ML20128P297
| ML20128P297 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/28/1985 |
| From: | Brown K KANSAS GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20128P270 | List: |
| References | |
| 2.206, OL, NUDOCS 8506030503 | |
| Download: ML20128P297 (10) | |
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-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISS rON In the Matter of.
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KANSAS GAS AND ELECTRIC
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Docket No. STN 50-482 COMPANY ET AL.
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(Wolf Creek Generating
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Station Unit No. 1)
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AFFIDAVIT OF KENT R. BROWN f
County of Sedgwick
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ss State of Kansas
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'~N KENT R. BROWN, being duly sworn according to law, deposes
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and says as follows:
1.
I, Kent R. Brown, am Group Vice President-Technical l
Services of the Kansas Gas & Electric Company (KG&E).
My business address is Post Office Box 208, Wichita, Kansas 67201.
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As Group Vice President-Technical Services, I am responsible for the operation of KG&E's generating facilities and l
l construction of all generating, transmission and distribution l
l facilities.
Among those reporting to me are the Vice i
President-Nuclear, and the Manager-Quality First.
I am responsible for KG&E's Quality First Program.
A' statement of ny professional qualifications is attached hereto.
I B506030503 850529 PDR ADOCK 050004G2 C
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.I make this Affidavit in response to the May 15, 1985
! petition filed by the Government Accountability Project (GAP) j pursuant to 10 C.F.R. 52.206.
I have personal knowledge of the matters stated herein and believe them to be true and correct.
3.
KG&E established the Quality First Program in early 1984 to provide a way for all personnel working on the Wolf Creek Project to report, on a confidential or anonymous basis, j
any concerns with the quality of the Wolf Creek Generating l
Station and for having those concerns investigated and resolved.
The Program also provides that persons raising concerns will, if they desire, be informed of the results of l
j the investigation (or if the concern involves non-safety issues, that the concern has been tranferred to the affected organization to be resolved).
The Affidavit of Charles Snyder j
describes the Program in detail.
4.
The Quality First Program is in addition to other mechanisms for those working on the Wolf Creek Project to raise safety-related concerns.
For example, such concerns can be communicated directly to the person's supervisor or to any d
level of project management.
They can also be communicated to the NRC, either to the resident inspectors on the Wolf Creek site or the NRC's Regional Office.
These reporting mechanisms have been discussed with, and brought to the attention of, all 4
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project employees.
Notices are posted throughout the site calling attention to'the Quality First Program.
(Examples of
'such notices are attached to Mr. Snyder's Affidavit). Also
-posted throughout the site are notices calling attention to the ways'to communicate with NRC, including collect telephone calls.
,5.
Since the inception of the Quality First Program, all Quality First files have been handled on a confidential basis.
KG&E felt that this was the most Effective way to encourage workers to come forward with concerns as well as the most effective way for Quality First investigators to obtain information from other individuals about the concerns expressed by those coming to Quality First. This is why it would be s_
/ inappropriate for the NRC to physically take possession of the N
_ uality First files, as sought by the GAP Petition.-
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NRC inspectors and investigators have been given full j
access to Quality First files at WCGS.
As shown in the NRC l
Inspection Reports discussed in Mr. Snyder's Affidavit, well over half of these files have been reviewed by the NRC.
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Each person bringing a concern to Quality First is asked whether he or she wants to receive feedback on the 4
. resolution of the concern.
Of the 258 persons who have brought
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concerns to Quality First, 143 have requested and received this j
_ feedback.
If any_ individual was not satisfied with Quality l
First's resolution of his. concern, he or she would be able to N !
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take that concern to'th9 NRC or seek other relief.
This provides a very effective mechanism for any worker who is dissatisfied with Quality First's handling of his or her Concern.
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The Government-Accountability Project's petition requests that the Office of Investigation conduct an investigation into the compromising of the Quality First program by William Rudolph, site QA Manager.
Mr. Rudolph was originally responsible for the resolution of allegations made against the QA program which he supervised.
He currently is responsible for the resolution of Quality First Observations (QFO's),
discrepancies identified in the course of Q1 investigations.
~g The charge that Mr. Rudolph somehow compromised the Quality First Program represents a misunderstanding of both the Quality Assurance and Quality First Programs and is not supported by the facts.
9.
Mr. Rudolph is the Manager of QA at the Wolf Creek site and held that position at the time that the Quality First l
Program was established.
Indeed, Mr. Rudolph was one of the
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persons responsible for creating that Program.
During the first five months of the Program's existence (from mid-March,
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l 1984 until August 21, 1984), the head of the Quality First 1
i effort -- the Quality First Team Leader -- reported to Mr.
I Rudolph.
In August, 1984, the Quality First Program was I '
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reorganized and Mr. Snyder was appointed as its Manager, and the reporting responsibility was moved from the Manager QA (WCGS')(Mr. Rudolph) to the Director-Quality.
(In November 1984, Mr. Snyder's reporting responsibility was moved to the Group Vice President-Technical Services.) Therefore, it was only during'the Program's first months that Mr. Rudolph was even theoretically in a position to " compromise" the Quality First Program.
