ML17055D484
| ML17055D484 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 01/11/1988 |
| From: | Kane W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Donlon W NIAGARA MOHAWK POWER CORP. |
| References | |
| EA-87-104, NUDOCS 8801200224 | |
| Download: ML17055D484 (62) | |
Text
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50-410 License No.
NPF-69 EA 87-104 ATTACHMENT 1 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 631 PARK AVENUE KING OF PRUSSIA, PENNSYLVAN!A1940C Niagara Mohawk Power Corporation ATTN:
William Donlon President 301 Plainfield Road
- Syracuse, New York 13212 Gentlemen:
Subject:
NRC Office of. Investigations (OI) Report No. 1-85-020 This refers to the investigation conducted by the NRC Office of Investigations (OI) concerning (1) the adequacy of your Quality First Program (Q1P) investi-gation of the circumstances associated with the installation of certain neutron monito;ing system (NMS) cables at Nine Mile Point, Unit 2, in May, 1985, and (2) the accuracy of the facts concerning the installation effort as reported in a letter to the NRC dated July 11, 1985.
The Q1P investigation had been conducted after the NRC had informed your Executive Director for Nuclear Operations, in a letter dated June 7, 1985, that this office had received an allegation that there was improper installation of the NMS cables due to excessive pulling tension, inadequate quality control (QC) coverage of this activity, and improper pressure by contractor employees to complete installa-tion.
The OI Report of Investigation Synopsis is enclosed.
Although sufficient evidence was not developed during the OI investigation to demonstrate that improper pressure had been exerted on contractor employees to complete the installation of the cables, the information developed during the Ol investigation demonstrates, at a minimum, that the July 11, 1985 letter to the NRC was incomplete and misleading.
That letter, which was signed by the Director of Quality Assurance and reviewed by your Nuclear Compliance and Verification Group, stated that the installation of the cables was technically satisfactory, and the QC Program was adhered to; however, the letter did not indicate that (1) pushing of the cable during the installation was done without a procedure, (2) pulling of the cable during the installation was done without using a tension monitoring device, as required, and (3) Quality Control per-
- sonnel, although physically monitoring the installation effort as required by the QC program, did not have specific inspection criteria and inspection procedures available to determine the acceptability of the cable installation.
Although the procedural violations associated with the installation effort were previously identified during an NRC inspection conducted in November and
- December, 1985,
(
Reference:
NRC Inspection Report No. 85-42) and were cited in a Notice of Violation sent to you on January 22, 1986, the NRC is also concerned that the July ll, 1985 response to Region I was incomplete and misleading, and the QlP investigation which formed the basis for that response was not adequately
- planned, conducted or evaluated.
In particular, (1) the individual responsible for conducting the investigation, although investigating an electrical cable installation activity, was lacking in electrical experience; (2) the investigator used poor investigative techniques, such as interviewing
Niagara Mohawk Power Corporation personnel in the presence of their,supervisors and not interviewing craft personnel; (3) neither the investigator, nor the QIP manager responsible for overseeing the investigator, adequately analyzed and presented the facts obtained during the Q1P investigation; and (4) the Director of QA, as well as the others who reviewed the letter, apparently did not recognize these deficiencies.
These deficiencies raise questions regarding the adequacy of your Quality First Program in resolving employee
- concerns, and the adequacy of your communications with the NRC.
Furthermore, the NRC SALP Report sent to you on May 14, 1986 also raised concerns regarding the level of Q1P documentation to substantiate closure of employee concerns.
In addition, the NRC SALP Report sent to you on August 12, 1987 describes concerns regarding corporate management involvement and internal communications while handling QA concerns brought to the attention of Q1P personnel.
In view of these findings, we plan to schedule an enforcement conference to be conducteo in the Regional office within the next 30 days.
During the conference you should be prepared to discuss (1) the underlying causes of these Q1P and communication deficiencies, (2) the corrective actions taken or planned to correct these deficiencies and prevent recurrence, and (3) the reasons the NRC should believe that your QIP program now provides an acceptable outlet for allowing employees to raise safety concerns, and for having these concerns promptly and effectively resolved.
When you have reviewed the enclosed Report Synopsis and a'r e prepared to discuss its findings please contact us to arrange the date and time for the conference.
Your cooperation with us in this matter is appreciated.
Sincerely, Wi liam F.
ne, Director Division of Reactor. Projects
Enclosure:
,As Stated
Niagara Mohawk Power Corporation CC:
Connor 5 Wetterhahn John W. Keib, Esquire J.
A. Perry, Vice President, guality Assurance Troy B. Conner, Jr.,
Esquire C.
V. Mangan, Senior Vice President - Nuclear T.
E.
- Lempges, Vice President, Nuclear Generation T.
W.
Roman, Station Superintendent, Unit I J.
C. Aldrich, Superintendent of Operations, Unit I R.
G. Smith, Superintendent of Operations, Unit 2 A. Z. Pinter, NMPC, Site Licensing
- Director, Power Division
.W. Hansen, Manager Corporate guality Assurance C.
- Beckham, Manager, Nuclear gA Operations T. J.
- Perkins, General Superintendent R.
B. Abbott, Station Superintendent Department of Public Service, State of New York Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New York
0
ENCLOSURE SYNOPSIS The NRC recoivad an anonymous letter, dated May 20, 1985, alleging impropriatio~
in the ins+allation of the Neutror. Mnritoring System (ttt'S) cables at hine Mile Point, Unit 2 (NMP-2).
Specifically, it alleged improper management pressura and the over-tensioning and breaking of twn cables due to the application c
excessive pul'. tension.
On June 7, 1985, theNRC referred this natter back Tc Niagara Mohawk Power Corporation (NMPC) for resolution of the concerns; whereupon NMPC's Director of guality Assurance (gA) referred the matter to IlMPC's equality First Program (01P).
6:P reviewed relevant OC Inspection Paports
!IRs), cable pull tickets, and'or conformance E Dispositions (NEDs).
They alsn interviewed eight OC pa~scrnel, three individuals from enqineering, five cnnstruction supervisnrs, one proiect
- manager, and three craft supervisors.
Some of these were interviowed in groups and, in several instances, in the presence of their superiors.
The glP ir vestigator advised that he received such detailed information from the individuals he interviewed that he felt it was unnecessary to ques".nn craft pe'rsonnel, opining that to interview craft level personnel would have
- beer, a
waste o, tima.
In a letter dated Julv ll, 1985, NMPC's gA Man~aar raported glP's f'.r.Rings to tha NRC.
He reported that the installation of the cabla was technically satisfactory, the OC program was adhered to by qualified parsnnnal, and there was no evidence of inproper pressure by supervision.
He added that there would be continuity and -'nsuletion resistance testing perfnrned on the installed cable during the month of July, with a gA technician assicred to moritor the tests.
