ML20138G698
| ML20138G698 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/11/1983 |
| From: | Griffin H NRC |
| To: | Herr H NRC |
| Shared Package | |
| ML20138G131 | List:
|
| References | |
| FOIA-84-291 NUDOCS 8512160376 | |
| Download: ML20138G698 (31) | |
Text
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Februtry il,1983 l 1
e lla'ESTIGATIVE MEMORANDU1' T0: R. K. Herr FROM: H. B. Grif fin '
n -
SUEJEC1: C0l;FIDENTIttliY AS DISCUSSED WIT
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,0n February 3_and 4,1983, during interviews withL
..._ jat Wolf Creek, thi issue'of }
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confidentiality was discussed. ( .. 'said' he AdJrey.iously talked to Bill SEIDLE. I later learned that SODLE had' granted prior to my interviews with him. During my talk with(iconfidentiality he told me he -
had_ discussed his_ contact with EEIDLE with three, Dan
[ '
discussed 'his contact withItthe RRCthat 'with since heofker had ,oldl' ality had been rendered a mute point. I tol
. m the NRC would be sanitized should it
._ ___)that his written state-used in an NRC proceeding.
[entto,\saidheknewthathisidentitycouldnotbeprotectedbecauseDaniel already h ew he h I did not offer { ~~ad) cor.tacted confidentiality,the nor I;RC didand had come he request it. to the IEC trailer.
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CiUTOMTIC INCORPORATION WC-AP-003.1 "0THER PROCEDIUtAL CHANGES REQUIREDX (Rev.7/8/S2)
INCORPp0RATIONNOTREQUIRED INTERIM CHANGE TO PROCEDURE (ICP)
ICP 621 Expiration Date 11/14/82 Procedure AP-VI-02 Revision 14 TITLE 1.
Justification: To close KGSE Audit Finding S-40011/81-18 concerning rework on ASkE stamped components.
2.
ew Effected Paragraph (s): 3 t.1 ffbb N J
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- 3. Existing Requirement: None s) g 3 g2 '- . .
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- 4. Change (3) to Read:
, Add betow 3.t.1:
Note:
Rework affecting de as-suppt.ied condition of ASME code stamped components shalt. be categor) "A" nonconformance regardless of he proposed disposition.
Originator T '# 3 N6 Date N /3 O V CONCURRENCE DATE /. AUI"dORIZATION DATE Services Manager Dise.ipline Manager (s)
Project Quality Manager c- - ,
y j rQ #-f vA Project Manager "
/V CONOmn 3CE DATE / APPROVAL DATE "
KG&E N * -ager (WCGS) '
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W Q-/4-JL' - - ypS y na >
KG&E Construction Mgr.
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. NOTE (1)
Place ( V) in appropriate block to indicate Concu(rence/ Authorization l required (Originator). i NOTE (2)
In the absence of any of the above managers, tnat manager's designee {
may provide the required Concurrence / Authorization.
NOTE (3)
NOTE (4) KG&E QA Manager-(WCGS) concurrence is required on all Safety-Related ICP's.
XG&E Construction Manager approval is requireo on all ICP's.
Varbol approval obtained from Corporate Level III NDE by Va bal approval obtained from Manager of Welding Technology
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, CONSTRUCTION PROCEDURE Tree PROJECT NAME WOLF CREEK GENERATING STATION Administrative Pr swo me.
TITLE _ h nennfnrmanes. Onntrol and Renortine AP-VI-02 v.swne sees n l I VI Does mene n 6-17-82 14 Peen 1 .e 13 PROJECT NO. 7158 FOR KANSAS CAS AND ELECTRIC COMPANY KANSAS CITY POWER AND LIGHT COMPANY - -
1 WOLF CREEK GENERATING STATION .. ,( -
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BURLINGTON, KANSAS .: ,,
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DANIEL INTERNATIONAL CORPORATION ^- c N
Rev. Desert,ii.n
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Revise paragraphs J.c. J.A4, or 3.24, 4.2.1.7, and 6.0 D.J. Dennison 02/25/81 Revise Appendix III, Added cenw J.E. Steely 02/26/81 10 o,,,,, G.L. Fouts 03/02/81 ..
Exhibit G and instructions, %
Deleted Exhibit D. Revise ref. 2.5 o n.
o, w., C.D. Mauldin 11/23/51 g,,,, VJ Turner 1or LD Bryant A A/c/c1 11 General Revision owner C.L. Fouts 11/30/81 on.in ., C.D. Mauldin 01/19/82 -
12 Incorporate ICP #393 DanW I..D. Bnant 01/19/52 c -- _. G.L. Fouts 01/20/82 o,wne,,, C.D. Mauldin 04/13/82 oenw L.D. Bryant 04/13/52 13 General Revision %. b.L.
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ve/4*/ot orieineio,
/)tcie(U hep # L ' 4 -/6 --(L 14 Incorporate ICP's #498 ǿ '" # ' ~
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Deneel C..: ,.
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AP-VI-02 Nonconformance Control and Reporting 9 """*"14 6-17-82 13 13 Page et
- 6.0 EXHIBITS AND APPENDICES
/
6.1 Exhibit A - Nonconformance Report, Revision 8 6.2 Exhibit B - Nonconformance Change Sheet, Revision 1 6.3 Exhibit C - Nonconformance Log, Revision 7 a
J 6.4 Appendix I - Nonconformance Flow Chart, Revision 1 6.5 Appendix II - Instructions for Required Change Sheet Signa-tures, Revision 1 6.6 Appendix III - Instructions for Close/ Void In-Process, Revision 0
6.7 Appendix IV - Instructions for Processing Callaway NCR's, ,
Revision 0 .
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i AP-VI-02 o n Nonconformance Control and Reporting i
4-14-a2 ..
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'Jhis procedure describes the methods used to identify, control, -
and report safety and non-safety related materials, parts and
- components that do not conform to the requirements of applicable drawings, codes, standards, specifications or other documents, to prevent inadvertent use or installation. *
2.0 REFERENCES
- 2.1 SNUPPS Standard Quality Assurance Manual, Section B-9:
, , conforming Material Control". "Non-
[
2.2 Consr.ruction Procedure AP-VI-12: " Corrective Actica". .
- i l 2.3 Daniel International Corporation Quality Assurance Program Manual (Nuclear). *
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,j 2.4 Construction Procedure AP-VI-06: Supplier Qualification and s - Surveillance". l
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2.5 " Construction Procedure AP-VI-07: " Quality Data Analysis".
2'. 6 Construction Procedure AP-VI-08:
Materials, Parts and Components". " Identification and Status of l,
2.7 Construction Procedure QCP-I-01: " Receipt, Storage and Preser-vation of Safety Related Material and Items".
l 2.8 Construction Procedure QCP-I-05:
) Records". " Quality' Processing of Q&
2.9 Construction Procedure AP-II-04: Stop/8 tart Work Authority". ,
3.0 GENERAL 3.1 A nonconformanc'e is a deficiency in a characteristic, documen-tation, or a procedure which renders the quality of an item unacceptable or indeterminate. Nonconformances are departures from approved project requirements and include physical defects, test failures, incorrect or inadequate documentation, or devia-t
{ dures. from prescribed processing, inspection, or test proca-tions b
3.2 Monconformance Reports shall be categorised either "A" or "B",
. by the Discipline Engineer at time of dispositioning.
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- AP-VI-02 mese no Nonconformance control and Reporting 4-14-82 n pee. 3 er is l
3.2.1 Category "A" NCR's are those nonconformances disposi-tiened as requiring Client and A/E approval, i.e., f "use-as-is", or " repair".
, 3.2.2 Category "B" NCR's are those nonconformances disposi-
', tioned by the Discipline Engineer, that do not require ~
Client and A/E approval, i.e., " rework" or " reject".
NDTE: Deficiency Reports (DR) written in accord-i ance with previous revisions of this proco-
- dure, shall be processed as described for Category "B" NCR s. .
3.3 Nonconforming items involving NSSS (Westi= P 2 e) furnished
) materials and equipment shall be processed per the provisions of '
this procedure. Nonconformances involving NSSS items shall be a Category "A" nonconformance regardless of the proposed disposi-tion. -
i 3.4 Nonconformance Reports shall be typed or printed legibly using black ink, with required signatures also in black ink.
3.5 Nonconformance Reports (NCR's) will be logged and assigned a sequential control numbgr and identification code as follows:
, 3.5.1 The log will have a series of sequential numbers starting with 00001. ~~
i 3.5.2 The NCR numbering system shall be as follows: '
N . -
1 - S**- N - 00001 - M 4
i a b c d a "
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- s. SNUPPS Unit Designator
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} b. Algha designation "S" to represent Safety Related and i
"N to represent Non-Safety Related.
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- c. Alpha designation "N" to represent Nonconformance Report.
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- d. Sequential les Number.
- e. Discipline Designator l NOTE: The alpha designations for the various disciplines are as follmus:
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AP-VI-02 $
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RESPONSIBLE RESPONSIBLE DISCIPLINE MANAGER QUALITY SUPERVISOR Mechanical-M Mechanical Manager Sr. M/W Quality Supervisor
- Electrical-E Electrical Manager Sr.' Electrical Quality Supv.
Civil-C Civil Manager Sr. Civil Quality Supervisor Piping-P Piping / Welding Manager Sr. M/W Quality Supervisor '
ND11:
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i Receiving NCR's will include the designator i j
"R" (e.g. ER). The responsible manager does mot change. 'Ibe quality responsibility i
j rests with the Project Quality Services Engineer.
c Welding NCR's will include the designator "W" (e.g. EW). The Pipe / Welding or Mechan-
. ical Manager is responsible for processing .
and resolution of all Welding NCR's. Tha quality responsibility rests with the Senioz - '
N/W Quality Supervisor. t ,
Non-safety related =aaen-formances (all disciplines), the quality responsibility j c
- rests with the Senior Non-Safety quality Supervisor.
j
' 3.6 A Conditional Release may be 'obtained to install or perform
additional work on material or equipment that is under warehouse control and on hold for minor receiving discrepancies or has been previously issued, but is found to be acaconforming during the course of construction activities (Reference 2.6).
- Tag" has been affixed, or other appropriate control method has been utilized on an ites, implementation of a rae - adad ,
i disposition on category "A" NCR's can be accomplished prior to the receipt of the A/E's disposition, only with the . Client's i concurrence. Correspondence from the client shall be attached 1 to the original NCR. ..
i 3.4 Category "A" a NCR's which the A/E will not disposition, due to I the nature of the probles,- shall be sent to the KGEE Construc-tion Manager for disposition and approval.
3.9 Nonconformances observing a may be identified by any project personnel nonconforming ' condition, however, only Quality personnel may originate a Nonconformance Report as described in Section 4.1.
