IR 05000482/1985028

Insp Rept 50-482/85-28 on 850527-31.No Violations or Deviations Noted.Major Areas Inspected:Quality First Files

ML20134M380
Person / Time
Site:	Wolf Creek
Issue date:	08/23/1985
From:	Martin L, Renee Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20134M363	List: IR 05000482/1985028 ML20134M361
References
50-482-85-28, NUDOCS 8509040101
Download: ML20134M380 (6)

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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-482/85-28 License: NPF-32

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Docket: 50-482 Licensee: . Kansas Gas & Electric Company Facility Name: Wolf Creek Generating Station Inspection At: Wolf Creek Generating Station, Burlington, Kansas Inspection Conducted: May 27-31, 1985 Team Director: R. P. Denise, Director, Division of Reactor Safety andProjects(DRSP),RegionIV Team A: D. D. Driskill, 01, Region IV M. Emerson, 01, Region IV T. A. Nash, Allegation Coordinator, Region IV Team B: R. G. Taylor, Reactor Inspector, Region IV M. E. Murphy, Reactor Inspector, Region IV R. P. Mullikin, Reactor Inspector, Region IV L. E. Ellershaw, Reactor Inspector, Region IV B. Siegle, LPM, NRR V. Nerses, LPM, NRR Team C: L. E. Martin, Chief, Project Section B, Reactor Projects Branch, Region IV B. J. Youngblood, Licensing Branch Chief, NRR W. P. Haas, Special Assistant for Allegations, IE J. E. Cummins, Senior Resident Inspector, Wolf Creek H. F. Bundy, Resident Inspector, Wolf Creek B. L. Bartlett, Resident Inspector, Wolf Creek NOTE: Team A Details documented under separate cover as 0I Assistance to Inspection A4-85-005, dated June 12, 1985, w

Inspector: v/ , Irz M 13!f[

R.' G. Taypr Reactor Inspector /Dafe Project section B, Reactor Projects Branch l Region IV (Team Leader B)

8509040101 850828 PDR ADOCK 05000482 G PDR (_

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-2-Approved:

L.WMaYtin, Chi

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j' f4 fatef Project Section , Reactor Projects Branch /

Region IV (Team eaderC)

Inspection Sumary Inspection Conducted May 27-30, 1985 (Report 50-482/85-28)

Areas Inspected: Special inspection of Quality First (Q1) files. This inspection involved team members from Region IV DRSP, Region IV Office of Investigations, NRR, and IE for a total of 679 onsite inspector-hour Objectives of Inspection: To completely r? view all KG&E Q1 files to determine whether Kansas Gas and Electric Company (KG&E) has properly dealt with the concerns brought to this organization by the employees of KG&E and its contractors. As a result of this review, determine what NRC actions are required with emphasis on issues affecting full power operation of the plant and management integrit (

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-3-DETAILS 1. Persons Contacted G. L. Koester, Vice President, Nuclear C. C. Mason, Director, Nuclear Operations F. T. Rhodes, Plant Manager C. A. Snyder, Manager, Quality First R. M. Grant, Director, Quality W. J. Rudolph, Manager, Quality Assurance H. K. Chernoff, Licensing W. M. Lindsay, Supervisor, Quality Systems D. R. Smith, Superintendent, Plant Superintendent M. G. Williams, Superintendent, Reg. Quality Administration T. L. O'Hearn, Nuclear Plant Engineering A. Mee, KEPC0, Project Coordinator R. Flannigan, KCPL, Site Representative All of the above were present at the exit intervie The team members also interviewed other licensee employees and members of the Q1 organizatio . Background KG8E began developing an internal program for followup on safety concerns in January 1983. The Q1 program and concepts were implemented in February 1984. The program started with 4 people that reported to the Director, Quality via the Manager, Quality Assurance. In November 1984 the Q1 organization was placed directly under the Group Vice President, Technical Services and had 27 peopl Q1 receivas concerns in three ways: (a) Hot Line, (b) walk-in, and (c) exit interviews of all KG&E or contractor employees. At the time of this inspection, there were 271 case files with a total of 752 concern Only 4 of the concerns remained ope . Scope and Mechanics of Review All 271 case files were reviewed with each individual concern being evaluated to the following criteria:

o File content o Nature of concern o KG&E classification o 50.55(e) reportability

