ML19343D404
| ML19343D404 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/27/1981 |
| From: | Broom K, Vurpillat R HOUSTON LIGHTING & POWER CO. |
| To: | |
| References | |
| ISSUANCES-OL, NUDOCS 8105040417 | |
| Download: ML19343D404 (56) | |
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7! 3l UNITED STATES OF AMERICA 9i NUCLEAR REGULATORY COMMISSION LOl BEFORE THE ATOMIC SAFETY AND LICENSING BOARD L3 L4 In the Matter cf: 5 LC 5 - L6 HOUSTON LIGHTING & POWER S Docket Nos. 50-4980L L7 i COMPANY, ET AL. 5 50-4990L LF ! 5 (9 l (South Texas Pr'oject, 5 Units 1 & 2) 20 5 5 21 l 22 , 13 l TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, E_T_ AL. 16 . og 17 ! IS l DR. KNOX M. BROOM, JR. 29 l MR. RAYMOND J. VURPILLAT 10 i 11 ! ON 12l 33 , B&R MANAGEMENT AND STP QA PROGRAM 14! lb ** u
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l 3! UNITED STATES OF AMERICA l 4I ' NUCLEAR REGULATORY COMMISSION 5: I 6l 7i BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 8l 9
.0 In the Matter of: 5 i HOUSTON LIGHTING & POWER Docket Nos. 50-4980r, *2 l COMPANY, ET AL. 5 50-4990).
3; 5 4I (South Texas Project, 5
.3 i Units 1 & 2) 5
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,9 { TESTIMONY OF DR. KNOX M. BROOM, JR.
- 0 , AND RAYMOND J. VURPILLAT ON B&R
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MANAGEMENT AND STP QA PROGRAM
,I : }* I Q. 1 State your names.
I4 i A. 1 Knox M. Broom, Jr. (KMB) and Raymond J. Vurnillat
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(RJV). S' Q. 2 Dr. Broom and Mr. Vurpillat, by whom are you 9 10 i employed? - 11 : 12 l A. 2 (KM3, RJV): Brown & Root, Inc. (B&R) Q. 3 Dr. Broom, what is your position and what are j5l
.6 your current responsibilities?
17)' A. 3 (KMB): I am Senior Vice President of the B&R 18 i ~ 19 ! Power Group and Ass'istant to the Group Vice President. The 10 l il ; Quality Assurance (QA) Department of the Power Group, which
,2 ' ,3 has responsibility for the B&R QA Program for the South i4 e5 Texas Project (STP), reports to me. '6 l Q. 4 Mr. Vurpillat, what is your position and what are 7 .8 your current responsibilities? .9 10 il 1
2 l' l A. 4 (RJV): I am Lhe Manager of the B&R Power Group 3l 4 QA Department and report to Dr. 3 room. I am responsible for 6 the management and direction of all QA Programs implemented 7 I within the B&R Power Group, including the B&R STP QA Program. 9 10 I Q. 5 Dr. Broom, please summarize your professional 11 ! 12 ! qualifications. 13 i 14 - A. 5 (KMB): I have a Ph.D. in chemistry from the 15 i University of Arkansas and a Master of Science Degree from 16 l f the University of Arkansas, where the bulk of my studies 19 I involved nuclear chemistry and physica. I have a BA degree 20 ! 21 l from the University of Southern Mississippi where I majored 22 : 23 ! in chemistry and mathematics. I have worked in nuclear 24 i 25 ' power and nuclear power research for more than 17 years. I 26 j 27 l am a member of the American Nuclear Society, American Chemical 28 i 29 l Society, American Society for Quality Control, and other 30 - professional organizations. I am a registered nuclear 33 l 32 engineer in the state of California. 34 Q. 6 When did you join B&R? 35 36 , A. 6 (KMB): I joined B&R in August of 1972. 37 I 38 i Q. 7 What did you do prior to joining B&R? 39 40 A. 7 (KMB): My position immediately preceeding my 41 42 ; joining B&R was Manager of Nuclear Activities for Middle 43 44 S uth Services, a subsidiary of Middle South Utilities, Inc. 45 46 There, I assisted in the project management of five nuclear 4 4 units at the operating companies of the Middle South System, 49 i 50 l 51 L
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1{ 2 3 and a part of my responsibilities included helping establish 4 5,i the early QA/QC Programs which were required for these 6l nuclear power projects. Prior to my work at Middle South 7 8 Services, I worked for one year at the Atomic Energy Commis-9t 10 l sion, where I administered research contracts involving 11 i fuels and materials development pertaining to nuclear power. 12
' l ~3 14 l Prior to that, I was employed by Atomics International, a 15 16 subsidiary of North American Rockwell, where I was involved in research work pertaining to nuclear reactors.
