ML20245B484

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Advises That Use as Is Disposition Acceptable,Based on Review of Daniel Intl Welding Procedure Spec Technique Sheet Number N-8-8-A-4,Rev 0,for Welding w/3/32-inch Electrode Using 105 Amperage
ML20245B484
Person / Time
Issue date: 03/14/1984
From: Gilbert L
NRC
To: Frost W
NRC OFFICE OF INVESTIGATIONS (OI)
Shared Package
ML20245B374 List:
References
FOIA-84-291, FOIA-85-101, FOIA-85-161, FOIA-85-327, FOIA-85-600 NUDOCS 8706170631
Download: ML20245B484 (1)
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t-March 14, 1984 MEMORANDUM T0: W. E. Frost

. O! Field 0ffice *.

FROM: L. Gilbert -

Engineering S'ection

SUBJECT:

DANIEL INTERNATIONAL As requested, I reviewed Daniel International Welding Procedure Specification Technique Sheet Number N-8-8-A-4, Rev. O to determine if a "use as is" disposition would be acceptable for welding with 3/3P ,'

electrode using an amperage of 105. Since the ASME Code,Section IX does not list a change in amperage as en essential element for '

requalification of this procedure, a "use as is" disposition is

. . acceptable.

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fE! 3 Ei'.l, r ffCUII IV MEMORANDUM FOR: Richard K. Herr, Director, Office of Investigations  ;

FROM:

Robert D. Martin, Regional Administrator, Region IV

SUBJECT:

GENERAL ALLEGATIONS REGARDING KG&E AND QUALITY FIRST General allegations regarding KG&E and Quality First were forwarded to Region IV from a former KG&E employee. Region IV also learned that OI received the same allegations. Region IV also found that KG&E had a copy of the same document as received by Region IV and OI.

Since the allegations provided no specifics, this memorandum formalizes my request that OI assist Region IV in interviewing the alleger and one additional person identified by the alleger. Further actions are to be determined following review of the transcripts by Region IV and OI.

f LaAkat Robert D. Martin Regional Administrator

-- cc: T. F. Westerman R. P. Denise L. D. Martin I

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DEPOSITION: James T. Murphy, Superintendent )

A foreman by the name of Ray Anderson came up to me Thursday and said, "I've l got my first NCR." I said, "On what?" He said: "QC came down and there vere five or six people welding on one power source. I had a girl welding, and the machine was set correctly. QC came and put the amp probe on the machine, probably just when some people had pulled off." This would increase the amperage anywhere from 10-20 amps above prescribed procedure. This happens on a daily occurrance of 5-10 times a day. There are 20 grids running out of one power supply. QC came and insisted on writing an NCR. This NCR was written not.

against a code violation, but against a procedurb.

The following day I contacted QC and asked him why he wrote the NCR, knowing that this was an everyday occurrance. The only thing the NCR would accomplish would be to impact our schedule by at least two or three days. I tried to ex-plain to QC that with fif teen to twenty welders on one power supply, there would be constant fluctuation in amperage. If he were to write an NCR every time this happened in one day, he could probably, with no trouble, write ten to fifteen

.,. daily. He didn't want to listen to me. I told him to go out and learn a little more about the construction trade, learn his job, and use a little dis- .,

j cretion where discretion should be used.

That was the extent of the phone call. This phone call was witnessed by other people at my desk. Voices were raised during the conversation on both sides.

Never was there any threr.t to his physical being or to his job. It was never '

mentioned. There were two general foremen and one engineer present during this celephone conversation. -

About 30 minutes later, the lead QC and the QC I spoke with came from the reactor to my desk.

I cried to explain to Rich Booth that the only thing this QC accomplished by writing the NCR against the procedure was to generate more paper that would be dispositioned "Use as is" and impact our schedule by three to four days. Rich Booth said, "If you want somebody 's ass , you den 't take it out on my QC man, you take it out on me, and this is the way the ' procedure's going to stay." I told him, "If that is your procedure, who is yove boss, and maybe Monday we can get this thihg resolved." One word led to the other, The conversation was heated on both parts about job knowledge, but never at any time, was any threat used against him, other than my saying, and I quote myself:

"Maybe we've got too many QC men here with nothing to do, except be petty."

This will be an ongoing occurance, as long as we're in this construction phase, and there are no amp probes for the welders to check themselves. I found out from welding that the last time those machines were calibrated was approxi-mately six months ago. End of statement, j There were no throats, no promised repercussions made at any tima, to any one. ,

I did mention to Rich Booth that we're tripping over QC until you need one, then  ;

they become very rate, and the wait for QC can be upward <to three hours. They I g

'- then departed, and I thought the argument was resolved by my telling them that  ;

I was going to see their boss Monday morning. '

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Page 2 There was no mention ever of any kind of a threat or repercussions that would affect him, othe,r than trying to change the procedure. 1 never threatened him or intimidated him about losing his job, or even mentioned his job. The only

,. thing I did, him too, was that we both became very vocal. Language was used.

My parting statement to him was, "If you're going to stay in construction.

learn something about it."  !

Witnessing this argument were: Perry Latham, C.F.. Mike Hubler, C.F., and systems engineer Terry Bradley, who will gladly furnish depositions in my behalf.

Respectfully'yours.

% %8-James T. Murphy 4

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. i HEMORANDUM FOR: Richard K. Herr, Director )

Office of Investigations, Region IV ,]

FROM: Robert D. Martin Regional Administrator

SUBJECT:

KANSAS GAS AND ELECTRIC COMPANY (WOLF CREEK) Q1 PROGRAM

Reference:

Memorandum, R. K. Herr to R. D. Martin, dated 10/28/85 We have reviewed the referenced memorandum and its attachments for the purpose of determining whether or not they contain information which would warrant the initiation of an OI investigation into the Q1 Program itself. Region IV does not believe that the technical information contained in the concerns attached to your memorandum warrant further investigation by 01. Any technical matters contained in those concerns were reviewed and dispositioned during the course of the review conducted by Region IV. NRR, and IE of the Q1 Program. Details of those reviews and the conclusions drawn are already a matter of record.

Concerns related to the handling of drug-related issues have been previously identified during the 01 assistance that was given to those reviews of the Q1 Program. As we both know, NRC has not issued any guidance nor taken a firm position as to the precise manner in which drug-related allegations are to be

' handleo by licensees. Therefore, whether drug-related concerns were appropriately handled by KG&E is arguable since no objective standards exist against which Region IV can evaluate. In any event, should such matt 6rs be judged as wrongdoing, then they clearly fall within the purview of OI's jurisdiction to determine whether or not they should be pursued further.

