Urgent to meet you RE: CCNPP safety concerns
7/24/2003 12:19:33 PM Central Daylight Time
Dear Mr. Wallace:
I urgently request to meet with you to discuss the following two items at your earliest convenience:
1. My Safety Concerns at CCNPP.
2. CCNPP's blackballing me for employment due to knowledge of my prior protective activity.
1. I raised some concerns during your Calvert Cliffs Nuclear Power Plant (CCNPP) Unit 2 Steam Generator Replacement (SGR) Project regarding the inappropriate design control processes for Systems, Structures, and Components (SSCs). I had questioned the inappropriate resolutions of the following items for design and operability concerns:
A.) Concrete Repair of the Pressurizer Wall (dog house) and
B.) Out of plumpness of the supporting structures/variable spring hanger deficiencies and dispositions discovered during the non-defueled mode (mode 4) subjected to HELB and seismic loading.
I believe that my concerns had not been adequately addressed in the design
and operability evaluation for CCNPP despite the fact that I had fully elaborated
my concerns to your engineers and managers. I also had documented my reasons
on the daily activity log. These logs were read by other cognizant engineers
who supported my issues.
For example, the actual purred concrete samples testing by the concrete testing manufacturer revealed that the repaired concrete shear capacity was within 2000 pounds per square inches and not the required 4000 minimum requirements for the plant's design and operation for mode 4 where the concrete bursting had occurred and still required to meet the High Energy Line Break (HELB) and seismic loading. I had appropriately brought these issues to the attention of your staff and the designated technical specialist who signed the closure of the issue when I refused to sign and accept the final resolution even on my last day (April 18, 2003). I was designated as your structural engineer during the split shift coverage of SGR Unit 2 from Jan. 06 till April 18, 2003.
I provided some brief discussion of this issue the week after my last day of April 18, 2003 when I provided my complimentary training to your management, procurement, and engineering staff. I did not inform your management in a form of an allegation, but rather as the information awareness (actually reflected as one of my design examples in my handout of 119 pages).
Your QA Procurement staff became concerned when I described the mode 4 and defueld requirements and its impact on the plants' operations for the concerned items. After the training, some of your Procurement QA Staff told me that this was not included in their scope of activities, because CCNPP management had instructed its internal QA that the SGT Company would cover the oversight function of SGR Project and not CCNPP internal QA. This seamed very strange, because CCNPP still needs to audit SGT to ensure full compliance with the applicable codes of federal regulations per 10CFR50 Appendix B, Criteria VII, XVI, and XVIII for adequate implementation of Criterion III (Design Control) processes.
Regulation: Criterion VII of 10CFR50 Appendix B requires the control of items, components, and services. The licensee (CCNPP) is ultimately responsible for the adequate implementation of its vendor's QA Program. SGT's QA Program in this regard did not meet the code requirements for commercial grade dedication (safety related activity per EPRI 5652, NCIG-07) and the sample testing of concrete strength requirements (design control deficiencies) for the above issues and the Licensee is ultimately responsible for its nuclear safety. The SGT’s root cause evaluation report was not correct, because the maximum calculated stress in the concrete was determined to be 3600 pounds and less than 4800 pound allowable shear stress. 3600 is less that 4800 and if the calculation was correct, then the concrete would have not burst. This is the indicative that the existing concrete may not have been meeting its original design intent. Once I raised this issue, SGT management decided to rescind its root cause evaluation report and calculation and declared that SGT QA Program does not require any root cause evaluation. I explained that if SGT QA Program does not require the root cause evaluation, then it would not meet the intent of 10CFR50 Appendix B requirements. In addition, CCNPP was supposed to hire two concrete experts from ACI Committee to investigate the concrete crack issue and satisfy all the concerns raised for concrete crack, but this never occurred. I urged CCNPP management to send some samples of the fixed concrete prior to returning the CCNPP Unit 2 into operational mode of 4, 5, and fully operational. The test results confirmed that my concerns were accurate and the concrete shear capacity was around 2000 psi and much less than 4000 psi required strength. I was told that Bill Holston, as the Engineering Manager of CCNPP had indicated that he was the committee member of ASME Section XI and could justify that the root cause evaluation for concrete and for the spring hanger support that was found out of plump is not necessary and the concrete does not need to have enough shear strength to withstand the mode 4 and operational requirements. If Mr. Hostrom had made this statement, then he is not correct.