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CONSTRUCTION PROCEDURE l mLa ,' AP-VI-02 me= n Nonconformance Control and Reporting 4 82 "
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! 3.10 Client personnel may initiate an NCR by providing a written -
! request to the Project Quality Manager. -
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- l 3.11 An NCR may be generated to facilitate KG&E subcontractors / Con-j tractor Nonconformance Reports, for work other than ASME Code a
related items, with prior approval of the Client and the Project l l Quality Hansger. Subcontractors' NCR's will be processed upon receipt by the Daniel Quality Department, ubers a " cover" NCR will be generated that will reference the subcontractor NCR i number, and be assigned a Daniel NCR number for tracking pur- .
poses only. Upon NCR resolution, Daniel Quality Department will be provided written notification stating the NCR has been l closed. The subcontractor will be responsible for transmitting ,
i subcontractors / Contractors original / resolved NCR's to the Daniel l I
Document Control vault following closure.
- l 3.12 Correction (s), deletion (s), addition (s) and/or redisposition(s) may be made to in-process NCR's by initiating an N M Exhibit B), in accordance with Appendix II, " Instructions for Required Change Sheet Signatures". All required signatures shall be obtained on the Change Sheet prior to incorporating the change into the original NCR. The originator of the Change gheet shall be responsible for obtaining the required signa-
.: , tures. NCR Cha23e sheets, shall be attached to the original NCR. '
i
! 3.12.1 When a his discovered, the error t may be corrected by ~ 1.ugineering discipline, or ..
! Quality Personnel in the NCR signature / review cycle, j '. by drawing a single line through the error, correcting 3 the error, initialing and dating the correction. The l NCR will not need to be returned throughout the review
- j .
cycle. Errors in the upper third portion of the NCR may be corrected by the originator or reviewers during ,
processing.
NOTE: Errors may be corrected as stated, provided the correction does not alter the intent of
, the NCR.
j 3.13 Nonconformance Reports may be closed / voided without being processed through normal channels in accordance with the provi-l sions of Appendix III of this procedure.
3.14 If the original NCR is lost, a legible copy of the NCR will be marked " Certified True Copy", and signed by the Project Quality Hansger or the Project Quality Engineer.
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AP-VI-02 one. a*==== i Nonconformance Control and Reporting '-l' M !! ,
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3.15 A supplier identified nonconformance (Daniel Purchases) which the supplier dispositions "USE AS IS" or " REPAIR" req? tire Daniel resolution. A Daniel NCR shall be initiated, with the sup- -
plier's NCR attached, and shall be processed to obtain applica-i ble disposition approval of the nonconforming ites (Refernace 2.4).
3.16' Inspection and documentation requirements for the approved NCR disposition of " REPAIR" or " REWORK" shall be the same or equal, to the original method utilized, or as specified by the vendor or A/E as applicable.
i 3.17 Dispositions of nonconformances pertaining to ASME Code items shall be reviewed by the Authorized Nuclear Inspector (ANI) for ,
his concurrence.
l 3.18 When an NCR identifies more than one item, each item may be closed separately, provided each item is processed in accordance with the approved disposition and so documented on the NCR at the time the item is completed. -
3.19 Nonconforming items shall be identified by a " Quality Bold
- . Tag (s)" or other control methods (Reference 2.6). Hold Tags
',2 -
shall . reflect the number.of the associated NCR. In addition to .
using Hold Tags, the nonconforming items shall be segregated i
whenever practical. ,,
, ei NOTE: Any control method utilized other than Hold Tags for
! Al. DIE items, shall be approved by the Authorized I'
- Nuclear Inspector (ANI). His approval shall be r 4 documented on the NCR. The ANI shall initial and date next to the description of control method. -
3.20 If for any reason, a previously closed NCR/DR needs to be reopened, a new NCR shall be issued identifying the reason for r v ing. On the closed NCR/DR, enter the new NCR number along i with a brief statement justifying reopening of the nonconform-ance. De new NCR shall reference the original NCR/DR number.
3.21 A trend analysis on NCR's shall be performed in accordance with the requirements of Reference 2.5.
1 3.22 Major program breakdown or omissions, repetitive nonconforming 1 situations, omissions of tests, and any serious problem (s) as identified by Daniel shall be controlled in accordance with the
- ! provisions of Reference 2.2 or 2.9, as appropriate.
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CONSTRUCTION PROCEDURE P'**'8" A TlTLE AP-VI-02 o... n Nonconformance Control and Reporting - 14 Page 7 et 11 3.23 NCR's generated at Callaway indicating nonconforming conditions applicable to the Wolf Creek Site and processed through Wolf Creek Document Control shall be handled in accordance with Appendix IV of this procedure.
i 3.24 Where supplemental sheets are added to a NCR, the information on i these sheets shall be initialed and dated by the originator of the information/ supplemental sheets.
3.25 Where the title " Senior Discipline Quality Supervisor" is used, the title " Services Quality Supervisor" also applies.
l 3.26 Where the term Deficiency Report (DR) is referenced in other I approved site procedures, it shall mean Category "B" NCR.
! 4.0 PROCEDURE -
. l 4.1 Initiation of Nonconformance Reports RESPONSIBLE POSITION ACTION
{ QUALITY PERSONNEL (ORIGINATOR) 4.1.1 Document on the Nonconformance' Report (Exhibit A), the i
existing requirement, a full description of the l asoconforming condition, and the method of inspection I utilized. Sketches and other supportive documentation
! shall be attached as required for clarity. Number the
! documents and indicate the number of attachments in -
! the description section of the NCR as necessary. l 1
i 4.1.2 pbtahv S ces-"-9----s ?__ L, 111_. i =
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- EQ5E and prodMfg~p-4trir_, Ctliid"W , icas_ ..
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4 y'into the ~ NCR% no PQSE will then provide a -
i sequential number to the requestor and enter this l ,
number in the NCR Log.
1
, 4.1.3 Enter the NCR number and discipline suffix designation
- in the space provided. ,
4.1.4 Fill out Hold Tags, including the NCR number, and attach tag (p) as necessary to the nonconforming item (s). Material shall be placed in a segregated
- storage. area, if practical, or exercise other control I
measures. The originator shall document method of control on the NCR, i.e., enter serial number of Hold l
Tass, segregated area, etc.- Obtain ANI approval for control methods, if other than Hold Tags used on ASME items.
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, AP-VI-02 e
neum Nonconformance Control and Reporting C pag. e of ..
4.1.5 Forward the NCR to the appropriate Senior Discipline Quality Supervisor.
- SENIOR DISCIPLINE QUALITY SUPERVISOR -
4.1.6 M % description of nonconformance for clarity, i
. validity, and detail, verify the deficiency code, assigned suffix . designation, sign and date in the
) space provided. -
4.1.7 Forward the original NCR to the Project Quality Services Engineer.
- - PROJECT QUALITY SERVICES ENGINEER
) 4.1.8 Verify NCR control number and make required entries in the Nonconforssace Log (rwhnit C) and make input to
, Management control System.
- 4.1.9 [etWa'ru u =,erisin~aT"NCRCto'~tte < appIfe:able"* Project i i
- 1.
ylscipline Raginee3for dispositioning, and retain a copy in the open suspense file.
, x 4'. 2 Processing of Nonconformance Reports i
PROJECT DISCIPLINE ENGINEER --
- 4.2.1 Review asipropriate drawings / specifications and review i
' acaconformance firsthand (as appropriate) for recom-sended disposition.
-l ,
!' 4.2.2 Provide a disposition adequately addressing the ,
deficiency and justification for disposition choice, i
and assign Category "A" or "B" to the NCR. ' The term "
i " Cat. A" or " Cat. B" shall be placed to the right of -
the disposition block. .
Nott: If the NCR involves NSSS materials or epipment, place "NSSS" under the term " Cat.
A.
4.2.3 Define the cause of the deficiency and specify any corrective actions which may prevent recurrence of
{: similar nonconformances, sign and date the NCR.
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- AP-VI-02
o, n Nonconformance Control and Reporting 2 + =? "
P 9 .e n NOTE: A partial disposition may be assigned to a NCR when the cause of deficiency is unknown, -
or where the extent of rework / repair neces- -
sary cannot be determined until further investigation is made. Partial entries l shall be made in the " Recommended Disposi-tion and Basis for Recommendation" and "Cause of Nonconformance and Action to
, Prevent' Recurrence" sections of the NCR and '
all approvals obtained prior to implementing the partial disposition.
Following the partial disposition investi-gation, subsequent entries in the disposi-tion section of the NCR shall be made
- utilizing a NCR change sheet. 'Ibe NCR change sheet shall be routed to the person-nel that signed the original NCR. -
4.2.4 Forward the NCR to the Discipline Manager.
DISCIPLINE MANAGER 4.2.5 Review the NC5 for sufficient detail, adequacy of reca==anded disposition and corrective action state-ment, and possible conflict with other disciplines.
4.2.6 Evaluate NCR to determine if there is a potentially ..
under the provisions of 20CFR"$0755Ie%-M and check the appropriate box. When it is determined that there is a poten- -
tially reportable nonconformance, immediately notify and forward a copy of the NCR to the KG&E Manager QA (WCGS) for further action. .
4.2.7 gian and date original NCR to document concurrence / -
approval of recommended disposition, corrective action statement and assignment of Category A or B.
4.2.8 Forward the original NCR to the Project Quality Engineer.
PROJECT QUALITY ENGINEER .
4.2.9 Perform an evaluation to assure adherence to quality program requirements, adequacy of the recommended disposition, and corrective action to prevent recur-rence. Sign and date the original NCR to document concurrence.
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= - -- i t a t it M1 h f$9 m La AP-VI-02 g,,, w Nonconformance Control and Reporting b1M2 33
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4.2.10 Transmit a copy of page 1 and attachments of the NCR l -
(Category A only) to the onsite Rechtel Lead Liaison l Engineer, or to the the Westinghouse Site Manager if
- NSSS related, for rev ew and approval of DIC disposi-ties, or, if requ red, provide an alternate A/E
- disposition.
- 4.2.10'1 Transmit a copy of Category A NCR's that A/E j .
will not disposition to IIEE Construction . ;
j Manager for disposition sad approval.
l l 4.2.11 Upon receipt of an approved disposition from the A/E, i
- M888, or Client representative, attach to the original
! . NCR form. .
j 4.2.12 Review the NCR for concurrence (ASME only).
NITII: If the Project Quality Engineer does not concur, the NCR shall be returned with
, commenes to the Project Discipline Engineer i for resolution.
i i 4.2.13 Sign and date NCR.
A .
4.2.14 Obt. tin the concurrence of the Authorised Nuclear i
Inspector (ANI) on NCR.'s (Category & and B) for ASME ,,
Code items. This concurrence shall be documented on the NCR. '
4.2.15 Forward a copy of the NCR to the Project Quality Services Engineer and forward original NCR to the
- Project Discipline Manager responsible for implement-ing the disposition. *
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, PROJECT QUALITT SERVICES ENGINEER
- 4.2.16 Update NCR Img and make input to the Management l
Control System (MCS).