10.
Mr. Rudolph's managerial position over the Quality First Program during the time that the Quality First Team Leader reported to him in no way represented a " conflict of interest."
In practice, the Quality First Team could -- and did -- bypass the Manager QA (WCGS) when the Team thought it was appropriate to do so.
The ability to go arcund Mr.
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- Rudolph demonstrated that there-was no conflict of interest and that Mr. Rudolph was not in a position to " comprise" the
- Quality.First Program.
Furthermore, only if concerns were aimed at KG&E's on-site Quality Assurance Organization itself 7
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-- as opposed to the Quality Assurance Program -- would Mr.
Rudolph's adrinistrative subordinate be investigating allegations dealing with Mr. Rudolph's organization.
Concerns l
with the QA Program would not be concerns directed against Mr.
Rudolph or the QA Organization.
The QA Organization oversees L V
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r"'s the QA Program, but is not synonymous with the QA Program.
k Thus,-the-fact that the-Quality First Team was investigating concerns about-the QA Program while reporting to the Manager QA
-(WCGS)'did not represent a conflict of interest.
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11.
During the March-August 1984 period, only two concerns were received which were aimed at the QA Organization.
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Both were administrative in nature and had no direct safety significance.
In any event, when the Manager-Quality First
-assumed control of the Program in August 1984, he reviewed all
. concerns that had been closed out and determined that all the resolutions were appropriate.
This reevaluation further assured that there was no " compromise" in the Quality First Program during the period of time that the Quality First Team l
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Leader reported to the Manager QA (WCGS).
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GAP is also incorrect in its reference to Mr.
i Rudolph's responsibilities concerning Quality First Observations (QFO's).
As discussed in Mr. Snyder's Affidavit, a QFO is issued when a Quality First investigation reveals a problem or potential problem unrelated to the initial concern which triggered the investigation.
GAP states that Mr. Rudolph is " currently responsible for the resolution of" QFO's.
QFO's are the responsibility of the affected organization to resolve.
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QFO, then it has the responsibility to resolve that QFO.
For
-;all other QFO's, the WCGS QA organization would audit and perform surveillances just as it would for any other activity.
Here, too, there is no conflict of interest.
Quality First can, in its discretion, bypass the QA organization to make sure that'the issue is resolved.
Quality First personnel, as is true with anyone, can take the matter to the NRC.
And, the Quality First Organization verifies that all QFO's are resolved and that the resolution is'being effectively implemented.
13.
GAP's Petition alleges that KG&E has "... ignored or buried the serious concerns of the members of the workforce" that those members brought to Quality First.
That is most certainly not the case.
Each allegation brought to Quality First has been diligently pursued by the Quality First Organization to its proper and correct resolution. 'The independent Quality First Organization is a credible group of highly qualified individuals who perform their job in an unbiased manner, unrestrained by management pressures.
14.
KG&E's Quality First Program has provided an additional outlet, not previously found on most nuclear projects, where individuals can confidentially discuss their concerns, be assured that they will be promptly evaluated without personal repercussion, and receive feedback addressing the results of the investigation.
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KG&E has taken'the initiative.
We have developed and implemented an effective program for investigating and
-resolving quality concerns.
We have opened our program and i
files to all levels of the NRC for their review, comment and verification of corrective action.
16.
Some~ concerns significant to safety were discovered through the Quality First Program.
Consequently, the effort required to screen the thousands of individuals leaving the project was worthwhile in that an added level of assurance for
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protecting the health and safety of the public has been afforded through the Quality First Program.
Kent R Brown
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Subscribed and sworn this M b day of May. 1985 lok 0 \\fh NotgrPubl?c' 2
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'(g Kent R Brown
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Kansas Gas and Electric Company
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1984 Kent R Brown, Group Vice President - Technical Services, has been employed by Kansas Gas and Electric Company since November 1982.
He obtained a Bachelor of Science degree in Mechanical Engineering from California State University at Long Beach in 1967. Mr Brown has 17 years of experience in the nuclear field.
He worked for two years at Stone and Webster Engineering as an engineer in the mechanical and nuclear organizations.
He was responsible for design of safety and non-safety related systems on three nuclear units.
While at General Atomic Company for seven years, he served in various senior project management positions managing design optimization studies for the gas-cooled reactor, development and presentation of technical material for proposals and as an engineer designing safety systems. With Holmes and Narver Incorporated for two years, Mr Brown was project manager responsible for conceptual design of.the Waste Isolation Pilot Plant, a deep salt bed n
repository for disposal of nuclear wastes.
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\\j Prior to coming to Kansas Gas and Electric Company, Mr Brown was a vice president of the Management Analysis Company.
His responsibilities included probabilistic and economic evaluations of plant cost and schedule, organizational and management consulting for nuclear projects and various corporate responsibilities.
As Group Vice President-Technical Services, duties and responsibilities include being in charge of all technical aspects of Kansas Gas and Electric Company encompassing operations, transmission and distribution, engineering and construction.
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