ML20128P311
| ML20128P311 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/28/1985 |
| From: | Snyder C KANSAS GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20128P270 | List: |
| References | |
| 2.206, OL, NUDOCS 8506030507 | |
| Download: ML20128P311 (20) | |
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION
-(
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BEFORE THE COMMISSION In the Matter of
)
)
. KANSAS GAS AND ELECTRIC
)
Docket No. STN 50-482 COMPANY, ET AL.-
)
)
(Wolf Creek Generating
)
Station Unit No.-1)
)
AFFIDAVIT OF CHARLES A.
SNYDER County of coffey
)
)
as State of Kansas'
)
CHARLES A. SNYDER, being duly sworn according to law,
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eposes and says as follows:
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1.
I, Charles A.
Snyder, am employed by Kansas Gas and Electric Company'(KG&E) as Manager - Quality First.
My business-address is Box 309, Burlington, Kansas 66839.
As Manager - Quality First, my responsibilities include oversight and supervision of KG&E's Quality First Program, described in this Affidavit.
I attended the University of Colorado, majoring in electrical engineering.
I have over 33 years experience in construction engineering, project management, procurement, planning and scheduling, electrical design, quality control surveillance, craft supervision, quality d
8506030507 850529 PDR ADOCK 05000402 O
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. assurance monitoring, field engineer supervision, and
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construction project evaluation.
This experience encompasses commercial, light industrial, heavy industrial, military missile complexes, and fossil _and nuclear power plant construction involving civil, structural, mechanical and.
electrical disciplines.
Approximately ten (10) years has been devoted to nuclear power plant' construction. For approx.imately.
2 years, I served at the Institute for Nuclear Power Oparations on Construction Assessment Team investigations.
I assumed the position as Manager - Quality First in August, 1984.
2.
The purpose of this Affidavit is to describe the Quality First Program at the Wolf Creek Generating Station (WCGS), how the program developed, its staffing and management, the Program's implementation, and its review by the NRC.
I have personal knowledge of the matters stated herein and believe them to be true and correct.
3.
The Quality First Program in effect at the WCGS provides a method for all persons who work at the WCGS site or KG&E's home office in wichita to make known any quality concerns to an independent investigative organization for L
evaluation and resolution. The Quality First Program represents l
i a major commitment by KG&E that all concerns expressed by these personnel will be thoroughly evaluated and responded tc.
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I.
HISTORY OF QUALITY FIRST PROGRAM I
A V
4.
During the Fall and Winter of 1983, the WCGS Quality Assurance (QA) organization received or was referred a number of allegations from various personnel who were working or had formerly worked at the WCGS site.
During the course of investigating these allegations, KG&E management and the WCGS QA organization became convinced that a separate group was needed to receive and investigate concerns expressed by site personnel.
This realization was based on the amount of effort and resources which the WCGS QA organization was devoting to the allegation investigations.
5.
KG&E wac also aware of programs which were being established at other nuclear construction sites to provide an
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independent mechanism to solicit, investigate and resolve allegations and concerns from site personnel.
In late January, 1984, KG&E management decided to establish such a program for Wolf Creek.
6.
During late January and February, 1984, the Quality First Program procedures and facilities were developed.
As part of this process, a member of the WCGS QA organization I
visited Arizona Public Service Company to study the "APS Quality Hot Line" program used at the Palo Verde facility.
In
- addition, members of Detroit Edison's "Safeteam" program gave a presentation on that program at WCGS..
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7.
On February 24, 1984, KG&E's Vice President-Nuclear
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issued a Project Directive, " Quality Concern Reporting System "
which established the Quality First Program.
The initial
- i Quality.First procedures were issued on March 14, 1984, and by that time the key elements of the program were in place.
II. DESCRIPTION OF QUALITY FIRST PROGRAM 8.
The key elements of the Quality First Program have
-remained basically unchanged since the outset of the Program.
9.
All workers with any concerns about the quality of Wolf Creek are invited to make those concerns known to Quality First.
Participation is encouraged by site-wide publicity, including posters, pamphlets (distributed with each worker's paycheck), question and answer sheets (distributed to all personnel), work place meetings explaining the Program, and s
hard hat stickers. Copies of some of these materials are attached hereto.
10.
A toll-free telephone number is in operation 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day (with an answering machine during non-work hours) to receive concerns.
The phone number is widely publicized, including tear-away tags on the posters on site.
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11.
Concerned individuals may come in to the Quality i
First office at any time during normal working hours to express l
their concerns directly to Quality First personnel either in writing or orally.
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12.
All personnel are interviewed.by Quality First t.
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~ interviewers before they leave-the site at the end of their site employment and' asked whether they have any quality concerns relating to Wolf Creek.
They are also provided with-forms on which they may state any such concerns.
If an individual leaves the site and does not return before 1
terminating employment, Quality First sends the individual a letter-(with a stamped return envelope) soliciting any quality concerns that the individual may have.
f-l 13.
.The Quality First Program affords any individual the right to submit his or her concerns confidentially, and in the
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i case of the telephone " Hot-Line" anonymously.
In addition, persons contacted by investigators looking into a concern are 4
spoken to in confidence.
Case files are safeguarded and are f
made available even within the Quality First Program, only on a
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-strict, need-to-know basis.
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Any individual reporting a concern is asked whether he or she wishes to be informed of the results of the i
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_ investigation.
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Upon receipt of a quality concern, it is investigated l
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by Quality First personnel.
A separate file is opened for each individual raising a concern.
An initial review is made to determine'whether the concern has potential safety i
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i significance.; Concerns having no safety significance are referred to the affected organization for resolution. -For
-those concerns which are retained by Quality First, an investigative workplan is prepared, the matter is investigated
.and an investigative report is written.
If the concern is substantiated, a Quality First Action Request (QFAR) is
-transmitted to the organization responsible for corrective action (without disclosure of the originator's identity),
unless, of_ course, the concern was resolved during the course-oftheinvestigation.AfIftheinvestigationdiscloseda problem or potential problem unrelated to the initially expressed concern, Quality First initiates a Quality First
[
Observation (QFO) which is transmitted to the appropriate s
organization (without disclosure of'the identity of the initial alleger).
Substantiated concerns are evaluated for reportability under 10 C.F.R. 550.55(e).
16.
Following completion of the investigation, the a
. individual initiating the concern is contacted by telephone or 1/
Prior to August 1984, organizations responsible for corrective action were notified by Quality First using the site QA reporting mechanisms (e.g. Quality Program Violation Notices, Quality Program Deviation Notices, Surveillance Reports, etc.).
The change to the QFAR system was made to give Quality First even greater visibility and to recognize the separation of Quality First from the site QA organization.
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letter-(should he desire such follow-up) and is informed of the
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I outcome'of the investigation.
For those concerns which are initially determined to have no safety significance and are I
transferred'to the affected organization for resolution, the originator 1s informed by Quality First that his concern-has been transferred to that organization.
17.
Quality First receives responses from the appropriate organizations, evaluates the responses and verifies that appropriate corrective action has been performed.
Quality First also receives responses as to non-safety concerns so that
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the status of these' concerns can be tracked.
III.
STAFFING AND MANAGEMENT OF QUALITY FIRST PROGRAM
- 18.
In its-initial stages, the Quality First Program.was carried out by an entity called as the Quality First Team, led by the Quality First Team Leader.
The Team Leader reported to the Manager, Quality Assurance (WCGS) who in turn reported to the Director-Quality.
(In practice, the Team Leader also had direct access to the Director-Quality or higher in RGGE management, as deemed necessary by the Team Leader).
The Team was initially composed of four members.
Subsequently, a i
retired FBI agent who had been a consultant to KG&E's legal j
department was added to provide appropriate investigatory l
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skills for resolving allegations of wrong-doing.
By August, I
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1984 the Team had, increased to about 12 members, in response to h 'the number of-people to be interviewed and the number of concerns being received.
-19.
In-response.to the~ increased numbers of concerns to be investigated'(as more exiting personnel were interviewed) and because of the substantial time demands which the Quality First Program was imposing on the Manager QA (WCGS), !KG&E management decided to further increase the number of people working on the Program and to set up the Program as a separate Quality First Organization headed by its own Manager.
In
' August, 1984, the Quality First Team became the Quality First organization, with its Manager reporting directly to the Director-Quality.
The Manager also had the option of bypassing O the Director-Quality and reporting directly to the Vice President-Nuclear.
During the Fall of 1984, the size of the organization increased to 27 in response to the larger numbers of site workers leaving the project as construction was being completed and the need to promptly investigate the concerns raised.
2/
During the late Spring-early Summer 1984, the Manager QA (WCGS) was spending about 80% of his time on Quality First matters.
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A further organizational change took place in
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November, 1984, when the reporting responsibility for the Manager, Quality First was changed from the Director-Quality (with the option of direct reports to the Vice President-Nuclear) to the Group Vice President-Technical Services.
This change gave the Quality First Program further visibility and also eased the substantial workload of the Director-Quality and Vice President-Nuclear.
21.
As a result of the reduction in the numbers of workers leaving the site, a reduction in the number of concerns raised, and the completion of investigations on concerns that had been raised with Quality First, the staff of the Quality First Organization since November 1984 has gradually been
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reduced.
At the present time the staff numbers 7.
IV.
QUALITY FIRST PROGRAM IMPLEMENTATION 22.
Since the start of the Quality First Program, 751 concerns (as of May 23, 1985) have been brought to the attention of the Program.
Of these, 726 were raised prior to fuel load, and 25 since that time.
The concerns were developed from interviews with more than 5600 personnel prior to their leaving the site, and from the 66 calls to the telephone Hot Line.
A total of 273 individuals (as of May 23, 1985) raised j
concerns.
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23.
Based upon the' investigations and evaluations t
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conducted by the Quality First Program, 198 of the 751 concerns have been substantiated. Seven are still in the investigatory process.
Of the 198 concerns which were substantiated, 18 were determined to be significant to safety.
With the exception of the 7 concerns currently under investigation, all others (including the 18 determined to be significant to safety) have been resolved and Quality First has concurred in the resolution.
V.
REVIEWS OF QUALITY FIRST PROGRAM 24.
The operation and results of the Quality First Program have been the subject of repeated NRC inspections.
Individuals from three different NRC Regional Offices have reviewed and evaluated the Quality First Program.
At least three members of the office of Investigation have visited the site to review the program and results of several Quality First investigations into allegations of wrongdoing.
NRC has had unrestricted access to all Quality First files, all Quality First personnel and management.
NRC personnel have contacted individuals who submitted concerns to Quality First.
According to NRC Inspection Reports, Inspection and Enforcement personnel have reviewed 136 Quality First files, more than half of all Quality First files.
Additional files have been reviewed -
)duringinspectionsforwhichreportshavenotyetbeen v
received.
25.
The history of NRC review of the Quality First 4-Program at WCGS dates back to April'6, 1984, when a L
presentation on the Program was given to Region IV and to April 17, 1984, when a presentation on the Program was given to n
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Commissioner James Asselstine during his site visit.
A similar l
presentation was given to Director of Nuclear Reactor
'Re'gulation Harold Denton and., Region IV's Administrator John Collins-on May 10, 1984.
An NRC resident inspector sat in on i
Quality First's interviews of project workers and selectively f
reviewed investiation files.
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26.
The first full NRC inspection of the Quality First 4
Program took place on September 25-27, 1984 and involved 53 j.
on-site inspector-hours by 3 NRC inspectors.
Inspection Rept.
No. 50-482/84-37.
The inspection was carried out "even though the program is not specifically required by NRC regulations."
Letter from Richard P. Denise, Director Wolf Creek Task Force, NRC to KG&E,. dated No'rember 2,1984.
As part of the inspection, the NRC reviewed 27 case files which had already i
been closed.