4.2.17 Retain copy of NCR in suspense File.
l l PROJECT DISCIPLINE MANAGER '
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4.2.18 Coordinate the implementation of the approved dis- l l position with the responsible supervisor (s).
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Nonconformance control and Reporting 4-14-82 n pee. 11 et is 4.2.19 Forward a work copy of the NCR to the responsible supervisor (s), and return original to Project Quality
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Services Engineer. -
! RESPONSIBLE SUPERVISOR 4.2.20 Notify the appropriate Quality Inspection Personnel prior 'to implementing the disposition. Implement the
- . approved disposit' ion.
QUALITY INSPECTION PERSONNEL .
1 4.2.21 Obtain the original NCR from the Project Quality Services Engineer upon notification from the respon-l sible supervisor that the corrective action is ready
- for verification.
2 .
4.2.22 Obtain statement of action taken from the responsible supervisor.
4.2.23 Perform inspection / verification of the implementation of the approved disposition, and indicate accepta-bility by signing the original NCR in the action
, verified section, and remove Bold Tag (s) or other j method (s) as indicated on the NCR.
) NDII: If rework / repair is unacceptable, inform the j responsible supervisor of the reasons for --
1 being unacceptable and leave the NCR opeu
- until the remork/ repair is acceptable. Any deficiencies. other than the original
- deficiency, caused by rework / repair shall be j documented on a new NCR in accordance with ;
~ this procedure. .
'l 4.2.24 Forward the original NCR to the Senior Discipline i
l Quality Supervisor. l
- EENIOR DISCIPLINE QUALITY SUPERVISOR 2
- 4.2.25 Review the completed NCR for adequacy of the completed corrective action, supportive documentation, and action to prevent recurrence. . Sign and date to signify formal closure.
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Nonconformance Control and Reporting O p . .e ..
- l NDII: The corrective action verification documen- l l tation, if required, shall be attached to l the NCR, or appropriate reference to the l' file location of the documentation shall be provided.
4.2.26 i . Forward the original NCR and attachments to the i Project Quality Services Engineer.
,' PROJECTQUALiTYSERVICESENGINEER 4.2.27 Update the NCR Log. Note the total number of pages which make up the NCR on the first page of the report.
Make input into MC3. ,
i 4.2.28
- Enter distribution list at the bottom of the NCR as mecessary. ,
4.2.29 Transmit the . original NCR to the Document Control Manager in accordance with QCP-I-05, " Quality Pro-cessing of Q& Records".
DOCUMDrr C0tffROL MANAGER 4.2.30 Produce copies of completed original NCR and make distribution as indicated on the NCR, in the distri-
) bution section, and any additional project require- ~~
l ments.
I 4.2.31 Retain original completed NCR as a Q& Record in i accordance with AP-IE-04, " Records .and FiHag"r--' *-~-^ -- "* **- ' i t
l 5.0 RETAINED DOCUMENTATION
, 5.1 The documents identified below become QA Records when completed
- and forwarded by the Project Quality Services Engineer to j h ====t Control.
5.1.1 Nonconformance Reports Exhibit A.
! 5.1.2 EG&E correspondence authorizing implementation of NCR '
i disposition.
- 5.1.3 Documentation providing objective evidence that I
corrective action haa been taken.
5.1.4 NCR Change Sheets, Exhibit B.
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,' AP-VI-02 A Page
, Page 1 of 1 4
Revision 3 i
LIST OF EFFECTIVE PAGES i
On a changed page, the portion of the text affected by the latest change is indicated by a vertical line along the right hand margin.
Total number of pages in this procedure is 2e consisting of the
! following:
/
l PAGE REY. PAGE REY.
Title 14 Exhibit A 8 -
A Page 3 Exhibit A 8 j
. 2 13
- Exhibit A 8
~
3 13 Exh'151t A 8 l 4 13 Exhibit A 8 5 13 Exhibit B 1 6 13 Exhibit B 1
- 7 14 Exhibit C 7
- 8 13 Exhibit C 7 9 13
- Appendix I 1 10 13 Appendix I 1 I 11 13
- Appendix II 1 12 13 Appendix III O
- 13 14 Appendix IV O --
Exhibit A 8 r
- Indicates pages changed, added, or deleted by the current change.
- Indicates pages added and intentionally left blank. ~
Insert this page immediately after the title page.
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Exhibit A NONCONFORMANCE REPORT (NCR) ,
1 Page 1 of 6 PMECT N/taAs0CR ACTION REQ'O #f Revision 8
.(1)
CONTMOL METHOO Q N NCR NUMBER d3) (5) (7)
IDENTIFCATION OF AREA APC ITEM
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A DANEft. L ww. .=e NONCONFORMANCE REPORT (NCR)
NM / .N ACTION REQD BY CONTROL METH00 0 N NCR NUM8ER (17) (18) (: 9) (20)
N' IMPET SWDdENT m w n C YES CNo O anmoan as aEccuuCNoEn l (21) AP-VI-02 !
Exhibit A
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AP-V1-02 Exhibit A b e s on 8 NONCONFORMANCE REPORT (NCR) Coatinuation sheet Pege _ of _,
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. AP-VI-02 Exhibit A (
. Page 4 of 6 l y Revision 8 1
- Instructions For Completing Nonconformance Report (NCR) -
- 1. Project Name/ Number - The Originator shall indicate the name and I number of the project; (Wolf Creek - 7158).
- 2. Identification of Area and Item - The Originator shall provide exact identification of the area and item which is affected by the noncon-forming condition; (i.e. , concrete pour number, procedure number in- -
cluding revision number, equipment number, serial number, lot number, l BLA, system number, subsystem number, and traveler number, design i
locations as applicable).
- 3. Contro11ina Documents - The Originator shall enter controlling docu-ments; (i.e., purchase order number, drawing number specification number etc.). Revision number is to be included in the referenced number.
- 4. Description of Nonconformance - The Originator shall provide a clear, concise description of the nonconformance and method of inspection.
Reference any attachments, (e.g. sketches etc...) required to clari-
. fy the description of the nonconformance.
- 5. Control Method - Quality Inspection Personnel shall enter the serial number (s) of the Bold Tag (s) used to control item (s) or identify other method of control utilized.
- 6. "Q" or "N" - The Originator shall identify the nonconformance by asrking an "I" in the area under "Q" if Safety Related, or under "N" if Non-Safety Related. (Page one only.)
NOTE: If the ites is special scope, 331.1 Critical, II/I, Fire .
Protection, or D-Augmented, the "Q" area will be marked and the appropriate title entered just below " System ID".
Also enter whether code or non-code. .
- 7. NCR Number - The Originator shall obtain NCR number (Paragraph 4.1.3) and enter the NCR number.
7 7a. Distribution - The Project Quality services Engineer shall des-ignate the NCR distribution, after closure of the NCR, on the .
form.
- 8. Oriainator Title Date - The Originator shall . sign, enter his title and date. .
- 9. Review and Concurrence - The Senior Discipline Quality Supervisor shall sign and date signifying satisfactory review and concurrence of the nonconformance description.
10.' Recommended Disposition and Basis for Recommendation - The Project
. Discipline Engineer shall provide a recommendation as to e Daniel desired resolution t.o the nonconformance, check the appropriate standard disposition box and enter justification for the recommended disposition. Enter "NSSS" and Category "A" or "B" as applicable.
AP-VI-02 '
Exhibit A Page 5 of 6 Revision 8 l
NOTE: Reject disposition may be used as a Daniel Engineering option when A/E input is desired for special circumstances. i 11a . . Cause of Nonconformance and Action to Prevent Recurrence - The Project Discipline Engineer shall identify the cause of the l nonconformance and provide a statement as to what action (s) 1 when appropriate, shall be taken to minimize and/or prevent recurrence. -
11b. Identify the supervisor (s) responsible for implementation of ~
disposition and action to prevent recurrence.
- 12. Action Taken to Control Nonconformance - The Project Discipline Engineer shall describe the action taken to control the nonconform ing item, if control method is utilized other than that described in instruction step 5.
- 13. Action Required by - The Project Discipline Engineer shall enter the latest date on which Daniel requests that NCR disposition review /
approval be received.
- 14. The Project Discipline Engineer shall sign and date the NCR.
- 15. Site Approval - The Discipline Manager shall review Steps 1 through 14 for acceptance. If acceptable, sign, enter title and date.
'15s. Potential 50.55(e) or Part 21 - The Discipline Manager, after review of nonconformance, shall check the appropriate block. If the "yes" block is indicated, immediately notify and forward a
- copy of the NCR to the EG84 Manager QA (WCGS) for further !
action.
i 16. Project Quality Engineer - Perform a quality evaluation to assure adherence to quality program requirements, adequacy of the recom- ~~
mended disposition and corrective action to prevent recurrence. Sign and date original to document concurrence,
- 17. Project Name/ Number - A/E Site Representative shall enter the Project name and number this NCR applies to.
- 18. Same as #13. (NOTE: Completed by A/E Site Representative.) ,
- 19. Same as #6. (NOTE: Completed by A/E Site Representative.) .
20.. Same as 99. (NOTE: Completed by A/E Site Representative.)
- 21. Impact Statement Included: The A/E shall make the Approved as Recommended: appropriate entries in Disposition Revised as Follows: these areas.
- 22. Documents to be Revised - The A/E shs11 designate whether or not a change will be made to a design document as a result of this noncon-formance and shall identify impacted documents.
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.____._____.._.__,_.______._.._______.,_.m._m__,___,.,_,.,__,_, .
AP-VI-02
- ' Exhibit A Page 6 of 6 Revision 8
- 23. A/E Approval - The A/E shall sign and date signifying review and approval. (Category A only.)
- 24. SNUPPS or Utility Approval - The appropriate representative shall sign and date to signify their review and approval if applicable.
- 25. Distribution - To be completed by A/E to add any personnel they wish to have copies in addition to those listed on Page 1 of NCR. -
- 26. Project Quality Enaineer - Sign and date the NCR signifying concur-rence of the approved disposition. (ASME only)
- 27. Project Quality Enaineer - Coordinate with, and obtain the signature of the Authorized Nuclear Inspector (ANI) on NCR's' for ASME code items. The ANI's concurrence shall be documented on the NCR.
- 28. Statement of Completed Action - The Responsible Supervisors for the ,
implementation of the required corrective action shall state the actions that have been completed.
~~ ~ ~ ~ - ~~ ~
l
- 29. Action Completed - The Responsible Supervisor (s) shall sign, enter title and date to signify completion of required action.
- 30. Action Verified - Upon Quality verification that the approved dispo-sition has been successfully completed, and the reinspection is indicated Satisfactory, Quality Inspection Personnel shall sign, enter title and date, signifying acceptance.
NOTE: Paragraph 4.2.20 of this procedure shall be followed if rework / repair is unacceptable.
