ML20235K130
| ML20235K130 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/17/1985 |
| From: | Driskill D, Herr R NRC OFFICE OF INVESTIGATIONS (OI) |
| To: | |
| Shared Package | |
| ML20235J982 | List: |
| References | |
| FOIA-86-59 Q4-85-022, Q4-85-22, NUDOCS 8707160165 | |
| Download: ML20235K130 (7) | |
Text
'
Title:
WOLF CREEK GENERATING STATION:
ALLEGED HARASSMENT AND INTIMIDATION AND TECHNICAL CONCERNS OF FORMER DANIEL INTERNATIONAL CORPORATION EMPLOYEE Licensec:
Case Number: Q4-85-022 Kansas Gas and Electric Company Report Date: October 17, 1985 P. O. Box 208 Wichita, Kansas 67201 Control Office: 01:RIV Status:
CLOSED INQUIRY Reported by:
Approved by:
d[
D. D. DFisTill, Investhator R.
K'.
Herr, Director Office of Investigations Office of Investigations Region IV Region IV Participating Personnel:
L. N. Robinson, Investigator. 01F0, RII 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 "0FFICIAL USE ONLY."
I information in this record was deleted in accordance with the f re6 dom of Informallon Act, exem tions 10 E01A.
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71 5 970710 STEPHENS86-59 PDR
1 s
DETAILS OF INQUIRY PURPOSE OF INOUIRY The purpose of this inquiry was to clarify and obtain amplifying cetails ns of a former Daniel International Corporation (DIC) e,)
Wolf Creek Generating Station (WCGS), which were provided to the Nuclear Regulatory Comission (NRC) by the Government Ac-countabili Project, Washington D.C.. The in ial allegations provided by the former were as s jected to harassment and intimidat p oyment at WCGS personal concerns relative to the sa ety of some aspects of pipe upport (hangers) and piping installations at WCGS.
BACKGROUND On May 16,1985, Ben B. HAYES, Director, Office of Investigations, NRC, received a letter from Billie Pirner GARDE of the Government Accountability Project (GAP), Washington, D.C., which transmitted, as enclosures, a letter to the NRC Commissioners, an analysis of NRC's March 11, 1985, response to the isolation and resolution of the ructural steel weld deficiencies at WCGS and an April 27, 1985, affidavit of l
(confidentiality 70 granted - see conditions relate n paragrap The GAP letter and its enclosures (Exhibit 1) was forwarded to the NRC Office of Investigations l
Field Office, Region IV.
01: liq additionally forwarded a copy of Exhibit (1) to the Office of Investigation Field Office, Reg conduct further i erview of to regarding place of employme
, and WCG,
place of 7D employme Apri
, 1985 affidavit relat at WCG from l
S alizin nd ng pressure and harassment" employment at WCGS.
supervisors and DIC management ignore reported in-stances o rave er d screpancies which were caused int onall py circum-vention of procedures and by " outright falsification."
that management covered up these problems to avoid delaying eir sche M es.
Based on the lack of specific d n
that F0, Region II, intervie affidavit, it was requested lifying information relative n
alle
~
nd an infonnatio
)
within DIC possess relative to problems On September 3,1985,
'was i tigator, Larry H. ROBI $0h at NRC inves-NRC confidentiality agreement, Exhibit n
7 m
1 during any NRC investi a ion /
inspection.
was specifically uestioned relative
- 4pril25, 1985, af fida it whi forwarded to the NRC by representatives of GAP.
A transcript of the interview is Exhibit (3).
related in the Hanger and pi g
rou IC at WC from
)
~
that the preparation of travelers or pipin anger insta ation i lved the review of existing piping u d hanger package documentation and drawings. M.the reviews of this associated
{
documentation frec ent
~ulted in the identification of errors in documents
)
and/or drawings J
tha the DIC su ervisor ersonnel frequently i
ignored the problem areas
.other brought to their attention.
identifiedoneinstanceg believed a traveler discrepancy was caused intentionally as a resu o a supervisor's circumvention of procedures and " outright falsification" of records (ibid, pages 19-27, and pages 127-133). M. stated the " falsification" was the supervisor's failu to modify traveler to include pertinent data known only to him.
related the discrepancies in this traveler package were identified and 1
a corrected prior to the issuance of this traveler.
j In one instance was told by a supervisor to ignore field l
ests Rs preparation of travelers (ibid, page 31),
foun that D piping and hanger engineers would not follow proce res when preparing travelers for issuance (ibid, page 33).
M relat nt with DIC at WCGS M experienced many prob lations or DI management and engineers to interf ith.
rienced problems with ersonnel records, performance eva uations.
W-2 (tax with-holdt records, and promot ons, while working at WC ibid, pages75-117 ons d these problems to be harassment supervisors and DI management.
did not provide any specific informa on relative to this perceived ha sment, nor evidence that thes individually or in a conspiracy were intentionally direct
'also did not provide any information which would indicate ing int ated by supervisors or management.
i discussed view that DIC management a " lack of integrity"
~ ibid, age 139).~ Without providing details, hat " excessive numbers of hardware and paperwork discrep s were b ng discovered afte field acceptance" (ibid, pages 138-139),
additionally discussed what believed to have been the harassment er DIC employees by DIC superv's on and management (ibid, pages 142-146).
. statement regarding the alleged harassment of coworkers was general in na ure and did not include specific evidence or adequate details that would corroborate pinions.
Closure Information This report of inquiry is provided to NRC, Region IV, for evaluation of technical matters reported byM.- In view of (1) the lack of evider relative to the percei arassment and intimidation, (2) the voluntarily terminated employment with DIC at WCGS, and (3)
.was
~
i i
re-employed by DIC her investigation of this allegation is meri suspicion regarding falsification of a record was identified and correc prior to the issuance of the record, no further investigation is carited.
This matter is closed.
LIST OF EXHI8ITS Exhibit No.
Description 1
GAP Letter with Enclosures, dated May 15, 1985 2
Confic'entiality Agreement, September 3,1985 3
Transcript of Interview of September 3,1985 o
/
/
1 j
g0' CONFIDENTIALITY AGREEMENT p
i (Original to source of information, NRC to retain signed copy of duplicate original) i I have information that I wish to provide in confidence to the U. S.
uclear Regulatory Commission (NRC).
I recuest an express pledge of confidentiality as a. condition of 1
providing this information to the NRC.
I will not provide this information voluntarily to I
the NRC without such confidentiality being extended to me, i
It is my understanding, consistent with its legal obligations, the NRC, by agreeing to this confidentiality, will adhere to the following conditions:
(1) The NRC will not identify r.e by name or personal identifier in any NRC initiated document, conversation, or communication released to the public which relates directly to the
)
information provided by me.