19 i Q. 8 Describe the positions you have held with B&R and 20 ! 21 ! give approximate dates. 22 ' 23 , A. 8 (KMB): On joining B&R in 1972, I worked for one 24 i 25 - year in Business Development following which I transferred 26 1 27 j to the Power Engineering Department where I was responsible 28 1 29 ) for Nuclear Licensing and QA. In June of 1975, the Power f Group was formed, and shortly thereafter, my responsibility 32 33 for the QA Department was transferred to report directly to 34 the Group Vice President for Power. I was promoted to Vice 35 36 I . President of Power Engineering in December 1976. My responsi-37 38 bilities from June of 1975 until June of 1979 continued in 39 40 the engineering area. In June oi 1979, I was made Assistant 4~1 4 j to the Group Vice President of Power Group. In this position, 43 ! 44 the QA Department again reported directly to me and the j Group Vice President. In summary, my responsibilities with 47 48 [ regard to the B&R QA Department for the Power Group began in 49 '! 50 l 51 l I l l . v il 1! 2J 3j 1973 and continued through the fonnative stages of our l 4l 5j program for the STP until a period of approximately six 6l months before the construction permits were issued. Then, I ' 7! 8! assumed responsibility for the QA Department again in the 9l 1 l 10 i summer of 1979, and the QA Department has continued to l 11 ! 12 l report to me since that time. 13 l 14 Q. 9 Mr. Vurpillat, when did you join B&R? 15 ! 16 l A. 9 (RJV): I joined B&R in August of 1980 in my 17 i gg ; present position. 1 9 '. 30 t Q. 10 Please summarize your professional qualifications 21 l and experience. 22 ; 23 A. 10 (RJV): I have a Bachelor of Science degree from 24 ! 25 ; Purdue University. I am a Registered Professional Engineer 25 1 27 I sPE) in Indiana and California. I am also a member of the 28 i 39 l American Society for Quality Control, and a member of various 30 ' 3g l American Concrete Institute (ACI) and American Society of 4 32 33 Mechanical Engineers (ASME) committees. Prior to joining 34 35 B&R, I spent eight years as the district manager for Pittsburgh 36 Testing Laboratory where I was responsible for planning and 37 38 l supervision of all phases of inspection and testing functions 39 i 40 related to medium to large construction projects; four years 41 42 j as Director of Quality Control (QC) for the Warner Company, 43 44 a construction materials company, where I was responsible 45 46 f r attaining'and maintaining the quality of concrete materials and ready mixed concrete production; one year as a partner 49 50 51 l
1 2 3 l" in a construction business involved primarily in concrete construction related to medium-sized private and commercial 6l projects; and twelve and one-half years as Assistant QA 7l 8i Manager for United Engineers and Constructors where I was 9l 10 l involved in the planning, management, and supervision of QA 11 l 12 i Programs related to design and/or construction of 16 commer-13 ' 14 cial nuclear power plants, and QA planning related to 7 15 ' ther nuclear plants that never reached the construction 16 { f7g { permit stage. I was also involved in the same functions 19 related to many non-nuclear projects including more than 10 20 21 ! fossil-fueled power plants. 22 ' 23 ' Q. 11 Dr. Broom and Mr. Vurpillat, please describe the 24 ' 25 ' purpose of your testimony. 26 ; 27 l A. 11 (KMB, RJV): The purpose of our testimony is to 28 ' 29 , describe the B&R organization, the development of the B&R QA 30 ' 31 i Program for STP, the management involvement in the STP QA 32 ' Program, and the responses of B&R to the NRC enforcement 33 34 actions against STP. 35 i 36 ' Q. 12 Dr. Broom, briefly describe the history and 37 38 l organizational structure of B&R. 39 i 40 l A 12 (KMB): B&R is a subsidiary of Halliburton, Inc. 41 l 42 ! and is one of the world's largest engineering and construc-43 i 44 i tion firms offering its services to a broad spectrum of 45 46 i industries including power, petroleum and chemicals, marine, 47 i manufacturing, forest products, mining, heavy civil, and 48 49 50 51 i l'; 2; I 3 others. Currently, B&R employs more than 70,000 people. In 4! 5 its more than 60 year history, B&R has performed engineering, 6[ constraction, and project management services on a wide 7I 8I variety of projects worldwide. g These projects have ranged 0 y in size from small local maintenance services to multi-billion 2 dollar grass roots projects of many types. 4' B&R is organized into industry groups, each headed by a a . 6 senior executive who reports to the President and Senior 7l 5' Executive Vice President. The group executives, the President, 9; O and the Senior Executive Vice President form the Operating 9 j Committee of the company which meets regularly to establish 3 corporate policy and review the company's performance and 5 planning. Attachment No. 1 shows this organizational 6' 7; structure of B&R. 8 9: The B&R industry group that is directly responsible for 0< 1; the STP is the Power 1roup, which is headed by W. M. Rice, 2' 3 Group Vice President. This group performs engineering and I 4 5 construction of power generation projects for many utility 6 and industrial clients. To date, the Power Group has per-formed engineering,and/or construction activities for over 0l 100 fossil or nuclear power units (with over 75 units in 1! 2l operation) consisting of more than 40,000 MWE of power 3i 4 I generation. The organization of B&R Power Group is shown in 5 Attachment No. 2. The primary elements of this organization 6i are engineering, construction, operations (which include 9 i 0' 1 I i Ii 2, l 3l project management) and QA--all which report separately and 4l 5! independently to Power Group Management. 6i 7i our compeny is affected by numerous government laws and 8i 9 regulations which apply to various areas of our business. O y We have many formal procedures which are followed .to ensure 2 compliance with these laws and regulations. f