Prior +n submission of the July ll letter, NMPC's Nuclear Compliance and Verification (HCLV) Grc up at NhP-2 reviewed a draft of glP 's findings.
Pcl ing the OI investigation, NCSV personnel stated that they were directed tn assist
(}1P by reviewing the draft but not raquested to perform a formal review and verificatior effort.
Consequentl~~,
they advised that they did not dn any field work or research to develop supporting documentation for the statements cortained within the letter.
A system attorney for NMPC also reviewed the July ll letter;
- howevar, he testified that he did not check the facts, assuming they were as stated.
In Septamber
- 1985, an alleger approached a'rapresentativa of the Nav York State Public Service Commission
.(NYSPSC) raising questions about the adeauacy of the g!P investigation into the NMS cable concerns, tha breaking and over-tensioninq of cables during installation, and pressure on construction workers to complete the installation.
On October 3, 1985, the Regional Administrator requestad that 0'etermine the validity of the allegatinn that ~
the 01P investigation did not accurately report the facts of the incident in the licensee's July 11 letter.
The investigation included an'xamination of the adaouacy of the installation and associated procedural compliance, including adherenca to the gA'rogram; as well as the questior nf improper pressura by supervision and the overall adequacy of the licensee's invastigaiRve and review effort.
Case No.
1-85-020
0
'I The July lI, 198'5, response advised that the concerns about cable pullina appeared tn refer to a "mock'ull and "nn nne" had any knnwledae nf over-tensinr ina or breaking the cables.
It further descr',hed the techniquo. of
~rstallatinn as a "push" technique that had been approved by enair oerir c and utilizing the tnw line as a guid~.
- However, OI interviews of OC inspec+nrs, craft personnel and supervisors, snab o'f whom had been previously interviewod
.by 01P, disclosed that a combination push/pull method was emplnved to effect cable installation.
Thes>> individuals alsn disrlosed that, even though pull tensinn was employed during installation, there was no tension mnnitnrinq, as
~equir'ed by the criteria set forth in the cable pulling procedure.
- Also, there was nn written documentatinr. reflecting review and apprnval of the "push" technique, which most acknnwledaed was a new method and nest the norm for cable installation at NMP-?.
OI interviews revealed mixed recollections regarding a "mock" pull prior tn installation.
However, interviews with craft and gC personnel disclosed that in several instances either an NMS cable conductor broke durina installation or, at the very least, separated or disconnected frnm the plastic pnlywater hose that was used to guide the cable and pump lubricating.fluid irtn the cnnduits.
These instances of either a break or disconnection/separation were during installation and not limited tn problems encountered during a "mock" nr test pull nperatinn.
Further, thev were alleaed hv some tn have been related tn QIP personnel durina their investigative effort.
Craft personnel also
- indicated that the amount nf pull tension applied durinq installatinn varied anywhere from the use of one or twn fingers as a guide on the plastic polywater
- hose, to pullino w'.th one hand and one an and including the exertion of possiblv 80 pounds of pu'.1 pressure on some of the more diffi'cult and lengthy uns.
The majnrity nf the NMS cables (i.e., Hark Nn. NJP-2a) had a pull tensinr. limit of 35 pounds.
Additionally, there is nn OC inspection prraram/criteria for cahle "pushing" at NMP-?.
Mhen questioned as tn what criteria was being applied durinq inspection, OC personnel advised they were visually observing the physical integrity of the cable.
They admitted that they were limited tn,iudning how much tension was applied, and one OC inspector'ndicated that periodically ho, had tn caution the craft personnel to back nff on the amnunt of pull tensinn beina applied.
OC personnel acknowledged that, although they did nnt think any cables were damaqed during irstallatin'n, it was impossible tn say whether any cables were over-tensiored, because tensinn mnr itnrina devices had nnt been used.
The NMPC response n<.luly 11 also advised that the estimated production levels were achieved each Cay, with the exception rf the second shift nn Hay 2/3, which produced considerahly less; and resulted in the removal of two con-
.struction supervisors.
It further stated that'interviews with the twn invnlved individuals corfirmed that low productivity was the cause of this action.
OI interviews with craft personnel;. including craft foremen, disclnsed that a
number of individuals felt that.there was more pressure than usual associated with th>
NMS job.
They cited the:fact that supervisors from Stone and Webster Engineering Cnrpnratinn (SPEC) and L. K. Comstnck (LKC) were around mnre than usual and seemed to exhibit more irterest than normal in the effort.
Case No.
1-85-0?0
In addition, tho cnntention that the lack nf p<cduction afte" the first night's work resulted ir, th~ dismissal of two supervisors on the second shift is nnt supported by evidence that their production level was significantly less than the other shift or> the first day.
Testimony from ind'.viduals or: the first shiit indicateC that they installed approximately the same number as the second shift'that day, and that there were the norI".al startup difficultirs and problems associated with beqinning any new iob effort.
The two individuals who were rennv~d acknowledged that it. was their understanding that thpy were removed because nf alleged non-productivity; hnwever, neither aqr>>ed that it was a,iustified or va".d contention.
Neither cnnstruction nor electrical contractor supervision could pro'duce an~,
documents quantifying the effort on the first night and comparing it with the work by all other shifts.
Interviews with craft personnel leave nn dnubt that the sudden removal of two night shift supervisors after the first night' activities made an impression or. the persnnnel, Most of thr OC inspectors and craft personnel, as well as craft supervisors, opired that the sudden remrval of the two niaht shift supervisors was a drastic action, uniustified and unprecedented at NthP-2.
OI's investigat',ve findings indicate that the licensee's July 11, 1985, letter
+r> the NRC cnntained false> and inaccurate information regardinq tho cr rdiitinns end atmosphere surroundina the NY>S cable installatinr> effort.
Thor'- is evidence that individuals intr rviewed by 01P prnvided irformation,roaardino problems er.cnuntered during installatinn (i.e., cable breaks/separations) and pressure associated with the effort, information that should have raised questions concernino the lic~nsee's findings.
OI believes that the suhmissinn of this erroneous irformation constitutes at a minimum a careless disregard of tI>~ truth and accuracv of the t infnrmation on the part. of the licensee.
01's investigation also disclosed that procedural vi>nlatior>s occurred dvr-'rg cable installatinr., including a failure tn adhere to OA guiidelines.
The evidence again indicates that these violations resulted at a minimum from careless disregard of procedures'nd guidelines on the par+ of the cognizant parties.
Although many craft personnel spoke of pressure tn complete the installation effort, there is insufficient evidence to conclude that there was improper pressure by supervision.
Additionally, OI interviews with cognizant contractn>r construction and electrical management per nnnel did not disclnse evidence of management pressure from within the, licensee's oraanizatinn.