I understand the term "public release" to encompass any distribution outride of the NRC with the ' exception of other public agencies which may reqv re this information in furtherance of their responsibilities under law or public trust.
(2)
The NRC will disclose my identity within the NRC only to the extent required for the l
conduct of NRC related activities.
)
' (3)
During the course of the incuiry or investigation the NRC will also make every ef for:
~ consistent with the investigative needs of the Commission to avoid actions which.would
- clearly be expected to result in the disclosure of my identity to persons subsequently contacted by the NRC. At a later stage I understand that even though the NRC will make l
every reasonable effort to protect my identity, my identification could be compelled by l
orders or subpoenas issued by courts of law, hearing boards, or similar legal entities.
In such cases, the basis for granting this promise of confidentiality and any other relevant f acts will be communicated to the authority ordering the disclosure in an ef fort to maintain my confidentiality.
If this effort proves unsuccessful, a representative of the NRC will attempt to inform me of any such action before disclosing my identity.
I also understand that the NRC will consider me to have waived my right to confidentiality if I take any action that may be reasonably expected to disclose my identity.
I further
)
understand that the NRC will consider me to have waived my rights to confidentiality if I i
provide (or have previously provided) information to any other party that contradicts the I
information that I provided to the NRC or if circumstances indicate that I am intentionally providing false information to the NRC.
l Other Conditions: (if any) I (o#S/N7-M 7N S d.rE # A##M M M l
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I have read and fully understand the contents of this agreement.
I agree with its provisions.
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INVESTIGATION STATUS RECORD 1
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Office of Investigations E
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y Vl400m x oT=tm Asoc~< o to suen c' WOLF CREEK:
ALLEGED HARASSMENT & INTIMIDATION DRISKILL AND TECHNICAL CONCERNS OF FORMER DIC EMPLOYEE I
STATUS (Soncity date. and promnr a bne! deecreten)
On A
tor, 01 received from GAP the affidavit of a former WCCS DIC who alleged harassment and intimidation and various technical l
concerns GS.
This correspondence was forwarded to OIF0:RIV for apprisal of Region IV and to OIF0:RII for an additional interview of alleger to obtain details l
concerning the allegations. On Sept. 3, 1985, 01F0: REG.II investigator interviewed the alleger to obtain specifics. On Sept. 17, 1985, OIF0: REG.II hand delivered this transcript j
to OIFO:RIV. OIFO:RIV reviewed the transcript for specific example of wrongdoing.
No l
specific vrongdoing issues were identified. This transcript will be provided to staff of Region IV.
Repott of Inquiry is in typing.
ECD: 10/85 l
DATE:
Oct. 31, 1985 - This case is closed.
Inquiry report was sent to Regional Administrator on 10/17/85.
l i
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o January 27, 1986 nucear owomness networc 1347% massachusetts. laurence, kansas 66044.(913)749-1640 FREE,00M OF INFORMATION Director ACT REQUEST Office of Administration FCE A -[4 -N US Nuclear Regulatory Commission h h /M 9-N Washington, D.C.
20555 FREEDOM OF INFORMATION ACT REQUEST To Whom It May concern:
i Pursuant to the Freedom of Information Act, U.S.C.
522, as amended, the Nuclear Awareness Network requests the following documents regarding the Wolf Creek Nuclear Generating Plant.
Please consider " documents" to include reports, studies, test results, correspondence, memoranda, meeting notes, meeting,
minutes, working papers, graphs, charts, diagrams, notes and summaries of conversations and interviews, computer records, i
and any other forms of written communication, including inter-nal NRC staff memorands.
The documents are specifically re-quested from, but not limited to, the following offices of the NRC:
Office of Analysis and Evaluation of Operational Data (AEOD); Office of Nuclear Reactor Research (NRR); Office i
of Nuclear Regulatory Research (Research); Office of Inspection and Enforcement (I&E); Office of Investigations (OI); Generic Issues Branch of the Division of Safety Technology, and the Operating Reactors Branches of the Division of Licensing.
In your response, please identify which documents correspond to which requests below.
Pursuant to this request, please provide all documents prepared or utilized by, in the possession of, or routed through the NRC related to the Wolf Creek Nuclear Generating Plant:
- 1) Any and all information within the Office of Investigation's cases regarding investigations which have occurred and/or closed within the time frame of August 20, 1985 and the receipt of this letter.
This request extends to any and all documents from any other NRC offices which may have been in-volved in any way, or have information pertaining to any OI cases.
- 2) Any and all, Quality First files, or portions of files, within the NRC's cont'rol and or possession.
j
_t_
I i
If any of the material covered by this request has been des-e 1
troyed and/or removed, please provide all surrounding docu-I mentation, including but not limited to a description of the action (s) taken, relevant date(s), and justification (s) for the actions.
l For any documents or portions that you deny due to a specific FOIA exemption, please provide an index itemizing and describing l
the documents or portions of documents withheld.
The index should provide a detailed justification of your grounds for I
claiming each exemption, explaining why each exemption is rele-i vant to the document or portion of the document withheld.
This index is required under Vaughn v.
Rosen (I), 484 F.2d 820 (D.C. Cir. 1973), cert. denied, 415 U.S. 977 (1974).
l We look forward to your response to this request within ten,
days. We further request that a copy of your response to this FOIA be placed in the Kansas Local Public Document Rooms (LPDRs).
I Sincerely, t
Stevi Stephens l
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GOVERNMENT ACCOUNTABILITY PROJECT j
1555 Connecticut Awnue, N.W., Suite 202 U S lEC Washington, D.C. 20036 (202)232-8550 135 MAY lB PM 12: 54 May 15, 1985
^7 ;( r [iE.',i' ' '
I
[,igTE Ei.,
The Honorable Nunzio Palladino, Chairman Commissioner James K. Asselstine Commissioner Frederick Bernthal Commissioner Thomas Roberts Commissioner Lando Zech Daar Commissioners:
On behalf of the Nuclear Awareness Network (NAN) the Government Accountability Project (GAP) hereby files a request pursuant to 10 C.F.R. 2.206 regarding the Wolf Creek nuclear power plant now operating at low power near Burlington, Kansas.
s 5
This request results from the continuous failure of the Nuclear Regulatory Commission (NRC) staff to address serious safety allegations in a manner which can assure that the Wolf Creek facility can operate above 5% power without endangering the public health and safety.
i At a recent Commission meeting regarding the Near Term Operating License (NTOL) Plants the Commissioners were advised on the status of the Wolf Creek plant and the various staff investigations and inspections.