! Examples of 3 i ,
4 these are our system of procedures for OSHA, financial 6! reporting, EEOC, and, of course, QA. These systems provide 7i gi for internal audits, as well as audits by outside agencies, 9! Oi to verify compliance. 1 jj Q. 13 What is B&R's prior experience with large scale 3' construction projects? 4i 5' A. 13 (KMB): B&R has performed engineering, construc-6 c. 7i . tion, and project management services on many large scale 3! 9l projects. Included have been many projects for the U. S. O! 1j Government, Corps of Engineers, Department of Defense, NASA, 2-3; and other agencies which have required compliance with i o, exacting codes, standards, and military specifications. 6l . Examples of projects we have developed are the manned space-7! 8l craft center in Houston, Texas, minuteman missile installa-9l 0i tions, highways, bridges, dams, airfields, and shipyards to 1! 2i name but a few. 3
- 4 A wide variety of large scale industrial projects 5
6 completed by B&R include power plants of all types (coal, 7 8i oil, gas, nuclear, and hydro-electric), refineries, pipelines, 9! 0[ ll i l i 1l l 2 ' 3 offshore oil and gas platforms, papermills, mines and smelters, 4 and petro-chemical complexes. 5! 6 Q. 14 How does B&R organize and manage a large project? 9f A. 14 (KMB): For most large projects B&R utilizes a 91 10 l Project Management System and a Project Task Force concept. 11 ! 12 l A Project Manager is given full authority and responsibility 13 14 i for execution of a given contract and all of the necessary 15 16 l resources--manpower and material--are assigned to the Project 17 i gg i Manager as long as required for the project. We assign 19 people and dedicate the required office space for the per-21 l formance of the home office functions--engineering, . pro-32 ' 23 ! curement. scheduling, cost control, administration--and at 24 ' 25 ; the project site, we assign the construction forces and 26 i 27 l equipment required for the project. The Project Manager is 28 l 29 l given full control over these resources. Similarly, on i 30 31 l nuclear power projects, we dedicate the necessary QA personnel 2 3 as a project team under the direction of a Project QA Manager 34 ll 35 1 who reports independently from the Project Manager to Power 36 I Group Management. 37 38 on all major projects, B&R proyides frequent executive 39 40 contacts between the client management and B&R management to 41 42 ,l assure our client of our interest in and attention to his 43 ' 44 project and to provide an overview of the status and progress 45 46 , f ur w rk. . 47 ! ; 48 ! 49 50 51 1
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1 2 3 Q. 15 How cid B&R first become involved in the nuclear-~~ ~ 4 field? What were its qualifications to design and construct 5 6 a nuclear power plant? 7 8 A. 15 (KM3): B&R began its efforts to enter the field 9 1C l of nuclear power in the mid-1960's by recruiting employees 11 ! experienced in the nuclear field, and in 1967, received its 12 13 l 14 first contract frot Carolina Power & Light Company to perform 15 ' construction, field procurement, and related quality assurance 16 l 17 g activities for the Brunswick Steam Electric Station. This 19 I project consisted of two-821 BWR units located at Fouthport, 20 ' 21 ! North Carolina. In 1973, as the Brunswick Project was 22 : 23 ' nearing completion, B&R was awarded a contract of similar 24 ' 25 scope by Texas Utilities, Inc. for its Comanche Peak Steam 26 , 27 l Electric Station consisting of two-ll50 Mw PWR units located 28 ! 29 ! near Granbury, Texas. . 30 ! 31 These two projects established a sound base in construc-32 33 tion and QA activities associated with nuclear power plants. 34 However, B&R was also interested in performing nuclear 35 36 plant design and engineering. Through the latter part of 37 38 l the 1960's, recruiting efforts continued to obtain experienced 39 i 40 l personnel in the nuclear design field and in November 1970, 41 l 42 j B&R purchased an equity position in the NUS Corporation, a 43 44 company highly respected for engineering and consulting 6 activities related to nuclear power. By 1973, we had 47 I assembled a good nucleus of design personnel and with nur 48 49 50 51 t I ( :
1 2 3 association with NUS and access to its personnel, were 4 prepared to provide design engineering services for a nuclear 5 ;, 6 power plant project. In that year, we initiated work on STP 7 8 for the design, procurement, construction, and related QA 9 ! 10 activities for the STP. 11 12 Q. 16 At the time you became involved in B&R's QA 13 14 Program for STP, how was the program organized? 15 i 16 ; A. 16 (KMB): Originally, when the STP PSAR was prepared f.f.,l in 1974, the QA Department reported to the Engineering 19 I Department and was separate from the Construction Department. 3J I 21 l The internal organization of the QA Department followed in 22 . 23 ! the traditional lines of quality engineering, inspection, 24 i 25 services to support the various organizations, a vendor 26 27 i surveillance section, and an auditing section. 28 l 29 : Prior to the issuance of the construction permits for 30 ! 3g i STP, the B&R Power Group was formed under which engineering 32 33 ;l and construction both reported to one group executive. The 34 ! QA organization was transferred to report directly to the 35 36 head of the Power Group, thereby being entirely independent 37 38 from the engineering and construction organizations. That 39 i 40 organizational arrangement has continued to the present. 41 i 42 j Q. 17 was this organization in compliance with applicable 43 i 44 industry practices and NRC requirements? A. 17 (KMB): Yes, the QA Program, including a descrip- l 47 tion of the organization, was described in the PSAR for the 48 49 50 51 i li 2 '" 3 STP and was thoroughly reviewed by the NRC as well as HL&P 4 5 and found to be acceptable as evidenced by the approval of 6 this program in the NRC Safety Evaluation Report and the 7 8 issuance of the construction permits for the STP in December 9 10 , 1975. The B&R QA organization is very similar to that which 11 i 12 l is found in many engineering and construction companies 13 ! 14 ' engaged in nuclear power plant activities. 15 16 Q. 18 Was this organization similar tc those used on 17 i other projects with which you are familiar? gi 19 I A. 18 (KMB): Yes, the STP QA Program provided by B&R 20 1 21 ! is entirely analogous to that found on most nuclear projects. 22 : 23 ! Details of the organizational structure vary from project to 24 i 35 project, but no significant differences exist of which I am 26 ' 27 { aware. From the outset, the QA organization for STP has 38 i 29 l provided QA/QC services for design, procurement, and construc-3 3 tion activities supplied by B&R, with HL&P providing oversight 32 33 . surveillance activities in all of the corresponding 34 areas. This arrangement is quite common. 35 36 Q. 19 At the time you first became involved in the QA 37 38 Program at B&R, what was B&R's attitude toward quality? 39 40 A. 19 (KMB): I first became involved in nuclear QA at 41 42 l B&R in 1974 in conjunction with B&R's construction activities 43 44 at the Brunswick Steam Electric Station for Carolina Power & Light Company. This project was underway when the original 47 QA/QC criteria (10 CFR 50, Appendix B) were issued which 48 { 49 50 i 51 I 1 1 i l' 2 3 required a formal QA Program in compliance with these regula- , 4l 5 tions. A program had been established in compliance with 6 7 these regulations and was in effect at the Brunswick project. 3 From my first involvement, I believe that B&R's management 10 had the proper attitude concerning nuclear QA/QC requirements, 11 : 12 l and that our project personnel generally reflected this same 13 I ! i 14 attitude. l 15 l 16 l Management's commitment to the importance of QA/QC on 17 i gg j nuclear projects was expressed on many occasions to its 19 20 ,{ personnel both at the Brunswick project, and at the Comanche 21 ! Peak and the South Texas Projects, which were in the early 22 : 23 l planning stages. These expressions were designed to impress 24 ! 25 , upon project personnel that nuclear QA requirements are 26 ! 27 j especially stringent and should be fully complied with. 28 l i 29 Furthermore, in that period of the history of the nuclear 30 31 , industry, the QA/QC requirements were evolving quite rapidly. 32 We encountered problems in adding requirements in mid-stream 34 35 and ensuring that personnel met these additional requirements. 36 ' As a result, B&R management was directly involved in these 37 38 projects and aware of the importance of an adequate QA/QC 39 40 program. As an example of B&R management's early recognition 41 42 , of the importance of the nuclear QA/QC project requirements, 43 44 a policy was established for STP in 1976 under which all new 45 46 B&R employees,at a nuclear project received a formal nuclear 4 QA orientation program. 4 49 50 51
- l 1i 2h Q. 20 Describe the senior B&R management activities 3f 4!
5 which evidenced their commitment to QA/QC in nuclear projects. 6 A. 20 The senior management of B&R has been (KMB): 7 8I involved in our QA activities from my earliest knowledge of 9i 10 our projects. At the Brunswick station, our management, 11 12 including senior officers and an executive vice president, 13 14 ; attended meetings frequently with the client at the site to 15 i 16 l discuss specifically the status of our QA Program and the f7g steps being taken to ensure that all requirements were met 19 prior to the operating license. 20 i 21 ! In october of 1973, the Executive Vice President of B&R 22 , 23 i established the QA Management Review Board (QAMRB) which was 24 i 25 : composed of senior management executives of B&R in order to 26 l 27 j provide an oversight of our QA programs for nuclear as well 28 i 29 ; as fossil power plant projects and to report periodically to 30 ' 3g j the top management of the Company. The membership of this 32 Board presently includes the Group Vice President of Power, 33l! 34 ' 35 all of the senior officers in the Power Group, a representa-36 tive from our Procurement Group and the Power Group QA 37 38 Manager. This Board has met regularly since its establishment 39 ! 40 to receive reports from the QA Manager concerning the status 41 l l 42 l of our QA program. In addition to these periodic meetings, 43 i 44 the QAMRB members regularly receive a compendium of significant 5 QA documents as an additional means of staying abreast of QA 47 Program activities. - 48 49 50 51 1 l , ! I 1 [ i - I
1 ll 2" 3 An additional and important responsibility of the QAMRB 4 ~ has been an annual QA/QC Program review, that is performed 6I for the QANRB by B&R management personnel with the assistance 7 8 of cutside consultants, Management Analysis company and 9 10 Southwest Research Institute. The purpose of this review is i 11 , 12 l to determine the effectiveness of the overall QA Program in 13 ! 14 ' the B&R Power Group. These reviews have evaluated the B&R 6f Power Group QA Program including the STP. The reviews are f generally broken down according to the 18 QA criteria of 10 19 i CFR 50, Appendix B, and are used by senior B&R executives to 20 21 l closely monitor areas of the B&R QA Program which require 22 i 23 ! special attention or corrective action. The results of each 24 ! 25 ; of these reviews are carefully evaluated and fully discussed 26 i 27 l at the QAMRB meetings; and for those findings where corrective 28 1 29 j action is determined to be appropriate, management makes 30 ' assignments to the affected B&R organizations and requires 32 written responses describing those corrective actions. 33 34 In addition, since the beginning of the project, the 35 36 . Operating Committee of B&R has received an annual review of 37 , 38 j the QA Program associated with the STP presented by the QA 39 40 Manager of the Power Group. Beginning in September 1980, 41 42 j the Operating Committee has received a briefing on the STP 43 1 44 QA program monthly. Such activities demonstrate that the 5 6 senior management of B&R is properly involved in the project 47 to ensure that sufficient resources are provided for the 48 49 conduct of the project in a timely fashion. 50 51 l I L 2" 3 Management policy concerning our dedication to full 4 5 compliance of all quality requirements has been communicated 6 to project personnel through written and verbal communications. 7 8 For example, we have had letters signed by senior company 9 10 officials throughout the course of the Project stating the 11 12 company policy of full compliance of all QA requirements, 13 ! 14 and these letters have been posted in visible locations at 15 ' 16 f the site and in the Houston offices and have been incorporated ) in the Project QA manuals. There have also been presentations fl 19 by senior officials of the B&R Power Group to Project personnel 20 ! 21 l stating our management policy. For example, in the summer 22 t 23 , of 1979, J. G. Munisteri, the Group Vice President of the 24 l 25 - Power Division, spoke to all QA/QC personnel and construction 26 l supervision at the project site emphasizing our full commit-27 i 28 l 29 l ment to strict compliance with all QA requirements. 30 ' Finally, since the inception of the project, senior B&R 31 l 32 ' management officials have made frequent visits to the STP 33 34 site and have met and discussed project activities with a 35 l 36 ! . Variety of Project personnel. This has been in recognition 37 ! 38 l of the importance of direct Project visibility and involve-39 40 ment by senior B&R management. In late 1979 and early 1980, 41 l 42 with the increased concerns raised about management of the 43 44 B&R QA Program for STP, senior management visits to the site 5 have been more frequent. In my own case, since the beginning 47 of 1980, I have spent a minimum of two to three days a month 48 49 at the site. 50 51
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l! 2" 3 Q. 21 Please give some other examples of specific 4 5 a tions taken by B&R Senior Management which indicated a 6 commitment to the STP Quality Assurance Program. 7 3i A. 21 (KMB): One example that cames to mind is a 9 10 meeting held in early 1978 at which M. M. Fitch, Senior Vice 11 12 President, Power Construction, met at the STP site with key 13 14 I construction and QA/QC supervisory personnel. At this 15 i 16 l meeting, Mr. Fitch emphasized senior management's requirement 17 i yg j that all Project personnel fully comply with Project quality 13 requirements. He further emphasized the need for professional-20 ! 21 ism in Construction /QC relationships. 22l; 23 l Another example of Senior Management's involvement in 24 l 25 : assuring that friction between Construction and QA was 26 1 27 j minimized occurred in early 1979, wi:en J. C. Bazor, the then 28 ! 29 : newly appointed Vice President of Power Construction, held a 30 ' 31 l meeting at the site with key supervisory personnel. At this 32 meeting. Mr. Bazor reaffirmed the B&R management philosophy 34 that B&R Management would not tolerate any circumstance in 35 36 ' which a B&R Construction employee acted unprofessionally, 37 38 ! and that Management would not hesitat to dismiss any employee 39 40 , violating tnis policy. 41 i 42 l Q. 22 Please give some examples of steps taken by QA 43 44 Management prior to the NRC Show Cause Order which reflect 45 46 .: QA Managementis effort to maintain an effective, and well-4 ! motivated Project QA/QC organization. 4 49 l l 50 l 51
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1 2 A. 22 (KMB): 3l In the area of organization, the project 4 QA organization was originally conceived along traditional 6l lines that provided for QC inspection, ver. dor surveillance, 7 8 and support activities. However, this organization has not 10 ; been static through the course of the project. 11 ! 12 I In 1976, we recognized the need for increased quality 13 ! 14 i engineering support for QC Inspectors, and technically 15 i competent discipline engineers were added at the site. In 16 { f 1978, a full-time vendor surveillance representative was 19 I located at the site to improve coordination between vendor 20 21 surveillance and site operations. In 1978, we added full-time 22 23 ! schedulers to the Project QA organization to assist in 24 ! 25 j planning and scheduling manpower, training and procedure 26 ; 27 ; requirements. In 1978, we reassigned Quality Engineers and 28 l gg j QC Inspectors on the basis of plant areas rather than technical 30 ' 3g j disciplines in order to parallel the Construction organization 32 ! 33 and provide better coordination and mutual understanding. 34 In 1979, regional vendor surveillance offices were established 35 36 ! . to provide closer control of suppliers. Finally, since the 37 ' 38 beginning of the Project, QA Management has recognized the 39 40 importance of adequately staffing the Project with experienced 41 ! 42 l personnel and has conducted an ongoing nationwide recruiting 43 44 campaign. As a result, our QA Department manpower level has 45 46 in reased fr m less than 100 in 1975, to more than 500 at 47 present. 48 { 49 ' 50 51 l
l L; 2 3 In the area of QA employee relations, significant improvements were initiated by QA Department Management in 6' 1979 and early 1980 in recognition of the importance of 7 8 regular management meetings, adequate pay and benefits, and 9 10 employee recognition, including monitoring and responding to 11 , 12 j individual employee concerns arising in the course of the 1 143 l! Project. Frequent meetings were held with Project personnel 9 {3 l6l and QA Management to communicate policies and to get feedback from employees. Although agreement was not always reached f7g 19 l on each employee complaint, all cases were reviewed and 20 ' 21 i evaluated. 22 ! 23 i Through the initiative of QA management, as the Project 24 , 25 i progressed, better working conditions were created by provid-26 i 27 l ing air conditioned field offices, additional field radios . 28 t 29 , and trucks, increased relocation benefits, overtime pay for 30 3g salaried personnel, better QA tools, special visible reccgni-32 ! tion of QA supervisors, and improved pay levels and policies. 33 34 offsite recreational activities and civic projects were 35 36 sponsored and encouraged such as softball games and community 37 38 ! clean-up projects. Written communication was provided 39 I 40 through information memos and bulletins, and company publi-41 42 ; cations such as the Brownline, Brown-Newser, and Brownbuilder. 43 44 In 1979 as concrete activities accelerated, management instituted a , requirement that a minimum of 24 hours be set 47 ! aside for each concrete preplacement inspection (or longer 48 49 1
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l 1l 2 3 if required) to preclude any construction activities such as personnel and trucks standing by that could create pressure 6 on the Inspectors to hurry their work to release a pour. 7 8 Of course, normal management functions were performed I 9 l 10 l such as regular personnel performance evaluations. Inter- ) 11 ' discipline development, reassignment 3, 12 and promotions were l 13 i 14 l encouraged to improve personnel opportunity and growth. 15 16 l Finally, a number of actions were taken to improve 17 ' mutual understanding and reduce friction between Construction g 19 ! and QA personnel. For example, in June 1978, construction 20 1 21 i and inspection procedures were integrated to define and 22 i 23 i clarify operational interfaces, improve planning and schedul-24 , 25 : ing, and promote cooperation. In August 1979, a Task Fcrce 26 ! 27 l was established by Engineering, Construction, and QA to 28 I 29 l clarify the intent of specification terms such as " flat", 30 i
" straight," "no free standing water," and similar items 33 l 32 which require interpretation.
33 In 1977, a weld defect report-34 . ing system was established to improve construction awareness 35 1 36 ' of 'tte nature of welding problems. In 1978, in-process 37 38 j punch lists to note and control actions required prior to 39 40 formal inspection steps were established. These and many 41 i 42 - other actions were taken to facilitate daily operations by 43 44 improved understanding and cooperations. 45 Q. 23 Please give some examples of steps taken by QA 47 Management prior to the NRC Show Cause Order which reflect 4d 49 50 51 1 2 3 QA Management's effort to assure proper QA/QC personnel . 4 training. 5 6 A. 23 (KMB): In the area of personnel training, since 7 8 the inception of the Project, new employees have received a 9 10 presentation relative to orientation for nuclear projects 11 12 which emphasizes the special nature and quality requirements 13 14 l for nuclear projects. All QA personnel also attend overview 15
- 16. l slide / tape presentations relative to nuclear Codes and f Standards and quality records. A study brochure supplements 19 ! these presentations.
20 i 21 ! Since the beginning of the Project numerous diverse 22 ! 23 i in-depth training courses have been presented for construction, 24 i 25 ' Engineering, and QA personnel. In addition to technical 26 27 training, operating procedures and procedural changes were 28 1 29 l c vered. Beginning in 1978, Construction and QA personnel 1 30 37 l attended joint training programs so as to develop common 32 I understanding and interpretations. Opportunities have been 33 l 34 i created for interdiscipline cross training to broaden personnel 35 36 opportunities and flexibility. This training has also 37 38 , encouraged development of less-skilled employees so that as 39 40 performances of entry level Inspectors progressed, they 41 l could achieve higher levels of certification. 42 43 44 Various management training courses by B&R, outside 45 specialists, and video tape / programmed instruction have been 46 i 47 ! presented. Again many of these courses were attended jointly 48 49 ( 50 51 l ! l
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2L 3l by Construction and QA Supervisors so as to improve interrela-4l 5i tionships and understandings. 6j 7l Although training courses were frequent within B&R both 8I 9 ! at the site and in Houston, additional professional develop-0 3 ment was also encouraged by other means. Included were such 7 activities as outside technical training by ACI, ASNT, ASME,
.3 .4 and other outside organiza.tions; membership on technical 2 .6 , committees of national sccieties; attendance at seminars and .7l' .g .9 \
technical conferecces; and participation in the Nuclear 0l Plant Reliability System and the Coordinating Agency for 9i
~l Supplier Evaluations.
3' Q. 24 Describe HL&P's involvement in the development 4' 5 and review of B&R's STP Quality Program. 6i 7i . A. 24 (KMB): B&R's QA Progran for STP is under the
.8 i 9l 0I programmatic direction of HL&P. B&R's QA Program for the 1: STP was initially described in writing as a part of the 2: 1 3l preparation for the STP PSAR. This description was reviewed 4
in detail by HL&P and its comments were resolved to its 6' satisfaction to ensure that B&R's program and HL&P's program 27
)
8i were fully compatib,le. At various times since the develop-9i 0 ment of the original program, modifications to the program l 1 2j concerning various procedures and detailed instructions 23 '
,,g have been made. The QA procedures were submitted to HL&P l56 f r its review and comment prior to implementation. HL&P '7 i8 has performed a surveillance function over all of the B&R QA .9 10 il i
.I L!
26 3l Program activities since initiation of the Project. This 41 5 includes on-site surveillance activities, HL&P vendor sur-6 7 veillance inspection personnel accompanying B&R vendor 8i surveillance inspection personnel on shop inspections, joint 9j participation in audits and, of course, separate and indepen-
.3 '
2l dent audits conducted by HL&P of B&R's QA activities.
.4 Monthly meetings on the QA programs have been held with HL&P
.9 l -
,6 l for virtually the duration of the Project. There is a
.7 i
,gj continuing dialogue on nearly a daily basis between HL&P's
'9! O STP QA Manager and B&R's Project personnel. Audits which 3l are performed by B&R's Audit Group are discussed in exit
.2l
.I j j critiques which HL&P personnel often attend. B&R has invited
. 's
;5 : and HL&P has attended the exit critiques of the NRC's Vendor
;6}
;7 l .
Inspection Branch inspections of B&R's activities.
'S l
;g i, our standard practice at B&R on the STP has been to l0 i
;g keep HL&P fully informed of all activities and problems as they arise on the Project. HL&P has taken a strong leader-f3 f
!4 ship role, as is expected of the Licensee, and has provided 51
- 6 guidance and direction of the entire program through the
;7 l: .
- S l life of the Project.~
HL&P has performed audits of the B&R 9I 0j program by independent auditing groups separate from its STP 1i 2 QA organization since the inception of the Project. These 3
;,g audits have been thorough and have pointed out areas where
'5 i 8 tr program could be improved and the improvements indicated 6
'7 have been impleinented.
18 :
,9 l 0l il 1
1 Q. 25 For the period between the issuance of the l 4 5 construction permit in December 1975, and the NRC's special 6 investigation in late 1979 and early 1980, what is your 1 7I l 8 personal assessment of the QA program for STP? 9 10 A. 25 (KMB): During this period, the B&R QA program 11 12 and the HL&P Company QA program maintained surveillance and 13 ' auditing of the STP activities. 14 A number of deficiencies 15 i 16 i n erning implementation of procedures were discovered. f7 Inspection and surveillance personnel identified many indi-19 ! vidual items of nonconformance, such as components or ma.terials 20 1 21 l which did not precisely meet specification requirements. 22 t 23 ! The deficiencies were corrected, as is evidenced by close-outs 24 i 25 i of nonconformance reports, corrective action requests, and 26 27 audit deficiency reports. 28 i! 29 In my experience, the number of findings and the types 3 f findings are representative of those found en most nuclear 3 32 ' construction projects. B&R and HL&P had identified problem 33 34 areas in which improvements had been made and others in 35 36 which improvements were underway at the time of the NRC 37 , 38 l special investigation. Although you can never be completely 39 40 satisfied with your performance, on balance, I believe the 41 42 QA program for the Project was effective and that areas of 3 4 nonconformance were identified and under control, although 45 46 patterns of nonconformances were not always picked up as 47 promptly as they should have been, especially in the welding 48 49 area. l 50 51 l l 1 1
1 2 3 One area where I believe we might have done a better 4 5 j b is in trending deficiencies as they occurred on the 6 Project. Although informal trending was done, I believe we 7 8i should have had a more formal trending program to document 9l 10 the recurrence of nonconformances. Also, I believe we 11 12 should have provided a more efficient document control and 13 , 14 : retrieval system. Although basically under control, on 15 i 16 ! ceasions it took substantial time to locate and assemble 17 ! tg l documentation. 9! Q. 26 Please comment on the STP problems relating to 21 ! soils, concrete and welding, in light of your answers to the 22 ; 23 ! preceding questions. What do these problems reveal about 24 i . 25 ! the QA program? What do they indicate about the overall 26 l 27 l structural integrity of the plant? 28 l A. 26 29 : A nuclear QA program requires that all defi-30 ciencies or deviations from project requirements be docu-3g 32 ! mented as nonconforming conditions. As I indicated earlier, 33 l 34 35 l many instances of nonconformance have occurred on STP just 36 ! as they occur on any such project. The vast majority of 3e 38 these deficiencies are of little safety significance and are 39 40 corrected quite easily. In other instances, significant 41 i 42 l deficiencies occurred at the Project, and were recognized as 43 1 44 being significant and were reported to the NRC. The voids 45 46 f und in some , complex concrete placements are an example of 4" i such a deficiency. In the placement of concrete in areas of 4f
- 49 I 50 51 I
s l
i 1 l 2 3 extreme rebar congestion, steps were taken to avoid the 4 creation of voids. Unfortunately, due to the configuration l 5I l 6 of embedded steel and rebar, some voids did ocqur. This has l 7 l 8 required additional precautions which have been taken to 9 10 avoid recurrence. .In all cases, these voids were detected 11 12 and have been repaired. This is not an uncommon occurrence I 13 14 l in placing concrete in situations such as I have described. 1j~ t ' Furthermore, it is important not to lose perspective. 17 g The concrete problems we encountered were not atypical and 19 ! the structural strength of our concrete has been found to be 20 ! 21 ! quite acceptable. Similarly, while we have had procedural 22 ! 23 , problems in the soils area - mainly due to misunderstandings 24 ! 25 ! or poor communications - we should not lose sight of the 26 27 findings of our Task Force as to the adequacy of our soil 28 ! 29 compaction work. It is only in the area of welding where we 30 l fell down. We recognize this area of deficiency and are taking steps to repair existing deficient welds and to 32 33 { 34 prevent recurrence of such problems in the future. 35 36 our welding problems at the site were attributable to a 37 38 failure to insure that the many welding and inspection 39 40 procedures we had on paper were fully and properly implemented. 47 > 4j j Our welding program, as set out in those procedures, was in 43 44 accordance with all Codes and standards and, if properly 45 implemented, would have produced uniformly high quality 47 welds. However, we now know that the welding procedures 48 49 50 51
\
1i 2: 3l were not always being fully implemented, and that our 4j 5i Inspectors were unfortunately not always picking up failures 6l 7i in procedural implementation, and were not always performing i 8 g close-enough inspections of the welds themselves to assure
;0 code compliance. While it is unfortunate that these pro-
.2 cedural and inspection deficiencies occurred, it is important
.3
.4 to point out that our QA auditing system did detect the
.5 . '
.6 ; deficiencies and focus attention on the magnitude of the
.7I
,g problem. The audit findings resulted in our stopping all
*9!
