ML20150C314
| ML20150C314 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/10/1987 |
| From: | Driskill D, Griffin H, Hayes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20150C176 | List: |
| References | |
| FOIA-87-800 NUDOCS 8803180117 | |
| Download: ML20150C314 (129) | |
Text
-_ _ -____________
Title:
WOLF CREEK NUCLEAR OPERATING CORPORATION:
ALLEGED MATERIAL FALSE STATEMENT BY KG&E MANAGEMENT Licensee:
Case Number: 4-86-004 Kansas Gas and Electric Corapany Report Date: November 10, 1987 Post Office Box 208 Wichita, Kansas 67201 Control Office: 01:RIV Docket No.: 50-482 Status: CLOSED Reported by:
Reviewed by:
Y a
.c
)
H. Brooks GriffinpInvestigator Donald D. Dristil V Directo Office of investigations Field Office Office of Investigations Region IV Field Office, Region IV Participating Personnel:
Appr by:
Chris VanDenburgh, Region ! Inspector Don Caphton, Region Ill Inspector Donald D. Driskill, Director, OlF0: Region IV OfficeofInv()esig Ben 5. Hayes
) rec r ions information in this record was deleted in a:cerdance w:th the fresdc of information Act, exe"ptions k Mb F0tA N ' D
~
WARNING The attached document / report has not been reviewed pursuant to 10 C.F.R. 5 2.790(a) exemptions nor has any exempt material been deleted. Do not disseminate or discuss its contents outside NRC. Treat as "0FFICTAE'T5E ONLY."
3 8803180117 880314 a
SYNOPSIS in March 1984, Kansas Gas ar.d Electric (KG&E) established the Quality First i
program (Q1) for the purpose of responding to employee concerns at the Wolf j
Creek Generating Station (WCGS). A KG&E contract emplo,ee was selected as the Q1 Team Leader, and he, working under the supervision of the Quality Assurance 1
(QA) Manager, established policies and procedures for the program. Q1 moni-tored a telephone hotline, interviewed walk-in employees, and interviewed terminating employees for any concerns they had related to tardware, installa-tion, documentation, and wrongdoing. Q1 investigators investigated the concerns, issued reports containing conclusions, and recomended corrective action.
In August 1984, KG&E management removed Q1 from under supervision of the QA Manager and replaced the Q1 Team Leader with a permanent KG&E employee with l
the title of Manager of Q1. By this time, Q1 had a case backlog of several l
hundred concerns yet to be investigated. The Manager of Q1 hired additional investigative staff members and initiated policy and procedural changes in Q1 which ultimately resulted in various Q1 personnel making allegations to the NRC about the credibility and effectiveness of the program and its management.
In September 1984, a Nuclear Regulatory Comission (NRC) inspector began a lengthy review and evaluation of the Q1 program and issued a series of inspec-tion reports on technical issues that were generally favorable. Also beginning in September 1984,)the Assistant to the Director for the NRC Office of Investigations (01 evaluated the Q1 program. The resulting 01 report was highly critical of the program's investigative process and concluded that the NRC should not rely on Q1 to adequately resolve employee concerns.
In May 1985, an NRC Region IV task force conducted a 100% review of completed Q1 cases on technical issues, and concluded the Q1 investigations were generally adequate. The task force was critical of Q1's verification of correcuve action. During the task forces' review, two O! investigators reviewed 112 Q1 files related to wrongdoing issues and concluded the investi-gations were incomplete, poorly documented, and inadequate for the purpose intended.
In June 1986, the NRC O! initiated an investigation focusing on the Q1 program between late August 1984 through December 1984, the results of which are l
contained in this report. This NRC investigation was conducted in response to I
allegations that KGlE management had utilized the Q1 program in a manner l
designed to suppress employee concerns from being fully investigated and/or having appropriate corrective action implemented, so the employee concerns l
would not interfere with the WCGS operating license.
Twenty-one present and former Q1 personnel were interviewed along with the KG&E Chief of Security and the KG&E Vice president, Nuclear. individual Q1 l
investigations were reviewed with each of the investigators interviewed. All of the Q1 investigators interviewed disclosed sufficient recollection of the issues reflecting that they had assimilated the facts and performed some type of investigation. Based on these interviews, certain Q1 case files were selected for review. In addition, two NRC inspectors participated in technical reviews of selected case files, and their evaluations were reported as part of this investigation.
Case No. 4-86-004 1
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This investigation concluded that commencing in August 1984, the new Manager of Q1 made certain fundamental changes in the Q1 program which directly led to a perception by a ma,iority of the former Q1 investigators interviewed that employee concerns were not being adequately investigated. These changes included a prohibition related to investigators' scoping of their investiga-tions beyond the parameter of the original allegation. Another change defined Q1's involvement in an issue as complete once the concern was referred to another organization such as QA, a construction or design group, security, or the KG&E legal office.
During the interviews with the former Q1 investigators, a trend emerged. Each investigator believed his work was adequately investigated and accurately reported, but many believed their fellow investigators had been restricted or manipulated by Q1 management which resulted in concerns not being adequately investigated. The case review portion of this investigation established that a vast majority of Q1 investigations were nct adequately documented and acceptance of the investigative conclusions 3as largely an act of faith in the judgment of the individual investigators. Tne case file review revealed that many concerns received meaningless superficial investigation. The most corrrnon reason for this may have been that under the Manager of Q1's supervision, concerns, upon receipt, were sumarized in one or two sentences providing little detail for the Q1 investigators to utilize to conduct a meaningful investigation. A large percentage of the wrongdoing issues were inadequately investigated and documented, and as voiced by the KG&E Vice-President, Nuclear, wrongdoing was not in the mindt of much of KG&E management as being related to safety.
In contrast, some of the most significant technical issues received extensive Q1 attention and multi-level management review. Also, the NRC was involved in closure on many of these important technical issues, and in these instances the Q1 program was highly successful in communicating important problems to the affected organizations for corrective action.
A substantial number of concerns which merited a thorough investigation were given only superficial attention, and their inadequately investigated and documented closures were accepted by Q1 management. Despite the substantial number of shortcomings identified in the Q1 program during this investigation, it is concluded that the evidence does not establish wrongdoing on the part of KG&E management. However, it is r:comended that the NRC not place great reliance on the Q1 investigative program in the form that it existed in late 1984 1
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Case No. 4-86-004 2
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ACCOUNTABILITY PAGE ThefollowingportionsofthisROI(CaseNo. 4-86-004) will not be included in the material placed in the POR. They consist of pages 3 through 126.
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i Case No. 4-86-004 3
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THIS PAGE LEFT BLANK INTENTIONALLY Case No. 4-86-004 4
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~ TABLE OF CONTENTS Page SYN 0PSIS............................................................
1 ACCOUNTABILITY PAGE.................................................
3 APPLICABLE REGULATIONS..............................................
7 DETAILS OF INVESTIGA110N............................................
9 Purpose of Investigation.......................................
9 Background.....................................................
10 Graph Reflecting Q1 Cases Opened and Q1 Cases Closed by Month.,
14 l
Graph Reflecting Number of Existing Employees Interviewed by Q1 by Month...................................................
16 Graph Reflecting Q1 Case Closure Average Per Month.............
18 Interview With Charles HILL, Former Q1 Investigator, Wolf Creek
)
Gene ra ting S tat ion (WCGS).....................................
19 Interview With n THE 24
{InterviewWit (InterviewWith
- 32) 6,7 6 N (Interview With
- 38) q.7C,47D Interview With 41 Interview Wit 2 7O Interview With 47
(,, ') d.4 7 0 Interview With 5
6, 7 d,v fp
(' Interview Wit j
l
- 52) l O
,Interv ew 7p Intery w Wi 7p Inte ew W gg gv73 Interview With 59)6,70.V 70 Interview Wi
(
63 70 Interview Wi l
69 70 ntery Wi y
nt ew Wi 7p Interview oh OHMSON, Chief of Security, Wolf Creek Nuclear Opera
- 85) d 7C Y 7 86 i
(InterviewWith Interview With obert L. SCOTT, Former Q1 Lead, WCGS..........
89 Interview With Charles SNYDER, Manager of Q1, WCGS............
93 Case No. 4-86-004 5[, y q / '? $
f:: n D. u.!
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TABLEOFCONTENTS(Continued)
Page Interview With Glenn L. K0 ESTER, Chairman of the Board, WCN00.
103 Willfulness / Intent Section....................................
105 A g e n t ' s A n a ly s i s..............................................
119 Agent's Conclusions...........................................
122 LIST OF EXHIBITS...................................................
123 LIST OF ACR0NYMS...................................................
125 1
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Case No. 4-86-004 6
APPLICABLE REGULATIONS Allegation: Material False Statement by KG8E Management 10 CFR 50.5S(e): Conditions of Construction Permits, Notification to the NRC of Design and Construction Deficiencies AEC, Chapter 16, Section 186: Revocation, Material False. Statements l
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I Case No. 4-86-004 7
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THIS PAGE LEFT BLANK INTENTIONALLY l
Case No. 4-86-004 8
DETAILS OF INVESTIGATION Purpose of Investigation The purpose of this investigation was to determine whether the Quality First (Q1) program at the Wolf Creek Generating Station (WCGS) was utilized by Kansas Gas and Electric (KG8E) management to suppress employee concerns from being fully investigated and/or having appropriate corrective action imple-mented, so the concerns would not interfere with fuel load or licensing.
The following allegations, made to the Nuclear Regulatory Comission (NRC) by former Q1 investigators, denote ways in which KG&E management allegedly altered the Q1 program in order to close out concerns without adequate invest-igation or substantial corrective action.
1.
Charles SNYDER assumed supervision of the Q1 program in August 1984, with t mandate from KG&E management to have all Q1 concerns that could interfere with fuel load closed by December 1984 SNYDER comunicated this mandate to the Q1 investigators in his first meeting with the Q1 staff.
2.
As the December 1984, target fuel load date approached, significant Q1 findings referred to the affected organizations still had not received corrective action. Some of these findings received no corrective action prior to fuel load.
3.
Q1 investigators were forbidden by Q1 management to investigate other concerns they identified during their investigations. Q1 management required the Q1 investigators to report the new concerns to the Quality Assurance Departirent (QA) as Quality First Observations (QFO); however, QA was too busy to address these issues before licensing, and as a result QFOs were not investigated.
4 KG&E management limited the time Q1 investigators were allowed to work on investigations and limited the scope of their investigations in order to close the concerns quickly.
5.
Af ter SNYDER assumed supervision of Q1, because cases were being closed without adequate investigation, the program lost credibility which resulted in a dramatic drop in the number of concerns reported to Q1.
6.
Significant allegations reported as substantiated by Q1 investigators were subsequently documented as unsubstantiated by Q1 management.
7.
Significant findings reported by Q1 investigators were ultimately reported as being without nerit by Q1 management.
8.
Certain Q1 investigators were terminated or removed from Q1 by Q1 management, because they refused to change investigative findings which substantiated allegations.
Case No. 4-86-004 9
9.
The Q1 procedures were changed by Q1 management to make it easier to close investigations without adequately examining their merits.
- 10. Significant Q1 investigations were closed without adequate investigation by Q1 management, because they had a conflict of interest with the issues being investigated.
11.
Initially the Q1 program was authorized to investigate all wrongdoing; however, KG&E management ordered that drug allegations i
received by Q1 were to be referred to Security. Security did not investigate the allegations.
- 12. Certain Q1 investigators hired into the program by SNYDER were closing Q1 files without actually conducting investigations. A comon method used by these Q1 investigators was to report that the allegation was not specific enough to investigate when, in fact, there was sufficient information to pursue the concerns.
INVESTIGATOR'S NOTE: Twenty-one former Q1 personnel were interviewed during this NRC investigation. The Q1 investigators were asked to review a Q1 master list which contained a brief description of each allegation.
This list had been prepared in May 1985 for the NRC to use in its evalua-tion of the Q1 program. The investigators were questioned about the cases they had investigated. Cases potentially related to allegations being investigated by the NRC are sumarized in the body of this report.
The transcripts of the interviews are exhibits attached to this report.
Following the case reviews with the former Q1 investigators, each were questioned about their knowledge related to the allegations made against Q1 management.
i
Background
On February 16, 1984, the Atomic Safety and Licensing Board Panel (ASLBP) licensing hearings for the WCGS were concluded. On July 2, 1984, the ASLBP i
issued a favorable licensing decision to KG&E for the WCGS.
In March 1984, KG8E created the Q1 program to establish a licensee emplojee concern program, so site employees could bring their safety concerns to the l
attention of the licensee. Q1 was set up to monitor hotline telephone calls, take walk-in concerns, and to interview all terminating employees relative to d
hardware, installation, documentation, and wrongdoing concerns. Owen THERO, a 4
KG&E contract employee, was made Team Leader of the Q1 program and helped create its procedures and policies.
Initially Q1 management reported to the site QA Manager, William RUDOLPH. In August 1984, overall supervision of Q1 was transferred to the KG&E Manager of Quality, Richard GRANT. In August 1984, Charles SNYDER was named Manager of Q1, and THERO was reassigned to supervise the Q1 interview group.
In September 1984, Region IV NRC Inspector Glen Madsen was assigned by the Director of the Division of Reactor Safety and Projects, Richard Denise, to evaluate the Q1 program at WCGS. In Inspection Report STN 50-482/84-37, Madsen reported an on-site inspection from September 25 through 27, 1984, in which he conducted a programmatic review of Q1. In Inspection Report 84-48 i
which covered October 9 through November 2, 1984, Madsen analyzed the Case No. 4-86-004 10 L _,_
organizational structure, the qualifications of the investigators, and also reviewed 57 Q1 investigative files. In Inspection Report 84-52, which covered the period November 13 through December 13, 1984, Madsen reported his review of 31 Q1 files and associated Q1 action reports, in Inspection Report 84-58, which covered the period December 14-24, 1984, and January 7-18, 1985, Madsen l
reviewed 18 Q1 investigative case files related to 86 concerns which included closed Q1 files. Madsen also analyzed the reportability of the issues and evaluated the alleger recontact aspect of the program. Madsen further reported that he had completed file reviews for about 40% of the existing Q1 files. In l
Inspection Report 85-09, which covered the period January 21 through February 15, 1985, Madsen reported the review of four files and 15 concerns, in Inspection Report 85-24, which covered March 6-8, 1985, Madsen reported his review of 24 closed cases. Madsen's overall conclusion relative to the 01 program's structural organization, methodology, performance, and resulution was generally favorable.
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During September and October 1984, William Ward, Assistant to the Director, l
Office of Investigations, conducted an evaluation of the KG&E Investigative Program (Exhibit 26). Ward examined Q1 investigative files as part of his l
review, and interviewed Q1 personnel. He also visited the KG&E Legal Depart-ment (Legal) in Wichita, KS, reviewed investigative files, and conducted appropriate interviews _with investigative personnel. Ward's subsequent l
evaluation report was critical of the following aspects of KG&E's investiga-tive process:
1.
There was no central control for the various KG&E groups involved in conducting investigations and no standardization of their work product.
2.
Drug allegations received by Q1 were referred to Site Security (Security) or the KG&E Construction Manager and were not actively investigated.
3.
Q1 investigators were not allowed to pursue other deficiencies they identified during their investigations, and there was no feedback to Q1 on the deficiencies identified in Q1 observation reports.
4.
KG&E interpreted the NRC's reportability requirements under 10 CFR 50.55(e), as it potentially related to wrongdoing, as requiring both (1) a construction deficiency which if uncorrected could adversely affect the safety of operations during the life of the plant and (2) a significant breakdown in the QA Program before a concern qualified as a reportable j
issue.
5.
KG8E had employed only one trained investigator.
l 6.
Many of the Q1 investigators emphasized the hardware aspects of wrongdoing issues and their resulting reports did not focus on the elements that may have indicated intentional wrongdoing.
7.
Many Q1 investigations did not attempt to evaluate the potential scope of the allegations, but tended to treat each as an isolated I
incident.
8.
Q1 investigative reports generally did not document the results of Case No. 4-86-004 11
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interviews and document reviews in sufficient detail to establish the basis for the investigator's conclusion.
Ward concluded that KG&E had no integrated investigative program and conse-quently recommended that no reliance be placed on KG&E's investigative product.
On May 27-31, 1985, an NRC task force made up of Region !Y inspection staff headed by) Division Director Richard Denise, along with Office of Investina-tions(01 investigators Donald Driskill and Mark Emerson, conducted a 160%
review of existing Q1 case files. The Region IV inspection staff's findings were reported in NRC Inspection Report STN-50-482/85-28. The inspection staff concluded that Q1 reached proper resolution on technicals issues and that the program had the appropriate level of management integrity and independence.
The inspection staff was critical of the appropriateness of feedback to Q1 from other organizations to support closure of the Q1 cases. The inspection staff also was critical of Q1 for not trending the Q1 investigative findings for KG&E management.
l The 01 investigator's reported their findings in 01 report A4-84-005. The OI investigators reviewed Q1 files for 112 concerns generally considered to be wrongdoing. Twenty technical concerns were also reviewed as part of the 112 concerns. As a result of this 01 review, many of Ward's conclusions regarding shortcomings in the Q1 program were corroborateo.
1 The O! investigators reported that the Q1 investigative conclusions in about two-thirds of the case files reviewed were not supported by documentation.
The investigators reported two fundamental shortcomings in the program: (1) lack of experienced investigative personnel, and (2) progrannatic requirements which would ensure objective and thorough investigations. The 01 investi-gators concluded that the interview of the allegers, in most cases, was inadequate based on the review of interview notes and/or tape transcriptions.
Secondly, Q1 investigators primarily focused on the "impact on safety" as a basis for not performing thorough investigations on the employees concerns.
The 01 investigators concluded that little consideration was apparently given to the possible adverse safety aspects of drug abuse and other wrongdoing, and that wrongdoing investigations were closed preraturely or were not investigated because of their perceived lack of impact on safety. The O! investigators further concluded that the investigative activitj of many of the Q1 investi-gators was poorly documented. The 0! report listed case examples where the information contained in the support documentation was not consistent with the Q1 conclusion. It was further concluded that the Q1 staff was not grounded in the fundamentals of investigation and was failing to adequately resolve allegations of wrongdoing.
In June 1986, an Office of Investigations' investigation was initiated, with the concurrence of the Connission, related to allegations that KG&E management was utilizing the Q1 program as a "cover up", thereby suppressing employee concerns from being fully investigated and/or reported to the NRC.
Review of Q1 Computer printout for Employee Concerns A current Q1 computer printout for all Q1 investigations was reviewed covering the period from March 1984 through March 1985. A numerical count by month of Case No. 4-86-004 12
concerns (1) opened for investigation and (2) investigated and closed during this period was made and plotted on a line graph. SNYDER replaced THER0 as supervisor on Q1 in August 1984 Beginning in August 1984, the number of concerns opened by Q1 dropped significantly. Between the date SNYDER replaced THERO and the target date for fuel load, December 1984, there was a dramatic increase in the number of cases closed per month during this period. The following graph illustrates these monthly totals. Correspondingly, during this same period the number of new allegations logged as open concerns by Q1 dropped.
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21 ji Q1 CONCERNS OPENED AND INVESTIGATED 250
'r CONCERNS 225--
OPEN
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- _ CLOSED
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3/84 5/84 7/84 9/84 11/84 1/85 3/85 4/84 6/84 8/84 10/84 12/84 2/85 l
MONTHS
Another variable to be considered was the number of exiting employees inter-viewed by Q1 during this same period. The following graph shows by month the number of terminating employees interviewed by Q1 through December 1984 I
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--....--.4.
}l EM P L.OYEES PROCESSED BY Q1 l
1000 7_g g g p 9 900--
EM PLOYEES 800--
700--
600-f 500--
N 400--
300--
200--
d d
l 3/84 5/84 7/84 9/84 11/84 1
4/84 6/84 8/84 10/84 12/84
[_
MONTHS
The number of investigators in the Q1 program increased during this same period. A numerical case count by month was made for each investigator, and this data was used to establish a case closure average per investigator per month. The results were plotted on a line graph. The graph indicates that the average number of cases closed by investigators began increasing in August 1984, after SNYDER replaced THERO. The results show that in the months prior to SNYDER taking control of Q1, individual investigators averaged closing 4 or 5 cases per month. In Noverber, 1984, the investigators averaged a closure rate of 11 cases per month with some investigators having closed only one case and others closing as many 33 or 36 cases thct month.
INVESTIGATOR'S NOTE: Noteworthy is the fact that
)# N who handled the more subjective wrongdoing investigations arassment and 47 9 intimidation, discrimination, falsification,etc.), closed 33casesin November 1984, and had a three month closure average of over 18 cases per month. Unlike reviewing a document or reinspecting a weld, wrongdoing issues norr. ally require indepth interviewing and corroboration of the interview testiinony before a valid and supportable investigative conclu-sion is attained.