Unfortuantely that briefing was neither complete nor accurate.
This request seeks to insure that the staff is required to review and also to report publicly on the full scope of safety significant problems at the Wolf Creek plant prior to the Commission granting full power operation.
Since NAN and GAP have had a continuous dialogue with the staff, particularly the Office of Nuclear Reactor Regulations, for some time we had hoped that formal legal measures would not be necessary.
Unfortuantely for all parties, the staff has affirmatively refused to acknowledge the serious ramifications of saftey problems at the plant.
In other words, this 2.206 is not based on what the Commission would prefer to regard as late-filed allegations, but instead on the inadequate handling of hardware and quality assurance information known to the staff.
{l-
~~
l
2-Specifically, the Staff through Region IV has refused to take possession of and pursue the allegations that have been provided through the Kansas Gas and Electric Company (KG&E)
Quality First program.
(The Quality First program is the utility company's allegation finding initiative program.)
Since the program was widely popularized as being a progressive and totally independent ef fort GAP has channelled workers with quality concerns to the program.
It is now clear, through the monitoring of several of the safety related allegations, that neither the
)
company nor the NRC are going to resolve those problems.
For example, contained in the Quality First files (referred to as "Q-1 files") are the statements and supporting information from over 240 individuals who have expressed over 700 safety significant concerns.
It is our understanding that not only has the Licensee ignored or buried the serious concerns of the members of the workforce, but so has the Nuclear Regulatory Commission's task force on Wolf Creek.
The staff reported to the Commission that there were only nine allegations under review at the plant.
That may be technically accurate, but in reality the staff has knowledge of several hundred allegations which it has steadfastly refused to take regulatory possession of or to monitor or to enter into the NRC's allegation tracking system.
This has allowed the staff to inaccurately present a picture of a plant without serious safety deficiencies.
since the staff has refused to take possession of the files and assure the Commission and the public that the allegations contained in these files have been adequately resolved, GAP and NAN have recontracted the workers in order to take affidavits relative to their concerns.
Under seperate cover today the first af fidavit of workers who have raised concerns in vain to site management has been forwarded to the Of fice of Investigations for their review.
We have also requested that the Office of Investigations open an inquiry into the allegations of deliberate management mishandling of the Quality First program.
Additionally, attached to this letter is a copy of NAN's Analysis and Comments on the Nuclear Regulatory Commission's March 11, 1985 Response on the Isolation and Resolution of the Structural Steel Weld Deficiencies at Wolf Creek which NAN has provided to the members of both federal and state officials who have demonstrated an interest in the safety of the Wolf Creek plant.
______ _ _- o In conclusion GAP requests that the Commission
- 1) require the Staff to take possession of the Q-1 files and provide to the Commission and the public the analysis of why the significant safety related deficiencies identified for the past year by members of the workforce do not pose a danger to the public health and safety,
- 2) conduct an inquiry on the ramification of the collective safety significance and/or adequacy on the quality assurance program in the light of the information contained in i
the Quality First files, and l
l
- 3) require an explanation from both NRR and Region IV as to why they allowed the allegations to be exempt from the regulatory analysis for determination of safety significance.
- 4) request OI conduct an investigation into the compromising of the Quality First program by William Rudolph, site QA Manger.
Mr. Rudolph was originally respons1 Die Ior the resolution of allegations made against the QA program which he supervised.
He currently is responsible for the resolution of Quality First Observations (QFOs), discrepancies identified in the course of Q1 investigations.
We look forward to ao early response.
Respectfully submitted,
%~
e Billie Pirner Garde Ci s Clinic r ctor Robert Guild, Esquire Staff Attorney 410 Stevi Stephens Director of Nuclear Awareness Network l
1
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35 gn is PH 12: 54 n
.....c nucear - QWoreness5 networc 1347% nnsscdusetts. burence, kcnso,s 66 044.(913)749-164 0 ANALYSIS AND COMMENTS ON THE NUCLEAR REGULATORY COMMISSION'S (NRC) MARCH 11, 1985 RESPONSE ON THE ISOLATION AND RESOLUTION l
OF THE STRUCTURAL STEEL WELD DEFICIENCIES AT WOLF CREEK.
}
On March 3, 1983 the NRC imposed a $40,000.00 civil penalty on Kansas Gas and Electric (KG&E) for failure to adequately 3
control activities affecting the quality of safety-related work.
Specifically, the Borated Refuling Water Storage (BN) 6 System and the Auxiliary Feedvater (AL) System were turned over from the construction contractor, Daniels International j
Corporation (DIC) and accepted by KG&E start-up organization I
on October 28, 1982,.and November 23, 1982 respectively.
This l
followed final Qualihy Assurance (QA) checks with quality documentation in which hardware (actual "in the field") dis-crepancies were not listed. The NRC's evaluation of this I
incident was that "the aspect of [KG&E's] QA program which should have assured that systems and documentation deficiencies vere identified, tracked and resolved has broken down."
l 1
i The NRC places great emphasis on the need for licensees [KG&E]
to " implement a QA program that identifies and corrects con-struction deficiencies in a timely manner."
- However,
" based on a review of the circumstances surrounding this violation
[the NRC] determine [d] that [KGLE's] untimely notification of the conditions under the reporting criteria of'10 Code of l
Federal Regulations 50.55(e) (50.55e) was also a violation."
l The NRC insisted that KG&E's actions should include a
"...re-view of related Quality documentation", that KG&E's " response should also address measures taken or planned to ensure that
[their] QA procedures are adequate..." and that " appropriate documentation [be] available. "
To prevent recurrence of such a violation, KG&E established i
a Quality Documentation Review Task Force on January 20, 1983.
A corrective action program was subsequently submitted to l
Region Four NRC (RIV) on March 2, 1983.
Among KG&E's commit-I ments to the NRC were " implementation of organizational and personnel changes that should improve quality" and a "documen-tation review which will be expanded to include additional detailed review of those areas where documentation deficiencies have been experienced."
More specifically, in KG&E's January 13, 1983 inter-office memo (KWCLC-2403) Gary Fouts, KG&E Construction Manager, informed Luther Warrick, DIC project Manager, of the estab-lishment of a Task Force to investigate and review documen-tation due to " concern about completion and accuracy of, the turnover Quality documentation and backup Quality docu-mentation" and that "the concern of the review of both groups j
of documents has been somewhat substantiated by the recent i
KGLE QA surveillance of the BN system."
l The NRC disclosed that these late 1982 KG&E audits " revealed l
numerous documentation deficiencies that were carried on a list separate from the systems exception list.
This separate list was referenced on the exception list as a single line entry to ' resolve discrepancies with the BN travelers.'
