ML19343D379
| ML19343D379 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/27/1981 |
| From: | Amaral J HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML19343D370 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8105040361 | |
| Download: ML19343D379 (9) | |
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5i TESTIMONY OF JOHN M. AMARAL 6i REGARDING ALTERNATIVE OA ORGANIZATIONAL STRUCTURES 7i 3l 9l Q. 1 Please state your name and occupation.
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1 John M. Amaral.
I am Manager of Quality Assurance h2i of Bechtel Power Corporation (Bechtel).
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Q. 2 Please describe your educational and professional L6 background.
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2 I am a graduate of the University of Southern to, California where I studied Industrial Management and Industrial
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Engineering.
I have over thirty years of industry. experience.
3 Prior to joining Bechtel, I was the Manager, Quality 15 Systems with Aerojet Nuclear Systems Company.
I also held 16 17 several other upper positions with that corporation in ZS :
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various aspects of quality assurance (QA), reliability and 30 31 program management.
32 In June, 1972 I joined Bechtial as QA Manager for the 33 3
LMFBR, Fast Flux Test Facility.
I served as Deputy QA 36 Manager of the San Francisco Power Division.
In 1976, I was 3,
38 promoted to Manager,, QA at the Bechtel Gaithersburg Division.
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to i I am now Manager of QA for Bechtel.
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42 I am a registered Professional Engineer in California 43 '
g4 and certified as a Reliability Engineer by the American 45 Society for Quality Control.
I am currently Chairman of the 46,
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Energy Division of the American Society for Quality Control.
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-lle-l 8105040361
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Q. 3 What is the purpose of your testimony?
6i A. 3 I will describe Bechtel's recommendations to 7
0 Houston Lighting & Power Company (HL&P) concerning alterna-9 0
tive QA organizational structures for the South Texas Project 1
2l (STP), and explain the basis for Bechtel's recommendations.
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Q. 4 How did Bechtel become involved in reviewing the
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l7i A. 4 In January 1980, HL&P requested that Bechtel g;
'3 I review the QA program which was being implemented at SJP.
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The requested review was to include both the deficiencies in 2
.3 the QA program which had been discovered in HL&P's own
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.5 reviews of the program, and those preliminarily identified in
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,7 discussions between HL&P and NRC Region IV personnel, as 3!
I,9 well as alleged deficiencies which had appeared in the news 0'
l media.
This was before the NRC I&E Report 79-19, the Notice
.9 l2 i of Violation or the Order to show cause were issued.
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Q. 5 How did Bechtel perform its review of the QA
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l6 l program?
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5 Under my supervision,. selected personnel from 19i
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three of the power division offices of Bechtel were assigned il !
t perform a comprehensive, in-depth audit of the construction
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For these purposes we examined celected i5 !
elements of the STP quality assurance activities.
Our 66 i 67 review involved a check of QA manuals and procedures in use 18 19 !
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5l by both B&R and HL&P; an examination of design control 6'7j procedures (especially field-initiated changes); a review of 3I special processes (primarily welding and NDE activities); an
'0 j audit of the nonconformance reporting system and several CL !
L2l other areas.
The review identified a number of concerns L3 I (4
which we were able to trace to six " root causes" which are L5 (g l discussed in the testimony of Mr. Oprea.
L7(g j The results of the comprehensive audit were contained b3 in the Final Quality Assurance Management Report to HL&P 20 <
21 dated July 24, 1980 which was attached to EL&P's response to 22 13 the Show Cause Order.
24 25 Q. 6 When did HL&P request Bechtel to review alterna-25 1
27 tive QA organizational structures at STP?
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A. 6 In April, 1980, after Bechtel had begun its
}'O' review of the STP construction QA program, the NRC requested 32 '
that EL&P evaluate five options for the STP QA organiza-33 34 ;i tional structure.
Since Bechtel was in the midst of its 35 ;
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audit of the QA program, HL&P requested our assistance in 37 !
