ML20204E882
| ML20204E882 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/11/1987 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| WM-87-0080, WM-87-80, NUDOCS 8703260090 | |
| Download: ML20204E882 (3) | |
Text
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NUCLEAR OPERATING CORPORATION f
March 11, 1987 Mr. R. D. Martin, Regional Administrator U.S. Nuclear Regulatory Comission P 1 14ARIIIW 1
Region IV
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611 Ryan Plaza Drive, Suite 1000 aO-i Arlington, Texas 76011
_J Letter: WM 87-0080 Re:
Docket No. 50-482 Ref:
Letter dated 1/30/87 from JEGagliardo, NRC, to BDNithers, NCNOC Subj:
Discussion of Region IV OI Investigation Results
Dear Mr. Martin:
The purpose of this letter is to discuss the results of investigations performed by the Region IV NRC Office of Investigations (OI) and documented in the reference.
The reference transmitted a synopsis of the results of four investigations conducted during the period of March 5 to August 25, 1985 concerning potential wrongdoing at Wolf Creek Generating Station.
Each of these cases of alleged wrongdoing had been reported to and investigated by our Quality First Program.
In three of the cases, the OI Investigator stated that the Quality First investigation was not conducted in a manner that would meet acceptable investigative standards of the Nuclear Regulatory Comission (NRC).
The Quality First investigative standard is to conduct objective investigations of definitive concerns with consideration given to all available information. Concerns expressed are expected to be presented with accuracy and to a level of detail that will permit conducting a focused and meaningful investigation and gathering of credible facts - not opinions or second hand information.
Received concerns are evaluated prior to investigation and categorized as either a Quality issue (includes technical safety-related, QA program, controlled substance abuse, intimidation / harass-ment / discrimination of protected individuals and other wrongdoing) or a Functional issue (includes personnel health and safety, cost / scheduling, management practices / policy not related to plant safety or quality and miscellaneous security items such as misuse of company property or theft).
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An Equal opportunny Employer M F HC% ET
r NM 87-0080 Page 2 As a result of the reference letter, the Quality First Program has been reviewed to identify any generic weaknesses.
We are confident that the following changes incorporated between early 1985 and the present have significantly strengthened our program.
o For concerns investigated by other organizations, investigations must be properly documented and conclusions justified to the satisfaction of Quality First, which is ultimately responsible for the closure of all concerns on the basis that meaningful investigations were performed and support the conclusions, o
Potential wrongdoing has been defined and wrongdoing concerns determined to have merit require NRC OI and Resident Inspector notification.
o Quality First responsibilities include the preparation of concern trend reports which indicate the quantity of concerns substantiate 3, unsubstantiated, and open for each category of con wrn.
Although the four synopses represent very old cases which had no effect on the quality of Wolf Creek Generating Station, there is the inference that the Quality First Program is flawed.
It should be noted that Wolf Creek Nuclear Operating Corporation (NCNOC) was not notified of the results of these investigations until the reference letter was received and Wolf Creek Nuclear Operating Corporation was given no opportunity to discuss the results with the investigator or NRC Management.
WCNOC believes there are significant errors in the synopses of the OI Investigations.
Although the four identified cases are quite old and little can be gained from further review of the specific cases, there is a need to review discrepancies which affect the conclusion reached by the Quality First investigation.
Specific concerns with the OI Investigations which have led to incorrect evaluations include:
(a)
Allegation of falsification - It should be noted that the records allegedly falsified were not Quality Assurance inspection records, they were completed in accordance with existing procedures and no falsification of records occurred.
(b)
Allegation of discrimination - This particular case involved a clerical person and was not investigated as a quality issue.
The OI investigator followed up on information from a Quality First interviewer and did not comunicate with the investigator of the case.
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. ;, g WM 87-0080 Page ~ 3 (c) Allegation of use of marijuana and/or cocaine - 'Ihe person who made the allegation regarding this offsite activity made three different'and conflicting allegations.
Based on the consistent parts of the allegation and a determination that the alleged witnesses were not witnesses but only additional people with information, there was not a case that could be pursued.
We would like to have the opportunity to review the details of. these cases with those involved in the investigation. We further recommend.that, prior to placing material such as this in the public document room, the facts of the cases be reviewed with Licensee management to ensure that the facts are correct.
Very truly yours,
__ A Bart D. Withers President and Chief Executive Officer BDW:jad cc: PO'Connor JCumins