Finally, the undercurrent contained within the concerns expressed in the three interviews is a conviction on the part of the individuals that there was some effort by the licensee to attempt to use Q1 to circumvent NRC interest in problems. Given the extent of the review of the particular technical issues involved in the concerns; the review of all other issues identified in the Q1 Program; the extent of our followup relative to other potential wrongdoing RA:RIV RDMartin:jc 12/ /85 1

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  • cases; the files made available to us; and our ability to interview people '

involved in the program, I cannot find sufficient merit in the generalized concerns of these individuals to warrant Region IV reconimending that 01 conduct an investigation. '

1 Robert D. Martin Regional Administrator .

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. B. Hayes, 01 M. E. Emerson -

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DEC E9 Y MEMORANDUM FOR: Richard K. Herr, Director Office of investigations, Region IV FROM: Robert D. Martin Regional Administrator s

SUBJECT:

KANSASGASANDELECTRICCOMPANY(WOLFCREEK)Q1 PROGRAM

Reference:

Memorandum, R. K. Herr to R. D. Martin, dated 10/28/85 We have reviewed the referenced memorandum and its attachments for the purpose of determining whether or not they contain information which would warrant the

  • initiation of an 0I investigation into the Q1 Program itself. Region IV does not believe that the technical information contained in the concerns attached to your memorandum warrant further investigation by 01. Any technical matters i

contained in those concerns were reviewed and dispositioned during the course of the review conducted by Region IV, NRR, and IE of the Q1 Program. Details of those reviews and the conclusions drawn are already a matter of record.

Concerns related to the handling of drug-related issues have been previously

identified during the OI assistance that was given to those reviews of the Q1 d Program. As we both know, NRC has not issued any guidance nor taken a firm position as to the precise manner in which drug-related allegations are to be handled by licensees. Therefore, whether drug-related concerns were appropriately handled by KG&E is arguable since no objective standards exist against which Region IV can evaluate. In any event, should such matters be judged as wrongdoing, then they clearly fall within the purview of OI's jurisdiction to determine whether or not they should be pursued further.

Finally, the undercurrent contained within the concerns expressed in the three interviews is a conviction on the part of the individuals that there was some effort by the licensee to attempt to use Q1 to circumvent NRC interest in problems. Given the extent of the review of the particular technical issues involved in the concerns; the review of all other issues identified in the Q1 Program; the extent of our followup relative to other potential wrongdoing RA:RIV RCMartin:jc  !

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Richard K. Herr, OI .

cases; the files made available to us; and our ability to interview people  ;

involved in the program, I cannot find sufficient merit in the generalized .

concerns of these individuals to warrant Region IV recommending that 01 conduct an investigation.

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Robert D. Martin l Regional Administrator .

cc: i B. Hayes, OI M. E. Emerson -

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    • ~~ UNITED ITATTs b -

! ,y c NUCLEAR REGULATORY COMMISSION Distribution: . I f I cAsmorog. o. c. ossa LUU 4/b t,% [ #/ WJDircks .[P..I__ {~

      1. U.S. !EC April 23, 1985 JRoe exAinuaN .-

TRehm VStello Lliw \

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GCunningham gy HDenton "q -

JFunc3es WO "h The Honorable Dan Glickman

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United States House of Representatives [L .

Washington, D.C. 20515

Dear Congressman Glickman:

Thank you for your letter of March 20, 1985 and your interest in the safe construction and operation of the Wolf Creek Generating Station.

I have been informed by the Director of t'he Office of

- Investigations (01).that each of.the.01 cases . involving the Wolf Creek project %gder active investigation.

At license the time for the that Wolf it considers Creek plant,the thequestion Commission of awil-1'be full-power /

briefed on the status of the pending investigations. Thel Commission will authorize a license for the Wolf Creek plant only if and when it finds that there is reasonable assurance of no undue risk to the health and safety of the public, All matters under investigation which have a bearing on the Commission's health and safety findings will be fully addressed before the Commission authorizes a full-power license. .

Sincerely, ,

Original signed by -

Eunzio J.. Pa11adina Nunzio J. Palladino I

a OI Treated as Chairman's Telcon 4/4 Correspondence. to Rehm -

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Corresoondence coordinated with t u ,rA u s .j.

Comrs' offices by C/R. Ref: CR-85-34 4/ /85 orr cc . AO/EDO C/R OCA OCP OCM OCF

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NbCLEAR REGULATORY COMMISSION OFFICE oF INVESTioATioNS FIELD OFFICE. REGloN IV 0 0. N O L I S C/=*t O .

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ASSISTANCE TO INSPECTION REPORT February 9,1983

SUBJECT:

KANSAS GAS AND ELECTRIC (W0i.F CREEK)

ALLEGED PROCEDURAL VIOLATION REGARDING CERTIFICATION TESTS REPORT NUMBER: A4-83-003

1. On , W. C. SEIDLE, Reactor Project Chief, Region IV, received a call from , the Daniel International Civil Quality Training Coordinator Technician at Wolf Creek, during which detailed a sequence of events that occurred during the previous week regarding improper testing procedures. SEIDLE made arrangements for , to contact the Wolf Creek NRC SRIs VANDEL and ROBERDS and this reporter.

. 2. On the afternoon of , came to the NRC trailer at Wolf Creek, and was interviewed by this reporter.

stated that during the previous week, had given a coatings QC Inspector realized certification test to a Daniel Coatings Lead. E stated after the test that four of the questions contained in the test were in-valid because of revisions in coatings procedures, said the value of the four auestions was sufficient to cause the Lead QC Inspe ctor to fail the test, stated the test had administered was the only test of 'that class approved by Kansas Gas and Electric.

I stated that by procedure, had no choice other than to fail the Lead QC l Inspector.

3. stated was subsequently told by the Daniel Quality Training Supervisor, the Acting Daniel Project Quality Manager, and a Daniel QA Supervisor to disregard the procedure and score the coatings test after '

i taking :out the invalid questions. detailed attempts to per-suade Daniel management to abide by procedure, but stated eventually followed their instructions after was threatened with termination by supervisor for insubordination.

4.

stated called the NRC in an attempt to protect job,and because feared that part in violating the procedure would result '

in dismissal, executed a signed, sworn statement, Attach-ment (1),on , detailing the events surrounding this situation and provided copies of Daniel correspondence related to this .

. matter, Attachment (2).

5. On , discussion witn the Region IV Regional Administrator resulted in him requesting that the results of OI's efforts to date be n ruI~~~)Il wa ys iv m2MA f - N-Q u

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. .. : ~ DO N0-~ J SC _OSE A4-83-003 Page Two forwarded to Region IV for consideration of appropriate inspection action. This AIRS, along with attachments, are forwarded to you for any action you deem appropriate.

Attachment (li, -

signed, sworn statement, dated-Attachment (2) - Daniel correspondence memorandums H. Brooks Griffin, Ir$estigator Office of Investigations Field Office Region IV ,

APPROVED BY: A & -

Ri' chard K. Herr, Director Office of Investigations Field Office -

Region IV cc: John'T. Collins, RIV W ic H. Johnson, RIV William C. Seidle, RIV (w/ attachments)

William J. Ward; 01:DF0 e

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NUCLEAR REGULATORY COMMISSION I

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DEC 2 6 B84 fiz.;frid.:i.f:3 I?