No violations or deviations were found and "the NRC inspectors reached favorable conclusions regarding q
l evaluation of technical concerns...." Id.
The inspection did i
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" identify deficiences' requiring some correction to-help ensure an' effective program."
Id.
27.
The Inspection. Report itself noted that continued
- attention was.being devoted to staff needs, that the qualifications of the Quality First staff appeared to be
' adequate, that documentation in closed files appeared adequate and complete, and that all records were being maintained in a confidential manner to protect the identify of allegers.
In sum, the Inspection Report 50-482/84-37 (p.4)-found that the
" Quality First organization-is effectively implementing the program as planned and define'd in" the Quality Program Manual.
28.
The Report suggested a number of improvements in the Program.. Although formal guidelines were available for reporting of quality concerns and processing those concerns, additional guidance was suggested in a number of areas, including the processing of wrongdoing allegations.1/ A
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In the Nuclear Awareness Network (" NAN") undated document entitled " Analysis and Comments on the Nuclear Regulatory Commission's'(NRC) March 11, 1985 Response on the Isolation and Resolution of the Structural Steel Weld Deficiencies at Wolf Creek," attached to the Government Accountability Project's May 15, 1985 letter to the Commissioners, WAN states at p.3, "When the NRC innpected Q1 in September of 1984, it found that processing of wrongdoing concerns (i.e. drugs, alcohol, intimidation, harassment, discrimmination, falsification of information) was particularly deficient."
This is a total misstatement (continued next page),
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suggestion was made to include in Program procedures a feedback mechanism for wrongdoing concerns directed to Security or KG&E management that may also include technical deficiencies.1/
The Report suggested that certain personnel qualification requirements be included in the procedures and that a feedback mechanism from Security and KGEE management for wrong-doing concerns be established.
Finally, the Inspection Report suggested that Program procedures should address prioritization criteria.
29.
Four subsequent NRC inspection reports have examined the Quality First Program.
Inspection Report 50-482/84-48 covered the October 9 - November 2, 1984 inspection during i
N,,/ (Continued) i of the Inspection Report, which states that "[gluidance for processing of wrongdoing concerns (i.e. drugs, alcohol, intimidation, harassment, discrimination, falsification) was particularly deficient."(emphasis added).
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The NAN document cited above mischaracterized this comment by stating that "[w] hen the NRC inspected Q1 in September of 1984, it found that... informational flow had no feedback mechanism for wrong-doing concerns directed to Security or KG&E management, which may include technical i
deficiencies" (NAN emphasis).
NAN apparently would have readers believe that there were actual wrong-doing concerns directed to Security and KG&E management, which may include technical deficiencies.
The Inspection Report itself only suggested that the Program procedures address the possibility that these types of concerns may include l
technical (as well as wrong-doing) concerns.
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which NRC reviewed an additional 57 closed case files.
- Again,
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no violations or-deviations were identified.
The Report found 2
that the additional guidance on the processing of wrong-doing
- allegations and other matters had been provided,.and that criteria had been established for prioritizing concerns and l-trending analyses.
30.
Another inspection of the Quality First Program took place from November 13 - December 13, 1984 involving 51 on-site inspection hours, again identifying no violations or i
deviations.
Inspection Rept. No. 50-482/84-52.
This Report l
noted that the Procedures now incorporated personnel qualification criteria.
The inspector reviewed 31 closed case files.
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31.
A fourth inspection which examined the Quality First Program took place during December 17-21, 1984 and January 4
4 7-18, 1985.
Inspection Rept. No. 50-482/84-58.
No violations or deviations were noted.
Seventeen closed case files were reviewed by the inspectors.
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32.
The most recent report, Inspection Report No.
l 50-482/85-09 covered an inspection conducted during January 21 t
- February 15, 1985, again with no violations or deviations identified.
The inspector reviewed four more case flies as l
well as 12 closed concerns and 6 open concerns.
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33.
There have been additional inspections of the~ Quality First Program subsequent to those discussed above.
While inspection reports for these have not yet been issued, these inspections represent further in-depth NRC review of the Quality First Program.
Based on the exit interviews from these inspections, KG&E is aware of no violations, deviations, or
.open items relating to the Program.
34.
Given this substantial history of NRC inspection of the Quality First Program, there should be no question as to the 1
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I adequacy of the NRC review of the Quality First Program and its j
implenentation.
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Charles'A W ' "
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This aforegoing instetr=nt was acknowledged before me this M day of g, 1
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Nora P. Nash = Notary Public NOR4P.NAeH 4 6 p g w c >.r 9 D i
My Comnission Expires:
May 15, 1000 l
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HELP US KEEP QUALITY 1st AT //OLF CREEK e
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i Be sure to let us know how to report results back to you and how we may get back to you to clear up any questions that may arise.
All concerns brought to the attention of Quality 1st Team will be pursued. The Quality 1st Team will make every effort to resolve issues as quickly and thoroughly O
as possible.
Remember. If you have a quality or safety concern, do not ignore it. Tell your supervisor or tell your foreman. Then, if the problem you've found is still not resolved, call:
Quality 1st HOT LINE 364-8421 (ext.1818) nuramm
uality is first at Wolf Creek Generating A
tation. Nothing is more important than (V) quality and safety. Nothing gets more attention or a higher priority from those in charge of the project.
Wolf Creek is going to take the quality effort of a lot of people to bring it to completion. Should you have a concern about the way a job has been done. Think it through - and if you're still concerned, use the chain of command to let your concern be known.
t g-First, let your supervisor or foreman know during working hours. On weekends or about your concern. If you are not satisfied after hours, your call will be recorded, then call the Quality 1st Hot Line. Explain your a follow up to obtain additional information.
concern. Your concerns will be heard and A Quality 1st Coordinator will report back to th:y will be heeded.
you on how your concern was resolved. If 3 prefer a face-to face visit on your you have chosen to remain anonymous, you ity/ safety concern, como directly to the may call back in about ten working days to Quality 1st Trailer #98.
check on the status of your concern.
When you call, identify yourself (and that's You can call the Quality 1st Hot Line optional), spell out your quality or safety 364 8421 (ext.1818) any time. The line will concern. (If your call is being recorded, be answered by the Quality 1st Team please give the date and time of your call.)
When you call, give a complete description of the problem.
Let us know:
. Specificlocation of concern
. System or procedure
. Activity in process
. Date and time
. Construction or operations
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. How the Quality 1st Team can learn more about the problem
. Whether you've already notified your supervisor or foreman
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UNITED STATES t
NUCLEAR REGULATORY COMMISSION b
REGION IV
,d 11 RYAN A DR U
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e,,,e ARUNGToN. TEXAS MD11 NOV 021984 In Reply Refer To:
Docket: STN 50-482/84-37 Kansas. Gas and Electric Company ATTN: Glenn L. Koester Vice President - Nuclear
.P.O. Box 208 Wichita, Kansas 67201 i
Gentlemen:
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This' refers: to the inspection conducted by Messrs. E. F. Fox, Jr., G. L.
Madsen, and W. P. Mais's during the period of September 25-27, 1984, of activities authorized by NRC Construction Permit CPPR 147, for the Wolf Creek Generating Station, and to the discussion of our findings with Messrs. R. M.
Grant and C. A. Snyder, at the conclusion of the inspection.
Arets examined during the insdection included the structure and implementation of. the KG&E Quality First Program. Within these areas, the inspection consisted of selective examination of procedures and representative records, in' erviews with personnel, and observations by the inspectors. These findings t
are documented in the enclosed inspection report.
Within the scope of the inspection,. no vjolations or deviations were identified.
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The.Qua.1.ity First program provides a mechan' ipr't'o receive, evaluate, and resolve quality concerns which might not otherwise come to the attention of KG4ELorltotheattent3ngf_.theNRC. Because the program fulfills an a
im$[ttlnt' function,"4 decided to evaluate its effectiveness even though the program is not specifically required by NRC, regulations., Although the NRC inspectors did not identtfy'any violations or deviations, they did identify deficiencies requiring some correction to help ensure an effective program.
2.
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'I't"is important to esiphasize that the NRC inspectors reached favorable conclusions regarding evaluation of technical concerns based.on a review of l
past performancei.as established by closed technica1' files. Since the Quality Firbt program haslrecently undergone very significant changes in management stryctute,,.respur'de assignments, supervisory personnel,' senior experienced Personnsl;dsphihgly.a,1,er,t t.q. indications of deleterious thanges iri pro
'and 3he details of implementing the program, KG&E senior management should bei i.
implemedtnfiin.
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Kansas Gas and! Electric Company.f 1-
.--re4Should:you*have4ny. questions concerning-this. inspection,1we will'be pleased to discuss them with~'you. -
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Sincerely, f
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Richard P. Denise, Director Wolf Creek Task Force c.
Enclosure:
2'-
l-Appendix - NRC Inspection. Report ~',
i 50-482/84 cc w/ enclosure:
Kansas Gas and Electric Company
+
ATTN: ' Gene P. Rathbun, Manager of Licensing P.O. Box 208 WichitafKansas,'67201 i
Forrest Rhodes, Plant Superintendent Wolf Creek Generating Station j
P.O. Box 309 Burlington, Kansas 66839
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ex APPENDIX U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report:
50-482/84-37 CP:
CPPR-147 Docket:
50-482 Category:
A2 Licensee:
Kansas Gas and Electric Company (KG&E)
PJ 0. Box 208 Wichita, Kansas 67201 Facility Name: Wolf Creek Generating Station (WCGS)
Inspection At: Wolf Creek Site, Coffey County, Burlington, Kansas Inspection Conducted:
September 25-27, 1984 ONk Inspectors:
Edwin F. Fox, Jr., Technical AMistant Date-r -
N PSAS, IE m1 G
/O-Y-f Glen L. Madsen, Reactor Inspector Date j{j N-9-7V
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Walter P. Haass, Special Assistant for Date Allegations and Investigations, IE Approved:
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. 'E. Hartin,~ Chief Wol ' Creek Task Force Ke /
Inspection Summary
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Inspection Conducted September.25-27, 1984 (Report 50-482/84-37)
Areas Inspected: _ Routine announced inspection of the structure and implementa-tion of licensee programs for investigation and resolution of quality concerns resulting from exit interviews with licensee and licensee contractor employees, walk-in interviews and hot-line telephone calls.
The inspection involved 53 inspector-hours onsite by three NRC inspectors.
(P o
-Results: Within the areas. inspected, no violations or deviations were identified.
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2 OETAILS.
I 1.s. Persons 4C' ntacted. --
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- Principal Licensee. Personnel-9-
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.R.'N..: Grant,iDirector.-Quality
- C.: A.- Snyder... Manager.- Quality First OxLwThero/:; Quality;First Interview Supervisor R. L. Scott,1 Quality First Investigetion Supervisor Rt.Walters,- Quality First' Investigator L.~.Cv.Issinghoff, Quality First Interviewer Mark: Stewart, Engineer / Quality Assurance
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NRC Personnel
- Richard'Denis'e, Director Other Personnel-Other licensee' employees contacted included technicians and office x
personnel.
- Attended exit interview.
2.
Exit Interview The inspection' scope. and findings were summarized on September 27, 1984 with those? persons: indicated in paragraph 1 above.
3.
Organizational Structure of KG&E Program for Processing Allegations
.The KG&E-Quality;:Eirst. program for processing allegations is implemented under thd'.dfre~ctidn 'of C. A. Snyder, Manager-Quality First, who reports to R.. M. Grant,. Director-Quality. The latter reports to G. L. Koester, Vice President-Nuclear., The Quality First organization is acceptably located within the.KG&E organization to assure proper attention and independence.
