.
17 I have with me Carl Mohrwinkel, who will be 18 assisting in the interview this afternoon.
i 19 Normally I'm a Project Director in the Office 20 of Nuclear Reactor Regulation, and I've been assigned to 21 lead this review effort.
22 We're on a fact-finding mission, trying to 23 find out what has gone wrong with the process, if 24 anything, and attempt to develop a factual record that we 25 can use to come up with probable root causes and identify NEAL R. GROSS
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er w . , , - - - - -
,--e-
1 potsntial corrsctiva cetions that could be rscommandad
,, 2 both for NRC and Northeast Utilities to improve the 3 process for future employee concerns and allegations.
4 Our focus is on the process, and it's not our i
5 intention in this interview or in any of the other i
- 6 interviews to assess blame. We wanted to meet with.you, l l
! 7 Mr. Raymond, to obtain your input from an historical 8 perspective since you were involved with the processing of J 9 allegations and employee concerns at Millstone in the i l
l 10 years past. !
1 :
l l 11 We're transcribing this interview for two l
l 12 reasons: one, to permit us to concentrate on what you're i
13 saying and to minimize note taking, and we want to be able 14 to understand and react and ask the right kind of follow-15 up questions,'and also then we'll have a factual document 16 that we can go back to and refer to and deliberate to make 17 sure we've got a good understanding of what you've told I
18 us.
19 The accuracy of your transcript is important.
l 20 So we want to make it available to you when we get it back 21 to have you go through it and make any errata changes, 22 clarifications or changes, to make sure it captures what 23 you wanted to say.
24 It would be our intention to have the 25 transcript placed in the public domain at the conclusion NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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l
=
1 of our rsvicw effort ofter wa iscus our raport.
. 2 That is pretty much the preamble to the 3 interview. Do you have any questions or comments before 4 we get started?
5 MR. RAYMOND: No, John, it's clear.
6 TEAM LEADER HANNON: Okay. Just sort of to 7 set the stage for the purposes of this interview, we 8 reviewed selected Millstone discrimination cases and had a 9 number of interviews with various NU officials and NU 10 employees and developed several questions about the NRC 11 processes for handling licensee employee concerns and 12 allegations. So hopefully in this discussion today you'll 13 help us -- be able to help us understand what NRC's 14 practice in the past has been and what your current 15 understanding of the way it has changed over the time and 16 what it has evolved to today and help us understand more 17 contemporaneously how the -- what the practice is.
18 Some of the questions we may be asking you may 19 have already been dealt with in previous reviews and 20 investigations, and it's not our intent to rehash all of 21 the material. If you have knowledge of where that 22 information might exist in the public domain, you can 23 simply refer us to that.
24 MR. RAYMOND: Okay.
25 TEAM L1ADER HANNON: Also, as I said earlier, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 -
1 it'c not our purpose h2ra to try to cococs blema or to ba 2 -- focus on any personalities. We're -- we're after 3 process issues and concerns, trying to help ourselves come 4 up with some corrective actions. ,
5 So let me ask you, Carl, if you will, to begin 6 the que .oning. That's a little bit of the background of 7 what we're trying to do.
8 MR. RAYMOND: Okay. Thanks for that, John.
9 INVESTIGATOR MOHRWINKEL: Now, Bill, if you 10 could just bring us up to date with your -- a few 11 sentences about your educational background, your training 12 that allowed you to qualify for the kind of job you have 13 here at NRC.
14 MR. RAYMOND: My education is I have a 15 Bachelor's degree in physics, Master's degree in nuclear 16 science and engineering, and that's it for formal 17 education. I had that when I came to the Commission in 18 1975.
19 But prior to joining the Commission, I also 20 worked for about five years for NSSS vendor, Babcock &
21 Wilcox.
22 INVESTIGATOR MOHRWINKEL: NSSS being?
23 MR. RAYMOND: Oh, nuclear steam supply system 24 vendor.
25 And spent five years working with' B&W on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
WASHINGTON, D.C. 20005-3701 (202) 234-4433 (202) 23W
e 1 ctart-up of thair -- covaral of thair pinnto on tha Ecct 2 Coast principally and worked ---my area of specialties was 3 in core physics, core physics measurements, and start-up 4 and test programs, which is the job I was essentially 5 hired for when I came to the Commission in 19'76 -- I'm 6 sorry -- 1976.
7 INVESTIGATOR MOHRWINKEL: And you've been with 8 the Commission since 1975?
9 MR. RAYMOND: True.
10 INVESTIGATOR MOHRWINKEL: With no break in 1
11 service? l 12 MR. RAYMOND: True. ,
13 INVESTIGATOR MOHRWINKEL: Do you hold any 14 professional licenses or --
15 MR. RAYMOND: Well, prior to -- the other 16 thing on qualifications perspective is I did pick up a 17 license, an operator license, at a research reactor. I 18 got my Master's degree at Virginia Tech, and they had a -- j l
19 they had a research reactor there, and I was licensed to 20 operate it.
21 No, but I don't have a license for a ,
l l
22 commercial nuclear power plant. So any other training -
23 I've received since then has been technical, managerial, 24 supervisory type training that the Agency has offered as ,
25 part of their employee development program.
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. _ _ _ . _ _ _ . _ . _7 . _ _ _ . .l 1 INVESTIGATOR MOHRWINKEL: What yoors wara you
. 2 working at Millstone?
i 3 MR. RAYMOND: I started the Millstone I l
4 assignment in July of '87.
i 5 -
INVESTIGATOR MOHRWINKEL: And what were your 6 jobs'at Millstone from '87 on?
7 MR. RAYMOND: It was the senior resident l 8 inspector for all three units, principally. I actually 9 went through the first couple months -- there was still a i
10 senior at Units 1 and 2, and I waa a senior at Unit 3 for j 11 essentially the summer of '87, and then by the f.ill -- I'm 12 going to guess around September of '87 -- I was a senior 13 for all three units and held that until July of '92, when 14 I left that assignment.
l
- f. 15 INVESTIGATOR MOHRWINKEL: So there were four 16 people total there. You were the senior, and they had one 17 resident for each one of the units?
18 MR. RAYMOND: That's the way we broke up the i
19 assignment earlier on. We had a resident for each unit, )
i 20 with myself as the senior. So that's what I was trying to 21 do. I was essentially sp'.itting my time in oversight with 22 the resident on each of the three.
23 And we held that structure for most of that 24 five-year period, but we realized in there that we had to 25 reapportion how we were reassigning our resources, and we l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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. 1 trisd to pull bsck from a strict unit focua cnd used
- 2. residants to double up on areas nacding more attention and
.t.
l 3 more focus,.and so we -- we got the residents then to 1
4 cross unit lines more towards the latter part of my 5 assignment there, and I think they -- I think they j- 6 continued that after I left, but Paul -- Paul Swetland can 1 7 better speak to how they organized and ran things from '92 i
8 on.
j 9 INVESTIGATOR MOHRWINKEL: Well, ao John said, 10 our focus in interviewing you was to try and get a feel 11 for how the allegation process was handled and your views l
12 of how it was handled and your views of any changes that !
1
- 13 may have taken place. So with that in mind, I would ask i 14 you to comment, if you would, on how you personally j 15 handled allegations while you were the senior resident at i
l 16 Millstone that may have come directly to you from a 17 concerned employee. j l
- 18 MR. RAYMOND
- That's a big question, and I'm !
1
- l i -19 not sure what detail. So I'll just give a general !
20 response -- i
{
! 1
- j. 21 INVESTIGATOR MOHRWINKEL: Right.
22 MR. RAYMOND: And then you'll have --
r !
23 INVESTIGATOR MOHRWINKEL: That's fine.
24 MR. RAYMOND: -- to start focusing me.
I 25 INVESTIGATOR MOHRWINKEL: Yeah.
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a
. 1 MR. RAYMOND: But wa handled -- you know, I l
. 2 handled allegations while at Millstone in probably, you 3 know, a broad spectrum from somebody made a call to the l I
4 regional' office with a concern that ultimately would get '
5 forwarded to the resident's site to be dealt with, to one l 6 of the residents picked up a concern while walking through !
7 the plant. It was brought in and we had to -- you know, a we wrote up an allegation receipt form and started it in 9 the process that way, to someone came to me personally to 10 --
and so I was the initiator of a receipt form for 11 follow-up and inspection, to whatever.
12 They would come in from various sources, and 13 to the extent that, you know, I was also the principal -
14 receiver of a concern that was handled under 15 confidentiality. Someone didn't even want to come to me 16 at work. I had to meet with somebody in the Waterford !
17 Library, you know, to get a concern, you know, at one 18 point.
19 And then walk-ins. Clearly, being the NRC 20 office at the site, you had some people that just walked 21 in the door and said, " Hey, I have a concern about 22 something," and so we'd handle them that way. l i
1 23 INVESTIGATOR MOHRWINKEL: So when a person 1 24 approached you personally -- let's talk about those -- and ;
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1 you do with that wh n you wara ct Milletona? How did you
...-~ 2 -- what was the first step you did, and how did you see it 3 through whatever you defined as resolution?