2. Your staff at CCNPP became fully aware of my protected activity (whistle blowing) case against Exelon. I had discussed my issues in full depth with one of your mechanical engineers who was my mechanical engineer partner in the same shift. I introduced him to you on January 2003 at the gatehouse. I have another witness within your staff that tried to find me a job at your CCNPP. He approached one of your Reactor Head Project Managers, Mr. Bill Tench to highlight my qualification and expertise in the Codes for an employment opportunity. Mr. Tench told him: "Make sure that the person whom you are talking about and is giving us the training of ASME Tutorial Course today gives me his Resume ASAP before he leaves the site". My witness paged me immediately when I was leaving CCNPP. I sent him my electronic Resume. My witness went to see Mr. Tench the next day. My witness told me that Mr. Tench had already printed my Resume and had it in front on his desk. My witness asked Mr. Tench: "what do you think about his credentials as shown in his Resume?" Mr. Tench replied to my witness: "this is the person that I really need to help me with this project due to his knowledge and code expertise showing on his Resume, but do you know really who he is? I knew him from ComEd, Oscar had brought many issues against Exelon and he is PAIN IN THE ASS, but technically very good. I would love to hire him, but my boss who also came from ComEd would not want to hire Oscar, but I need him and if it was up to me, I would not hesitate".
From April 2003 up to now I have not been contacted for this position at all despite my frequent contacts with reactor head managers whom I knew during my service at CCNPP. My witness has reminded Mr. Tench a couple of times, but heard nothing and advised me to contact you since I knew you from ComEd. I also need to protect the identity of my witness not to be the subject of any retaliation for revealing this news to me. The above statements from your manager, Mr. Tench show clearly that he was aware of my protective activity at Exelon and refused to hire me. If it were my Resume with no name, I would have been working for you since April 2003 or I might have not left your site. This is unlawful.
Note: In another incident, I also had sent you my Resume and one of your staff, Mr. Ken. Boone had sent a request to your HR in early June 2003 to send me some questionnaire electronically and I replied to the subject request. This opportunity was not specific to any task and assignments. I have called many times to your HR designated individual to find out the status of my application, but I have not heard any reply to my repeated messages. The subject e-mail would be provided upon your request.
The reason that I want to discuss the details of the above two items with you is because I trust in you and know that you would not tolerate any quality compromises at your CCNPP. I knew you from the ComEd time frame of 1990-1997 and I highly trust your integrity and ethics. The management who replaced you destroyed all the ComEd's integrity by increasing the power uprate at any cost and that is why they selling more electricity than when you were there. There have been three incidences of Exelon's nuclear plants forced shutdown at Dresden, Quad Cities, and Byron due to Power Uprate as quoted by August 2002 INPO documents. At ComEd, I had met with you and received highest achievement awards from your designated engineering VPs and managers for the standards and codes that I developed and incidences that I defended ComEd engineering positions with NRC/NRR. I wrote codes to defend the operability of our nuclear plants. I knew you as a man who would not jeopardize the integrity of its plants and staff at the price of the production and the influence of other partners who have no ethics and are known as the killers of safety advocates. You promoted me three times within 5 years and I like to thank you, because you realized my contribution to ComEd nuclear plants. When I contributed to the success of ComEd/Exelon I was not recognized by Kingsley and when I found issues that I could not hide in order to protect my job and the company’s position with the regulators, then I was kicked out.
