ML19343D343
| ML19343D343 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/27/1981 |
| From: | Deverley R HOUSTON LIGHTING & POWER CO. |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8105040322 | |
| Download: ML19343D343 (11) | |
Text
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- 30709
-g CG UNITED STATES OF AMERICA i
i i NUCLEAR REGULATORY COMMISSION P
i ll Il
- l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I
In the Matter of:
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HOUSTON LIGHTING & POWER 5
Docket Nos. 50-4980L 3
5 50-4990L-5 (South Texas Project, 5
[l Units 1 & 2) 5
)
5 I
i TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET AL.
f, OF 8
RICHARD W. PEVERLEY
'i ON I,
I !
THE ROLE OF QC INSPECTORS IN VERIFYING DESIGN l !
CHANGES (CONTENTION 1(7)(a)) AND QUALIFICATION OF PERSONNEL APPROVING DESIGN CHANGES j
(CONTENTIONS 1(7)(b) AND 1(7)(c))
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UNITED STATES OF AMERICA I
NUCLEAR REGULATORY COMMISSION l
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I
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In the Matter of:
i HOUSTON LIGHTING & POWER 5
Docket Nos. 50-4980L COMPANY, ET AL.
5 50-4990L (South Texas Project, Units 1 & 2) 5
'l TESTIMONY OF RICHARD W. PEVERLEY ON THE ROLE OF QC INSPECTORS IN VERIFYING DESIGN CHANGES (CONTENTION 1(7)(a)) AND QUALIFICATION OF PERSONNEL APPROVING DESIGN CHANGES (CONTENTIONS 1(7)(b) and 1(7)(c))
l Q. 1.
Please state,icur name.
i A.
1.
Richard W. Peverley.
i f
Q.
2.
By whom are you empi ycd?
f j
A.
2.
Brown & Root, Inc. (B&R).
Q. 3.
Please describe your current position and respon-1 l
sibilities.
l
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A. 3.
My present title at B&R is Assistant Engineering i
Froject Manager-Special Services.
I am responsible for I
l Design Quality Engineering, Document Control, Training, and l
I Engineering Material Control.
I currently have approximately 1
i 100 people in my organization, including 60 clerical personnel, l
20 management support personnel, and 20 engineers.
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4.
Please summarize your professional qualifications.
I i
A. 4.
I obtained a Bachelor of Science Degree in Civil l
l Engineering from Colorado State University in 1954.
I spent l
three years in the U.
S. Air Force as a jet pilot and was I
discharged with the rank of First Lieutenant.
I have approxi-mately twenty years of engineering experience in environmental testing, reliability,. quality engineering, and project I
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management.
I am a Registered Professional Engineer in the l
State of Texas and California, and I am a member of the American Society for Quality Control and the American Concrete Institute.
l l
Q.
5.
Please summarize the various positions you have held on the South Texas Project (STP).
A.
5.
I began working on the STP approximately 5 1/2 years ago as a Project Quality Engineer in the B&R Houston i
Office.
Two years later, I was promoted to the position of l
Senior Project Engineer - Quality.
One year after that, I was promoted to my present position.
l Q. 6.
What is the purpose of your testimony?
A.
6.
The purpose of my testimony is to address conten-j tion 1.7(a), to the extent it alleges that Quality Control i
(QC) Inspectors have a role in the verification of design l
changes, and contentions 1(7)(b) and (c).
My testimony will l
l show that the Contentions are without basis, and will explain i
.i
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i that the Engineering Department, not QC Inspectors, is t
responsible for verifying that design changes are executed I
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in accordance with the purposes of the original design, and that design changes at STP were properly approved by qualified personnel.
Q. 7.
What is the role of the QC Inspector at STP?
j A.
7.
The basic responsibilities of an Inspector are the
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same for all discipline areas of the Project, and these i
i responsibilities have not varied significantly over the life of the Project.