MEMORANDUM FOR: Allegation Files 4-83-A-08 and 4-83-A-54 FROM: T. F. Westerman., Enforcement Officer *

SUBJECT:

QUESTION OF INTIMIDATION, HARASSMENT, AND/0R DISCRIMINATION During a re~ cent visit by Rich Stark, the NRR Allegation Coordinator, the closed

-Region IV allegation files regarding Wolf Creek were audited. Allegation files 4-83-A-08 and 4-83-A-54 were idt.ntified by Mr. Stark to contain possible open issues relating to' intimidation, harassment, and/or discrisgination.

Larry Martin and I met with Richard Herr and Brooks Griffin from the RIV OI Field Office on December 20, 1984, to discuss these'two files. -

In allegation file 4-83-A-08,_the alleger was told by speed memo to delete .,

-. questions-that were wrong due to recent procedure revisions. The alleger

-questioned the_ legality of violating the administrative procedure which required review and approval of revisions. He was told to follow his supervisor's instructions or be fired for insubordination. This allegation came to Region IV via an 01 Assist Inspection Report (AIR) A4-83-003.

OI indicated that it was'their position that a threat of termination for insubordination did not' meet 01's criteria for intimidation'or harassment. OI informed- at the time of the investigation that it was within the supervisor's lawful right to threaten with termination for insubordination.

A11egation file 4-83-A-54 relates to a welding helper who alleged that he was 4

! laid off in a "ROF" (reduction in force), after being reassigned from the  !

reactor building to the auxiliary building, because he complained that a welder '

and fitter were not following procedure. ,

'01 indicated that in this case, the alleger provided no specifics to support that his "ROF" was other than normal., Since he had not been able to pass the welder qualification test, he was a good candidate for "ROF". When he called 01, he sounded somewhat disjointed in his conversation. He could not, for example, remember his foreman's name. He was almost four months late in making the complaint.

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Memo for Allegation Files 4-83-A-08 and 4-83-A-54 ,

It is'01's view that the alleger's Case did not provide sufficient supportive detail to warrant further investigation.

7AW T. F. Westerman -

Enforcement Officer CC:

R. K.' Herr" H. B. Griffin L. E. Martin-4 W

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Q4-84-042

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,8 , AkLING10N,1EX AS 7N11 J September 11, 1984

.MDORA"DUM FOR: Richard K. Herr, Director Office of Investigations FROM: John T.' Collins, Regional Administrator

SUBJECT:

ALLEGATION ON ALTERATIONS TO KG&E PERSONNEL RECORDS Attached is a namorandum for file from Dale A. Powers, Acting Enforcement Officer, dated September 10, 1984, relating to possible alterations of

ur(cnnel records at the Wolf Creek site. This allegation, the allegction raview, and the record of conversation were previously discussed viith Mr. Driskill on September 9.

. I raquest that an investigation be made into this allegation. '

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Regional Administrator

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1 Att6chment:

As stated cc: R. Hall J. Kelly T. Wdsterman D. Driskill 4

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!%. ',. NUCLEAR REGULATORY COMMISSIO!!

'j e (. e E'. -[ OFFICE OF INVESTIG ATIONS FIELD OFFICE, REolON IV w e 611 RYAN PLAZ A DRIVE, SUITE 1000

, , ARLINGTON, TEX AS 76011 January 31, 1985 MEMORANDUM T0: Robert Martin, Regional Administrator Region IV FROM: - Richard K. Herr, Director ~

Office of Investigations Field Office

SUBJECT:

REPORT OF INQUIRY (04-84-042)

Attached is Report of Inquiry Q4-84-042. This

,' case is CLOSED.

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Attachment:

As stated i

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MAY a 41985 f'*

In Reply Refer To: .

Docket: STN 50-482 .,

Glenn L. Koester, Vice President Nuclear Kansas Gas and Electric Company P. O. Box 208 Wichita, Kansas 67201

Dear Mr. Koester:

This is to confirm our discussion today in which you comitted to maintain the KG&E Quality First files intact and complete and under safekeeping arrangements for the foreseeable future, and that there will be no disposal or modification of such files without prior notice to and agreement by the NRC, Region IV. If this is not your understanding of this commitment, please notify me immediately.

I recognize that in prior discussions you had indicated the intent to maintain these files. The purpose of my telephone call and this letter is to confinn this as a commitment to the NRC.

Sincerely, Original Signed By:;

Richard P. Denise R. P. Denise, Director Division of Reactor Safety and Projects (

cc:

See next page bec to DMB (IE31) bec distrib. by RIV:

RPB2 Myron Karman, ELD, MNBB (1)

Resident Inspector R. D. Martin, RA SectionChief(RPB2/A) R.- P. Denise, RIV File T. F. Westerman

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l Kansas Gas and Electric Company ATTN: Kent R. Brown, GVP, Technical Services P. O. Box 208 Wichita, Kansas 67201 s

Kansas Gas and Electric Company ATTN: Gene P. Rathbun, Manager of Licensing (Sameaddressasabove)

Forrest Rhodes, Plant Superintendent Wolf' Creek Generating Station P. O. Box 309.

Burlington, Kansas 66839 .

Kansas Radiation Control' Program Director i

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  • GodRNMENT ACCOUNTAD'lLITY PROJECT

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Washington, D.C. 20036 (202)232-8550 <

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Commissioner Frederick Bernthal

  • pommissioner Thomas' Roberts '85 MAY 31 P3:59 ptommissioner Lando Zech ,

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Dear Commissioners:

0FF!Cr Or SECRt.iA: <

00cdTinG & SERVitJ.

BRANCH i on May 15, 1985 the Governinent Accountability Project (GAP) filed a citizen's petition pursuant to 10 C.F.R. 2.206 on behalf of the Nuclear Awareness Network (NAN) of Kansas. That petition j requested that the NRC Staff be required to take possession of l files which documented hundreds of complaintis and' concerns from

' workers at the' Wolf Creek nuclear power plant, investigate the adequacy of the resolutions to technical and wrongdoing issues ,

raised by the workforce, and evaluate the implications of the '

findings for the overall safety of the plant and the character and competence of the management of the Kansas Gas and Electric l 1

, Company. .

This filing amends the May 15 petition. This amendment is based on our analysis of information contained in the Quality First files. This information, which has been provided to the Office of Investigations, removes any doubt that Wolf Creek has been the subject of a serious quality assurance breakdown. It further reveals the inaccuracy of KG&E's assurances that all issues which have. implications for the safety of the plant have been adequately resolved.

We understand that the NRC Staff has conducted a major review effort this week as a result of our petition, and that the results of that review are being disclosed to the Commission today in a private briefing. The results of the review effort, the basis for any staff opinion, and the recommendations by the staff for any further action must be made public prior to any full power licensing vote.