1 4 MR. RAYMOND: We -- we had a process in which j i
5 we get a concern. We recorded it usually through the I l
6 allegation -- you know, an allegation receipt form, and 9 set up a briefing, set up on capturing the concern, two 8 things in parallel. One was an assessmer.J for what the 9 cencern meant to us relative to operational safety to see 10 if there was something -- any sort of immediacy associated 11 with the concern that had to be dealt with right away, but 12 then also frame -- after capturing the facts of the 13 allegation, as part of the allegation receipt, set up a l 14 recommendation for, you know, what do we think should be -
15 - you know, how should this be handled, and that whole 16 process then -- the allegation receipt would be sent 17 through region. There would be an allegation panel.
18 That whole process changed over time, and the 19 way it changed, it became -- allegation panels occurred 20 regularly, like every week, but prior to that it was done 21 on an as needed basis early on, but in any case, you 22 prepared the receipt, the concern receipt form. The 23 information got sent to the region. You decided there was 24 a division of who was going to do what to follow it up.
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AA 1 it up. Somatim30 tha region would d:cida to diepntch 2 somebody if the concern warranted that. A specialist from 3 the region would come up and look into it, or if it was 4 deemed sufficient, the next planned, routine inspection 5 would cover it.
6 That's the general response. Then we --
7 that'.s on the front end. So we usually -- residents, we 8 would either -- I or myself or the residents would i l
9 participate in panel meetings, panel meetings to discuss i l
l 10 the issues, provide additional input, and that was l 11 particularly useful to the staff because even though we 12 had the concern, being there at the site we could gather 13 data about the concern, as well, and bring that 14 information and help the panel make decisions as to what 15 it meant and what needed to be done, and then that helped 16 get the Agency response better formulated. l 17 Then we would be involved on the closecut side ;
1 18 of things in terms of sometimes helping to draft --
19 obviously we covered the concerns in the inspection 20 reports or then we might get involved in the closecut, the 21 drafting of the closecut letters.
22 I need to qualify what I've just said though 23 based upon how things happened over time because that was 24 the process that worked fairly well when you've got just a 25 few concerns coming in, and I think the residents had a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE. N.W.
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1 lot of ownarch'ip on the iscuss from racaiving through
- ,,, 2 inspection through closr e for things that were resident ,
3 issues to handle.
{ 4 That process started getting choked'up when 5 you had a lot of concerns coming in, and the Agency was --
6 we w'orked for a while working issues from the beginning 7 through the end goint, cradle to the grave sort of 8 approach, and after a while that was so much of a burden 9 there was either dedicated resources in the regional staff 10 to help do that, as well as resources sent to the 11 Millstone site to help in that process as well.
12 INVESTIGATOR MOHRWINKEL: If an employee came 13 to you with a concern, did you or the other residents ever 14 screen the allegations to decide whether they had merit or 15 not before dealing with the region on them?
16 MR. RAYMOND: I think what we tried to do is ,
17 you take a concern and you record what you get, and so if 18 you mean by screening -- we don't decide what's a concern 19 and what's not a concern, what to put down and what not to 20 put down. You capture what comes in the door or what's 21 given to you, and then you deliver to management what you 22 think is the merits of the issue or what's the 23 significance of the issue and what's the recommended l 24 approach to following up on the issue.
25 INVESTIGATOR MOHRWINKEL: Which management?
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13 i 1 MR.-RAYMOND: Oh, my mr.ntgamnnt. I'm talking l
l .
2 about --
I i 3 INVESTIGATOR MOHRWINKEL: NRC, okay. i l
4 MR. RAYMOND: -- my management.
j 5 INVESTIGATOR MOHRWINKEL: I wanted to make l
I l 6 sure you weren't talking about NU.
i 7 MR. RAYMOND: No, no.
I 8 INVESTIGATOR MOHRWINKEL: Okay.
9 MR. RAYMOND: My management. Everything I'm 10 saying is all in the context of the NRC process.
11 INVESTIGATOR MOHRWINKEL: Okay. I just wanted i l
I 12 to make sure of that. '
13 So in other words, let me restate this and see 14 if I've got your thought. Any time an NU employee would i 15 come to you with a concern or an allegation or a safety 16 issue, you entered it into the system without question.
17 MR. RAYMOND: Yeah.
18 INVESTIGATOR MOHRWINKEL: Okay.
19 MR. RAYMOND: I believe there's a real good 20 track record of capturing concerns.
21 INVESTIGATOR MOHRWINKEL: Okay.
22 MR. RAYMOND: Now, you always have the -- you 23 know, as a qualifier there is did I write down what he l
24 said, and making sure you captured what he thought the
{
l 25 issue was correctly.
I
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~ . . . .-. -. -- . .. . .. -- .- .-.
1 INVESTIGATOR MOHRWINKEL: Un-huh.
2 MR. RAYMOND: And go, you know, there's a 3 caveat there in how well you capture a concern.
4 INVESTIGATOR MORRWINKEL: But how well you 5 capture it, you get in your own mind -- if you're hearing 6 what he believes he's telling you is perhaps a separate 7 issue, but the concern that I was trying to get at was to
- 8 make certain that every allegation, with your caveat, 9 entered the system. I want to make sure your answer 10 wasn't, " Yeah, occasionally we got some we thought were so ;
11 ridiculous we threw them in the trash can." j 12 MR. RAYMOND: No , no, no. l
- 13 INVESTIGATOR MOHRWINKEL
- And you're not l
14 saying that. So that's fine. I I
15 MR. RAYMOND: I want to make sure --
16 INVESTIGATOR MOHRWINKEL: Yeah.
17 MR. RAYMOND: -- I state that that's how it 18 was. No , we didn't do that. Clearly we tried very hard 19 to give each allegation its due, each concern its due.
20 INVESTIGATOR MOHRWINKELe How do you think the 21 alleger community at Millstone viewed you personally or 22 viewed the NRC residents as a group in terms of 23 responsiveness to employee concerns?
24 MR. RAYMOND: I don't know if there's one 25 answer to that question, Carl. I think some people might NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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1 re: pond wa did a credible' job with their iccusa. I think 2 there's also some other people who would be critical on 3 the job that we did with their issues. So there's --
4 there'F a spectrum.
5 TEAM LEADER E." MON: Un-huh. Why do you think l 6 that's true?
7 MR. RAYMOND: Because they've stated it .
l 8 publicly. j 9 TEAM LEADER HANNON: No, no. But I mean 10 what's behind it? Why did they feel that way do you 11 think?
12 MR. RAYMOND: Well, the issues that I have --
l 13 the concerns that I have in mind are not on how we i 14 dispositioned technical issues. I don't think there's a 15 criticism there, although there might be one in regard to 16 timeliness of dispositioning of certain issues, and we can l l
17 talk specifics if you want to, such as how well the Agency 18 dealt with the Rosemont issue generically across the 19 board, you know, for all plants, not necessarily 20 Millstone.
21 I think there was a -- there would be an 22 agreement with the staff and allegers that the issue was l 23 handled at Millstone, but it was not necessarily handled 24 on a timely manner across the -- across the country at 25 other plants.
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.o l
1 But in any essa, my thought was on technien1
?- 2 issues there should be a general consensus that we 3 dispositioned technical issues acceptably. On the 4 handling of employee concerns and, in particular, in the i 5 area of protecting people from harassment and I
6 intimidation, I know there's people who feel that the 7 Agency, the NRC and/or DOL, could do better on providing 8 employee protection. So in that regard there would be 9 criticism.
10 INVESTIGATOR MOHRWINKEL: Do you think that 11 criticism is fair or accurate relative to the NRC?
12 MR. RAYMOND: I want to give -- I don't know.
l 4
13 We'd have to know what a specific critique is. So I'm ;
14 going to give you a specific point. Let's get focused.
15 INVESTIGATOR MOHRWINKEL: Yeah.
16 MR. RAYMOND: I think there's merit to the 17 criticism that says it takes too long to process a DOL 18 issue or -- and I don't know what the answer to that is. '
19 I don't know if there needs to be a better interface 20 between NRC or DOL, or if the Agency needs to be a better 21 proponent for the alleger as part of -- as part of their 22 process, or if NRC needs to have more legislative 23 authority to follow through on issues. I don't know what 24 the right response is, but I can anderstand from an 25 alleger's point of view how if I raised a concern and I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 rho 0E ISLAND AVE., N.W.