4 Case No. 4-86-004 17 g
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RATIO OF CONCERNS CLOSED TO CONTRIBUTING INVESTIGATORS E
32.o-----------------------
RATIO rI y
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RATIO 9.6 --
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3/84 5/84 7/84 9/84 11/84 1/85 3/85 4/84 6/84 8/84 10/84 12/84 2/85 MONTHS
Interview With Charles HILL, Former Q1 Investigator, WCGS On June 27, 1986 HILL was interviewed in by NRC Investigator DonaldDriskill(Exhibit 1). HILL said he a en praytously employed by l
Nova Power Company from March 1984 through September 1984 in the Quality l
Startup program at WCGS. HILL said that he and Owen THER0, the Q1 Team i
Leader, were responsible for writing procedures and implementing the Q1 program. HILL said that when Q1 was initiated, he and THERO reported to RUDOLPH, the QA Manager, but later Q1 were placed under GRANT, the Corporate i
QA Manager, ostensibly to acnieve greater independence for Q1. HILL said this change tas the result of an incident when RUDOLPH ord ed the Sec r guard kMM force to break in a arch a terminating employee's truck for documents while was being interviewed b gators. HILL said that the secur orce removed documents from truck, showed them to RUDOLPH, then RUDOLPH ordered the security guar to shred the documents.
INVESTIGATOR'S NOTE: The KG&E Legal department refused to produce their internal investigation of this issue, claiming it was an attorney work
[
product. A more detailed explanation is contained on page 32 of this report.
l HILL said that originally Q1 was created to identify problems at WCGS. He said that at the time, the Government Accountability Jroject (GAP) was l
l becoming involved in WCGS licensing, and KG8E management decided it would be a l
good idea to interview terminating employees. HILL said that by the time Q1 was fully operational, as many as 50-75 people were interviewed each day. He i
explained that the number of concerns mounted, and some of the issues were difficult to resolve.
HILL said that he recalled an issue, identified in June or July of 1984, which related to mater structural eel weld rod reports (MSSWR). HILL said that the Q1 investigation deterr.ined that the American Welding Society (AWS) required records related to traceability for 50-70% of the steel used a complete, missing, or inaccurate. MILL said the Q1 investigator who was aggressively pursuing this issue, was 70 r
l removed from th Q1 program by Daniel International Corpo and KS&E management and placed back in QA. HILL said he considere removal a7 O demotion. He said the MSSWR issue was transferred to Bech I to be resolved by walkdown inspections and sampling. MILL said that'te did not know the outcome on this issue, but said that because WCGS had been licensed, he presumed they had answered the concern. HILL in cated that he and THER0 f
l believed GRANT's and RUDOLPH'E removal of g
had an intimidating effect 7D on most of the remaining Q1 personnel and n 'b'te their independence to perform their Q1 function.
HILL said he recalled that the allegations related to the structural steel i
ssue wert provided by two different allegers. He explained that in of
, removal, a violation was written by another investigator, N
LL said that af ter he lef t the Q1 program, he later had occasion to ta to one of the two allegers who told him he had subsequently been teral-nated at WCGS for tardiness. HILL said it was his understanding that another Q1 investigation had demonstrated that this accusation against the alleger (tardiness) was not true. HILL said that this former employee told him that g g y 2 f)
I Case No. 4-86-004 19 i
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,_ __ _.. _ _,.__, __, m _.__ _ ___,___ -____. -- -. _~
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KG&E had since telephoned him and asked him to drop his harassment allegation against the utility.
HILL said he recalled a Q1 meeting during which GRANT said he had received complaints from the construction and startup departments about the aggressive echniques employed by Q1 investigators. HILL said he believed that a Q1 investigator from the KGIE General Counsel's Office in p[~ichitawh had been assigned to Q1 to handle drug and intimidation allega-adversely affected by GRANT's statements. HILL said he believed l
became less aggressive in his investigations as a result.
HILL said that while Q1 was still under RUDOLPH's supervision, they were authorized to hire as many as 20 more investigators. HILL said that by the time he lef t the Q1. program, he and THER0 had hired 8-10 additional investi-gators. HILL said there was one investigator, Robert L. SCOTT, hired by i
GRANT. HILL said SCOTT care to be referred to by the other Q1 investigators as "Bechtel Bob', because he always searched for means to invalidate allega-tions rather than investigate them. HILL said that he believed GRANT hired SCOTT as a "ringer" to replace THERO. HILL said SCOTT regularly socialized with GRANT, and this eventually led to a confrontation between THER0 and GRANT at which time GRANT literally swore on a Bible in his office that he had no j
intention of replacing THERO.
HILL said that two days later an organizational chart was released dated the previous day relegating THERO to lead a Q1 interview group, and SNYDER took i
over as head of Q1. HILL said he believed THER0's removal as head of Q1 was l
the suit THER0's confrontation with RUMLPH over RUDOLPH's handling of i
the case. HILL said THERO was demoted to the job of supervising the int ew group and SCOTT was made sup;rvisor over the investigators. HILL said that in SNYDER's initial meeting with the Q1 investigators, he emphasized that investigations would be done his way or the investigators would have to I
l 1 eave the Q1 program. HILL said that SNYDER's background was that of a KG4E construction superintendent.
HILL said that prior to taking over the Q1 program, SMYDER had headed the KS&E division handling prudency. HILL said that in 1979, SNYDER had defended KA M 's position related to the pipe cleanliness issue. HILL said that when investigated by Q1 -
in)ILL explained that 01ssolvo,
sue K
and pe was n construct ng argon dans i welding. He said Dissolvo tape had a high halide concentration and said it was recognized that halide tended to cause stress corrosion cracks in stainless steel under pressure. HILL said that he had personally written a Quality Program Violation (QPV) on the Dissolvo tape issue. HILL said that when $NYDER was in the construction department, he (HILL) had argued with SMYDER about this issue. HILL said thr.t SNYDER had disagreed with him about the cleanliness problem, but that the construction group's records were so poor they could not demonstrate that the pipes had been cleaned. HILL said that SNYDER had eventually given in to the argument and had agreed that M would correct the probles. HILL said that by the time he left Ql. SNYDER had nothing to resolve the probles, but HILL said his QPV had been escalated into the QA program, for resolution INVESTIGATOR'S NOTE: HRC Inspector Chris Van 0enburgh, who assisted 01 in this investigation, reviewed a sampling of QFARs to determine if j
l
appropriate corrective action was implemented in response to Q1's f(ndings. The following is a sunnary VanDenburgh's evaluation.
A review was made at WCGS of Q1 QFARs to assess the adequacy of the Q1 organi-zation's investigative closures. Information evaluated was the information in the Q1 file for eacn ites. Several licensee personnel were querted for interpretation and explanations regarding the files and Interfacing conditions of the period of time in question.
Findings:
Fourteen QFAR files relating to the Q1 organization's investigation of flushing and hydro concerns were reviewed to assess the adequacy of Ql's investigative closures. The files in general lacked data to support the Q1 investigative conclusions reached. Such supporting information, if previously assembled, was not retained with the investigative files. Twelve of the 14 LFARs based on the statements esented acc table closurea.
e r wo sur on follow-up and one I
suppor requ to assess l
the Q1 cTosure statement'of adequacy.
U Q1 Closure: Q1 Investigato, closed the itse stating that the Md, y7Q procedure would be written. '
Connent Regarding Q1 Closeout Action: Review of Q1 action in the matter found the Q1 documented closeout to be one of stating that the required corrective action would be taken to correct the concern. The Q1 investigative file did not indicate a continuing responsibility for follow-up to assure that the corrective action was taken prior to closing out the concern.
Q1 Closure: Investigator accepted closeout on 1/2/85 based upon bN statcments maae that corrtettve action to achieve the correct flow would be HQ accomplished. He signed a verification of corrective action on 1/3/85 stating l
that "the lines in question were used in this normal configuration and had acceptable flow rates."
t Comment Regarding Q1 Closeout Action: There was no flow data in the Q1 investigative file to backup the Q1 investigator's decisten regarding accept-ability of the flows nor was there a comparison of the flows to an I
acceptance criteria. For example, there was no information to show that BR00K.5' statement that "the lines in question were used in their normal configuration and had acceptable flow rates' met the required flow acceptance l
l 9 7D l
Case No. 4 86-004 21 1
be DO j
1 criteria. The validity of the Q1 closure of the concern could not be sub-stantiated through the review of the Q1 investigative file.
Concern Invest ated h'N i
Q1 Closure:
Investi ssued his investi ative re ort on i
an ver ica on o orrec e ac on repor on e final */N acceptance of the flushing was subsequently found acceptable under SUlJE100.
Concent Regarding Q1 Closecut Action: Based upon the information availcble in the file, the Q1 closeout appeared to be acceptable.
. Concern Inves d
Closure 1 invest ator closeout conclusion was that the final b,N s
y ana s repor an are e con ng ocumen s g
and that "Startup is connit,ted to follow AN5I standards per the F5AR."
He further stated that the others quoted are ewrely guidelines which have been incorporated into the F5AR. He stated that the proof flush was done in normal design configuration with normal design flow rates to prove system cleanliness.
Coesnent Regarding Q1 Closecut Action: The concern lacked specificity regard-
,ing any particular system and piping, however, did focus on requirements.
addressed the controlling acceptance requirements. AN5I M45.2.1.-1973, paragraph 3.1.2 stated "The system shall be flushed at its normal design velocity..." Since the flushing program wAs sttuctured to meet the g
controlling requirements, the closeout by appears acceptable, a
l Q1 Closure: The Q1 investigation stated that a Supplemental Correction Report (5CR) was written on 12/11/84. There was a log entry error, the system had t yn turned over (released for flushing) on 8/23/83.
Coenent Regarding Q1 Closeout Action: The Q1 closecut action appeared to be acceptable for this specific item.
It was noted that the Q1 investigation did not address whether or not other log entry errors existed,.
v70
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These QFAR closures by Q1 were sampled to dgermine if the Q1 closecut appeared to be valid. The finding was that the Q1 closeouts appeared to be valid.
HILL said that ge investigated by Q1 was traceability on Class !
valve parts We said that when 'they broke down valves to flush them, they were losing traceability on the internal parts." He said the valve parts had been stored in boxes, and when the various parts were reasses61ed, traceability was lost. HILL said that he believed this activity voided the MPP-1 data reports. HILL said he also believed the records on the hydro-testing were inadequate, and that Q1 was substantiating this type of probles with fuel load only six months away.
6'16,19 HILL said that elieved other Q1 investig ors q
(not further identified),
had experience types of problems with YDER over thei tiga ive created the Q1 program had been removed from control. personnel who had findings. HILL said that by the time he lef t Q1, the HILL said that SCOTT did not try to exert pressure on investigators to change their investigative conclusions, because it was not consistent with his personality. HILL said that SCOTT merely referred the investigative findings to SMYDER who would argue with the investigators and place pressure on thee to change their conclusions.
HILL said he remembered that had followed up on a telephonic alleg-ation which corroborated o n related to leople us
[,, 9 (,
site addressed in Q1 repor HILL said tiat afte started investigating the ut.
- word ca down" that Q1 was not
- l70 business and that this information should be turned over to Security. HILL said the names of the suspected drug users were turned over to Security, and within a day the suspects names were coemonly known throughout Olc.
HILL said that when as told to drop the drug case, responsibility le N for handling drug i ues was rned Lr to Gary FOUTS, KME Construction Manager. The allegation that Shad been investigating involved drug gp use by senior KGAE management esp oyees in the Dic quality program. MILL said that FOUTS' approach to the drug information was to have Security run criminal checks on the alleged drug users. HILL said that if the criminal record checks were negative, then FOUTS dropped the information.
HILL said that SNYDER eventually started limiting the amount of time he allowed investigators to develop information on cases. HILL said it was his opinion that after SMYDER took over and site personnel became aware of the changes in Q1, the nus6er of concerns reported to Q1 dropptd dramatically.
HILL said he did not know of any instances when specific allegations were trashed, but said many of the allegations that were substantiated by Q1 were designated by the Q1 supervisors to have 'no merit.'
9b HILL said that Q1 also investigated the alleged blackballing o at 1
Arizona Public Service (APS) by RUDOLPH. HILL said that the first two drafts
+7) of the Q1 investigative report concluded that blackballing had occurred. HILL said that the Q1 report which was eventually issued said th::t the allegation Case No. 4 86 004 23
/
7e cc 7 h
was unsubstantiated. HILL said that he disagreed with this conclusion, because Q1 was in possession of tape recordings from two APS employees who had personal knowledge that the blackballing had occurred. HILL said that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter Q1 had made the tape recordings of the APS employees' interviews, Glen K0 ESTER, KG&E V-P Nuclear, ordered that the Q1 tape recorders be "picked up."
HILL said that some of the investigators' disagreements with Q1 super-vision had been documented and were contained in the Q1 files. He speculated that the files had probably since been "cleaned up", including the tape recordings.
HILL said that THERO had lef t the Q1 program about a month af ter he (HILL) did because of the loss of independence and freedom to report their c0nclusions accurately. HILL said he believed that SNYDER had received a mandate from K0 ESTER to have all Q1 issues resolved by December 1984 so the allegations would not interfere with fuel load. HILL said that it was his opinion, based l
on SNYDER's construction background and his relationship with K0 ESTER, that l
K0 ESTER had inserted SNYDER into the Q1 program with a mandate to resolve the outstanding issues in the utility's f avor and to cover up any activities which would interfere with the licensing of the plant.
Interview With Owen THERO, Former Q1 Team Leader, WCGS On August 21, 1986, THERO was intervi u d in Lebo, KS (Exhibit 2). THERO said he was originally hired in 1981 to develop a surveillance program at WCGS.
THERO said that in 1984, he was mcde Team Leader of the Q1 Program. THERO said he lef t Q1 and his employment at WCGS in October 1984.
THERO said that during the ASLBP hearings for WCGS, the Nuclear Awareness Network (NAN), a registered intervenor, petitioned to set aside licensing for WCGS. THERO said that when NAN produced former 01C employees with allegations concerning construction deficiencies at WCGS, RUDOLPH, the QA Manager at WCGS, asked him to investigate the NAN witnesses' concerns. THERO said that at the time, he was working as a consultant to RUDOLPH in his surveillance capacity.
THERO said that RUDOLPH wanted the issues evaluated and investigated in a l
timely manner to determine whether it would delay licensing. THERO said he subsequently had a discussion with RUDOLPH regarding the fact that as employees were laid off because construction was winding down, they could expect an increase in aliegations. THERO said he proposed an investigative THER0 said O program to interview eeployees as they were exiting the site.
ed on the creation of a Q1 program. He said that HILL, and he were the original investigators. THER0 said y also,manne an a egation hot-line and handled "walk-in" intersiews.
TNERO said that KGlE formalized the Q1 program by writing a procedure which was subsequently published. THERO said the procedures and the program were endorsed and approved by K0 ESTER, the KG&E V-P Nuclear. THERO said that KG&E made a video tape which explained the activities of the Q1 program to exiting agloyees about to be interviewed. THERO said that the procedure creating Q1 defined the authority and the mechanism for how Q1 would perform its job.
THERO said that when Q1 was set up, it had already been determined that drug investigations would be handled by the in-house security force.
Case No. 4-86-004 24
[3, 7CA 7D k
THERO stated that as the reputation of Q1 spread around the site, the activity and the number of concerns identified to Q1 greatly increased. THERO said that the Q1 investigators worked very hard to build a reputation for credie bility aa.d integrity related to their handling of the employee concerns.
THERO said he believed this reputation led to the employees' willingness to share their concerns with Q1.
THERO said there r,ad been employees who made allegations to Q1 who were 4 advers ected by having talked to the Q1 investigators. THERO said h
d startup engineer wh was a alk-in interview, was the victim of reta ory cts. THERO also said was blackballed from further employment in the nuclear industry as the result of having come to Q1.
THERO caid that part of Q1's mission was to determine the "root cause" of prc olems. THERO said that KG8E management had difficu'ity with the philosophy of Q1 initiating other investigations based on information developed during an investigation. He said he believed KG&E management was looking for "quick resoluticC to 17blems, so that they could get the plant licensed.
THERO taid that soietime about September 1984, Q1 was reorganized creating an inve.igation group and an interview group. THERO said that he was replaced as the head of Q1 by SNYDER. THERO said he was made supervisor over the interview group and SCOTT was assigned as supervisor oser the investigators.
THERO said the explanation he was given for his removal was that "they wanted to cet a permanent KG',I employee to head the program." THERO said he person-ally r liesed he was removed because he was aggressively pursuing the e
inu 5tyations and this was perceived as a problem by KG&E management.
THERO taid that SNYDER's background was as a constructis a superintendent at i
L* CGS, and $NYDER had successfully represented KG&E's position in the prudency hearings. THERO indicated that he believed there was a conflict of intere' with SNYMR taking over Q1, becausa SNYDER was the subjut of sone of the allegations being investigated by Q1.
THERO said one allegation involved the use of dissolvable tape called Dissolvo tape which had been used in small bore piping in the early construction at the plant. THERO said that Dissolvo tape was intaJed to be used as a purge dam for argon gas to keep the gas concentrated to make better welds in pipes.
THERO sc'd it was later determined that the tape contained high chloride concentrations which were detrimental to stainless steel when subjected to stress and heat and could result in stress corrosion cracks in the sipe.
THERO said that whn PDER hsd been a manager in construction, he sad been responsible for p6..eanlind s to prevent foreign matter from being flushed into the heat er.q rs. TPW.Md that Q1 was investigating an allegatin i
that an exten<';
m:nt of b m % tape had been left in the pipes. THERv said that sir +.
ai d *,/ Q1, Q1 was, in essence, investigating allegations v.r
-'M*-
'dd that the issue regarding Dissolvo tape
-a
. left the Q1 program at WCGS. THERO said had not been r i c;
- +. u. '4 l
he felt it wa;. it r-m.
ad started hot functional testing prior to the resolution c a 3;d n se issue.
j THEi! u Nt during flui; q, the startup personnel observed excessive h ssolvo tape flushed on of the pipes in the form of a black amov <
l s u b v..+
4.
Critical and non-critical pipes were flushed at the same time, and k 7 6,V/[]
Case No. 4-86-004 25
it was impossible to tell which lines contained the tape residue. THER0 said that although he disagreed with the decision to proceed with the hot functional testing, he believed SNYDER had received instructions to close the issue so that it did not interfere with licensing.
THERO said that when SNYDER became the Mancger of Q1 he ma 6 dramatic changes in the program. THERO said SNYDER orJered that problems identified by Q1 were to be turned over to the QA orgar ization for resolutioa. THERO said that as licensing neared, cost and scheduling began to impact on the Q. activities.
The QA organization received greater responsibility for insestigtting Q1 allegations. THERO said "Once the senedule as tspect entered into it and put these pressures on us,pect and thr money (WI became then the program less and loss effective."
THERO said another concern investigated by Q1 involved ex.
ternal pipe cleanliness. THER0 said there were g c orld concentrations on the exterior of stainless steel pipe. THERO said the Q1 investigation demonstrated that to resolve the issue, swipe tests were performed on a sampling of pipe. THERO said, however, that prior to the swipe tests, only those pipes which were to be used in the sample were citaned. THER0 said this type of corrective activity was a result of trying to quickly close allega-tions. THERO said the problem of intergranular stress corrosion cracking had been identified in boiling water reactors (BWRs) snd that manufacturers like Westinghouse and GE had written process specifications to control the amount of chlorides. THER0 said Q1 recownended a 10 CFR 50.55(e) report on this issue. THER0 said the NRC became involved and eventually issued a stop-ark order. THERO satJ he believed KG4E ' engineered" the external cleanliness problem away, because there was no easy corrective action for piping covered by insulation.
INVESTIGATOR'S NOTE: N In Caphton who assisted 01 in this investigation, reviewed The following is a surmary of the NkC inspector's evaluat Case Review Concern opened: 7 19-84 Concern closed: 7-27-84 During his 91 investteation, MILL discovered an Instance when _a Technical u. imU cleaner waii aues to clean only a selected portion of pipe lnc rietals instead a the entire pipe. The cleaned portion of the pipe was used in the
'samphipe test. The Q1 investigator reported that swipe tests had been perforined on the reactor coolant syster hot and cold legs and that three of four sw1pt tests had falltd the.0015 mg/M criteria. HILL reported that additional swipe tests were taken under insulation, and four of eight f ailed.
The nuclear plant engineer (MPE) subsequently detersined that the.0015 criteria did not apply af ter insulation was instal fed. The RPE repor;ed that amounts of chloride less than.003 mg/W wr e not detrimental, i
HILL reported his investigative findings on a Quality deviation report. Tia
@ pl investigative file also contained a Q1 investigative report written by y
another QI investigator, which referenced a non-conformance report (NCR) written on this condition. As a result of the NCR, personnel
[0'ivorking for TMI were retrained regarding swipe tests and new procedures were l
issued regarding sampling processes to sh.ure that external pipe cleanliness l
h[
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standards were maintained. The file also contained a Westinghouse concurrence in the procedural changes.