- 31. Senior Discipline Quality Supervisor - Reviews the NCR for clarity, and evaluation of the completed actions, corrective actions to pre-vent recurrence, and adequacy of supportive documentation. Sign and --
date the NCR to document concurrence and formal close out.
32.. NCR Continuation Sheet - Continuation of information ' indicated on page 1 of NCR, as required, referenced on page 1.
1 NOTE: Numbering is not to imply sequential flow. .
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AP-VI-02 Exhibit B Page 1 of 2 Revision 1 Date: (1)
Nonconformance Report Revision (1)
Change Sheet NCR/DR # (2)
Description and Justification for Chanae(s) - (3)
Originator - Title - Date (4) 1 Review and concurrence (5)
(5) (5)
Concurrence - Title - Date Concurrence - Title;- Date Concurrence - Title - Date Concurrence - Title - Date (5) (5)
Concurrence - Title - Date Concurrence - Title - Date i
Distribution * (6)
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. f' AP-VI-02 Exhibit B Page 2 of 2 Revision 1 INSTRUCTIONS FOR COMPLETING THE
, NONCONFORMANCE REPORT GANGE SHEET
- 2
- 1. DATE - Originator of'the change (s) shall enter the date and revision
' number of the change. '
- 2. NCR NtRfBER - Originator of the change (s) shall enter the NG number,
.same as original.
- 3. ESCRIPTION OF CHANGE - Originator of the change (s) shall provide a clear, concise description of the desired change (s) as noted on' the original NG deficiency description or disposition. Additionally he
- shall provide a detailed justification for the desired change (s) to the original N G. -
- 4. CRIGINATOR OF THE GANGE(S) - Originator shall sign, enter his title and date.
5.* REVIEW AND CONCURRENCE - Originator of the change (s) shall obtain the appropriate signatures of responsible positions as indicated on the original NCR form, as applicable. (Refer to Appendix II)
~
- 6. DISTRIBUTION - Project Quality Engineer shall aske distribution as indicated on Page 1 of the original NG form.
EDIE: This form to be utilized to make changes to the in process NG deficiency description or disposition categories, and
, therefore, becomes an attachment to the original N G . ,,
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AP-VI-02 Exhibit C Page 2 of 2 Revision 7 INSTRUCTIONS FOR C0tfPLETING NONCONFORMANG IDG .
The Project Quality Services Engineer shall be responsible for entries and as,intenance of the Nonconformance Log. .
- 1. Nm Number - A series of alpha symbols and ammerical numbers in sequencial order used to control N 3 in accordance with paragraph 3.8 of this procedure.
- 2. Originator - Name of writer of NG. '
- 3. Action Verified By - Quality Inspection Personnel. (Inspector siga-ing N a at time of closure.)
- 4. Preparation Date - Date N G aumber issued.
- 5. Code Related - Designated by "C" if nonconforming material is AEMK Code related.
- 6. EIA - A three digit code made up of alpha and numerical charac-ters to designate what building, elevation / level, and area, (A/E designated) the material will be used in. .
- 7. Approved Disposition Date - Date disposition approval was signed by Project Quality Engineer.
4 i 8. Deficiency Code - A three digit code made up of both alpha and numerical characters to designate deficiency .
'. category.
- 9. Approval Date - Date disposition was approved by A/E and/or ..
NSSS/ Client.
- 10. Subsystem - An alpha-numeric code of up to three characters ased to designate subsystems.
- 11. Data closed - Date NCR was signed off by Senior Discipline Quality Supervisor. .
- 12. System - System in which the noncomformance exists.
- 13. Neferehce Documenta - Documents listed which pertain to or ident-ify. the nonconforming ites, i.e., Purchase Order Number, Drawing Number, Specification, Code, etc. '
- 14. Sususary of Deficiency - Brief description of nonconforming or deficient item.
- 15. Discipline Coordinator - Name of Discipline Coordinator responsible for obtaining disposition and site approval on the original NG. '
.. j
_ _ _ - -- - ------- - - -l
. - i AP-VI-02 i , Appendix I
. Page 1 of 2
, ; Revision 1 NCR.FI4W CHART l l
Quality Originator
- 1. Identifies nonconformance.
, j 2. Initiates NCR.
, 3. Obtains control number from PQSE.
- 4. Places status tags (obtain ANI approval for control method
~
j other than Hold Tags).
l V 5. Forwards NCR to SDQS.
1 Senior Discipline 1. Reviaws for clarity and com-Quality Supervisor pisteness.
. 2. Sign and date, f 3. Forward to PQSE.
Project Quality . 1. Verify control number. -
Services Engineer 2. Enter in NCR Ing any pertinent information.
1 V
3.
4.
Make input to NCS.
Place a copy in suspense file.
Project Discipline Engineer 1. Provide disposition and corree- '
tive action.
- 2. Assign NCR Category "A" or "B".
- 3. Assign "NSSS", if applicable.
y 4. Sign and date NCR. ,
Project Discipline Manager 1. Review recommended disposition /
+ corrective action.
I
- 2. Evaluate for 50.55(e) or Part
- 21. If it is potentially re-portable, notify IGfmE QA Mana- ~'
i '
ser (WCGS).
- 3. Sign and date NCR.
V 4. Forward to PQE.
Project Quality Engineer 1. Perfore quality evaluation for-adherence to quality program.
i 2. Sign and date NCR. -
- 3. Transmit a copy to client, A/E or NSSS representative for dis-position.ing. (Category A).
- 4. Review NCR for concurrence (ASME only).
- 5. Sign and date NCR.
- 6. Obtain ANI concurrence.
- 7. Forward copy to PQSE.
- 8. Forward orfginal to responsible l Pou.
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' AP-VI-02 Appendix I Page 2 of 2 Revision 1 Project Quality 1. Input to NCS.
Services Engineer 2. Retain copy.
w lProjectDisciplineManager 1. Coordinate with responsible supervisor.
- 2. Forward work copy to respon-sible supervisor, y 3. Forward original to PQSE. __
Responsible Supervisor 1. Notify appropriate QI. ,,
, 2. Implement disposition.
Quality Inspector 1. Obtain original from PQSE.
. 2. Reinspect / verify implementa-tion /obtain statement of cor-rective action from respon- .
sible supervisor. ,
- 3. Remove Hold Tass.
- 4. Forward to SDQS.
Senior Discipline 1. Reviews for completed action Quality Supervisor and action to prevent recur-rence.
, 2. Sign and date.
- 3. Forward to PQSE.
Project Quality 1. Update Log.
Services Engineer 2. Annotates total number of pages on,Page 1, lists distribution at bottom of NCR.
, , 3. Copy in file, input to MCS.
- 4. Original to Document Control y Manager.
Document Control Manager 1. Makes distribution.
- 2. Retains original as Q& Record.
4 6
9
. _ _ - _ - _ . _ __ _._,,_.,-,.-...c.,r., -_,,._-_...__...,,.-,__..,,,m, ,m__,.,,,,m y_,,._
,, ,. AP-VI-02 Appendix II Page 1 of 1 Revision 1 INSTRUCTIONS FOR REQUIRED CHANGE SHEET SIGNATLRES 1.0 The following signatures are the minimum signatures required when processing a nonconformance change sheet, except for those changes as specified in Paragraph 3.12, which do not require a change sheet.
2.0 Prior to Project Discipline Engineer Signature l 2.1 No change sheet required 3.0 Prior to Project Quality Engineer Signature, but after Project Discipline Engineer Signature 3.1 If change is to description only:
- 1. Senior Discipline Quality Supervisor
- 2. Project Discipline Engineer
- 3. Project Discipline Manager 3.2 If change is to the disposition only:
- 1. No change sheet required .
4.0 Prior to Final Close Out Signature, but after ANI Signature 4.1 Any change, except those in Paragraph 3.13:
- 1. Project Quality Engineer
- 2. Project Discipline Engineer
- 3. Project Discipline Manager l .
- 4. ANI, if Code related -
- 5. A/E and/or client review and approval on $riginal ca_tegory ,
A.NCR. Signatures on change sheet are not required.
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AP-VI-02 .
, Appendix III '
Page 1 of 1 t' Revision 0 INSTRUCTIONS POR VOIDING IN PROCESS NCR'S After' assignment of a control number to an NG, the following steps shall be taken to void an NCR.
1.0 If the originator or SDQS determines that the NCR has been written in error, the originator shall attach a brief note of justification / -
explanation to the NCR and forward to the Senior Discipline Quality Supervisor (SDQS). -
1.1 h SDQS shall review the NG and the justifidat.kon7e~xplanation. ~
If the SDQS concurs, he shall enter a statement " written in error" or " void" in the justification / explanation for the
. statement in the " Statement of Completed Action" section. Sign and date the MG in the " Action Verified". block. Forward the N G to the Project Quality Engineer.
1.2 h Project Quality Engineer (PQE) shall review the NCR and justification for voiding. If the PQE concurs, he shall sign and date the NCR in the block abov: the SDQS signature, sad forward the NCR to the SDQS.
1.3 The SDQS shall have the originator remove Nold Tags, if applicable, and enter "N/A" in the unused portions of the NG. N SDQS shall forward the NG to the Quality Docu-ment Section for processing in accordance with QCP-I-05.
I 2.0 Should th<t Project Discipline Engineer (PDE) or the Project Disci-
,I pline Manager (PDM) determine that the NCR is invalid, written in error, or no longer applicable, he shall so indicate in the disposi-tion sect:;on of the NCR.
l
' Provide justification for the statement, sign and date the NCR and forward the NCR to the PQE. ,
I 2.1 h PQE shall review the NCR, the justification statement, and
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if the PQE concurs, sign and date the NCR in Block 16. h PQE forwards the N G to the SDQS. I e
h SDQS forwards the NCR to the originator of the NG.
2.~2 '
2.3 h originator shall remove Nold Tags and sign and date the NCR. ~'
- h originator shall forward the NG to the SDQS.
- 4 1
2.4 h SDQS shall . sign and date the NCR, enter "N/A" in unused blocks, and forwards the NCR to QDS for processing in accordance with QCP-I-05.
3.0 For those NCR's designated as Code-related, (ASME), the ANI must signify his concurrence by signing in the appropriate space on the.
NCR form. This review shall be accomplished after closure of the NCR, but prior to transmittal of the NCR to Document Control (Para-graph 4.2.31). .
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AP-VI-02 Appendix IV Fase 1 of 1 Revision 0 INSTRUCTIONS FOR PROGSSING CALLAWAY NCR'S 1.0 This instruction .is for Callaway generated NCR's that are applicable to Wolf Creek Generating Station.
WOLF CRKEE DOCIRENT CONTROL MANAGER 1.1 Forward copies of Callaway NCR's indicating nonconforming conditions Quality applicable to the Wolf Creek site to the Project Engineer.