01P's failure to int~rview craft personnel.involved in the instal ptinn
- effort, hard to separate some of the individuals from their supervisors and peers during the interviews, as w6,1 as interQcting personal npininns into the interview process, are vieweo as cnntributing to their failur~ tn develop accurate information.
In addition, many of the interviewees appear tn ba the same individuals who would have had a vested interest in prnt6cting themselves
.against the allegations contained in the anonymous letter of. Hay 20, 1985.
Case No.
1-85-020
ATTACHMENT 2 NHP-2 ENFORCEHENT CONFERENCE March 18, 1988
- 1:00 p.m.
EA 87-104 Summarv:
In June 1985 Region I formally requested that Niagara Mohawk evaluate alleged problems concerning the installation of neutron monitoring (NH) cables at Nine Mile Point 2
(NMP-2).
The resulting Niagara Hohawk review was transmitted to Region I containing false and inaccurate information regarding the cable installation.
Technical Significance:
The safety significance of the cable installation problems is negligible.
The installed cables were acceptable for use as is based on satisfactory continuity and insulation resistance
- tests, and subsequent preoperational tests and routine operations have demonstrated acceptable performance.
Chronology:
5/20/85
- Anonymous letter alleges that neutron monitoring cables had been installed improperly, in violation of procedures, and without proper quality control (gC) involvement.
6/7/85 7/11/85 9/85 12/4/85 1/11/88 Region I requests that Niagara Mohawk review the problem.
Niagara Mohawk transmits
- review, which states that neutron monitoring cable installation was satisfactory, in accordance. with procedures, and with acceptable gC coverage.
Anonymous worker alleges to N.Y. Public Service Co'mmission that review was inadequate and findings were incorrect.
Specialist inspector identifies Level V procedure violation but determines the cable installation to be technically acceptable.
OI concludes that the July 1985 Niagara Mohawk response contained false and inaccurate information and constituted careless disregard on their part.
Region I transmits OI Synopsis to Niagara Mohawk and requests Enforcement Conference.
- False, Inaccurate Information and Errors in Niagara Mohawk Review:
Niagara Mohawk stated that "All personnel confirmed the pushing technique of cable installation."
OI found that cables were installed by a combination push/pull technique, that no tension monitoring was used as required for
- pulling, and that there was no written documentation of the review and approval of the push technique.
2.
Niagara Mohawk stated that "No one had knowledge of overtensioning or breaking cables."
OI found that "in several instances either conductor broke during installation or, at separated or disconnected from the plastic was used to guide the cable....
- Further, of breaking or disconnection) were alleged been related to glP personnel during their effort."
an NMS cable the very least, polywater hose that they (the instances by some to have investigative 3,
Niagara Mohawk stated that "SWEC guality Control by Interoffice Correspondence to SWEC Engineering stated that cables installed into the undervessel flex conduits were
~
~
~
~
~
ushed..."
and that "the guality Control Program was adhered o
Gy qualified personnel...."
OI found that cable "pushin was being app
'ere visually They admitted tension was a
periodically on the amount "there is no gC inspection program/criteria for at NHP-2.
When questioned as to what criteria ied during inspection, gC personnel advised they observing the physical integrity of the cable.
that they were limited to judging how much pli.ed, and one gC inspector indicated that e
had to caution the craft personnel to back off of pull tension being applied."
The Niagara Mohawk review listed the five job categories into which the 20 interviewed people belonged.
Craft personnel were absent from the, list, but it did list "3 Craft Supervision".
The OI Report noted that "glP's failure to interview craft personnel involved in the installation effort, and to separate some of the individuals from their supervisors and peers during the interviews, as well as interjecting personal opinions into the interview process, are viewed as contributing to their failure to develop accurate information."
Inspection Summaries and Corrective Actions on NH Cables and glP:
December 1985
- Technical Review of Cable Installation;
$SpeciaT7sX inspector for 5 days TR 85-42)
The inspector reviewed the NH cable installation and observed a
mockup cable installation.
The IR issued a violation for failing to follow procedures (lack of pull tension monitoring and excessive bend radii).
The inspector concluded that NH cables had been pulled (based on 2-3 breaks reported in cable attachment loops) and that there was no installation procedure for push installations.
Based on the demonstration the inspector concluded that using the lubrication guide tube, it was not possible to install NH cable without pulling but that the pull force was acceptable.
He found that the NH cable could be installed by pushing alone when there was no lube tube.
January 1986
- Review of glP (5 Han Team for 5 days IR 86-04)
The team reviewed glP, its operation, its review of specific
- concerns, and its, perception by workers.
The team found numerous positive aspects and numerous weaknesses, including review of potential wrongdoing, qualification of investigators, and documentation.
The team concluded that the program was perceived positively by workers.
- Overall, the team concluded that all 76 cases reviewed by the team had been ultimately dispositioned adequately..
June 1986
- Followup Review of glP; (SRT an5 Sec77on Chief for 2 days IR 86-29)
The review focused on the progress toward correcting the previously noted weaknesses.
The review noted Niagara Hohawk's responsiveness in making improvem'ents in glP based on the team's assessment.
Particular improvement was noted in the process for handling of potential wrongdoing issues.
September 1986
- Review of gA Proqram Concerns Under glP Review;
$ 4 Han Team for 5 Vays : TR 86:SZT Region I had become aware of programmatic quality control (gC) concerns raised by gC inspectors to glP.
Because of the impending licensing of Unit 2, the team reviewed the adequacy of the guality Assurance Program in parallel with the glP review.
The team concluded that there were n'o hardware deficiencies and that gA overchecks of gC inspection activities had identified and corrected hardware deficiencies.
ATTACHMENT 3 MARCH 18, 1988 ENFORCEMENT CONFERENCE NRC OI REPORT 1-85-020 (Q1P INVESTIGATION OF NMS CABLE INSTALLATION)
~ INTRODUCTION
~
SUMMARY
REPORT TO NRC
~.BASIS FOR QlP INVESTIGATION
~
NMPC COMMITMENT LETTER TO NRC
~
CHRONOLOGY OF EVENTS
~
NM RESPONSE TO NRC -LETTER 1/11/88 I.
Q1P INVESTIGATOR'S EXPERTISE II. INVESTIGATIVE TECHNIQUES III. ANALYSIS 5 PRESENTATION OF FACTS IV. REVIEW ADEQUACY V. 7/11/85 REPORT - ADEQUATE
SUMMARY
OF INVESTIGATION VI. CONCLUSIONS
NMPC LETTER TO RC DATED JULY 11 1985
SUBJECT:
ANONYMOUS EMPLOYEE CONCERN - INADEQUATE CONTROL OF CABLE PULLING AND QC OVER THIS ACTIVITY.
