ML19343D390
| ML19343D390 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/27/1981 |
| From: | Frazar R, Goldberg J HOUSTON LIGHTING & POWER CO. |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8105040398 | |
| Download: ML19343D390 (37) | |
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4 UNITED STATES OF AMERICA
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6 NUCLEAR REGULATORY COfG1ISSION ,
7; 8i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 10 11 '
12 13 ' In the Matter of: S 14 5 15 HOUSTON LIGHTING & POWER S Docket Nos. 50-493OL 16 COMPAITI, ET AL. 6 50-4990L 17 5 13 , (South Texas Project, s
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f3 TESTIMCIPI ON BEHALF OF HOUSTON LIGHTING & POWER CCMPAlri, ET AL.
.e 23 OF t 26 ' I 27 MR. JEROME H. GOLDBERG !
23 MR. RICHARD A. FRAZAR l 29 I 30 ON 31 '
32 HOUSTON LIGHTING & PC%ER COMPA1Pf' S 33 , CURRENT MANAGEMENT OF THE SOUTH TEXAS PROJECT r i 34 i 35 ' j 36 '
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i 3l 4l 5i UNITED STATES OF AMERICA 6l NUCLEAR REGULATORY COMMISSION 7i 8l e BEFORE THE ATOMIC SAFETY AND LICENSING BOARD "i
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19 In the Matter of: $
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~3 I HOUSTON LIGHTING & POWER 5 Docket Nos. 50-4980L 14 CCMPANY, ET AL. $ 50-4990L
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et M APPLICANTS' TESTIMONY ON CURRENT
] MANAGEMENT OF THE SOUTH TEX'S PROJECT 24 ec
'- The following is testimony presented on behalf of 26 27 I Houston Lighting & Power Comoanv, et al. (Auplicants) on
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29 ' Houston Lighting & Power Company (HL&P) management of the 30 31 overall project activities of the South Texas Project (STP).
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33 The panel of witnesses presenting this testimony consists of 34 I 33 Mr. Jerome H. Goldberg and Mr. Richard A. Fracar. The
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testimony consists of the following segments:
}gg,! 1. Mr. Jerome H. Goldberg with respect to HL&P's j0 '
organization and staff resources for management of the !
4{ design and construction of the STP and how HL&P is fulfilling na j 44 ' its management responsibilities. i
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5 2. Mr. Richard A. Frazar with respect to EL&P's 6;
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4- TESTIMONY OF JERCME H. GOLDBERG 5 ON THE CURRENT MANAGEMENT OF STP 6i 7; Q. 1 State your name and current emplcyment.
8 ol' A. 1 Jerome H. Goldberg. I am Vice President, Nuclear
-8 10 Engineering and construction, of Houston Lighting & Power to T:. ,l Company (HL&P).
14 Q. 2 Describe your professional experience and educa-15 16 , tional background.
3-1 13 A. 2 I received a Bachelor of Science degree in Marine to j' ' Engineering from the U.S. Merchants Marine Academy in 1953 91
- ' and a Master of Science degree in Nuclear Engineering from
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Massachusetts Institute of Technology in 1960.
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I joined HL&P as Vice President, Nuclear Engineering 27 and Construction in October 1980 where I have responsibility 23 t 29 for engineering and construction of the South Texas Project 30 ,
31 - (STP) and HL&P's planned Allens Creek facility.
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33 ' From 1971 unti' Cctober 1990 I was employed by Stone &
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e-a- Nebster, wheru I began as a nuclear engineer and was promoted 36
,i to positions of increasing management responsibility up to as "S'
g the position of Vice President and Deputy Director of Construc-40 ' tion. During the course of my employment with Stane & j l '-
! 42 Webster I also served :s Project Engineer and Project Manager j
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44 > of the Beaver Valley I Nuclear Project and as Chief Engineer
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Prior to joining Stone & Webster, I was employed frem o
6 1955 to 1971 at the Quincy, Massachusetts ship building yard
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in various positions involving engineering, design, construc-g 9
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I became the Nuclear Construction Manager and was responsible 13 for all nuclear construction activities associated with four 1
1: summarines built at the 2uincy facility.
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17 , I served on active duty in the U.S. Navy from 1953
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no to 1955.
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I am a member of the American Nuclear Society and a ce
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Neu York, Pennsylvania, P.hede Island, California, Virginia
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41 23 Q. 3 What has been your involvement on the STP?
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30 A. 3 Since joining HL&P in late October 1980, I have et 32 been responsible for the sanagement of STP and have supervised
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.n the activities of the STP Project Manager and his staff for i.~c design, engineering and construction. Concurrently, I have ,
,- , i di so been providing direction for the continued upgrading of HL&P !
i j9 ei staff qualifications and administrative and technical prece- l 20 i ,
41 dures associated wi+h the management of STP engineering, 43 design and construction.
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- Q. 4 What is the purpose of your testimony?
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4, A. 4 The purpose of my testimony is to describe how 6 HL&P is currently managing the engineering, design and 7
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construction of STP, and to explain the bases for my opinion 9'
30l that HL&P is fulfilling its management responsibilities in 11 7, ;
full compliance with applicable requirements and standards 13 of crofessional competence.
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13 Q. 5 What is HL&P's role in the management of STP?
16 17 i i A. 5 Under the Participation Agreement among the
_se e 19 { co-owners of this Project, HL&P's responsibilities include 20 '
21 management of engineering, design, construction and operation o f STP . HL&P administers the contract with the architect-engineer-constructor, Brown & Root, Inc. (B&R) and the 41 contract with Westinghouse, the company which is supplying
-n lo the nuclear steam supply system. As is often the case uith 29 30 nuclear plant construction contracts, the e contractors 31 32 provide engineering, design, procurement, fabrication, 23 >
34 1 construction and quality assurance (QA) services for the 35
- 36 activities within the scope of their respective contracts.