~'Th'is:.isTariecent change from the prior organizational arrangement in which
...wthenresponsibilitynfor Quality First was assigned to W. J. Rudolph, Manager-Quality Assurance. ' The-new arrangement minimizes the potential R.qqrtconfl.icts; oftinterestgiri the processing of allegations... '
4.:., ' Formality of the Effort;as Reflected in Official Instructions,..
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n III-29Fand for processing the concerns by Quality First (QPM 19, Rev. 0)
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~are documented and have been made available to affected. personnel.
-(j.i..,RHowever, our inspection identified the need for additional guidance in the following areas:
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t V-a..
Processing of wrongdoing allegations.
b.
Responsibilities of the Engineering Support Group.
c.
Definitions of Priority 1 and 2 categories of concerns.
d.
Trending analyses to assure identification of generic concerns.
e.-
Qualification criteria for staff' personnel.
Guidance for the processing of wrongdoing concerns (i.e., drugs, alcohol, intimidation, harassment, discrimination, falsification) was particularly deficient. Responsibility for the resolution of these concerns, involve-ment 'of management, and the procedures for closecut were not described.
5.
Information Flow Procedures for the flow of information as stated in QPM 19, Rev. O are adequate, with the exception that no feedback mechanism existed for wrongdoing concerns directed to Security or KG&E management that may also include technical deficiencies, and there was no feedback mechanism from
. Security or KG&E management.regarding corrective action or disposition of wrongdoing concerns for file closecut.
6.
Number and Qualifications of Personnel
~
The Quality First organization was.found to be comprised of three inter-viewers, one engineering support person, and thirteen investigators (for resolving technical concerns) with each group directed by a supervisor. A
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request has been made and approved for ten additional investigators who are expected to be available shortly. Continuing attention appears to be i-devoted to staffing needs based on the number of concerns received to date and the number anticipated from the remaining site contractor personnel.
1 The qualifications of the Quality First staff, based on the review of resumes, appeared to be adequate for the assigned responsibilities in the various engineering, welding and quality assurance areas of expertise.
i However, no documented qualification requirements for these positions were 4
given in QPM-19 to provide continued assurance of qualified staff I
personnel.
Further, use of specific investigators to resolve quality concerns consistent with their areas o.~ expertise should be properly coordinated.
7.
Precision and Adequacy of Decision Making Process A review of all the 27-closed technical quality files (some of which include more than one concern) was conducted through the evaluation of-file documentation.
It was concluded that the disposition of the tech-nical concerns was adequate up to the point that the concern was sub-stantiated or determined to be without merit; technical considerations of F
adequate broadness were applied in the evaluation.
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Documentation and Record Retention 4
For'the closed technical files, documentation appeared adequate and 3
complete to facilitate auditing of the records.
In addition, all records 1
7 tare maintained in a confidential mannersto protect the -identity of the allegers and are filed in accordance with QA program commitments.
- 9.
--Management Notification r
f
. A review of. the completed -technical actions indicated that upper management.is notified of the results of the investigation (whether substantiated or not) and provided a copy of the investigative report.
Management participates in Quality First meetings once every two weeks.
However, the inspectors found no documented evidence of man 1gement.
feedback with regard to concerns tracking, analysis, job perfornance, or 4
' suggested improvements.
.10. : Trending and Assessment of Trends Trending activities currently encompass projection analysis for total program scope ' definition, and identification of common technical areas
[
across the various quality concerns.
The latter could be useful for identifying generic concerns.
.11.
_ Implementation of the Quality First Program Based on the review of the technical files closed thus far, the Quality
. First organization is effectively implementing the program as planned and defined in QPM-19. The review indicated that the technical' concerns appear to have been closed properly.
A brief-review of those concerns involving wrongdoing (12 files were reviewed) indicated that in most instances they were transferred from
- Quality First to Security (for drugs) or to KG&E management for corrective i.
. action or disposition after Quality First investigation.
However, no documentation was found to describe the corrective ~ action or disposition of the concerns and there was no feedback from these organizations to Quality First for closeout. With regard to appropriateness of involving
- DOL on matters of d'iscrimination, KG&E indicated that employee protective rights are posted.at various plant locations. -
12.. Priority Treatment of Concerns 1
Quality First has established categories for assigning priority for the processing of concerns. Priority 1 concerns are those determined to impact fuel load, while Priority 2 concerns are those of a less--
significant nature. However, as stated in item 4 above, QPM-19 does not address the criteria for determining the placement of concerns in each
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category. NRC needs to.be kept informed regarding category placement decisions-for all quality concerns.
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- 13. Progress of Effort Toward Resolution of Concerns The licensee is apparently intent upon resolving all of the quality
'l concerns, Priority 1 as well as Priority 2, by their projected fuel load date. As of September 27, 1984, there were 342 open concerns, of which 212 are Priority 1, and 220 closed concerns, of which 77 had been transferred to other KG&E organizational units for resolution.
The licensee is aware of the backlog and the effort required to resolve the issue. Resources necessary to accomplish this task prior to fuel loading have been authorized. The. licensee is also fully aware of the need for NRC to be informed regarding the adequate resolution of all quality concerns.
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UNITED STATLG l
I NUCLEAR REGULATORY COMMISSION o
3 U~ u h M
1 REGION IV e
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PARKWAY CENTRAL PLAZA ButLotNG 811 RYAN Pt.AZA DRIVE. GUITE 1000 j,om.
ARLINGTON, TEXAS 79011
\\j DEC 1 S 1984 In Reply Refer To:
Docket: STN 50-482/84-48 Kansas Gas and Electric Company ATTN: Glenn L. Koester Vice President - Nuclear P. O. Box 208 Wichita, Kansas 67201 Gentlemen:
This refers to the inspection conducted by Mr. G. L. Madsen of this office during the period October 9-November 2, 1984, of activities authorized by NRC Construction Permit CPPR-147 for the Wolf Creek Generating Station, and to tae discussion of our findings with F. Rhodes and R. Grant and other members of your staff at the conclusion of the inspection.
Areas examined during the inspection included implementation of the KG&E Quality First Program and the licensee's overall startup test program. Within rg these areas, the inspection consisted of selective examination of procedures
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)
and representative records, interviews with personnel, and observations by the
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inspectors. These findings are documented in the enclosed inspection report.
ope of the inspection, b(o'11tionsecradeviations.y_er,ej We have also examined actions you have taker, with regard to previously identified inspection findings.
The status.of these items is identified in paragraph 3.b of the enclosed report.
i Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, R. P. Denise, Director Wolf Creek Task Force
Enclosure:
Appendix - NRC Inspection Report 50-482/84-48
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9-KansasGasandElectric. Company.'cc w/enclosu're:
Kansas Gas. and Electric Company-fATTN: Gene'P.~Rathbun,~ Manager of Licensing.
P. O.: Box 208
. Wichita',' Kansas-67201 e
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Forrest Rhodes,. Plant Superintendent j,
Wolf Creek Generating Station P. O. Box 309 l
Burlington, Kansas.66839 j
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APPENDIX
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION IV NRC Inspection Report:
STN 50-482/84-48 Construction Permit:
CPPR-147 Docket:
50-482 Category:
A2 Licensee:
Kansas Gas and Electric Company (KG&E)
P. O. Box 208 Wichita, Kansas 67201 Facility Name: Wolf Creek Generating Station (WCGS)
Inspection At:
Wolf Creek Site, Coffey County, Burlington, Kansas Inspection Conducted: October 9-November 2, 1984 7!/Y Inspector:
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'G. L. Madsen, Reactor Inspector Date Approved:
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C E. Martiri,
'feT, Wolf Creek Task Force Ope /
Inspection Summary Inspection Conducted October _9-November 2, 1984 (Report STN 50-482/84-48))
Areas Inspected:
Routine, announced inspection of the structure and implementation of licensee programs for investigation and resolution of quality concerns resulting from exit interviews with licensee and licensee contractor employees, walk-in interviews and hotline telephone calls, and evaluation of the licensee's overall startup test program.
The inspection involved 87 inspector-hours onsite by one NRC inspector.
Results: Within the areas inspected, no violations or deviations were identified.
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t' DETAILS
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1..
Persons Contacted R. - M. ' Grant, Director-Quality _
- C. A. -Snyder, Manager-Quality First
- 0. L. Thero, Quality First Interview Supervisor
- ~
R. L. Scott, Quality First Investigation Supervisor
- D. L. Daniels, Quality First Interview Supervisor R.- L. Walters, Quality First Investigator
- D. Rice,-Security Operations. Supervisor F. T. Rhodes, Plant Manager W. J. Rudolph, Manager, Quality Assurance (QA).
W. G. Norton, Reactor Engineer Supervisor G. Reeves,-Supervisor, Quality Control (QC)
C. G. Patrick, Supervisor, Quality Evaluation R.-M. Stombaugh, Supervisor, QA Audits NRC Personnel f
- W. G. Guldemond,' Senior-Resident Inspector H. F. Bundy, Resident Inspector
. B. L. Bartlett, Resident Inspector Other Personnel t
Other licensee employees contacted included technicians and office I
- personnel.
b.
v.e. 4. -
v 2.
Exit Interviews Exit interviews were conducted on October 19, 1984, with C. A.'Snyder and R. L. Scott and on November 1, 1984, with R. M. Grant and C.'A. Snyder to discuss the inspection findings and' concerns relating to the Quality First Program.
W. G. Guldemond of the NRC staff attended the November 1, 1984, l
meeting.
^ ' '
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- An exit interview was conducted on November 2, 1984, with F. T. Rhodes and
' W.'.J. Rudolph to discuss the, findings relating to the evaluation of-the overall Startup Test Program.
W. G. Guldemond, H.-F. Bundy, and B. L.
0 Bartlett of.the NRC Wolf Creek resident staff were in attendance.
3.
KG&E Quality First Pruaram The inspection results relating to the structure and implementation of the...
licensee programs for investigation and resolution of quality concerns i.
resulting from exit interviews, walk-in interviews, and hotline calls were,__ ' ',
documented in NRC Inspection Report STN 50-482/84-37. - The purpose.of this ;4 2..--
inspection was a followup to concerns identified during the previous i-inspection and a continuation of the evaluation of KG&E's implementation e
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The results of this inspection effort
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follows.
a.
KG&E Organizational Structure For the period covered by this inspection, the Quality First program was implemented under the direction of C. A. Snyder, Manager-Quality First, who reported to R. M. Grant, Director-Quality.
The latter reports to G. L. Koester, Vice President-Nuclear.
During the course of this inspection, the inspector was advised of KG&E's plan of reorganization which will have C. A. Snyder, Manager of Quality First reporting to Kent Brown, Executive Vice-President.
This arrangement will further reduce the potential for conflicts of interest in the processing of allegations.
b.
Quality First Program and Instructions KG&E has revised the Quality First program document (QPM 19) and has issued the following Quality First Administrative / Process guidelines:
QFI-001 Quality First Administrative / Process Guidelines Issuance and Control QFI-002 Processing Quality First Investigation Reports, Action 1 [
Requests (QFAR), and Observations (QFO)
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QFI-003 Quality First Interviewing Technique Guidelines QFI-004 Preparing, Maintaining, and Closeout of Quality First Concern Files The revised program document and the newly issued guidelines provide the needed additional guidance identified in NRC Inspection Report STN 50-482/84-37, in the following areas:
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1.
Processing of wrongdoing allegations.
2.
Responsibilities of the engineering support group.
3.
Definition of Priority 1 and 2 categories of concerns.
4.
Trending analyses to assure identification of generic concerns.
Guidelines are in preparation which are to provide guidance for qualification criteria for Quality First personnel, c.
Numbers and Qualification of Personnel At the end of the inspection period, the Quality First organization O
was comprised of two interviewers, one engineering support person, g
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j and 15 investigators (for resolving technical concerns).