SCOPE:
PROVIDES
SUMMARY
REPORT OF RESULTS OF INVESTIGATION BY NM Q1P IN DIRECT RESPONSE TO NRC LETTER OF JUNE 7, 1985 AND NM COMMITMENTS IN LETTER TO NRC OF JUNE 21, 1985.
CONCLUSIO CABLE PULL INSTALLATION WAS TECHNICALLY SATISFACTORY, QC PROGRAM WAS ADHERED TO AND NO EVIDENCE OF IMPROPER PRESSURE BY SUPERVISION WAS FOUND.
BASIS FOR INFORMATION REPORTED:
BAGKUP MATERIAL CONTAINED IN
'1P FILES ON INVESTIGATION.
THIS
t t
BASIS FOR 1P I VESTIGATIO NRC REQUEST NRC LETTER OF JUNE 7, 1985 AND ATTACHED UNSIGNED ALLEGATION LETTER TO NRC DATED 5/20/85.
ALLEGATIO S
~
5/3 8t 4 TWO CABLES WERE BROKEN DUE TO EXCESSIVE PULLING TENSXON WHILE INSTALLING NMS CABLES.
~
ACTXON OBSERVED BY SWEC UNSATISFACTORY INSPECTXON
~
CABLES REATTACHED TO
, INSTALLATXON COMPLETED.
OVERTENS IONEDt BUT NOT TO QC INSPECTORS, WITH NO REPORTS.
PULLING EQUXPMENT AND SEVERAL OTHER CABLES POINT OF BREAKXNG.
~
IMPROPER PRESSURE BY SWEC CONSTRUCTION USED TO PUSH THROUGH IMPROPER INSTALLATION.
SWEC CAUSED PERSONNEL TO BE RELIEVED OF DUTIES OR REMOVED
'FROM THEXR JOB.
AFFECTED MEN WERE UNJUSTLY DEALT WITH BY SWEC.
NRC REQUEST OF NM 0
REQUEST INVESTIGATE MATTER AND PROVIDE TO NRC PLANS AND SCHEDULE WXTHIN ONE WEEK OF RECEXPT OF LETTER.
~
INVESTIGATION SHOULD DETERMINE:
1)
TECHNXCAL ADEQUACY OF INSTALLED CABLE 2)
ADEQUACY OF QC COVERAGE OF THE ACTIVITY 3)
MEASURES TAKEN TO ENSURE, THAT NO IMPROPER PRESSURE TO COMPLETE WORK XS PERMITTED.
0 NM COMMITME T LETTER T R
F JUNE 21 1985 PURPOSE -
RESPOND TO NRC SPECIFIC REQUEST OF JUNE 7, 1985 FOR PLANS AND SCHEDULE FOR XNVESTIGATION.
STATED PLANS & SCHEDULE
~
INVESTIGATION ONGOXNG - INVOLVES REVIEWING RECORDS RELATED TO NMS CABLE INSTALLATIONt I ~ E ~
INSPECTION REPORTS
- INSPECTXON PLANS ENGINEERING SPECS.
& E & DCR'S N & D's INSTALLATION DOCUMENTATION
~
INVESTIGATION TO INCLUDE INTERVXEWS WITH APPROPRIATE PERSONNEL FROM THE FOLLOWXNG GROUPS:
QUALITY CONTROL ENGINEERING CONSTRUCTION 0
INVESTIGATXON WILL DETERMINE:
TECHNICAL ADEQUACY Of INSTALLED CABLE
" ADEQUACY OF QC COVERAGE OF INSTALLATXON
-,MEASURES TAKEN TO ENSURE THAT NO IMPROPER PRESSURE TO COMPLETE WORK WAS PERMITTED.
~
RESULTS OF COMPLETED INVESTXGATION WILL BE REPORTED To NRC BY JULY 15, 1985.
0 0
HR L
Y F EVE T 2.
3.
5.
6.
7.
8.
9
~EVE TS NM REC'D NRC LETTER DTD. 6/7/85.
MGT. MEETING WITH REGION - PXPE SUPPORT REASSESSMENT RESULTS.
Q1P INVESTIGATION CONDUCTED.
NM LTR.
TO NRC-OUTLINES PLAN & SCHED.
NM SENDS NRC XNVESTIGATION
SUMMARY
AND CONCLUSXON.
NRC RES.
INSP.
REVIEWS Q1P FILES.
CABLE INSTALL. TEST COMPLETED SATISF.
NM PERFORMED AUDXT OF Q1P.
NRC XNSPECTION OF CABLE INSTALLATION (IR 50-410/85-42)
(NM RESPONsE 3/3/86,
'LOSEOUT 86 7/11/86).
DATES 6/14/85 6/17/85 6/14-7/10/85 6/21/85 7/11/85 8/85 8/85 10/85
'1-12/85 10 A.
NRC OI XNVESTXGATOR INTERVIEWED PEOPLE AT NMP-2.
12/85'0 12.
13.
14.
B.
SYNOPSXS OF OI REPT.
RECEIVED BY NM.
NRC SP.
TM. ASSESSMENT OF Q1P (IR 86-04).
NM TOOK ACTION/
cLoseoUT (86-29, PG.
16 AND 17).
NRC SALP REPT.
SENT TO NM (PG.
20, CONSTR -
LXCENSEE INVEST.?).
NRC SP.
TM. INSP -
QC CONCERNS (IR 86-52)
(NM TOOK ACTION, CLOSEOUT 87-42, 12/10/87).
NRC SALP RE~oRT SENT To NM (PG.
32 ASSURANCE OF QUALITY/QIP).
1/88 1/86 5/86 9/86 8/87
NM RESPONSE TO RC LETTER 1/11/88 I.
THE INVESTIGATOR'XPERTISE
~ THE Q1P INVESTIGATOR WAS QUALIFIED TO CONDUCT THE INVESTIGATION BY HIS BROAD TECHNICAL BACKGROUND AND NUCLEAR EXPERIENCE.
~ QlP INVESTIGATORS RECEIVED FIVE DAYS OF.
TRAINING BY OUTSIDE EXPERT
,IN INTERVIEWING AND INVESTIGATIONS TECHNIQUES.
o THE ISSUES WERE NOT COMPLEX ELECTRICAL MATTERS.
~ Q1P INVESTIGATOR TOOK STEPS TO DEVELOP THE NECESSARY KNOWLEDGE.
~ CONSULTED WITH QA INDIVIDUALS KNOWLEDGEABLE IN THE AREA.
~ QlP INVESTIGATOR WAS ACCOMPANIED TO THE FIRST INTERVIEW BY KNOWLEDGEABLE INDIVIDUAL FROM NM PROJECTS QA.
~
NO INDICATION THAT ANY "LACK OF ELECTRICAL EXPERTISE" AFFECTED THE CONDUCT OF THE INVESTIGATION.