PROJECT QUALITY ENGINEER 1.2 Forward the Callaway NCR to the appropriate Discipline Engineer, -
after evaluating for Wolf Creek applicability.
PROJECT DISCIPLINE ENGINEER 1.3 Review Creek. and evaluate Callaway NCR for applicability to Wolf .
1 1.4 Eave appropriate documentation generated utilizing the Callaway
NCR as an attachment.
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[ .** , $,, UNITED STATES r.' * , f. '*,e
, NUCLEAR REGULATORY COMMISSION 4MW. 8 OFriCE OF st.vESTIGATIONS FIELD OFFICE. EEGION IV 611 RY AN PLAZA DRIVE. SUITE 1000 - -
g 8 .
ARLINGTON. TEXAS 7M11 DATE: Aucust 18. 1983 REPORT OF INVESTIGATION
~
TITLE: WOLF CREEK GENERATING STATION ALLEGED INTIMIDATION OF DANIEL INTERNATIONAL ELECTRICAL QC INSPECTORS CASE NUMSER: 4-83-005 C0;' TROL OFFICE: 01F0: Region IV STATUS: CLOSED PERIOD OF INVESTIGATION: March 1, 19E3 - March 18, 1983
. REFORTING INVEST!G" TOR: /k7$ 8- _
H. Brooks Griffin,g.vestigator Office of Investigations Field Office, Region IV REVIEWED BY: // A4 &
Ri'charo C Herr, Dire'ctor Office of Investigations Fiele Office, Region IV -.
, Asw vWe '
ki ri t ar. J. n ro , Di rec cr Division of Field Operaticns -
Office of Investigations ,
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Roger Office [ortu6a, ~ Deputy Director of Investigations f /
- ?:::.E: i' :
4 bp &
Ber. 5.
o , , % a ,9,J Office /c.-afes,;irect::ry f investiga-icn_
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An aliegeticn was received by the NRC Senior Resident Reactor Inspector z't the Welf
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Creek fiuclear Generating Statien, Burlington, Kansas, that.a Daniel International f
(DI) electrical QC supervisor had attempted to pressure QC inspectors :
into t t
acceptin,g ncnconforming conditions by signing off inspection reports. The alleger ;
.. identified one instance wherein a QC supervisor threatened a QC inspector with _
f temination for resisting his instructions not to write a nonconformance report f
(NCR). '
The alleger along with four QC inspectors who work for the QC supervisor in question were interviewed and expressed knowledge of the threat of termination !
of the QC inspector. The QC inspectors also related instances where the QC super- -
~ ' ~
visor instructed them to accept what they believed to' be nonconforming conditions. l The QC ins'pectors stated the instructions of the supervisor were circumvented by ii correcting the deficiencies without his knowledge or successfully addressing the
~ l problems to a higher level of management. I r
~ ;
The DI electrical QC supervisor in question was interviewed, and he denied ever instructing QC inspectors to violate established procedures. The supervisor ;
admitted threatening one QC inspector with temination during a' disagreement ever j
the writing of an NCR. The supervisor stated he regretted his choice of words in this disagreement with the inspector. .. f t
The DI Senior Electrical QC Supervisor was interviewed, and he expressed knowledge )
of the areas of contention between this supervisor and the QC inspectcrs. The ,
ser.icr supervisor expressed the belief that the supervisor in question had not -
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actually attemptec to curtail the freedom of the inspectors to re;crt nonconforming .
ccccitions. The senior supervisor stated he believed his succrdinate used poor !
jucgerent in cc=.unicating his differing opinicn to the QC inspectcr whom he hu threatened with termination.
Curing -he ccurse of this investigation, all of the QC inspectcrs interviewed su c: nat as a result of -he FRC's incuiry into this matter, i :se-ir.g was ".eid e
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with the D1 QC supervisors, and their differer.ces were resolved. The QC inspector expressed the belief that corrective action had been taken, and
'they new had adequate freedom to report nonconforr.ing conditions. _
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Furoose of Investigation .
The purpose of this investigation .ies to determine if a Daniel Ir.ternational (DI)
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electrical QC supervisor at' Wolf Creek had adversely affected the electrical QC
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- ir.spectors' freedom to report nonconforming conditions by intimidating QC inspector through policies, instructions, and threats of termination.
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Background
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On March 1, 19S3, Harold ROEERDS, NRC Senior Resident Inspector for the Wolf Creek Euclear Gen _erating Station in Burlington, Kansas, received a telephonic allegation from who identified himself as a Saniel International (DIl electrical y . , r- 9 -
QC inspector. ~ROBERDSstatedj.
threatened QD inspectors with ationkermin#;
if they failed alleged to acceptthat a DI certain electrical Q non-conforming conditions on inspections. On March 8,1983, the Reg' ion IV Regional .
Administrator requested Office of Investigations' assistance in addressing this allegation of potential intimidation of QC inspectors.
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Interviewoff (Confidentiality Recuested)
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On March 17, 19E3, 'an. electrical QC inspector for Daniel International (DL) a5 k'olf Creek, wgs interviewed by NRC Investicator H. Brooks
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GRIFFIN in Emporia, Kansas, l ,
executed a signed, sworn statement which is included in this report as Attachment (1). ; irequested and received con-fidentiality, and signed a Confidentiality Aheeme'nt which is included in this report as Attachment (2). ,
detailed an incident that occurred near the first of February 1983 in which electr'ical QC inspectors Gary ANDRADE (spelled phonetically in Attachment [1] as AfsDRIETTI) and Eennis McMuni. REY identified anchor bolts used for raceway supports which did 'not have letter stamps identifying their length. {. . stated these
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letter stamps were placed on the bolts,by the manufacturer, but wehe probably destroyed during installation. '
stated that ANDRADE and McMURTREY; wanted to report the deficiencies but the electrical QC lead, Art DOAN, told them there was a letter issued by Qual,ity Engineers (QE) that said it was "0K" to accep: the bolts without letter stamps. }htated that ANDRADE and McMURTREY initially accepted
. DOA!;'s .explar.ation.
' paidthataboutamonthlater,ANDRADEchangedhismind
' anc v[ro'te a ter.:randE. to James PATTERSON, the Senior, Electrical Quality Supervisor) ,
regarding his concerns with the anchor bolts. . stated that PATTERSON called a reeting with Jchr. ROSS, a D1 electrical qualitfe.ngineer, DOAN, the QC lead, and , '
"Eill ELGO T, the QC electrical supervisor, recarding the anchor bolts. '
stated that PATTERSON subsequently inst,ructed that nonconfonr.ance reports (HCRs)'
should be written on the bolts. ' stated 1! hat following the meetir.c, A*iDRADE i.r.d McM' J RTREY wrote the NCRs on the bolts.
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stated he was also concerned about the use of a "megger boy," which had been cor.structed ty DI engineers and used to determine if the insulation en cables 1
v.Es acceptatit. stated the "neccer box" was kept by the D: craf ut5or.nel n: s:Es cor. :- , Iste by, ciectrical :s inspec: cts in cenjur.ctier. s:ith t Grat 1
cecper" in 1: e fitid. j stated he had tsen tr.ic by a co-worker;(ictritity unknewn) of Er it.:ident in which QC inspectors, Editard FT.ECRICKSON ano ,Retem m=**r -m en . -
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'j; C;ETEELi., were verifying insulation using this "megger box." stated that it was his understanding that the box registered a reading on a chble they were testing, but thtt when they removed the cable from the box, the reading did not -
fluctuate.(, jstated this lack of fluctuation caused the inspectors to suspect the validity of th' readings e on this "nonquality noncentrolled megger box."( (
stated he had heard that FREDRICKSON and CAMPBELL reported this inc.ident toJTheotis PEARSON, the equipment lead, and ELLIOTT. []statedhehadheardfrom'other inspectors that ELLIOTT told CAMPBELL a,nd FREDRICKSON that the box was fine, and t' rat it did not nded to be calibrated. [_ lstatedthatFREDRICKSONandCAMPBELL later wrote a memorandum about the box to@ohn ROSS, the quailty engineer. [
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stated ROSS wrote a reply on the memorandum stating the box could be used for general readings, but that it could not be used for verification since it was not calibrated. [ }statedthatwhenELLIOTTfcundoutthatFREDRICKSONand C;3PSELL had$ritt$n the. memorandum, he became upset with the inspectors and told -
themthattheyshouldnotgooverhishead.{ ]statedthattohisknowledge this box had never been calibrated and was still on-site, although he did not know its location. ( } stated he recently made the NRC Senior Resident Inspector at Wolf Creek aware of the existence of the "megger box."
INVESTIGATOR'S NOTE: harold ROBERDS, the NRC Senior Resicent ,
' Inspector a.t Wol.f Creek, was contacted, and he confinned thatb 3 had r.ade him aware of the "m6gger box." ROBERDS stated that he would
- address the use of the "megger box" during~a routine inspection module. ,
[ _ )related another incident in which an electrical-QC inspector nared " Steven
'D .5C.*. identified a support that was welded out of the middle one-third. F A
said that LARSON wanted to write an NCR on the condition but that ELLIOTT told him not to write the NCR.[ ]said that LARSON did not accept the weld but it.s:cac, arrar.ged to get a Middle Third Deviation Notice (MTD).
I':si.UIGATOR'S NOTE: The reference. middle third refers tc, th centri area on a piate to which a piece of metal is 1: te wEiced it raximum strength. .
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.said that on another occasion, ELLIOTT and another QC inspector (identity l ~
Inknodn),had just completed a gciding school for their certification. b stated that because hej u. -
was already certified, he was giving them on-the-job ~ .
training by taking them out on nspections. l .! stated that,when they located
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- jj the weld to be inspected, _ _. _ 2 _ .
htatedhetold _
, TLLIOTT and the inspector he would arrange to haveg o that
- j they could complete the inspection.' stated'that ELLIOTT said this was not necess,ary and that they could compleh the inspection withou _ . __, _ . , }
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k_said he thought ELLIOTT wasr joking, but eventually he realized ELLIOTT was J
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serious when heEstated became upset at his Q___bd ELLIOTT was mad, he did that when he reali l: l any7nore30u't it. f said he later returned to the weld and arranged to have
, then completed the inspection.
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3 [ said he has related the above instances to the NRC as examples of how ELLIOTT (supra) had used his position to undermine quality control at Wolf Creek.
l . stated he did not know of any electrical QC inspectors who signed off on
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nonconforming cohditions under pressure from ELLIOTT. [ _ laiso stated he did..
r.ot' knou o'f a'ny other QC inspectors at Wolf Creek who ided toTd him they knew of
, existing nonconforming conditions other than those already mentioned. Although
' not ~contai6ed in .his sworn statemen.t to the KRC,[ dstatedhewaspresentand H overflard ELLIOTT'threate6 LAE50N with terminatih if hk failed .tc follow his .j explained that to the best of his knowledge. -
L -(ELLIOTT's) instructions.(
I LARSON had not acquiesced to ELLIOTT's threat and had not acce'pted nonconforming l
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conditions. ] stated he did not know of any other threats made by ELLIOTT l to'LARSON orko any other QC inspectors.