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-4-o Substantiated or not o KG&E actions / resolution o NRC acceptability for full power license The review was accomplished by three teams. One team was assigned all of the intimidation /harrassment, drug, falsification, security, and wrorgdoing issues (documented in 01 Report A4-85-005) with the other two teams handling all other issues. - Each concern was reviewed and evaluated by a team member and this evaluation was subsequently reviewed by the team leader and/or the team director. All concerns received two levels of revie The teams met with the team director each afternoon to discuss status and l significance of individual reviews.- Because of the sensitivity of the confidentiC ity of the Q1 files, the teams did not duplicate records or file informatio . Result of Review The teams reviewed all 271 case files and evaluated KG&E's documentation, determination, and resolution of the 752 concerns. The following is a categorization of the concerns in percentile:

Technical (Safety) 61%

Technical (Nonsafety) 3%

Intimidation /Harrassment 6%

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Industrial Safety 2%

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Industrial Relations 5%

Security 1%

Drugs- 4% ,

Falsification of Records 2%

Other 16%

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Approximately 40% of the 271 case files had previously been reviewed by j Region IV, however, they were again reviewed during this inspection to

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provide continuity and to insure that all concerns received at least two levels of review.

, The review of the technical concerns revealed that-KG&E and Q1 had

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performed a good in-depth follow up, proper classification and appropriate corrective action. There were instances where the NRC team disagreed with whether the concerns were substantiated or not and this will be discussed

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in a subsequent paragraph of this repor The review of ~ the concerns related to drugs, intimidation /harrassment, .and falsification were not handled with the high level of performance exhibited in the technical area. These concerns were categorically followed up by organizations other than Q1 and the closure documentation did not exist in the Q1 files. .An example would be a drug case that was l

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-5-turned over to the security organization where the follow up was not communicated to Q1. There were several concerns where all of the leads were not adequately followed to support the conclusion. Additional effort outside the Q1 organization by the NRC was required to determine if these concerns were properly investigated and closed as indicated in the Q1 file. The Q1 file closed many of these concerns when they were transferred to the other organizatio The review of the drug and intimidation /harrassment concerns by organizations outside the Q1 organization often identified poor follow u These types of concerns often require the expertise of a professionally trained investigator to properly follow up on all lead It was apparent that some of these concerns received marginal investigative effort, and therefore, the assurance that the appropriate classification and resolution was reached was margina .

There were instances where the NRC reviewers disagreed with the Q1 classification of substantiated /not substantiated. There were other concerns where the information contained in the Q1 files did not support the closure of the file. There were approximately 34 concerns where the NRC team had to go outside the Q1 organization and look at other information or interview other personnel to reach the conclusion that the particular concern was or was not a restraint to full power operation of Wolf Cree The NRC team noted that many concerns could have been closed much sooner, but the concentration of resources was directed almost totally to the interview process rather than the investigation and closeout / resolution process. The final resolution may have been the same had the investigation and closecut taken place in a timely fashion, however, the substantiated /not substantiated classification can change and the timely response to the concerned party is very important. It was also noted that the only trending of the Q1 files was related to the number of open versus closed files. The NRC team could not identify any trend information that provided KG&E top management with type or significance of concern . Conclusions The NRC teams, after follow up on the Q1 files and follow up on numerous items outside the Q1 organization, concluded that KG&E Q1 had:

o Reached proper resolution on technical issues in a responsible manne o An appropriate level of management integrity was evidenced by proper resolution, management involvement, and the independence of~the progra o Not required appropriate feedback and appropriate level of investigation from other organizations to insure that the Q1 files contained all information to support closur l s

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-6-o Failed to provide appropriate trending to managemen Many of the above items were noted during previous inspections of the QI activitie After careful review of all 271 case files and each of the 752 concerns, the NRC teams concluded that there were no issues that would be a restraint to full power operation of the Wolf Creek Generating Statio There are issues that will require continued NRC follow u Although Q1 is not a required or regulated activity, it is a highly visible activity and therefore, of matter of importance to the NRC and KG& KG&E has committed to continue the Q1 effort and to retain all records as permanent records. This is an important management tool for KG&E and to assure its effectiveness in the future will require continued management attentio The NRC does not view the Q1 activities as a mechanism to bypass the NR From the inception of Q1, Region IV has been interested in this effort of KG&E to better manage the quality of the Wolf Creek activities. This is the seventh inspection that the NRC has conducted of the Q1 organizatio The NRC will follow up on the concerns identified in this report and will continue to review the Q1 files and finding . . - _ - .