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~
1 wno truly wronged by my cmployar for rcicing that concern, 2 that the process that they had to go through, you know, 3 over -- which could take years and lots of lawyer time and 4 lots of out-of-pocket expenses to get through, how that 5 could be unfair, and then the process is not serving that 6 individual well. ,
1 7 INVESTIGATOR MOHRWINKEL: When you received l l
8 allegations from, again, NU employees, do you ever -- do 9 you have a recollection of ever going to discuss the i
10 concern with NU management prior to or simul'taneously to 1
11 entering it into the NRC system? l 12 MR. RAYMOND: Not as a concern.
13 INVESTIGATOR MOHRWINKEL: But as a --
14 MR. RAYMOND: Not as an allegation received.
15 INVESTIGATOR MOHRWINKEL: How then?
16 MR. RAYMOND: If you have a technical issue 17 that you know is a topic that -- about which you need more 18 information in order to decide its significance or not, 19 you had to work that into your inspection somehow, and on 20 those occasions you'd have to get into the topic with NU
< 21 management.
22 But you get into the topic, you know, on the 23 basis of " hey, this is no different than any other thing,"
24 from their perspective, "than anything else I was going to 25 try to inspect today."
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. . .. - . ~ - - - - . . . . . . . . - - ... - - . . -.-.- .
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' {
1 INVESTIGATOR MOHRWINKEL: Whsn thay --
.. 2 MR. RAYMOND: As opposed to walking into --
. 3 you know, how it wasn't, you don't get a concern and then 4 you go to the Superintendent's office and say, " Hey, I l
5 just got an allegation that said you did X. You know, is 6 this true or not?" That was not -- that was not how you .
i 7 did it.
8 TEAM LEADER HANNON: Okay, but one of the 9 inputs we've received through other interviews during the
) 10 course of this review has suggested that our process when 11 we do that, when we go to NU in your case, NU management, i
s 12 directly with a concern no matter how it's presented, that
- 13 it has the effect of fingerprinting the individual who has 14 -- who has raised that concern.
I 15 MR. RAYMOND: I think that that is a 16 vulnerability to what you're doing, and when we're 17 finished talking -- when I finished talking and you
] 18 started talking, I realized I need to qualify my previous 19 answer, too, because at Millstone -- maybe it's different y
20 at Millstone than anyplace else. I don't know -- we got 21 into a mode in which it was clear there were issues that
- 22 were being turned over to the utility, that they, the I 23 utility, probably knew it came through the allegation i 24 process.
25 And what I mean by that is I can't -- you NEAL R. GROSS j COURT REPORTERS AND TRANSCRISERS 1323 RHoDE ISLAND AVE., N.W.
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1 know, without looking at records, figuring out exsetly -- l ett '
2 know whora exnctly to put this in time, but we got into a 3 mode where we would receive allegations. They would get ;
1 4 paneled. The decision by the panel would be to turn them i 5 over-to NU for follow-up, and there essentially was a 6 letter that was sent to the Vice President at the time 7 that said, "We understand there are these concerns. You 8 should look into them and respond back within so many 9 days," and then we would do a back side review on that.
- 10 So, you know, we were operating in that mode 11 for a while, but that was always from the Region I -- you 12 know, there was a letter issued from the region.
13 INVESTIGATOR MOHRWINKEL: Now you testified --
14 I understand your point there -- you said when we got the 15 licensee response, we did a back side review. As John-16 said a minute ago, we have heard some criticism, and 17 that's what's driven seme of these questions, of the whole 18 process, and one of the concerns, one of the criticisms 19 that we have received from the alleger community was that ]
20 oftentimes on these licensee referrals of allegations, NRC 21 accepted the licensee response as gospel and filed it away 1
22 and that was the end of it, without going and doing some !
l 23 follow-up to see if the licensee's response was 24 reasonable, credible, made sense, whatever, and that was a 25 criticism. ;
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20 1 I'm wondaring now you just said wa did a back
. 2 end follow-up.
3 MR. RAYMOND: Yeah.
J 4 INVESTIGATOR MOHRWINKEL: But could you talk a little bit about that and was that universal or was that 5
i 6 occasional'or how did that work?
7 MR. RAYMOND: I think we didn't just take the 8 responses and file them away. We had a deliberate l 9 process. Part of our process was to review responses and 10 then do a follow-up review or inspection of the adequacy 1
11 of the -- not only the response, but the corrective
- 12 actions that were taken just as you would with any other
] 13 corrective action program problem.
14 Let's say if the issue dealt with a problem 15 with tagging, let's say, or it was a tagging issue that 16 was part of the original allegation. Were their
}
l 17 corrective actions to fix tagging program processes for 4
18 problems adequate enough? And that was a very deliberate 19 thing because not only did residents do it, do follow up j
20 of allegations; the region sent inspectors or sometimes 21 even teams of inspectors to Millstone to follow up on i
j 22 issues, questions that were raised about program or 23 processes problems through the -- through the allegation
. 24 process. I mean not only just allegation, but also using 4
25 resident inspection inputs or indicators of problems.
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21 1 Th;ra wara vary daliberate follow-ups.
- 2 I mean so we could tick of some examples.
3 Jack Durr, then acting as -- who's presently a Branch 4 Chief for Millstone -- I'm trying to think what his 5 position was back in '88. It was probably at least a 6 section chief, may have been a branch chief back then, 7 too. I can't remember, but Jack Durr came to this site, 8 came to Millstone. I think it was in '89 with a group of 9 people and did a very focused review of program areas that 10 was focused as a result of allegations that we had 11 received.
12 Skipping forward in time, Scott Stewart was a 13 project engineer in the region who also came to the site 14 and did very focused reviews on Millstone programs or 15 processes, focusing on areas that had been raised as 16 problems within the allegation process for which NU had 17 given us a response and for which he judged the adequacy 18 of their follow-up.
19 And there's a couple other examples like that.
20 There was a -- I forget the name of it -- but it was an 21 OSTI type of inspection that was done.
22 INVESTIGATOR MOHRWINKEI,: OSTI is 23 Operational --
24 MR. RAYMOND: Operational Safety Team 25 Inspection that was done prior to '92 because, you know, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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- i 1 it was before I left, in which thara wco'maybn a dozsn l 2 people at the site following up on a broad spectrum. I 1
3 mean t.he inspection scope for that was rather broad, but 4 it was also to focus in on areas that had been, you know, 5 suspect or were of a concern as a result of inputs, 6 including inputs from the allegation arena.
7 So that's my general answer. Now, was there a 8 specific issue that somebody's got in mind -- not you, not 9 the team -- but someone who talked to the team might -- a 10 specific issue that they felt we turned over to the 11 licensee and the licensee's-response was inadequate and he ;
12 didn't see?
13 INVESTIGATOR MOHRWINKEL: Well --
14 MR. RAYMOND: I can't say there wasn't one.
15 INVESTIGATOR MOHRWINKEL: I don't want to get 16 into specific issues.
17 MR. RAYMOND: Specifics.
l 18 INVESTIGATOR MOHRWINKEL: But let's talk from 1 19 a boarder, a process orientation. The sensitivity on the i
20
~
part of the resident staff in general to the employees 21 that are bringing concerns forward, how sensitive do you 22 think, in general, you were back in the late '80s to the 23 concern that these guys may be getting harassed and 24 intimidated by their employer because they brought issues 25 to you?
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1 What 1svol of censitivity do you think exicted ;
i 2 back in those dsya?
- /..
3 MR. RAYMOND: I'm not sure how to -- how to !
4 answer the question, sensitivity. We would have -- we 5 would have held -- I mean, you know, I forget when 50.7 f 6 came into being, but it was probably close'to around that f 7 time. As a new regulation, we were attuned to it. We l
8 were attuned to making sure there was not H&I for raising )
9 safety concerns. We were attuned to or sensitive to 10 making sure even if you had an allegation about H&I that 11 had to go through the whole DOL /OI mill and review process
~
12 that there wasn't a chilling effect, which is why the
/
13 region kicked out chilling effects --
14 INVESTIGATOR MOHRWINKEL: Yeah, but I think 15 you're in the early '90s time frame now.
l 16 MR. RAYMOND: Oh, before '90s.
17 INVESTIGATOR MOHRWINKEL: Because when --
18 50.77 19 TEAM LEADER HANNON: Yeah, I want to say late 20 '80s, September '89, but I'm not positive. I think that 21 was approximately the time frame that came out.
22 INVESTIGATOR MORRWINKEL: Okay.
23 TEAM LEADER HANNON: Does that sound.right to 24 you, September '89, somewhere?
25 MR. RAYMOND: I can't -- I can't say yes or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N W.
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. .. 1 no , but --
} _
2 INVESTIGATOR MOHRWINKEL: But I'm apaaking for >
- .. -r if 3 the time period prior to that regulation. What was the j
4 staff sensitivity during those years? Do you have a feel 5 for that?
t-6 MR. RAYMOND: Well, I think my general feeling l-7 is that we were sensitive to making sure people'could get '
j 8 their issues processed without harassment and 1
) 9 intimidation, even if it was for a period without the j 10 force of a regulation. I think the Agency had that.