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INVESTIGATOR'S NOTE: On the evening of March 17,1983,t 1 ,
aler.g with another D1 electrical QC inspecter,f.,cr. is TOWSE!;D, contrcted this investiceter, unenneur.ced, et ne her.EdE Inn in b Emporia, Kansas, made statements in tht. preso.ce of the other inspector, which indicsted he had violated tht conditions of confidentiality.
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6 Ir.terview of Dennis TOWNSEND 0 i' arch 17,1983, Dennis TOWNSEND, a DI electrical QC inspector, was interviewed by SRC Investigator H. Brooks GRIFFIN at Wolf Creek. TOWWSEtjDwasaskedaboutan '
ir.cident involving the' writing of NCRs on anchor bolts idehtified by QC inspectors.
TOWhSEND' stated 'he was involved in this inspection, and that the inspectors were required to verify torque on anchor bolts. 'T0WNSEND stated he was working in the retro-support group and the inspection criteria the group was told to use did r.ct have as many inspection points as the criteria used by the ongoing support group. TOWNSEND stated that after two QC inspectors identified anchor bolts that cid not have letter stamps, the QC inspectors in the retro-support group questioned the limitations placed on the inspection details they were instruct.ed to use.
70/NSEND stated that if the inspector did n't o know the length of the ancher bolt, re cculd not adequately naasure torque on the bolts, particularly if the porticn of -
the bolt ex' posed was of insufficient length to fully engage the nut. TOWNSEND stated that the inspectors felt that inspection for stamp letters should be part of the inspection details. TOWNSEND stated that during a nesting he attended, ELLIOTT and DOAN told the QC inspectors that quality engineering had distributed a letter
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advising the inspectors they did not have to check for letter stamps. TOWNSEND stid he ha,d heard from other inspectors (identities unknown) that Dennis McMURTREk, a QC inspector, was told by ELLIOTT ito sign off on two bolts without letter stamps. ,
~ ~..hSEND stated that. CHENOWETH, a former QC inspector, teid him that he (CHENO~.:ETF)
'conplained to PATTERSON, the senior QC supervisor, about the verbal instructions ,
giver. by ELLIOTT concerning the anchor bolts. ?OWNSEND exp1'ained CHENOWETH told hir (TOWNSEND) that he (CHENOWETH) made his compiaint duri.ng his exit / resignation r
resting. TOWNSEND stated CHENOWETH told him that PATTERSON had a neeting with ELLIOTT and DOAN, ar.d that PATTERSON rescinded their instructions. TOWNSEND said
-Eat inspectors are now required to check for letter stamps. TOWNSEND stated it
, = t ris ur.derstandir.g that NCRs had not as yet tec'. written on these ancher bolts,
.. te believed that hCRs were being prepared. i
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7 101.'.SEi.D was asked whether he knew of the existence of a "megger box" on site. He stated be did not use a "megger box" in his inspections, and he was not aware of this device. ,
TO',:SSEND stated he witnessed an argument between ELLIOTT and a QC inspector named Steve LARSON. TOWNSEND stated "that ELLIOTT did not want LARSON to write an NCR on a ciddle third violation, and that ELLIOTT threatened LARSON with termination if he disobeyed him. TOWNSEND stated he later heard that LARSON arranged to write a
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' middle third deviation notice (HTD). TOWNSEND said it alarmed many of the inspectors' that ELLIOTT had threatened LARSON with tennination.
TO'<.'NSEND stated that as long as he had been an inspector at Wolf Creek, he had -
never failed to report an NCR condition, no'r did he know of any other inspectors who has failed to do so. TOWNSEND stated it was his opinion that ELLIOTT had not -
tried to circumvent quality nor tried to interfere with QC inspectors' freedom to report ncnconfoming condition's but was merely trying ,to insure that QC inspectors follow established procedures as he-(ELLIOTT). understood their meaning.
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Ir.te-view of Dennis Lee McMURTREY
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- Cr Parch 17, 1983, Dennis McMURTREY, a DI electrical QC inspector, was interviewed l ty !.RC Insestigator H. Brooks GRIFFIN at Wolf Creek. McMURTREi stated he had been erployed as a QC inspector at Wolf Creek for about 4 months.
McMURTREY was asked about his involvement in an incident concerning anchor bolts without stamped letters discovered at Wolf Creek. McMURTREY stated he identified
- v.s ar.chor bolts without letter stamps during inspections at Wolf Creek. McMURTREY stated he took this matter to DOAN, his lead, and DOAN,showed him Appendix II of
- Cp X 302, which stated that inspectors were not to inspect to cer'tain civil attritates regarding anchor bolts. McMURTREY stated they were inspecting for tercus on the bolts and were not required u'nder Appendix II to check for identi-fication indicating length on the bolts. E.cMURTREY, stated he acceptfd D0AN'S instructions, and signed off on the checklist. McMURTREY s said that 'aater he became corcerned about his signature on these inspections and he wrote a memo-randur to quality engineering asking for an opinion. @.cMURTREYstatedthatquality engineering wrote him a reply stating that identificatio~n stamps were not part of the ir.spectior, attributes. McMURTREY stated he 1.ater learned that an NCR had been.
written wt.ich described the inspection criteria to be examined cn these anchor
- bolts and he found the instructions in conflict with Appendix II. McMURTREY
. - - steted he brou.ght this conflict between the NCR and Appenjix 11 to ELLIOTT's ;
- i- e .-icn, and that ELLIOTT took the NCR to a cuality engineer, John ROSS. .i McM' J RTREY stated thai during t'his peri,od, another inspector named-CHENOWETH went to l
FATTIF.SG!i (supra) on this same matter. McMURTREY stated he remembered that another
'rs;t; cr named ANDRADE raised questions on this issue and asked for directions and l ir.structions from ELLIOTT. McMURTREIsaidthatANDRADEandELLIOTT.hadadis-acreere.nt over how the inspections should be conducted and that ANDRADE wrote a it- er about the ar.chor bolts to PATTERSON, the senior superviscr, and SCHRYER
- e c : ject inspection manager. McMURTREY stated FATTERSON decided that identi-
'::-icr stc;;d be a part of the ir:spection detail regardless of what QE said he stic that PATTERSON instructed that NCRs be written on the anchor bolts that
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did not contain stamped letters. McMURTREY' stated he was the one who wrote the HCF.s ano;he placed the hold-tags on the correspending anchor bolts. McMURTREY stated he believed ELLIOTT had been acting in good faith in following the instructigns from QE, and was not trying to circumvent quality. ,
M:PJJRTREY was asked if he knew of the existence of a "megger box" at Wolf Creek.
McMURTREY stated that he was not knowledgeable in the ush of meggers, and that he did not know of any such box. ,
McMURTREY was asked about an incident involving an argument between LARSON and ILLIOTT. McMURTREY stated that LARSONidiscov red a support that was welded out of the middle third and he felt that an NCR was required by procedure. McMURTREY, stated that ELLIOT' T wanted to handle the de'fect by checking to see if a middle third deviation notice had been written. McMURTREY stated it was later determined that a middle third deviation notice was appropriate for this particular support.
McMURTREY said that during the argument between ELLIOTT and LARSON, he . heard ELLIOTT threaten LARSON..with termination. McMURTREY said the other inspectors were very concerned about the threat, but that he did not know of any QC inspectors at Wolf Creek who had been intimidated into signing off on defective work. McKUP. TREY..
said he felt that electrical QC inspectors had adequate freedom to report nonconforming conditions.
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!nterview of Gary ANDRADE i
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Or. March 17,19E3t Gary ANDRADE, a DI electrical .QC inspector, was interviewed by NRC Investigator H. Brooks GRIFFIN at Wolf Creek. ANDRADE' stated he had been employed by DI as a QC' inspector for about 4 months. ANDRADE stated he was working in the retro-support group, wherein they were reinspecting welds on electrical supports. ANDRADE said it was his opinion that DI was pushing the inspectors to accept all of the electrical supports and get the " retro-program" (reinspection) cidsed in a hurry.
'A';DF.ADE was asked about an incident nvolving anchor bolts without stamped letters.
AGRADE stated the ins'pections conducted by the retro group were in accordance with Appendix II of QCP X 302. ANDRADE said that u'nder this appendix, certain civil attributes were not among the inspection criteria. ANDRADE stated that the engoing -
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support group wasfiiispecting under civil criteria of QCP VII 106, which had more inspection criteria, including identification of stamped letters on anchor bolts.
AOF.ADE stated he became involved in this controversy after he wrote-a memorandum to' FATTEilSON and SCHRYER E pointing out that Bechtel's Specification 10466-C-103A rec,cired that ar.chor bolts bear stamped letter identifications. ANDRADE stated ,,
that during his inspections, he located a third' unidentified anchor bolt in addition to the two that McMURTREY had found. 'ANDRADE stated this anchor bolt had been manufactured with a stamped letter but it had been damaged during instal-iation and the letter was not visible. ANDRADE stated that en March 10, 1983, a QC inspector who was no longer employed at Wolf Creek, CHENOWETH, told PATTERSON about the anchor bolt .prcblem during his exit meeting. 'A!;DRADE stated it was his under-
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star. ding that .FATTERSON became concerned and ordered the inspection criteria changed. ANDRADE stated that PATTERSON had NCRs written on these anchor bolts and l had the stainless steel acceptance tags pulled.
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AGADE .r:2s asked about his knowledge of a "megger box" used by QC inspectors at i 9 e site. ACU~if statec that the retro-support group dic not use "megger boycs",
because they dic' not inspect cables.
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11 A'iDRAJE v:as asked about an incident involving an argument between-ELLIOTT and LAR50!i. , A:iDRCE said he heard from co-workers (not further ider.tified) that LARS0!i nad fc;nd c piece of tube steel welded to a plate that was out of the middle third. ANDRADE s,tated ELLIOTT had argued that LARSON should get QE to get a Middle Third Deviation Notice. ANDRADE stated that it was his understanding that a riddle third violation could 'be dispositioned by a Middle Third Deviation Notice prepared by QE. , ANDRADE stated that he hac heard ELLIOTT's statements to LARSON about doing things "his way," or showing LARSON "the road."
ANDRADE stated that he did not know of any QC inspect'o'rs at Wolf Creek who had been intimidated into signing off defective work. ANDRADE~ stated he felt that electrical QC inspectors had adequate freedom to report nonconforming conditiens.