THER0 said that when Q1 was reorgarued, SNYDER took over as team leader reporting 'o K0 ESTER with GRANT signing the group's time cards. THER0 k -
cated that RUDOLPH's actions related to or arch and the removal of documents from an exiting employee's truc may have contributed to sion to have Q1 report to K0 ESTER or THER0 said that while a QC inspector, was in the QC trailer making allegations, RUDOLPH ordered Security to sea h hi ruck for documents. THERO said RUDOLPH called him to his office after eft, and said RUDOLPH 1aughingly told him it was going to be hard fo to prove anything, because Ser;urity had found some documents and destroye em. THERO said RUDOLPH tol him he h d reviewed 4y 4y p the documents before Security destroyed them. THER0 said investi-gated RUDOLPH's actions and issued a report.
THERO sai subsequently made another allegation that RUDOLPH had or a ob at APS. THD0 said thet whtn Q1 investigated this 41(,.,
"blac kba l }
all on, Q1 concluded that RUDOLPH's action had resulted in d
not ng t b.
THERO said SNYDER changed the report to reflect t))
' t at there was no evidence RUDOLPH influenced APS' decision. THERO said SNYDER explained that he did not believe there was sufficient evidence to conclude against RUDOLPH.
INVESTIGATOR'S NOTE:
when interviewed 'vy 01, said he had substantiated blackba ng; owever, the case file review as part of this investigatio e file contained a Q1 investigative report initialed by oncluding the allegation was unsubstantiated.
[,, M SNYDER, when nterviewe by 01, said he was the one who drew the con.
clusion that the allegatio was unsubst ntiated based on his review of the documents contained i e file. SNYDER indicated he had not discussed the c6se wi j
N45-2.5rehna Q1 investigator, investigated alle
~
structural steel welding did not meet ANSI ir because many of the in:pection records had been lost.
THERO sai eport conclude that welding program did not meet gp code or QA equ r s.
THERO said ved with GRANT and RUDOLPH about his conclusions and, as a resu was removed from Q1. THER0 said GRANT and RUDEPH told him that removed, because of his ecottonal de r lated to this i ve.
ERO said that neither RUDOLPH nor GRANT said sition was techhically incorrect.
THERO said that shortly before he was removed as tesa leader of Q1, GRANT hired SCOTT as a Q1 investigator. THERO said he soon realized SCOTT was not what he seemed to be because he did not investigate what he (THER0) assigned him to investigate. THERO said he heard rumors that SCOTT had been hired to replace him. THERO said he confronted GRANT about SCOTT's position, and said GRANT literally pulled out a Bible and swore that SCOTT was not hired to replace him. THERO said that a short time later he was ceiled to a meeting by K0 ESTER and was informed that SNYDER was replacing him as team leader of Q1.
1riERO said SNYDER tenediately called a meeting with the Q1 staff and issued an ultimatum that work would be performed his way or the investigators should seek other employment.
I h
- g7g9gp, Case No. 4-86-004 27
i l
THERO said he recalled tha a Q1 investigator, subsequently complained to him about SNYDER changin c cl ions in his report. THERO said he asked DENISE of the NRC to t k but said he did not attend their discus-sion. THERO said that other Q1 investigator, told him he had "knock-down, drag-out' sessions ith Q1 supervision over investigative conclusions.
THERO said Q1 investigated an allegation on the traceat,llity of valve parts t
which were disasserbled by the operations maintenance department. THERO said he had heard that, to resolve the issue, valves known to be satisfactory were preselected for sampling to demonstrate there was no problem with traceability.
THERO said Q1 regularly tape recorded interviews with allegers, but said K0 ESTER ordered that the recorders and tapes be removed er g g alleced exual harassment against a senior KG&E manager r's THERO said he thought KG8E Legal in Wichita a sumed respons1D1 y
4 sexual harassment investigation. THERO said he did not know what or K0 ESTER did with the tapes.
INVEST! GATOR'S NOTE: During this investigation, tapes were observed in i
the Q1 files. SNYDER said he did not know of any tapes other than those in the case files.
THERO said drug allegations received by Q1 were referred to Security or FOUTS, but said he had no indications that the allegations were ever investigated.
THERO said Q1 was created to encourage employees to take their concerns to the licensee rather than the NRC or intervenor groups. THERO said Q1 was not created to cover up issues. THERO said he would never have been associated with Q1 if he "even had the foggiest notion that it wasn't an up-front, legit-inate program." THERO said, however, that KG&E management changed Q1 by managing the conclusions of the investigations. THEROsaidit(Q1)'becamea bigger problem to KG8E than a solution....." THERO explained that as licensing l
neared, KGlE manaaement (GRANT, SNYDER, and K0 ESTER) took the resolution of allegations away from Q1 to expedite the closing of specific concerns. THERO said that it was his belief that between the time he left the Q1 program and i
the time WCGS was licensed, significant issues remained unresolved.
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Case No. 4-86-004 28 7
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,s-O! Case Review of Q1 Investigation
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g, Concern opened:6-6-84 Concern closed: 6-19-84 ontained a document dated October 1986 prepared by
@T(Thecasefil ia investigator. The purpose for this new document was to review t e ro es and respons15'ilities of the eleven individuals who had been named in 1934 as drug users. There is no explanation why this document was created and it contains no conclusions.
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,a U}4 INVESTIGATOR'S NOTE: On April 20, 1987, Mark VINING of the KG&E Legal g9 departmentinWichita,KSwascontactedregafrinnan I request to review the KG&E investigative file on the search ofg truck. VINING said I
that this file was considered a work product o en &E Legal department in preparation for potential litigation. VINING said that this ccmcern was not identified to the Legal department by Q1 no did ha e any involvement in the investigation.
VINING said that performed this investigation in the behalf of the Legal department.
NG said that after reviewing the file, KG&E took the position that it was a privihged document and would not be produced for the NRC's review, Case No. 4-86-004 32
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..M F Concern opened: 8-7-84 Concern closed: 9-12-84 The file cortained an inter-office IDemo dated 9/12/84 from THERO to SNYDER indicating that the allegation tha'
'had been blackb led b RU LPH
- f' for a ob at AP5 w s s stantiated. On Se tember 2 e e-a t (r, a c onica in erv ewe m na er a ao e e w o sa a ma e no a 1ve s a emen s a ou er-viewe a
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app icant or e,ob with more experier ce was ed.
he file contained a t
d tele h c interview by HILL with!
said that he asked out and RUDOLPH res on ~
y as ng f they wanted a recommendation on ir n,
escri ed RUDOLPH's res onse as "Jid he t in t at e was w a e were 00 n or an e sa
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said he had not provided AP5 with any information one way or another. RUDOLPH Said, however, his r*,sponse or lack of response could have been interpreted as l
his not recosynending I
The Q1 case file contained a policy change which read "future inquiries l
regarding employment reconsnendations would be forwarded to KME personnel.'
The Q1 investigative report signed b5 5NYDER concluded a m1$ understanding had taken place, but had no influence oi, not be,ing selected." This conclusion was in direct confli:t withh--
' conclusion that the allegation was substantiated.
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3-28-8< Concern closed: 10 19-84 ve er umen on March 2 198 an a een on resso, a hy V, g (,,
n nater. i n Apr.11 10,1954, the 5tartup Manager was interviewed, D
ar up and said he had told -
that he believedge should take problems to his T
supe rv isort_Ii rst. On July 20, 1984,-
i5 tart-u > superv hor reported th a i---
had been a difficult esp' oyee and & "bitcier", and la b'
take h s concerns to 1 or the C rat r than his su rvision, re re a on u a
een era ha a
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F tar up anager s ac on was re a. a ory a cons ue ayoa on o esiployee proteqtion as_ descrii,cd f GO CFR 210. The' Cl investigative file has subtr.qdntly reinstated ant received backpay. The
[
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. eye Conceia closed: 9-18-84 6-6-84 concern opened @o:r re In this case,q lle ed that he had en sub tad to harassment and (p,q C intimidation r,n sa e concerns.
se e a
fomp ain w1 e ansas uran esources om ss on n une
) ton his case with the presiding officer, who said he had been dis-p) itissed without cause,and that Dlc would have to pay him unemployment. In this instance _-
reported the allegation as substantiated In the final review, th'bre appeafed to have been no followup related to any type of c<orrec-tive action or repercussion for having harassed and intimidateal The whole issue seemed to have been resolved with the labor hearing.'
Durinc
. s review, SNYDER said he had E '1b INVESTIGATOR'S N rec nded that upervisor, be terminated at the a1g time indings we e re ort d, but said no action was taken agains SNYDER said as eventually reinstated in his job.
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01 Case Revt l
- -84 Closed: 10-15-84 0 n g,1(4 nyes 1 a ve an ndicated he was oin to intervie
- owever, ere s no n ca on n e
e( a anyone was n erv e.
The Q1 file contains an interof fice memorandum signed by SNYDER and THERO which refers to a site policy memorantium which encourages employees to take d9 there concerns to their supervisors first, but says they may go the the NRC.
The Q1 file lists the allegation as unsubstantiated; however, there is no documentary evidence to indicate that vi investigation was conducted.
N g g g cg 7 p Case No. 4-86-004 35
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Q1 Closure: P0 7158-$R-5900 was written to procure 316 $$ (ASTM A-276) fittings from the manufacturer, Crawford Fitting Company, through a supplier Tawflalve and Fitting Company during the period 1980 to 1954. Furchase requisition dated 9/8/50 stated that a "Certificate of Cosipliance shall state that all material meets the material specification as stated herein and all requirements of P.O. are met. The certificate shall be accompanied by a certified Etch Test Report." An ETR per ASTN A-262 dated 7/14/80 for heat number 78044 was sent to DIC along with the Certificate of Compliance (C0C).
j Case No. 4-86-004 36 g
7g
A copy of the same ETR was thereafter sent with each C0C. The u nufacturer and supplier claimed that the ETR was only intended to be a one time typical test to accept the test method and show that the materials which were all manufactured to identical processes passed _the one time test. Per Crawford, it was not their intent to perform a micro etch test with each heat lot manuf actured and shipped.
Q1 identified that DIC had previously investigated and decided, based upon a study of requirements, that the ETR was not required. _jased uporLthis, DIC issued a change order on 4/24/84, one month before the
. allegation, deleting the ETR recuirement. DIC Considered the matteT to De cM sed based upt.n this action.
01, on 6/12/84, closed out the_
__jallegation investigation based upon the DIC action concludin ft. hat tht-toncern was withotet merit.
NRC Inspector's Coments Regarding Q1 Closecut Action: The ETR was a require-ment of the P.O. and ef fective reasonable quality conformnce should have identified the fact that an ETR dated 7/14/50 was questionabla for all subse.
I
(
quent lots shipped to DIC over a four year period. Since the P.O. specified that a certified ETR be sent, a valid up-to-date certified ETR should have been sent, The DlC finding one month prior to the hotline call that the ETR was not t
required appears to be valid. The ETR dated 7/14/80 for heat number" TdD44 appeared to be a valid report acknowledged by the unuf acturer. Although the I
same report was repeatedly used, there was no evidence that the report was falsified. The mnuf acturer's position was that one ETR f ulfilled fiis requirements and apparently was not told otherwise for four years. DIC apparently never questioned whether the report met requirements untti the time of the work surro.nding the April 1984 change order MO. 7158-5R-59000-14 deleted the certified ETR from the purchase order.
The Q1 investigation closure statement of 6/12/84 stating that the concern was without merit appears to be of f target considering that for approximafe'ly four years the certified ETR dated 7/14/B0 was sent with subsequent orders while f
the P.O. requirement appeared not to have been fulfilled with up-to-date certified ETRs. The Q1 closure should have shown that the allegation had been partially substantiated, however, at the time was without merit. The Q1 Investigattom did act address the receipt / vendor Inspection and quality control (QC)/ assurance failure to identify that the certified LIK dated 7/14/80 for heat nurr.ber 78044 was being used for all subsequent shipments to DIC at WCG5.
Concern opened: 8-9 84 Concern closed: 9-20-84 An electrical QC inspector u de an allegation to Q1 that an electrical QC supervisor had set,a sup5 ort / peek quota for QC inspectors which adverselytelep 4
affected quality.!
another nuclear site. T1e former QC supervisor described the number of 4W inspections that he prescribed as goals and not quotas, and said that no ions,,were given to sacrifice quality. Based on the case file review, tele hone call to the former Cs rvisor ears to be the on1 nvestigativ, e ort u e in t is case, n
inves a ve g fKy.W)g Case No. 4-86-004 37
~__.. - _ _ _ -.- -.. ~ - -. _ _.
he said he intended to interview other QC inspectors, but there is no evidence to suggest that he did. The alleger's allegations about the quotas related to retro raceway support welds allegedly not in accordance w)th AW5. The alleger indicated that many welds were undersized. The file revealed that a year earlier the MRC had identified defittencies in the fillet welds on the elec.
trical raceway supports as documented in inspection report (50.482-53-10).
In this instance, the Q1 investigator apparently concluded the allegation was unsubstantiated solely based on the accused supervisors dental in spite of knowledge that there had been extensive problems with these welds. Further.
more, there seems to have been no attempt to determine whether other QC inspecto-s had been adversely affected by the superviscrs expectations, nor were any attempts made to determine whether suprvisory levels above the QC i
I supervisor may have been responsible for the origination of the alleged quotas.
01 Case Review of Concern ened:
8' 9-24-84 le th. (
h an umen ontro erv sc.
se uen nyes i-
$g ators crim na e aga ns m or pursuing qua y co erns.
n this i
l Said he re orted that he interviewed a3
/\\
nvest a on w o sai ea e er was ec nica com e en u was o oo ea ing wi peop e an, t ere ore, no a capa e ea,
ea eger eventually filed a complaint with the DOL on September 21, 1954 The Q1 file I
does not refltet the outcome of this case.
i INVEST! GATOR'S NOTE: During this case review, SNYDER was asked to determine the outcome of this cas n April 29, 1987, SNYDER ssid a l
DIC representative reported tha had eventually been reinstated by 01C and had consequently dropped his X case.
l Concern opened: 9-19 84 Concern closed: 9-19-84 urin this invest i
three Civil ins tors and e
arasse J r super-i X
visors.
15 nyes ga ton, rformed ersonnel file 1
h reviews epcimentine reprimands, leave p
. appra 5,
payro records. -
Investigative report has one sentence WR1cm referencet /4 g
other personnel contacted who did hot feel any one person was treated The individuals actually contacted during this l
differently than the rest.
investigation appeared to have been restricted to those supervisors accused of i
the harassment and inti. nidation. The notes of the interview with the alleger f
l are not detailed, and there it no description of the nature of the harassment j
twas the interviewer as well as the investigator l
and intimidation, in this case, and _The nvestigative file does contain the basis for drawing
\\} the conclusion that the allegation as unsubstantieted, d
Case No. 4 86 004 38
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Concern opened: 4-17-84 Concern closed: 10-30-84 This investigation focused on l' concrete expansion anchor bolts that did not have suf ficient tensile strength rating to meet the requirements. The file showed that on February ll,1982, SNYDER had written a letter for FOUT5' signature to F. L. WARRICK, the DIC Project Manager. The letter author 1 red the use of Ramset l' Trubolt. ShYDER was present during the 01 review of this case and explained that the Essis f or the letter was a verbal evaluation perfor1ned by Bechtel explaining why the bolts were satisf actory. SMYDER said I
that Bechtel had given a verbal 0.K. which was to later be followed by a I
written response. The case file showed that on February 17, 1982, SNYDER wrote a second a letter for FOUT5 which rescinded the use of the anchor bolts.
5NYDER explained thst Bechtel's written response on the issue was different from the verbal explanation they had received, so the authorization to use the bolts was rescinded. The file explained that the concrete expansion anchors were required to have a minimem of 100ksi (pounds per inch) ultimate tensile strength. The bolts authorized by FOUT5' letter had a tensile strength of 75ksi.
An RCR was subsequently written and dispositioned by revising the tensile strength specifications. The file also noted that Ramset fastening Systems Nde a 10 CFR, Part 21 notification to the MRC regarding the tensile strength issue. The QI investigator's file indicated that there was no evidence that any bolts were installed between FOUT5' first letter s*d the letter rescinding the authorization. This allegation was Feported at, unsub-l stantiated by Ql.
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.,...,7, j..,j V TIGATOR' NOTE: NRC Inspector Chris YanDenburgh reviewed Q1 case The following is a sunnary of VanDenburgh's evaluation.
R_eview of 1
===1.
Background===
(Items 1 through 25) identifies 25 separate concerns which were recehied from two allegers. The first concern (Item 1) indicated that the original deficient condition and intent of forty-one CARS had been lost because the CARS had been revised to suit political conditions.
In addition, the CARS were considered to be ineffective and positive corrective act10n was nonexistent.
The file was opened on June 6, 1984; the concern was closed on h
October 10,1984;. and the ile was closed on February 4, 1985. The investi ator f recer was The ori inal investi ative report
, g ij was per orme
- owever, s repor was no accep e 3d 9
Program manage nt.
11.
Safety Significance The allegation, if substantiated, is saf ety significant. A CAR is initiated in response to deviations and nonconformances identified i' the construction of safety-related systems.
If the original intent of the CARS had been changed and effective corrective actions had not been implemented because of extensive revisions, then the reliability of the safety-related systems may have been adversely affected.
-/
l
!!!. NRC Inspector YanDenburgh's Review A.
Work Plan scope ive changes to Clas, excessive number of NCRs, poor management control, inadequate audit programs and no corrective programs. The inspector j
reviewed the transcripts of three subsequent interviews with the anonymous alleger which were recorded and transcribed. The content of
{
these transcripts indicates that in many instances, the 411eger was prompted using information that was developed from some other source.
i The file also contains handwritten notes from another interview. These notes indicate that forty one CARS had been issued and that they are "garbage" and that 17,000 MCRs had been perforined which indicate a trend of poor work. The interview transcripts and notes do not substantiate nor provide,a source for the specific allegation that forty.one CARS had i
been revised based on political conditions and that the original j
condition and intent of the deficiency had been lost.
l Regardless of the source of the allegation, a work scope plan was deve.
loped to describe the recoernended actions to investigate this concern.
These actions included the determination of the number of revisions indicated for each CAR, performance of a detailed analysis of two CARS which had been specifically mentioned in the testimony (CAR-Z5 and CAR-33), investigation of the generic reasons for the CAR revisions and i
interviews or various KG5E QA system personnel and DIC QA enetreering personnel. This work plan appears to be appropriate to resolve the stated concern.
B.
Review of the investigative Report The first assigned investigator wa His proposed investigation report was not accepted by Q1 Progr#m esmagement. He described the concern as previously stated and indicated in the susmary of his investi-gation that a randos selection of CARS with revisions were reviewed and l
evaluated, partial documentation related to the above CARS were revleEd i
and evaluated, and various per$0anel were Interviewed. TRIS 18 $1811er.
but not the same required wort actions as specified in the work scope documen t.
This investigation identified the following problems with the i
CAR program:
1.
CARS had been opened for greater than two years without being satisfactorily Investigated on a monthly basis as required by procedure.
)
l 2.
CAA revisions were made without adequate procedures governing the performance of revisions.
3.
Dates of completion of corrective actions were changed by revisions without explanation.
I 1
I
1 4.
Numerous discrepancies were identified in a list which was developed to determine the scope of the corrective actions required for all the outstanding CARS.
5.
Commitments made as part of the CARS were not being accom-plished.
6.
Potentially reportable incidents based on 10 CFR 70.55(e) and 10 CFR Part 21 requirements were not being evaluated. InstrJc-tions or procedures to delineate the 50.55(e) reviewing requirements were not documented by procedures and the respon-sible individuals were not identified.
7.
Completion dates of corrective actions were not issued and f urther commitments on the parties involved were not estimated.
8.
Conditions that met the requirements of Nonconformance Reports had been dispositioned within the CAR without documenting on an NCR form.
9.
Sore of the aforementioned conditions were previously detected by the QA surveillance and audit group. However, positive and appropriate corrective actions such as a stop work order was never implemented.
/
Based on these findings,
--' concluded that there was a breakdown in the
/)[)
CAR program. The investigative report made specific recomrendations in the form of Q1 Action Requests for evaluations and corrections to the CAR program.
.. su)ervisor did not accept the conclusior.s of the investigative
' report, )ecause the report did not address the original allegation that forty-one CARS had been revised to suit political conditions and that the
/)])
original intent of the CARS had been lost.
berforwed an investi-gation which went beyond the scope of the oK191#tl investigation and concluded that the progranmatic QA requirements for the CAR program were ineffective. Although this conclusion ray be valida evaluation and conclusion did not substantiate the originally state 5 contern. Q1 program management rejecte-71nvestigative conclusions and termi-nated his services because he was not responsive to the programmatic requirements of the Q1 Program.
Subse uent to te ination new investigation to address the g[}C concern was as This investi ation consisted of a h
review o sw'c a,
een ssue w rev s ons; s
,4 ~77 without revisions were not reviewed.
== investigation report identified the outstanding CARS and in3tcated w 0ch CARS were revised, identified the reason for the revisions, and then concluded whether there was an apparent degradation to the original _ deficient condition as a result of these revisions. The investigation indicated that the original concern was substantiated because revisions to CAR-31 prevented positive corrective action for this CAR from being effective. No corrective action was re ested because a more detailed inv i ation was underway I
re ve ro am ase w c was considered 1
Case No. 4-86-004 45 IIko 7
,7,.,,7 6 r.
to be similar in nature and whose corrective actions wert considered to encompass the antici,)ated corrective actions for CAR 31. _
lltem 4,
identified a programatic breakdown in relation to safity-re sted structural steel welding.
C.
NRC Inspector's Conclusions The NRC Inspector concluded that this specific quality concernT Item 1, as stated, does not appear to have a basis in the orig nal allegation transcripts or n(.tes taken from the allegers. The alleger was prompted in the interview with informtion which was developed by the Q1 interviewer f rom a source other than the alleger. Regardless of the source of the concern, the work scope plan developed was an appropriate method to substantiate or refute the concern.
N Althougt investigation report substantiated the originally stated Q%
concern, The NRG Inspector's review indicates that the Concern was not sub-stantiated. Of forty-five CARS reviewed, only one CAR (CAR 31) was identified 4N in which extensive revisions had degraded the intent of the original def t-ciency. Corrective actions for this discrepancy were not required because a new CAR (CAR-19) haf already been issued for which corrective actions were considered to encompass the corrective actions of the original deficiency Identified in CAR-31. The NRC Inspector's review of CAR-19 indicated that this conclusion was correct.
The NRC Inspector's review also indicates tha investigation and the associated orreative action to the substan'tiated condern { CAR-19) do 4%
resolve an of findin s.
He st ed that t concerns identified b were no een a e us,e a resse nyes a ve re or or e sew ere w n
e rogram.
e
.nspec or conc u e a
n s
Instance, the Q1 Progr,am was inef f ective because identified safety-related concerns, i.e.
koncerns, were never satisf actorily resolved by the Q1 Program nor any otner K65E organization.
IV. Sunna ry in suenary, neither the notes of the original allegation nor the transcripts of subs g
with the all s
vlee a Msis for the as stated concern o g
erv rs orm n
'a ne sources o er an ea egers, ever est, the as stated concern may be valid and if substantiated, safety significant. The original investigation went beyond the scope of the original work plan and cas.J to conclusions which did not substantiate the original concern, but did identify new concerns which could have a safety significance. The original investigator was terminated because he did not follow the programmatic requirements of the Q1 Program; however, no attempt was made to address the concerns identified by his report. A new investigation was performed following the prograrunatic requirements of the Q1 Program which subsfantiated the alltgation; however, the hRC Inspector's review indicated that although l'
the new investigation did identify a problem with one CAR, the new investigation did not substantiate the original concern.
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01 Revlew of cern closed:
11-15-84 Concern o ened:
l nyes na o as a s a constituted a su lenental b
TnTesI su stan ae ea ea on and
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ontaine w ic escr e a
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i samp ing program inc e
va ves, o w a prev ous y been 4
disassembled as described in the allegation. Two valves were determined to have material discrepancies which were identified on startup field reports (5FR) 1-EM-45 and 1-BG-142 related to valves BG-8481A and EM-V8922A,
- C97h, Case No. 4-86-004 51
t
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respectively. The sample reported that grade 2H nuts were installed on these N
va h es rather than grade 66 nuts. However, the sample reported that the two i
discrepancies were listed for valves that had not been disassembled.
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Case No. 4-86-004 61
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Concern opened: 6-6 84 Concern closed: 11-9-84 It hao been alleged that piping preheat and weld records had been falsified and "bought off" af ter the fact by inspectors who never lef t their desks. The al investigative report indicated that 19 randomly selected QC inspectors had responded that they had no information on this subject and the investigation was determined to have no merit. These 19 inspectors purportedly discussed six general topics all of which were unrelated to this allegation. The testimony of the 19 inspectors was not recorded, however, a review of the case files indicated these undocumented discussions were used to close a number of Q1 cases as unsubstantiated. The files contained a list of the 6 general topics. This methodoloqy for closing cases is not considered valid.
p 4
Concern opened: 6-6-84 Concern closed:
11-9-84 l
It was alle ed that electrical and civil rk was s ned ees wo 1 not eave s.
5 case se same I
ra y se as a or concluding that this allegation was not substantiated. The case Teport indicated there was also a document review, but the documents reviewed were not specified. The absence of any documentation on the results of interviews or document reviews offers no evidence that any meaningful investigative effort was put forth in this case.
Concern opened: 8-9 84 Concern closed: 11-12-84 It had been alleged that QC inspectors were not, allowed to write NCRs unless l
engineering pre -approved or requested the NCR.
_ investigative report concluded that DIC procedures authorized quality personnel to ort inste ucRs, i
and res said RCR control numbers were ined free
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p y prov sng roun ormatton for the log entry.
l concluded that the PJTE may question the validity of potential NCRs prior tor issuing the cqntrol number, and conclu_ded that the allegation was without i
merit.
seemed to focus on the iright to question the validity of an NCR as sufficient to determine this a e'Qation was unsubstantiated.
Tdilitionally the case file contained the same undocumented general ciiscussions with 19 randomly selected QC inspectors. Again, none of the 6 topics dis-cussed with the QC inspectors related to the allegation under investigation.
01 Case Review of Q1 Investigation Concern opened: 8-9-84 Concern closed: 11-12-84 gy 47b [$
Case No. 4-86-004 62 L
lt was alleged that electrical support checklists were held in a suspense TTle, and that sometimes "unsat" on the checklists were reinspected by dif f erent inspecjors and "deemed sat" without any intervening rework having g
been perf omed. '
quotedaDICprocedurefortheinstallationofelec-(p trical raceway supports'which said "checklists with documented discrepancies shall be htld until discrepancies have been corrected and documented to clear $19 the unacceptable condition. When discrepancies have been corrected and accepted, clear the discrepaacles by either changing the unacceptable entry to acceptatle, with_ an ernlanation in the remarks section, or by generating an naw chec klist. " tr concluded that the proccdure authorized one or more Eecklists and changini unacceptable to acceptable, and Concluded the alle-sation was without merit. One of the 6 topics discussed with the 19 randomly selected QC inspectors was "When final checklists are 'unsat', they are changed to in-process inspections where they do not have to be addressed formally, just handed back tc craf t to fix."
The inclusion of this topics list does not take the place of an investigation into the alligation that deficiencies may have been "shopped around" for a QC inspector who would accept the deficient condition.
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~v Concern opened: 3-21-M Concern close : 7-24-84 h
The I file did not contain e'vidence o investi attye of r th s bl case.
e case con a ns a urve anc e r s ne who h
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Concern opened:
5-9-84 Concern closed:
10-30-84 Q1 received an allegation that special scope valves disassembled by maintenance personne) during hydroflushing were being reinstalled without the required paperwork.
substantiated this allegation and wrote which reewfnendej that the A5ME code valves, if disassefr&ied, should g
5e tagged and logged. It was deter 1nined that only a small percentaqe of the y
special scope valves were covered by ADM 14 405, a,n administrative _p ocetu r e which required a construction work permit (CWP) and QA involvement.
concluded that startup QC personnel had not been involved, and repor.ed ': hat
,this_ constituted a violation of REG Guide 1.143_ and the F5AR cocynitments.
recommended corrective action in thelQFARlwas: (1) to determine the
' extent of work without QC inspection, (2) 3etermine remedial actions necessary
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to accomplish the inspection, and (3) cetermine what was necessary to prevent reoccurrence.
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, :- :.y k %M[M, M.MM M...N Case Review of O! Investigation 4-84-026 An 01 investigation was conducted to determine whether two DIC QC inspectors h re harassed and intimidated by their QC supervisors and to determine whether
{ inspection drawings had been f alsified by the DIC QC supervisors. 01 received testimony from witnesses and admissions from the QC supervisors which resulted in an 01 conclusion that two QC supervisors had harassed and intimi-dated the two QC inspectors. The OI investigation concluded that the same two QC supervisors admitted they had color coded drawings to reflect that the areas had been QC inspected and accepted when, in fact, they had not. During the OI investigation, it was determined that the Q1 investigation into these same allegations were unsubstantiated. The file review indicated that HILL, S e Q1 investigator who initially investigatad this concern, reported that J
harassment and intimidation as well as falsification had occurred. The QI report of investigation, however, ultimately repotted that the allegations were unsubstantiated.
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01 Case Review of Q1 Investi ation Concern opened: 7-2-84 Concern closed: 11-2b4 This allegation related to a reactor building inspector buying of f item without actually conducting the inspections. The alleger identified a
' corroborating witness. The report file showed that eleven negative responses were received from interviewees about the allegation. The Q1 investigator reviewe6 NCRs on LAe polar crane and also inspection reports. The inspector accused of having bought off on inspectiont without having conducted the inspections denied the allegation. The Q1 investigator concluded T1st the allegation was unsabstantiated. In this instance, the investigative effort appears to have been comprehensive and all logical leads appear to have been pursued, although there is not a Comprehensive write-up about who was inter-viewed and what was saTJ. There was no evidence of any action reports having been written on this issue, g.
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INVESTluT03'5 NOTE: NRC Inspector Chris unDenburgh reviewed Q1 case j
MM The following is a suesnary of the RRC inspector's ya vat o*r
===1.
Background===
(!tems 1 through 21) identifies twenty-one concerns which were aceTHd free one alleger. An interview with the alleger identified specific prob'iens concerning the testing of the standby diesel generator systee and generic conceras as they related to the adequccy of the preoperational test program. Of these twenty-one concerns, thirteen vers found to be substantiated.
i The file was opened on March 3,1984; the ccncern was closed on October 19, 198'; and the file was closed on January 21, 1985.
!!. Saf ety $1gnificance Case No. 4-86-004 71 1p,pninw l
u
~
i 4
r A review of each individual concern indicates that the concerns which t
{
were substantiates were potenttally safety stentricant ene that tne unsubstartfated concerns were not safety sign 171 cant. The substantiated concerns are potenttaily safety signiricant In that tney aseress spectrie 2
weaknesses with the testing of the standby 61esel generator system wnten coule arrect the operability of this safety system as weil as the adequacy or tne overa n preoperational test program. In spectric, the s
i sR stantiates concerns coalt witn the rollowtse tuplesj 1.
The adequacy of accepted calibrations was questionable. This is potentially safety signiricant. In that tr tne calibration or i
instruments uses to recore safety relates cata 1s not maintained.
l l
then acceptance cata taken witn tnose instruments cannot be reited i
upon to demonstrate the design balls of the safety System.
l i
2.
Water was being used as a testing media in moisture sensitive areas.
l The introduction of water as a calibration mesta in systems whfen i
require dry air or oil could adversely affect the operation of the safety-related system.
3.
Calibration records did not adequately reflect as-found conditions.
l The documentation of the as-round consttions on ca11bration records is necessary to determine the acceptab111ty of cate which was j
prevfously obtained with the instrument. The vartance o N l
l as-found data is used to re-evaluate the previous data taken with the instrument and determine 17 the previous test results would be j
i invalidated. Without as found calfbration cata. all previous test results recorded with the instrument found out of calibration would
)
be unsatisfactory and the testing wou1C be reeutres to be re-
}
performed.
l j
4 Rejection of calibrated instruments was not documented. As i
discussed in 3ection II.3.1r calibrated Instruments are not j
i documented as being rejected, a re-evaluation of previous data taken with the Instrument cannot be perforted.
i 5.
Calibration records for instruments used in preoperational tests
)
were not reviewed by Instrumentation and Control technicians prior to signing the preoperational prereeufsftes as reeutred by l
procedure. Tnts review is performee to ensure tnat the instruments l
are in ca11Sratton and to ensure not171 cation 17 the instruments are I
subseewntly Toond out or calfbretton. If this review Ts not
,t
]
performed thon the ca11bratton process becomes questionable and the sata tateg w.tn the instruments may be Invalteates.
j 6.
Start up Docweent Control did not revise the Drawing Inden as j
changes became available. Tne Ineen is uses to vertry that the most recently approved electrical schemattes and mecnanical drawings are uses for presperational testing. If the Ineen it not matntained then the resu_1ts of the preoperational test may be Inve116ated.
I 7.
The Architect Engineer (techtel) had lost control of the design i
change process in relation to the standby 61tsel generators. As i
sfscussed in section II.6. IT approved changes are not incorporated Case No. 4 M 004 72 h
,,_,-.,-__.,-------,,---r-
l it.to the preoperational testing, the preoperational test results may be invalidated.
8.
The preoperational test for the standby diesel generators did not demonstrate all of the design requirements as specified in the Final Safety Analysis Report (F5AR). System design, as specified in F5AR, is required to be demonstrated b) preoperational testing in order to demonstrate the operability of the safety-related systems.
9.
The calibration of resistance temperature detectors (RTO) instrument i
loops did not account for loop resistance in the calibration.
Corpensetton for loop resistance is required in the calibration of the instrument loop to ensure accurate measurement of process values.
- 10. The calibration status of permanently installed primary plant instruments were not indicated on the instrument. Without the indication of this status, it becomes difficult and Ny be impossible to determine if the instrument is in calibration.
Safety related data obtained with this instrument my be subsequently invalidated.
11.
Instruments are being calibrated individually instead of in a loop resulting in subsequent problems when the loop is operated. As discussed in Section II.9, this relates to the calibration accuracy of the instrument.
- 12. The Startup Manager downgraded NCRs and changed routing free NPE to Bachtel. McRs are required to be disposstioned in accordance with the QA Program. Deviations from this program may have adverse aff ec's on the quality of safety related systems.
- 13. A rag was found in the Day Tank of the Standby Diesel Generator.
The cleanliness of equipment is required to be maintained to ensure the satisf actory operation of safety-related systems.
In general, each of these concerns identified a specific or generic problem identified with the testing of the standby diesel generator sy s tem. To a large extent, these problems concern the instrument cali-bration program and its uses as It relates to the preoperational test program.
Ill. NRC Inspector's Review A.
Work Plae $ cope The NRC review of th file indicated the the concern was based on the notes taken freurine alTrger. These consist of two pages of specific corvents as submitted by the individual. These notes were reviewed and compared to the description of the concerns. The concerns as surrertzed are appropriate survutions of the original allegations.
B.
Q1 Investigative Report Case No. 4 86-004 73 1
The next portiori of the NRC inspection involved a review of each of the individual concerns and the corrective actions taken to address each concern.
1.
The first concern involviro the adequacy of the accepted calibrations was investigated and substantiated. The Investigation identified two problems with the administrative procedures as they related to the calibration program.
In addition, the investigation identified that three of thirteen randomly chosen, previously acceptably calibrated instruments, were not in calibration.
Although the investigation concluded that the calibration program was not adequate, no corrective actions were identified by the investigator to follow up on this observation. With respect to the two problems identified with the administrctive procedures, adequate corrective actions were initiated to correct these discrepancies.
2.
The second concern dealing with the use of water as a testing medium in moisture sensitive areas was investigated and substantiated. The investigation identified that water was introduced into moisture sensitive areas based upon the observation that a water gauge was j
used as the testing means on a instrument calibration sheet. The corrective action identified that the water gauge was used and that a medium other than water should have been used for the instrument Calibration.
The investigative conclusion was actually in error. A test gauge calibrated in inches of water indicated that the test gauge itself was calibrated with water as the test media and not that water was actually introduced into the system. However, the use of a test gauge calibrated in inches of water was actually incorrect for this specific application, because the instrument to be calibrated was
~
required to indicate in inches of lube oil.
The response to the corrective action identified that water was not used as the testing media and that, in fact, air was used as the testing medium.
In addition, the response determined that the use I
of air was actually incorrect. Corrective actions were taken to ensure that all the gauges were re-calibrated to compensate for the differences of specific gravities between the various tesving mediums.
In sunnary, althcugh the allegation that water was introduced into mbisture sensitive areas was substantiated and the response to the corrective action was adequate to correct the errors in calibration, the investigation did not substantiate the allegation and did not appropriately addresi' corrective actions to the observed condition because the original conclusion was in, error.
3.
The third, fourth and fifth areas of concern dealt with calibration records not adequately reflecting as-found conditions, documentation of instrument calibration rejections and the review of calibration records for preoperational verifications. The investigation sub.
stantiated these concerns and identified appropriate corrective actions.
Case No. 4-86 004 74 i
i t
The first response to the corrective action reevest was not respon-i sive and was rejected by the Q1 program. The second response Indicated that the subject of the corrective action had been pre-v1ously identified by a prevfous QA audit and conclu6ed that the 5 tart up Program was not required to document as-found callbration data.
This response was incorrect, because the QA audit finding was identified Suring construction and the Q1 Program concern was
[
]
identified during preoperational and startup testing which was j
required to be performed to different, more restrfctive, criteria.
Nevertheless, the response indicated that a supplemental program would be implemented which wovic icentify all instruments from which safety-related acceptance criteria sata would be obtained. Further-more, all future testing wovie be annotated to Indicate this Intnrm-atton, so that following the use of these instruments, post-test l
calibrations could be performed to ensure accurate cata was obtained. In addition, a re-evaluation of all previous l
preoperational testing would be performed in a similar manner to validate the data obtained from these instruments. There was objective evidence in the file to indicate that this program was l
properly described and implemented.
l 1
a in sussnary, although the response to the corrective action request l
was not correct, the corrective actions undertaken by this program j
adequately address the original concerns as well as the corrective j
actions requested in the investigator's report, i
)
4 The sixth and seventh areas of concern indicated that Start-up j
Document control was not revising the Drawing Iness as changes 1
ocenrred and that the Architect En9fneer had lost control of the i
desfon change process. These concerns were substantiated by the i
investigation. Corrective actions were not reeutred for the first concern because administrative procedures spec 171cally required that i
the drawings for preoperational testing be ver171ed by another i
source which was >eing adequately maintained for this purpose. The i
administrative requirements for the 5tartup Program did not require
]
the use of the Document control Drawing Index as the source of this t
Information. The response to the corrective action request for the i
second concern was respons1ve and would resolve that corrective l
action. However, the corrective action does not appear to cloteout i
3 j
the Identified concern due to the loss of sesign change control.
5.
The eighth concern identified that preoperational test on the i
standby efesel gererator sie not meet all the Final 5afety Analysis l
lleport (F5AR) requirements. A review 16entiflei two Instances In I
j which the T5AR requirements were not Incorporated 1810 the test procedure. Corrective action requests were 14entif fee to resolve I
these two settetenctes. The responses to both corrective actions l
were adequate to resolve the concerns. In the ffrtt case, the j
response Indicates that the Investigator misunserstood the require-ments and provided an explanation of those reeufrementst the explan-atton was subsequently acceptes.
In the second case, the response indicated inat the F5AR requirements were not facoiporated and that j
subsequent component testing was reeutres to be reperfomed.
f j
Case No. 4.H-004 75 l
1 1
,,_s,.-.--_
6.
The ninth, tenth and eleventh concerns indicated that instrument loops were not being individually calibrated, that the RIDS were not being calibrated in the loop and tnat the calibration status was not appropriately indicated on the instrument as required. The correc-tive action requested was adequate to resolve each of these concerns. The response to the corrective action request indicates that there was a misunderstanding by the investigator on the requirements for loop calibrations. The response delinea[es the calibration method required for the instruments and tha fact that loop calibrations were not specifically required in these instances.
Tfie aext concern IJentified that the operational status of EITTorition indicators did not meet all requireinents. The corrective Action requested an evaluation and wes appropriately resolved by a citange to the adminiskative procedures. In addition, the corrective actions'for the T hurth end fifth concerns dealing with calibration reQuit ei in the form of a supplemental program to provide a verifica M
' i e calibration accuracies of_
in Section III.B.3), would safety-related instruments (disco i
also correct this observed defich 4cy".
7.
The twelfth concern involving the Start-up Manager downgrading SFRs, NCRs and changing the routing from NFE to Bechtel was investigated and sabstantiated. The corrective actions requested an eval gon and appropriate changes in the administrative progtams to brir4 Gem into conformance with the requirements of the QA Program,7 e response to the corrective action request indicates that this concern was the subject of a QA audit which did not substantiate the concern. The QA audit involved a substantial review of the adminis-trative requirements, outstanding documents, and the implementation of SFRs and NCRs for the identified discrepancies.
8.