11 INVESTIGATOR MOHRWINKEL: To what extent do i 12 you think you were trained to be -- to have that i
13 sensitivity? W#as there any specific training you
) 14 received to heighten your awareness and sensitivity to the l ,
15 potential for H&I?
1 l '16 MR. RAYMOND: I don't know if I can put my i
- 17 finger on a certain training program, no.
I
- 18 INVESTIGATOR MOHRWINKEL
- Okay.
) 19 TEAM LEADER HANNON: I'm just looking here at f 20 50.7 in the CFR, and it doesn't show what date this came i
j 21 into -- this is Code of Federal Regulations -- but it 22 doesn't say what date 50.7 became effective, but my 23 recollection --
J I. 24 MR. RAYMOND: Late '80s.
25 TEAM LEkDER HANNON: --
it sounds like -- I i
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, . w. - - ,.- -
,W .s - - - *s ..RJJ. 4 a as Am__-._J. -w: .d__4 se A A 4, si 4 m.2Aa._as.wm. _ ._2..m,y. EL2p. I..,.A.a4 d_ J,.
b 1 think it w:o loto '89, but I'm not 100 parcant poaltiva on 2 that.
3 MR. RAYMOND: Yeah, I vaguely recollect it 4
4 wasn't in place when I first started at Millstone, but l
- 5 then came into -- came into being.
i i
J
- 6 INVESTIGATOR MOHRWINKEL: So whatever 7 sensitivity you would have had for that issue in those 8 early days would have been your own -- from your own 1 l
9 instincts. There was no training you can -- l I
10 MR. RAYMOND: Just -- !
i l
l 11 INVESTIGATOR MORRWINKEL: -- recall or any !
l j 12 programmatic approach that --
l 13 MR. RAYMOND: Yeah.
14 INVESTIGATOR MOHRWINKEL: -- the Agency was 15 taking? !
4 4
16 MR. RAYMOND: Or I want to make it less 17 personal. I mean obviously as an individual or as a 18 professional or as an inspector, you had a sense for ;
19 what's right or what's wrong on how to handle issues, but 20 it wasn't just -
- I think there was an Agency, i e., me, .
21 myself, and my lines management, that had a general 22 consensus as to how you -- what the expectations would be l 23 on how a utility would handle safety concerns, and clearly 24 harassing people, a person for raising concerns was not - -
25 would not have been accepted or acceptable.
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- , 26 1 INVESTIGATOR MOHRWINKEL
- In retro 2 pact now 2 when you look back, and you've probably spent --
3 MR. RAYMOND: Now, therc's a question ce i 4 didn't fully answer.
t 5 INVESTIGATOR MOHRWINKEL: Okay.
6 MR. RAYMOND: And that was: was there a way 7 in which we handled allegations that didn't lend itself to 3
8 protecting people's identities? And I think we did do 9 things earlier on that didn't do as good a job doing that 10 as we could have been. In particular, if you go into a --
11 if you look at some of the earlier Millstone reports, we 12 for a while were record -- when we discussed an issue, we
- 13 put an allegation number tag with the issue, which was a 4
14 good'way for us to keep track of how we -- how we brought 15 an issue to closure, but probably put an unnecessary tag
. 16 on the issue in the public record.
17 Now, I don't think there was a way that an 18 allegation number could be traced to an individual, but 19 certain topics could easily be traced to, you know, an
- 20 individual at a site, and so there was probably a public l 21 record that -- that didn't protect, you know, alleger i
- 22 confidentiality as good as it could have, even though we 23 never named the person's name.
24 Do you see the point there?
]
25 INVESTIGATOR MOHRWINKEL: Yes.
t j NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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.- - . . . - -.-. . - . . . ~ . . . . . _ . ~ _ _
~~.--~.-.-~~~.~_-..-
j
i
'1' MR. RAYMUND: .And than wa.recognizsd that.
l,,
1 2 We, the region, as a team, we recognized that and stopped i i
3- doing that. So that whenever we gave coverage to an h- 4 allegation issue in an inspection report, it was I j 5 transparent as to how we got to that topic.
- 6 INVESTIGATOR MOHRWINKEL: Well, actually your
} 7 amplification of your previous answer sort of answers the ;
8 question I was-going to ask, but I'll ask it anyway. Now ]
l 9 with hindsight from several years away and with al1~the l 10 effort that's being put on Millstone and the situation 11 there and all the thinking I'm sure you did in
! 12 anticipation of meeting with John and myself today and all L
! 13 those things having to do with Millstone, in retrospect is
! 14 there anything significant perhaps other.than what you 1
j-15 just said that you would have done differently as a person i 16 or as the Senior Resident or is there anything you would
- - 17. have suggested to the NRC in the time frame you were the i 18 Senior Resident that the NRC should have done different to 19 make the allegations program run better?
i 20 MR. RAYMOND: That's too broad of a question,
- 21 Carl. I don't have the big picture answer.
) 22 INVESTIGATOR MOHRWINKEL: Okay.
23 MR. RAYMOND: Why did it not work at Millstone 24 and what can we do to make it better? I'm sorry. I just 25 don't have the --
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~ ' '
I 28 l 1 INVESTIGATOR MOHRWINKEL: Okty.
2 MR. RAYMOND: -- I don't have the big picture 3 answer.
l ,
4 INVESTIGATOR MOHRWINKEL: Let me try a 5 different approach on that one then. You made reference 6 to 8.8 and the changes that have been made and now you're ;
7 working with the new 8.8 that just recently came out here 8 at Connecticut Yankee. Do you think that the new 8.8 has l 9 improved the process? Do you think we're better serving l l
the alleger community than we were previously based upon 1
10 !
11 the new 8.87 12 MR. RAYMOND: Oh, yes.
13 INVESTIGATOR MOHRWINKEL: You do. Okay.
l 14 MR. RAYMOND: Yes.
l 15 INVESTIGATOR MOHRWINKEL: Do you see today 16 areas in which we could still improve and if so, what 17 would those be just for looking ahead?
18 MR. RAYMOND: I'll go back to what I --
just 19 to under. score what I said earlier, that I'm not sure we '
l 20 still can't do more to protect the guy who has been l
l 21 harassed or intimidated, to bringing that case to full
! 22 review and closure on a more timely basis just to -- just 23 to disposition it, and do that in such a manner that is
- 24 fair to both sides because the utilities, they need to 25 have their due process as well.
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, 1 I don't know what cocuroc thnt. I 2 INVESTIGATOR MOHRWINKEL: How -- I 3 MR. RAYMOND: Now, let me -- I thought about 1
4 something else though as I was answering that question. I j l
5 have this feeling though, too, looking back at the l 6 Millstone experience that the process that we had was too 7 cumbersome. When you had dozens or hundreds of 1
8 allegations to process and I don't know what the answer is 9 on that, as to how to solve that, but it just became very 10 cumbersome. i 11 TEAM LEADER HANNON: Well, let me follow that l
12 if I could expand that thought a minute. You already 13 indicated what the process you were going through to deal 14 with the issues to get them evaluated, and one of the 15 concerns that we have heard expressed is that the NRC l 16 tended to deminimize (phonetic) issues they thought had
! 17 low safety significance, and apparently didn't address the i
18 potential for regulatory significance; it may have low I 19 safety significance, but it's not something you just l
20 should walk away from.
21 And the sense that I've gained is that maybe 1
22 we walked away from things in the past that had low safety 23 significance, but have later come around to burn us l
24 because they have high regulatory significance.
l 25 What is your view on that?
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1 MR. RAYMOND: I think wa tricd to Ccticfy 2 both, and maybe we need to get into talking about specific l
3 issues or specific programs or specific areas of concern, 4 but you know, through my tenu: e at Millstone one area that 5 came under a lot of scrutiny was the tagging program and 6 processes and problems, and we tried -- with every 7 concern, we did a -- we did -- assigned safety 8 significance to the issue, and we treated it then -- could l 9 measure it with the safety significance in a manner 10 similar to any other issue that would come to us, whether 11 it, you know, came from an alleger or it came from an 12 inspector observation or it came from a licensee finding.
13 We always measured things through their safety j 14 significance, and then more significant things get quicker 15 follow-up and resolution to make sure that the plant is 16 safe or there is a basis for continued plant operations.
17 But I think we also kept a focus on program 18 compliance and program performance and things that were, l
19 quote, regulatory significance. Now, there might be 20 differing views as to how good or bad a program was 21 depending on how many areas you had, but we were always
-22 trying to measure what was the -- what was the health of l 23 the tagging program, and that -- we did that through the l
l 24 follow-up inspections that I mentioned to you.
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l 31 la l 1 at tha oito with tha cora progrcm that routinaly hnd you i 2 looking at tagging, as well as a bunch of other things, 3 you had continual inputs from which you were able to i
4 speak. Well, what's the overall health of this program or 5 process and is it really broke or does it have weaknesses?