We are particularly concerned that the briefing that the commission itself receives by the staff will not be thorough and complete. We have included by reference in this amendment all of j' the information contained in Quality First files now in I

possession of OI, and make specific reference to the following  ;

i issues which remain unresolved: j

1) Harassment and intimidation of Quality Control personnel, start-Up engineers, contract inspectors, and craft ..!I employees at the Wolf Creek plant. (See all harassment and intimidation claims including those referred to the KGEE legal office for resolution from the Quality First program.)

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Please provide to' representatives of NAN by the close of business today the information provided to the Commission and/or tha Executive Director's Office stemmihg from this week's review T

' and inspection effort into wrongdoing and quality assurance l deficiencies.

' Sincerely, i

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Billie Pirner Garde citizens Clinic Director i

Robert Guild, Esq.

Attorney 1

cc$ Mr. William J. Dircks .

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In Reply Refer To:

Docket: STN 50-482/85-28 jij,R,.g,i ,[{AjDip

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Kansas Gas and Electric Company ATTN: Glenn L. Koester Vice President - Nuclear I P. O. Box 208 Wichita, Kansas 67201 Gentlemen:

This refers to the special inspection of Quality First conducted by the NRC during the period May 27 through 31, 1985, of activities authorized by NRC _

l Operating License NPF 32 for Wolf Creek, Unit 1, and to the discussion of our findings with yourself and other members of your staff at the conciusion of the inspecM n.

This inspection consisted of examination of the Quality First records, interviews with personnel, and observations by the inspectors. These findings are documented in the enclosed inspection report.

Within the scope of the inspection, no violations or deviations were identified.

Should you have any questions concerning this inspection, we will b~e pleased to discuss them with you. ,

Sincerely, Original Signed Byt Richard P. Denise R. P. Denise, Director Division of Reactor Safety ,

and Projects

Enclosure:

Appendix - NRC Inspection Report 50-482/85-28 cc w/ enclosure: (cont.onnextpage) ,;

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Kansas Gas.and Electric Company .

Kansas Gas and Electric Company ATTN: Gene P. Rathbun, Manager of Licensing P. O. Box 208 Wichita, Kansas 67201 Forrest Rhodes, Plant Superintendent Nolf Creek Generating Station P. 0.' Box 309 Burlington, Kansas 66839 -

, Kansas Radiation Control Program Director bec to DMB (IE01) bec distrib. by RIV:

  • RPB Myron Karman, ELD, MNBB (1)
  • Resident Inspector R. D. Martin, RA
  • SectionChief(RPB/B) R. P. Denise, ,
  • R&SPB J. Harrison, RIII
  • RIV File
  • MIS System
  • RSTS Operator *D. Weiss, LFMB (AR-2015)

P. O'Connor, NRR J. Taylor, IE H. Denton, NRR B. Hays, 01 R. Herr, 01,'RIV

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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report: 50-482/85-28 ,

License: NPF-32 Docket: 50-482 Licensee: Kansas Gas & Electric Company Facility Name: Wolf Creek Generating . Station Inspection At: Wolf Creek Generating Station, Burlington, Kansas Inspection Conducted: May 27-31, 1985 Team Director: R. P. Denise, Director, Division of Reactor Safety and Projects (DRSP), Region IV Team A: D. D. Driskill, 01, Region IV M. Emerson, OI, Region IV '

T. A. Nash, Allegation Coordinator, Region IV Team B: R. G. Taylor, Reactor Inspector, Region IV s M. E. Murphy, Reactor Inspector, Region IV R. P. Mullikin, Reactor Inspector, Region IV L. E. Ellershaw, Reactor Inspector, Region IV B. Siegle, LPM, NRR V. Nerses, LPM, NRR -

Team C: L. E. Martin, Chief, Project Section B, Reactor Projects Branch, Region IV B. J. Youngblood, Licensing Branch Chief, NRR I W. P. Haas, Special Assistant for Allegations, IE f J. E. Cummins, Senior Resident Inspector, Wolf Creek i H. F. Bundy, Resident Inspector, Wolf Creek l B. L. Bartlett, Resident Inspector, Wolf Creek NOTE: Team A Details docume'nted under separate cover as 01 Assistance to Inspection A4-85-005, dated June 12, 1985.

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( A J Inspector: ._/ , Is M' 83 R. G. TayJor, Reactor Inspector /Dafe Project section B, Reactor Projects Branch-Region IV (Team Leader B) - .'

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1,5,f4 L.W Ma7 tin, Chi Project Section , Reactor Projects Branch

)7atef Region IV (Team eaderC)

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Inspection Sumary Inspection Conducted May 27-30, 1985 (Report 50-482/85-28)

Areas Inspected: Special inspection of Quality First (Q1) files. This inspection involved team members from Region IV DRSP, Region IV Office of Investigations, NRR, and IE for a total of 679 onsite inspector-hours.

Objectives of Inspection: To completely review all KG&E Q1 files to determine whether Kansas Gas and Electric Company (KG&E) has properly dealt with the concerns brought to this organization by the employees of KG&E and its contractors. As a result of this review, determine what NRC actions are required with emphasis on issues affecting full power operation of the plant and management integrity.

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DETAILS ,

1. Persons Contacted G. L. Koester, Vice President, Nuclear C. C. Mason, Director, Nuclear Operations F. T. Rhodes, Plant Manager C. A. Snyder, Manager, Quality First R. M. Grant, Director, Quality .

W. J. Rudolph, Manager, Quality Assurance H. K. Chernoff, Licensing W. M. Lindsay, Supervisor, Quality Systems D. R. Smith, Superintendent, Plant Superintendent M. G. Williams, Superintendent, Reg. Quality Administration T. L. O'Hearn, Nuclear Plant Engineering A. Mee, KEPCO, Project Coordinator R. Flannigan, KCPL, Site Representative .

All of the above were present at the exit' interview.

The team members also interviewed other licensee employees and members of the Q1 organization.

2. Background KG&E began developing an internal program for followup on safety concerns in January 1983. The Q1 program and concepts were implemented in February 1984. The program started with 4 people that reported to the Director, Quality via the Manager, Quality Assurance. In November 1984 the Q1 organization was placed directly under the Group Vice President, Technical Services and had 27 people.

Q1 receives concerns in three ways: (a) Hotline,(b) walk-in,and (c) exit interviews of all KG&E or contractor employees. At the time of this inspection, there were 271 case files with a total of 752 concerns.

Only 4 of the concerns remained open.

3. Scope and Mechanics of Review

- All 271 case files were reviewed with each individual concern being evaluated to the following criteria:

.o File content o Nature of concern o KG&E classification .

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o 50.55(e) reportability 1

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o KG&E actions / resolution o NRC acceptability for full power license The review was accomplished by three teams. One team was assigned all of the intimidation /harrassment, drug, falsification, security, and ,

wrongdoing issues (documented in 01 Report A4-85-005) with the other two teams handling all other issues. Each concern was reviewed and evaluated by a team member and this evaluation was subsequently reviewed by the team leader and/or the team director. All concerns received two levels of review.

