ML20209B405
| ML20209B405 | |
| Person / Time | |
|---|---|
| Issue date: | 01/09/1985 |
| From: | Fitzgerald J NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Hayes B NRC OFFICE OF INVESTIGATIONS (OI) |
| Shared Package | |
| ML20209B334 | List: |
| References | |
| FOIA-85-101, FOIA-85-A-42 NUDOCS 8702040033 | |
| Download: ML20209B405 (2) | |
Text
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SUBJECT:
REPORTABILITY OT WRONGDOING TO NRC ,
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Comissioner Roberts 2 able to adopt the licensee's report subject to a strict quality control review which could include selective verification or corroboration by 01.
Consequently, I accepted the invitation extended by Mr. Charnoff $nd the Kansas Gas and Electric (KG&E) Vice President - Nuclear who made the necessary arrangements. Two senior members of my staff and I visited WCGS in mid -
September 1984 where we received a briefing from KG8E officials and employees of the investigative group established at WCGS. This group is called, Quality First (01). I was pleased with the courtesy extended to me and I found the briefing very useful. I did develop some misgivings that I felt had to be resolved before I could make any decisions regarding accepting the licensee's work product.
Accordingly, I charged a senior menber of my staff, Bill Ward, to initiate an evaluation of the KG&E investigative program. I asked him to explore all aspects of it, and review such records and conduct such interviews as would be necessary for a thorough programatic evaluation. At the same time, I ins-tructed him not to become involved in specific investigative matters although I certainly expected him to remain alert to any he might encounter during his evaluation. I also asked him to be prepared to brief me in detail and to provide a written report.
Bill made two trips to Kansas in September and October 1984 during which he visited WCGS twice and KG&E Corporate Headquarters once. This endeavor was with the full knowledge and cooperation of KG&E. He was granted full access to all records he requested. He interviewed a wide variety of persors ranging fror senior corporate officials to craf t and contractor personnel. Some of the interviews that he conducted were at the request of the interviewees who apparently availed themselves of the opportunity to register concerns or express misgivings to an NRC investigator. All of these steps were in my view necessary and relevant in order to perform a useful program evaluation. This evaluation consumed about seven infield staff days.
Bill provided a memorandum documenting his findings and opinions regarding the KG&E investigative program. I have previously given a copy to the Staff, and am now enclosing a copy (enclosure 1) for your infortnation as it may help to place in context our activities at WCGS. I have not yet reached any conclu.
sions regarding WCGS, nor am I offering Bill's memorandum and views as any-thing other than a centexting document.
You will note that one of the issues raised by our review was whether a licensee or applicant has a duty to notify the NRC of alleged wrongdoing.
We subsequently raised this question to the Office of General Counsel. 1 .
have enclosed our menorandum and their reply (enclosure 2) for your infor-mation. .
This, then, is how we ended up at WCGS. We were not there to detennine the lictnsce's compliance with NRC requirements per se. Rather, we went there both to attempt to resolve a problem in a non adversarial manner and to explore a creative partial solution to our chronic resource shortfall.
Because of the latter, I plan to evaluate two other investigative prograns b