I strongly believe that when you left ComEd, the management intimidation and fear at Exelon started and destroyed any freedom to bring safety issues to the management attention. When I was at engineering and produced standards and codes to defend our plants I was rewarded by your staff, but the whole picture changed when you left. Production took the front seat and quality was thrown to garbage as well as safety issues. Please refer to NRC's citation on October 4, 2002 against Exelon who willfully discriminated against a Byron Employee Concerns Program's (ECP) Supervisor who said: "There is a Chilled Atmosphere at Exelon and employees are afraid of their jobs to bring safety concerns to the ECP staff".
I had met with you on a couple of occasions and you showed care and attention to the personal issues as well as nuclear safety issues. I know that you would not tolerate any of your management’s actions to blackball me for employment at your company. I would be part of the solution and not problems at your company. In fact, I want to ensure that your reactor head project would implement quality into design and fabrication at the beginning to fully meet the codes and standards. I will give you my full commitment to ensure code compliance.
I never had intended to be a whistle blower or be destructive to the nuclear power industry that I proudly served for 21 years, but could not walk on my ethics and integrity to protect myself and Exelon for criminal wrong doings. I did not want to be a subject of criminal prosecution per 10CFR50.110 to wrongfully protect my job and hide the Exelon's falsification of records as displayed in my DOL hearing, which is in appeal process. Unfortunately these DOL hearing lasts for many years of frustration, but I need to feed my family and serve the nuclear industry that I proudly served.
I had raised 9 significant allegations against Exelon and specifically Messrs.: Oliver Kingsley and David Helwig due to my Stop Work Order against GE, Holtec, US Tool & Die, and Exelon and their retaliation against me when I told NRC. I had exhausted all my avenues internally at Exelon and escalated the issues to management, but when I was ignored, insulted, removed by conspiracy from Exelon, then I had no choice to tell NRC. Later I found that Exelon falsified records to lie to NRC and NRC did not catch them. That is why I was at OIG in July 21 and 22, 2003 to let them know about the shortcomings and incompetence of NRC as the guardians of public health and nuclear safety.
As you may be aware by numerous media coverage (i.e. Associated Press, Salt Lake Tribune, Las Vegas Sun, Las Vegas Review Journal, San Francisco Bay AlterNet, etc.) that one of my 9 allegations against Exelon/Holtec spent nuclear fuel dry cask storage. All the media coverage started in June and July 2003 which my issues were escalated by the Senator Reid's staff to the national attention and NRC/OIG. These media stories for public health and nuclear safety have unintentionally further blackballed me from the employment and I don't regret it at all, because the price of integrity and ethics is very high.
I have been unemployed from October 2001 till now except the three months that I was at your CCNPP (thanks). I have witnesses that even NUPIC Utilities knew about my issues with Exelon from the first day that Exelon terminated me in October 2001. Russell A. Bastyr, my last boss in Exelon Nuclear is the Secretary of NUPIC. Demark Owner, Mr. Mark Inserra tried to find me a job at the First Energy's Beaver Valley NPP and everything was all set for me to start on June 30, 2003, but First Energy VP has stopped the offer when they found out that this new person coming to their site is Oscar Shirani (of Course, this is not admitted by Demark). Mark Inserra who has incentive to employ me for a mutual interest is not even responding to my repeated phone calls from June 30, 2003 up to now. I had left him several messages that I am a grown person and could digest the bad news and please tell me why?, but he refuses to call me back to admit to any inside information that he might know.
NRC staff failed to identify the issues that I raised at GE, Holtec, US Tool & Die and other suppliers that they inspected prior to my design assessments. Exelon's history is full of willful violations. You may read about my issues on the Internet by searching "Oscar Shirani" and all the media coverage of one of my 9 allegations against Exelon is displayed.
Please make an arrangement to meet with me at your earliest convenience.
This document was posted online December, 2003 by Russell D. Hoffman. For a complete guide to Oscar Shirani's allegations please visit: