ML20198B794

Discusses 841024 Telcon W/M Vining & 841025 Telcon W/ R Fortuna Re Release of Util Documents by Ofc of Investigations.R Fortuna Understood That Util Would Provide Investigative Repts Upon Request

ML20198B794
Person / Time
Site:	Wolf Creek
Issue date:	10/31/1984
From:	Herr R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20198B650	List: ML20198B645 ML20198B658 ML20198B665 ML20198B673 ML20198B682 ML20198B760 ML20198B775 ML20198B781 ML20198B794 ML20198B806 ML20198B818 ML20198B832 ML20198D229
References
FOIA-85-101 NUDOCS 8511070255
Download: ML20198B794 (1)

Text

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[* "%,5 uNiTEo statts _Lu p NUCLEAR REGULATORY COMMISSION y I

,g .! OFFICE OF INVEEUGADONs FIELD OFFICE.F.EGION IV , p Y.', / '

'" "EiO^EYEEs'EII " la October 31, 1984 -5 AN 11: 30 "fEi Lf LWESiictJ! .y' E W M IEns MEMORANDUM T0: File -

FROM: R. K. Herr, Director Office of Investigations Field Office SUSJECT: TELECON ON OCTOBER 25, 1984 WITH ROGER FORTUNA REGARDING RELEASE OF KG&E DOCUMENTS TO 01

1. On October 24, 1984, I talked to Mr. Mark Vining, legal Counsel for KG&E, concerning the release of documents from KG&E's completed and/or ongoing investigative reports to 01. Mr. Vining explained that he is in possession of an internal KG8E document which he described as a

" Memorandum of Agreement" between Mr. Roger Fortuna and KG&E's legal representative identified as Shaw, Pittman, and Towbridge located in Washington, D.C. Mr. Vining stated that according to the agreement, only the investigative report would be released to 01; not the associated documents. Mr. Vining emphasized that 01 has access to any file, document, folder, or exhibit in the Quality First program, but because 01 would not protect these documents from F0IA requests, most documents associated with investigative reports would not be released into the custody of 01.

2. Mr. Vining repeatedly expressed KG&E's willingness to cooperate with 01.

3. On October 25, 1984, Mr. Roger Fortuna advised that Mr Vining's definition of the " Memorandum of Agreement" was not his (Fortuna's) understanding of this agreement. Mr. Fortuna advised the Region IV OI '

Field Office it was his understanding that KG&E would provide to 01  !

investigative reports upon request and those investigative'neports would ..

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be " complete reports" wherein the associated documents would accompany ,

the investigative report. Mr. Fortuna stated that he had recently, a within the past couple of days, discussed this situation with a Washington based law firm (Shaw, Pittman, and Towbridge) representative and expressed 01's understanding of the agreement.

R. K. err, Director Office of Investigations Field Office cc: Ted Gilbert, 01:HQ File k

8511070255 851015 PDR FOIA VARRICCB5-101 PDR l .o

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In Reply Refer To:

Docket: STN 50-482/84-37 Kansas Gas and Electric Company ATTN: Glenn L. Koester Vice President - Nuclear P.O. Box 208 Wichita, Kansas 67201 Gentlemen:

This refers to the inspection conducted by Messrs. E. F. Fox, Jr. , G. L.

Madsen, and W. P. Haass during the period of September 25-27, 1984, of activities authorized by NRC Construction Permit CPPR 147, for the Wolf Creek Generating Station, and to the discussion of our findings with Messrs. R. M.

Grant i ad C. A. Snyder, at the conclusion of the inspection.

Areas examined during the inspection included the structure and implementation of the KG&E Quality First Program. Within these areas, the inspection consisted of selective examination of procedures and representative records, intcrviews with personnel, and observations by the inspectors. These findings ,

j are documented in the enclosed inspection report.

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Within the scope of the inspection, no violations or deviations were '

identified.

The Quality First program provides a mechanism to receive, evaluate, and J resolve geality concerns which might not otherwise come to the attbntion of ' -

KG&E, or to the attention of the NRC. Because the program fulfills an it.portant function, we decided to evaluate its effectiveness even though the program is not specifically required by NRC regulations. Although the NRC inspectors did not identify any violations or deviations, they did identify deficiencies requiring some correction to help ensure an effective program.

It is impcrtant to emphasize that the f4RC inspectors reached favorable conclusions regarding evaluation of technical concerns based on a review of past pt.rformance, as established by closed technical files. Since the Quality F.irst program has recently undercone very sionificant chances in tranagement structure, resource assignments, supervisory personnel, senior experienced personnel, and the details of implementing the program, KG&E senior management should be upecially alert to indications of deletericus changes in program impleentgion.