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Daniels replaced O. L. Thero as interviewer supervisor.
Based on a review of resumes.and discussions with selected personnel, the qualification of the newly assigned personnel appeared to be adequate for their assigned responsibilities.
However, no documented qualification criteria for these positions was available.
As discussed in paragraph 3.B above, guidelines for qualification 4
l criteria are presently in preparation.
This matter is considered to i
l be an open item (482/8448-01).
[l d.
Review of Closed Quality First File Cases I
J 4
A review of 57 closed case files (some which included more than ona concern) was conducted through the evaluation of documentation in the case file.
Thirty of the cases reviewed dealt with nonquality related matters such as cost, scheduling, industrial safety,'and work j.
assignments.
For the remainder of the cases reviewed, it was concluded that disposition of the technical concerns were substantiated or found to be without merit, corrective actions were' initiated, and an attempt was made to recontact the individual that submitted the concern.
e.
Trending and Assessment of Trends g
Quality First activities are trended based on the number of concerns received and investigation of concerns closed.
As of October 28, j
1984, KG&E records indicated that 610 concerns have been received, 392 investigations have been closed, and 218 concerns remain open for I
investigation.
During the period September 30, 1984, to October 28, 1984, 48 concerns.were received.and 149 investigations of concerns l
were closed.
The number of open concerns was reduced from 329 to 218.
l f.
Priority Treatment of Concerns i
As indicated in paragraph 3.b above, Quality First has established criteria for assignment of priorities for processing of concerns.
j Following issuance of the criteria, all open concerns were reassessed regarding priority for completion. As of October 28,-1984, 139 open concerns had,been assigned a Priority 1.
Priority 1 concerns are
(
those considered to have a potential impact on fuel loading..
2 g.
Control of Quality First Activities
~
i Quality First established a computerized control for their l
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activities.
Information fed into the computer file includes the following information:
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1.
Case file and concern'identific'ation..
2.
Category for each concern (presently 17 categories) %. k....
3.
Concern findings (6 options) l
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Concern priority.
5.
Assigned investigator.
6.
Reference to closure letter.
7.
Date of file opening.
8.
Date of concern closure.
9.
Date of file closure.
The computer list presently indicates 98 closed case files.
Quality First is presently performing a verification program to assure the accuracy cf the computer information for the closed files.
Additionally, guideline QFI-004 includes a requirement for completion of a new (uality First file folder checklist.
Quality First is presently in the process of preparation of a checklist after each case folder presently in the organization's master file.
h.
Exit Interviews - Quality First Personnel I
The file of exit interviews for former Quality First personnel was reviewed.
The file did not contain adverse comments relative to construction quality; however, four individuals declined signing of the exit sheet with no indicated explanation, i.
Drug Related Concerns During the early portion of this inspection, the drug related concerns were reviewed.
Eight of the cases were transferred to security and two to construction management for evaluation. The inspector noted an absence of a formal program for these activities, including:
1.
Transfer from Quality First.
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2.
Evaluation of the concern.
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i 3.
Feedback of finding to Quality First to permit an evaluation relative to the effects on quality.
4.
Feedback to the alleger.
As noted in paragraph 3.b above, QPM-19 has since been revised and includes formalization of actions regarding the above listed concerns.
4.
Overall Startup Test Program The purpose of this inspection was to determine whether the licensee has developed administrative controls which will assure that the startup test program (core loading and power ascension) will be prepared, performed, and evaluated in accordance with regulatory requirements.
References and documents utilized for this inspection activity are as follows:
a.
Chapter 14 of Wolf Creek and SNUPPS FSAR.
b.
Q640.6, Q640.11, pages 3A-23 and 3A-23A of the SNUPPS FSAR.
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c.
d.
KG&E Proceduras.
(1) ADM-01-070, Revision 0 (draft), "Startup Test Program" (2) ADM-07-101, Revision 13, " Wolf Creek Generating Station
-Procedures, Content, and Format" (3) ADM-07-100, Revision 18, " Preparation, Review, Approval, and Distribution of WCGS Procedures" (4) SU75008, Revision 0, Startup Program Reference Document and Phase III Startup Schedule, Revision 3 (5) Startup Sequence Procedures 507S009 through SU75016 A review of the above references and documents linked with discussions with various KG&E personnel resulted in the following observations and conclusions:
a.
Test Program
~s (1) The overall test program is described in KG&E Procedure
/
A0M-07.-070, and the startup program reference document 5U75008.
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The general areas include core loading, initial criticality and low power and power ascension testing as specified in the FSAR for WCGS.
The plant manager has the overall responsibility for safe operation of the plant.
The superintendent..of technical 3
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support is responsible for the startup test program as delegated by the plant manager.
The reactor engineer supervisor is
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responsible to the superintendent of technical support for the administration of the startup test program, preparation of test procedures, performance of the test program, review of test results, and preparation of the final startup report.
l (2) A comparison of the FSAR test commitments to the context of
(
Phase III startup schedule SU75008 revealed.that appropriate tests are scheduled. A natural circulation test and a loss of heater drain pump test are to be performed at the lead SNUPPS
. - plant (presently planned for Callaway) in accordance with Q640.6 l
of the SNUPPS FSAR.
WCGS will prepare procedures for these tests in preparation for performance of these two tests in case ' "
l Wolf Creek becomes the lead SNUPPS facility.
a A comparison of the tests scheduled in Phase III Startup. - ~
Schedule 5U75008 to the reference and procedure body sections of j
the plateau sequence documents"SU7S009-through-SU750016 revealed--
apparent discrepanciec.. Discussions with KG&E personnel i
r ~~3) f resulted in an agreement to make changes to the reference and
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procedure body of Procedures.SU75009 through SU75016 to more
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x clearly reflect'the sequence _of startup test activities.
This matter is considered open item (482/8448-02).
(3) Procedures ADM-07-101, " Wolf Creek Generating Station i
Procedures, Content, and Format," and ADM-07-100,' " Preparation,
' Review,-Approval, and Distribution of WCGS Procedures " include instructions relating to the following:
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(a) Management approval (b) Plant safety review committee reviews (c) Test objectives (d). References to FSAR*and Technical Specification limitations i
(e). Pertinent prerequisites t
(f) Acceptance criteria b
(g) Provisions for checkoff lists 1
(h) Procedure modifications.
l (i) Step by step instructions for procedure performance (j) Special precautions (k) Instructions for data taking and record keeping.
(4) A review of FSAR commitments and commitments to Regulatory I
Guide 1.68 and discussions with KG&E personnel revealed general i
i agreement.
However, the NRC inspector was informed that KG&E's p
. plans include using preoperational testing checkout of systems t (
to fulfill the requirements of Regulatory Guide 1.68 for the startup program.
This matter is under evaluation by NRC and is considered an open item (482/8448-03).
i-b.
' Test Oraanization The overall responsibility for the safe operation of the plant
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and overall control of the startup activities has been assigned
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l to the plant manager. The superintendent of operations is delegated the responsibility for the safe operation of the L
station.in support of the Startup Test Program.
The superintendent of technical support -is responsible for the Startup Test Program and the reactor engineering supervisor is l
l responsible to the superintendent of technical support for the administration, test procedures, test performance, review of L
tests. and' preparation of the final startup test report.
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c.
Test Program Administration t
A review of administrative measures which have been established
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governing the conduct of testing includes:
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(1). Distribution of WCGS procedures and table of contents are made by the PSRC clerkler~ distr bidioh IT1dex.
An updated table of contents, indicating the current revisicn for the applicable procedure group, will be transmitted with each procedural transmittal.
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(2) Personnel' performing testing activities shall be qualified to their normal job functions in accordance with ANSI /ANS 3.1-1978.
Training for non-Wolf Creek Staff will be conducted and records maintained in accordance with ADM-06-100, " Training and Qualifications Records," and ADM-06-101, " Test Administration."
(3) Methods for changes to test procedures during the conduct I
of the test.
(4) Criteria for interruption of a test and continuation of 1
testing.
i (5) Methods for documentation deficiencies and obtaining f
resolutions.
1 The formal control for scheduling of test activities is accomplished through the utilization of startup sequence Procedures SU75008 through SU75016.
The reactor engineering i
supervisor in conjunction with the lead test engineers will determine which tests will be conducted on each shift based on startup sequence documents and current plant conditions.
i The program for evaluation of test results include the i
following:
(1) Test results are compared to design and safety review acceptance criteria.
.m eu (2) In the event of deficiencies, appropriate contingency l
actions include such things as (1) reexamining the i
measurement data for possible computational errors; I
(2) verifying that measurement conditions are consistent with design test conditions; (3) repeating the measurement if the discrepancy remains unresolved; (4) performing additional tests to determine the source of the i
discrepancy; and (5) revising the plant operating
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procedures to permit operations while a review of safety..
l implications is being made.
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(3) The results of tests are reviewed as.follows:*
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(a) The review package is assembled by the lead test ~'
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engineers.
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(b) Review and acceptance by the reactor engineering
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(d) Review and acceptance by the PSRC.
(e) Review and acceptance by the plant manager.
(f) Test records place in QA records room.
(g) Startup report by the reactor engineering supervisor, d.
Startup Test Program Reference Document SU75008 indicated that, "in general, each test procedure should be performed in the recommended sequence and the test results evaluated prior to proceeding to the next sequence.
In this way, the individual test sequences provide natural " hold points" in the startup prcgram for systematic review of test results and an evalua'. ion of test deficiencies for program continuity." This approach is in accordance with Regulatory Guide 1.68.
However, the procedure also contains the words, "For those tests which require an extensive amount of data analysis and whose acceptable results are not a prerequisite for the next test sequence, the test evaluation may be deferred until later in the startup program so that unnecessary program delays can be avoided." Fifteen tests are listed with specifications for " test performed at" and " test results required before exceeding." The delay of results
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evaluation until a later sequence is presently under evaluation by NRC for acceptability and is considered an open item (482/8448-04).
e.
Test and Measurement Equipment The instrument and control (I&C) supervisor is responsible for the control of I&C test and measurement equipment and the operation of the I&C test laboratory.
Their activities are governed by Procedure ADM-08-801.
Presently Revision 4, dated October 8, 1984, is in effect.
The procedure includes requirements for calibration, traceability to recognized standards, calibration stickers, identification stickers, history use logs, and calibration schedules and records.
A review of records for two instruments revealed three periods where calibration was performed after the prescribed due date.
A review of history use records indicated that the instrument had not been utilized during the expired calibration periods.
The mechanical and electrical supervisors are responsible for the control of their test and measurement equipment.
Their responsibility includes identification-of-the-instrument, affixing calibration tags, maintaining records, and scheduling O
of recalibration.
Mechanical and electrical utilized the I&C calibration laboratory for much of their calibration activity;
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however, some of the work is performed by authorized vendors.
s' Mechanical and electrical are controlled by their own administrative procedures. A check of two electrical devices indicate that calibrations were current.
f.
During the review of sequence Procedures SU75008 through SU75016, no clear evidence of QA/QC involvement during the Startup Testing Program was apparent.
Discussions with KG&E QA and QC personnel revealed the following:
(a) QC has planned involvement during the initial fuel loading activities.
(b) QA has planned audits for completion of preoperational testing and readiness for startup activities.
(c) Quality engineering is scheduled to audit startup i
procedures to determine adherence to licensing commitments.
This effort is to include a determination of the need for QA/QC hold points in the startup test program.
The audit of these procedures is scheduled to start November 5, 1984.
'N (d) During the startup testing phase, the QA audit and QA surveillance groups are scheduled to be involved.
The i
exact scope has not been defined.
1 The question relating to QA/QC involvement will require additional evaluation and is considered an open item (482/8448-05).