I 6 I think we were making those assessments as we l
7 went. Now, there might be differing opinions as to how we i
8 -- the conclusions we reached and whether we could have !
i !
i 9 gotten to a conclusion sooner that said the whole process l l
10 was in breakdown or not. I mean, you can always second l
l 11 guess that, but I think we were trying to address it. J l l l
l 12 But was there a specific area you wanted to --
l l
l 13 I answered it within the context of tagging.
l 14 TEAM LEADER HANNON: I think that your answer 15 is a fair response to that question. I just wanted to get l
l 16 your thoughts.
l 17 Also, have you been involved -- were you I 18 involved with any enforcement actions for -- that came out i
! 19 of an H&I concern?
20 MR. RAYMOND: Oh, yes. I was. I mean several i
21 things during -- several issues during my five years at 22 Millstone went to enforcement for either on the merits of 23 the technical issue or as well as on the merits of the H&I l
24 issue.
25 TEAM LEADER HANNON: Okay. Just focusing on NEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N W.
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!._ _ __ 32 ,
1 1 tha H&I enforcamsnt actions, in hindaight what ic your l4 2 opinion on the adequacy of the enforcement that the Agency
! 3 took?
! l
( 4 MR. RAYMOND: Clearly at the time that we were 5 contemporaneous with handling the issues, I felt the i
~
6 actions were the right and proper actions in accordance 7 with our policy, the enforcement policy.
l 8 Now, do I think that -- do I have an opinion l 9 on that today looking backwards? I don't think I've got a i l
10 basis to answer any differently, that I think the present ;
l 11 policy is adequate, and again, that's just from an l 12 inspector's point of view. That's not the result of any 13 broad study of the enforcement policy or its adequacy, and l
l 14 I'm aware -- oh, by the way, I'm aware that our Inspector ;
j 15 General's Office, you know, within the last two years has l 16 come out with a report on that that says the Agency could l
17 do better in protecting whistle blowers.
18 Even with that in mind, I think the present ;
l 19 policy probably has enough latitude to get the job done, 20 but that's just my opinion.
21 TEAM LEADER HANNON: Okay.
l-j' 22 INVESTIGATOR MOHRWINKEL: How well do you 23 think new residents coming to Millstone or any other site 24 are trained in terms of what's going to be expected of i
! 25 them in terms of the allegation program and in terms of i
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, . . ... . . - . - . . .. - - . _ . . . _ . _ . . _ . . . - . _ . , . . . _ - - =
I tha technical cnd plcnt cpacific knowicdga thsy nasd to-
)
2 hevo? I i ,l. l 3 MR. RAYMOND: Present day it's good and it's !
4 l better than probably it was earlier on because we've i a
5 always had - "always." I've got to qualify my remarks 6 because I tend to generalize too much -- but I can 7 remember getting allegation training on how to handle l
8 allegations from the region as an inspector going back to-
! 9 certainly before I started at Millstone. I can't remember 10 how frequently you got that training or those types of j 11 specifics way back when, but present day it's more 12 deliberate. It's more regular. It's done in the form of
[ 13 the counterpart meetings when we go down to the region 14 once or twice a year.
15 You know, I don't remember whether we get it l
l 16 every time we go or probably every other time we go, but l
l 17 it's definitely once a year. So it's getting more t
i 18 focused.
19 TEAM LEADER HANNON: How are you held
'20 accountable to and what are the standards you're held l
l l
l 21 accountable to today, in today's environment? !
l i
22 MR. RAYMOND: Notice of the allegations? ;
23 TEAM LEADER HANNON: Yes.
24 MR. RAYMOND: My accountability is to i l
- 25 implement those portions of the allegation receipt process
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. 1 at tha 1sval of my'intorfcca with tha plcnt cnd/or public
.- 2 hare at tha oite end to making sura that whan I gat I
3 concerns, I get it captured and brought it to the system ,
i 4 and follow up on items that have immediacy and do ;
5 independent assessment, you know, of the issue, or if the 6 things aren't immediate, get it down to the panel and let 7 the panel decide what needs to be done and what the Agency 1
8 response should be. That's what I'm accountable to do. ;
, i i 9 TEAM LEADER HANNON: Is that part of your !
1 10 performance appraisal that you're appraised on annually?
11 MR. RAYMOND: Yes, there is one of the i l l I
12 performance elements. I'd have to look at it, but it's 13 measured. There is an opportunity to assess, I think.
14 Now, allegations, you know, I mean, numbers of 15 allegations received are different for different sites.
16 So, you know, during my time at Millstone, I don't have a l
17 hard and fast number, but it took a large percentage of l
i 18 our time, I mean, and I won't try to put numbers on it, 1
19 but it took an inordinate amount of our time. i l'
20 Whereas here or other plants that I've been l
21 assigned to, the time that I spend processing allegations ;
)
22 is very small because of the relatively few number of them 23 that have to come through.
24 TEAM LEADER HANNON: But there is a 25 performance element in your performance elements and i
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,. ctendnrds now th t you're epprciosd cgninct on cn ennuni-i
. -- 2 basia. Has that always bosn trua or -- !'
.i; i
3 MR. RAYMOND: I think --
! i j 4 TEAM LEADER HANNON: -- is it a recent i l !
5 development-or when did that become effective?
l l 6 MR. RAYMOND: I don't -- I can't say 1 ,
7 definitively without look at --
)
?
8 TEAM LEADER HANNON: Do you recall having been 9 appraised on your performance at Millstone for how 10 allegations were being handled? !
1 11 MR. RAYMOND: In general, I think I could l l
12 probably find -- excuse me -- I think I could probably :
13 find a performance appraisal that made reference to 14 handling of allegations, and I know in performance 15 appraisals that I wrote for my subordinates at Millstone i
16 on units that had a high allegations work load, that I l 17 recognized resident inspector performance on that ]
18 processing and handling of allegations. I think I could 19 find a performance appraisal that said that. ]
. J 20 TEAM LEADER HANNON: Okay. One of the !
21 concerns that we have right now is historically there may 1
22 have been a diffuse accountability, and I think maybe the 23 evolution of the management directives --
!. 24 MR. RAYMOND: This is an internal concern?
I I 25 TEAM LEADER HANNON: Internal, yeah.
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i 1 1 -- hnva ottemptsd to be mora offectiva in l
l.. 2 terms of having individuals held accountable for how That's why I was asking you I 3 allegations are processed.
l 4 what your recollection was at Millstone, j l
5 MR. RAYMOND: The process changed through the I 6 years, John. So we would have to try to get specific in l l
7 terms of who was responsible for v'4at in any one .
8 particular day, at any one poi:c in time. For a while 9 projects handled -- had responsibility for a large part of
- 10 the program, but as -- I'm talking very general terms and 11 very much, you know, as best as I can recall.
12 As the amount of allegation work load 13 increased, they started giving more -- better definition l
14 to internal handling of the process within the region.
15 Allegation coordinator had a more -- I'm going to 16 hesitate. I don't want to get too exact on what people !
17 were doing down there since I was so far removed from l
18 them, but from my perception way out in the field, the l 19 allegation coordinator was -- had a more defined role on l
20 processing, piece-wise processing of issues and keeping 21 track of them.
22 So maybe prior to a certain time or prior to a 23 certain milestone on our internal procedure the process 24 may have been too diffuse. Maybe I can understand that 25 now. I don't know if I knew enough about it to be able to NEAL R. GROSS
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1 giva you thnt concarnfrommyharcpbetiva.
2 TEAM LEADER HANNON: Wall, let m2 --
3 MR. RAYMOND: Because my role is always
- 4 defined. You're here, and you're on the front line, and 5 when_you get them, you've got to deal with it. It doesn't 6 make'any difference where it comes from. If it's a safety 7 issue, you've got to deal with it.
8 INVESTIGATOR MOHRWINKEL: I want to make sure 9 I understand what you're saying though. I think I heard 10 you say that at some point in the past historically there 11 was an allegation coordinator, and that was the focal 12 point, and that seemed to be working pretty well in your 13 mind. Then that disintegrated somewhat, and now you see i
14 it better. Is that what you kind of said?
15 MR. RAYMOND: If I did, I didn't intend it j l
4 16 that way. You know --
17 INVESTIGATOR MOHRWINKEL: Well, I heard you 18 say at some point in time there was an allegation 19 coordinator, and that person was responsible for being I 20 think you used the word " focal point."
l 21 MR. RAYMOND: I think it's reversed, Carl, and 22 again, I say this with a lot of caveats because I'm not 23 sure how accurate my recollection is or how good my 24 perspective was, but I was going to -- I thought it was 25 maybe the opposite, that maybe the projects did handle NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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d 1 allsgationo cc th3y ccma in on a ceca-by-ense bacio, and
,,,. 2 I'm not sure what involvement or what role there was by 3 the allegation coordinator or how long the allegation !
I 4 coordinator existed. !