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.2 As the Project manager, HL&P bears the responsibility for .
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,. 0 seeing that those services are properly performed in accordance }
with applicable contractual requirements and the commitments 43 to the Nuclear Regulatory Commission, as set forth in the i
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Safety Analysis Report. ;
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4 7 :. Q. 6 How does EL&P make sure that its contractors 48 i !
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3 4 A. 6 To carry out its responsibilities, HL&P has 2
6' assembled a professional staff to oversee the work of the 9
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_30 HL&P's E:cecutive Vice President, George W. Oprea, Jr., is in 11 .
charge of this effort. As shown in the attached organization
- 1. 7 13 chart ( Attachment No. 1 to this testimony), Richard A.
1 ,4 13 Fracar, the QA Manager for the STP, and I, as Vice President -
15 1/ Juclear Engineering and Construction, report directly to Mr.
13 19 Cprea. The STP Project Manager, David Barker, reports to
~O me. Ha is responsible for engineering, construction, procure-n, ment, cost, and schedule of the Project. Mr. 3arker has a 2'
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- staff of 230 personnel that comprise HL&P's Project Management 43 team. I meet frequently with Mr. Barker and his key project a l 23 tear members, and together we review engineering and construc-29 20 tien management issues related to STP. HL&P's staff is 32 physically located at the engineering and design offices of 2a 34 '
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B&R, the architect, engineer and constructor, as well as at
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o the construction site. This olaces our staff in direcc 3I
.3 contact with both the work and the contractor's team respon-33
,.0 sible for cerforminc- the work.
". ,3 Q. 7 Is Quality Assurance a part of the HL&P Project j
. a- Management team? ;
44 , ! 43 i A. 7 No. As shown by the QA Department organization i n: ; 47 chart (Attachment No. 1 to Mr. FraCar's testimony), the QA as - ' i
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1 1 3 4: Manager on the STP reports directly to the Executive Vice o. gl President. There is also a separate HL&P corporate QA group 7i ' gj that has offices in Houston, and its manager also reports 9' 10 , directly to the Executive Vice President. 11 Q. 8 How is the Project Management team organised? 13 A. 8 As shown in the Project organisation chart (Attach-1.1 13 ment No. 2 to this testimony), reporting to Mr. Barker, the 16 17 , Project Manager are Joseph Briskin, the Manager, Houston _3c 19 < Operations, and Leon English, the Project Site Manager. og ' 31 They are responsible, respectively, for the Houston office on
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a. and on-site portions of the Project team. Mr. Sriskin, the o Manager, Houston Operations, is responsible for engineering,
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-- c.rocurement, croject control services, accounting and .croject as 33 i administration. The persons reporting to him include the n ~.o 30 Project Engineering Manager, the Project Control Manager, -1 32 ' the Project Purchasing Manager and the Project Controller.
44 34 , Mr. English, the Project Site Manager, directs the
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co cn-site efforts of HL&P and its prime contractors in the jI areas of construction, site purchasing, security, startup, oc l
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accounting, construction control and site engineering. Re.corting to him are the Construction Superintendent, the i na 43 Construction Control Supervisor, the Supervising Project 44 l 45 i 4 - Engineer, the General Supervisor STP Accounting, and the nb i i 47 Startup Manager. l 43 - i
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L 2' 31 4; The total staffing for the Project Management team 5 li 6 includes 230 HL&P employees of whom about 195 are profes-7I g sional employees. This does not, of course, include the QA 9 staff or the plant operations personnel. 79 91 Q. 9 How do you stay in touch with Messrs. Barker,
-- i 13 ' Briskin, and English?
14 15 A. 9 I am in touch with Mr. Barker almost on a daily is 17 basis regarding a variety of matters. In addition, I attend s~ o 19 , the Project Review Meetings and also the B&R Quality Assurance 20 33 Management Review Board Meetings which are held at the site nn on a monthly basis.
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n. My contacts with Mr. Briskin and Mr. English are through
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26 Mr. Barker on an organizational basis. However, I mee t with of 23 ! them directly on a case-by-case basis whenever the need 29 - 30 arises. 31 32 Q. 10 Describe the qualifications of HL&P's Project 33 34 , Engineering group for STP. 35 i 36 A. 10 HL&P's Project Engineering Manager has a staff ,
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_' j of 50 engineers. They review analyses, designs and specifi- I j40 ; g cations. In addition, there is a seven-man licensing and i I j ! 41 technical staff reporting directly to Mr. Barker that is i 43 , responsible for providing the licensing interface with the ' 44 i 45 l NRC. The 57 full-time members in these two technical support 46 . ' 1/ 48 i 49 50 9 i
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li 2; 3 4l groups have substantial (over 265 man-years) nuclear experi-5; 6i ence. Another 40 individuals provide part-time support. 7i gj Technical support staff are located at both the B&R Houston 9' 10 ffices and at the STP site. 11 The qualifications of some of the key individuals in 12 13 ' , our management organization are: 14 15 i (1) The Project Manager, Mr. David Barker, has a Masters 16 i 17 i degree in nuclear engineering and 16 years experience in 13 ; 19 ; various areas of the design, maintenance, testing, QA, 20 i 21 ! construction and management of nuclear pro]ects. no
}} , (2) The Manager, Houston Operations, Mr. Joseph Briskin, ca - 2 ,' has over 20 years of experience in power plant project 2s .
26 j management, including 10 years related to nuclear power 3e ; 23 ! plant construction. ! 29 30 : (3) The site Manager, Mr. Leon English, has over 29 31 ) [ 32 l years experience in power plant construction management i 33 i l 34 ; including 12 years related to nuclear power plant construction. 35 I 36 i ' (4) The Supervising Engineer-Houston Engineering has a 37 l Bachelor of Science degree in mechanical engineering and has 3g 39 ! had 8 years design experience with HL&P-40 ! 41 (5) The Supervising Engineer-Site Engineering has a 42 1 43 j Bachelor of Science degree in nuclear engineering and 6-1/2 i 44 l l 45 l years nuclear e,xperience, including 3 years in startup 46 ! 47 ! engineering at the Tennessee Valley Authority's Browns Ferry 48 : 49 l Nuclear Plant, and 3-1/2 years at HL&P. i 50 51 1 _9_
_e._ 1 2, 3l 4i The Houston engineering group includes all the major 5i 6i engineering disciplines plus licensing, health physics end 7i gi nuclear fuel. The site engineering group also includes all 9 10 , the major engineering disciplines plus health physics and 11 l nuclear licensing. 12 i 13 i Q. 11 What is the function of HL&P'a STP Project 14 15 : Engineering group? 16 17 j A. 11 The Project Engineering group gives programmatic 13 19 : direction to the B&R design and technical support effort. 20 . 21 ! B&R has a large staff of Design Engineers responsible for 72 53 the engineering and design of the power plant. HL&P performs
'4-reviews of these activities. The reviews are designed to b5 '
26 ; ensure that B&R has considered the applicable industry codes 2e i 23 and standards, regulatory requirements and HL&P's preferences. 29 > 30 ' Q. 12 Describe the process by which HL&P performs this 31 32 engineering review. 33 34 A. 12 Our Project Engineering group reviews and approves 35 l 36 basic design documents, provides owner's direction to B&R 37 3g and Westinghouse design activities, and participates in 39 ! resolution of problems in project engineering, construction 40 j 41 ; and procurement activities. 42 i 43 : The HL&P Project Engineering team is structured along 44 discipline lines, much the same as the structure of B&R 45 46 { 47 i engineering. The HL&P Engineers are in contact with their 48 i 49 i 50 51 l i
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L 2 3' 4 B&R counterparts virtually every working day. 'EL&P informs o 6 B&R of its questions, concerns, design preferences, etc. At 7 3' times HL&P Engineers work closely with B&R Engineers to find 9 engineering solutions to inportant design problems. At 10 11 other times, HL&P involves itself in .'.ecisions on manpower 7_7_, l t,
; levels and in the assignment of B&R personnel. We have
_s 10 directed that certain design studies be perfor=ed or design am 17 options be implemented, and we have directed changes in the
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19 procedures used by B&R. 20 21 HL&P Engineering uses all of these tools to ensure that on {} B&R's Engineering team is properly addressing the Project n:a
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design requirements. 26
-- Q. 13 Please present some specific examples of action 41 23 EL&P has recently taken as part of its direction of 3&R 29 30 construction and design efforts.
3L 32 A. 13 Based on operating experience, or technical 33
, evaluation of a system, component or structure, we frequently j# For direct B&R to incorporate a modification to the design.
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~' instance, EL&P instructed B&R to utilize the criteria of 3S 39 10 CFR 50, Appendix R, and added criteria developed by EL&P 40
, i 4' 4-tended to increase the protection for redundant safety-42 43 related circuits from seismic events, flooding, fires, and 44 4 45 : missile hazards. In addition to establishine certain basic
,73 criteria, EL&P has and will continue to review and monitor e
4b i 49 50 t .. L 1 3 fa raceway design efforts to ensure they meet the established
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7 3 As another example, HL&P established the basic criteria 3' 3, for the instrument and station air systems both in system L' 2 layout and specification of component materials and sizing. 3
, Criteria established by HL&P were based on previous experience in our fossil plants and included significant operations and 5
7' maintenance input intended to increase the reliability of s 3 these systems. EL&P drawings and specification comments 3 1 were transmitted to B&R for this purpose. 2 3 Finally, HL&P has taken the lead in evaluating the 4 l proposed design changes resulting from the TMI experience. We are actively involved in providing direction to B&R in i 3+ this matter. 9 3 Q. 14 Are you able to express an opinion on how HL&P's 1 2 current management of design and construction on this Project 3, 4 compares to generally accepted practice for nuclear construction? j A. 14 Yes. In the course of my 26 years of experiences, 7 I have been significantly involved in the construction of 12 3 3' nuclear power plants. I believe that I am in a position to l 3 l- compare HL&P's management structure and competence to that 4 3 of other owners involved in complex nuclear projects. 4 5: Q. 15 How ' does HL&P compare? 5 7 3i 9 3 1, i
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, Since each project is different it is not possible I to draw any precise conclusions from a comparison of results.
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!' However, it is possible to compare the numbers and qualifi- ) ; cations of professionals each utility employs to manage its construction project, and to examine the level and extent of I
1 corporate management attention that is applied to the project. I I can confidently state that EL&P is devoting adequate I resources to its management of the STP. Not only is the
) staffing adequate, but EL&P has taken steps to assure that ) , direction and control is exercised at appropriate levels and that lines of responsibility are si=ple and direct. EL&P 0 . has added the position I hold, Vice President, Nuclear 8
i Engineering and Construction, to expand its management I effort in its nuclear program. I personally co==unicate
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I with whatever level of B&R management that I feel is required [ to ensure their awareness of our needs and the i=portance of I
; proper and timely execution of the work.