The teams met with the team director each afternoon to discuss status and significance of individual reviews. Because of the sensitivity of the confidentiality of the Q1 files, the teams did not duplicate records or file information.

4. Result of Review The teams reviewed all 271 case files and evaluated KG&E's documentation, determination, and ~ resolution of the 752 concerns. The following is a categorization of the concerns in percentile:

Technical (Safety) 61%

Technical (Nonsafety) 3%

Intimidation /Harrassment 6%

Industrial Safety 2%

Industrial Relations 5%

Security 1%

Drugs 4%

Falsification of Records 2%

Other 16%

Approximately 40% of the 271 case files had previously been reviewed by Region IV, however, they were again reviewed during this inspection to provide continuity and to insure that all concerns received at least two levels of review.

The review of the technical concerns revealed that KG&E and Q1 had performed a good in-depth follow up, proper classification and appropriate corrective action. There were instances where the NRC team disagreed with whether the. concerns were substantiated or not and this will be discussed i in a subsequent paragraph of this report. 3 The review of the concerns related to drugs, intimidation /harrassment, and falsification were not handled with the high level of performance exhibited in the technical area. These concerns were categorically followed up by organizations other than Q1 and the closure documentation did not exist in the Q1 files. An example would be a drug case that was L

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1 turned'over to the security organization where the follow up was not )

' communicated to Q1. There were several concerns where all of the leads were not adequately followed to support the conclusion. Additional effort outside the Q1 organization by the NRC was required to determine if these concerns were properly investigated and closed as indicated in the Q1 ,

file. The Q1 file closed many of these concerns when they were t transferred to the other organization. ,

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' The review of the drug and intimidation /harrassment concerns by organizations outside the Q1 organization often identified poor follow up.

These types of concerns often require the expertise of a professionally trained investigator to properly follow up on all leads. It was apparent ,

that- some of these concerns received marginal investigative effort, and therefore, the assurance that the appropriate classification and resolution was reached was marginal.

There were instances where the NRC reviewers disagreed with the Q1 classification of substantiated /not substantiated. There were other concerns where the information, contained in the Q1 files did not support -

the closure of the file. There were approximately 34 concerns where the NRC-team had to go outside the Q1 organization and look at other information or interview other personnel to reach the conclusion that the particular concern was or was not a restraint to full power operation of Wolf Creek.

The NRC team noted that many concerns could have been closed much sooner, but the concentration of resources was-directed almost totally to the interview process rather than the investigation and closeout / resolution process. The final resolution may have been the same had the investigation and closeout taken place in a timely fashion, however, the substantiated /not substantiated classification can change and the timely response to the concerned party is very important. It was also noted that the only trending of the Q1 files was related to the number of open versus closed files. The NRC team could not identify any trend information that provided KG&E top management with type or significance of concerns.

5. Conclusions The NRC teams, after follow up on the Q1 files and follow up on numerous items outside the Q1 organization, concluded that KG&E Q1 had:

o Reached proper resblution on technical issues. in a responsible manner.  ;

o An appropriate level of management integrity was evidenced by proper resolution, management involvement, and the independence of the program.

o Not required appropriate feedback and appropriate level of .

investigation from other organizations to insure that the Q1 files contained all information to support closure.

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o Failed to provide appropriate trending to managenent.

Many of the above items were noted during previous inspections of the Q1 activities..

After careful review of all 271 case files and each of the 752 concerns, the NRC teams concluded that there were no issues that would be a restraint to full power operation of the Wolf Creek Generating Station.

There are issues that will require continued NRC follow up.

Although Q1 is not a required or regulated. activity, it is a highly visible activity and therefore, of matter of importance to the NRC and KG&E. KG&E has committed to continue the Q1 effort and to retain all records as permanent records. This is an important management tool for KG&E and to assure its effectiveness in the future will require continued management attention.

The NRC does not view the Q1 activities as a mechanism to bypass the NRC.

From the inception of Q1, Region IV has been interested in this effort of KG&E to better manage the quality of the Wolf Creek activities. This is the seventh inspection that the NRC has conducted of the Q1 organization.

The NRC will follow up on the concerns identified in this report and will continue to review the Q1 files and findings.

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December 21, 1984 IU E !%-L IliE N ' ,

t':lDRAfiD'JM FOR: Robert D. Martin, Regional Administrator Region IV , ,

a-fROM: . A en B. Hayes, Director N Office of Investigations 4! EJECT : 01 EVALUA110h' 0F THE KAfiSAS GAS & ELECTRIC (KG6E)

.lf! VEST]GATIVE PROGRAM T i, t. attiched r.emorandum from William L'ard is one of three anticipated reports I have as. Led Mr. Ward to prepare. With the anticipation that many licensees will' institute their own. investigative process concerning allegations, I thc ucht it prudent that we review three such licensee programs. Please note that Mr. Ward did not do an " investigation" of the Quality First Program but -

rure a managerial review to assist me in formulating a national perspective on ho,e the Office of Investigations should inferface with the utilities investi-t otive program.

I cth that this docuneent not be made public at this time. As I have noted clove, it is one of three reports which will assist me in developing policy.

ilt ese note that the "staf f" also did a review of the Quality first Program at 1.'si f C re e t . The results of their review are unknown to me personally, s

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December 21, 1934 ,

Hil:0RAfiDUM FOR: -

Ben B. Hayes , Director Office of Investigations FROM: William J. Ward, Assistant to Director Office of Investigations

SUBJECT:

01.EVALUAT10fi 0F THE KANSAS GAS & ELECTRIC (KGAE) .

INVEST]GATIVE PRO 1 RAM '

At the suggestion of KG6E's retained counsel, Mr. Gerald Charnoff, you, E.ichard Herr and 1 visited KG6E's Wolf Creet Generating Station near Eurling-  !

ton, Kansas on September 19, 1984 where we received a briefing regarding the Q.:ality first Program. Based on the results of that briefing you instructed ne to conduct a thorough evaluation of the KG&C Investigative Program, of which Quality first (Q1) was but one part. Accordingly, I visited Wolf Creek during the- period of September 25 through 27 and again on October 17, 1984. I.

also visited KG&E Corporate Headquarters on October 16, 1984. During these visits I reviewed records and interviewed KG&E and contractor personnel at both senior management and working levels. As a result of these efforts, I -

feel 1 gained a good understanding of the LG6E Investigative Program - such as it is. -

Quite simply, thcre is no investigative program per se'. Investigations are conducted by several rG&E organizations. There does not appear to be any integration of effort, nor is there a central point where everything comes together. Before pursuing this point any further, let me describe some of the KG&E investigative units.

The Quality First Program was established in about f: arch 1984 to investigate and resolve confidential quality concerns resulting from Q1 hotline telephone cells and Wolf Creek Project Personnel Exit Interviews. Q1 also receives a eubstantial number of allegations from " walk ins". ,

The Q1 charter is to investigate all qualtity cc,ncerns relating to, "...hard'-

l 5,-rc / installations, documentation /intinid6 tion ar'd/or herassment issues."