The exception list stated that the traveler [ documentation] dis-crepancies were cosmetic and did not affect hardware.
Your
[KG&E] audit, however, discovered that some hardware dis-crepancies (lack of heat numbers) were included in this dis-I crepancy list.
The scope of the problems discovered in this l
audit were discussed during the enforcement conference on 1
February 18, 1983." [ Minutes from this meeting should be j
requested.]
1*
l.
Luring the approximate time frame of January 1983, a Special Projects Group under the direction of Craig Moring as " piping l
document co-ordinator" was given authority through a KG&E inter-office memo to ",fix travelers".
Jim Tweedy, " traveler review lead" in piping and hengers, was assigned two engineers and two clerks to check the documentation.
Inquiries should I
l be made as to the exact identity and function of these persons i
l and organizations, what occurred within these organizations i
after the discrepancies in the BN system were discovered, and I
I why the discrepancies within the BN system were considered l
unique.
l "Due to potential deficiencies in the Wolf Creek Quality pro-grams", KG&E submitted a letter (KMLNRC 83-019) outlining a Systems Turnover Quality Action Plan and delineating the commitments made by KG&E to RIV.
Among these:
- 1) "To assure that KGLE construction and startup personnel will conduct a complete walkdown of all future safety-related systems."
4
- 2) "As a tool to monitor the effectiveness of the DIC and KGLE j
l turnover verification reviews, KG&E QA vill perform a sur-1 veillance of each safety-related system after the formal I
systems turnover."
3)
"A management audit by an outside firm will be performed of both DIC Quality and KG&E QA organizations" which.vas expected to be completed by the end of August 1983. [This independent audit should be requested and reviewed.)
- 4) "As a related matter, the KG&E procedure for reporting 4
l 50.55e deficiencies will be revised to clarify responses."
[ Implementation of this procedure was reported closed out in Inspection Report 50-482/83-11 on May 20, 1983.)
b t
O
The Combined Review Group comprised of KG&E and DIC employees
' was established as an additional quality check point to provide final Quality construction documentation review.
This group has issued status reports for all of the weeks within the months of November 1983, December 1983, January 1984 and the first week of February 1984.
[ As DIC contends that this group was responsible for discovering future documentation dis-crepancies, these status reports should be requested add re-viewed for information pertaining to the Structural Steel Weld deficiencies which arose.]
In the early spring of 1984, KG&E developed its Quality First (Q1) program to receive, evaluate and resolve Quality concerns from workers at the Wolf Creek site.
All workers are required to be processed through Q1 before leaving the site and to sign a statement revealing any Quality concerns.
In essence, worker allegations related to safety are contained within Ol's case files.
Of the thousands of exit interviews conducted, j
KG&E has established approximately 250 case files which in-clude their investigations and resolutions of employee safety allegations.
Until September of 1984, Q1 was under the direction of William Rudolph, also KG&E QA site Manager since April 20, 1983.
- Thus, employees relayed allegations to 01, which were a direct re-
~
flection against QA, to the QA Manager.
When the NRC inspected Q1 in September of 1984, it found that processing of wrong-doing concerns (i.e. drugs, alchohol, intimidation, harassment, discrimination, falsification of documentation) was particu-larly deficient, infonnational flow had no feedback mechanism for wrong-doing concefns directed to Security or KG&E manage-ment, which may include technical deficiencies.
Nor was there any feedback mechanism from Security or KG&E management re-garding corrective action or disposition of wrong-doing con-cerns for file closecut.
Although the potential conflict of interest under the direction of Bill Rudolph was reduced when his replacement coincided with the NRC's inspection, KG&E management is still in direct control of Q1 with no systematic check or review by any independent body.
In spite of these Quality organizations and commitments by KG&E, they received a disconcerting twenty-one Violations and two Deviations from the NRC during 1983.
These were issued primarily for f ailures within the QA program.
This was more than double the number they had received in 1982.
In 1984 KG&E once again received an inordinate number of Violations and Deviations.
Among the most serious during these two years were violations for intimidation of Quality Control (Q/C) in-spectors occurring in March of 1983.
Another incident in-volving the termination of a OA inspector on August 4, 1983 transpired when the inspector identified "O relared problems with documentation of various safety-related items as well as concerns in the hardware of items."
This information, reported to Bill Rudolph, KG&E QA site Manager, resulted in his decision to terminate this employee.
Yet Rudolph was later put in charge of Q1 processing of worker allegations regarding safety concerns.
. On September 4, 1984 a $64,000.00 Civil Penalty was levied acainst KG&E for intimidation of this QA inspector.
The NRC rated this a Severity Level II violation, the most severe received by KG&E to date.
KG&E now holds the dubious dis-tinction of being the only licensee of a nuclear facility to l
be fined for intimidation of a worker.
This worker was rein-stated in the fall of 1984 and subsequently fired again in January of 1985.
He is now suing KG&E for failure to adhere to the courts orders:
reinstating employee to a comparable position, compensating back wages, posting status of decision on Wolf Creek site, and expunging worker's record.
KG&E is appealing the court's decision and requesting the Fifth Circuit Court's interpretation of the Employee Protection Act be upheld.
In brief, it states that in order for an employee to be protected he must report his concerns directly to the NRC, not to the utility.
Conversely, KG&E contends that the safety allegations of workers are being properly processed and adequately resolved by Q1.
Due to concerns over conflict of interest within KG&E's Q1 managemerA, the NRC's assessment of improper processing of Q1 corrective actions and particularly KG&E's contention that worker alle-gations be directed to the NRC not to them, all 250 case files -
o snould be requested and thoroughly reviewed.
On November 21, 1984, the NRC imposed another Civil Penalty cn KG&E in the amount of $75,000.00.
The penalty was esca-lated $25,000.00 due to the NRC's appraisal of KG&E's failure to correct discrepancies when found.
"Contarary to the [re-i quirements), the inspection program for safety-related Structural Steel Welds (SSW) was not adequately executed to assure conformance to the requirements of construction Pro-cedure QCP-VII-200 Revision 4 and the American Welding Society (AWS) D 1.1-75 Code nor were adequate records kept to document the quality of the welds.
Furthermore, once deficient welds were identified, no actions were taken to correct the deficien-caes."
The chronology of the SSW problems is as follows:
DIC Corrective Action Report (CAR) 29 was issued on March 22, 1983 indicating a f ailure of 148 out of 241 SSW which were randomly reinspected.
A potential 50.55e was reported to RIV on March 23, 1983 and Non-Conformance Report (NCR) ISN 10381pW vas issued.
This NCR dispositioned the defects as " cosmetic" and called for rework on 6 (2.5%) of the velds.