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.,, N., LEAR REGULATORY COMMISSION
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611 RYAN PLAZA DRIVE. SulTE 1000 8
ARLINGTON, TEXAS 76011 9 *-
O m 2 ees
\\'v In Reply Refer To:
Docket:
STN 50-482/84-52 Kansas Gas and Electric Company ATTN: Glenn L. Koester Vice President - Nuclear P. O. Box 208 t
Wichita, Kansas 67201 Gentlemen:
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This refers 'to the inspection conducted by Mr. G. L. Madsen of this office during the period November 13 - December 13, 1984, of activities authorized by NRC Construction Permit CPPR-147 for the Wolf Creek Generating Station, and to the discussion of our findings with C. A. Snyder and other members of your staff at the conclusion of the inspection.
Areas examined during the inspection included implementation of the KG&E 4
O Quality First Program and followup to allegations. Within these areas, the
(
inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector.
These findings are documented in the enclosed inspection report.
Within the scope of the inspection, no violations or deviations were identified.
We have also examined actions you have taken with regard to previously identified inspection findings.
The status of these items is identified in paragraph 2 of the enclosed report.
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t Kansas Gas and Electric-Company !
i Should you have any questions concerning this inspection, we will be pleased to j
discuss them with you.
t Sincerely, f
[
R. P. Denise Director Wolf Creek Task Force j
Enclosure:
Appendix - NRC Inspection Report 1.
50-482/84-52 cc w/ enclosure:.
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Kansas Gas and Electric Company i:
ATTN: Gene P. Rathbun, itanager i
j-of Licensing i
i P. O. Box 208 j
Wichita, Kansas 67201 t
Forrest Rhodes, Plant Superintendent Wolf Creek Generating Station P. O. Box 309 Burlington, Kansas 66839 i
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APPENDIX
/~'N U. S. NUCLEAR REGULATORY COMMISSION
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REGION IV NRC Inspection Report:.STN 50-482/84-52 Construction Permit:
CPPR-147 Docket: STN 50-482 Ca tegory:
A2 Licensee:
Kansas Gas and Electric Company (KG&E)
P. O. Box 208 Wichita, Kansas 67201 Facility Nama: Wolf Creek Generating Station (WCGS)
Inspection At: Wolf Creek Site, Coffey County, Burlington, Kansas Inspection Conducted: November 13 - December 13, 1984 Inspector:
Md-S 6
~G. L. Madsen, Reactor Inspector Date
/h lJ Approved:
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//$$bf L. E. Martin, C ef, Wolf Creek Task Force FatJV Inspection Summary Inspection Conducted November 13 - December 13, 1984 (Report 50-482/84-52)
Areas Inspected: Routine, announced inspection of the implementation of licensee programs for investigation and resolution of quality concerns resulting from exit interviews with licensee and licensee contractor employees, walk-in interviews and hotline telephone calls, and followup to allegations.
The inspection involved 51 inspector-hours onsite by one NRC inspector.
Results: Within the areas inspected, no violations or deviations were identified.
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DETAILS 1.
Persons Contacted K. Brown, Group Vice President, Technical Services C. A. Snyder, Manager-Quality First R. L. Scott, Quality First Investigation Supervisor D. L. Daniels, Quality First Interview Supervisor R. L. Walters, Quality First Investigator W. J. Rudolph, Manager Quality Assurance (QA)
C. G. Patrick, Supervisor, Quality Evaluation R. H. Stombaugh, Supervisor, QA Audits H. G. Williams, Superintendent of Regulatory, Quality, and Administrative Services K. R. Ellison, Supervisor, Startup Technical Support NRC Personnel H. F. Bundy, Resident Inspector Other Personnel
's Other licensee employees contacted included technicians and office I
personnel.
..\\g 2.
Licensee Action on Previous Inspection Findings (Closed)OpenItem(50-482/8448-01): This item was open because the Quality First program document did not provide qualification criteria for Quality First personnel. A review of the latest revision of the Ovality First program revealed that the licensee has included personnel qualification criteria.
This item is closed.
3.
Quality First Organization For the period of this inspection, the Quality First program was implemented under t,he direction of C. A. Snyder, Manager-Quality First, who reports to K. Brown, Group Vice President. Technical Services. The itRC inspector was informed that KG8E is presently reducing the size of the organization and effective December 21, 1984, the group will be coinposed of the following:
1.
Manager-Quality First 2.
One Supervisor 3.
'Four Interviewer / Investigators
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Two Secretaries
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4.
Quality First Trending and Assessment of Trends As of December 10, 1984, KG&E records indicate that 666 concerns have been received, 620 concerns have been investigated, and 46 concerns remain to be investigated. The investigative activities, associated with the existing open concerns, are scheduled for completion before the end of December 1984.
5.
Review of Closed Quality First Files A review of 31 closed case files, representing 74 concerns, was conducted through the evaluation of documentation in the case files.
The inspector's evaluation included a review of:
a.
The accuracy of the inspection plan versus the concerns received b.
The rational of the investigation, correcti e actions, and basis for closure of the concern c.
The reportability of the concern in accordance with the requirements of10CFR50.55(e) d.
The endeavors to recontact the individual that submitted the concern.
6.
Quality First Action Requests (QFARs)
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As of December 10, 1984, Quality First has initiated 76 QFARs. The QFARs are formally transmitte<.' to the responsible organization.
The QFARs include a description of condition found, proposed corrective actions, and scheduled completion date.
The QFAR program also requires a response fro:n the responsible organization to Quality First.
KG&E has established a computerized listing of issued QFARs for tracking purposes. Records indicate that responses have been received for 32 QFARs. As a result of Quality First review,11 responses were rejected and 21 responses were accepted.
In the cases of rejected responses, the QFARs were sent back to the responsible organization for action with a newly assigned due date.
The NRC inspector reviewed 10 accepted QFAR responses to assess the adequacy of the followup activities.
The remaining 55 open QFARs are scheduled for completion before the end of December 1984.
7.
Quality First Observations (QFOs)
As a result of Quality First investigation of concerns, 21 QFOs have been initiated. A QF0 is a conditicn that appears to be adverse to quality and which was outside of the area of concern being investigated. The QFOs are
[3 forwarded to the affected organization for action and closure, k
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The inspector's review of tracking systems utilized for the control of QF0 followup activities with personnel from the Quality First, QA, startup and s
operation organizations revealed the following:
a.
Tracking syst. ems were in existence for following the processing of QFOs within each organization; however, a portion of the QFOs had not been included in the operation organizations tracking system.
Quality First provided operations with a copy of all 0 fos issued to date as an initiation step to correct this condition.
b.
QA has established an audit program for assessment of the QF0 followup activities.
Of the 21 QFOs issued to date, responses have been completed for 7 QFOs.
The remaining QFOs are scheduled for completion prior to the end of December 1984.
8.
Followup To Allegation (4-84-A-80)
A utility received an employment application and resume from an individual who indicated experience with various companies involved in the construction of four nuclear power plants, including WCGS.
The utility's evaluation of the resume disclosed false statements relative to his p
service in the U.S. Marine Corps.
The NRC inspector reviewed the individual's personnel file and discussed the matter with the individual's former management at WCGS.
The review disclosed the following:
a.
The individual did work at WCGS as indicated on his resume, b.
The individual was hired during a recruitment trip to Hidland, Michigan.
The resume indicated that his previous employment was at the Midland Nuclear Power Plant.
c.
The personnel file indicated satisfactory performance of work while at the WCGS.
Based on the above, this item is considered closed.
9.
Exit Interview Exit interviews were conducted on November 16, 1984 and December 19, 1984, with C. A. Snyder.
H. F. Bundy of the NRC staff attended the November 16, 1984 meeting.
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UNITED STATES
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\\J FEB 2a m In Reply Refer To:-
Docket: STN 50-482/84-58 Kansas Gas and Electric Company ATTN: Glenn L. Koester Vice President - Nuclear P. O. Box 208 Wichita, Kansas 67201 Gantlemen:
This refers to the inspection conducted by Messrs. G. L. Madsen, R. Smith, R. Taylor, and B. Breslau of this office during the periods December 17-24, 1984, and January 7-18, 1985, of activities authorized by NRC Construction Permit CPPR-147 for the Wolf Creek Generating Station, and to the discussion of our findings with Mr. F. T. Rhodes, and other members of your staff at the conclusion of the inspection.
Areas examined during the inspection included review and witness of control
/^N room operations, preoperational tests and testing, review of completed
( j) preoperational tests, review of the KG&E Quality First program, followup on
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allegations, review of open items, review of violations, observation of simulator operations and review of startup program and administrative procedures. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspectors.
These findings are documented in the enclosed inspection report.
Within the scope of the inspection, no violations or' deviations were identified.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
~iA. L n y
R. P. Denise, Director Wolf Creek Task Force
Enclosure:
Appendix - NRC Inspection Report STN 50-482/84-58
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cc (see page 2) g jk1 "
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-Kansas Gas and Electric Company
-22 9,ecw/ enclosures: '
' Kansas Gas and Electric Company
' ATTN: Gene P.;Rathbun, Manager of Licensing
'P. 0.'. Box ~208 I~
~ Wichita, Kansas l 67201, i.
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.Forrest' Rhodes, Plant Superintendent l
' Wolf CreekLGenerating Station-
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P. 0.-Box 309.
.Burlington-Kansas 66839 i
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I
s APPENDIX f
U. S.-NUCLEAR REGULATORY COMMISSION
'N REGION IV NRC Inspection Report:
STN 50-482/84-58 Construction Permit:
CPPR-147 Docket:
50-482 Category:
81 Licensee:
Kansas Gas and Electric Company P. O. Box 208
' Wichita, Kansas 67201
-Facility Name: Wolf Creek Generating Station Inspection At:
Wolf Creek Site, Coffey County, Burlington, Kansas Inspection Condu d:
December 17-21, 1984 and January 7-18, 1985 h'} k' b
t Inspectors:
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R! Smith,'ream Leader, Wolf Creek Task Force Date N
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$-/Q-$S G. L. Madsen, Reactor Inspector Date
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- 8. Breslau, Reactor Inspector, Wolf Creek Date Task Force J-/9.f[
f.Taylo/,ReactorInspector Date
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Approved:
W 2- # # 'O
'L. Martin, Chief,~WolfGreekTaskForce
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Date Insnection Summary Insnection Conducted December 17-24, 1984, and January 7-18, 1985 N(Recort 50-482/84-58)
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.. Areas-Insoected:
Routine,. announced inspection of control room operations, preoperational test and testing, review of completed preoperational tests, review of-startup and power ascension procedures.. Review of KG&E's Quality First program, followup on allegations, review of open items, review of violations, observation.of simulator operations, review of startup program and administrative procedures.
The inspection involved 202 inspector-hours onsite by four NRC inspectors'.
Results: Within the 10 areas inspected, no violations or deviations were identified.
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DETAILS 1.-
Persons Contacted Kansas Gas and Electric Comoany
- G.-L.
Koester, Vice President - Nuclear
- C.' Mason, Project Director
'F. T. Rhodes Plant Manager
- R. M. Grant, Director Quality F. D.' McLaurin, Assistant Startup Manager M. G. Williams, Superintendent of Regulatory, Quality, and Administrative Services R. L. Stright, Licensing K. Ri Ellison, Supervisor, Startup Technical Support
- W. M. Lindsey, Supervisor, Quality Systems R. Glover, Startup Manager R. L. Hoyt, Emergency Planning Supervisor
- 0. Maynard, Licensing Supervisor
- W. J. Rudolph, Quality Assurance Manager, Site
- W. B. Norton, Reactor Engineering Supervisor M. Estes, Operations Coordinator
.[mT B. Hicks, Technical Writer-3, S. Armstrong, Shift Consultant J. Goode, Licensing Engineer H. Chernoff, Licensing
- C. A.. Snyder, Manager, Quality First H. Cambell, Startup Engineer J. D. Pickett, Startup Engineer
- R. L. Walters, Quality First Investigator A. Critchely, Quality First Investigator J. Brooks, Quality First Investigator
- C. J. Hoch, Quality Assurance Technician A. Mah, Training Supervisor P. Turner, Manager, Nuclear Training The NRC inspectors also contacted other site personnel including plant operator, startup engineers, test engineers, administrative and clerical personnel.