Q[ Q PASA/I off I E,t@_ - PSA/ @ WCTF,M D/WCTF RPDenise p jEFFcx:-Q;D LEMartin M/ / /84 M WN6 ass }/gLMads'en M/ / /84 M/ / /84 M// /84 IQ/1,/84 V # # # A

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i Kansas Gas and Electric Company -

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

Sincerely, Richard P. Denise, Director Wolf Creek Task Force Encicsure:

App:2. dix - NRC Inspection Report 50 4E2/84-37 cc w/ enclosure:

Kar.sas Gas and Electric Company ATTN: Gene P. R6thbun, Manager of Licensing P.O. Eox 208 Wid ita, Kansas 67201 Tco: cst Rhodes, Plant Superintendent L'oif Creak Generating Station P.O. Box 309 Euilington, Kansas 66839

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e 1 cc '.o C:3 (IE01) b'cc distrib. by'RIV:

RFS1 P. O'Connor, NRR K. Kneil, NRR RF52 Resident Inspector R. D. Martin, RA E PL t:i'S Section Chief (RPS2/A) C. Wisner, FAO

'RIV file R. Denise, DRS&P MIS System "yrt n i: ora.an, ELD, M :EB (2) R. Walker, RIII

'A'.t AS 11 ATE DEPT. HEALTH R. Smith m

APPENDIX U. S., NUCLEAR REGULATORY COMMISSION REGION IV NRC Inspection Report: 50-482/84-37 CP: CPPR-147 Docket: 50-482 Category: A2 Licensee: Kansas Gas and Electric Company (KG&E)

P. O. Box 208 Wichita, Kansas 67201 F6cility Name: Wolf Creek Generating Station (WCGS)

Inspection At: Wolf Creek Site, Coffey County, Burlington, Kansas Inspection Conducted: September 25-27, 1984 Inspectors: ,

EdWin F. Fox, Jr. , Technical m /ONh j AMistant Date PSAS, IE

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/0 - V- WY 131en L. Madsen, Reactor Inspector Date

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N'?-SV Walter P. Haass, Special Assistant fcr Date Allegations and Investigations, IE Ipprcued: n ///x &

T_.-E. Hartin,' Chief Wol f Y

' Creek Task Force

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Insy ction Su=ary Inspection Conducted September 25-27, 1984 (Report 50-482/84-37)

Arcas Inspected: Routine anncunced inspection of the structure and implementa-tion of licensee programs for investigation and resolution of quality concerns rcruiting from exit interviews with licensee and licensee contractor erployees, Galk-in interviews and hot-line telephone calls. The inspection involved 53 inspector-hours onsite by three NRC inspectors.

Ersults: Within the areas inspected, no violations or deviations were i de nti f ir-d.

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2 DETAILS ,

1. Persons Contacted Principal Licensee Personnel

• R. M. Grant, Director - Quality

• C. A. Snyder, Manager - Quality First

0. L. Thero, Quality First Interview Supervisor R. L. Scott, Quality First Investigation Supervisor R. k' alters, Quality First Investigator L. C. Issinghoff, Quality First Interviewer Mark Stewart, Engineer / Quality Assurance f.'RC Personnel

' Richard Denise, Director Other Personnel 0- .r licensee employees contacted included technicians and office sonnel.

' Attended exit interview.

2. Exit Interview The inspection scope and findings were surmtarized on September 27, 1984 with those persons indicated in paragraph 1 above.

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3. Croeni7aticnal Structure of KG&E Program for Processing Allegations The KS&E Quality First program for processing allegations is implemented -

ur. der the direction of C. A. Snyder, Manager-Quality First, who reports to .

P. M. Grant, Director-Quality. The latter reports to G. L. Koester, Vice )

F res icent-fiuclea r. The Quality First organization is acceptably located I.

within the KG&E organization to assure proper attention and independence.

T!,is is a recent change from the prior orcanizational arrangement in which the r+-sicnsibility for Quality First was assigned to W. J. Rudolph,

ariagar-Quality Assurance. The new arrangement minimizes the potential for conflicts of interest in the processing of allegations.

4 Fog,Flity of the Effort as Reflected in Official Instructions Fce:.al cuidelines for reporting quality concerns (Project Directive III-29) and for processing the concerns by Quality First (QPM 19, Rev. 0) are docun,er.ted and have been made available to affected personnel, n ever, our inspection identified the r.eed for additional guidance in the fGlwir g areas:

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a. Processino of wronadoina alleaations.

b. Responsibilities of the Engineering Support Group.

c. Definitions of Priority 1 and 2 categories of concerns.

d. Trending analyses to assure identification of generic concerns.

e. Qualification criteria for staff personnel.

Guidance for the processing of wrongdoing concerns (i.e., drugs, alcohol, intimidation, harassment, discrimination, falsification) was particularly deficient. Responsibility for the resolution of these concerns, involve-ment of management, and the procedures for closecut were not described.

5.,lInformationFlow y'." i Procedures for the flow of information as stated in QPM 19, Rev. O are

, l/\ adequate,withtheexceptionthatnofeedbackmechanismexistedfor p6h Y wrongdoing concerns directed to Security or KG&E management that may also include technical deficiencies, and there was no feedback mechanism from

/(yay Security or KG&E management regarding corrective action or disposition of

's wrongdoing concerns for file closecut.

6. l Fumber and Qualifications of Personnel

[ .f, The Quality First organization was found to be comprised'of three inter-viewers, one engineering support person, and thirteen investigators (for sI ~. [ resolving technical concerns) with each group directed by a supervisor. A yC h * }i .

request has been made and approved for ten additional investigators who are expected to be available shortly. Continuing attention appears to be devoted to staffing needs based on the number of concerns received to date

' ]r d.F [ (f. L-and the number anticipated from the remaining site contractor personnel.

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The qualifications of the Quality First staff, based on the review of resumes, appeared to be adequate for the assigned respcnsibilities in the various engineering, welding and quality assurance areas of expertise.

Mcwever, no documented qualification requirenents for these positions were given in QFM-19 to provide continued assurance of qualified staff -

personnel. Further, use of specific investigators to resolve quality concerns consistent with their areas of expertise should be properly coordinated.

7. Precision and "deguacy_ of Decision Making Ppotesj f 7 G %.w f /

A review of all the 27 closed technical quality files (some of which include more than one concern) was conducted through the evaluation of file documentation. It was concluded that the disposition of the tech-nical concerns was adequate up to the point that the concern was sub-stantiated or detepined to be without merit; technical considerations of ec'ec.uate broadnesf'were applied in the evaluation.

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4 Documentation and Record Retention For the closed technical files, documentation appeared adequate and complete to facilitate auditing of the records. In addition, all records are maintained in a confidential manner to protect the identity of the allegers and are filed in accordance with QA program commitments.

Mani.gement Notification A review of the completed technical actions indicated that upper management is notified of the results of the investigation (whether substantiated or not) and provided a copy of the investigative report.

Management participates in Quality First meetings once every two w eks.

Monever, the inspectors found no documented evidence of management feedback with regard to concerns tracking, analysis, job performance, or suggested improvements. _

n Trending and Assessment of Trends j et W' 1 -

Trending activities currently encompass projection analysis for total program scope definition, and identification of common technical areas across the various quality concerns. The latter could be useful for identifying generic concerns.

prg_lcr ntation of the Ouality First Program Based cn the review of the technical files closed thus far, the Quality First organization is effectively tr;plementing the program as planned and defined in QPM-19. The review indicated that the technical concerns egea,r to have been closed properly.

A brief review of those concerns involving wrongdoing (12 files were reviewed) indicated that in most instances they were transferred from Quality First to Security (for drugs) or te, KG&E management for corrective action or disposition after Quality First investigation. However, ng. -

1. ccur.r.tation was found to describe the corrective action or disposition  ;

of the cm.cerns and ' here was no feedback from these organizations to Quality First for closecut. With regard to appropriateness of involving  ;

DOL on matters of discrimination, KG8E indicated that employfe protec;ive V, , t rights are posted at various plant locations, g / j ;j , g , ,, j 2'+-; d '? - gt e 4 [ e Pr,ior,ity_ Treatme t of Concerns f , l t l' Quality First has established categories for assigning priority for the L' procrtsir.g of concerns. Priority 1 concerns are those determined to i impact fuel load, while Priority 2 concerns are those of a less '

significant nature. However, as stated in item 4 above, QPM-19 does not ,

address the criteria for determining the placement of concerns in each  ;

NRC needs to be kept informed regarding category placement  ;

category.

decisions for all quality concerns.

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5 i 13. Progress of Effort Toward Resolution of Concerns The licensee is apparently intent upon resolving all of the quality concerns, Priority I as well as Priority 2, by their projected fuel load date. As of September 27, 1984, there were 342 open concerns, of which 212 are Priority 1, and 220 closed concerns, of which 77 had been transferred to other KG&E organizational units for resolution. The licensee is aware of the backlog and the effort required to resolve the issue. Resources necessary to accomplish this task prior to fuel loading have been authorized. The licensee is also fully aware of the need for NRC to be informed regarding the adequate resolution of all quality concerns.