5 TEAM LEADER HANNON: Well, let's clarify.
6 When you say " allegation coordinator" --
7 MR. RAYMOND: But then -- but then --
l l
8 TEAM LEADER HANNON: -- are you talking about 9 the region or are you talking about the headquarters 10 person?
11 MR. RAYMOND: Oh , the region.
12 TEAM LEADER HANNON: Okay.
13 MR. RAYMOND: The region.
14 TEAM LEADER HANNON: Okay.
15 MR. RAYMOND: Now, maybe someone is going to 16 say, " Hey, geez, we had an allegation coordinator for 20 17 years," and so maybe my recollection isn't all that good, 18 but I think in later years -- let's get focused on my --
19 my assignment at Millstone. In the latter part of my 20 assignment at Millstone, I think there was a more 1
21 structured approach on how allegations came in and were j l
22 tracked through the -- and tracked through a formal l 23 process within the region. That was clearly more evident 24 later, later in my five-year assignment than earlier in my 25 five-year assignment, but you've got to take that with a j l
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, 1 grain of colt becaues thare could hava besn c lot thnt was J
.t.
2 going on within tha rsgion that just wasn't visible to me.
3 So I'm not sure how valuable that input is.
4 TEAM LEADER HANNON: How do you view the 5 Region I allegacion coordination function today? Good, i
6 bad, indifferent?
7 MR. RAYMOND: Good.
8 TEAM LEADER HANNON: Good?
9 MR. RAYMOND: Overall good.
10 TEAM LEADER HANNON: Okay. Do you think they 11 have enough support? Again, that's perhaps an unfair 12 question because you're out here in the field, but from 13 what you can see, do you think they have enough resources i
14 in Region I to do an adequate job of overseeing the 15 allegation program? Do you have a feel for that?
16 MR. RAYMOND: A very qualified yes. Again, my
- 17 only measure of that is I have occasion to go in, and 18 recently I've had an occasion to go in -- to go in and 19 have to review allegation files, and my experience has 20 been -- is those issues, those files are well laid out and 21 organized, and I can get all the information as a user of I i
22 that system. I can get what I needed out of it very 23 easily.
4 24 So from an endpoint user's point of view, I 25 think it's great now. If you asked the same question to
. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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40 1 tha p2ople h ving to do cll that, mayb2 th;y nand ten mora !
2 people to get to that point and they're working, you know, 3 triple overtime or something. I can't speak to that, you 4 know. ,
l 1 5 TEAM LEADER HANNON: Okay. Can we take a I
6 short break? j 7 (Whereupon, the foregoing matter went off the l
8 record at 1:32 p.m. and went back on the l
1 1 9 record at 1:40 p.m.)
10 MR. RAYMOND: Okay. After I thought about --
11 during the break I thought about some of the things I've 12 been saying, and thinking about it I realized I might be 13 painting what could be taken as too rosy of a picture, you 14 know, about the process, and so I want to speak to that a 15 little bit.
16 I don't want to try to give you or anybody the 17 impression that the process we had was perfect. It 18 clearly was not perfect. From the point of view of an ;
i 19 administrative mechanism for handling concerns and 20 processing issues, I think there's room for improvement 21 before. There's probably ways we could find to improve it 22 today.
23 But from the point of view of getting safety 24 issues and getting them into the Agency and for dealing 25 with them and dispositioning them, I think the process NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 rho 0E ISLAND AVE., N.W.
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1 csrvad us wall. I think -- I think wa used it to en input l
. , , . 2 that we get from a vast variety of places to help us 3 measure how safe is a reactor or is the reactor being .
l 4 operated well or not well?
( 5 I'think we served the process well, and the ;
I i
- 6 process served us well to be able to assure ongoing plant i 7 safety. That's the extra thought I wanted to get in onto l 8 it. '
t l
l 9 TEAM LEADER HANNON: Could you elaborate on L .
I 10 what you thought could have been -- how the process might i . .
i 11 have been improved, particularly with regard to corrective 12 action follow-up and responsiveness on the part of the NRC ;
13 to the particular alleger's concerns?
-l
! l l
14 MR. RAYMOND: Yeah. In responsiveness, I l i
15 think we were responsive to individual inputs to the 16 extent that when an allegation comes in and until you have 17 a chance to validate how good the information is or the is assertion is or is not, you treat it as this is how it is.
19 If someone-thinks it's unsafe, you treat it, you know, as 20 that plant'or that program was unsafe until you -- until 21 you proved otherwise.
22 And at the inspector level we always gave 23 allegations that came in, employee concerns, the highest 24 of priority. They would very often supersede priority !
25 given to any other planned work activity that we had l NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS i i 1323 RHODE ISLAND AVE., N W.
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,-. , , -r-- . . - - , . , , - -- , - ~ , . , -. -. -, .-,-
, .- . . .._ _ - _ - - . . . . . - . - . - . - - . . . . ~ . . . - . - - . ~ - - - . - . -
~42
- 1 eithar that dry or comatimaa that waak. So in that i'
i-2 regard,'I think we were very -- we, the staff, was very 3 responsive to employee concerns.
4 Now, how responsive we appeared to somebody
- _5 else on t'he back - Din the back end of the process once i
! 6 we'Ve gotten the concern and put it into our perspective 7 as to what does this input mean to our view on a program j j 8 performance, or plant performance, et cetera? Somebody
, 9- else might have a different perspective that-says we 10 weren't responsive, but-I think we -- you know,._from my
{
t' 11 perspective we were-responsive on getting issues in, I' 12 taking -- pulling them apart, understanding what they 3
13' meant to us, and then acting accordingly.
j 14 INVESTIGATOR MOHRWINKEL: You just raised a 15 question in my mind by your comment. Let me ask you this 16 question. This question may be more appropriately asked 17 of somebody at a higher organizational level than 18 yourself,'but because you touched upon it, I want to 19 specifically ask and see what your reaction is.
20 Do you feel that NU plants are getting an-21 inordinate amount of attention at the expensive of other !
22 plants that may also have similar problems that the NRC i 23 may be inadvertently overlooking due to resources being 24 concentrated at NU?
25 MR. RAYMOND: Look, Carl. I'm not sure how --
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l .
43 1 thtt's a big quoction.
i 4 2 INVESTIGATOR MOHRWINKEL: Well, it may be more 3 appropriate for somebody at a higher pay grade than 4 yourself, but you did touch upon, you know, resource i l
5 questions and focusing on NU and so on. I just had that 6 question.
1 7 MR. RAYMOND: Yeah, I'm going to pull back to 8 try to answer --
9 INVESTIGATOR MORRWINKEL: That's fine.
10 MR. RAYMOND: -- that question without the !
11 benefit of more input or study relative to everybody else, 12 but --
13 TEAM LEADER HANNON: Let me though play the 14 devil's advocate on the comment about your responsiveness, l
15 and how do you respond to the assertion that, okay, maybe 16 you did deal with the issue on the front end as quickly as 17 you've just said, but as far as the corrective action l
18 follow-up, could you comment on how you thought the NRC 19 did during your tenure at Millstone to follow up ]
20 corrective action that may have been implemented by the 21 utility?
22 MR. RAYMOND: And I think I'm going to give 23 you a two-step answer there. I think at the time I 24 thought we were responding appropriately. I think the inputs that we had about program problems and processes t
i 25 i
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I wara b31ng accacesd, and utility cetions wara ravicwId l 2 for, you'know, overall -- I guess I've got to get 4
i 3 specific. There were issues on procedure compliance.
4 There were issues on adequacy of the tagging program or 5 adequacy -- or adequacy of procedures, and through 6 allegation inputs as well as any other -- all other 7 inputs, there was a recognition from the late '80s through !
8 the early '90s that performance was on the decline, and I 9 think we assessed -- the record will show we assessed that 10 decline, and we were -- we, the NRC, were engaged with the 11 utility then to get them to first recognize that and then 4
, 12 deal with that.
! 13 And at the time we believed that their i
14 response in our -- their response was appropriate to try 15 to address the issues, and, again, you have to put this i
16 within the framework of we had to have an assessment at j i i 17 the time as were the program problems weak enough or poor l 18 enough that you're in total breakdown so that the plant 19 shouldn't operate or was there a weakness there that i 20 needed to be addressed before, you know, things got out of l 21 control, and it was okay for the plant to operate as they i 22 -- aus they continued working these problems.
23 And clearly through '91 '92, we were in the 24 latter mode. We thought they were degrading -- signs of 25 degrading performance. There was a need for performance NEAL R. GROSS COURT REPORTERS AND TRANSCRISERS 1323 RHODE ISt.AND AVE., N.W.
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1 Gnhnnesm:nt progrcm. Th:t's why thsre waa o PEP, cnd wa
,,..-s 2 felt initially that the things that we were going to do to a
3 affect those -- to arrest that performance decline and to 4 fix those problems was adequate.