I,CFADE's and'EcSURTREY'sI February 17, 1983', memorandum to John ROSS, QE, and -
AfiDRADE's' March 11, 1983', memorandum to PATTERSON and SCHRYER are included in this repcrt as Attach :ent (3) and Attachment (4). ANDRADE also provided the applicable page of QCP X 3 2, Appendix II, to the NRC which is included in this report as Attachment (5). l
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Interview of Steien LARSON Dr. March 17, 1983, Steven LARSON, a DI electrical QC inspector, was interviewed by '
!iRC Ipvestigator H. Brooks GRIFFIN at Wolf Creek. LARSON was asked if he had been aware of the controversy concerning inspection criteria for anchor bolts. LARSON stated that the inspection criteria under Appendix II of QCP X 302 did not require all of the inspection points listed in the civil criteria of QCP VII 106. LARSON stated inspectors were instructed to only check torque on the bolts. LARSON said he had always chec'ked to the civil criteria on his inspections, and that PATTERSON changed the instructions to include the civil criteria after some of the inspectors complained.
LARSON was asked about the incident involving his discovery of a support welded cct of the middle third. LARSON said that certification tests given to welding ~
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inspectors called for an NCR to be written anytime a major defect involving welds out of the raiddle one-third were identified. LARSON stated that the QC inspectors had been instructed that if quality engineers leayned from craft personnel of a middle third violation, they had the option of authorizing a Middle Third Deviation
!.ctice (l'TD). 'tARSON stated that if the QC inspectors found the defect, they wer.e instructed by precedure to issue an NCR.
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LARl EON stated that in this instance,1ELLIOTT and he disagreed about the writing of cr. i;R cr. the middle third deficiency. LARSON said thct ELLIOTT told him that if .
he did r.ct do it his way, he would show him the gate. LASSON stated that'as 'a -
resuit of ELLIOTT's sta.tements, he (LARSON) did not write an NCR. LARSON stated that sutsequer.t to his conflict with ELLIOTT he bad talked to quality engineering, and they told him that Middle Third Deviation Notices were usually issued in response to QC HCRs. LARSON indicated that 'ELLIOTT's threat of terminatiori did not it.ti:.icate him into signing off on any defective work. LARSON stated that since the 'E's irvestigation had been. initiated into this mctter, the inspecters r.et
..' " t"eir su;crviscr, ELLIOTT. LARSON stated he did ret r.ow think that ELLIOTT r.+tr.1 idet he said about terminating him, and he believed the problems hac Leei.
i res lvec. .
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13 LARSON,was asked if he knew anything about a "megger box" used at Wolf Creek site t.y electrical CC inspectors. He said the retro-support group did not inspect
' cables, and he did not know anything about a "megger box." -
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LARSON stated that he did not know of any QC inspectors that had been intimidated,
- nor was he aware of any inspect' ions that had been improperly accepted at Wolf Creek, other than the ones he had identified to the NRC. LARSON stated that he did not believe that DI management personnel were attempting to intimidate QC
' inspectors into by-passing inspection steps or signing off on improper inspections .
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Ir.terview of Cluster M. " Bill" ELLIOTT
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. Or. March I8,1983, Cluster M. ELLIOTT, a DI electrical QC supervisor, was -
interviewed by NRC Investigator H. Brooks GRIFFIN at k'olf Creek. ELLIOTT stated he was the supervisor over the raceway, retro-supports and ongoing support groups.
ELLIOTT was asked about' the incident involving anchor bolts not identified by stamped letters at Wolf Creek. , ELLIOTT. stated that two of his electrical QC inspectors, ANDRADE and McMURTREY, wrote a memorandum to quality engineering questioning the inspection criteria contained in Appendix II. ELLIOTT stated that qutlity engineering (QE) wrote a reply to their memorandum, referencing an NCR that had been written on the retro-support reinspections. ELLIOTT stated that after QE's explanation was returned to QC, McMURTkEY cane to him and shewed him a copy of Appendix 11 versus the NCR that QE had referenced. ELLIOTT stated that after -
he reviewed the two documents, he agreed with McMURTREY that the NCR did not speci-fically state that the civil criteria should be excluded from the inspection.
ELLIOTT stated he took a copy of Appendix II and the NCR to a quality engineer by the name of John ROSS. ELLIOTT: stated he and ROSS talked to David MOSS, a QE supervisor, an'd then held' discussions with Timothy MURPHY, a quality electrical ,
c'.vil engineer. ELLIOTT stated that as a res' ult of their discussions, QE then wrcte a reply stating QC inspectors should inspect to the criteria contained in Ape 1 dix .II. ELLIOTT stated he met with PATTERSON, the electrical QC ~ supervisor, ,
ar: -hat FATTERSON decided he~ would change the irspecticn criteria to include the 7 civil criteria.
ELLIOTT stated that PATTEP. SON ordered the acceptance tags pulled, en the anchor bolts not identified oy stamped letters, and he also instructed that
'.C:.s be written on the anchor bolts.
ELLIOTT was questioned about the incident in which he disagreed with a QC inspector ty the name ofiSteven LARSON regarding a support welded out of. the middle third.
. ELLIOTT stated that the QC inspector insisted that an UCR be written on this segrt, and that he (ELLIOTT) said the inspector should che:L to determir.e if a MTD had already been written. ELLIOT1 said he toic LAi.50h' ti.at checking for I
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15 MTDs was the established procedure at Wolf Creek for QC inspectors, and that if LAA50N c,ould not follow this, he would "get son. cone who could." ELLIOTT stated d.at in other words he meant he (ELLIOTT) would terminate Lt.R50N if the established ~
procedure was not followed. ELLIOTT stated that his choice of words was not proper, and the situation probably did not merit such harsh comments.. ELLIOTT '
stated that DOAN, the lead, arranged for a Middle Third Deviation Notice. ELLIOTl stated he did not think his statements to LARSON would cause any of the inspectors to accept nonconforming conditions.
INVESTIGATOR'S NOTE: ELLIOTT was not interviewed
.regarding the incidents involving the inspection of a hby
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1_e_lectrical QC inspectors. Such inquiries would compromise
) confidentiality. Th'is nonconforming condition -
was addr'essed to the NRC Senior Resident Inspector at Wolf Creek to be included in his routine inspection module.
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16 Ir.terview of James L. PATTERSON Or March 18, 1953, James L. PATTERSON, the DI Senicr Electrical Quality Supervisor, -
was interviewed by NRC 1,nvestigator H. Brooks GRIFFIN at Wolf Creek. PATTERSON was asked about the incident involving anchor bolts without stamped letters. PATTERSON stated he knew that one of the electrical QC inspectors by the name of ANDRADE had written a menorandum on this problem, but that this me_morandum had not come to him. 'PATTERSON stated he learned about the anchor bolt problem when a former ir.spector named CHENOWETH told him about it during his exit interview. PATTERSON -
said CHENOWETH told him anchor bolts had been identified that did not have stamped letters on them, and the lack of the stamped letters meant that the inspectors were
'nct able to determine the length of the bolt. Following his meeting with CHENOWETH, PATTERSON stated he looked at the NCR that addressed the reinspection criteria for deterninin5 torque on anchor bolts. PATTERSON said he decided that the intent of -
the NCR was not to ignore the civil criteria for the inspection of these anchor bolts. PATTERSON stated he called a meeting and tolo the supervisor and the lead to change the inspection criteria to include the civil criteria. PATTERSON stated he ordered the check sheets pulled from the vault and NCRs written on the three anchor bolts.
! PATTERSON was~ asked about the incident involving ELLIOTT's. alleged threat to LARSON regarding possible termination over a conflict on an NCR. PATTERSON stated that a ,
Q~ ir.spectcr by the name of ANDRADE had ccme te his office, and told him about
~
ELLIOTT's statement to LARSON. regarding terminaticn. PATTERSON emphasized that. ,
ir.spectors are free to come to his office anytime to discuss their problems as leeg as they inform their lead and supervisor. PATTERSON stated that LARSON had called quality engineering for a Middle Third Deviation Notice number, and that on two occasions the quality engineers gave him incorrect MTD numbers for the parti-cular support that,LARSON:was inspecting. PATTEE 50N stated he believed the ergineers had been looking at the wrong suppert g-cup, and the incorrect numbers they gave LAP. SON were an accident. PATTER 50% sta:sd he understood why LARSON war.teo to write an NCE, and he believ'ed it was urfortunate that ELL 10T1 had choten
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s, to n.tke the statements he did regarding showing LAR50!i "tth gate." FAT 1ER50fi saic he did not believe ELLIOTT I intended to terminate LARS0ri.
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Status of Investigation This status of this investigation is CLOSED. _
INVESTIGATOR i S NOTE: The following individuals named in this report as ,DOAN, ROSS, FREDRICKSON, CAMPBELL, PEARSON, MOSS, and MURPHY were not interviewed because both ELLIOTT '
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.and PATTERSON acknowledged the situation alleged by I g- .. -., 1 and corroborated by the fear QC inspectors interviewed. -
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'(1) - Signed Sworn Statement 3-17-83 _
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(2) - /Lonfidentiality Agreement 3-1s-83 *
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(3) - xANDRADE's and McMURTREY's MemorandumtopohnROSS(QE) 2-17-83 (4) -
ANDRADE's Memorandum to PATTERSON and SCHRYER 3-11-83 (S) -
QCP-X-302, Appendix II Undated j'
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, hereby make the follcuing voluntary statement t o l W . I-f, o o h (Gr-/t- W u , who has identified h2mself to me as an '
investigator with the U. S. Nuclear Regulatory Ccmnission. I make this state-ment freely with no threats or prcmises of reward having been made to me.
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. 1 I have read the for-L=rstaternent cons
- of k handwri W pages.
I have made and initialed any necessary corrections and have signed my name in Tl
- ink in the margin of each page. I swear that the foregoing statment is true and correct. Signed on S-/) -23 .
at F//?3Qm - G l
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Subscribed and sworn to before e at//M this, /7/A)ay of //fa re/1 ,
19[(J at UslF Cred. .
2NVESTIGMOR: WI'INESS:
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CONFIDENTIALITY AGREEMENT I Nava jnformatien Regulatory Comission (NRC). that I wishoto, provide in confidence to the U. S. Nuclear a ccndition of providing this information to the NRC.I request:an I will not provide thisexpress pledge information to me. voluntarily to the NRC withou(such confidentiality being extended agreeing to this confidentiality, will adhere to the following (1)
The NRC will not identify me by name or personal identifier in any NRC initiated document, conversation, or comunication released to the public which relates directly to the information provided by me. -
"public release" to encompass any distribution outside of the NRC with theI understand futherance of their responsibilities under law or public trust.excsp (2)
The NRC will disclose my identity within the NRC only to the extent required for the conduct,of_NRC related activities.
1" (3) affort consistent with the Gvestigative needs of the Comiss -
which would sersons clearly subsequently be expected contacted to result in the disclosure of my identity to by the NRC
!ven though the NRC will make every reason. AT a later stage I understand that 1y identification could be compelled by orders or subpoenas aw, hearing boards, or simila.r legal entities. urts of issued by coa In such cases, the basis for a
- ryranting this promise of confidentiality and any other releva confidentiality.