The thirteenth m eern identified a rag found in the standby diesel generator day tank. The investigation substantiated that the rag was found. The corrective action required a review of the operation of the standby diesel generator to determine the existence of any other conditions which would adversely affect the operations of the diesel generator. The response to the corrective action indicated that a review team revhwed all the Rejected Item Reports (RIRs) concerning their adherence to the administrative procedures and investigated all paperwork addressing the RIRs performed a field walkdown of the standby diesel generators and transferred all the outstanding RIRs to KGLE Operations for control. These actions appear to be appropriate to resolve the substantiated concerns.
C.
NRC Inspector's Conclusions it was concluded that the Q1 Program was effective in identifying and resolving significant safety issues,related to these allegations. There were several examples in which the concerns and investigation resulted in significant corrective actions. As a l'esult of the the second concern, a discrepancy in the calibration of the standby diesel generator gauges was identified and corrected. As a result i.f the ttfrd, fourth and fifth i
concerns, a supplemental program was impTementet to ensure that gauges used for safety-related data were calibrltion checked following the Case No. 4-86 004 76 I
J
examples in which the calibration of instrumentation was performed using water as the test medium on systems in which water was not to be intro-duced. The concern was sunmarized to indicate that water was used as a testing media in moisture sensitive areas.
Safety Significance:
The use of water as the test media on systems which are moisture sJnsi-tive can adversely effect the proper calibration and operation of safety components and gauges which have been designed to be moisture-free.
Proper calibration techniques are necessary to ensure the accurate indication and continued operation of safety-related equipment.
Therefore, there is a safety significance to the allegation, if tubsten-t1ated.
Scope of Q1 Findings:
Q1 substanbated the allegation by the observation of the use of a water gauge used as the testing means for (4) lube oil level switches which did not compensate for the dif ference in specific gravity Letween water and 1
lube oil. Additionally, the observation of actual calibrations indicated that the administrative requirements for the perfor1 nance of calibrations were not being followed.
3.gla,t,e h
~ posed Corrective Actions:
Pro indicated that, two level detectors were calibrated without 1_
compensatiofEfor the use of water vice lube oil; the calibrations for two level detectors and a prer.sure instrument were found to contain insuf fi-cient evidence to demonstrate satisfactory calibration.
Additionally, two calibration procedures concerning the calibration of instrument loops and temperature elements were determined M contain insignificant evidence deemed necessary to demonstrate sat the instruments were satisfactorily calibrated. The
.equ M ed a retest of the affected Tilstruments and a review of adomphal data sheets to detercine the extent of the findings, a revision of the procedures identified to be deficient and identification of actions to prevent reoccurrence.
Corrective Action Response:
The actual corrective action indicates that the test medium used in the calibration of four level switches was air and not r. ster as identifier The use of air, however, was still incorrect. Action was taken to i
properly calibrate the affected gauges using lube oil as the test medium.
The most cause was determined to be perscnnel error. Adequate corrective j
actions were undertaken to counsel all technicians of this error. The response further indicnes that I & C calibration procedures are not 3Ficient. The QFAR concern is indicated to be adequately addressed in QI Surveillance 5597 and Audit KQWLKW5U 83-002; therefore,'no corrective actions are necessary.
NRC Evaluation:
The original allegation was properly sumarized as a concern with the use l
of water as a test medium in moisture sensitive areas. However, the Q1 l
substantiation erred in that the use of a gcuge calibrated in inches of H2O does not dernonstrate the introduction of water into moisture t
Case No. 4-86-004 80
i performance of a preoperational test and that previcus preoperational testing was evaluated to ensure the calibration accuracy of the test gauges used. As a result of the eighth concern, additional component testing was performed on the standby diesel generators. As a result of the thirteenth concern, all outstanding Rejected Item Reports (RIRs) were reviewed and the control of these items were turned over to Operations control.
It was also concluded that the specific corrective actions identified If the investigator had been adequately resolved by the responses to the corrective action requests. However, there were several examples in which adequate corrective actions were not accomplished because the investigator did not request corrective actions, and there were also several examples in which the investigator substantiated his findings based on a misunderstanding of the requirements. The investigation of the first concern identified that the instrument calibration program was not adequate becaese three of thirteen randomly selected instruments were found out of calibration, however no corrective actions were specified.
The investigation for the seventh concera substantiated that the Architect Engineer lost control of the design change control process, Fowever the identified corrective action noes not appear to close the concern. In the third concern, the inve's'tigator misinterpreted the use of a gauge calibrated in inches of wateF.' In the eighth concern, the investigator misunderstood the requiretnints of the F5AR as they related to the testing of the standby diesel generators. In the ninth, tenth and
^
eleventh concerns, the investigator misinterpreted the calibration requirements for instruments loops. And in the twelfth concern, the investigator came to conclusions which differed from the results of a detailed QA Audit on the same subject, which was considered to be more extensive than the Q1 investigation.
In review, the majority of the concerns dealt with the adequacy of the calibration program as it related to the startup and preoperational test 1
program. The inspector noted that there were numerous inspection reports 1
issued concerning the adequacy of the preoperational test program. MRC 1
Inspection Reports 50-482/84027, 50-482/84031, 50-483/84035, and l
50-482/84048 specifically identified similar deficiencies in the pre-
~
operational test program. The inspection reports and the Systematic Assessment of Licensee Performance (5 ALP) 1ssued for the period 8/1/82 to 7/31/83 all indicate that the preoperational test program was considered to be very poor. These various inspection reports identify discrepancies with the preoperational test program beyond the deficiencies identified j
with calibration program and go so far as to document in Inspection Report 50-482/84043, a progranmatic breakdown in the preoperational test program for which escalated enforcement was taken. The NRC inspection reports indicate that additional s ecif conia'ns beyond the scope of the concerns identified in the have been identified and l
reso ve.
Problem Areas identified by the NRC Inspector:
l Item 1 File Opened:
84/03/28 Case No. 4-86-004 77
.. -.l
Concern Closed:
84/10/19 gQ Tile closed:
85/01/21 Q
h Description of Allegation:
Instrument calibration is in doubt in that instruments do not function at proper setpoint af ter calibration.
Safety / Quality Significance of Allegation (if true):
There is a safety significance to the anegation that the I & C calibra-tion process is not effective. Portable and installed measuring and test equipment (M&TE) is required to bC properly Calibrated for the satis-factory p2rformance of proportioned and startup testing. Permanently installed plant instruments must remain calibrated for the continued verification of the technical significance.
Ineffective calibration procedures invalidate the testing program and, therefore, the validation of the plant's design basis, as well as the continued operability of the piut's safety systems.
Scope of Q1 Investigation:
l The investigation was performed to review the adequacy of previously accepted current data sheets of I & c instrument calibrations and deter-mine if the results were still valid. This review included verification of compliance with administrative guidelines and a reperformance of a calibration for 13 instruments.
Substantiated by Q1: YES Synopsis of Q1 Investigative Findings:
Of 13 instruments recalibrated, 3 instruments were found out of cali-bration (22.9%).
In addition, the investigation identified that previously accepted data sheets for calibration /recalibration were not performed in accordance with the appropriate administrative procedure and that recalibrations were performed without using the correct acceptanca criteria basis. The investigator concluded that the allegation was
$9M tantiated. Because there is no evaluation pru ided as to the Es ecific conditions of the instruments which were found to be out of callDration, this Conclusion is questionable. The failure of three Out oTITitrteen previously accepted instruments may not be conclusive and the use of this as evidence that the entire calibration program is deficient is not conclusive. Factors such as the amount of time in service, construction activities in progress, type of instrumentation and the degree of variance of the calibration must be considered in the evaluation of these particular failures.
As corrective action, the investigator identified t (discussed later). No corrective actions were identified to addtess the sub-stantiated allegation that previously accepted calibrations were not repeatable. Therefore, the Q1 investigation was not effective in resolving a safety-significant concern.
M P*
7g 47p Case No. 4-86-004
Proposed Corrective Action: (12) NRC Evaluation of C/A C/Af1:
indicated that retesting data sheets examined for the KJ System (stcby DG) during startup testing program indicated that they were performed to SU6 C504 instead of ADM 08-806 as revised by ADM 14-103 para.4.8.1.
Requested evaluation and revision of proce.
dures to comply with requirements.
MRC Eval: The startup administrative document, ADM 14-103, required that components be entered into the site calibration program, AD CD8-806 following acceptable component testing. However, f ollowing recali-bration, the retesting was performed per SU6 C504 (identity unknown). Th response indicates that the requirement to enter components inw sner site calibration program af ter testing will be deleted by ACN 001 to ADM 14-103/9 because the applicable operations procedures will be implemented for all calibration activities after the startup program.
This would appear to be acceptable if the applicable operations j
procedures ensured that components were periodically calibrated and 1
if found out of calibration, that appropriate measures are taken to ensure that the data taken with the instrument (in the preop or startup test) was not subsequently invalidated.
the A
ability ~of the operations procedures to ensure that the above cited concern is addressed.
1 C/Af2:
indicates that specific switch test records contain data which is inconsistent with the Total Plant 5et Point Document (IP5P) and with vendor prints. Requested determination if cali-bration test records for the KJ and other systems exhibited similar discrepancies and determine the effect of these discrepancies on the adequacy of component and preop test results.
1 l
The response indicates that although there were inconsistencies between the component records, the TP5P and vendor drawings, there l
was not a prograsunatic breakdown in the accuracy of the TP5P.
l Additionally, there was no impact on preoperational test results, j
NRC Eval: This conclusien appears to be adequately supported by the specific examples cited. Additionally, since specific setpoints were not in question, but rather the tolerances of these setpoints, there is a lessor safety significance.
D Description of Allegation:
The original allegation concerned three specific I
Case No. 4-86-004 75 7
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l sensitive areas. Therefore, although a significant concern was identified (i.e. the lack of compensation for the difference in specific gravities in the calibration process and the lack of specificity of calibration procedures), the original allegation was not substantiated, l
investigated or corrected.
With respect to the corrective actions taken, the actions concerning the I
lack of compensation for specific gravities were adequately addressed by the licensee. ( As an example of the adequacy of their corrective actions, the corrective ac'. cons identified that although the original concern on the use of water as the test medium was incorrect, air was' used as the test medium, which in itself is incorrect.) The adequacy of the corrective action with regard to the deficiencies identified with the calibration.rocedures are not evaluated since the concern was the se et o aa Au.1
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r This is a good example of the QA followup of a (F0. The QF0 was sent to startup (10/29/54), the answer (1/9/85) to the WO did not address the generic problems with the calibration precess as it relates to preoperational test data; QA performed an audit (5/21/85) of the QFO response and concludes the response is inadequate. A new response is not required based on the identi-fication of the corrective action program.
Another example of a QA audit of a QF0 response. The QF0 was issued to startup on 10/20/84 Their response (12/21/84) indicated that no action was 1
required because the startup program was effectively over and the program was corpleted satisf actorily. QA audited the response on 5/30/85 and concluded p
Case No. 4-86-004 84 l
i
that the response was adequate because the requirements which were not met by startup were required to be met by other groups as well as startup. QPV 5/85-156 was issued to effect this required corrective action. QPD 5/85-156 was issued 5/20/85. The response of 6/25/85 demonstrates that the procedures have been revised to require the development and upkeep of the quality matrix.
Another example of a QA audit to a QFO. This is interesting because QA reviewed the QFO on 10/18/84 before startup answered the QF0 on 12/11/84.
Both QA and startup found that the QF0 misinterpreted the administrative requirements. Furthermore, QA answered on 5/20/85 that the QF0 was responded to.
So QA not only reviewed the adequacy of the response, but the adequacy of the original question, the QF0 was issued 10/5/84 documenting the failure to record and review outstanding equipment deficiencies (RIRs, 5FRs, see yellow note).
These must be reviewed to ensure everything is fixed before operating or l
testing equipment. The response (10/15/84) implements a team review of all l
systems to identify all deficiencies and then transfer them to the operations department for control. The QA audit (5/24/85) ensured that the corrective actions were adequate and accomplished.
In this example, the QF0 was issued because three findings (identified in
_) were reports of QA audit findings in report 3-597.
The QFO says this is indicative of prompt corrective action not occurring. This is true. The QFARs were satisf actorily resolved indivi-dually. QA audited the response to this QF0 and concluded that there is nothing more that can be done about prompt corrective actions. I agree.
Interview With John JOHNSON, Chief of Security, Wolf Creek Nuclear Operating Corporation OdCMOC)
On May 15,1987, JOHNSON was interviewed by NRC Investigator H. Brooks Griffin at the WCGS site (Exhibit 20). JOHNSON said he had been Chief of Security for seven years.
JOHNSON said that in 1984 he recalled tha asked him to run D' h criminal records checks on ten DIC supervisors ma s who had been named in 41, association with drug use allegations received by Q1. JOHNSON said he had the ten individuals record's checked, and none had criminal records. JOHNSON said that at the time, no one in his department performed any investigative work on the allegations made to Q1. JOHNSON said that at the time, security did not know the request for the criminal checks was related to drug allegations. He said th negative replies on the criminal checks was referred back to and that was the end of security's involvement.
JOHNSON said he understood that Gary FOUTS (KG&E) or Forrest RHODES (01C) received the drug allegatinn information from Q1. JOHNSON said that FOUTS referred the allegations to him (JOHMSON), and he said he sometimes received Case No. 4-86-004 85 g,, 7 g + 7,p, N
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drug allegation information directly from Ql. JOHNSON said during late 1984, he received r.o instructions from his superiors as to what to do with drug allegations. JOHNSON said there was no requirements for liin to recontact Q1 with the results of any use he made of the Q1 drug information. JOHNSON said FOUTS wanted a reply if any information was true, but said his recontact with FOUTS was informal.
When questioned about what use he made of the Q1 drug information, JOHNSON said that the Security compared the information they received from Q1 with information they had already developed. He said on occasion they performed searches in the WCGS power block and searches of vehicles. JOHNSON said several employees had been terminated as a result of the security departn>ent's investigations into drug allegations.
JOHNSON said that three or four weeks af ter Q1 began referring drug allegations to security, FOUTS began requesting formal feedback from security.
JOHNSON said his department made written responses to FOUTS regarding how they used the drug information. When JOHNSON was questioned as to whether his handwritten responses were placed in the Q1 file, he said he believed they were. JOHNSON said he believed his investigative work regarding these allegations may have been used to close some of the Q1 files.
JOHNSON said that the confidentiality granted by Q1 prevented security from recontacting the allegers in that security did not know the identity of the allegers. JOHNSON said that at the time, security resources were not allocated for drug investigations, and said security did not have drug testing on the site. JOHNSON said that when the Security received a single source of information related to drug use, they did not respond to it. JOHNSON said that if a second independent source was developed, they would usually follow up on the information. JOHNSON said he had exchanges of information with the local Sheriff's Department and had also used narcotics detection dogs for searches relative to drug allegations. JOHNSON said that employees were not terminated unless drugs were actually found. He also said that employee drug testing on site did not begin until 1986.
JOHNSON was questioned regarding the number of employees terminated for drug use between March 1984 and March 1985, and stated he believed it may have been approximately one dozen employees. JOHNSON said that approximately half of these terminations were the result of information provided by Q1. JOHNSON said that if an individual was terminated for drug use and had performed quality related work, the work he had performed was reviewed to deterinine whether there were secondary "sign-off s" or reviews of the work. JOHNSON said it was his understanding that in those instances when there were no secondary reviews, the work performed by the terminated employee was reinspected.
g Case No. 4-86-004 86
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' %7.%rbik;j.Q Wp% sp$ Ws@ Q.c.Jf f'W kW,..,f Intervi2w With Robert L. SCOTT, Foriner Q1 Lead, WCGS On Juae 3,1987, SCOTT was interviewed by NRC Investigator H. Brooks Grif fin in Russellville, AR (Exhibit 21). SCOTT said that he was a registered Professional Engineer, Quality Engineering. SCOTT said he was hired into Q1 as an investigator and worked for THER0 and HILL.
SCOTT said SNYDER became the manager of Q1 a few weeks af ter he joined Ql, and f
said he was made a Q1 lead over the investigative group. When questioned about his promotion to lead, SCOTT said THERO told his that GRANT wanted hia to ettend a meeting with K0 ESTER about changes in the Q1 organization. SCOTT said he was aware that Q1 was planning to hire :, ore investigators, because Q1 was behind in its investigations. 500TT said SNYDER was introduced as the new manager of Ql, THERO was sv,de interview lead, and he was made the investigator i
lead.
SCOTT said he did not know SNYDER before this meeting, and said they
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were asked to hire additional investigators af ter the meeting.
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SCOTT said that he initiated an investigation, related to the Olt CAR program, but said he did not toeplete s iny n.
When I
questioned about his investigative approach fo SCOTT said he listed the CARS which had been revised and eli ne the ot 5.
SLJTT said he interviewed DIC engineering erployees about revisions to CARS. SCOTT said at the time he assumed his new duties as lead, he had discovered no evidence of manager.ent pressure to revise CARS resulting in their being ineffective.
Case No. 4-86-004 89 4
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When SCOTT was questioned about whether SNYDER in his initial meeting with the staff specified the number of cases that were to be closed before fuel load, SCOTT said he did not remember any such discussion in this meeting nor did he recall any statements made by SNYDER to the effect that anyone who could not meet these goals should seek other employment.
SCOTT said the use of QF0s was initiated to document concerns outside the scope of the allegation which could be turned over to the responsible organi-zation. SCOTT said that he was the one who instituted the use of the QF0s.
SCOTT said that when he joined Q1, he realized that there was a problem with investigators expanding their investigations to such a degree that the original concern was lost, making it difficult to close the concern. SCOTT said that under his supervision, attention was given to creating an investiga-tive work plan so that the investigator understood what was expected of him.
SCOTT said that the use of QFOs was not intended to narrow the focus of the investigations to a point where related deficiencies were not identified or reported. SCOTT said that he recalled an investigator, whose name he did not remember expressing reservations about the use of QFOs. SCOTT said that after he explained his reasoning, the investigator accepted his explanation.
SCOTT was questioned about a prohibition against investigators discussing cases among themselves. SCOTT said he realized that investigators who were conducting parallel investigations were not verifying infonnation in some instances, but rather relying on information received from their fellow investigators. SCOTT said he conveyed to them that this was not satisfactory.
SCOTT said there was a problem with Q1 investigators spending too much time discussing their cases, not investigating, and disturbing the other investi-gators. SCOTT denied that the prohibition was instituted to make it easier to close cases or to control the conclusions of the investigators. SCOTT said the investigators were not prohibited from soliciting technical expertise.
SCOTT emphasized that the mission of the Q1 program was to identify potential problems which could adversely affect the operation of the plant.
SCOTT said he did not recall investigations being closed by merely referencing an NCR or a CAR. He said he felt the program required an investigation and a conclusion for each allegation. SCOTT said that the investigative conclusion was sent to the affected organization, and that it was their decision whether an NCR or a CAR would resolve the problem. SCOTT said he did not recall what was done with drug allegations taken by Q1.
When questioned about the designation that allegations were substantiated but had no merit, SCOTT said the investigator was the one who made this determi-nation. SCOTT said he had never concluded that a substantiated allegation had no merit. SCOTT said he recalled discussing whether allegations had merit with the investigators, but he never independently concluded that an allegation had no merit.
SCOTT said he never tried to limit the amount of time or the scoping of allegations. SCOTT said he recalled instances when he did not believe the investigators had pursued the investigation far enough, and he said he suggested that they continue to investigate. SCOTT was informed that based on the NRC's review of the Q1 case files, many of them were poorly documented.
SCOTT said he did not recall the cases being pocrly documented.
1 Case No. 4-86-004 90
(c,
10 SCOTT was questioned about the methodology employed b to close cases referencing general undocumented discussions with 19 r selected QC inspectors on six general topics, none of which related to specific alle-gation. SCOTT said he did not endorse this type of superficial effort. SCOTT volunteered that some of the Q1 investigative personnel had such extensive experience in certain areas that he felt it could work as a disadvantage to the program. SCOTT offered that there may have been instances when the l
investigators realized the condition described in the allegation would not be detrimental to the hardware and, as a result, they may not have thoroughly documented their investigative effort. SCOTT said that when he found this lack of documentation, he would return che investigative report to the inves-i tigator and instruct him to conduct a more thorough investigation and documen-tation of his investigative effort.
SCOTT was questioned about how priorities were set for the investigation of i
allegations. SCOTT said allegations generally were investigated in the order in which they were received by Q1. SCOTT said that individual cases were assigned to investigators who had expertise in the area related to the alle-gation.
SCOTT was questioned about what his signature on a Q1 investigative report signified. SCOTT said it meant that enough information had been gathered to substantiate the conclusion made by the Q1 investigator. SCOTT was questioned about why so many of the files contained one or two sentence descriptions of the allegations, and did not contain the results of the Q1 interviewer's discussion with the alleger. SCOTT offered that there had been difficulty in determining exactly what the alleger's concern was in some of the interviews.