I 38 evaluating the options suggested by the NRC.
no i l Q. 7 How was the Bechtel review of alternative QA 4j ; organizational structures conducted? 41 43 l A. 7 The review of alternatives was conducted in 44 l 45 { parallel with. the Bechtel audit of the STP construction QA 46 47 i program and overlapped the audit schedule. Our conclusions 43 l 49 l l 50 i I l 51 1 I i i ) _1 v_ 1 1 1
L 2. 3I 45l and recommendations were based on consultation with the 6 audit teams, with other Bechtel Quality Assurance Managers 7! 3' and with other managerial personnel in Bechtel whose exper-9: 60! ience in the nuclear power industry is both broad and success-61 i L2 ; ful. L3 (4 Q. 8 What were your basic conclusions and recommenda-L(j tions on organizational structure? l A. 8 Our conclusions were contained in my letter to 19 ; HL&P of May 9, 1980, which addressed the alternative organi-20 ! 31 ' zations suggested by the NRC. I pointed out that the solu-22 l 23 tions to the root causes of the QA problems were not dependent 24, 25, upon the particular QA organizational structure. As I 36 t I stated, "Since these root causes exist, the organizational 27 i structure of the Quality Assurance Departments is of lesser g 30 concern." I emphasized the need for positive attitudes 32 ! toward quality management. 33 ; 34 i on the basis of our review, Bechtel recommended an 35 ' 36 i expanded version of the first alternative or " option A" 37 i 38 i mentioned by the NRC (i.e., the existing organization with 39 ! 40 upgraded staffing). 4k.; We described our approach as encompassing ". . mainte-4 i 43 ' nance of the existing basic assignment of QA program responsi-44 45 bilities of both HL&P and Brown and Root; acquisition of 46 47 ! qualified quality professionals with credentials that indicate 48 I i 49 j j 50 1 51 i i
1i 2; 3i 4j 5; successful performance of similar functions; and dedication 6i 7 i to fully implement the upgraded QA plan, with particular 8' 9{ attention to performance of the QA Tasks and functions. 0l As part of this alternative, we recommended "that as an 1! 2! interim step HL&P acquire the services of an outside organiza-3 4 tion dedicated to and possessing the expertise required for 5 6 performing this type of function. The personnel of the 7i gj third party organization could be integrated into the HL&P 9 0t and Brown & Root organizations in supervisory positions 9g, until such time as permanent personnel can be obtained by both companies." We felt that this was the quickest and 5 easiest way to fill the apparent voids in the STP QA organi-6 7t zation, but, much more importantly, we concluded that this S: 9; alternative retained the fundamental precept that the " doers" l 0' have responsibility for both doing and controlling the work. l 9 -e'}l It is a concept which has been implemented successfully in I 4 numerous utility /AE Constructor combinations over the years 6 7; in nuclear power construction. Admittedly, this alternative i 8! does not represent a dramatic change in organizational 9: 0 arrangements but, in concert with the significant upgrading 1 2 of both organizations' QA/QC staffs (which we recommended), i 34l It was our view that these steps addressed most directly the 5l concerns we had identified. 6i 7i a! 9i 01l i I -A44-
L; 2l 3l 4i ll 5l Q. 9 Why did Bechtel not recommend a new structure 6i 7i giving QA responsibilities to a third party organization? 3: A. 9 There are some QA functions that a third party 9 ,0 1'l organization can perform effectively in an operation as .2 demanding and complex as the design, procurement and construc- .3 .4 tion of a nuclear plant. But, in my opinion, it is mandatory 3 .6 that the organization performing a function be responsible .7. ,g-i for the quality of that function. The organization responsi-e' }, ble for design must be held accountable for the quality of 1}> the design - and the constructor must accept responsibility j for the quality of the construction. .5 It is evident that if the organization doing the work .6 ; .7 ! is responsible for the quality of its work, the addition of .8 ,9 a third party can do nothing to improve quality. To the .0 i 2 contrary, such an addition might relieve the working organi- ~2 ' zation of responsibility for quality even though the third 3 4k party cannot be expected to be responsible for something it l sI l 6 cannot control. 