5 Now, in 1996, looking back, obviously that has 6 come to light that that wasn't -- that wasn't enough, and 7 there's been a recognition within the Agency that we could 8 have done something sooner. You know, we could have done 9 more sooner, you know, back in the '93 '94 time frame.
10 TEAM LEADER HANNON: Okay. With regard to you 4
11 indicated we have learned some lessons, are there specific 12 parameters, performance indicators, metrics that you would l 13 suggest that we ought to be monitoring to assure we're 14 making progress in this area with regard to allegation and 15 employee concern follow-up?
16 MR. RAYMOND: I'm a believer in using 17 performance indicators. I don't know if I have an answer 18 for you that points to which ones are the best ones to 19 use. You know, one measure that we've always had within 20 the NRC is we feel comfortable with a company's or a 21 utility's handling of concerns as measured by the number 22 of concerns that come to us, and I guess that's a valid 23 measure on most -- on most occasions, in most situations.
24 TEAM LEADER HANNON: Now, wait a minute. Let 25 me understand that though.
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46 i i'
1 MR. RAYMOND: But m ybe it isn't. l 2 TEAM LEADER HANNON: But help me understand }
- 3 what you just said. Are you comfortable with the handling j I i 4 of employee concerns at Connecticut Yankee? l
- i
, 5 MR. RAYMOND: Yes. !
l l 6 TEAM LEADER HANNON: Why? Why is that? How l l :
i
.! 7 do you arrive at that comfort level?
4 i 8 MR. RAYMOND: Mostly because of how I see 9 issues being handled on a daily basis through the benefit l- 10 of my position of being here, and I don't -- again, I 1
3 .
i 11 don't see everything, you know. There's 360 people here, i !
- 12 and Pete and I are just two. So we don't see all l 1
13 interfaces and all interactions, but within -- within the
{
{ 14 limited forum that we get to operate in on a daily basis, i I
l .
- 15 which includes seeing how issues are brought before the (
[ 16 control room and dealt with or how people, employees write i 17 up their concerns or discrepancies as an ACR or a problem l 18 of identification process and how that concern comes into
[
19 the, quote, management review team, which is a group of 20 NRC managers with the unit director on a daily basis, and l 21 how they -- you know, how management -- what management's i
j 22 response is to employees who raise concerns and how they j
, 23 treat the issues and how they give positive reinforcement !
24 back to people for doing good jobs, even though it might 25 be painful for them to deal with it. l
! NEAL R. GROSS I COURT REPORTERS AND TRANSCRISERS j 1323 RHoDE ISLAND AVE., N.W.
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>. l
47 1 TEAM LEADER HANNON: You cnid NRC mrn garo. I 2 think you meant --
3 MR. RAYMOND: I meant NU managers, yeah.
4 TEAM LEADER HANNON: Yes. Okay.
5 MR. RAYMOND: So within that forum, you get 6 very' positive assessments about the health of the 7 organization in terms of their ability to identify their 8 own weaknesses, complement those who identify them and 9 bring them forward and deal with them.
10 TEAM LEADER HANNON: So I take it you're not 11 seeing many issues come to the NRC at Connecticut Yankee?
12 MR. RAYMOND: Well, I avoided that, but, yeah, 13 there is another measure out there, and one of which is 14 how many issues that I'm aware of that have been -- that is have transpired here over the last several years, and 16 there's on the order of, you know, a couple -- you know, a 17 dozen or two.
18 TEAM LEADER HANNON: Now, contrast that with 19 your experience at Millstone.
20 MR. RAYMOND: Well, it's clearly an order of 21 magnitude -- well, I've got to be careful. I don't know 22 what the latest figures are at Millstone, but they're 23 probably an order of magnitude worse than that, bigger 24 than that.
25 TEAM LEADER HANNON: So it's fair to conclude NEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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so -
- I 1 thnt you didn't -- you waran't comfortchle with tha wny
. . - 2 employees' -concerns were being handled at Millstone. !
j 3 MR. RAYMOND: I didn't say that. Did I -- did
- 4 you --
- 5 TEAM LEADER HANNON
- No,.I concluded that. l i ;
i
- '6 MR. RAYMOND
- Yeah. t
.i
- 7 TEAM LEADER HANNON
- . What was your degree of l
8 comfort then with the --
i i 9 MR. RAYMOND: Here's the problem with that i 10 performance indicator. I think it's inadequate. I think I 11 we've had a tendency as an Agency to measure a licensee's
- 12 success by how many concerns we get and that bypass the
~
13 utility system. I'm going to go out on a limb here a-14 little bit because I probably have a view on this or a ;
l 15 perspective that's different than the Agency view. i i l 16 I'm sure the Agency feels that you can measure i 17 the health of a licensee system based upon the number of i
l 18 concerns that circumvent their process and come to us, and ,
- 19 maybe the bottom line is that's all that counts. Okay? I l
- 20 don't know.
i f 21 But I think the flaw in that performance 22 indicator is that if you've got somebody who's bent on 23 coming to us no matter what and start, you know,. flooding l 24 us with concerns, they're going to drive that performance i
25 indicator way off the -- way off the board relative to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
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4 4
I whara that plent io, cnd thr.y're going to maka it en-i C 2 outlier relative to anybody else.
3 And so you're going to get a performance 4 indicator that without the benefit of detailed review or 5 study as.to why that performance indicator gives. It
)
! 6 might not be a good barometer on the health of the rest of
- 7 the organization and how well the licensee is-handling --
l 8 handling employee concerns.
2 9 Let me take this home now to Millstone. I 10 answered in general. I believe personally for a time
- -11 there was a healthy organization within the NU -- within 12 in the Millstone plant, and I'm going to be very specific j 13 and very focused. I'm going to talk about at Millstone.
- 14 so I'm going to exclude then what it was like at 4
i j 15 Connecticut Yankee prior to my coming here. I'm going to 16 exclude then from my assessment what happened in Berlin 17 because I 'didn't see that-arena as much as I did at the 18 site.
19 But I believe that an accurate perception or 20 an accurate assessment was for a time that the process for i
21 handling concerns at the worker-supervisor interface and 22 beyond that within the management chain and beyond that 23 within the programs that NU ultimately wrapped around the 24 management chain for handling concerns was a viable i 25 program that worked for the vast majority of the people.
l NEAL R. GROSS !
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___ _ __ _ ._ ~ . , . . _ _ _ _ _ _ . . -_ _ _ __ _ .
50 1 Thtt'c changsd now cinca thn lato '80s-ocrly
.s 2 '90s time frame, and I can't explain that change. My 3 conclusions are -- I don't have conclusions -- my 4 assessment is that either I had an inadequate meaeure 5 before. Maybe there was a problem. There was a problem 6 at Millstone that was deeper or broader than I had 7 realized in the past and it wasn't recognized until later, 8 or the working relationship between management and worker 9 has eroded, and so there really was a change in their 10 performance. l 11 And I don't know which it is, i
12 INVESTIGATOR MOHRWINKEL: You said one thing 13 that was interesting, I thought, here relative to 14 Connecticut Yankee. You said that it's your view that i
15 management supports and rewards employees who come forward i 16 with concerns even though it may make management 17 uncomfortable.
18 Clearly that's not the feeling we've gotten 19 from interviews with people at Millstone, and maybe in one 20 sentence that perhaps is the essence of the problem, the 21 lack of a supportive environment down at Millstone for 22 people who raise concerns.
23 MR. RAYMOND: Right.
24 INVESTIGATOR MOHRWINKEL: I'm wondering what 25 your reaction is to that.
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51' 1 MR. RAYMOND: And I guacs I'm having to 2 compare now, and I'm trying to -- I'm pausing only to try 3 to remember now all my collective Millstone experience. I 4 think Millstone management tried to do that. I can 5 clearly think of instances along the way in which they did 6 give positive reinforcement to people who brought forth 7 concerns and got them dispositioned.
8 And the difference is I'm not sure how well 9 they were doing that, if they were consistent in doing 10 that across the board at all three units, and don't take 11 this to be another unit differ -- you know, a comment on 12 the differences between the Millstone units because it's 13 not intended to be that. I don't have enough assessment 14 and review to try to make those distinctions.
15 But maybe they just weren't as consistent and 16 as good at doing that down there, but clearly they -- you 17 know, again, I sat there for five years on a daily basis, 18 saw that organization bring concerns brought up on a daily 19 basis by people that were put into their PIR process that 20 were dealt with, and it was not too unlike what you see 21 here.