SCOTT said the sumaries of the concern contained in the files may have been the result of this earlier problem. SCOTT said that he accepted this practice of distilling the employees concern down to one or two sentences. SCOTT added that on a number of occasions, 'ie had requested that interviewers solicit more specifics to aid the investigators in pursuing the allegations. SCOTT said there were instances when the investigators would recontact the allegers to j
gain more specifics.
j SCOTT was also questioned about why the Q1 files contained so little documen-tation on the results of investigative interviews and document reviews. SCOTT l
said he did not recall a lack of documentation but agreed that some of the j
investigative effort may have been sumarized to him verbally by 1
investigators. SCOTT pointed out that criticisms for lack of documentation in the Q1 files came primarily from the NRC Office of Investigations and not from Region IV personnel.
SCOTT was questioned about whether Q1 investigators "inherited' other investi-gators cases late in the program. SCOTT said Q1 supervision attempted to schedule termination for the Q1 investigators af ter they completed all their open cases. When questioned about whether he had instructed that documents be removed from the files or whether there had been a purge of Q1 files, SCOTT said he recalled asking the Q1 investigators to remove any documents that were not relevant to their cases.
SCOTT was questioned about the intermittent use of by KG&E Legal b,7C and whether DOL findings or Kansas Department of Hu n Resou ce findings g 7y influenced Q1 investigative findings. SCOTT said that he did not monitor or
[o,7 N 7.0 f Case No. 4-86 004 91 j
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l k supervise the investigation pe ormed for Legal. SCOTT was questioned about whether any findings related to wrongdoing resulted in any action taken aga ose etermined to be wrongdoers. SCOTT A
responded by stating that he did not recall any specifics. Although there had been changes within the DIC, he was not sure if they were directly related to Q1 findings.
SCOTT was questioned about whether there was a response to Qi0s before fuel load, and he said there was. SCOTT said SNYDER expressed his concern to the QA manager that responses to QFOs needed to be completed before fuel load.
SCOTT was questioned abou his incomplete investig f the CAR program which was reas ed t SCOTT said he recalleo orked on the CAR inve on for a mont o a month and a half. SCO he n
initially a o develop his own investigative plan, and said he did QV not requ o accept his (SCOTT's) investigative plan. SCO a
he informe his investigative approach on this case, but sai.
elected us a different approach. SCOTT said he continu to fonito investigative effort, and he was shocked when he determine Finvest-1 gation was "rar611 SCOTT said that despite repeated discuss ons, he finally gave up on who had apparently failed to comprehend his instructions.
d he had informed SNYDER, on occasion, that he was concerned about per/ormance.
SCOTT said that at one point in his discussion wit old him "Man, just tell me what you want, and I'll write anythini ou want.
SCOTT said it was his opi ion that they did not need thi of person in Q1. SCOTT said that befor turned in a draft report, ad no r lized to him what Sg his investi conclusion mi SC id whe urned in his draft report, he concluded that was not capable o un tanding the issue or conducting the investi tion. SCOTT said he decided tha uld be cetter just to stop the investigative process. SCOTT said he tol he was disa ed in his work and that Q1 no longer needed his services TT said terminated the same day with SNYDER's concurrerce. SCOTT said he pu investigative report in the file, and turned the file over to SNYDER.
said he did not know what SNYDER did with the file, but said SNYDER may have turned it over to K6&E Legal, j
b 6
SCOTT said he reassigned the case to and that ted a matrix approach and finished the iny SCOTT sat a
concluded the allegation was substantiated based on one CAR een i
i d numerous times. SCOTT said that there was no action on any of findings. SCOTT indicated that based on his review of indt h
not agree vi conclusions. SCOTT said he did no to be influenced by eport but eephasized that he had not int i
removed the report rom se file. SCOTT recalled that at some point in time, he had instructed o document conce side the scope of the i
id not follow his allegation on a QF0. S said, however, tha instructions.
SCOTT was questioned about whether any other investigators were reroved from Q1 because of their investigative findings, and he indicated he did not know of any others. SCOTT pointed out that they were all contract employees and i
were scheduled to leave the site at the end of the investigative process.
I Case No. 4 86 004 92,
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SCOTT was questioned about whether any of thi Q1 investigators complained to rel ted to their investigative 9g him about the lack of corrective actio findings. SCOTT said he recalled that had expressed concern about the lack of responsiveness to QFOs. SCOTT in ated that once the investigative reports or the QFOs were reported to the affected organizations, he believed Q1 had met its' obligations.
SCOTT denied that Q1 supervisors were either limiting the time or limiting the scope of investigations. SCOTT said he attempted to monitor the investigations to make sure they were focused on the allegations, but said he told the investigators to take as much time as they needed to draw appropriate conclusions.
SCOTT was questioned about some of the dramatic closure rates for individual Q1 investigators. SCOTT explained the investigators were given the tools and the guidance tr., pursue their investigations, and the efficiency of the tystem allowed them to close their investigations at the rate they did. SCOTT said that SNYDER did not see the investigative reports t.'til they were complete, and said SNYDER was very critical of typographical errore in reports. SCOTT said he believed the Q1 statistics showing that a majority of cases were closed by December 1984, demonstrated the program accomplished its objectives.
SCOTT said Q1 was a good program, and he disagreed with any characterizations that the allegations were closed without meaningful investigation.
SCOTT said there were no instances when he changed or attempted to change any investigator's report or conclusion. When questioned about whether he knew of any Q1 investigators who had a conflict of interest with the allegations they were asked to investigate, he said he did not. When questioned specifically about the internal pipe cleanliness allegations, SCOTT said that StlYDER was not involved in day-to day investigative activities and tle cases were essen-tially complete befnre SNYDER knew their conclusions. SCOTT was questioned about whether many cases were closed for lack of specificity, and he said he did not believe this was the case. SCOTT said there had been instances when attempts were made to recontact allegers for additional information.
When questioned about the Q1's proficiency or thoroughness in wrongdoing allegations, SCOTT said that as far as he knew they were as thoroughly investigated as were the technical issues. SCOTT concluded that Q1 was a good program, and he believed it had integrity.
Interview With Charles SNYDER, Manager of Q1, WCGS On May 12, 1987, SNYDER was interviewed by NRC Investigator H. Brooks Griffin at WCGS (Exhibit 22). SNYDER was represented during this interview by Jay SILBERG of Shaw, Pittman, Potts, and Trowbridge. SNYDER said he began his esployment with KG&E at WCGS in June 1980 as a project construction man?ger.
Beginning in March 1982, he represented KG&E at Institute of Nuclear Pcwer Operations (INPO) until December 1983, then he returned to WCGS and repre-sented the utility in its rate case hearings. SNYDER said that in August 1984, K0 ESTER selected him to become the Q1 Manager.
SNYDER said he assumed responsibility for Q1 on August 20, 1984. He said that THERO had been the Q1 team leader, and explained that he had not replaced THERO but rather was assuming control of Q1 from RUDOLPH. SNYDER said THER0's title was changed to Interview Supervisor.
Case No. 4-86-004 93 7
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SNYDER said that Q1's mission was to receive concerns from individuals associated with the project, investigate their concerns, draw conclusions and, if necessary, request corrective action from the affected organizations.
SNYDER said that Q1 also verified corrective action once it was completed.
SNYDER said that part of Q1's program involved recontacting employee's who expressed a d2 sire to know what was done with their concerns. SNYDER said that Q1 generally focused on safety related concerns involving documentation, hardware, procedure or methodology of activity, and also wrongdoing.
SNYDER said the one exception was drug allegations which were lumped with functional concerns such as costing, scheduling, management, improprieties, incompetence, all of which were transferred to other site organizations for resolution. SNYDER said that consequently Q1 interviewers took drug alle-gations, but Q1 did not investigate them. SNYDER said drug allegations were handled by a variety of organizations, such as the construction manager, KG&E operations, or Security. SNYDER said he believed most of the drug information was ultimately referred to Security, although it passed through these other organizations.
SNYDER said that when he became manager of Q1, he reported to the Director of Quality, GRANT. SNYDER said Q1's micsion and operational procedures,:ere removed from the QA procedures in November 1984. SNYDER said that when Q1 was under the control of the QA Manager, the procedures called for deficiencies to i
be reported on QPV and Quality program deviations (QPD) which were described in the QA procedures. SNYDER Q1's procedures changed and a document, QFAR, was created to document deficiencies.
SNYDER was questioned about the incidents in vin break-in of b i (,,,
truck, the subsequent alleged blackballing o or a job at
, an alleged kickbacks, all of which allegedly invo QA Manager, RUDOLPH.
- g#
SNYDER said was a e Q1 investigated the blackballing issue. SNYDER said the search o truck occurred before he became the manager of Q1, and said Q1 was n nvo ed in the investigation of alleged kickbacks.
SNYDER denied that, in his initial meeting with the Q1 staff, he had given them a mandate that all the cases be closed by December 1984 He said that his statements concerning resolving, investigating, and closing out cases involved planning efforts. He said he did not receive a mandate from his superiors to have the cases closed by any particular time. SNYDER said that his initial meeting with the Q1 staff was more of a pep talk and the estab-lishment of goals. SNYDER denied making any statements that Q1 employees who could not support these goals should seek other employment.
SNYDER said one of the changes he made in Q1 was to review the open concerns and coordinate manpower needs so that there would be no duplication of effort i
on similar allegations. SNYDER said he also implemented the use of a computer to control recordkeeping for Q1. SNYDER said the biggest "bottleneck" interfering with Q1, the tape recording of interviews, was eliminated. SNYDER t
said that K0 ESTER directed Q1 to stop using tapes, but K0 ESTER did not share i
with him his reason for directing that tape recorders not be used. SNYDER l
said the problem of getting tapes transcribed held up the Q1 investigators' access to the infornation.
g g
Case No. 4-86 004 94
SNYDER explained that Q1 was made up of an interview group and an investi-gative group. SNYDER said the interviewers took the allegations, then the allegations were transferred to the investigators. SNYDER explained that the investigators had the authority to recontact the allegers for more information if necessary. SNYDER offered the explanation that some of the files contained lengthy sununaries of walk-in employee interviews on a variety of concerns.
SNYDER said a majority of the concerns in the files were from terminated employees who wrote brief, often only one line, descriptions of their concerns. When SNYDER was questioned about the lack of documentation in the Q1 files for many of the exit interviews, he agreed that the brief descriptions of the allegations were probably all the information the investigators had. SNYDER said that no documentation had been removed from the Q1 files to his knowledge.
When SNYDER was questioned about the requirement that Q1 investigators write QFOs 'n lieu of opening new investigations on issues identified during their investigations, he explained that originally Q1 used QPDs and QPVs. He said QPDs aescribed a deviation from a requirement and the QPVs indicated a violation of a requirement. SNYDER said the QFAR allowed the investigators to document and identify the problem which could then be sent to the organization responsible for fixing the problem. SNYDER said the QF0 was created in order to identify a weakness in the program to the affected organization and to QA.
SNYDER said that Q1 investigators were not allowed to investigate issues not directly associated with the concern they were assigned to investigate.
SNYDER was questioned about former Q1 investigators' concerns that their QFOs were not being acted upon in a timely manner. He stated it was true that he had found a reluctance on the part of some of the organizations to respond to QFOs, and said he had approached the project director and received his endorsement that the organizations would respond to the QFOs. SNYDER said his motivation for using QFOs instead of opening new cases was that Q1 was created to handle employee concerns. He said he felt the QF0 was a legitimate way to document potential deviations, just as other deviations were documented.
SNYDER was questioned about whether Q1, as a matter of policy, closed cases that were reported on a higher tier document, such as an NCR or CAR. He agreed that Q1 investigators had the option of closing concerns based on these documents.
SNYDER was questioned about his prohibition against Q1 investigators dis-cussing their cases among themselves. SNYDER said that when he took over Q1, they had a team concept and people were being exposed to information they did not need. SNYDER said the Q1 investigators had adequate credentials to perform the job they were assigned. His prohibition was for the purpose of making them more productive. SNYDER further explained that his prohibition did not extend to the point that investigators were unable to draw upon the technical expertise of their fellow employees.
When questioned as to why earlier in the program the contents of interviews seemed to be more detailed than later in the program under his supervision, SNYDER stated that when the 01 program was originally created there may have been an influx of allegers who had awaited an opportunity to come forward. He opined that later in the program there were possibly fewer disgruntled employees, and that most interviews were with terminating employees whose Case No. 4-86-004 95
concerns were less defined. SNYDER also said he believed that those laid off later in the program were not as disgruntled as those who were laid off first.
SNYDER was shown the line graphs which indicated an increase in the closure rate and a decrease in the opening of concerns by Q1 after he assumed control of Q1. SNYDER said the changes he implemented in the program could not have affected the number of allegations reported to Q1. As related to the increased rate of case closure, SNYDER said he believed his organizational restructuring created a more effective and efficient investigative organization.
SNYDER said that when NRC Inspector Madsen began his Q1 case review in September 1984, they made all the files available to him. SNYDER said that, if there were any criticism of the files or of the program in general, it was conveyed to them by Madsen in his exit meetings. SNYDER said the 01 investi-gators had not conducted exit meetings, suggested improvements, or expressed criticisms of the program. SNYDER said that 01 did indicate the NRC should be informed of substantial wrongdoing issues investigated by Q1.
SNYDER was questioned about the 10 CFR 50.55(e) reportability requirements.
He said that the Q1 interviewer made the preliminary determination as to whether a particular allegation was reportable. After the investigator returned his investigative findings to the interviewer, the final decision was made on whether it was a reportable condition.
SNYDER was questioned about whether Q1's wrongdoing investigations focus primarily on hardware issues rather than the intent of the alleged wrongdoers.
SMYDER s that in case of the allegation of falsified color-coded drawings there was a re-evaluation of encased bolted and welded connections on steel am as well as re-examination of lot and heat nuders.
SNYDER opined that the problem had been adequately tddressed. When questioned about whether the Q1 investigation addressed the intent of the inspection supervisors in falsifying color-coded drawings, SNYDER said there was no attempt to find out whether these same supervisors had adversely affected any other inspections. SNYDER indicated he was unaware of whether these super-visors suffered any repercussions as a result of falsifying the color-coding on the drawings. SNYDER said the Q1 investigation concluded that these supervisors were not involved in wrongdoing. SNYDER said Q1 accepted the supervisors' explanation for their actions.
SNYDER was questioned as to whether Q1 investigated the allegation of kickbacks made against RUDOLPH, and he said that Legal and Q1 performed a joint investigation on this issue. SNYDER said the investigation revealed RUDOLPH had received money, but it was for a contract for services related to another nuclear site.
SNYDER denied that he had limited the time investigators were allowed to work on cases. He also denied that he put pressure on investigators to close cases prematurely. SNYDER said there were no rges of the Q1 investigative files.
SNYDER was questioned about related to swipe tests performed on pipe to determine pipe clea ss. When question about information developed by the Q1 investigator that the only pipes cleaned were those to be included in the sample, SNYDER said he was unaware of this aspect of the investigation.
Case No. 4-86-004 96
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t When questioned about the reason for the removal o from the Q1 gp program, SNYDER said he believed this action occurr e
ssu supervision of Q1. SNYDER said no one had ever explained to him wh was removed.
~
SNYDER was estioned a which related to the alleged black- [' U alli ob at SNYDER said he reviewed nyes e report which showed the allegation was unsub-dg ta SNY')ER said the file contained a memo prepared by THER0 addressed to him whi he belie d drew conclusions contrary to the facts of the case.
SNYDER sai did not draw a conclusion on this case, and said the conclusion hat the a egationwasunsubstantiatedwashis(SNYDER's) conclusion based on his review of the case file.
It was pointed out t hat durir.; his interview with the SNYDER argued that U
l NRC, said he believe had een ac alled.
file) was in error and he con b THER0's written conc 1 n
[h tended that the Q1 investigator had not drawn a conclusion on this matter.
DER sai e was naware as to whether THERO verbal'y consulted wit efore writing the memorandum concluding the allegation as bst ed.
SNYDER said he did not recall having questioned bout whether he had a conclusion related to this case.
When questioned about the fact that many of the Q1 files contained little documentation of evidence as a basis for investigators to draw their con-clusions, SNYDER agreed that the flies were not complete and the investigative res not thoroughly docwnented. SNYDER offered that, in the case of the blackballing investigation, he believed this occurred while his supe sory changes were in transition. SNYDER opined that after his investi-gative reporting procedures were fully implemented, he did not believe there were many instances when the Q1 supervisors disagreed with the investigators.
When $NYDER was questioned about allegations made to the NRC that he had limited the scope of Q1 investigations, he explained that ths Q1 mission was to investigate employee concerns in a timely manner and to see that corrective action was implemented. SNYDER said that if the Q1 investigators felt the issues were broader in scope than what they had been asked to investigate, they had the opti.on of calling Q1 and making an allegation.
SNYDER was questioned about the validity of limiting the sco>e of the inves-tigations by investigating just the concern alleged rather t:1an attempting to determine the extent the potential problem. SNYDER explained that Q1 investi-gators were not auditors; that Q1, as a program, did not take an audit approach in its investigations. SNYDER said that some of the former Q1 investigators had expressed dissatisfaction with having to use QFOs, but said none of them ever came to him and expressed a problem with how 0 fos were being resolved.
SNYDER was questioned about the NRC task force's criticism of Q1's verifica-tion of feedback on allegations referred to the affected organizations.
SNYDER said he had accepted the NRC task force's criticism and generally agreed that at that point in time, the feedback to Q1 was not meaningful.
SNYDER explained that when information was transferred out of Q1, it was interpreted that the responsibility for the issue was also transferred.
Case No. 4-86-004 97
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I
l SNYDER said that procedurally, feedback was not requind; however, corrective
{
action was still verified according to procedure.
Qb SNYDER wa uesti ed abou he arassment and intimi-W 8 dating of hich was su stantiate yl was pointed out
.( 1.h to SNYDER that t s case was referred to Leg d, an as eventuall reinstated, however, the allegation was listed as unsubsta isted by Q1. y SNYDER said he had no recollection of this case.
SNYDER was i
da investigation of t intimidation of f
S DER sa tha verbally I %
a ;+ supervisor d
was gu ty of h assment and 6 i
~
intimidation. SNYDER said he prepare for GRANT's signature to send to D!C informing them that he believe guilty of harassment and dg intimidation and demanding action agai
$N E at despite j
the fact that i': was outside his authorit ded termi-SNfDER said that as far as he knew, no action was en ainst SNYDEF. was questioned about Q1 conclusions on wrongdoing investigations that were referred to Legal. SNYDER said that after he began reporting to Kent BROWN, B90WN infenned'him that he believed there was a need to make a call as to whether allegations referred to other organizations for investi-gation were substantiated or unsubstantiated. SNYDER said he wrote letters to the various orgarizations receiving transferred Q1 concerns and asked them to respond. SNYDER said the raplits he received were recorded as the conclusior,s for the allegations.
SNYDER was questioned abou an al ation that the t p support night shif t told a su or te named (
ot to go to the NRC ause wou d put., 00 people out of work, was questioned why the Q1 case file consisted of an investigative 4 work plan saying that.
as going to be interviewed, a memo with THER0's and SNYDER's signatures sta ing it was site policy to encourage employees to take their concerns to their superviMrs first, and the concern was closed as un'ubstantiated. $NYDER was asked how this type of allegation could be closed s
with such little information and no investigative effort, and why it would be accepted by Q1 supervision. SNYDER said he warr not familiar with this case and could not offer an explanation.
(g %
SNYDER was questioned abo the hara!
ment and on investi ions conducted by Q1 related t involvin When
)
it was. pointed out to SNYD R that ttr was ano er Q1 case jh file said the. allegation was unsubstantiated, however, the Q1 investigator believed his investigation showed the allegation to be substertiated.
YDER said that he had reviewed this case file and pointed out thatl had initialed the Q1 investigative report h ed the allegat on as un b-stantiated. SNYDER concluded that if said differently in his interview with the NRC, then he was mistaken.y SNYDER was also questioned about which related to an acid etch l
test requested on purchase orders sent o wferd Company for stainless steel l
fittings. For four years, Crawford had sent the same etch test with fittings that were purchased for the site. During the Q1 investigation, a Crawford I
Case No. 4-86-004 98
[
7gt(-7y,g m_,
l representative was telephonically contacted, and said the etch test had been a one-time test to show the process for producing the fittings. Site procedures were subsequently changed deleting the etch test from the purchase requirement. SNYDER said that he would not have sec.nd-guessed engineering's decision deleting the request for the etch test from the procedures. SNYDER said he was not familiar with details of this investi the investigative effort, as represented by the file,gation and agreed that i
seemed to have been lacking. SNYDER emphasized, however, that if engineering had told him the etch test was not required, it would have been sufficient for him to accept the deletion of the etch test from the procedure.