This NCR was closed on August 30, 1983, the potential 50.55e was withdrawn on October 21, 1983 and DIC CAR 29 was closed on October 22, 1983 with the Architect / Engineer ( A/E) disposition: "use-as-is."
Simultaneously, CAR 31 was issued on August 10, 1983 indicating 20% of the Miscellaneous Structural Steel Weld Records (MSSWRs) i were missing.
In August of 1983 NCR ISN 11975CW was issued documenting 42 missing weld records in the pumphouse, even though the discovery of missing records was documented on the NCR on June 30, 1983.
Although KG&E's OA/QC program required MSSWRs to be prepared and retained [0Cp-VII, OP-IV-III, ANSI Code N45.2, Bechtel Spec 10466-0A-1) no 50.55e was reported by KG&E relative to the discovery of missing documentation until a telephqnic report to the NRC on September 18, 1984.
This occurre'd only after the June 11-September 18, 1984 time period " review of OA/QC and 01 personnel qualifications and subsequent inter-views when the NRC inspector became aware of potential prob-lems with DIC CARS 29 and 31."
The NRC immediately called and enforcement meeting with KG&E on October 29, 1984.
By November 21, 1984 the violation and $75,000.00 Civil penalty were issued.
In August of 1983 when NCR ISN 11957CW was issued documenting the 42 missing records in the pumphouse, "KG&E along with RIV NRC performed other inspections", yet the NRC claims to have had no knowledge of the problems with missing documenta-tion until June-August of 1984.
This is a decided discrepancy within the NRC's response.
Also of concern is why a delay of one year occurred before this " clearly reportable 50.55e item" vas reported to the NRC.
Despite the concerns evidenced by CAR 31 regarding documen-E tation discrepancies, CAR 29 which indicated hardware dis-crepancies on the same welds that showed documentation problems, was closed approximately two months after CAR 31 was issued.
Inquiries should be made into why there was no connection made between CARS 29 and 31 by DIC and KGLE Quality management organizations; why KG&E did not issue a 50.55e relative to CAR 31 document discrepancies in August of 1983; why CAR 31 was issued in August of 1983 instead of June of 1983 when the 42 missing veld records were discovered; how these buildings with the MSSWRs could have been turned over and accepted by KG&E from February 1984 onward without CAR 31 being completed and closed; and why CAR 31 was not closed until January 26, 1985 when the corrective action date on it is January 26, 1984.
During the February 27, 1985 KG&E/NRC meeting in Bethesda on the MSSWRs, Richard Denise (RIV) questioned John Berra (DIC) about the reason why these missing MSSWRs did not surface earlier than late 1984.
Berra repiled, " sample NRC inspection done in the summer of 1983 [ occurred] and no deficiencies were found", yet in February of 1983 DIC had performed a random reinspection of Structural Steel fillet velds and in-dicated an unacceptable percentage of welds were defective.
Further, CAR 29 was generated on March 22, 1983 to document these failures.
It indicated 148 out of 241 welds inspected were deficient.
On September 11, 1984, KG&E and DIC informed the NRC that there were no records for 319 weld joints in the reactor building alone, of which 48 did not meet code / design original require-ments.
The NRC's position was that the August 30, 1983 NCR vas improperly dispositioned and the underlying premise for
. )
i its closure was faulty.
It further appeared that "the quality status of the majority of all structural steel welds was at best indeterminate."
By September 28, 1984, numerous inspection records were found missing, welds were found missing or un-acceptable and records which were. located indicated unacceptable welds were documented as being acceptable.
Among many requirements relative to the SSW problems, the NRC requested KG&E to demonstrate that problems of QA activities experienced within the SSW area were not also present else-where at Wolf Creek.
A letter dated January 9, 1985 from Congressman John Dingell, Chairman of the Sub-Committee on Oversight and Investigation, was sent to Nunzio Palladino, Chairman of the NRC, echoing identical concerns.
The letter voiced worries on behalf of the committee that "these problems were not found until construction of the Wolf Creek plant had been virtually completed" and requested assurance that "a OA breakdown such as that which occurred in the SSW program did not extend to other aspects of design and construction of Wolf Creek. "
On January 23, 1985 Chairman Palladino issued his response to 5
Chairman Dingell "which raised more questions than it answered._"
Among those appear to be his citation of the establishment of an NRC Task Force at Wolf Creek in July of 1984 to " insure the overall inspection program at the Wolf Creek Station would be completed on a schedule consistant with the utility's pro-jected fuel load date."
A subsequent lengthy investigation and extensive report has been published by a Louisiana reporter releasing evidence that these Task Forces assigned to all I
J Near Term Operating License Plants (NTOLs) are under the direction of the Department of Energy (DOE).
The division between the NRC and DOE has been made very distinct by the Energy Reorganization Act of 1975.
Congressman Ed Markey, Chairman of the Sub-Committee on Energy, Conservation and Power is now investigating this involvement.
Palladino personally issued a March 20, 1984 memo indicating that the NRC must make licensing of these NTOLs their highest priority regardless of safety implications.
Pa11adino's response went on to inform Chairman Dingell that the "NRC's Office of Investigations (OI) has several investi-gations underway whose conclusions would provide insight into this [SSW) problem."
Those investigations relate to a number of issues including missing, falsified, or erroneous QA records.
With these investigations incomplete, the NRC issued Wolf Creek's low-power testing license on March 11, 1985 and resolved the SSW problems with the issuance of a volu'minous response to Kansas officials which was mailed the same day the license was issued.
These investigations, which could involve potential criminal activity by KG&E management have still not been completed.
Palladino additionally responded to Dinge11's concerns over the NRC granting KG&E exemptions from welding regulations that "the NRC has not ' granted' exemptions from conformance to AWS D 1.1 as the deficient welds required, but rather ' accepted
l 1
- changes' that KG&E requested to ammend the Final Safety Analysis Report (FSAR) Section 3.8.3.6.3.3."
Needless to say, we do not have the expertise to question the i
technical issues of the A/E resolutions.
However, it"is of major concern that there seems to be no regulatory guide for the review of compliance with regulations relative to QA breakdowns.
Instead, the NRC, rather than utilize regulatory guidance, relys on engineering judgement for reinspection.
Consequently, it puts into question the regualtions governing other areas reviewed for reinspection.
The assurances within the NRC response that deficier7ies do not extend to other areas at Wolf Creek are questionable.
DIC contends that the MSSWRs were controlled by an "open-ended" traveler system as opposed to the " closed-ended" system present in other disciplines.
Secondly, usage of the " triplicate traveler" was not put into effect within the MSSWRs until approximately 1980, by which time the SSWs were almost com-plete.