'ONCLUSIO THE Q1P INVESTIGATOR HAD SUFFICIENT EXPERTISE AVAILABLE TO ADEQUATELY REVIEW THE MATTER.
NM RESPONSE TO NRC LETTER 1/11/88 II.
INVESTIGATIVE TECHNIQUE
~ DIFFERENT AND MORE INFORMAL TECHNIQUES THAN OI - Q1P FOCUSES ON TECHNICAL ISSUES.
~ INVESTIGATION WAS DESIGNED TO BE ADEQUATE FO INTENDED PURPOSES.
FOR ITS
~
GROUP INTERVIEWS WERE REASONABLE
- RECONCILE ANY INCONSISTENT RECOLLECTIONS
- DEVELOP MOST REASONABLE EXPLANATION MORE EFFICIENT RULED OUT WHERE VERACITY OR INTIMIDATIONIS CONSIDERED TO BE AN ISSUE
~ CRITERIA FOR DETERMINING WHO TO INTERVIEW INVOLVED INDIVIDUALS HAVING BOTH TECHNICAL AND FIRST-HAND KNOWLEDGE OF EVENTS.
~ NINE OUT OF 20 WITNESSES (INCLUDING TWO REPLACED SUPERVISORS)
WERE INTERVIEWED INDIVIDUALLY.
CONCLUSION:
ADEQUATE INVESTIGATIVE TECHNIQUES WERE UTILIZED TO ACHIEVE THE PURPOSES OF THE INVESTIGATION.
NM RESPONSE TO RC LETTER 1/11/88 III. THE ANALYSIS AND PRESENTATIO OF FACTS
~ GOAL WAS TO INVESTIGATE TECHNICAL ADEQUACY OF
. INSTALLATION, QUALITY CONTROL COVERAGE AND IMPROPER PRESSURE.
~ INVESTIGATION WAS LIMITED - DID NOT PERFORM. AUDIT OF PROGRAMMATIC MATTERS 'RELATED TO INSTALLATION.
~
FACTS DEVELOPED SUPPORTED CONCLUSIONS REACHED.
CONCLUSION:
1.
THE ANALYSIS AND PRESENTATION OF FACTS WERE ADEQUATE.
2.
WHEN REVIEWED IN CONTEXT OF A SPECIFIC
RESPONSE
TO A SPECIFIC INQUIRY, THE-REPORT WAS NOT MISLEADING OR INCOMPLETE.
~
. ~
NM RESPO SE TO RC LETTER 1/11/88 IV.
REVIEW ADEQUACY
~ MANAGER OF QlP WAS ACTIVELY INVOLVED IN PHASES OF INVESTIGATION.
COMMUNICATED ASSIGNMENT TO INVESTIGATOR CONDUCTED PERIODIC REVIEWS REVIEWED FACTS DEVELOPED BY INVESTIGATOR
~ DIRECTOR OF OA HAD SUFFICIENT BASIS TO ACCEPT REPORT.
- REVIEWED REPORT
- DISCUSSED WITH INVESTIGATOR
- PERIODIC MONITORING OF INVESTIGATION
- DISCUSSIONS-AND INFORMATION OBTAINED FROM OTHER TECHNICAL PERSONNEL INCLUDING NM OA AND SWEC OA.
~ NUCLEAR COMPLIANCE AND VERIFICATION ASSISTED EFFORT.
REVIEWED EARLIER DRAFT OF REPORT REVIEW INDICATED ACCURACY OF FACTUAL STATEMENTS
~ LEGAL REVIEW OF LETTER AND
SUMMARY
REPORT FOR:
- CLARITY NO MISINTERPRETATION
- RESPONSIVENESS TO ORIGINAL NRC REQUEST CONCLUSIO PRIOR TO THE REPORT'S SUBMITTAL, AN ADEQUATE MANAGEMENT REVIEW WAS CONDUCTED.
~
~
NM RESP SE T R
LETTER 1/11/88 V.
THE JULY 11, 1985 REPORT WAS AN ADEQUATE
SUMMARY
OF THE INVESTIGATIO ALLEGATION:
PUSHING OF CABLE DURING INSTALLATION WAS DONE WITHOUT PROCEDURE.
~
NMPC ADMITTED TO VIOLATION OF NOT CHANGING THE ELECTRICAL SPEC.
~ ENGINEERING, QC AND CONTRACTOR REPRESENTATIVES PARTICIPATED IN FIELD
.DISCUSSIONS AND INITIAL FIELD TRIAL METHODS FOLLOWING MOCK PULL.
~ PUSHING METHOD NOT WELL DEFINED (PRIMARILY PUSH VS.
PRIMARILY PULL TO INSTALL CABLE).
~ WORK CREWS BRIEFED ON METHOD.
~ MAY 10, 1985 MEMO DOCUMENTING ACCEPTABILITY OF METHOD USED TO INSTALL CABLE.
~ LACK OF PROCEDURE NOT RELATED TO BREAKAGE OR OVERTENSIONING.
ALLEGATXO :
TENSION MONITORING DEVICE NOT UTILIZED.
o MENTIONED IN REPORT TO NRC OF 7/ll/85 AND ALSO PART OF SUPPLEMENT TO N&D 11960.
~
NO FIRST HAND KNOWLEDGE OF OVERTENSIONING OR BREAKING CABLES DURING ACTUAL CABLE INSTALLATIONS.
~ PROBLEMS DURING "MOCK PULL" NOTED.
~ ACKNOWLEDGED TOWLINE AS GUIDE.
M RESPONSE T
NRC LETTER 1/ll/88 V.
CONTINUED...
ALLEGATIO:
QC PERSONNEL DID NOT HAVE SPECIFIC INSPECTION CRITERIA AND PROCEDURES AVAILABLE.
~
QC PERSONNEL PERFORMED TO THE NORMAL SWEC OA.
INSPECTION PLAN.
~ TYPICAL ATTRIBUTES INSPECTED ON CABLE INSTALLA-.
TION INCLUDED CLEANLINESS, TICKET ISSUANCE, CABLE
- TYPE, CONDITION AND INTEGRITY OF CABLE,
- ROUTING, ETC.
~
NO EVIDENCE OF OVERTENSION OR BREAKAGE BASED ON INTERVIEWS.
t Q1P INVESTIGATION RELIED ON RESULTS OF CONTINUITY AND INSULATION RESISTANCE TESTING ON INSTALLED CABLE TO BE PERFORMED FOR FINAL ASSURANCE OF ADEQUACY.
TESTS WERE WITNESSED BY NM QA AND RESULTS OF TESTS WERE'ATISFACTORY.
NM RESPO SE TO RC LETTER 1/11/88 VI.
CONCLU IONS 1.
UNDERLYING CAUSE
~
MISUNDERSTANDING AS TO NRC EXPECTATIONS.