7; i S This situation would'be compounded in a case such as 9! ~ 0l STP where over half the plant is completed. What would be a j feasible dividing line for the transfer of QA responsibility? I 31 4l For the entire plant? For the remaining plant? For open 5 deficiencies?, For improperly closed deficiencies? For 'I ! rework? It is obvious that the transfer of responsibility 8*9l l 0i 1l l 4 1 b" l l l
i 1: 2 3l 4l, for QA would be an extremely complex undertaking, if feasible, 5 6\\ 7I at all. gi It is for these reasons that we believe that a third 9 party QA organization is not an appropriate alternative and k2 ! that we made our recommendation to: '.3 L4 A. Strengthen the HL&P and B&R QA organizations, and L3 L6 B. Provide motivational indoctrination to HL&P and B&R L7 i Lg at all levels of management. i 3, 50, Q. 10 Can you briefly describe the principal reasons n' {} for recommending against the other options set out in the 13 NRC's Order to Show Cause? 24 15 A. 10 Yes, Option B involved the development of an 16 ; 17 - organizational structure where all levels of B&R QA/QC IS, 29 ; report to HL&P. Although this has the superficial benefit 30 : of appearing to enhance HL&P control over the QA/QC function, 3; 32 it would place B&R QA/QC personnel in the position of " serv-33 34 i ing two masters" and raise, again, 'the cor ern about reliev-33 i 36 ; i 37 l ing B&R " doers" of quality responsibility. I would also be 38, very concerned about miring HL&P in the details of the 39 i 40 i program and thereby detracting from their ability to maintain 41 l 42 ; an overview of the quality function. 43, 34 l Under Option C, EL&P would establish a total QA/QC 4f ! organization,to conduct those functions now performed by 4 47 ' B&R. Again, this is a dramatic change but one which has the 48 : 49, 50, 51 i i t -149- = =
t 2, 3! 4l potentially deleterious effect of relieving B&R of responsi-5> 6! bility for quality. It also has many of the same disadvan-7! 8I tages of Option B as well as a potential for a period of 91 .0l instability in the relationship between the two organizations .[1 2' as EL&P personnel move in to a more direct supervisory role ( '3
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f* Option D essentially calls for a third party to er.ecute L7 i QA/QC functions. I believe that both organizations would L5 L9 i suffer from their lack of involvement in quality-related 20 ' 21, functions . mentioned above. I can see a confusion 22, i 23 between the responsibilities of HL&P and the third party as 24 25 well as a perturbation in the relationship between B&R and 26 27 HL&P by the addition of a new interface - a third party with 28 : its own methods of correspondence control, procedural documents, 29 ; 30 etc. 31 5 32 We also looked at Option E - establishing in EL&P a 33 : 34 ! duplicate QA/QC organization to match that of B&R. Although 35 i 37 ! this " beefs up" the organization by achieving a "one-to-one" 36 3g ; relationship between B&R and HL&P QA/QC personnel, it detracts from " doer responsibility" on the part of B&R and, in my 4 41 judgment, has a large potential for gaps in implementation 42 : 43 ! ("I thought he did it"). 44 j 45 l Q. 11 Has Bechtel followed the implementation of its 46 47 l recommendatiens? 48 49 i 50 l 51 ..a-
L i 2 3i 4! A. 11 Yes. We have recently completed a review and 6I 7; audit of the QA/QC program against our 198C4 findings and we 8! 9, found that the concerns we expressed last year have been k0 i addressed satisfactorily. Our observations also tend to .1, '2 i support our judgment as to the optimum organizational arrange- .3 '4 ment for QA/QC functions at the STP. .3 .6
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