0;hcr concerns such as cost and sche:dule issues, thef t of property or drugs ti c rtferred ciscwhere. The manager of Q1 currcntly reports to the Director of QJality (R"th a " dotted 1,ine" relationship to the KCt.E Vice President-fiuc-1rar.

The mEr.ager of Q1 infoned me that , drug related allegations are referred to the Wolf Creck Security Department for investigation. He further rdvised that ,,

clltgetions of theft of company property are similarily referred. Interviews

' with the Wolf Creek Chief of Security revealed that he has received only four '

referrals from Q). More importantly, he advised that he has no investigative -

pcrsonnel assigned to his staff. He further edvised that there is no formal procedure whereby results of any of his ' investigative" efforts would be

, icported back to Q1.

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Du cmber 21, it Further inquiry revealed that Q1 currently refers drug allegations as well as other non-quality conu rns to the KG&E Construction Manager. The Construction Mhrieger evidently places these items on a tracking system, and in turn further-refers them to other KG&E or contractor managers for resolution. The Con-struction fianager informed me that he has one individual assigned on a part time bcsis to track follow-up action on these items. No investigative person-nel are assigned to this unit.

The KG&E Corporate Manager of Internal Audit, who reports directly to the ,,

Chairman of the Board, occasionally conducts investigations. When inter- <>

s it wed, the manager advised that the number of these investigations has 1Fpnred off with the advent of Q). Nonetheless, most past as well as current investigations are related to cost and schedule or vendor issues.

. .c Vice President-General Counsel plays a major role in the KG&E investiga-

.:ve program. The legal staff conducts a wide v6riety of investigations of a i 'ditive nature such es sexual harassment, character issues and matters which r ;y entail litigation. Interestingly, the only Q1 investigator with fonnal ii.vestigative training is in f act under a personal services contract with the r-neral Counsel. Thus, although he normally reports through the operations (hain to the Vice President-Nuclear, he also has direct access to the General kunsel for whom he occasionally conducts investigations. In this 16,tter n.r& city, he is worhing outside of the operations management chain.

Tht re is yet another pityer in the KG&E investigative program, the Executive h :istant to the Chairman, who is currently Acting Director of Operations.

Although this. individual's duties are rather vaguely defined, he appears to have some general oversight responsibilities regarding the security and i v rgency response programs. In this regard, he is occasionally involved in investigative work. One such example cited to me was an investigation he

< % ducted of the f revdulent use of a KG&E telephone credit card.

li!tly, as rc.any issues are apparently "farroed out" to various rqanagers for v orlution, it is clear that each of these in turn is, in effect, involved in ihr conduct of investigations. I did not attempt to pursue this aspect any Art hcr other than to establish that no other formally trained ' investigative

,+ r!cnnel are asiigned to these units.

/.s I indicated et the outset, theref is little if eny coordination, let alone w ti.grition of these investigative activities. !t is clear that KG&E does not t ruly have cn investigatite program in view of this. I think a prerequisite for a (orporate investigative progrcm would be either the designation or

.t blishment of an organization at the corporate level to be the central f, ral point of all of these uncoordinated activities. I would strongly it c u.rs nd that this ctganization be free of cost and schedule concerns to the c tent possible or practicable. In my view, the lack of any such organization is one of the c6usal factors behind the shortcomings in the Quality First ficgrcm which 1 will now describe.

Q1 was originally cstablished with a built in conflict of interest: It icparic d to the Wolf Creek Manager of Quality Assurance. The conflict arises

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i in that the quality concerns being investigated by Q1 represent ostensible -

f ailures of the QA program. fiot only is this rather self evident, but many of th Q1 personnel with whom I spoke mentioned this. Evidently, LG6E recognized this problem because, in August 1984, they moved the organization up one notch

, so that it reported to the Manager of Quality. The Manager of Quality in turn reports to the Vice President-fiuclear. h'onetheless, a significant number of the closed cases in the Q1 files were done under the old syttem which in turn raises s'ome question as to their total objectivity. This is compounded by the j fact that the Manager of Quality Assurance has been the subject of several i allegations releting to'his character, and is at the time of this Nriting n under investigation by KG6E as a result of them.

Even though the Q) reporting relationship has been rrodified, the attached flow chart (Enclesure 1) shows there is still the potential for considerable influence by the ik.neger of QA over problems identified by the Q1 Program.

Let me illustrate this by describing procedures. Q1, for reaans which are not wholly locical to me, is divided into two basic groups, the interviewers, ,

end the irvestigators. Although there has bcen fine tuning of this sys'em, '

msch of it during the peiiod of this evaluation, this system appears to work lite this. An 611egation received by any of the three pathways described above is handled by one or more Q1 interviewers. These persons document the allegations, male an initial prioritization, initiate a case file, and perform -

an initial b0.55(e) determination (more on this later). The rnatter il than rcferred over to the Q1 investigators who are housed in a separate trailer.

The Q1 investigators perfect an investigation plan and then set forth on their investigation. Leaving for the moment what passes as an investigation, let us focus on what happens if the Q1 investigator encounters relevhnt quality information beyond that which was contained in the original allegation.

QJite simply, the Q1 investigators do not investigate these collateral issues icgardless of their importance. Rather, as indicated on their flow chart, they document thtse in what is called a Quality Firs t Observation (QF0). The Ql 0 is sent to the l'er+ger of Quality Assurance. The flow char,t indicates the series of potential actions which may flow from QA's reaction to a QF0; bcwev-l er, the flow chart rivcals, 6nd personnel have testified to me, that there is l no system or requirement for QA to feed back the reculis to the-Q1 Progr6m.

l To ny knowledge, unless someone were to mLe a specific effort to track dow'n 1

'the results of QF0, it could littially disappear within the system, especially in t hese f rantic fir,al wecks prior to projected fucl load.

j I r. r tioned that the Q1 intcrviewers raate an initial detcrtination of 50.55(e) rcportability. I should add that a final detcrmination is made upon com-piction of the investigation. In each instance the investigator fills out a ft+m (Enclesure 2) entitled WCGS Request for Pcportability fraluation. The instiuctions on this worksheet state, ir,ter alia, that in order to be report-  ;

able, a deficiency h?s to satisfy paragraphs 46 and 4b; i.e., there raust be a >

j construction deficiency that, were it to have remained uncorrected, could have j affected adversely the safety of nperetions of the nuclear plant at any time throughout the expected lifetime of the plant, and the deficiency represents a .