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Q. 16 From your own personal observations, is EL&P's 1 management program working effectively? I I A. 16 Yes. In =y opinion, EL&P's management program ! )
. is fulfilling appropriately its responsibility to the public ) } and to NRC to have STP engineered and constructed in a I $! quality manner. I intend, however, to effect even further 3
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16 17 18 - 19 10 il 1 Attachment No. 1 EXECUTIVE VICE PRESIDENT G.W. OPREA, JR. I VICE PRESIDENT NUCLEAR ENGINEERING
& CO,4STRUCTION J.H. GOLDBERG i
-SOUTH TEXAS PROJECT -NUCLEAR FUELS 0.G. BARKER R.P. MURPHY
-ALLENS CREEK PROJECT -NUCLEAR OPERATIONS (VACANT) (VACANT) l
-NUCLEAR SERVICES -QUALITY ASSURANCE J.R. SUMPTER R.A. FRAZAR
-NUCLEAR LICENSING C. G. ROBERTSON l
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L 2 3' 4 5t TESTIMONY OF RICHARD A. FRAZ1LR 6i ON THE CURRENT QA PROGRAM FOR STP 7 S
- 9 Q. 1 State your name and current employment.
0 1 A. 1 Richard A. Frazar. I am the Manager, South Texas 2 3 Project Quality Assurance of the Houston Lighting & Power 4 _ Company (EL&P). 3, Q. 2 Describe your professional experience and educa-i 5 tional background. 9 0 A. 2 I graduated from Lamar University with a B.S. in T j Chemical Engineering in 1968. From 1968 until 1972, I was 3 4 employed by Monsanto Company in the Material Technology c Section as a corrosion engineei. In this capacity, I was responsible for conducting corrosion studies and field S 9 investigations in support of chemical operations. During 0 1 this time I gained extensive experience in the use of metal-2 3 lographic techniques for failure analysis and nondestructive 4 3 testing techniques for flaw detection purposes. In 1972, I l . 6l transferred within Monsanto to the Manufacturing Department 1 8 where I supervised the operation of a pressurized reaction 9 0! copolymer resin unit. I joined EL&P in 1973 as a Metallur-1, 2 gical Engineer in the Quality Assurance (QA) Departmenu. 3 4, Since joining EL&P, I have been associated with QA. In 5t 6' 1974, I was named Supervising Engineer for the STP QA program. 7i g I was promoted to Project QA Manager for STP in 1975 and then o promoted to Manager of the QA Department on April 1, 1977.
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i 1l 2, 3! 4! 5; In June, 1980 in response to growing concerns about the 6i 7l STP QA Program, I relocated to the Site and temporarily 8. 9; assumed responsibility as Project QA Manager. 0 y Q. 3 What has been your involvement in the QA Program 2 f r the South Texas Project (STP)? 3 4 A. 3 As I have stated previously, I have been involved 6 in the QA program since I joined HL&P in 1973, and particularly 7i E in the STP QA Program. From 1974 to 1977 I worked full time 9 0 ,. on STP QA - first, as Supervising Engineer and later as 9 ; j' Project QA Manager. In 1977, I was promoted to Manager, QA.
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In this capacity, I was responsible for all of the HL&P 9 6' activities related to QA in both the nuclear and fossil 7l plants. Nonetheless, I continued during this time to devote 8, 9' the majority of my time to STP QA matters. In June, 1980 I O, 1 relocated to the STP and assumed responsibility as the STP 2 :! QA Manager. 3 t a jl Q. 4 What is the purpose of your testimony? 6' A. 4 The purpose of my testimony is to describe the ! i , S current organization of the B&R and HL&P QA staff for STP. 9l , l 0i Q. 5 Please define the term " quality assurance" and I 9 k' explain how it is distinguished from " quality control" (QC). 3i 4l A. 5 QA is defined in the Introduction of Appendix B 5l as comprising "all those planned and systematic actions 6 7' 8j necessary to provide adequate confidence that a structure, 9l a; 1! l 1l 2c j 3i i 4! l 5, system or component will perform satisfactorily in service." 6 7I In this context QA includes the systematic actions of engineer-8l 9, ing, procurement, construction and the services used to control quality. It includes a separate QA group that 12 ! functions as an arm of management whose responsibilities are 13 14 to develop pclicy; verify implementation of policy; diagnose, 15 ' 16 anticipate and prevent problems. QA includes QC which is an 17 i lg ' , independent check to verify that requirements have been met. 9ai 20 ; QC activities involve physical inspections of completed 22 : 22 : in-pr cess construction work such as measuring the spacing 23 reinforcement steel (rebar) before pouring concrete or 4 25 - ,
.ographic examination of a weld.
2 e, ; 27 ! The QA requirements for a particular activity depend on 28 29 the nature of the activity and its relationship to safety. 30 31 ' Appendix B states that the QA program shall provide control 32 33 l over an activity "to an extent consistent with its importance 34 ; 35 ! to safety." For some activities the QA requ_rements include 36 37 ! a 100 percent QC inspcction of the work; for example, all ASME Safety Class 1 welds are required by the ASME code to 39 l 40 have 100 percent radiographic examination. In other cases 41l! 42 - the requirements may include only intermittent QC sampling
- 43 i l 44 i or periodic audit, as for example, soils compaction and con-l
' 45 l 46 ! crete batching,' which require periodic sampling for verifi-47 i 43 l cation of properties as defined in ASTM and ACI codes. 49 i 50 i 51 i 4 1
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- 5. Q. 6 Describe the management organization for accom-5' 7 plishing QA and QC on STP.
3, 3- A. 6 As with any major construction project, STP is 3 g being constructed from materials and components that are 3 being procured under contracts with a great number of organ-3 4 i=ations. QA requirements are established in the contracts, a 6 including the contracts with the principal contractor, Brown 7 E & Root, Inc. (B&R), and the supplier of the nuclear steam 9 0 supply system, Westinghouse Electric Csrporation, Inc. In 9 j almost every case the contract requires the supplier to 4 perform certain QA functions with respect to the goods or 0 services provided under the contract, subject to audit or 6 7 inspection by or for EL&P. The contract with B&R provides S 9' for B&R to perform QA services for its design and construc-0 1 tion activities on the Project. B&R's QA activities include
- 3 QA audits of vendors and subcontractors other than Westinghouse, 4l g QA on Westinghouse supplied equipment upon receipi. at the 6;
o ' site and the QA requirements applicable to B&R design and 8 construction activities. 9, O EL&P and B&R have an integrated QA Program for STP 1 2 which is described in detail in the " Quality Assurance 3i 4; Program Description" filed with the NRC. 5! l g! EL&P reviews the QA activities of B&R, providing program-matic direction and verification that the program is being 9 0 1,
L 1 3' . 4' I properly inplemented. In addition, HL&P QA performs audits 3 7 of all QA activities on the Project, including the activities 3! 3! of HL&P, B&R, and many of the vendors. The HL&P QA program 3; g serves as an independent check by which HL&P can assure itself that each contractor QA program, and in particular 3 4 the B&R QA program, is functicaing properly. B&R, as prime 6 contractor for the Project, is responsible for implementing 7, E' a QA program which fully satisfies the 18 criteria of Appendix 9 g B. The HL&P QA Staff assures that B&R is adequately fulfilling 9 { the requirements of the project QA program. EL&P does not duplicate B&R's QA activities, although HL&P does perform I its own periodic QC inspections, review of procedures and 6 7! records and observations of work in progress to verify that 3i 9 the B&R program is functioning properly. 0 1 Q. 7 How is the HL&P QA staff organized? 2 3, A. 7 I am the Manager of the HL&P STP QA organization 4 and I report directly to the Executive Vice President. 6 There are five people who report directly to me, the Project 7 6 QA General Supervisor; the Supervisor, Quality Systems; the 9 0 Supervisor, QC; the Procurement Project QA Supervisor; and 1 2 the Operations QA Manager. 3; . 4' The Project QA General Supervisor directs the Discipline j 8 i QA personnel, providing programmatic direction to B&R and g interfacing with NRC. Reporting to him, are the three 9, 0 1i 4
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2 3! 4i Ii Discipline Project QA Supervisors, who direct the QA personnel 5' 7' in the Civil / Structural, Mechanical / Nondestructive Examination 3 g, and Electrical / Instrumentation and Controls groups. 3i
- , The Supervisor, Quality Systems directs the site quality syu personnel, who develop and administer the HL&P f
s Project QA Plan; evaluate the B&R QA/QC program; administer 6 the HL&P STP QA personnel training and certification program; 7 g , provide administrative control of HL&P QA procedures and 9 O provide mechanisms to correct the QA programs. T { The Supervisor, QC directs the HL&P QC personnel in their conduct of inspections as requested by HL&P Discipline 5 QA personnel to provide separate spot checks of the inspec-3 7 tions performed by contractor QC personnel. These HL&P QC 8 9 personnel do not inspect for acceptance of work. 0' 1 The Procurement Project QA Supervisor coordinates HL&P 2' 3 vendor surveillance / audit activities and provides program-4' 3, matic direction to B&R regarding vendor surveillance and 6* auditing functions. t 8l 9, The Operations QA Manager directs EL&P's QA program for 0; plant operations, and is not directly involved in the design 1-2 and construction activities. 3: 4 There is also a separate Corporate QA group with offices 5I 6 ! in Houston that is headed by Mr. Robert Ulrey. That group has four sections: (1) vendor surveillance, (2) audits and 9: 0t 1i i
w 1 3 i technical services, (3) Allens Creek Project and (4) fossil 7 projects. Mr. Ulrey reports directly to Mr. Oprea. 3 3: Attachment No. 1 is an organization chart that shows 3 g these reporting relationships. j Q. 8 Describe the B&R QA organization. I A. 8 The division of B&R parforming the work on the 3 STP is the Power Group, which is headed by the Group Vice 7 i President for Power, Mr. William M. Rice. The Power Group 3
) QA Manager, Mr. Vurpillat, reports to the office of the t
{ Senior Vice President, Dr. Knox Broom. The B&R STP.QA 3
, Manager I, ports to Mr. Vurpillat, and is located at the ? South Texas Project site.
s I The B&R STP QA organization is divided into five sections, 3 3 which are generally parallel to the sections of the EL&P QA 3 L organization. The sections are Quality Engineering, vendor 2 3 Surveillance, QC, Quality Systems and Site Surveillance. 4
., Each of those sections is headed by a Manager, and is divided
- 3 into a number of subsections, as shown in Attachment No. 2.
7 3 The Quality Engineering group is divided into five sec-3 3 tions that encompass the major disciplines (i.e., Mechanical, L 2 NDE, Electrical / Instrumentation & Controls, Civil / Structural, 3 4, and Material Procurement). Quality Engineers control QA -i jI activities related to their individual disciplines. The {; Quality Engineers work closely with their lead discipline 3 3 1i
1
- 1 I
_. . i 1 1 l L ' 3 i counterparts in Engineering and Construction to resolve 3 7 problems that are identified during construction to assure 3 3 that the cause is determined and adequate corrective action ' 3 g is accomplished. The Quality Engineers nerform reviews of 2 3, engineering documents, purchase orders, and nons nformance f 3 reports for assuring conformance to quality requirements, 5 and prepare quality control inspection plans. The Quality 7 3 sngineers participate in planning QA activities (procedures, 9 3 plans, training, etc.) associated rith specific construction 1 j activites. Finally, the Quality Engineers assure that the QC Inspectors are provided clear instructions and acceptance !3 criteria. 7 QC inspects construction activities pursuant to inspec-3 3 tion planning instructions prepared by Quality Enginet. ring. 3 L QC is divided into seven groups, each directed by a St erin-2 3 tendent who reports to the QC Manager. The seven groups are a'
.; Mechanical, NDE, Electrical / Instrumentation & Controls, 3
Civil, Structural, Coatings & Insulation, and Receiving, 7 3 Storage and Maintenance. Reporting to the Superintendent of 3 3 each group are Lead QC Inspectors, who direct the activities L 2 of the QC Inspectcrs. These B&R QC Inspectors and Lead QC 3
; Inspectors perform inspections of construction activites for 5
5' acceptance. i 7' 3 3 3, L, _o -
t. Z
.t 4
5 Quality Syste=s cocrdinates the =aintenance of CA 3 7 records, records turnover p.:ccedures, de QA trai=ing and a g certificarica program, and the nonconformance trend analysis 0
, prcgram.
7 Vender Surveillance /Ecusten Cecrdination assures that inspections and audits of vendor activities are perfor=ed, 5 and serves as the interface between QA and Ecusten Engineer-4 I ing and Precure=ent activities. O g Site Surteillance performs surveillance ever site I activities at de direction of the Pro]ect GA Manager. s i, Q. 9 Ecw does Mr. Cprea keep infor=ed of develop =ents Je cn de ?rc4ect and crevide direcnien to vcu about de =anage-
, a . . =
.7 =ent of de QA Progra=? . .e.
- 9 A. 9 Mr. Cprea freTaently visits de site to review
.C
- 1 the pregress of construction, to discuss the status of the
.s primary Taality concerns, and to review the progress toward .a [i. closure of the Show Cause Order itens. Mr. Cprea also If, attends each =eeting of the S&R QA Manage =ent Review Ecard I IS (which are held en site) to review the status of the QA ic 10 Program. In additica Oc his freTaen en site visits and to f 12 for=al =eetings, Mr. Cprea receives fregaent briefings frc= i 12 g.; =e and nu=ercus QA reports frc= E!.J ? and 3&R, sc=e exa=ples ! .c
- ~
of which are listed belcw: le 94 %3 .
- s.o, 1, i
50 f = l 1l 2L 3I 4l 5l 1. HL&P QA Monthly Status Reports which include 6i 7j " a project deficiency status summary and a 8i 9' trend analysis summary. The deficiency 0 y status summary includes Audit Deficiency 2 Reports, Nonconformance Reports, and Correc-3: 4I tive Action Requests. 3 i 6; 2. Copies of all Audit Reports (HL&P and B&R) 7i g! 3. NRC Open Item Status Reports 9i 0j 4. Audit ~frend Analysis Reports 9 i j 5. Corrrective Action Requests 3l 4: Q. 10 What functions are performed by the HL&P Disci-5! 6' pline QA Personnel and B&R Quality Engineering groups? 7l A. 10 HL&P and B&R decided to give different names to 8, 9l these groups to avoid confusion, but both groups are composed l 0! l 1l of Quality Engineers with parallel responsibilities. The 2 3l I B&R Quality Engineers (QE's) perform their work on the 4 5l Pr je t in accordance with the programmatic direction they 6 receive from the HL&P Discipline QA Personnel. The B&R 1 1lj 8 Quality Engineering group is divided into separate sections 9, , Oi for the various disciplines: civil / structural, mechanical, 1l i 2 non-destructive examination (NDE), electrical / instrumentation l 3 4! and controls, etc. Each discipline is responsible for 5l 6, assuring that QA requirements are adequately reflected in I 7 g the various phases of Project des '.gn and construction. They 9i 01 1
4 L: I. 3l i 5l 3,I review procurement and design documents to assure that QA 7l requirements are adequately included and participate in 3 3; inspection planning, draft inspection checklists, and review 3' g and approve the QA aspects of construction producedures. 2' The Quality Engineers develop the criteria for training, 3 4 examination and certification of QA personnel and provide 6 technical direction and support to other QA personnel for 7i 5l 3 . resolution of quality problems. h They review documentation of Project activities, such 1 { as Design Change Notices and reports of QC inspection results to assure the applicable procedures are being followed. 3 They investigate adverse quality trends and identify the 3 7 need to issue Corrective Action Requests, which seek to S 9 eliminate the causes of errors, and they follow up to veri Jy 0, 1 the adequacy of the corrective actions taken. Finally they 2' 3; review completed packages of records as work is completed 4; - g, and assure that QC documentation is adequate. 6 - The B&R Quality Engineers perform all of this work 7 I 3 under the review and carection of the EL&P Discipline QA 9, - 0l personnel. EL&P discipline QA personnel review and approve 1! 2i B&R QA procedures and other system features and monitor 3i 4l their implementation. This implementation review includes GI y- techniques such as interviews with personnel performing the gl activities, observations of work in progress and reviews of 9: 0' completed work. 1i l I 2. 3' 4i 5 Q. 11 How do HL&P Discipline QA personnel interact 6, 7 with B&R Quality Engineers? 8: 9 A. 11 HL&P QA personnel work daily with B&R Quality
'0l y Engineering. This relationship includes the following
! activities:
.3 4 1. Project problems are resolved between HL&_?
.2
.6 Discipline QA and B&R Quality Engineering
.7
.5 ' staff.
o 0 2. Requirements and directives from HL&P QA to
>3 +
B&R QA are communicated through the HL&P i}
'3 Discipline QA/B&R QE interface. }
l5 3. Procedures are reviewed and approved through 15
!7 this interface. !S :
l 19 An example of how this relationship operates occurred i 10 ' l 11 during the structural and piping welding restart programs. 12 ' l3 , EL&P Discipline QA personnel worked with the B&R QE's on 14 ! resolution of problems prior to the welding restart and gg , il "eviewed NDE procedures generated by B&R QE's. This involved le , l 18 frequent discussion between the two groups to resolve dif- . I 19 , LO ferences in the procedures. This process was also used for 11 12 revision of the mechanical and civil construction procedures. 13 [4 HL&P Discipline QA personnel and B&R QE's witnessed NDE 15 i certification ' tests and reviewed initial radiographs of both 16 production and certification activities. All phases of the 19 ; 50
$1 j i
l l
1 I
- . l 1
L Z-3l 4! [ 2 l restart programs were jointly surveyed by HL&P Discipline 7 QA, B&R Quality Engineering and consultants. This relation-3l 9 ship is described in more detail in the testimonies of Mr. 3, Li Robert Carvel (Concrete Restarc) and Mr. Logan Wilson 2i (Welding Restart). 3 3 Q. 12 How is QC performed on the Project? 3 A. 12 As I just mentioned, the B&R Quality Engineers 7 I are responsible for inspection planning work and preparation ? 3 of inspection checklists. Their inspection planning work is t ~ 2 coordinated with the Construction organization to assure 3 that Construction and QC inspection planning are properly 3 sequenced. 3 I The B&R QC inspections are primarily performed by the 3 3' B&R QC group, although some civil QC work is performed by a 3 L subcontractor, Pittsburgh Testing Laboratory. HL&P Disci-2- 3 pline QA personnel review the documentation of the inspection 4 3j results, as well as the inspection planning, and provide 7j - direction to B&R to assure that the program functions properly. 3 The HL&P QC group is a small group of certified inspectors 9 3i in the three major disciplines who perform periodic inspec-Lt 2 tions to verify the adequacy of the B&R QC inspection. HL&P 3i 4l Discipline QA personnel plan the HL&P QC inspections and 5l g; utilize the HL&P inspection results in their evaluation of the B&R QA program implementation. 9 3 1I I I Li I LV 3l ! 1 4 Il ' Q. 13 What are the functions of the HL&P and B&R 2 1 l 7I Quality Systems groups? 31 3j A. 13 In each organization the Quality Systems group 3! t{ is responsible for preparing and maintaining the QA program a! documents. The B&R QA Systems group maintains B&R STP QA 3l 3 files and coordinates B&R's turnover of QA/QC records to a' 5 HL&P. The HL&P Quality Systems group eval.'tes the B&R
/ i E: QA/QC program level documents, trends observed in B&R's 3
0 implementation of its QA program, and provides programmatic 9 j direction to the B&R QA Systems group. In the case of both organizations it is the Quality Systems group that administers 4 5 the respective programs for training and certification of 6 7' QA/QC personnel. 8, 9! Q. 14 How is Procurement QA performed on the Project? O 1' A. 14 When a requirement for new equipment Jr services 2l is identified, B&R Engineering initiates the required engineer-3l 4i Prior to release of 5l ing d cuments to procure these items. 6 - these documents they are reviewed by B&R Quality Engineering l 8 9,l for assurance that the required QA commitments were included. 0l The B&R Quality Engineering group is also responsible for 11 2i preparation of a vendor inspection plan for use by B&R j 31 i 4l Vendor Surveillance which identifies the inspection character-5l 6 istics to be v'erified and the frequency of inspection trips {i 9 to the vendor shop for in process inspections. 0 1l l 1 1
1
. l 2
3 l 4 I 56 It should also be noted that prior to the award of a 6 , contract, the vendor's QA Program is reviewed by B&R's 7 8 9 auditing section to assure the vendor has a QA program which 0 is in compliance and consistent with our requirements. The 2 vend r's QA pr gram is audited on an annual basis to assure 3 I that it is properly maintai ed. .6 EL&P performs implementation reviews of B&R vendor ?/ r .5 surveillance and audits to assure that B&R is adhering to .9 l0 requirements and to provide the basis for programmatic is lI direction to B&R. Q. 15 What are the functions of the B&R Site Audit and Corporate Audit groups? 17 A. 15 The B&R Site Audit group performs regular on-site 13 19 audits of B&R procedures and activities as part of the B&R 10 31 audit program to meet the requirements of Criterion XVIII of 32 33 Appendix B. During 1981 this group is scheduled to perform 34 gg approximately 40 such audits to provide feedback to manage-16 ment on the adequacy of implementation of the QA program and 37 38 procedures. The B&R Project QA Manager uses the reports of 39 40 the Site Audit group to identify problems or potential il 42 problems. The B&R Corporate Audit group pr.rforms a similar 43 44 l function, in that it observes work being performed and 45 '. reviews records to verify the implementation of the B&R QA l 46 ; program, but its scope is broader, in that its audits are not restricted to on-site activities. The Corporate Audit
}G }
51
~
l L L 3i i, - i, group periodically audits each element of the B&R QA program, i! T including the Houston based engineering and vendor surveil-3
)- lance activities. Reports of the Corporate Audit group are )
sent to B&R executive management and to HL&P, and are an
)
important tool in assessing the effectiveness of the B&R QA {
} program.