SNYDER was questioned about' which involved an electrical QC supervisor allegedly settin ectrical QC inspectors. It was explained to SNYDER that the case file contained only an interview of the accused supervisor who defined the quota more as a goal. SNYDER was questioned about how, in the face of substantial problems with fillet welds related to the work inspected by this QC group, he considered this a valid investigation. $NYDER said he would have hoped the investigation would have consisted of more than just an interview of the accused. SNYDER questioned whether he was managing Q1 during the time these investigations took plare and said there was a possibility that, even though the case was shown to have been closed in October and November 1984, the work may have been concluded before August when he joined Q1.
SNYDER was questioned abou a document h ]Q review engineer alleged tha ed against I
him. It was point d out to YD tha investigation consisted f inte s with and who denie the discrimination, and Y <13)n losed e case as unsu ated. SNYDER was asked whether the aga of interviewing the people accused and limiting the investigation to their responses constituted an adequate investigation. SNYDER agreed that this investigative approach of simply taking a dental from the person accused of the wrongdoing was not a da Cac instance, SMYDER said he did not believe the fact tha nd were Q1 investigators affected the conclusion that ea ation was un bstantiated.
When SNYDER was questioned about (he more thorough and well-documented inves-6 g tigations conducted by
) earlier in tha program in contrast with the i
one interview investig ons was conducting in there was no intent to do a less than thorough job. late 1944, SNYDER said that gp
$NYDER indicated that if the cases were deficient in documentation, it was through ignorance rather than intent.
SMYDER was questioned abou which related to a letter written for FOUTS' signature author z ng the rel se of concrete expansion anchor bolts from a warehouse. SNYDER said that this allegation was ultimately substantiated in that DIC had not revised the procedure. $NYDER said he had written the letter for FOUTS' signature. SNYDER denied that he had influenced the Q1 investigation of this issue in any way and said he was not aware of the details of the investigation until this interview.
SNYDER was questioned about an investi ation performed by on the issue of '41 CARS have been rev s to suit po itical conditions, 7
original condition and intent have been lost. The CARS are ineffective and Case No. 4-86-004 99
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positive
- tive action nonexistent." SNYDER said he sn involved in assignin
[theinvestigation,andhewasnotawareo investigative [h efforts a he 3roceeded with his investigati YDER s id h s only knowledge was that SCOTT had determined tha work pr uct as unsatis-fac SNYDER said that SCOTT told him h nitore assignment, bu was unable to complete the assignme isfacto y.
When ques d about his knowledge as to whethe had completed an nyes i-gative report, SNYDER said he had relied on OT who told him tha was unable to comp e assignment. SKYDER said that based on SCO s
recommendation was ter ina d.
SNYDER said he had not reviewe report and never ed wit about his termination.
When SNYDER was questioned about why a copy o.
handwritten report was not retained in the Q1 file, he said he had not been aware of the existence of the report. SNYDER said he wa a that Legal had performed an inves-tigation of the termination SNYDER said he did not t5tnk it was
'/ M valid for Q1 to discard estigative report. He contended that sinceLegalhadacopy,l not been discarded. SNYDER said told him that he had worked with n his investigative approach, b had not followed SCOTT's direct ons. SNYDER said SCOTT told him that ad not given him anything he could use and that he wanted to terminate h m.
SNYDER was questioned about whether he had heard of any complaints from former Q1 investigators that their investigative conclusions were changed by Q1 l
investigators who inherited their incomplete cases. SNYDER said that he was not, aware of any instances when this had occurred. SNYDER said he did not know of any instances when Q1 investigators were laid off while still in the midst of an investigation. SNYDER said when only verification of corrective action remained, Q1 investigators were not retained.
't SNYDER was cuestioned about which related to valves that had been disasserbled and tracea i ity for t ir parts lost. During the Q1 investigation, there was an indication' that the sampling process had not been 1
legitimate, because the Q1 investigator had developed information that the results of an initial sample had been discarded. During a subsequent expanded sample, the deficiencies identified in the first sample no longer existed.
SNYDER said there had been a QPV written on the valve disassembly problem, b I
potentialwrongdoin!NYDERsaidtheQPVaddressedthemethodologyfortheidentifie h
to his attention.
d#
1 sampling. SNYDER was questioned about what omplaints by PATRICK and RUDOLPH against Q1 inve ator for reporting the i
alleged wrongdoing, had resulted in inatio ate being moved up.
SNYDER said that PATRICK and RUDOLPH did not ave any influence over program, and he did not recall PATRICK or RU00LPH complaining abou SHYDER was questioned about whether there was a time in the Q1 program when the investigation reports were not signed by the reporting investigator.
SNYDER said the investigators merely initialed their reports, and their initials indicated they had seen the final product.
SNYDER was questioned about whether he was aware of any appreciable number of Q1 cases being closed for lack of specificity in the allegation. SNYDER said Q1 interviewers attempted to develop information during the interview process, Case No. 4 86-004 100 4pgg i -.
i but he said some allegations were closed because they were too general in nature.
670 SNYDER was questioned about hich related to "piping preheat i
and weld records were falsi
, ooug after the fact ins ctors who -c 9 i
never leave their desk." It was pointed out to SNYDER tha had closed this case by referencing a general discussion with 19 ran ly se cted QC inspectors from various disciplines on six general topics, none of which i
related to the allegation. SNYDER said he could not support or condone this approach to closing investigations, but he would have to become more familiar with the file before he could connent specifically.
SNYDER was questioned as to whether K0 ESTER's decision to have Q1 stop using a
resul sex discrimination allegation made SNYDER said that K0 ESTER never lo o
ere ir a reason y he was suspen ng the use of tape recorders, but the two events occured in the same timeframe.
When SNYDER was questioned about how his philosophy for the conduct of the Q1 program differed from THEn0's, he opined that QA auditors were not very good investigators. SNYDER said he believed that the best investigators were the construction people for construction activities, startup people for startup activities, and operational people for operational activities. When questioned about whether these people could retain the objectivity when their va-ious departments were being investigated, he said he believed so. SNYDER indicated that he hired engineers into the program because they were able to obtain resolution for Q1 cases. SNYDER said he thought his methodology in hiring the engineers was good except possibly as it related to wrongdoing issues. SNYDER expressed the opinion that the Q1 program under his supervision was objective, and he belie'ved each allegation was given a fair review.
SNYDER was questioned about whether the Q1 investigative findings and Q1 QF0s were resolved before fuel load. SNYDER said that QA had the responsibility for verifying that corrective action was taken pursuant to QF0s. When ques-tiened about an alleged stack of Q1 documents that PATRICK, a QA supervisor had in his office, SNYDER said he believed these documents were a priority log maintained by QA. SNYDER pointed out that during this period of time, there had only beta 22 QFOs written.
SNYDER was questioned about a letter that THERO wrote about the Dissolvo tape issue before THER0 left Q1. $NYDER verified that THERO had given him the letter, but he took no action on THER0's reconnendations. When SNYDER was questioned about whether his earlier involvement in the internal pipe clean-liness program at WCGS had influenced his willingness to accept and act upon new allegations regarding that program. SNYDER said this was untrue. SNYDER said the pipe cleanliness issue was addressed on an NCR and said that any allegations relative to pipe cleanliness fell under the NCR. When questioned about whether he was willing to take any new or additional allegations on the subject, SNYDER said he believed the hydrolazing process and the NCR would generically complete or resolve any new allegations. SNYDER said he could not think of any variation in the internal pipe cleanliness issue that could not be resolved through the generic NCR.
t i l Case No. 4-86-004 101 7 g y ")
$NYDER said he interpreted THER0's letter about Dissolvo tape as a threat.
SMYDER opined that THER0's ability to comprehend the issues was limited.
SNYDER said the NCR was a higher tier document, and he had not intended to duplicate investigative effort on this issue.
SNYDER was questioned abou ch related to an allegation of l
vague walkdown procedures.
DER sa had significant investigctory gp findings substantiating the all at on.
ER said he interceded with REEYES, the startup unager, inuestioned about why there was @(behalf relative to his SNYDER as evidence of any investigative work by j
in the Q1 file, whereas, another Q1 investigator concluded the ion was unsubstantiated. SNYDER said he did not know that the result of investigation was missing from the file. $NYDER said that his invol in this investigation was limited to encouraging REEVES to respond to the QPVs.
said he recalled that REEVES was not particularly receptive to the investigative conclusions. When it was pointed out that the Q1 computer st howed this allegation was unsubstantiated, he said he recalled there were QPYs and QPDs written, so the allegation must have been substantiated.
SNYDER was questioned about Q1's verification of corrective action. SNYDER said he incorporated verification of corrective action into the Q1 program, and that Q1 had the right to reject the affected organization's corrective dCtion. SNYDER said that occasionally, he had rejected corrective action.
SNYDER denied that verification under his supervision wat, a "rubber stamp",
and that he had been 'hard nosed" on acceptance of corrective action.
SMYDER was questioned about whethe ad ever been assigned an NW investigation in whici he was the su
- e. allegation. SNYDER said that he did not recall any :uch investigation.
$NYDER was questioned about instances whe ad apparenting closed out (,, %
allegations wit t
erming a meaningfu igation. SNYDER of fered Ng that because of extensive experience in startup, he would know where to look for informatio to resolve an issue without an in depth irvestigative effort. SNYDER indicated that he did not spend a great deal of time reviewing the investigators' work files.
When questioned about whether there were any Q1 findings referried to the affected organizations that remained uncorrected before fuel load, SNYDER said every QFAR generated by Q1 was responded to and corrective action verified before fuel load. SHYDER said the status of corrective action items had been continually monitored until completed. SNYDER coevnented that the NRC also had input into the prioritization of issues needing to be closed before fuel load.
SNYCER was questioned about the Q1 conclusion in some instances that certain substantiated Q1 investigative findings had no merit. SNYDER said this was sometimes used to indicate that no corrective action was required or that corrective action was complete.
SNYDER said the biggest changes he mde in the Q1 program were in the area of documentation of the cases and written investigative guidelines. SNYDER was questioned about why cases that were transferred to Legal were not further investigated by Q1. SNYDER said that once allegations were transferred to Legal or recorded on a higher tier document, the issue was considered closed Case No. 4 4004 102 b 7C Y IM j
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by Q1. It was pointed out to SNYDER that, whereas Q1 had received generally favorable reviews by the NRC technical staff, that 01's review results were critical of the Q1 handling of wrongdoing issues. SNYDER seid that to a degree, he thought some of Ol's criticisms had merit. SNYDER said he did not agree that each new allegation required an investigation. SNYDER said some of the Q1 investigators were particularly knowledgeable of the people and issues and indicated they did not have to expend as much effort to resolve the issues. SNYDER said it was never his intent to require full documentation of investigations. SNYDER said he relied on the investigators to resolve the issues.
In conclusion, SNYDER offered the opinion that many of the former Q1 investigators who made allegations against him had done so because they had suffered either monetarily or their pride had been hurt and they were seeking retribution.
Interview With Glenn L. K0 ESTER, Chairman of the Board, WCNOC On May 13,1987, K0 ESTER was interviewed by NRC Investigator H. Brooks Griffin in Wichita, KS (Exhibit 23). K0 ESTER was represented by Jay SILBERG of Shaw, Pittman, Potts, and Trowbridge. K0 ESTER said he was the Vice-President of Nuclear for KG&E and had previously been responsible for the design, con-struction, startup, and operation of the WCGS. K0 ESTER said he was still the Vice-President of Nuclear for KG&E but no longer had the day-to-day responsi-bility for WCGS. K0 ESTER said he was also a member of the Board of Directors of KG&E.
K0 ESTER said the Q1 program at WCGS was created by his QA manager, RUDOLPH. It was mandatory that exiting employees go through Q1 so they could identify any concerns they had. K0 ESTER said that his signature appeared on the Q1 procedures. K0 ESTER said that when Q1 was created it was not part of the QA program, although Q1 reported to the QA Manager. K0 ESTER said that Q1 was created by reviewing similar programs at Palo Verde and a Toledo Edison site.
He said that initially most of the people involved in the WCGS Q1 program had QA backgrounds but, later, engineers were hired to be Q1 investigators.
K0 ESTER said that Q1 personnel received allegations from exiting employees, hot line calls, and walk-ins, and each concern was evaluated for potential 10 CFR 50.55(e) reportal'ility, K0 ESTER said that if a concern was validated as the result of a Q1 investigation, an action report was initiated. K0 ESTER was questioned as to whether Q1 reconnended ce;'rective action following their investigations. He said they did not but they did verify the corrective action taken by the affected organization.
When questioned about drug allegations received by Q1, PESTER said it was not intended that Q1 handle drug allegations and it was not part of Q1 procedures.
K0 ESTER said that when Q1 received drug allegations or harassment and intimi-dation allegations (wrongdoing), they performed a cursory review to see if it would adversely affect safety or a safety component in the plant, "and if it didn't, then they shipped it out."
K0 ESTER said the purpose of Q1 was to investigate safety allegations and to identify the deficiencies that needed to be corrected before the plant was licensed. K0 ESTER indicated that Q1's mission related to hardware concerns rather than drugs, harassment and intimidation, or other wrongdoing. When K0 ESTER was asked, "What was done with the wrongdoing allegations received by Q17" K0 ESTER said "They were sent to the responsible individual where they carne in, maybe the construction manager of KG&E, who in turn passed them down through whoever he was Case No. 4-86 004 103 l
responsible for. Maybe it was the DIC organization. Maybe if it was in the Bechtel". K0 ESTER was asked the question, "So you relied on KG&E construction managers or DIC construction managers to resolve harassment, intimidation, falsification, drug use?" K0 ESTER's response was "Absolutely, because our program didn't have anything in it to do that."
K0ES in r onse to a question posed by his representative SILBERG, said
[p' I b that had, to a certain extent, investigated wrongdoing as part of Q1 i e
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to a safety related item in the plant. K0 ESTER said cf b,,
otherwise es igations should have been performed for Legai.
K0 ESTER s d that as the only Q1 investigator who had the capa-bility of perform ng wrongd ng investigations.
K0 ESTER said that SNYDER replaced THER0 as head of Q1 because KG&E wented to have a KG&E employee rather than a contract employee running Q1 on a pennanent basis. K0 ESTER denied that SNYDER replaced THERO for the purpose of speeding up the closure of allegations so they would not impede fuel load. K0 ESTER said that while still working in Q1, THERO had created Quality Technology Coepany, and had already received a contract at another power plant. K0 ESTER said he formed the opinion that THERC was planning to leave his employment vith KG&E, and THERO made no inquiries about continuing his employment with the utility. K0 ESTER further expressed the opinion that the Q1 program did not need a manager with a QA background.
K0 ESTER was questioned about whether he had any complaints about THER0's management of Q1. He said it was his understanding that Q1 had been inter-viewing people with tape recorders, but the interviewees had not known they were being recorded. K0 ESTER said that when this came to his attention, he went to Legal counsel and they suggested t'at Q1 stop using tape recorders.
K0 ESTER was informed that an explanation had been given to the NRC that he nad recoved the tape recorders from Q1 as the esult of an all tion of x
discrimination allegation made against th bM K0 ESTER denied that this was the motivating force in his prohibiting he use of tape recorders and re-emphasized his reason for removing tape recorders was that he had been informed that people were being recorded without their knowledge. K0 ESTER was informed that some former Q1 investigators believed the motivating force for removing tape recorders was to decrease the speci-ficity and detail of the allegations, but K0 ESTER denied that this was his intent.
[, p K0 ESTER was questioned about whether RUDOLPH was relieved free hi bility over Q1 because of a search of an exiting employee's truc Y 9 K0 ESTER stated that RUDOLPH had nothing to do with the search of truck. K0 ESTER said that RUDOLPH was not removed as the supervisor of Q because of the search but rather to create greater independence for Q1.
K0 ESTER said that NRC Region IV encouraged him to make the change because of a potential conflict of interest between RUDOLPH's supervision of QA and Q1.
K0 ESTER explained that Q1 was a voluntary )rogram on the part of the utility and felt that Q1 was a good program which ind accoeplished its mission.
K0 ESTER was questioned about whether he 6ad knowledge o N
removal from the Q1 program because o es i estigation nto the miss ng MSSWRs. K0 ESTER said he did not know and was not aware of his removal from Q1.
I g, */c y Q Case No. 4-86-004 104
K0 ESTER was questioned si to why there was no apparent action taken against site employees involved in wrongdoing as established through the Q1 investi-gative process. K0 ESTER said he did not believe Q1 was designed to resolve problens with individuals but rather to identify necessary corrective action on hardware problems. K0 ESTER said he could not offer an explanation as to why no apparent action was taken against those found to have committed wrong-doing.
K0 ESTER said that he believed th e had een reprimands issued to individuals implicated in the break-in o truck.
K0 ESTER was questi thel termination and the refusal of Q1 ves'. gat we findings on his CAR pro ai es-ma na geme ar e tigation 7 Ave TER responded by saying he had hear
- name, but he was not f amil r with the issue.
Willfulness / Intent Section Allegation 1: Charles SNYDER assumed supervision of the Q1 program in August 1984 with a mandate f rom KG&E management to have all Q1 concerns.5at could interfere with fuel load closed by December,1984 SNYDER cortnunicated this mandate to the Q1 investigators in his first sneeting with the Q1 staf f.
a, HILL said that SNYDER, a former construction superintendent who, in his initial meeting with the Q1 staff said something to the effect "If you can't do it my way, then there isn't a place for you in this prograr' (Exhibit 1, p. 37).
- b. THERO said that SNYDER gave an ultimatum to the Q1 staff that they would do the investigations his way or they should find employ-ment elsewhere (Exhibit 2 49).
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by SNYDER to the effect that anybody not able to rieet these goals should seek other ernployrnent (Exhibit 21, p. 23).
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- h. SNYDER said that in his initial meeting with the Q1 staff, he established goals fcr the group. He said he had not received a m.andate f roan his superiors to have the cases closed at any particular time, and he did not require that the invettigators have the cases closed by any particular time (Exhibit 22, p.19).
1 K0 ESTER said no pressure was ever placed on Q1 mana.Jefnent or Q1 investigators to have the cases closed by December 1984 K0 ESTER said that any number of new allegations could have surf aced during that period of time (Exhibit 23, p. 30).
Allegation 2: As the December 1984, t a r g e t. fuel load date approached, significant 01 findings referred to the affected organizations still had not received corrective action.
Sorne of these findings received no corrective action prior to fuel load.
- a. HILL said that af ter $NYDER took over supervi i n f 1, they argued over the Dissolvo tape investigation HILL said ShYDER eventually agreed that tne problem needed to be wrected.
HILL said he learned just before he left Q1 that $NYDER did not send the issue back to construction for corrective action as he said he would do (Exhibit 1, p. 48).
- b. THERO said that based on his contacts with peop;e who remained in Q1 af ter he lef t, he believed that there were significant issues which remained unresolved when the plant was licensed (Exhibit 2,
- p. 63).
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- j. SCOTT said tha d$b ad complained to him about the inactivity )p related to correct ve ction. SCOTT said he believed that once Q1 had written the action report, the responsibility was shif ted out of Q1 (Exhibit 21, p. 118).
- k. SNYDER said he believed that all outstanding QFARs had been addressed and the corrective action verified before fuel load (Exhibit 22, p. 264).
- 1. K0 ESTER said that Q1 verified the corrective action taken by the aff ected organizations, but Q1 did not recorrrnend corrective action (Exhibit 23, p. 7).
K0 ESTER explained that Q1 was not created or designed to take action against individuals, such as those determined to have conducted wrongdoing, but rather to correct hard-ware deficiencies (Exhibit 23, p. 40).
- m. The document reviews conducted as part of this investigation indicated that the significant Q1 investigative findings were addressed by before licensing, but af ter most of the Q1 investigators had been terminated.
Allegation 3: Q1 investigators were forbidden by Q1 management to investigate other concerns they identified during their investigations. Q1 management required the Q1 investigators to report the new concerns to QA as QFOs; however, QA was too busy to i
address these issues before licensing and, as a result, the QFOs were not investigated.
Case No. 4-86-004 107
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6'1 C same month he had closed 27 cases.
said that these two cases which had been time consumin pr ably had field work invested
'et 70 in them during the preceding month (Exhibit 19, p. 55).
- h. SCOTT said he had never tried to limit the amount of time or the scope of investigations. He said he recalled instances when he had instructed investigators to investigate further when he did not believe they had gone far enough (Exhibit 21, p. 51).
- 1. SNYDER denied that he had ever placed time limits or attempted to limit the scope of investigations for any of his Q1 investigators 4%
(Exhibit 22,p.94). SNYDER said that if the Q1 investigators felt i
the concerns were broader in scope than they had been asked to pp investigate, they had the option of calling Q1 and making an allega-tion (Exhibit 22, p. 119).
DE was questioned about several investigations performed by in which he held undocumented general discussions on six tes unrelated to the specific allega-tions with 19 randomly selected QC inspectors in various disciplines. SNYDER said he could not condone this approach as an investigation (Exhibit 22, p. 218).