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significant brealdown in uny portion of the QuaTity Assu'rance Program conduct-ed in accordance with the requirements of Appendix B. This is being strictly interpreted by the Q1 Program to mean that thcre mast be a hardware defect

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l coupled with the significant brealdown in the QA Program in order for it to be ,

reportable. In other words, a significant breakdown in the Quality Assurance Program is not, in their view, required to be reported in accordance with 10 CFR 50.55(e). It was pointed out to me that Mr. Glen Madsen, fiRC RIV, agreed 6;ith this interpretation. U cuidance concerning 50.55(e) pon return from Wolf Creek, I reviewed thereportin rt ading of this guidance appears to indicate that a significant breakdown in the QA Program in and of itself is.a significant deficiency and thus, must be -(

u ported under 50.55(e). My file review at Wolf Creek revealed seyeral ..

instances where the initial determination was that there was a significant

i reeldown in a portion of the Quality Assurance Program but it was not (c midered reportable in the-absence of a construction deficiency which

... i; parently is perceived as having to be hardware problem. Quite frankly, ] do l not Loow for certain what the reporting requirer.ient is, but it ccriainly does  !

turgest to me that an intent to have significant breakdowns in QA programs

! rc ught to the attention of the tiRC. Currently they are not.

FGLE's intc rpretation of the reportability requirement is consistent with their position regarding the reportability of wrongdoing to the i4RC. Q1 .

crsonnel stated that.they had been advised by retained counsel that there was no rec virement to report such wrongdoing to the fiRC as harassment ard intimidation and records falsification. The investigators with whoM.J spoke irpeared to be surprised by this interpretation. Accordingly, I began a dctailed review of the Q1 files of both open and closed cases. I reviewed a -

irial of 303 case folders. Although the large volume of file n.aterial and the u.nstraints of time precluded my reviewing them in the detail which I would htve prcierred, this relatively cursory review identified the following instances of wrongdoing. 17 cases contained allegations involving drug use or iraffihing by project personnel. Some of these cases were sufficiently i M cific i.e., they contained the names of individuals or groups of individu-als, that they could have been acted upon by law enforcenient or investigative

rsonnel. Still others would have been useful to the security department as t a
iniciligence relating to drug abuse on site._ The remainder..were probably of little value to anyone. The Ley, however, is that notwithstanding the

. otations of the Q1 files, the security department has received only four of ac w antren alleptions. At the seme time, only one or two of the case ,

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'M6 rs u.c'itate any feedback from securf ty as a result of these referrals.

D':' oh is cent case folders indicate that the referrals have been made to the i a trw tion a.reger, none of the fiics reflect any feed back as to action f

' - U. n . (l"a n interviewed, the Construction l',anager indicated that these drug i.ili L.tions sc re passed on to the affected managers; for instance, for alle-

[ ri bns in.olving Daniel International personnel, the Daniel Construction

  • i.'5;cr w s informed).

/.t 1(si P4 of the case files contained allegations or implications of harass-r 0,1 cod intimidation, several of them quite serious. At the outside of the  ;

ai.luation, none of these have been referred to the NRC. (Some of these 4 L. ia sment and intimidation cases contain drug alle,gations as well as other ~

ellc9ations of wrondoing: in other vords there is overlap between the cat- '

i grics of wrongdoing that 1 am describing.) The following are repre-T L -_

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sentative of some of these allegations: A QC inspector asserted that he has -i '

been ordered to inspect strictly in accordance with what he felt were inade-quate procedures, and was harassed when he complained; e QC inspector for j Technical Metals, Inc., clairaed that he was harassed and intimidated for cooperating with Q1 in April 1984 (The Q1 investigator's notes reflect his belief that federal icw had been violated); a QC inspector who, made record falsificetion allegations to the fiRC was subjected to various forms of harass-r.ent prior to his. terroination to include being assigned to a desk irtrnediately adjacent to an individual cohabitating with the inspector's estranged wife; an ,.

allegation by a forTner QC inspector who claimed that he was blackballed from employrient at another nuclear site and that his confidcntiality had been '

b re a c hed. This last case is particularly interesting as hGl.E files reveal that this individual earlier had been the unwitting victim of an apparent illegal search of his vehicle during which documcnts contained in a box of his prrsonal possessions were removed and destroyed by licensee officials. (The of ficial allegedly involved in both matters is the l'.anager of Quality

/.ss urance )

I found at least 8 cases which involved alleged record falsification, fione of these, to the best of my knowledge, have been reported to the fiRC. Addition-ally, there were several cases which contain allegations that, if true, cast doubt on the independence and integrity of the Quality Assurahce Program.

Jndeed, many of the more technical allegations carried with them this same implication.

As I indicated above, only one of the epproximately 25 personnel assigned to the Q1 Program has had any formal investigative experience or training. The bulk of the individuals assigned to this organization appear to have a Quality

/.55urance or a Construction background. Nonetheless, I was very favorably iupressed with the attitudes of most of the personnel that I encountered.

There were uniformly bright and knowledgeable regarding the ectivities of the site and at least at the working level, appeared to be comitted to quality.

!?onetheless, their lack of investigative c>.perience was evident, in 6t least two arees, the attitude with which most of them appeared to fc.llow alle-gations, and their ability to docunent the results of their efforts.,

With regard to the first, it appears that the average Q1 investigetor pursues illegations as if the alleged deficiencies were only the product of either theddy workmanship or icziness. By;this 1 mecn few if any appear to approach the allegation from the perspective that the deficiency may be deliberate, i.e., that it may involve-wrongdoing. Some of them appcer to be either rnicilling or ur.able to draw inferences from observed deficiencies. As an t geple, some, when given the hypothetical c> ample of an alleger providing

? g cific information regudir.g clearly defective pipe hangers which had been 7ttepted, volunteered that this condition may have been a product of an 4 irproperly trained QC inspector. lione of them appeared to be alcrt to the  ?

fact that if the hanger were rejectable, then clearly the inspection records supporting them would be false. Even when this condition wes pointed out, only one suggested that the record falsification msy have been a product of '

hr.ressment and intimidation.

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- ,,f i n E. , Htyr s .6 Dec e:r.ber 21,19S O*

It was also not cicar to me just exactly how investigations were being -

conducted. It appcared to be highly variable. Although, most investigators indicated that they personally would look at suspected hardware, generally the responsibility for examining additional related hardware was given the affected construction organization. In short, quite a bit of traditional investigative work was given other entities for accomplishment with predict-ably variable results, let alone questionable objectivity.

Q1 investicative reports seldom p'rovide the detailed documentatiop to support .,

ihcir conclusions that we expect in'01 reports of investigation. ' They are at best bare bones efforts- that do not provide the reader an opportunity to see the cvidcnce relied upon by the investigators to arrive at their conclusions.

They apparently are construed as adequate enough by KG&E to allow them to cor-r ect deficicncies as quickly.as possible. It is highly likely that KG&E does not crpect these reports to be the literary or professional equivalent of 01 reports of investigation. Nonetheless, it is not unreasonabic*to. establish a 5 ttndard approaching that of 01's for such reports of investigation if KG8E a ishes an outside party such as the NRC to rely upon them in reaching an informed jedgment. I might add that there is one interesting. contrast. The, one trained investigator in the Q1 Program tends to produce Q1 reports of investigation of approximately the same degree of coverage as that'of his rel6tively untrained co-workers. On the other hand, the reports that,he.

produces for the General Counsel appear to be highly professional; i.e., they are quite ec11 written and detailed. -

I In the final analysis, I do not have a great degree of confidence in the Q1 F rogram. I certainly could not accept it as a suitable substitute for O!

offorts - at leest in the areas of wrongdoing which f all within the ambit of the 01. I say this bt sed only in part upon the deficiencies.that I have tited above. .