Thirdly, the fact that the utility did not discover documentation problems earlier was blamed on the absence of the Combined Review Group.
An outline of the precise differences between the two traveler systems should be required including:
the reason why the MSSWFs sere on an open-ended system when all other areas involving AWS D 1.1 welding were on closed-ended systems; whether all closed-ended systems are recorded with travelers documented in triplicate; when the triplicate traveler system was iintroduced; if other systems did not have triplicate travelers until 1980 as well, why there are not simi-lar documentation deficiencies within those systems; how many of the MSSWRs were recorded in triplicate (it has been determined that a portion were); and of those, in how many cases were all j
three travelers missing; and lastly if the Combined Review Group was not established untillate in 1983, how can there be any assurance that all other areas prior to this time are not deficient as well (recalling that the Combined Review Group i
i did not discover the documentation problems even once it was functioning.)
l the other areas which could be potentially affected by AWS D 1.1 i
l velding deficiencies are: 1) pipe Whip Restraints, 2) Embed-ment Fabrications, 3) Fire Dampers, 4) Safety-Related Ductwork and Supports, 5) Electrical Raceway Supports, 6) Electrical Equiptment Installation, and 7) Stud Welding.
On November 26, 1984, report KQWLKQW 84-456 was submitted to Bill Rudolph constituting the review done of all (twenty) KG&E 1
CARS by KGLE Quality Engineer, T. M. Halecki.
This brief, two page report consists of a list of the CARS and a two line summary, "...other than CAR 19 (MSSWR) no other si gnificant problems pertaining to DIC inspection and documentation were noted by review."
However, approximately five weeks later on l
l January 2,1985, Surveillance Report S-1223 was issued, signed by T.
W.
Halecki, showing an electrical weld problem.
DIC CAR 2 W-0046 was subsequently initiated on electrical equiptment 1
E foundation velds for deficiencies in welding and shimming of electrical installation, a AWS D 1.1 area.
This CAR remains open.
j
. 1 In summary, the parallel between the chronology of the deficiencies experienced within the BN system and the SSWs is remarkable.
The Violation, Civil penalty and KG&E's corrective action commitments on the BN system occurred in March of 1983.
Simultaneously, in March of 1983, DIC' CAR 29 indicating SSW defects was issued.
Just three months later, in June of 1983, SSW documentation was discovered missing.
One of KG&E's commitments to the NRC to correct potential conflicts in their Quality program was to revise the procedure for timely reporting of 50.55es.
This was resolved and closed on May 20, 1983.
Yet, no 50.55e was reported relative to missing MSSWRs until the fall of 1984.
The reporting criteria of a 50.55e requires:
- 1) a licensee to notify the NRC of each deficiency found in in design, which, were it to have remained uncorrected, could have affected adversely the safety of operations of a plant representing:
i) significant breakdown in any portion of Q/A program, ii) significant deficiency in final design not conforming to SAR, iii) significant deficiency in construction, iv) significant deviation from performance of specifications-which wil! require extensive evaluation, redesignor repair,
- 2) a licensee to report deficiencies within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC, and
- 3) a licensee to submit a written report within 30 days to the NRC.
However, as recently as February 2, 1985, KG&E received another Violation for f ailure to follow procedure for reporting non-i conformances.
An NCR dated in September of 1984 with numerous non-conformances relating to disassembly of pipe supports by insulation contractors against regulations, was not' reported as a 50.55e until December 12, 1984.
Pipe supports also f alls into the area of AWS D 1.1 welding.
Two further commitments by KGLE involved conducting complete walkdowns of all future safety-related systems and additional KG&E surveillance of each safety-related system af ter the formal system turnover occurred.
Yet, KG&E's walkdowns failed to be influenced by these major hardware and documentation dis-crepancies obvious within the MSSWRs.
Even though these dis-crepancies in hardware and documentation were available within their CARS, NCRs, 50.55es, etc., by February of 1984 KG&E accepted as complete, the turnover of a number of buildings with glaring safety-related deficiencies.
Further, if KG&E did surveillance of systems af ter turnover as they were com-mited to, they f ailed in this redundant effort to recognize these major discrepancies, Despite KG&E's appearances of insituting numerous additional quality organizations to assure discovery of deficiencies, KG&E has either been unable to uncover and report these prob-lems in a timely manner, or if they have discovered deficiencies, they have not implemented adequate corrective measures to pre-vent recurrance or resolution.
It would appear that KG&E's QA program is either seriously defective or blatantly deceptive.
The OA/0C program is the only means by which the public can be assured a nuclear facility has been constructed in a safe manner.
The implementation of the QA/0C program is under the direct control of the licensee [KG&E).
Although the NRC performs periodic checks on the OA/OC system, these are primarily reviews of issues brought to their attention by KG&E.
The NRC must rely on KG&E to follow the 50.55e reporta-bility criteria.
In concluding the documentation problems within the MSSWRs was not reportable under 50.55e requirements, KG&E exercised their discretion.
Similarly, they were de-linquent in their reporting of the deficiencies in the BN system.
In both instances, these serious deficiencies were only discovered inadvertently by NRC's review of other areas.
The NRC, and ultimately the public, must rely on the integrity of utility management to discover, report and resolve all issues involving potential safety concerns.
This represents the most disconcerting defect in the system.
In concept, a system which allows a utility with no previous nuclear ex-i perience, to monitor, analyze and correct problems within their own 0A/0C program (with no independent review body) is at-k best questionable.
It is unconscionable that a utility with the magnitude of vested interest KG&E has in getting Wolf Creek -
on line and in the rate base as soon as possible in order to recover financial debts be allowed to survey, and expected to report and resolve deficiencies.
More importantly than theory, however, hasibeen the practical application of this internal monitoring program.
It has been repeatedly evidenced that KG&E has succeeded oniv in their lack of conformance to NRC regulations, lack of adherance to their own quality com-mitments, lack of effectiveness of their redundant quality organizations, and lack of integrity and competence within their management.
- The NRC apparently has not maintained a chronology of safety defects, documentation problems and deportability of deficiencies
)
which have occurred at Wolf Creek.
The NRC continues to refer l
to each recurring incident as " isolated" and does not acknowl-edge problems within other areas which blatantly confirm the existance of a dangerous pattern of identical OA breakdowns.
Seemingly, the NRC intends their response to satisfy any con-cerns on the " isolation" of the SSW problems.
They requested investigations be conducted to discern potential problems with AWS D 1.1 welding n other areas, and they accepted as conclusive l
a two page report of a review of twenty KG&E CARS by a KG&E Quality Engineer [ Enclosure].