- j. A review of the Q1 case statistics as plotted on 14, 16, and 18 of this report show that under SNYDER' graphs on pages s supervision case closure rates for individual Q1 investigators rose dramatically indicating less time was invested in individual cases.
Allegation 5: After SNYDER assumed supervision of Q1 and because cases were being closed without adequate investigation, the program lost credibility which resulted in a dramatic drop in the number of concerns reported to Q1.
- a. HILL indicated SNYDER's mandate to have the allegations closed by December so they would not interfere with fuel load resulted in the loss of credibility for Q1. HILL said he believed SNYDER was intent on covering up any concerns which would interfere with licensing.
HILL Indicated that in relation to the interna e cleanliness allegations and the Dissolvo tape issu appropriate corrective action was not implemented
. 48).
- b. THER0 indicated that, under SMYDER's supervision, the Q1 program had lost credibility and was not an up-front legitimate program (Exhibit 2,p.60).
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- k. SNYDER said he believed Q1 during this period of time was a good investigative organization, and that its investigative work was meaningful. He said the NRC technical staff's review of the program resulted in favorable reviews. $NYDER said he thought prim ry criticisms care f rm O! investigations related to wrongdoing.
SNYDER said that he believed the forsner Q1 investigators who were critical of his supervision in the program during this period had made allegations against him because they had either suffered monetarily or their pride had been hurt, and they were seeking retribution (Exhibit 22, p. 273).
1.
The graph on page 14 of this report (infra) indicatts a significant drip in allegations mde to Q1 af ter August 1984 Allegation 6: Significant allegations reported as substantiated by Q1 investigators were subsequently docuinented as unsubstantiated by Q1 m nagement, and @ 1 g h)
FILL said he believed Q1 investigators 6,
had experienced pressure from $NYDEA to change their i vesti-gati e conclusions (Exhibit 1, p 3).
ILL said tha investigation of blackballing of was cha ed supervisors. HILL said fir two ifts of black-balling investigation o for a job at A reported e
allegation as substantiat L said that SNYDER ultimately changed the conclusion to unsubstantiated (Exhibit 1, p. 78).
- b. THERO said that he believe had dif ficulty with Q1 supervisors' atterrpting to change is investig sions (Exhibit 2, p. 44).
THERO said SNYDER change 4 7c9 N Case No. 4-86-004 111 k 3 C W D p/
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- k. SCOTT denied that he had ever attempted to change an tr<esti-gator's conclusion or attempted to coerce an investigato' into changing any investigative conclusions (Exhibit 21, p. i31).
- 1. SNYDER indicated that a certain number of Q1 concerns were 4
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Case Nc. 4-86-004 112
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before (f. W SNYDER said he had not discussed the case wit gp drawing the conclusion that the allegation was nsubstan ated (Exhibit 22,p.98),
m, The Q1 case file reviews did not indicte any additional investigative conclusions were changed beyond those cited (supra).
Allegation 7: Significant findings reported by Q1 investigatort were ultimately reported as being without merit by Q1 managtment,
- a. HILL said he did not know of instances when allegations were trashed but indicated that supervision had designated some substan.
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- b. SCOTT said that if an allegation was determined to be substan-tiated but without merit, this was a call made by the investigator.
SCOTT said he had never concluded a substantiated investigation had no merit (Exhibit 21, p. 49).
- c. SHYDER said that if a substantiated allegation was concludd to have no merit, it meant that no corrective action was re:;uired or
.268.ySNYDERN that correc ive act was completed (Exhibi 22 argued tha pipe cleanliness case was an example of o correcti e action being necessary~ because the issue was already reported on a higher tier document.
- d. The Q1 case file reviews indicated there were only a few instances when Q1 investigative findings were substantiated, but without merit, in that the concerns had already been reported or were already resolved.
Allegation 8: Certain Q1 investigators were terminated or removed from Q1 by Q1 management because they refused to change their investigative findings which substantiated allegations.
- a. HILT. said that as removed from Q1 because of his aggressive pJrsui o e si ss ng MSSWR investigation af ter making hispresentationtoRUDOLPHandGRANT(Exhibit 1,p.14).
- b. THERbaid tha was removed from the Q1 program, p becausq reported welding program did not meet ANSI requ remen s and becaus had ar against GRANT and RUDOLPH (E bit 2, p. 46)gued his position b.YI
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- 1. SCOTT said th when g' 7 rned in his inves ative report on the CAR program, w e t. Nc" he concluded tha was not ca able of conduc ng e nye tigation or unders n ig the issue. 9I said be decided to stop the whole process, terminated SCOTT indicated that nothing was done wit findings (Exhibit 21,p.91).
- m. 5 E said he terminate ased on OTT s reports to his tha work was unsatisfact and tha as unable to comp e 'he ssi nt.
SMYDER said he wa no aware of the 9h existence o nyestigative report. He stated that, since the KG&E Lagal depa nt had a copy, the report had not been discarded even though it was not contained in the Q1 files (Exhibit 22, p.
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Allegation 9: The Q1 procedures were changed by Q1 manLgement to make it r
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Case No. 4-86-004 114
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- a. THERO said SNYDER changed the Q1 program so that certain concerns would be transferred to QA for investigation (Exhibit 2, p. 24).
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SNYDER said he was responsible for proceduralizing the verification of corrective action as part of the Q1 program (Exhibit 22, p. 245).
SNYDER said he required greater docuinentation in the cases and nad written investigative guidelines incorporating these into the procedures (Exhibit 22, p. 270).
Allegation 10: Significant Q1 investigations were closed without adequate investigation, by Q1 rianagement who had a conflict of interest with the issues being investigated,
- a. THERO said SNYDER had been a construction superintendent and had been responsible for the internal pipe cleanliness program. THERO said $NYDER had demonstrated by his actions that there was a flict interest with the pipe cleanliness allegations investigated by Ql. THERO said that the Dissolvo tape t resolved at the time he left the Q1 program and said su w he felt that hot functional testing should not have started until the issue was resolved (Exhibit 2, p.19).
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5:0TT said SNYDER had not influenced the outcome of Q1's investigations into pipe cleanliness allegations. SCOTT said he was not aware of any instances when a Q1 investigator had a conflict of interest with the concerns he was asked to investigate (Exhibit 21, p. 133) r
- j. SNYD was estioned abou allegations made ai was po out to SNYDER that pI 1?
investiga on o these allegations c siste ely of king denia s from the two Q1 investigators, and con-p'J h cluded that the allegatior.s were unsubstantiated.
s d he did ir e this ac o ch but said he did not think the fact tha ere Q1 investigators affecte' M,w conc sion t
,. 165). As related to the pipe t.eanliness and Dissolvo tape issues, SNYDER said he did not believe that any possible new allegations might have been made to the Q1 program that could Nt have been resolved by the generic NCR related to this mu- (Exhibit 22, p. 230). SNYDER said he was not awart of
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Case No. 4-86-004 116
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Ic,16 eing assigned an the allegation (y investigations in which he was the*p 1
Exhibit 22,p.246).
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- k. K0 ESTER said that Q1 was taken out from under RUC01.pH's supervi-i sion for the purpose of adding greater independence to the program j
following discussions with NRC RIV (Exhibit 23, p. 21).
1' Allegation 11: Initially the Q1 program was authorized to investigate all wrongdoing; however KG&E management ordered that drug allegations received by Q1 were to be referred to Security. However, Security, l
in turn did not investigate the allegations.
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- a. HILL said that drug allegations received by Q1 were not inves-1 tigated but rather referred to Security. HILL indicated that Security did not perform investigations of the drug allegations (Exhibit 1
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- b. THERO said Q1 did not investigate drug allegations, but instead, turned them over to Security or to FOUTS. THERO said he had no indication that anyone investigated the drug allegations (Exhibit 2, p 64)*
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- f. SNYDER said that early in the Q1 program, drug use had not been placed procedurally in the wrongdoing category. SNYDER said that under his supervision it was placed in a functional category and j
referred to the affected organizations (Exhihit 22, p. 8).
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- g. JOHNSOR said drug allegations received by Q1 were referred to i
F0lJTS or RHODES or directly referred to Security. JOHNSON said he sometimes used the information in conjunction with information i
independently developed by Security. JOHNSON said he was eventually asked to w-ite reports back to FOUTS se.ying how the information was used by Security. JOHNSON said he believed seine of his reports may have been used to close Q1 files.
Case No. 4-86-004 117 7{
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- h. K0 ESTER said that when Q1 was created, it was never intended that l
Q1 would investigate drug allegations. K0 ESTER said he did not believe it was intended that Q1 would investigate wrongdoing concerns, but rather investigate saf ety allegations and identify deficiencies to be corrected before the plant could be licensed.
K0 ESTER said that wrongdoing allegations were transferred to the affected organization for resolution (Exhibit 23, p. 9).
Allegation 12: Certain Q1 investigators hired into the program by ShYDER were closing Q1 files without actually conducting investigations. A I
l cortnon method used by these Q1 investigators was to report that the allegation was not specific enough to investigate when, in fact, there was sufficient information to pursue the concerns,
- a. HILL said that SCOTT searched for means to invalidate allegations rather than investigate them (Exhibit 1, p. 33),
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Based on a review of Q1 cases, there was no Nlg indication he ' pencil wh ppe inves igations to close concerns without adequate investigation.
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- i. SCOTT said that if allegations lacked specificity, the Q1 investigators were instructed to recontact the allegers for additional information (Exhibit 21, p. 137).
- j. SNYDER said that many of the corcerns received by Q1 were not very specific in nature, because many exiting employees would only write a one-14"-
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descriptions were all that the investigators had to work with (Exhibit 22, p. 31). SNYDER said Q1 interviewers attempted to develop concerns and get as much detail as they could but allega-q ]p tions that were too general in n.i ria**d IFuhibit 22. p.
217). SNYOER was questioned about closeout of a substantiei number of investigations which were not w I une ed ard did nct appear to be meaningful. SNYDER offered tha
, may have been drawing on his extensive experience in startup c aTiow n:e tv vv the work more quickly without spendirig as euch time locating infor1 nation (Exhibit 22, p. 259).
- k. K0 ESTER denied that he had prohibited the use of tape recorders by Q1 for the purpose of limiting the amount of detail contained in t5e allegations.
K0 ESTER said he called for the removal of the tape recorders because he had been told that employees were beino recorded without their knowledge (Exhibit 23, p.16).
Agent's Analysis This NRC investigation established that in his initial meeting with the Q1 staf f, SNYDER made some definitive statements about what he intended to accomplish in the last few months of 1984 This investigation did not estab-lish that SNYDER had received a mandate from his superiors or that he created a mandate for the Q1 investigators to have all cases closed before fuel load.
This investigation demonstrated that at the time most of the Q1 investigators lef t the program in late 1984, very little corrective action had taken place relative to their investigative findings. The case reviews perfor1ned as part of this NRC investigation combined with the testimony taken from former 01 investigators indicated that the QFARs were addressed prior to fuel lead.
Additionally, this investigation determined, as did the May 1985 NRC Region h staff review, that verification of corrective action by Q1 was not meaningful.
Case ho. 4-86-004 119 (c,1c 47D, pn 1
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I SNYDER's initiation of the use of QFOs in lieu of expanding investigations to encompass new issues discovered during'nvestigators. investigations became on contentious issues for many of the Q1 The creation of the QFOs signaled a fundamental change in the mission of the Q1. THERO had envisioned an independent investigative organization that allowed the investigator to evaluate potential problems and scope the investigations accordingly. The original intent of Q1 was to arrive at pointed conclusions and recomend corrective action. The program was fundamentally changed under SNYDER to address issues only within the parameters of the orioinal allegation and to refer investigative findings to the affected organizations for whatever action they deemed appropriate. SNYDER told 01 that if a Q1 investigator had reserv-ations concerning the scoping of an investigation, he could call Q1 and make an allegation. These opposing perspectives on the mission of Q1 led to allegations made to the NRC that KG8E management was covering up employee concerns.
As this NRC investigation progressed, it became evident that the individual investigators believed they had maintained the integrity and completeness of their investigations regardless of their personal opinions on how Q1 should f unction. Individual investigators who insisted upon detailed thorough investigations and/or detailed documentation of their investigations were not prohibited by Q1 management from exercising this prerogative. As a result, in most instances, those investigators most critical of SNYDER's changes to the Q1 program were the same investigators who reported the vast majority of the significant investigative findings, this 1.e:cstination established that after SNYDER assumed supervision of Q1 significant numbers of tales were clated with superficial investigative effort and transparent 1v 1Wt;d documentation, all of wnten was accepted by Q1 i m.,nton, bi.w r there was no evidence to suggest wholesale discarding of allegations. This point was = M.tished by the fact that the individual
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investigators were able to recall s pecific investigative 6tidt; h a-ac t b cally every investigation they had seen assigned.
j This investiaetion did not substantiate that SNYDER's supervision of the program resulted in the decrease in the number of allegations nede to Q1. It was established, however, that exit interviews were sumarized in one or two sentences which ratutt*d in Pehibitively little information for the Q1 investigators to use in pursuing their investigations. This led to meaning-less investigations and premature closures of issues which merited further investigation.
Many of the investigators interviewed expressed ue belief that other investi-gators had their investigative conclusions changed by Q1 management, but theirs had not. This investigation established that SNYDER changed the investigative conclusion that RUDOLPH, the QC Manager, had blackballed an employee for a job at Arizona Public Service and that SCOTT and SNYDER had refused to accept significa t i vestigative findings relative to problems in the CAR program reported b 1D This NRC investigation identified a trend in Q1's handling of wrongd ing allegations which became issues before the DOL or Kansas Department cf Human Resources. Q1 essentially dropped these issues as Q1 concerns. The utility chenged its posture in these instances from investigating the merits of the case No. 4-86-004 120
allegation to assisting Legal in preparing for potential litigation. These wrongdoing issues were nu investigated for their potential adverse impact on the safety of the plant. Also, wrongdoers identified in Q1 investigations rarely experienced repercussisns as a result of Q1 findings against them.
Little evidence was obtained in the majority of the cases to indicate any attempt by Q1 management to change investigative conclusions. There were instances when substantiated allegations were listed in the Q1 files as having no merit. Nevertheless, this information was referred to the affected organizations for their consideration even though Q1 management believed the "no mertt' designation indicated that no corrective action was necessary.
There was evidence which indicated that some Q1 investigators were removed from t Q1 as a result of their a ressive investigation, as s
in the case of thei e to ing the scope of 7.V investigations as ses o a
the unwillingness to accept their i*.vestigative fin ngs, as e ca o
It is conc 1*:ded that these transfers and terminations reflect more curately a conflict between the investigators' and management's perception of the mission of Q1.
When SNYDER became manager of Q1, a number of procedural changes were made in Q1. However, the more significant changes were in the area of policy, such as wrongdoing issues referred to Legal and dropped by Q1. Also the sumarization of Q1 interviews into one or two sentences which eliminated most of the necessary detail available to investigators for a meaningful investigation.
The policy change with greatest impact was SNYDER's requirement that investi-gations remain within the parameters of the original allegation and the prohibition that investigations not be expanded.
SNYDER, who earlier in his career had been responsible for the internal pipe cleanliness pregram at WCGS, expressed the opinion that it was unnecessary for Q1 to continue to investigate pipe cleanliness allegations because of the the existence of a generic NCR regarding this issue. SNYDER's resolve to not further evaluate existing or future concerns relative to this issue was inconsistent with the objectivity necessary in an effective and meaningful investigative program.
This investigation established that drug allegations made to Q1 were referred to Security through the licensee and contractor project managers. These allegations were not investigated but merely viewed as an additional source of information for Security to consider in its limited response to drug use during this period in time.
This investigation did not establish any instances when allegations were discarded or ignored by Q1. This investigatien did establish, however, that the allegations were strictly focused in the narrowest sense on just the concern raised by the individual. In many instances, particularly late in the program, the investigations were transparently limited in content.
superficial, and essentially meaningless. This was inconsistent with the i
original intent of Q1 as a self-policing investigative program.
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Case No. 4.B6-004 121 7 p/
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Agent's Conclusion r
Despite substantial shortcomings identified in the Q1 program, it is concluded that the evidence gathered does not substantiate wrongdoing on the part of KG4E management in their conduct of this voluntary program.
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Exhibit No.
Description
.1 Transtript of Charles HIL', June 27, 1986 2
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20 Transcript of John JOHNSON, hay 15, 1987 I
21 Transcript of Robert L. SCOTT, June 3, 1987 1
22 Transcript of Charles SNYDER, May 12, 1987 j
23 Transcript of Glenn L. K0 ESTER, May 13, 1987 g
l 24 Q1 Allegation Master List i
25 Q1 Allegation Computer Printout 26 William Ward's Evaluation I
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ACRONYMS USED IN REPORT l
AE architect / engineer ANO Arkansas Nuclear One i
ASLBP Atomic Safety and Licensing Board Panel AWS American Welding Society i
CAR Corrective Action Reports COC Certificate of Compliance DIC Daniel International Corporation t
.j 000 Department of Defense t
00L Department of Labor
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EBASCO Ebasco Service, Inc.
ETR Etch Test Reports FSAR Final Safety Analysis Report GAP Government Accountability Project 14C Instrument and Calibration Group INP0 Institute of Nuclear Power Operations J
KG&E Kansas Gas and Electric Legal KG4E Legal Department l
MSSWR Material Structural Steel Weld Rod i
j NAN Nuclear Awareness Network
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NCR non-conformance report NRC Nuclear Regulatory Consnission 01 Office of Invettigations i
j Q1 Quality First Program QA Quality Assurance QC Quality Control a
Case No. 4-86-004 125 4
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QFAR Quality First Action Request i
t QF0 Quelity First Observations I
i QPV Quality Program Violations i
Security Site Security Department SFR startup field reports TMI Technical Metals, Inc.
TSL Technical Support Lead TVA Tennessee Valley Authority WCGS Wolf Creek Generating Station WCNOC Wolf Creek Nuclear Operating Corporation h
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Case No. 4-86-004 126
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ormati:n REPORT OF INTERVIEW f04 M
f-WITH JOHN JOHNSON i
l On May 15, 1987 JOHNSON. the KG&E Chief of Security (Security) for the Wolf Creek Nuclear Operating Corporation (WCNOC), was interview by NRC Investigator H. Brooks Griffin at Wolf Creek. JOHNSON said he had been the Chief of g)askedhimtoconductcrimi-Security for seven years, JOHNSON said that in 1984 nal record checks on ten supery sors a pers who had been named as drug users in an allegation ude to Q1. JOHNSON said he conducted the j
criminal ks but none of the ten had criminal records. He said he notified of the negative dv d s. JOHMSON said that his security group con ucte no nyestigativo activity on this allegation.
JOHNSON said it was his understanding that Gary FOUTS (KG4E) or Forrest RHODES (DIC) received the drug allegations from Q1. JOHNSON said FOUTS generally referred these allegations on to Security. JOHNSON said there had been occasions when Security had received drug allegations directly from Q1.
JOHNSON said that as of late 1984, he had no instructions from his superiors to investigate Q1 drug allegations and had no requirements to recontact Q1 with the results of any use Security made of the referrals. JOHNSON said that eventually FOUTS requested femal replies to drug allegations which FOUTS had referred to Security.
JOHNSON said the drug information received from Q1 was used to supplement information Security developed independently. JOHNSON said there had been occasions when searches of vehicles and the power block were conducted as a result of infomation received from Q1. JOHNSON also said that employees had been terminated as a result of drug investigations conducted by Security.
JOHNSON said FOUTS eventually requested for formal feedback from Security documenting how the Q1 drug information was used. JOHNSON said he had prepared handwritten responses to FOUTS. JOHNSON said he believed there may have been instances when Q1 used his written responses to close out their files.
JOHNSON said that because Q1 had granted confidentiality to allegers. Security was not allowed to recontact the allegers to gain additional information.
JOHNSON said that during this period in time. Security did not have drug testing progras on site. JOHNSON said that when Security received a single source of information about employee drug use, they generally did not respond to it. JOHMSON said that if a second independent source was developed, they would usually investigate the information. J0 mSON said he also exchanged information with the local sheriff's department and had, on occasion, used dog i
searches to locate drugs on site. JOHNSON said that esployees were not terminated unless drugs were actually found.
JOHNSON said that the drug testing program on site was not initiated untt) l 1936, and said that approximately a dozen employees may have been terminated
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for drug related activities. JOHNSON said he believed that maybe half of these terminations were the result of information referred by Q1. JOHNSON said that if individuals terminated for drug use were determined to have j
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Worked in Quality or safety-related areas, an effort was made to determine whether there were secondary sign-offs or reviews of their work. JOHNSON said it was his understanding that if there were no secondary reviews, the terminated employee's work was reinspected.
DATE PREPARED IN DRAFT FROM NOTES TAKEN DURING INTERVIEW:
May 15, 1987 l
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