The role of the Inspector is to provide i
j documented verification that the work performed by construc-I tion has been done in accordance with the appropriate procedures, i
specifications and other related design documents.
Daily l
inspections are performed in accordance with pre-planned checklists provided by Quality Engineering.
These checklists provide the Inspector with specific requirements for the performance of his work.
l Q. 8.
Does & QC Inspector have any responsibility for I
l verifying that design changes are executed in accordance I
l with the purposes of the original design?
l i
i i
A.
8.
No.
As explained below, verification of design
/
l changes is performed by the Engineering Department.
l Q.
9.
What standards and requirements govern the control of the design of a nuclear power plant?
l l
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A.
9.
Design co atrol is primarily governed by Criterion i
III of Appendix B to 10 CFR Part 50.
STP is committed to j
adhere to the requirements of Regulatory Guide 1.64, which invokes the requirements of ANSI N45.2.ll.
The mechanism by 1
l which design control requirements are implemented is described l
in the Engineering Procedures Manual, which is reviewed by j
the Quality Assurance (QA) Department.
t Q. 10.
Under the Project organization in existence prior to the NRC Order to Show Cause, describe the basic method by which field design changes in the Project were exe:uted and reviewed by Engineering to ensure that such cha1ges ware in accordance with the purposes of the original design.
A.
10.
By procedures originally issued in early 1976, l
l all requests from personnel at the construction Site for I
changes to, deviations from, or clarifications of requirements concained in the design documents were controlled through a system called Field Requests for Engineering Action (FREA's).
Such requests were recorded on a form designed for this purpose.
Once the request portion of the form was completed, the form was transmitted to Engineering.
Engineering then l
reviewed the request and exercised one of the four following options: (1) disapprove the request, (2) grant a deviation i
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I from design requirements, (3) change the design requirements, or (4) clarify the design requirements.
Requests were disapproved when the request would have I
resulted in an unacceptable deviation from the design basis, l
when the request could not be substantiated, or when the request involved a nonconforming item.
Deviations were i
granted on a one-time basis when the request represented a l
minor departure from design requirements.
When a deviation was granted, the completion of the FREA form would be the I
vehicle by which the request was approved.
When a design
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change was required, a formal change of the design document was required.
Clarifications were only granted when no
,l change to the design requirements was involved and only i
additional information was required to be provided.
Proce-
.l dures required that FREA's be controlled and submitted i
through the same review and approval cycle as the original l
l design document.
In addition, all FREA's written against safety related or seismic Category I documents required formal design verification.
Q. 11.
Please describe the organizational relationship I
between the B&R Design Quality Engineering Group and the B&R I
l QA Department.
A.
11.
Design Quality Engineering, which reports to the Engineering Project Manager, provides support to Engineering i
I
.i i
I Project Management for the purpose of assuring that design I
work is performed in conformance with the requirements of j
engineering procedures, the QA program, government regulations i
and industry codes and standards.
Design Quality Engineers I
do not themselves perform QA functions, and have no formal organizational relationship with QC Inspectors.
- However, l
Design Quality Engineers have assisted QC Inspectors in their tasks through informal contacts, and through such i
activities as QC Inspector training sessions conducted by Design Quality Engineering at the request of QA Management.
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Q. 12.
Please specifically address the allegation in Contention 1(7)(b) that there were personnel other than the original designer approving design changes and no first-hand knowledge of the purpose of the original design.
A.
12.
I believe this allegation dates to a period of i
time when the first Design Engineer was assigned to the I
l site.
This occured about May of 1978.
At the direction of l
j HL&P, B&R reviewed its organization to provide for the i
j assignment of Design Engineers at the site.
One of the functions of this organization was to process FREA's and, I
where technically feasible, to review these at the site.
It had been estimated, at the time, that it would take 1
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from 3 to 6 months to implement this organizational change 1
l fully.