- Denotes those attending the exit interview on January 8, 1985, and January 17, 1985.
2.
Quality First Organization The Quality First Program continues to be implemented under the direction of C. A. Snyder, Manager of Quality First, who reports to K. Brown, Group
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,'V Vice President, Technical Services.
The organization has been reduced in size and presently consists of the following:
1.
Manager - Quality'First 2.
One Supervisor 3.
Three Interviewer / Investigators 4.
Three Secretaries 3.
Quality First Trending As of January 10, 1985, KG&E records indicate that 686 concerns have been received, 685 concerns have been investigated and one concern remains to
-be-investigated. The one remaining concern to be investigated is scheduled for completion by January 18, 1985, and is not considered to impact upon issuance of a fuel load license.
4.
Review of Closed Files To date KG&E has established 237 case files for the 686 concern received.
Following NRC Inspection Report 50-482/84-52, 83 case files, reprasenting 391 concerns, had not been closed _by KG&E or reviewed by the NRC inspector.
Seventeen case files, representing 86 concerns, were :.clected c
for closed case file review.
The NRC inspector's evaluation included a
{d review of:
a.
_The accuracy of the inspection plan versus the concern received.
.b.
The rationale of the investigation, corrective actions, and basis for closure of concerns, c.
The reportability of the concern in accordance with the requirements of 10 CFR 50.55(e).
d.
The endeavors to recontact the individual that submitted the concern.
NRC inspectors have reviewed completed activities for about 50 percent of the 237 case files, representing 686 concerns, received to date.
As of January 10, 1985, 21 case files representing 149 concerns remain to be closed. The investigation of the concerns has been completed; however, the evaluation and acceptance of responses to Quality First Action
- Requests-(QFARs) and Quality First Observations (QF0s) is in progress.
5.
Quality First Action Reouests (0FARs)
Quality First has initiated 78 QFARs'. The QFARs are formally transmitted to the responsible organizations.and require a response.
Records indicate that responses have been received and accepted for 73 QFARs. As a result
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Lj of a Quality First Review, 11 of the initial responses to these 73 QFARs were rejected and were sent back to the responsible organization for action.
Five QFARs have not been closed by Quality First.
These five QFARs are scheduled for closure by January 18, 1985.
During this inspection, the NRC inspector reviewed 18 accepted QFAR responses to assess the adequacy of the followup activities.
To date, 28 of the 73 accepted QFAR responses have been reviewed by the NRC
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inspector.
6.
Quality First Observations (OFOs)
As a result of Quality First Investigation of concerns, 22 QF0s have been initiated. A QF0 is a condition that appears to be adverse to quality and which was outside of the area of concern being investigated.
The QFOs are forwarded to the affected organization for action and closure.
Of the 22 QF0s issued, responses have been completed for 20 QFOs.
The remaining QFOs are scheduled for completion by January 18, 1985.
7.
Followuo On Allecations ex (Closed) 4-84-A-22:
This allegation case stemmed frcm a contact with a
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former employee of Daniel International Constructors and the NRC.
The t
case was referred to KG&E for followup.
KG&E personnel interviewed the
-alleger in the presence of the NRC inspector.
KG&E broke down the s
interview into 10 separate items of concern.
The NRC inspector compared the content of KG&E's 10 concerns versus notes which were generated during the initial contact between the alleger and NRC and found adequate compatibility.
KG&E examination of the 10 concerns, revealed that two of the items were valid and either required corrective action or corrective action was underway which was caused by other findings.
The remaining items were not substantiated or were found to be without technical merit.
The NRC inspector examined documentation relating to KG&E actions.
The NRC inspector considers that the individuals concerns have been examined and addressed by KG&E in an acceptable manner.
KG&E contacted the alleger and provided documentation regardi.ng their findings and action.
The NRC inspector contacted the alleger to confirm receipt of the KG&E response.
The NRC inspector considers this case closed.
(Closed) 4-84-A-98:
The allegations were received by NRC Region IV as an attachment to a letter from the U.S. Department of Labor dated September 23, 1984, in regard to a complaint received by DOL under Article 210 of the Energy Reorganization Act.
Several of the items reported by the complainant were found to have been also reported-to the licensee's Quality First organization.
The NRC inspector noted that the
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allegation received by the NRC consisted of 6 essentially separate items while Quality First had 14 separate items.
The following discussion will center first on the items common to both the NRC inspector's followup and also to the licensee's investigation.
1.
NRC Item 1:
Contrary to procedures, material traceability for pipe supports was verified at weld fitup or later.
Licensee Finding:
The allegation was confirmed.
Basic charge was that bulk steel was cut off prior to applying markings to cut off piece. Traceability of the cut off piece was later established based on records for like material.
Licensee Action:
The licensee report indicated applicable procedures had been clarified in September 1982, and that sample of records generated after that time indicated satisfactory implementation.
NRC Finding: The NRC inspector accepted the licensee's finding and would note that this is a relatively common problem involving oversights by construction craft and QC personnel. Tne resolution appears adequate based on an interview with a knowledgeable person who stated that he and his group had been involved with hundreds of like instances. When no doubt about the traceability could
([ d reasonably exist, the individual piece would be marked for traceability. Where doubt existed, nonconformance reports were
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generated and the piece in question replaced.
Several NRC inspections of completed pipe supports have not identified any significant traceability problems.
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Conclusion:==
Based on the licensee's investigation and the referenced interview, the allegation is considered substantiated and adequate i corrective action has been taken.
2.
NRC Item 2:
Engineering aids signing for engineers. All signatures on "QICs" and " Pre-QIC reviews" to be signed by hanger engineers, not aids.
Licensee Finding:
The licensee's investigation confirmed that aids to hanger engineers were signing quality inspection checklist (QICs) pre-designating inspection attributes and signing again after inspection.
The investigation revealed that the engineer or his designee could sign the form and further found that the quality engineering gave approval to the attribute selection of the hanger engineer or his aid and was responsible for the inspection.
Thus, the allegation was considered to be unsubstantiated.
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Conclusion:
The allegation was substantiated 2
- but without merit.
3.
Allegation 3:
CAT team rejected hanger X-M16-AE05-R016/145Q for missing identification and this was not properly addressed by NCR 19260H. NCR disposition in error and CRG stamped in error.
Licensee Finding: Allegation was substantiated by investigation and NCR 20369 issued to obtain proper corrective action.
NRC Finding and
Conclusion:
The NRC inspector reviewed both NCRs and found the allegation to be substantiated and that appropriate action was taken to rectify.
4.
Allegation 4:
"Use-as-is-NCRs" affectkng hanger material-dimensions and location would not have been incorporated into drawings had the alleger not insisted.
Licensee Finding:
None - this allegation was not made to the licensee.
NRC Finding and
Conclusion:
The alleger appears in his statement to say that the perceived problem was resolved to his fN satisfaction.
The alleged factors that might not have been I
i documented were within the scope of the as-built walk down
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program for pipe supports conducted by the licensee.
This program was the subject of an NRC inspection (NRC Inspection Report 50-482/84-23) which identified no violations or deviations involving the alleged factors.
Since the alleger seems to have caused satisfactory resolution, the NRC inspector was unable to substantiate the validity of allegation.
5.
Allegation 5:
Inadequate verification'of the snubber transition assemblies and of the double nuts used on sway struts. The alleger stated he achieved resolution of his concern through his efforts.
Licensee Finding:
None - comparable allegation not made to
- licensee, 4
NRC Finding and Conclusion - same as allegation 4.
6.
Allegation 6:
General breakdown in SDL (System Discrepancy List) program.
v.
Licensee Finding:
Substantiated but corrected via Daniels Construction (DIC) Corrective Action _ Request No...45..
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NRC Finding and
Conclusion:
The allegation is considered substantiated.
The allegation was adequately addressed by DIC
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Corrective Action Request No. 45.~
NRC Inspection Report 50-482/84-08 also identified significant problems with the SDL program.
NRC. Inspection Report 50-482/84-18 noted that the violation (482/8408-03) was found to be adequately corrected by revision to procedures and that lists had been updated.
-b.
-The. licensee's Quality First group received seven other concerns or allegations than those identified in the complainant's letter to DOC referenced above. These were:
1._
Hoop shinkage in stainless steel pipe at welds not procedurally _
addressed.
2..
No QC inspection of welds presently underwater in the service water pump house.
3.
No water samples taken to verify halides in flush water after removal of purge dams.
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4.
MSSWRs generally inadequate.
5.
No QC verification of coping on skewed welds.
6.
Color code not sufficient for controlling pipe bolting material.
7.
Walkdowns not covering all inspectable attributes.
Review of the Quality First group records indicated that concerns 1, 4, 5, and 6 substantiated.
Concern 1 was, however, considered without technical merit.
Concerns 4,'5, and 6 were corrected by.
reinspection programs.
Concern 2 was considered refuted because the problem had been documented in NCR 7138 in fjovember 1982, which was' dispositioned by the-A/E; the components having been redesigned which obviated the need for the uninspected welds. Concern 3 was refuted since the flushing and sampling are part of the licensee's startup
-. testing program.
Concern 7 was considered refuted since the walkdown program was not structured to inspect all possible attributes.
The NRC inspector followed up on each of the seven items by review of related documents, interviews of site personnel outside the Quality First group, and by review of NRC inspection reports. The NRC inspector determined that the Quality First investigations and findings were adequately responsive to the concerns.
No violations or deviations were identified in this area.
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Insoection of TMI Task Action Plan (TAP) Items The following TMI TAP items were reviewed to determine their stttus.
This review consisted of a comparison to NUREG 0660 requirements as clarified by NUREG 0737, to licensee implementation of the same and involved a selected review of procedures and records as well as direct inspection of physical plant conditions.
(Closed), TAP Item I.C.1, Short Term Accident Analyses and Procedure Revision.
The licensee committed to implement emergency operating procedures based on the revised Westinghouse Owner's Group Guidelines in accordance with the schedule of NUREG 0737.
The NRC inspector reviewed selected emergency Procedures, i.e., EMG-FS-33 Post SGTR Cooldown Using Steam Dump. EMG C-31 SSTR With Loss of Reactor Coolant, Subcooled Recovery, EMG FR-H1 Response to Loss of Secondary Health Sink, EMG E-0 i
Safety Injection. These revised procedures adequately address the Westinghouse Owner's Group Guidelines.
(Closed) TAP Item II.B.1, Reactor Coolant System Vents.
The licensee shall install reactor coolant system and reactor vessel head high point vents remotely operated from the control room. A review of system drawings M02-BB04-Q (Reactor Head Vent System) and M12-BB02-Q (PORV)
O coupled with a direct inspection of the installation indicated adequate i
installation of the vent systems.
Remote control and indication is fv) acceptably established in Systems Operation Procedure SYS-BB-110.
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(Closed) TAP Item II-B-2, Plant Shielding.
Each licensee shall provide for adequate access to vital areas or temporary shielding, or postaccident
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procedural controls.
The design review shall determine which types of corrective actions are needed for vital areas throughout the facility, The licensee submitted its analysis to the NRC which was subsequently g
accepted and documented in NUREG 0881, Supplement 2.
An onsite inspection of dose rate zone maps, inline monitoring systenis and shielding installation meets the requirements within this item.
4 9.