22 I mean, you know, you can say, " Hey, we get a 23 high number of allegations." Well, an allegation is a l 24 safety concern that's only one out of 300 that are 25 identified every -- every year at every unit because, you NEAL R. GROSS l court REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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j
... - - - ~ .. . .-
52 1 ,
i 1 know, someone who writes up e - . puts something into the l
\
2 PIR process -- to that person that could be a safety J l
3 concern. They're not all, you know, the big nuclear l
4 safety concerns with the capital letter. There's concerns l l
5 there~: program process, problem process, and from that l l
6 perspective, you know, Millstone was riding their share of i
7 problems. I mean, so there was a vast number of -- vast J 8' number of performance issues or questions or issues that j 9 were being raised on a daily basis by the Millstone work l
10 force, and they were being dispositioned. j 11 Now, on the front end. Now, the back end, 12 correct actions and follow through, that all became part ,
13 of the overall performance decline and the ability of j i
14 Millstone management to deal with those was -- came under i 15 question and now is assessed today as inadequate, but from 16 the front end point -- part of the process, it was working i
I 17 there, as well.
i 18 TEAM LEADER HANNON: Okay. We've evolved to i 19 talking about the NU processes, and I want to, before we l 4
20 close out the interview, have you have the opportunity to 21 make sure you've told us everything you thought was 22 important for the NRC processes.
23 Is there anything you want to add to what 24 you've already told us with regard to NRC processes?
25 MR. RAYMOND: I can't think of anything, John.
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. 53 1 TEAM LEADER HANNON: Okcy. Could I mak you 2 then to provide us your insights and your views with 3 regard to the -- what your understanding is of the process 4 problems that we encountered at Millstone? i l
5 MR. RAYMOND: Yeah. I think what made 6 Millstone hard to handle ~was we had a spectrum of -- I 7 want to think clearly and say this carefully. We had a -- )
)
8 sources at Millstone on concerns that covered a spectrum i
9 of motives or circumstances under which issues were coming 10 to us, I guess is the point I want to make, and I realize 4
11 I'm not saying this very well.
12 TEAM LEADER HANNON: Shall we take a break?
13 (Whereupon, the foregoing matter went off the 14 record at 1:58 p.m. and went back on the 15 record at 2:01 p.m.)
16 TEAM LEADER HANNON: Okay. We're back on the 17 record.
18 I just want to restate the question so you 19 make sure you're focused on what I'm trying to get to. .I 20 want to get your view of what the NU's problems were now 21 that you've had the benefit of hindsight and some time to I 22 think about your experience there.
23 What do you think the problems were with the :
24 handling of employee concerns and allegations?
25 MR. RAYMOND: Okay, and to try'to speak to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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os } l 1 thnt, I do hava coma thoughts I'd offor to tha group, cnd l
, 2 I had jotted these down in some notes, and if you'll allow l 3 me, I'm going to refer to my notes to try to speak to it, 4 but first of all, from the point of view of the Millstone 5 or NU organization and how they -- how they handled 6 concerns, just talking about the NS -- nuclear safety 7 concerns program as a process, that changed in the five 8 years we were -- I was at Millstone from where it evolved l
9 from a single person in the 1980 time frame performing 10 that function on a part-time basis to becoming a separate 11 program office with formal procedures and a dedicated 12 staff by the time I left in 1992, and it had elements of 13 that program and process in place well before I had left.
l 14 NRC did focus on that to the extent that we 15 made several inspections, a couple of definite 16 inspections, team type inspections, of the NSC process and
. 17 found the program and process itself to be basically sound 18 or at least on paper it had the elements for success, but 19 the caveat was always we needed to see how it was going to 20 be implemented and what the fruits of the program were.
21 However, it became clear to me as I saw this 22 program evolving that neither the nuclear safety concerns 23 program or NU would ever be able to -- could make the NSCP 24 the avenue of choice to address the concerns of some 25 individuals who made a deliberate choice not to use that NEAL R. GROSS court REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE.. N.W.
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%> S 55 1 procace. I think that'o a wacknoco in cny nuc1cor cafoty 2 concerns program process.
3 And in particular, at Millstone there were, 4 out of the vast spectrum of allegations that we received, 5 the vast majority of which came from individuals who were 6 clearly interested in making things better and in raising 7 issues and getting them -- getting them resolved. There 8 were some questions in which people were not as forth --
9 it was not as clear that their motivations were that good.
10 For those cases I felt while I was there NU 1
1 11 tried to work with the situation in the best possible -
12 manner and, in a sense, build fences around hard cases so 13 as to minimize the disruptive influence of the few on the 14 rest of the organization.
15 Now, that's not to say that along the way some 16 employees raised valid -- you know, raised safety concerns 17 and were discriminated against by their supervision er 18 management. I think the inspection records from '89 to 19 '92 with the enforcement actions that we've taken validate 20 that that did occur, but there clearly -- in my 21 recollection of those cases, although we enforced them as 22 50.7 violations, if you look at why some of the harassment 23 and intimidation cases occurred as opposed to being 24 deliberate attempt to stifle safety concerns, I think some 25 of them the discrimination resulted -- occurred over NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLNs0 AVE., N.W.
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56 i 1 issuco for which there wara valid differsncac of technical i
. 2 opinion, and these differences were not resolved without l
(
3 harassment or intimidation just due to the lack of l 4 necessary managerial skills or supervisory skills or ;
i 5 training within NU on how to -- how to resolve conflicts, I l
6 conflicting positions in that way. !
7 That's --
so that's one spectrum of situations ;
8 or one group of people in which there were allegers that 9 were validly -- validly discriminated against.
10 There also though, in my opinion, were some i
11 employees who, while they brought safety concerns forward l 12 and the NRC and NU tried to give each of those concerns l 13 their due and resolve them, it was also apparent to me as !
14 an outsider, someone sitting there at the site, that there !
15 were situations in which some employees just got to get i 16 odds against their management, and they became embroiled ,
17 in a longstanding dispute that launched into an ongoing i i
18 battle, battle between NU and their employees, and that 19 battle was waged in the regulatory public forum.
20 There was a pattern of bringing concerns to 21 the NRC as part of a -- you know, an attempt to maybe --
22 this is only speculation -- but maybe to try to use 50.7 1 l
23 as protection. I can say that because these employees I i
24 would bring concerns to us or piggyback onto problems or 25 concerns that were either raised by others or that were NEAL R. GROSS ,
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- 1 problGm3 thnt tha NRC was wall cware of cnd knsw cbout, l
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2 but there was -- there was, in my opinion, an attempt just i 3 to add numbers of concerns to the process.
4 A review of the history of those concerns will 5 show a list of concerns that were either misinformation,
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6 fact's but not allegations; maybe they were trivial issues 7 or matters about which NU or the NRC were aware of and l 8 were working to resolve, such as program or process l 9 problems in the inadequacy of procedures or the need to (
I 10 upgrade procedures.
11 There also, in my five years at Millstone and i 12 in the experiences we had, there was also examples of j 13 individuals that conducted themselves in such a manner as 1
14 to be disruptive to the process and probably -- you know, i 15 and provided to NU valid bases for actions that would 16 affect their employment, that in my opinion or in the l 1
17 Agency's views didn't rise to a violation of 50.7. Either I 18 there were grounds for terminating individuals, but not ;
i I
1D for raising safety concerns.
20 I think I've already stated before -- I'll 1
21 just underscore it once more -- for the time that I was 22 there, the management relationship with the work force in 23 the concerns program was good for the vast majority of 24 employees, and I don't think it was perfect. The NRC, the 25 Milhone (phonetic) Review Group conducted a study at l NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS I
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- 1 Milletona cnd their ability to hendle safety concerno in
{
-, 2 about the '91 time frame, and I remember we were able to !
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.i 3 point out how their program and process was lacking in !
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4 some respects or many respects. I forget what the exact l 5 words were, but'so on the negative side, things could be 6 improved, but on the positive side, I think the process 7 for handling safety concerns was good for a large number 8 of employees as evidence by the large number of issues i 9 that were brought up and handled within the PIR process at 10 that time and dispositioned as well.
11 That's all for that.
12 TEAM LEADER HANNON: Do you have any other 13 questions, Carl?
l 14 INVESTIGATOR MOHRWINKEL: I don't think so.
? l 15 TEAM LEADER HANNON: Okay, Bill. Thank you !
l l 16 very much for your time. l t .
i l 17 It's approximately 15 minutes after two, and j i
18 unless you have any other comments, we'll conclude the l l
l 19 interview now.
20 MR. RAYMOND: Fine. Thank you.
i 21 TEAM LEADER HANNON: Thank you.
22 (Whereupon, at 2:10 p.m.,.the interview of 23 William Raymond was concluded.)
l 24 1 25 i NEAL R. GROSS l COURT REPORTERS AND TRANSCRIBERS 1323 RHoDE ISLAND AVE., N.W.
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I CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
Name of Proceeding: INTERVIEW OF WILLIAM RAYMOND Docket Number (NOT ASSIGNED)
Place of Proceeding: HADDAM, CONNECTICUT were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
h PAUL THORN official Reporter Neal R. Gross and Co., Inc.
I NEAL R. GROSS CoVRT REPORTERS MD TRMSCRIBERS 1323 RHoDE ISLAND AVENUE, NW (202) 2M 4433 WASHINGTON. D.C. 20005 (202) 234-4433
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