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CTATE oF KANSA3

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HOUSE OF REPRESENTATIVES February 14, 1985 The Honorable Nunzio Palladino Chairman M@lg Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Chairman:

We, the undersigned, members of the Kansas Senate and House of Representatives, are deeply concerned with the approach-ing conditional licensure of the Wolf Creek electrical generating station. It is our understanding that this licensure may occur in spite of the fact that open investigations exist into matters such as alleged construction defects and quality assurance de-ficiencies. Since such matters are directly relevant to the issue of plant safety, we ask for your assistance.

Correspondence between your office and the offices of Congressman Dan Glickman and Congressman John D. Dingell has been made available for our review. It is clear from our

. review of the Congressmen's questions and your response that:

1) A substantial number of structural steel welds have been found to be below accepted standards;

2) Investigations into the weld deficiencies are underway, l- including such issues as missing, falsified or erroneous l quality assurance records; and

3) Unanswered safety questions remain, including problems relating to the safe separation of electrical cables.

We have, for several years, expressed our concerns and our citizen's concerns relating to the safe and economical pro-duction of nuclear-generated electricity. The Wolf Creek project has been the object of scrutiny from this Legislature l

and from other agencies of state government. We have attempted j to maximize the ability of our utility commission to review l the project and determine the extent to which the ratepayers will assume construction related costs.

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Honorcblo Nunzio Pallcdino

~ February 14, 1985 Page Two However, Congress has established that your commission )

is the review mechanism for all matters relating to the safe  !

construction and operation of nuclear plants. It is in that  !

capacity that we seek your assistance.

We ask that all investigations, including any pre-invest- i igation matters pending in the Office of Investigation and  !

of Inspection and Enforcement, be concluded in a comprehensive and thorough manner. We ask that your findings be made available to us, to the Kansas Congressional delegation, our Governor and Attorney General, and to the Kansas Corporation Commission. We ad that these things be done prior to the issuance of a conditional, low-power operating license.

When the power is turned on at Wolf Creek, it is essential that all questions have been answered and all safety standards met. Only these conditions will provide the needed assurances to Kansas to validate the operational integrity of the Wolf Creek plant.

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We ask for your prompt response, and express our appre-ciation for your consideration of this matter.

Sincerely,

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I? k AAwads. ,kJ Rep. R.H. Miller Step. rvin Wm. E rkis /

1 Johnston Se Wint Winter

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ns,een's o to os scmetnow inn a. m*== .e EDO Control: 000367 3/06 1

SECY No: 85-136 'N - -1rilliam Hard 1 EXPRESSES CONCERN OVER LIM M M A'T MOLF CREEK ,

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g f% UNITED STATES g NUCLEAR REGULATORY COMMISSION 5 wasmesorose, p. c.soses ED0 PRINCIPAL CORRESPONDENCE CONTROL .

FROM: DUE: 03/08/85 EDO CONTROL: 000367 DOC DT 02/14/85 REP. R. MILLER, ET AL FINAL REPLY:

KANSAS CONORESSIONAL DELEGATION TO:

CHAIRMAN PALLADINO FOR SIGNATURE OF: ** PRIORITY ** SECY NO: 85-136 EXECUTIVE DIRECTOR DESC: ROUTINO:

EXPRESSES CONCERN OVER LICENSING OF WOLF CREEK DIRCKS ROE DATE: 02/22/85 REHM ASSIONED TO: NRR CONTACT: DENTON STELLO TAYLOR RMARTIN SPECIAL INSTRUCTIONS OR REMARKS: Lel-OCUNNINOHAM PREPARE REASSURING ANSWER.

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CORRESPONDENCE CONTROL TICKET 5ECT NtMBER: 85-136 LOGGING DATE: 2/20/85 0FFICE OF THE SECRETARY ACTION OFFICE: EDO .

AUTHOR: R.H. Miller, et al AFFILIATION: State Senate & House of Reps. of Kansas LETTER DATE: 2/la/85 FILE CODE:

ADDRESSEE: Chairman Palladino

SUBJECT:

Expresses concern over licensino of !b1f Creek.

ACTION: Direct Reply. Suspense: tiarch 3 DISTRIBUTION: E D&SB Rec'd Off.JD0 08! . . 7 ~ A W T h.ie.... / d , ~~ '

SPECIAL HANDLING:

. SIGNATURE DATE: EDO --- 000367 FOR THE COP 9(ISSION: Conbs ,

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