Action on Previous Inspection Findinos (Closed) Open Item (482/8426-03) - NSSS Vendor Review of Power Ascension and Emer.gency Procedures for Operating License Applications:
Operating license applicants are required to obtain reactor vendor review of power ascension and emergency procedures as a further verification of the adequacy of the procedures.
NRC Inspection Report 50-482/84-44 closed this item after conducting a detailed review of licensee documentation, these inspections results are adequate to close this open item.
(Closed) Open Item (482/3426-05) - Relief and Safety Valve - Applicant's shall submit to NRC, a correlation.or_ other-evidence to_ substantiate.tha-relief and safety valves tested in a generic test program demonstrate the (Q}
functionability of as-installed primary relief and safety valves.
Evidence of PWR relief block valve functionability will also be provided.
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. NRC Inspection Report 50-482/84-55 closed this item after conducting a detailed review of licensee documentation, these inspection results are adequate to close this open item.
(Closed) Open Item (482/8426-13) - The installation of inadequate core cooling instruments, supplementing the primary saturation monitor, must cover the full range from normal operation to reactor core uncovering.
This item-is being tracked by SER Item 84-00-140, which will remain open*
pending system operability.
(Closed) Open Item (482/8426-14) - Shift Relief and Turnover Procedures:
.This item is adequately addressed by Administrative Procedure ADM 02-010
" Shift Reitef and Turnover."
(Closed) Violation (482/8420-01) - The NRC inspector reviewed and verified that preoperational test SU3-BG03 has been properly corrected to reflect the requirements of WCGS Administrative Procedure ADM 14-200.
Additionally, the attendance sheets were reviewed which reflected that training sessions had been conducted for all startup personnel covering the requirements of the startup administrative procedure.
(Closed) Open Item (482/8426-10) - Two channels for accident monitoring of containment pressure are installed. The licensee has calibration h\\
procedures for these instruments.
This item is closed.
This is
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l Tasks II.F.1 Attachment 4 of NUREG 0737.
V (Closed) Open Item (482/8426-11) - Task II.F.1. Attachment 5 requires that a c.ontainment water level monitor be installed.
The following containment water level indicators are in place and operable:
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Normal sump level, 2 channels
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~ Recirculation sump level, 2 channels There are approved procedures for calibration of the transmitters and instrument loops for both level indicators.
This item is closed.
(Closed) Open Item,(482/8426-12) - Task II.F.1, Attachment 6, Containment Hydrogen Monitor. -A continuous indication of hydrogen concentration in the containment atmosphere shall be provided in the control room.
Measuring capability shall be from 0-10' percent under positive and negative ambient pressure conditions.
The indication shall function properly within 30 minutes of safety injection.
There are two hydrogen analyzers installed at the Wolf Creek facility that are in compliance with the requirements of tJUREG,07_37..
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- There areiapproved calibrations 'and operability verification-procedures to
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Operating procedures have been provided for placing this system in use and
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the'use is specified in the emergency procedures.
This item is closed, i-F
.(Closed) Unresolved Item (482/8429-03)..This item was unresolved due to F
the FSAR requiring that replacement training for.the I&E technicians be i
accomplished by classroom lecture for:
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'"1.
Fundamentals of instrumentation and control 2..l Pneumatic systems and equipment 3.
Electronics b
' 4. : Plant systems 5.~
I&C and other job related procedures 6.
Surveillance requirements" s
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The.NRC Inspector found that items 1, 2, 3, and 5 above were being handled by self study, not classroom training; that item 4 was being taught in the l
classroom; and that item 6 had not been accomplished. 'With regard to items 1, 2. 3.-and 5, the NRC inspector concluded that the licensee's program was adequate.
The NRC i_nspector also found that the FSAR committed that the I&C
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supervisor and most KG&E.I&C technicians would complete a 15-week.-
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1 Westinghouse I&C course. The NRC inspector found that the Westinghouse
!&C course-actually was 11 weeks in length. The difference between the 11 j
and 15 week courses was, according to licensee representatives, caused by the deletion of material not directly related to the Wolf _ Creek' site.
It i
u was determined that the licensee's training in the I&C area was-technically adequate.
Further review of revisions to the FSAR indicate's that'the FSAR has been revised to reflect the training that is required for Wolf Creek plant.
(Closed)Open' Item (482/8429-04)- The NRC inspector reviewed training l,
records and requirements for training of the.I&C technicians as related to j:
surveillance testing and concluded that in the area inspected this j
training and training plans were' adequate.
This' item is closed, i.
.(Closed) Open Item (482/8429-05) - The NRC inspector noted in review of i
p the FSAR requalification plan that results of evaluations of licensed f
operators were not included. This is a requirement of 10 CFR Part 55, j;
Appandix A.
The NRC inspector also noted that the reactivity manipulations did not include all items as required by NRC letter from 1
H. R.'Denton, dated March 28, 1980.
Documenting results of' evaluations j:
and the reactivity manipulations.are now included. This item is closed.
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(Closed) Open Item (482/8426-01) - Three Mile Island Action Plan Item 1.A.1.1 Shift Technical Advisor. The Shift Supervisors and Senior Operators have had 60 semester hours of technical or scientific education.
A Safety Evaluation Report (SER) has been written documenting acceptance of this i
-approach for the Wolf Creek Generating Station.
This item is closed.
(Closed) Open Item (482/8426-06) - Three Mile Island Action Plan Item II.B.4. Training for Mitigating Core Damage. The plant manager has completed the required training and the NRC inspector had reviewed the records of this training and considers the actions taken acceptable. This item is closed.
(Closed) Unresolved Item (482/8446-01) - Independent Witness of Testing l
During Startup Testing. The licensing Quality Assurance organization reviews all startup test procedures.
This Quality Assurance organization has performed, reviews, audits and surveillance inspections of testing and has plans and schedules for future reviews, audits and surveillance inspections. The testing organizations has inserted witness signoff steps in the test procedures that will be performed by a person other than the person performing the test.
There are also requirements for technical reviews of test and sections of tests by manageaent and the Plant Safety and Review Committee. The inspector considers these type activities adequate at this time and conformance and technical adequacy will be inspected during the (startup) power ascension phase of operation. This I
item is closed.
M (Closed) Violation (482/8438-01) - Failure to Follow Procedures.
The licensee's response to this violation has been reviewed and is acceptable.
Additional witnessing of that preopertional testing had shown that corrective action has been taken and improvement has been achieved.
This item is considered closed.
(Closed) Violation (482/83-36, Part 3) - Sagregation of Like Material With Different Quality Requirements.
Baseo on a review of DIC Nonconformance Report ISK 14670C and Cooper-Turner, Inc. letter dated December 12, 1983, it is apparent that regardless of what is stipulated in a purchase order to govern testing and documentation requirements for a given type of load indicating washer, Cooper-Turner produces and tests the washers in the same manner.
The above referenced letter was provided with a typical test certificate for the product. The letter states that the manufacturing plant (in England) tests each " cast" for load development capability in a companion bolt at a standard.015 washer protrusion gap.
The letter also states that the company's laboratory in Pennsylvania also performs a comoarable test. The provided test certificate indicated the minimum six tests had been performed on one " cast" while another " cast" was tested a l
total of 48 times. The typical test data indicated results of a consistent nature and all indicated an ability to develop a bolt preload l
approximately 10 percent greater than the required minimum proof load of l
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the asscciated bolt.
It follows that segregation of the washers by purchase order requirements would not contribute to the quality of installed bolted connections.
The licensee also caused DIC to research all field procurement orders to assure that the orders contained the technical product requirements of the Bechtel Technical Specification.
Bechtel also undertook a review of essentially the same orders already reviewed by DIC to provide further assurance that all purchase orders contain appropriate requirements. All of these actions have been documented in DIC Corrective Action Report 1-G-0036., This item is considered closed.
(Closed) Violation (482/83-36,Part7):
Use of Hot-Forged High Strength Bolts with LIWs. The licensee has stated that he believes that the inclusion of American National Standard B18.2.1 within ASTM A-325 and ASTM A-490 is sufficient to preclude the concern for under head distortion.
The NRC inspector agrees Table 5 of ANSI B18.2.1-1981 does require that the surface under the head of these particular bolts to be washer faced and flat.
By letter dated November 12, 1984, Cooper-Turner appears to contradict their cautionary note, at least as it applies to A-325 and A-490 bolts.
The NPC inspector examined a small sample of A-325 and A-490 bolts which may or may not have been hot-forged (documentation by the
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supplier of the forging method is not a requirement).
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did have a raised, washer faced, flat area under the heads in conformance K/
with ANSI B18.2.1-1981.
This item is considered closed.
(Closed) Unresolved Item (482/8336-04): Weakness in Procedures for Turnover of Construction Records to Permanent Record Vault - DIC Procedure QCP-I-05, Revision 20, contains the necessary provisions to document post initial-review changes to quality documentation. QCP-I-05 also contains necessary instructions to assure that nondiscipline related quality occumentation will be forwarded to the licensee for retention.
The several discipline related procedures and QCP-I-05, all for document review activities, have been revised to require review and retention of procurement documents versus the documented design as-built status. The NRC inspector was satisfied that the procedural changes have been implemented based on an interview of a licensee employee that had been heavily involved in the activities of the Combined Review Group (CRG) since its inception.
This item is considered closed.
(Closed) Unresolved Item (482/8336-05):
Procedure For Design of No-Go Gages for Determining the Acceptability of Joints Tightened Using LIWs -
Via a licensee prepared mockup containing two each A-325 and A-490 bolts, one each 3/4" and one each 1-1" bolt, the NRC inspector verified that the field modified feeler gages would go between the compressed washer protrusions and thus are capable of accurately measuring the required iv
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'v' washer gap with'the same accuracy as the washer vendor supplied gages.
This item is considered closed.
(Closed) Unresolved Item (482/8336-06): Apparent Lack of Procedures for Revision Control of Manufacturer's Instruction - The NRC inspector found that paragraph 4.16 of Procedure AP-IX-03, Revision 22, requires that each vendor manual or. instruction be received and stored by DIC Document Control.. This provision is applicable to both original and to subsequently revise vendor documents. The above paragraph also requires Document Control personnel to send the new or revised document to the
-appropriate lead discipline (installation) engineer who is required to review the document for impact on installation instructions and to document such review on a form to be returned to Document Control for retention. This item is considered closed.
(Closed) Open Item (482/8418-01): Temperature Differentials for Ultrasonic Examinations - The licensee provided the NRC inspector with a letter by Westinghouse dated January 8, 1985, stating that examiners are trained and instructed to enter differential temperature on all records as opposed to entering the temperature for the calibration block and the component under examination.
The licensee stated the above referenced letter will be placed with the records for permanent' retention. This item is con:;idered closed.
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(v) 10.
Test Results Review The NRC inspector reviewed the following preoperational test results for technical content, compliance with the Safety Analysis Report, Regulatory Guide 1.68, and compliance to the Itcensee's administrative procedures:
SU3-AB01, Revision 0, Steam Pump System - The objectives of this preoperational test are to:
Demonstrate the operability of the steam dump control system control circuits in both the average temperature and steam pressure modes of operation Demonstrate the operation of the main steam dump valves and steam dump cooldown, valves, including valve response to safety signals Verify operation of the main steam line drain valves control circuits, including valve response to a turbine trip signal Verify operation of the main steam to-turbine-driven auxiliary feedwater pump supply valves control logics, including valve response to an auxiliary feedwater actuation signal r
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. i The NRC inspector reviewed the results package and from this review, the inspector consider that the stated objectives were satisfied.
Preoperational Test SU3-8807 Pressurizer Level Control Test:
The. test objective was to demonstrate the level response and stability to pressurize level changes. The alarm and control steps to level changes were checked also.
The acceptance criteria was verified and this revi.ew indicates an acceptable preoperational test.