2 i Q. 16 How does EL&P audit its own QA program? 7. I A. 16 There is a section in HL&P's Corporate QA group
) ) in Houston which performs audits of the B&R and HL&P QA t
{ programs. The audit section observes work in progress and 3
; reviews records to determine the effectiveness of the QA 5 program. At times it participates in audits along with B&R 3
7 audit personnel and at other times it conducts its own 3
) audits. The HL&P audits compare the performance observed 3
L and the records reviewed to Project procedures, licensing 7 i j ' commitments, NRC requirements and other applicable standards. 4 3; HL&P audits cover the activities I supervise as STP QA 2 2 Manager, so I know fr m personal experience that they do a 7 3 thorough job.
)
3: Copies of HL&P and B&R audit reports are distributed to L 2 me, to EL&P executive management and to the manager directly 3< g, responsible for the activities addressed in the audit report. , 5 Q. 17 Describe the manpower levels of HL&P's OA staff i l ;' ' I for sTP. 3: [ ] l 1 'i
1 2 3 4 5 A. 17 The size of the site QA staff has been increased 6 7 considerably. In Nove=ber of 1979, there were (excluding 3 9 clerical) seventeen (17) QA persons assigned to the South 0 1 Texas Project Site. The 17 persons represented 83 man-years experience in QA and 148 =an-years in nuclear power activi-
.'2 d =
ties. By March of 1981, the staff (excluding clerical) f, increased to 43 persons representing 413 =an-years experi-
.i .5 ence in GA and 325 =an-years nuclear experience. Of the n ..~
c current staff of 43 persons, 13 have degrees. As a group,
~
the staff has an average experience of 9.6 years in QA and
, i.5 years in nuclear power.
3 Several ad=inistrative actions have been taken to
.=
1 increase the staff both quantitatively and qualitatively. s 9 These actions included retaining consultants who specialize 0
' ir finding professional and technical personnel and increas-s 3 ing the starting level salaries in order to attract = ore 4
e experienced personnel. l Q. 18 In developing its QA program, has EL&P utilized i - C l infornation concerning the staffing levels and QA organiza-9 ! O tiens of other utilities? 2 A. 18 Yes. In 1974 and 1975 infor=ation was gathered a 4 through the Edison Electric Institute (EEI) QA Task Force I =
~
l about staffing levels and QA crganization structures of a i nu=her of utilities, including Pacific Gas and Electric, ! o ! Florida Power & Light, Cc==cnwealth Edison, Duke Power, ! O 1 , f a
l 1 1 1 i l 2. 3l 4 5l Arkansas Power & Light, and Portland General Electric Company. i 6I 7! Subsequent to our studies of 1975, we continued to evaluate 8: 9 information on QA organizations obtained through the EEI QA 0I 'y ; Task Force and other contacts in the industry. From 1974
- 2 through 1979, Mr. Barker, HL&P's Project Manager, and I
.3 j attended EEI QA Task Force meetings. In fact, during 1974 .6 and 1975 Mr. Barker was part of the Subcommittee on Organi- .7 . .5 !
=ation of the EEI QA Task Force.
.9 gg Q. 19 Does the QA Program for STP meet the requirements et (( of Appendix B to 10 CFR Part 50? A. 19 'les, it does. I have evaluated the STP QA . ~e l3 Program (including both the HL&P and B&R portions) against !6 !7 l the 18 criteria of Appendix B, and am assured that the !S !9 program fully satisfies each of those criteria. On October 31, 10 [L 1980, we submitted to the NRC a description of the current 12
- 3 STP QA Program which was recently revised in the April 22, 14 !
- g i 1981 submittal. The revised description summarizes how the 16l -
program satisfies each of the 18 criteria. I supervised the le ; IS ! preparation of that description. Preparing that document 19 > 10 ! required us to review how the STP QA program was functioning il ' '2-and how it compares to Appendix B and the various Regulatory i3
- .g i Guides and industry standards that further interpret Appendix i5 !
B. I am fully > satisfied that our program fully complies i6l with the applicable requirements. is ; 10 , il } t 32-
l L, 2 . 3, , 4 5 Q. 20 Has that been true of the STP QA program in the 6, 7i past? 8 9, A. 20 Yes, it has. In originally defining the QA 0 y Program for STP, HL&P addressed each of the 18 requirements of Appendix B. EL&P made sure that both the HL&P and the 4 B&R QA programs fully satisfied the NRC requirements in the 6 various regulatory guides referenced in the Preliminary 7i 5' Safety Analysis Report. As the Project has progressed, c. O there have been a number of modifications to the QA program. 9 j Those changes have further strengthened a program that 3 already met NRC requirements. 3 Q. 21 Is there reason to believe that the QA program e 7 is being properly implemented? S, 9 A. 21 The NRC investigation that formed the basis for 0 1 the Show Cause Order found a number of instances of noncompli-n
} ance with project procedures, that is, instances of inadequate 4- implementation of the QA program. We have worked hard over 3
6 7; - the past year to strengthen our QA management of the Project, S' our administrative controls and the Project staff of both l 9 l 0i HL&P and B&R to improve the implementation of the QA program. 1 2 The changes EL&P and B&R have made in personnel, staffing, 3
. .g , organization and procedures are described in detail in my 5i subsequent testimony and that of Mr. Oprea and in the testi- ;6 mony of Dr. Broom and Mr. Vurpillat. We have succeeded in .'8 I 9 '
bringing about substantial improvements, which provide
'o i l Il
[
1 2 3 4 5 reasonable assurance that the QA program will be implemented 6 7 properly. 3 9 0 1 2 3
$ T.Eudson:11:D 7
I 0 1 2 0 4 5 5 7 3 9 0 2 3 4 5 6 7 S 9 0 1 2 3 4 5 6 ' 7 8-9 0 l
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