~
NOT EQUIVALENT TO OI INVESTIGATION.
o NOT 1NTENDED TO BE EXHAUSTIVE.
2.
CORRECTIVE ACTION NO OPEN TECHNICAL MATTERS.
e INVESTIGATION WAS ADEQUATE.
~
REPORT NOT MISLEADING OR INCOMPLETE IN CONTEXT OF SPECIFIC INQUIRY..
~
Q1P WEAKNESSES IDENTIFIED FROM NM AUDIT NRC SPECIAL TEAM ASSESSMENTS HAVE BEEN CORRECTED AND CLOSED OUT.
THESE INCLUDE:
IMPROVED FILES AND RECORDS.
EXPANDED REPORTING REQUIREMENTS.
IMPROVED COMMUNICATIONS & CLOSER COOPERATION BETWEEN 01P
& OTHER HM INVESTIGATION GROUPS.
BETTER COMMUNICATION AND FEEDBACK OF RESULTS TO CONCERNEE.
IMPROVED PROCESS FOR HANDLING POTENTIAL WRONGDOING CONCERNS.
PRIORITIZATIOH, CLASSIFICATION, STATUSING AND CLOSE OUT MORE STRUCTURED.
GREATER INDEPENDENT MANAGEMENT INVOLVEMENT AND REVIEW.
NM RESPO SE TO RC LETTER 1/11/88 VI.
CONTINUED...
~
REGARDING FUTURE NRC REQUESTS, NM INTENDS TO STRENGTHEN THE FOLLOWING:
DISCUSSIONS WITH NRC ON SCOPE AND CONDUCT OF INVESTIGATION, KIND AND TYPE OF REPORT TO NRC AND BACKUP DOCUMENTATION.
DISCUSS RESULTS WITH NRC AND ANSWER ANY QUESTIONS TO MINIMIZE ANY MISUNDERSTAND-INGS BETWEEN NM & NRC.
3.
IS CURRENT 01P PR RAM ADE UATE?
- YES, BASED ON ALL CHANGES AND ENHANCEMENTS IN PRACTICES AND PROCEDURES TO STRENGTHEN 01P PROGRAM ALREADY TAKEN AND CONFIRMED BY NRC.
~
PROVIDES ACCEPTABLE OUTLET TO RAISE SAFETY CONCERNS.
~
ALLOWS CONCERNS TO BE PROMPTLY AND EFFECTIVELY ADDRESSED.
~
NRC RESIDENT IS ROUTINELY INFORMED OF NEW CONCERNS AND STATUS OF Q1P ACTIVITIES.
I
REQUL Y INFORMATION DISTRIBUTI SYSTEM (RIDS>
ACCESSION NBR: 8801200224 DOC. DATE: 88/01/11 NOTARIZED:
NO DOCKET 0 FACIL: 50-410 Nine Mile Point Nuclear Stationi Unit 2i Niagara Moha 05000410 AUTH. NAME AUTHOR AFFILIATION KANE. W. F.
Region 1>
Ofc of the Director REC IP. NAME RECIPIENT AFFILIATION DONLONi W.
Niagara Mohawk Poeer Corp.
SUBJECT:
Discusses Investigation Rept 1-85-020 re adequacy of quality first program investigation of circumstances associated e/
installation of certain neutron monitoring sos cables at facility in May 1985.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED: LTR ENCL SIZE:
TITLE: Qeneral (50 Dkt)-lnsp Rept/Notice of Violation Response NOTES: 21 05000410 RECIPIENT ID CODE/NAME PDi-1 PD BENEDICT' INTERNAL:
ACRS DEDRO NRR/DLPG/PEB NRR/DREP/EPB NRR/DRIS DIR OE LIEBERMAN,J RQN1 FILE 01 COPIES LTTR ENCL 1
1 2
2 2
2 1
1 1
1 1
1 1
1 1
1 1
1 REC IP IENT ID CODE/NAME HAUQHEYi M AEOD NRR MORISSEAUi D NRR/DOEA DIR NRR/DREP/RPB NRR/PMAS/ ILRB OQC/HDS1 RES/DRPS DIR COPIES LTTR ENCL 2
2 1
1 1
1 1
2 2
1 1
1 1
1 1
EXTERNAL:
LPDR NSIC NRC PDR TOTAL NUMBER OF COPIES REQUIRED:
LTTR 25 ENCL 25
Docket No. 50-410 License No.
'N$. JAIL l989 Niagara Mohawk Power Corporation ATTN:
William Donlon President 301 Plainfield Road
- Syracuse, New York 13212 Gentlemen:
Subject:
NRC Office of Investigations (OI) Report No. 1-85-020 This refers to the investigation conducted by the NRC Office of Investigations (OI) concerning (1) the adequacy of your Quality First Program (Q1P) investi-gation of the circumstances associated with the installation of certain neutron monitoring system (NMS) cables at Nine Mile Point, Unit 2, in May, 1985, and (2) the accuracy of the facts concerning the installation effort as reported in a letter to the NRC dated July 11, 1985.
The Q1P investigation had been conducted after the NRC had informed your Executive Director for Nuclear Operations, in a letter dated June 7,
1985, that this office had received an allegation that there was improper installation of the NMS cables due to excessive pulling tension, inadequate quality control (QC) coverage of this activity, and improper pressure by contractor employees to complete installa-tion.
The OI Report of Investigation Synopsis is enclosed.
Although sufficient evidence was not developed during the OI investigation to demonstrate that improper pressure had been exerted on contractor employees to complete the installation of the cables, the information developed during the OI investigation demonstrates, at a minimum, that the July ll, 1985 letter to the NRC was incomplete and misleading.
That letter, which was signed by the Director of Quality Assurance and reviewed by your Nuclear Compliance and Verification Group, stated that the installation of the cables was technically satisfactory, and the QC Program was adhered to; however, the letter did not indicate that (1) pushing of the cable during the installation was done without a procedure, (2) pulling of the cable during the installation was done without using a tension monitoring device, as required, and (3) Quality Control per-
- sonnel, although physically monitoring the installation effort as required by the QC program, did not have specific inspection criteria and inspection procedures available to determine the acceptability of the cable installation.
Although the procedural violations associated with the installation effort were previously identified during an NRC inspection conducted in November and
- December, 1985,
(
Reference:
NRC Inspection Report No. 85-42) and were cited in a Notice of Violation sent to you on January 22,
- 1986, the NRC is also concerned that the July 11, 1985 response to Region I was incomplete and misleading, and the Q1P investigation which formed the basis for that response was not adequately
- planned, conducted or evaluated.