I als o was s truck by the general sense of fruitration evidenced by many of the f: ality first personnel as well as other Wolf Creek personnel w.ith whom I pcLe. The consensus appeared to be that harassment and intimidation was

.,;ite prevelent at Wolf Creek, especially within the Daniel International i i p r.intion, and that there was little thdt they could do to cbrrect it.

Scy did .not appcar to feel that they crdoyed any great support from their i wment structure, and indeed, that is not an illogical perception. Their 1 u r

  • r:nt st ructure is cc" posed of those f persons whose favorable employment

. aluttions are bcsed priu.rily on their ability to have Wolf Creek meet its w hi dahd fusi load date., Indeed, fuel load appears to be a recurring theme 1 he t one boars all over the site. This is understandable, it is even pre-dii ble, but it does not mal:e for an independent investigative program

'..- led i.ith the nur..bers and types of personnel needed to do the job. There

'5 Leon coosiderable turwver in the Q1 work force which is attributable to I t e at ens raore than the desire to find rsore stable employment in the face of a cc itible loss of job at the end of construction. At least two former Q1  !

e eployees asserted to me their belief that the program was viewed as a , l j

tir;drance to fuel load by the Vice President-Nuclegr. They and others appear l

to be genuinely contcrned about the effect of harassment and intimidation, i

trpecially by Daniel, on v. ell-intentioned and sincere craft personnel who L

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,, .,.Een B. Hayes 7 December 21, e, ,

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l bring deficiencies to the attention of the fiRC, 01, or even their own .

supervisors. .

L'ith regard to the harassment' and intimidation, it should be noted that KG&E has made a concerted ef fort to have employees bring such allegations to the

, attention of Q1 which in turn would have the ostensible mission of redressing the employees' complaints. Q1, hoveever, does not advise the complainant of his or her protections under Departr.ent of Labor (DOL) and f?RC r(gulations.

As a consequence, if .Ql's etter: pts to redress the employees' concerns are "

unsuccessful, i.e., they are vr.able to develop sufficient information to substantiate the employee's esserticns, or they are unable to coriect the l condition which led to the complaint to begin with, the 30 day period in which the employee must act to preserve his or her D0L rights is expired. This has the ef fect intended or otherwise of depriving employees of their right to DOL protection. j As I have mentioned to you previously, during'my evaluation I developed information relating to the character of certain senior KG6E officials. I will provide the details of this to you separately.

Fued on my evaluation, it is ny recommendation end firm belief that the flRC ~

should not rely on the results of the fG6E Investigative Program. Ra.ther, it should insist that reatters f alling within the jurisdiction of the L'RC be promptly reported through existing reporting channels, and a decision made at such time regarding the necessity of liRC interver. tion. At the same time, I do not wish to close on such a totally negative note. I strongly believe that licensee investigative programs are a step in the right direction, and that further, KG8E does have the nucleus for a fine program. We must be very ccieful not to throw the proverbial baby out with the bath water. With some wdifications along the lines that I have either suggested or alluded to in

~

this evaluation, I believe that this Agency could place increased reliance t.pon th~e licensees work products so long as it is assured of the candid and prompt reporting of relevant information. .

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. EXHIBIT _

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,/ % UNITED STATES

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$ ** ,4, g-r

$ NUCLEAR REGULATORY COMMISSION

$ , OFFICE OF INVESTIGATIONS FLELD OF(lQh,RE0bN IV .

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611 RYAN PLAZA ORIVE, SUITE 1000 ARLINGTON. TEXA,$,7%Q]{

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February 15,1985',;-illf-T0: Ted Gilbert l

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FROM: Richard Herr  !

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SUBJECT:

Q4-84-018(S)

Attached is the Supplemental Report Q4-84-018(S) to be filed in the 01 Field Office file folder for case Q4-84-018 whibh has been transferred to headquarters. Also attached is one page of the investigator's handwritten notes to be maintained in the file folder. '

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UNITED STATES j#

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NUCt. EAR REGULATORY COMMISSION .

OFFICE OF INVESTIG ATioNS FIELD OFFICE, REGloN IV I

% .[ . * * "EENO o .TE7 S 7 REPORT OF INQUIRY April 11, 1984 .

SUBJECT:

WOLF CREEK h0 CLEAR GENERATING STATION, BURLINGTCf , KANSAS:

ALLEGED INTIMIDATION OF QUALITY CONTROL INSPECTORS REPORT NUMBER: - Q4-84-618

1. On January 28,1984,5 ,'[a mechanical welding quality +','70-control inspector made allegations to1he NRC resident site inspector that he was harassed by a construction hanger superintendent over a nonconformance report cealing with improper welding amperace used on hangers at the Wolf Creek Nuclear Generating Station (Wolf Creek).
2. On March 9, 1964, the Region IV O! Field Office obtained a copy of Nonconformance Repert No. ISN-1534Z-PW relating to Daniel International that involved improper welding amperage used on hangers at Wolf Creek. A copy of this report was given to the Regicn IV technical staff for evalu-ation to determine if the nonconformance report (NCR) had been dispcsitioned properly. A written evaluation of the NCR was conducted by L. GILBERT, -

Engineering Section, Region IV NRC, wherein GILBERT advised that the disposition of the NCR is acceptabic. A copy of this NCR and the corresponding evaluation of the NCR are included with this Report of Inquiry as Exhibits (1) and (2).

3. On March 9, 1984, William M. LINDSAJ, Supervisor cf Quality Systems, Kansas Gas and Electric Company (KG&E), informeo 01 that a complete and comprehensive investigation of the original allegatien was being conducted b the utility. LINDSAY infomed OI that the results of the investigation lc be turned over to Region IV for evaluatier ir approximately 45 days.

lpon receipt by 0I Field Office (0!F0) Region IV of KG&E's investigative report, it will be evaluated by CIFO and/or Region IV. If the evaluatien determines that additional investigative effort is necessary, then the OI Field Office and/or Region IV will initiate appropriate action.

Exhibit (1) tiemorandum from L. GILBERT 3-14-84 Exhibit (2) Nonconformance Report No. ISN-15342-PW 12-01-83 Exhibit (3) Memorandum from W. S. SCHUM 2-07-84 REPORTED BY: -

'Wencel E. Frost, Investigator 01 Field Office Region IV APPROVED BY: / A!,

Ricnara~K. Herr, Director I OI Field Office Region IV ,

  • cc: E. C. Gilbert w/ exhibit J. T. Collins w/ exhibit T. F. Westerman w/o exhibit JO NO" ISC _0S E ,

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