B&R did, however, have an experienced and competent I
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f I
l Civil Engineer by the name of Douglas Robertson, already l*!
stationed at the site to assist in geotechnical activities, and he was given the assignment to be B&R's first Design Engineering representative at the site.
Procedures were revised to allow Mr. Robertson to review certain FREA's at the site in the following manner.
All FREA's involving any 3
Discipline activity other than Civil / Structural were immedi-I '-
ately sent to the respor.sible design discipline in the i i Houston Office with copies to HL&P.
The Site Design Engineer-
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ing Representative was authorized to review all Civil / Structural FREA's and, if in his judgement, he had the technical expertise to approve any of these FREA's he was authorized to do so.
I e,
Prior to granting such approval, however, he was required to I
i do two things.
First, he was required to gain knowledge of I;
.I the situation through discussions'with Construction; personnel
!l or visual observations.
Second, he was required to contact l
i !
the responsible Design Engineer by telephone.
If the responsible Design Engineer felt that the request f
was significant and that. calculational activities were I !
required, the Site Design Engineering Representative vould forward the FREA to the responsible Design Engineer for any Ii
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I, additional activities.
If the request was for a rather
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straight-forward change that did not involve any such calcula-I 1 I tional activities, the responsible Design Engineer would g;I!
i l
l authorize the Site Design Engineering Representative to l
approve the FREA.
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The Site Design Engineering Representative would then i
record the date of the telephone conversation, and with whom i
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it was held, on the FREA form.
He would sign the form, and provide a copy to Construction, Quality Assurance, and to the responsible Design Engineer.
Construction was then i
t allowed to proceed with implementing the change.
The respon-l sible Design Engineer was required to then process the FREA l
in a normal manner, i.e.,
to perform any activities required i
by procedures, to have the safety-related FREAs processed l
through the design verification cycle, and to obtain all of the remaining signatures including the Discipline Project 1
l Engineer, Design Quality Engineering, and the Engineering i.j Project Manager.
Through this process, there was a minimum risk of having to do some rework, but it was determined by B&R and HL&P that there was no safety risk involved since i
the FREA required control measures commensurate with those applicable to the original design.
This process complied l
l with the requirements of Regulatory Guide 1.64, which pro 1 ides i
l
. the requirements for QA activities during the Design and I
i ingineering phases of the nuclear plant.
l l
In short, contrary to the allegation in Contention 1(7)(b),
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all design changes were reviewed by Design Engineers with I
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l the appropriate "first-hand knowledge" of the purposes of the original design.
i Q. 13.
Please specifically address the allegation in j
Contention 1(7)(c) that there were design changes approved
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' by personnel unqualified in the type of design where the change was made.
A.
13.
I believe this allegation also involves the t
assignment of Mr. Robertson as the single Civil / Structural l
Site Design Engineering Representative.
Mr. Robertson has a Degree in Civil Engineering from the Sydney Technical College, in Sydney, Australia.
At the time of his assignment, he had approximately 20 years experience as a Civil Engineer involved f
in earthwork construction, surveying, soils and concrete testing, construction project management where piping, steel 3
erection, and concrete structures were involved, foundation investigations and design analysis, and airport construction; i
j such experience having been gained prior to his employment j
by B&R.
I had personally dealt with him before his assign-1 l
ment and knew him to be extremely well qualified in the Civil / Structural area.
At the time of his assignment as the l
Site Design Engineering representative, he was the Geotechnical Engineering representative on the Site.
Geotechnical Engineer-ing is only one part of the Civil / Structural Engineering i
l Discipline for which Mr. Robertson had extensive experience.
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l l
1 Turthermore, although Mr. Robertson was well qualified, all of his work with regard to FREA's was subsequently reviewed i
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and approved by the responsible Design Engineer, Design i
Quality Engineering and the Engineering Project Manager.
t 1
Thus, the allegation is without basis -- there were no i
design changes approved under Mr. Robertson's tenure as Site Design Engineer that were " approved by personnel unqualified i
in the type of design where the change was made."
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