Not only is it of major concern that they al. low KG&E to perform their own evaluation, but i
they apparently do so without requiring KG&E to submit any supporting documentation.
Moreover, even though the NRC accepted KG&E's review and assessment that no other problems in areas of AWS D 1.1 welding existed, within the NRC's own response, they reference DIC CAR 1-EW-0046 and KG&E Surveillance 4
Report S-1223 issued in January of 1985 (although they do not submit these reports in their response for of ficals to review) showing electrical equiptment foundation veld problems in an area with AWS D 1.1 welding.
Evidence of extending into other
. areas of AWS D 1.1 welding did not deter the NRC from closing out the SSW issue.
Nor was the NRC's decision to issue an operating license to a utility under investigation for potential criminal activity (i.e. missing welds, falsification of weld records and falsification of inspection reports) altered until investigations could be completed.
These investigation are still not resolved.
Of utmost concern is KG&E's continued intimidation and harassment of QA/QC inspectors.
This is far from an " isolated" incident.
In March of 1983, four QC inspectors were inter-viewed and corroborated another inspectors allegations of being harassed into signing off inspection reports erroneously.
An August 1983 incident involved the termination of a QA inspector who reported safety violations and resulted in an unprecedented Civil Penalty against KG&E in September of 1984 f or this intimidation.
Again in October of 1984 allegations from two inspectors performing reinspection of the SSWs were reported.
These employees claimed they were intimidated into producing results which would show the velds were acceptable.
Disallowing Qua.:.ity inspectors to perform their function l6l[
negates the mos-important safety check within the QA/QC Extending their appalingly lax attitude toward system.
quality even futther, KGLE is requesting, through the appeal i
process, that any responsibility toward their Quality personnel l
be alleviated and foisted upon the NRC.
Simultaneously, KG&E is issuing assurances to the state of Kansas, through their Q1 program, that worker allegations concerning safety are being handled properly.
There is absolutely no assurance that this is occurring.
There has been no independent review of Q1 case files.
In fact, requests to retain and review these files by attorneys intervening in the rate case, have l
been steadfastly refused.
Nor has there been an independent investigation into intimidation and harassment of QA/QC personnel.
In view of thE serious, repeated breach of com-l mitment by KGLE to allow safety-related problems to be identi-fied and corrected, a review of all Ol case files (with emphasis on intimidation and harassment), and interviews of select QA/QC personnel should be conducted immediately.
In conclusion, once again the NRC's response has raised more questions than it has answered.
Firstly, neither KG&E or the NRC's resolution of the MSSWR deficiencies is satisf actory.
They have concentrated on technical reanalysis and have paid voefully inadequate attention to the cause behind the SSW problems:
KGLE's significant Q/A breakdown revolving around 1
substanital documentation f falsification and major deficiencies l
in the function of KG&E and DIC Quality organizations.*
1 i
l Secondly, the NRC has accepted KG&E's contention that the SSW l
problem is an isolated incident when there are repeated j
l episodes of recurrance.
They further rely on KG&E's redundant i
j quality organizations which have failed consistently to j
discover deficiencies I
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A
/ 1 l
Thirdly, the NRC continues to allow KG&E to perform self-analysis without any independent review, when KG&E has con-spicuously failed to correct monumental quality problems or utilize additional quality program enhancements.
Lastly, the rampant intimidation and harassment of Quality I
personnel not only jeopardizes the safe operation of Wolf Creek, but is indicative of the arrogance and irresponsibility 1
of KG&E quality organizations.
It is also a direct reflection upon management integrity.
The NRC and KG&E must be held accountable.
If the state of Kansas is to have any assurance that Wolf Creek has been constructed properly and will be operated safely, it must engage in the following:
- 1) request and review additional documentation,
- 2) conduct a limited investigation into intimidation and harassment of Quality personnel (including review of Q1 case files), and
- 3) invite the NRC and KG&E to a Kansas forum to respond to inquiries into these numerous concerns raised about the quality of construction practices and the function of 6
5 quality organizations at Wolf Creek.
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_____________.________._________.__o
CHRONOLOGY 9/80 DIC CAR 7 issued (100% reinspection of socket welds (fillet) on small bore piping made prior to 6/80.
9/80 50.55e on socket welds reported.
8/81 DIC CAR 9 (deficiencies in mechanical /velding sur-veillance programs adverse trend in electrical area.
DIC begins to question AWS D 1.1 welding when these ASME deficiencies arise.)
8/82 DIC CAR 19 issued (100% reinspection of fillet velds made prior to 4/1/81 on ASME pipe hangers.
They began looking into other areas.)
10/22/82 BN system turned over.
l 11/23/83 AL system turned over?. ' '
l 11/82 DIC CAR 9 closed.
11-12/82 KG&E audits uncover deficiencies in the BN system.
?
1/20/83 Establishment of Quality Documentation Review Task Force.
l 2/3/83 Intimidation of a QC inspector.
2/18/83 Enforcement Conference on BN discrepancies.
2/83 Began looking at AWS D 1.1 areas.
l 3/2/83 KG&E's corrective Action Report to improve Quality Documentation review.
3/3/83
$40,000.00 Civil Penalty levied for BN system problems.
3/22/83 CAR 29 issued (148 out of 241 welds defective.)
l 3/23/83 Potential 50.55e reported to RIV on SSW defects.
3/83 NCR ISN 10381PW issued (weld discrepancies considered cosmetic.
6 welds reworked.)
4/20/83 Bill Rudolph assigned as QA site Manager.
5/20/83 Implementation of procedure for timely reporting of l
50.55es revised to clarify response.
I 6/30/83 42 missing welds on NCR ISN 11957CW documen,ted.
7/25/83 Interim 50.553 report on SSWs.
8/4/83 Termination of QA inspector.
l 8/10/83 DIC CAR 31 issued [Through Revision 7, 10/20/84]
(20% of MSSWRs missing, accepted as missing because of weld quality established during sample reinspection.
Not closed until 1/16/85.
Cause concluded to be result of lack of procedural compliance with respect l
to responsibility for organization, completion and maintainance of records.)
l 8/83 NCR ISN 11957CW issued (documenting 42 missing welds records in the pumphouse, dated 6/30/83.)
l 8/30/83 NCR ISN 10381PW complete.
10/21/83 Potential 50.55e withdrawn.
10/22/83 DIC CAR 29 closed (A/E dispositioned: "use-as-is".)
11/83-2/84 Combined Review Group status reports.
2/84 First building with missing MSSWRs turned-over.
3/84 KG&E's Q1 established under direction of Bill Rudolph.
6-8/84 NRC says they first learn of potential records problems.