In particular, (1) the individual responsible for conducting the investigation, although investigating an electrical cable installation activity, was lacking in electrical experience; g)'he investigator used poor investigative techniques, such as interviewing 880i200220 880iii AFiTCIAL RECORD COPY CP NMP2 LTR 0001.0.0 01/07/88 ADOCK 0> 004 0 ol
Niagara Mohawk Power Corporation i.1 JAIL BM personnel in the presence of their supervisors and not interviewing craft personnel; (3) neither the investigator, nor the Q1P manager responsible for overseeing the investigator, adequately analyzed and presented the facts obtained during the Q1P investigation; and (4) the Director of QA, as well as the others who reviewed the letter, apparently did not recognize these deficiencies.
These deficiencies raise questions regarding the adequacy of your Quality First Program in resolving employee
- concerns, and the adequacy of your communications with the NRC.
Furthermore, the NRC SALP Report sent to you on May 14, 1986 also raised concerns regarding the level of Q1P documentation to substantiate closure of employee concerns.
In addition, the NRC SALP Report sent to you on August 12, 1987 describes concerns regarding corporate management involvement and internal communications while handling QA concerns brought to the attention of QlP personnel.
In view of these findings, we plan to schedule an enforcement conference to be conducted in the Regional office within the next 30 days.
During the conference you should be prepared to discuss (1) the underlying causes of these Q1P and communication deficiencies, (2) the corrective actions taken or planned to correct these deficiencies and prevent recurrence, and (3) the reasons the NRC should believe that your Q1P program now provides an acceptable outlet for allowing employees to raise safety concerns, and for having these concerns promptly and effectively resolved.
When you have reviewed the enclosed Report Synopsis and are prepared to discuss its findings please contact us to arrange the date and time for the conference.
Your cooperation with us in this matter is appreciated.
Sincerely, grig'jZay Signeh B7-'illiam F.
Kane, Director Division of Reactor Projects
Enclosure:
As Stated OFFICIAL RECORD COPY CP NMP2 LTR - 0002.0.0 01/07/88
iiJAN 898 CC:
Connor
& Wetterhahn John W. Keib, Esquire J.
A. Perry, Vice President, Quality Assurance Troy B. Conner, Jr.,
Esquire C.
V. Mangan, Senior Vice President Nuclear T.
E.
- Lempges, Vice President, Nuclear Generation T.
W.
Roman, Station Superintendent, Unit 1
J.
C. Aldrich, Superintendent of Operations, Unit 1
R.
G. Smith, Superintendent of Operations, Unit 2 A. Z. Pinter, NMPC, Site Licensing
- Director, Power Division W. Hansen, Manager Corporate Quality Assurance C.
- Beckham, Manager, Nuclear QA Operations T. J. Perkins, General Superintendent R.
B. Abbott, Station Superintendent Department of Public Service, State of New York Public Document Room (PDR)
Local Public Document Room ( LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New York OFFICIAL RECORD COPY CP NMP2 LTR - 0003.0.0 01/07/88
Niagara Mohawk Power Corporation
$ i JAN 1>y bcc:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
DRP Section Chief Region I SLO Robert J.
- Bores, DRSS SECY J. Taylor, DEDO J.
Lieberman, OE W. Russell, RI T. Murley, NRR D. Holody, RI J. Goldberg, OGC T. Martin, DEDRO Enforcement Directors RII-II Enforcement Officers RIV-RV F.
- Ingram, PA J.
Bradburne, CA E. Jordan, AEOD B. Hayes, OI C. White, OI:Rl S. Connelly, OIA 0.
Nussbaumer, SLITP OE Files (3 copies
+ ltr hd)
EDO Rdg File DCS M. Haughey, NRR PDI-1 B. Clayton, E00 Region I Coordinator E. Wenzinger, RI S. Collins, RI W. Kane, RI W. Johnston, RI W. Russell, RI RI EO "Holody 1/
/88 RI: DRP
- Johnson 1/
/88 RI:DRP "Wenzinger 1/
/88 OI RI
- CWhite 1/
/88 RI:RC
- Gutierrez 1/
/88 1/9 /88
- See previous concurrences
bcc:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
DRP Section Chief Region I SLO Rober t J.
- Bores, DRSS SECY J. Taylor, DEDO J.
Lieberman, OE W. Russell, RI T. Murley, NRR D. Holody, RI J. Goldberg, OGC T. Martin, DEDRO Enforcement Directors RII-II Enforcement Officers RIV-RV F.
- Ingram, PA J.
Bradburne, CA E. Jordan, AEOD B. Hayes, OI C. White, OI:Rl S.
Connel ly, OIA D. Nussbaumer, SLITP OE Files (3 copies
+ ltr hd)
M. Haughey, NRR Pg1-1 B. Clayton, EDO Region I Coordinator E. Wenzinger, RI S. Collins, RI W.
- Kane, RI W. Johnston, RI W Russell
- DR Jo ton 2/
/8 RI:DRP Kane 12/
/88 RI:EO RI R
Hol ody M$'~
Jo nson iq 8'>
12/
/87 RI Rsg is@
R G lerz
~/4 /8t 0
R C
4t //88 I:D 1
- D Co ns 2/ /
RI: RA s
1 12/ /8f OFFICIAL RECORD COPY CP NMP2 LTR 0004.0.0 05/29/87
ENCLOSURE SYNOPSIS
'he NRC received an anonymous letter, dated May 20, 1985, alleging improprieties in.the'nstallation of the Neutron Monitor ing System (NMS) cables at Nine Mile Paint,.Unit 2 (NMP-2).
Specifically, it alleged improper management pressure and the over-tensioning and breaking of. twn cables due to the application of excessive pull tension.
On June 7, 1985, the NRC referred this matter back to Niagara Mohawk Power Corporatinr (NMPC) for resolution of the concerns; whereupon NMPC's Director of guality Assurance (gA) referred the matter tn NMPC's guality First Program (01P).
C P reviewed relevant l}C Inspection Repnrts (IRs), cable pull tickets, and Nonconformance 5 Dispositions (NIEDs).
They alsn interviewed eight gC perscninel, three individuals from engineering, five cnnstruction supervisors, one pro,iect
- manager, and three craft supervisnrs.
Some of these were inter viewed in groups and, in several instances, in the presence of their superiors.
The glP irvestigator, advised that he received such d, tailed information from the individuals he interviewed that he felt it was unnecessary to ques+'.nn craft personnel, opining that to interview craft level personnel wnuld have been a
waste of +ime.
In a letter dated July 11,
- 1985, NMPC's gA Mar aaer reported glP's f'.ridinas to the NRC.
He reported that the installation of the cable wa., technically satisfactory, the OC program was adhered to by qualified personnel, and there was no evidence of improper pressure by supervision.
He added that there would be cnntinuity and -;nsulation ~esistance testing perfnmed on the installed cable during the month of July, with a gA technician assiened to rior itor the tests.