Preoperational test SU3-BG06 Chemical and Vo"ume Control System.
The objectives of this test, are:
To determine by flow test that all letdown and cleanup flow rates are within design specification; To determine, by comparison of boron concentrations, that boric acid addition to the Reactor Coolant System has occu* red, using the normal and emergency flow patns; To determine by flow test the ability of the Chemical and Volume Control System to make up to the Reactor Coolant at design flow rates and boron concentrations, in all modes of operations; To determine by operational test that the letdown containment isolation valve closure times are within design specifications; To demonstrate the ability of the charging pump room
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coolers to maintain room temperatures within design limits; To verify the ability of the alternate seal injection flow paths to provide the required t
seal injection flow; To verify the ability of the Boron Concentration Measurement System to measure Reactor Coolant System boren concentration; To verify the maximum dilution flow rate with both centrifugal charging pumps operating.
The test acceptance criteria were met and this test is considered acceptable.
SU3-EJ02 Residual Heat Removal System:
The objectives of this test are:
Demonstrate the ability of the Residual Heat Removal System to cooldown the Reactor Coolant System at its design rate.
Demonstrate that the RHR pump suction from RCS hot leg isolation valves, Safety Injection System test line isolation valves, RHR pump discharge to hot leg recirculation isolation valve, RHR loop crosstie valves closure times are within design specifications.
Demonstrite that the RHR pump room coolers maintain room temperatures within design limits.
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The acceptance criteria were met and this test is considered acceptable.
SU3-EM01 Safety Injection System Cold Operations - The objective of this test is to demonstrate that:
The response and control circuit logic of valves, interlocks, motors and pumps of the Safety Injection and Containment Isolation Signals.
The response of the control circuit logic of the Safety Injection System to Load Shed and Load Sequencing signals.
The response of the Refueling Water Storage Tank valves associated with the Safety Injection System.
The acceptance criteria for Safety Injection Pump breakers are that each l
pump starts on a load sequencing signal and each pump stops on a load shedding signal.
The applicable valves are required to close on Containment Isolation signals or open on Safety Injection signals.
This criteria were met and this test is considered acceptable.
5U3-8804 - Pressurizer Pressure Control.
The objective of this preoperational test is to demonstrate the stability and response of the
[D pressurizer pressure control system including the verification of pressure
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alarm and control functions.
-All acceptance criteria were satisfied during the performance of this test. The test included pressure change response causing opening closing of spray valves, the energization,.de energization of heaters, opening and closing of the Power Operated Relief Valves, and the functions of the alarm annuciators.
This test is considered acceptable.
- 11. Simulator Drills The NRC inspector observed two emergency drills that were performed on the KG&E training plant simulator.
These two drills were a steam line break outside the containment and a primary leak located in the discharge piping of the charging pumps.
These drills were conducted in a satisfactory manner, however, the following comments were provided to the licensee:
More attention to margin to saturation and natural circulation should have been taken.
When verifying system are functioning properly closer observation of equipment status should be made.
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I&E Circulars 1
1 The NRC inspector reviewed the KG&E's administrative procedure for i
i controlling I&E circulars and considers the actions required and the i
h actions taken on previous I&E circulars acceptable.
13.
Exit Interview i
Exit interviews were conducted with the licensee personnel (denoted in i
paragraph 1).. Discussion were held on inspection finding in the Quality First program and the closure of open items, unresolved items and
-violations.
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' p* 44 UNITED STATES 9
NUCLEAR REGULATORY COMMISSION f.
9f REGION IV
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e PARKWAY CENTR A. PLAlt 8UILDING
- "Mt" "'iS.1Ex$' *EI "
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a 1, u MAR 111985 In Reply Refer To:
Docket: STN 50-482/85-09 Kansas Gas and Electric Company l.
ATTN: Glenn L. Koester Vice President - Nuc' lear P. O. Box 208 Wichita, Kansas 67201 Gentlemen:
This refers to the inspection conducted by R. Smith, G. Madsen, B. Breslau and K. Whittlesey, of this office during the periods January 21-February 15, 1985, of activities authorized by NRC Construction Permit CPPR-147 for the Wolf Creek Generating Station, and to the discussion of our findings with Mr. F. T. Rhodes, and other members of your staff at the conclusion of the inspection.
Areas examined during the inspection included review and witness of control
/~~N room operations, preoperational test and testing, review of startup and power
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ascension procedures, review of preoperational test results, staffing, and the
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Quality First program. Within these areas, the inspection consisted of
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selective examination of procedures and representative records, interviews with personnel, and observations by the inspectors. These findings are documented in the enclosed inspection report.
Within the scope of the inspection,'no violations or deviations were identified.
Three open items were identified in paragraph 3 of the enclosed inspection report.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, K
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R. P. D nise, Director Wolf Creek Task Force
Enclosure:
Appendix - NRC Inspection Report
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STN 50-482/85-09 U NIIY FRST cc:
(see page 2)
MAR 2 01985 MIGW SEBAM STAM M
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cc w/ enclosures:
Kansas Gas and Electric Company j
ATTN: Gene P. Rathbun, Manager of Licensing P. O. Box 208
. Wichita,. Kansas 67201 L
j' Forrest Rhodes, Plant Superintendent Wolf Creek Generating Station P. O. Box 309 l ~
Surlington, Kansas 66839 i
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j U. S. NUCLEAR REGULATORY CCMMISSION REGION IV NRC Inspection Report: STN 50-482/85 Construction Permit:
CPPR-147 Docket:
50-482 Category:
81 Licensee:
Kansas Gas and Electric Company I
P. O. Box 208 Wichita, Kansas 67201 Facility Name: Wolf Creek Generating Station Inspection At: Wolf Creek Site, Coffey County, Burlington, Kansas Inspection Conducted: January 21-February 15, 1985 Inspectors:
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R. Smith, Project Section A Reactor Project Date Branch 2
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/ _ s,s u B.' 8reslau, Project Section 8. Reactor Project Date Branch I Eb3 kfS ft w-
'G. Madsen, Project Section A Reactor Project Date Branch 2
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hv K. Whitti'esey, Prq; ec t Section A. Reactor Project Date Branch 2
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Approved:
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i I.' Martin, Chie, Wolf Creek Task Force 9'a tV i-
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Inspection Summarv i
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Inspection conducted January 21-February 15, 1985 (Recort 50-842/85-09) l 5
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Areas Inspected: Routine, unannounced inspection of control room operations, preoperational test and testing, review of completed preoperational tests, j
review of startup and power ascension procedures, staffing, review of preoperational test results and the Quality First program.
The inspection involved 226 inspector-hours onsite by four NRC inspectors.
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Results: Within the seven areas inspected, no violations or deviations were
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identifled.
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~3-A DETAILS 1.
Persons Contacted Kansas Gas and Electric Company (KGAE)
"F..T. Rhodes, Plant Manager
- C J. Hoch, Technician
- F..D. McLarvin, Assistant Startup Manager
- W. J. Rudolph, Quality Assurance Manager, Site
- M. G. Williams, Superintendent of Regulatory, Quality and Administrative Services
- 0. L. Maynard, Licensing Supervisor
'*H. K. Chernoff, Licensing
- R. L. Hoyt -Emergency Planning Supervisor
- 0. A. Namingeq, Quality Assurance Technician
- R. D. Flannigan, Site Representative "R. H. Belote, Manager, Independent Safety Engineering Group
- C. E. Parry, Superintendent Quality Systems Engineering M. Conaboy, Startup Engineer G
J. Goode, Licensing
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J. McKinstray, Operations Coordinator j
- G. L. Koester, Vice President Nuclear "J. Zell,. Superintendent Operations
- F. G. Gunnon, Quality Engineer
- W. M.*Lindsey, Supervisor Quality Systems
- R. L. Straight, Licensing J. D. Picket, Startup Engineer
- K. R. E111sca, Startup Technical Supervisor
- S. F. Hatch. Training Coordinator
- R. D. Flannigan, Kansas City Power & Light Representative
- C. C. Masor., site Director "R. M. Grar,, Director Quality
- C. A. Snyde., Manager Quality First
-R. L. Walters, Quality First Investigator A. Critchely, Quality First Investigator W. 8.- Norton, Reactor Engineering J. Costello, Startup Engineer P. 0.- Kinnerman, Startup Engineer J. G. Guimbellet, System Test Supervisor T. Fay, Licensing Engineer G.Boyer,SuperintendentTechnicaISupport T. Gloue, Training Records Clerk
. The NRC inspectors also contacted other site personnel including plant operators, startup engineers, test engineers, administrative and clerical personnel.
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During the Reactor Coolant System Hot Functional Test, the primary.
secondary and balance of plant systems were operated as an integrated system through cold operations and heatup to normal pressure and temperature, to generate steam with operation of the turbine generator and other steam auxiliaries, and through cooldown to ambient temperature and pressure. With the exception of the reactor internals inspection this-preoperational test is considered to have met its objectives and acceptance criteria.
508-0007.1 Hot Functional Plant Performance Test - The test objectives are:
To monitor the balance-of plant and electrical systems under loaded conditions during hot functional and power' ascension testing. The ability of the ventilation systems to maintain ambient temperatures within design limits is also verified.
To monitor the concrete temperatures surrounding hot penetrations and to verify evacuation alarm audibility in high noise areas.
The acceptance criteria are:
. Evacuation alarm audibility in high noise areas is verified.
The containment coolers maintain containment temperature within design.
Although 'a large number of the evacuation speakers and handsets had failed and were replaced during this test.
This test is considered acceptable.
4.
Quality First Oroanization The Quality First Program continues to be implemented under the direction of C. A. Snyder, Manager of Quality First, who reports to K. Brown, Group Vice-President of Technical Services. The organization presently consists of the following:
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Manager - Quality First 2.
One Supervisor 3.
Three Interview / Investigators 4.
Two Secretaries 5.-
Quality First Trending As of February 11, 1985, KG&E records indicate that 716 concerns have been received, 710 have been investigated.
Six concerns remain to be invtstigated.-
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Review of Qualftv First Files XG&E has established 249 case files for the 716 concerns received.
Following NRC Inspection Report 50-4a2/B4-58. 21 case files representing 149 concerns remained to be closed.
These 21 case files were closed prior to February 11, 1985, and the NRC inspector selected 4 case files, representing 15 concerns, for closed case review.
The NRC inspector's evaluation include a review of:
I a.
The accuracy of the inspection plan versus the concern received, b.
The rationale of investigation, corrective action and basis for closure of concerns.
c.
The reportability of the concern in accordance with the requirements of 10 CFR 50.55(e).,
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The endeavors to recontact the individual that submitted the concern.
Since January 1, 1985, 12 additional case files, representing 30 concerns, have been established. As of February 11, 1985, investigative activities for 24 of the 30 concerns had been completed and activities for 6 concerns remained to be accomplished.
The NRC inspector selected 12 of the 24 closed concerns for review of the investigative activities and
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corrective actions. Additionally, the NRC inspector reviewed the six open concerns and determined that closure of the following three concerns could potentially impact upon issuance of a fuel loading Itcense, a.
QCI-85-184, Item 2, Investigative activities are nearly complete.
b.
QCI-85-186, A work request has been issued and followup is in progress.
c.
QCI-85-188, A Quality First Action Request was in preparation for this item.
7.
Quality First Action Recuests (QFARs)
Quality First has initiated 84 QFARs.
Records indicate that responses have been received and accepted for all 84 QFAR's.
The NRC inspector reviewed 5 QFAR responses to assess the adequacy of followup activities.
8.
Quality First Observation (QFOs)
As a result of Quality First Investigation of concerns, 22 QFOs have been initiated. The QFOs were forwarded to the affected organization for action and closure.
Responses have been received for all 22 QFOs.
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