9/4/84
$64,000.00 Civil Penalty for intimidation of QA inspector.
]
9/18/84 50.55e report on SSW (22% of MSSWRs missing) reported telephonically, TE3564-K152.
s
)
9/84 Rudolph replaced as director of Q1 due to conflict I
of interest.
e 9/25/84 KG&E/NRC meeting to present reinspection information.
10/12/84 Inspection Report 50-482/84-12 issued: inspection period 5/f4-8/31/84 (p 16q: TE53564-K91 closed, "The suspect welds were found to be acceptable even though they did not look exactly like text book type veld.")
10/17/84 Interim Potential 50.55e telephonic report.
10/17/84 KG&E CAR 19 issued.
10/84 Reinstatement of QA inspector.
10/26/84 Inspection Report 50-482/84-22. (Significant Violation:
inspection period 6/11-9/28/84.
"During a review of QA/QC and Q1 personnel qualifications and subsequent interviews, NRC inspector became aware of potential problems with DIC CARS 29 and 31.")
10/29/84 Enforcement Meeting KG&E/RIV.
11/15/84 RIV Confirmation Action Letter (Guidance on KG&E corrective action program.)
11/21/84 Violation and Civil Penalty issued:
$75,000.00.
($25,000.00 was assessed.for failure to correct dis-crepancies when found.)
11/26/84 KG&E Ouality Engineer's report on KG&E's CARS.
l (Summarized no other problems in AWS D 1.1 welding except in MSSWs.)
11/84 Non-Destructive E: minations by NRC begin (to verify KG&E's corrective action program. They continue to 2/05.)
r 12/4/04 Enforcement Conference at Wolf Creek with KG&E/NRC.
l 12/12/84 Construction. Deficiency Report (CDR) reported to RIV.
(concerning insulation contractors:
DIC generated 31 NCRs--the first on 6/1/84--on pipe supports being partially disassembled.
The first 6 NCRs were through 7/27/84, which caused KGLE to issue CAR 14.
As a result of DIC reinspection of pipe supports, 25 NCRs were generated, 16 between 9/4-9/20/84 identifying Potential 50.55e.)
12/31/84 KG&E issues final CAR 19 report (1,0509 of 6,816 MSSWRs for safety-related SSWs are missing: 22%.)
12/31/84 KG&E pays $75,000.00 fine.
l 1/9/85 Congressman Dinge11's letter of concern:
Wolf Creek MSSWRs.
l l
Surveillance Report 5-1223 issued signed by T.
W.
Halecki.
1/2/85 1/85 DIC CAR 1-EW-0046 issued. (Electrical Equiptment welds attaching equiptment to foundation embeds have AWS D 1.1 discrepancies.
"An analysis of hardware application
(
of AWS D 1.1 welding identified one other area to be l
investigated for AWS welding problems.
This is in the area of electrical equiptment installation where perma-nent insba11ation is by velding the equiptment mounting l
frame to foundation embeds.")
1/11/85 QA inspector terminated again.
1/21/85 KG&E issued supplement to final report.
1/23/85 Palladino's response to Dingell. (As part of the Task Forse effort, the NRC staff conducted a SCVI at Wolf Creek...there were no pervasive breakdowns in QA identified.)
2/25/85 Inspection Report 50-482/84-23 (Intimidation of two weld inspectors during reinspection of SSWs. Reported to NRC 10/84 concerning performance of SSW reinspection program.
Task Force Director and NRC inspector inter-viewed individuals / allegations not substantiated.)
2/25/85 Inspection Report 50-482/84-23 (KG&E receives violation for'not reporting nonconformances to NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
" Failure To Follow Procedure With Respect To Handling Of Potential Reportable Non-conformances",
checked on NCR as " reportable" in 9/84.)
2/27/85 KG&E/NRC meeting in Bethesda to discuss SSW problems.
l 2/28/85 Inspection Report 50-482/85-58 (p5 & 8: closed; l
allegation 4-84-A-98...given to RIC from DOL 8/25/85 stating MSSWRs generally inadequate.)
1 2-3/85 KGLE supplemental information submitted to NRC.
f
U()g*l T.&50501 KO19 rM-a w r a a.
f INTEROFFICE CORRESPONDENCE To:
W.J. Rudolph II K0bCW84-456 yWN:
T.W. Halecki 7 %M DATg:
Nevernber 26, 1984 Review of G E Generated Corrective Action Request
SUBJECT:
In support of KGr.E CAR tb.
19, I have reviewed an of the GE initiated CAR's.
'Ibe general review was conducted to determine if any of the CAR's were similar in nature to the Quality Assurance problems as noted by KG&E CAR No. 19.
CAR No.
19 note $ inadequacies in inspection ard doeurwntation by Daniels.
This review will determine if other CAR's pose any significant problems as far as inspection by Daniels.
Listed below are the CAR's reviewed and the results of the review.
CAR No.
SUBJIET SITE IMPAd7 1
Drawings out of revision No L~ pact "
2 Storage vault does not contain the proper envircanental controls No Impact 3
No security procedures No Impact 4
Gulf Alley not providing the correct doc. entation for various fittings No Impact 5
Internal pipe cleanliness No Impact
{
6 Internal pipe cleanliness No Impact 7
Internal Pipe cleanliness No Impact 8
Inadequate doeunent control on obsolete documents No Impact and charrie information not controlled and translated into travelers
-9 Deficiencies in the mechanical / welding surveillance No Impact program, surveillance not beirry performed as prescribed le QE not reviewing travelers for accuracy No Impact 11 Not issued N/A 12 Work Request not properly processed, temporary No Impact modification log used in correctly and nonconfor-mance reports not properly initiated, tracked and closed.
- ..,,, 9 f
i TE 50501 K019 a774c naev7 e /1 DP,Yj i
KQWLKQW 84-456 Page 2 j
1 l
13 Permanancy of corrective action No Impa::
i I/8i--'~'~~~
' w"'" *** " ' s"i ""*'*"' "*** "*"* """" '*'
es/nl I
- 15 Minimr separation violated 1
No Impact I
16 Inadequate documentation and doe =entation review No Impa::
j 17 Inadequate review, processing aM documentation i
pertaining to KG&E Work Request No Impact j
j 18 t
Start-up Field Reports not being properly processed No Impact 19 l
Miscellaneous Structural Steel Welding (AWS-Dl.1)
N/A (This is the subject of the CAR Review) 20 Lack of procedural compliance for start-up aM No Impact operations activities 6
~.
I In semary, other than CAR No. 19, to Daniels inspection aM documentation were noted by the review.no other signi
>H/sjs
\\
RESPONSE REQUIRID: YES BY:
f No X
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