Prinr
+n submission of the July 11 letter, NMPC's Nuclear Compliance and Verification (HC8V) Group at NMP-2 reviewed a draft of QlP's findings.
Paring the OI investigation, NCSV personnel stated that they were directed tn assist l)lP by reviewing the draft but not requested to perform a formal review and verification effort.
Consequently, they advised that they did not dn any field work or research to develop supporting documentation for the s+atements cortained within the letter.
A system attorney for NMPC also reviewed the July ll= letter;
- however, he testified that he did not check the facts, assuming they were as stated.
In September
- 1985, ar: alleger approached a representative of the Nirw York State Public Service Commission
.(NYSPSC) raising questions about the adequacy of the (jlP investigation into the NMS cable concerns, the break:na and over-tensioninq of cables duringi installation, and pressure on consstruction workers to complete the installation,
.On October 3, 1985, the Regional Administrator requested that. OI determine the validity of the allegatinn that the glP; investigation did not accurately report the facts of the incident in the licensee's July 11 letter.
The.investigation included an examination of the adeauacy of the installatinn,and associated procedural rnmpliance, including adherence tn the gA program; as well as the question nf improper pressure by supervisinn and the overall adequacy of the licensee's investigaWve and review effort.
Case No.
1-85-020
The July ll, 1985, response advised that the concerns.about cable pulling appeared to refer to a "mock" pull. and."nn.nne" had any knnwledae nf over-tensioring or breaking the cable's.
It further described the technique of ir stallatinn as a "push" technique that'ad beer approved bv enaineerira and utilizing the tnw line as a guid~.'owever, OI interviews of OC inspec+nrs, craft personnel and'supervisors, some of whom had been previously interviewed by 01P, disclosed that a combination push/pull methnd was emploved to effect cable installation.
These individuals 'alsn disrlosed that, even thnueh pull tension was employed during installation, there was nn tension monitoring, as
~@quired by the criteria set forth in the cable pul'ling procedure.
- Also, there was nn written documentation reflecting review and apprnval of the "push" technique, which most acknowledged was a new method and net the norm for cable installation at NMP-2.
OI interviews revealed mixed recollectinns regarding a "mock" pull prior tn installation.
However, interviews with craft and gC personnel disclosed that in several instances either an NMS cable conductor broke during installation or, at the very least, separated or disconrected from the plastic pnlywater hose that was used to guide the cable and pump lubricating. fluid into the cnnduits.
These instances of eithe~
a hreak or disconnectinn/separation were during installation and not lim'.ted tn problems encountered during a "mock" or test pull operation.
Further, they were alleged by some tn have been related tn 01P personnel durina their investigative effort.
Craft personnel also indicated that the amount of pull tension applied during installation varied anywhere from the use of one or twn fingers as a guide on the plastic polywater
- hose, to pullina with one hand and nne are.
and including the exertion of possibly 80 pounds of pu'.1 pressure on 'some of the more difficult and lengthy
. uns.
The majority of the NMS cables (i.e., Mark,Nn. NJP-29) had a pull tension limit of 35 pnurds.
Additionally, there is nn OC inspection prroram/criteria for cable "pushing" at NMP-2.
When questioned as tn what criteria was being applied during inspection, OC personnel advised they were visually observing the physical integrity of the cable.
They admitted that they were limited tn.iudaing how much tension was applied, and nne OC inspector indicated that periodicallv he had tn,caution the craft personnel to back nff on the amnunt of pull tension beina applied.
OC personnel acknowledged that, although they did nnt think any cables were damaged during irstallatinn, it was impossible tn say whether any cahles were over-tensioned, because tension monitorina devices had nnt been used.
The NMPC response nf iluly 11 also advised that the estimated production levels were achieved each day, with the exception rf the second shift nn Ay 2/3, wh'.ch produced considerahly less;: and resulted in the removal of two con-struction supervisors.
It further'tated that.interviews with the twn invnlv'ed individuals corfirmed that low productivity was the cause of this action.
OI interviews with craft personnel,'ncluding craft foremen, disclosed that a
number of individuals felt that, there wa's more presstire than usual associated with the NMS job.
They cited the':fact that supervisors from Stone and Webster.
Engineering Corporation (SWEC) a'nd L. g. Comstock (LKC) were around more than usual and seemed to exhibit mnre interest than normal. in the effort.
Case No.
1-85-020
t t
In addition, the contention'hat the lack of production after the first niqht's work resulted in,the dismissal of two supervisors on the second shift is not supported by evidence that their pr'oduction level v.as significantly less than the other shift on the first day.
Testimony from individuals or. the first shift indicated that they installed approximately the same number as the
.second shift that day, and that there were the normal startup difficulties and problems associated with beginning any new job effort.
The two individuals who were removed acknowledged that it was their understandira that they were removed because of alleged non-productivity; however, neither agreed
+hat it was a,iustified or val'.d contention.
Neither cnnstruction nor electrical contractor supervision could produce any documents quantifying the effort'n the first night and comparing it with the
,work by all other shifts.
Interviews with craft personnel leave no doubt that the sudden removal of two night shift supervisors after the first night' activities made an impression or. the personnel.
Most of +he OC inspectors and craft personnel, as well as craft. supervisors, opir.ed that the sudden removal of the two night shift supervisors was a drastic action, unjustified and unprecedented at NMP-2.
OI's investigat',ve findinqs indicate that the licensee's July 11, 1985, letter
+o the NRC contained false and inaccurate information regardinq the cnnditions end atmosphere surrounding the NMS cable installatinn effort.
There is evidence that individuals interviewed bv 01P provided ir.formation reqardino problems er.countered during installation (i.e., cable breaks/separations) and pressure associated with the effort, information that should have raised questions concerning the licensee s findinqs.
OI believes that the submission of this erroneous ir.formation constitutes at a minimum a careless disregard of the truth and accuracy of +hat. information on the part nf the licensee.
OI's investigation also disclosed that procedural violations occurred during cable installatior., including a failure to adhere to OA guidelines.
The evidence again indicates that these violations resulted at a minimum from careless disregard of procedures and guidelines on the par+ of the cognizant parties.
Although many craft personnel spoke of pressure to complete the installation effort, there is insufficient evidence to conclude that there was improper pressure by supervision.
Additionally, OI interviews with cognizant contractnr construction and electrical management persnnnel did not disclose evidence of management pressure from within the. licensee s organization.
01P's failure to 'interview craft personnel involved in the instd>',ation effort, and to separate some of the individuals from their supervisors and peers during the interviejts, as we 1
as interiecting personal npininr.s'nto the interview process, arf. vieweo.as contributing to their failure to develop accurate information..
In'; addition, many. of the interviewees appear to be the same individuals who would have had a vested interest in protecting themselves
.against the allegations contained in the anonymous letter of. May 20, 1985.
Case No.
1-85-020