If- this effort proves unsuccessful, a representative of ~
.h2 NRC will attempt to infonn me of any such action before, disclosing my id also understand that the NRC will consider me to have waived my right to onfid:ntiality
' y id ntity.
i if I take any action that may be reasonably expected to disclose I further understand y rights to confidentiality that
.if I provide (or the haveNRC will consider previously provided) me to have waive infonnation
- a any other party that contradicts the infonnation that I provided to the NRC ..
' ra ifthecircumstances NRC. indicate that I am intentionally providing false infonnation -
- :hnr Conditi6ns: (if an[)
, have read and fully understand the contents of this agreement. I agree with ' '
s provisions.
l ----.._..., '
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l Sigrfat0Fe7t'sou'~ rte or 1Mf5 Nation .
Typed or(frintedJame.and_Addrhs.
c2d to on behalf of the US Nuclear Regulatory Com to
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Typed or Printed Nime and Title '
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[ ' .. , , 5.3.7 states miniansa embedmont must be equal to or. exceed the specified requirement 4 at completion cf,the installation,_,thei flnished bolt projec, tion siust result in the M threaded end of the bolt being at .leastiflush with the outside surface of the nut. ,
' El .. F:..L 3 g._
. t states; anchor bolte shall.have a mintmum embedmont, unless otherwise noted on S . drawing..iI Lo s .b.t.i. . i.- ' .. . > b u m . .
S L....
- the bolt.. hls L8ttatesithe Mu n.v. ;. stamped lettertI.D.-Tfor. length shall not be removed from the end of.
A . < .: . . . G .. ... ... QCP-X-JO2.Jppendix II states, certain expansion anchor bolt installations need not be I E inspected in regarts to civil attributes if listed on Table 1 of QCP-X-302' Appendix II.
.If., detail,is shown on this table, refer to Section
- III for specific requirements, which only lists, O MSIGNAI_UREERI hved rqu achipye4.within.1.and 1 .lf additional '
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- NO 45005 2$0tCIN 4SOO2 50lPKG .-_ .
SIGNATunE i
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.. ,.. ,. . DETACH AND RETAIN THIS RART FOR FOLI.nW UP
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' Page 1 of 6
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SCOPE c , I 1 U Thi'ar~7@jEn'3IR'Isi- app'1TcME tS'*the~VisiaI'Vei1Tibitihd of torque require- ,.. y Eents for expansion anchor bolts utilized for the, installation of racewa;'. . /.;- c j' supports in the Class .1E' buildings and Clas.s.1E , supports ,in,,the non-Class ~~~ - " " ~~ q -
. ,, Jj I..E_ b._u_i_ld._iu:;s installed prior to Augu..st
. 12..,..19.~82.-.,..,,,..e.. -
- i. _ GENERAL
.The torque renuirements and/or_ inspection _ requirements contained . berein bre as delineated in, thq disp ~osition section of NCR ISN3476C and/or;Bech-
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..,. ' t_el...T._e.c.h..ni_ - - - cal Spe..c.i.f.ica
.. .. t.io..n 10. 466@1'03ATQ)M7~~ .
_ .. . ,_ g II. TORQU2 VERIFICATION j i
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) 7:Isr accordance with-the above referenced.JCR..certain expansion anchor bolt-v
; installations heed not be .inspec,ted in. regard,to, Civil attributes.s. Refer yw,
.to Table 1,. to detemine if only torque verification is required or if. a ..'...
y
' full inspeci: ion is required per QCP-IV-106. Enen 'only'toique verification is required per Tcble 1, refer to Section III below for specific require -
'j ;
d ments and technique not shown on Table 1. Inspection and verifications t required by Table 1 installations,shall_b.e_perfomed by. Electrical Quality I Inspection. Inctall'ations .'not, referenced'. in Table.1.. require inspec ,t 1 for Civ.i.l at.t. rib.ute.s'.a'n..d.' .sh..al.1..~ be' in' 'sp_ec.'.t'ed.
- by Civil '.Qu.a.l.i..ty_.Inspec.t.
ioni.' i)
~
III. SPECIFIC REQUIPLENTS . Genercl inspection attributes and technique shall be as follows: Expa ns i on a n. -cho - - -- -r --.--'. ..:,bolte
.- --,-shall.-. not,be .inrtalled .in the following a.
creas without. prior approval unless specifically shown en 'the -- _ drawings; or. require,d,,und.er,..the., e provisions. forsurface r.ounte'd replacer.ent. plates. " t...---...<-~._,....
- 1. The outside face of the Reactor Building wa.l.l. ...k. ,
i
. . . .. . . . . , , . ,j
, 2. ".,pefpfo.ged concret.e columns, beams. ,and pilasters C.,(- )
- b. -D.L.ef1Fdisher 'shall be used between the nut and the supported.
" v .rk c:4 each bolt. Only,oue additional flat washer may be
' in:luded un1.ess..noted otherwise on.the drawing.
- c. ' Verification: Test the installed expas.sica :nch.or bolt with'a ... .
ialibri.ted Grup I ranually operated torque wrench. Test fer- ' torque by tairninf 5the nut in the direction which tightens it.. ' { Torque valu.rs in excess of those specified shall not be cause for rejection. l 1
- d. 7/. 'c' pt ine tetted npansico anchor bolt. if during testing the e i 1
. corerete 6n.n; not bra. sh : ut , the ar.ch :r does not break and the rnm..'TitM t orr,u.) fe obt#ined with r.o n.:,re than one and a half ;
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%,, . . . . .' f August IS, 1983 MEMORAt:DUM FOR: John T. Collins, Regional Administrator F.egion IV _
FROM: Ben B. Hayes, Director Office of Investigations
SUBJECT:
WOLF CREEK GENERATING STATION: ALLEGED INTIMIDATION OF DANIEL INTERNATIONAL ELECTRICAL QC INSPECTORS (4-83-005) Enclosed is the Office of Investigations report of investigation on this . subject. The' investigation established that an tct of intimidation did take place as alleged; however, no evidence was developed indicating that the supervisor's actions were condoned by his manageme.1t, or that this act of intimidation was other than an isolated incident. Neither this report nor memorandum may be released or disclosed outside of the NRC without the permission of the Director, 01. Internal NRC access and distribution should be limited on a need and right to know basis. ,
Enclosure:
As stated - cc: W. Dircks, EDO (3 copies) VR. Herr, 01:RIV 4
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' U.S. lmC In Reply' Refer To:,
Docket: STN 50-482/83-32 I:23 GCT 13 Nil 2: IS EfiCE 0F INV[siiGAliCNS f!ILD CfilCE. RECCNIV Kansas Gas and Electric Company ATTN: (Glenn L. Koester)
~
Yice President - Nuclear P.O. Box 208 - Wichita, Kansas 67201 Gentlemen: This refers to the investigation conducted by Mr. H. B. Griffin of the NRC Office of Investigations, Region IV field office during the period March 1-18, 1983, of activities authorized by NRC Construction Permit CPPR 147 for the Wolf Creek Generating Station- . This investigation was conducted to determine if a contractor quality control supervisor had intimidated a contractor quality control inspector by threatening employment termination during a disagreement over quality assurance matters. The investigation consisted of selective examination of procedures and representative records, interviews with personnel and observations by the investigator. . During this investigation, it was found that certain of your activities were in violation of NRC requirements. Consequently, you are required to respond to this violation, in writing, in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Your response should be based on the specifics contained in the Notice of Violation enclosed with this letter. Intimidation of quality ccatrol inspectors will not be tolerated from any source. The Kansas Gas and Electric Company is fully' responsible for the -- quality of the Wolf Creei denerating Station and must take the necessary actions to assure that persons performing quality assurance functions have suflicient authority and organizational freedom: (1) to. identify quality prob:=ms; (2) to initiate, recommend, or provide solutions; and (3) to verify . implementation of solutions. Your response to this violation should place particular emphasis on the corrective actions taken or planned to prevent ' future instances of quality control inspector intimidation. , In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Room unless you notify this office, by telephone, within 10 days of the date of this letter, and submit written application to withhold information contained therein within 30 days of the date of this letter. SecP acplication must be consistent with the requirements of 2.790(b)(l'. s , RPS-C [, WOJchnsen:ge RPE DDRRP&EP 'u ES RV' WC5+icle JEGagliardo TWesterman JTCo1117s
;;/ /E3 10 r; 10/ /63 10/d/83 102 ' /83
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Kansa's Gas and Electric 2-Company' . The response directed by this letter and the accompanying Notice is not subject'to'the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. Should you have any' questions'concerning this inspection, we'will be pleased - to discuss them with you. - Sincerely, W. C. Seidle, Chief Reactor Project Branch 2 -
Enclosures:
- 1. . Appendix A - Notice.of' Violation
- 2. Appendix B - NRC Investigation Report
. Cover Page and Summary
, . Case Number 4-83-005
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'bcc distrib. by RIV:
RPB1 Resident Inspector RPB2 Section Chief (RPS-C) TPB -J. Gagliardo, DRRP&EP J. Collins, RA T. Westerman ~ C. Wisner, PA0 J. Jaudon .. MIS SYSTEM B. Griffin RIV File Myron Karman, ELD, MNBB -(2)
, KANSAS STATE. DEPT. HEALTH 1 , ;
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E APPENDIX A NOTICE OF VIOLATION Kansas Gas anc Electric Company - Docket: 50-462/83-32 Wolf Creek Generating Station Permit: CPPR 147 Based on the results of an NRC investigation conducted during the period of - March 1-18, 1983, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987, dated March 9,1982, the following violation was identified: Intimidation of Quality Control-Inspector 10 CFR Part 50, Appendix B, Criterion I, states that construction permit holders are responsible for the establishment and execution of a quality assurance program, that they may delegate this work to others such as ' constructors, but they retain the responsibility for the program. Criterion-I further states that persons performing quality assurance functions shall have sufficient organizational freedom to identify quality problems; to initiate, to recomm'end or to provide solut. ions; and to verify implementation of solutions.
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DanielInternationalCorporation(Daniel;. International)istheprime contractor for construction of the Wolf Creek facility and thus has been delegated quality assurance functions by the licensee. Contrary to the above, on or about February 1,1983, a Daniel International quality control supervisor intimidated a quality control inspector with a threat of employment termination during a disagreement over whether or not the quality control inspector should document, by nonconformance report, a condition found which was apparently adverse to quality. ** This is a Severity Level IV Violation. (Supplement 11.0) (482/8332-01) Pursuant to the provisions of 10 CFR 2.201,' Kansas Gas and Electric Company is i hereby required to submit to this office, within 30 days of the date of this Notice, a written statement or explanation in reply, including: (1) the corrective steps which hav been taken and the results achieved; (2) corrective, ' steps which *ill be taken to avoid further violations; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown. Dated: Octo:er 11, 1983 m_ ID$ 8 '* D $ b N l f)$ f0 ,_ o 3- -
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