,0 safety-related welding in April 1980 pending a comprehensive
,,s i .
{j reassessment and revamping of the welding program.
!3 ' We have taken rigorous steps to assure that all proce-14 ,
!5 ; dures will be fully implerented and that welds will be
!6 i 17 l properly made, and also to assure that when non-compliances 19 1 gg i do occur they will be immediately identified by QA. We have 10 !
. taken steps to control the welding procedures and inspections, gy !
32 33 to retrain and requalify welders, and to recertify inspection I4 personnel to make sure that any deviations from the literal 35l ! interpretation of code requirements are identified as discrep-36{! 37 38 i ancies and the appropriate repairs made. In addition, we have 39 to created the position of STP welding Program Manager and staffed il g2 this position with a highly qualified individual. The Program 13 g4 i Manager is charged with coordinating implementation of all l 45 welding program procedures. Thus, quality welding will be 47 8 48 49 50 l 51
i il 2h 3 assured not only through a tighter QA Program, but also I 4 5 through better control and coordination of welding procedures. 6 In the areas of safety related welding, concrete, and 7 8 backfill, we have assembled special B&R/HL&P task forces, as 9 10 well as panels of experts from outside the Project to exten-11 12 sively investigate the adequacy and structural integrity of l 13 i' 14 the work performed at the Project. Their reports have f concluded that the backfill, as placed, is entirely adequate for the design requirements of this Project, and that in the 19 ! case of concrete, there is no reason to suspect any additional 20 l 21 ' voiding or substandard conditions associated with the struc-22 ' 23 . tural integrity of the concrete beyond those voids in complex 24 25 areas which were identified previously. Further, the repairs 26 27 l which have been made to those areas were found to be satis-28 ! 29 ; factory to ensure the structural integrity of the concrete. 30 3 with regard to welding, our welding program has been strength-32 33 l ened substantially and reinspection and repair of previous 34 ! welding is underway. 35 l 36
- Q. 27 How has EL&P kept itself knowledgeable about STP 37 38 activities?
39 40 A. 27 HL&P kept itself' properly knowledgeable &hout 41 42 all aspects of STP activities by being an integral part of 43 44 the Project organization. The vast amount of correspondence, 45 meeting minutes, and other Project documentation is evidence l 47 48 of this; they indicate daily involvem.ut in the Project in l 49 l 50 51 v
, 1 1l 2"
3 all its aspects. Outside of QA, HL&P personnel are in 4 5 residen e in B&R engineering offices viewing on a day-to-day l 6 basis the engineering work being performed. Since November, 7l 8 1978 more than 90 HL&P employees have been located with our l 9l 10 Project team in our Houston offices. They participate in j 11 12 our meetings and our day-to-day Project activities. They 13 i 14 ' review, comment, approve, and make suggestions about those 15 - 16 l activities. In the construction area, more than 30 HL&P 1 construction personnel are in residence at the site. They 19 participate in meetings on a daily basis at various levels 20 1 21 l of management and supervision. They are fully aware of the 1 22 l ' 23 I status of the work. They participate in the planning and 24 1 25 ! decision making process for the construction of the Project. 26 ! 27 j In the QA area, as I have stated earlier, HL&P is directly 28 1 29 l involved through daily personal conversations, meetings at l 30 ' 31 vari us levels, continuing surveillance activities, auditing 32 33 > l activities, attendance at audit entrance and exit critiques, j 34 I and Project QA meetings between B&R and HL&P. There is a 35 l j 36 ' variety of written correspondence that documents these many 37 38 , activities. EL&P has at least 41 QA personnel at the site. l 39 l 40 Q. 28 When individual physical disputes or other ,! serious site-level employee problems occurred among workers !I 41 l 42 43
. I 44 at the Project, was it usual for B&R Management to be aware 45 46 f such instances and to monitor and participate in the 47 resolution of these matters?
l 48 49 50 l 51 l
i 1i 2 A. 28 (KMB): Serious disputes among workers that rise 4} to the level of physical abuse have been rare on the Project, 5i 6! and Management has made it clear that such behavior will not 8 be tolerated. However, there have been isolated instances 9 10 of disputes as discussed in detail in testimony by Messrs. 11 12 Warnick, Singleton and Wilson. These have been known by 13 ! 14 ) both Houston and site QA Management, which have closely 15 1 16 l m nitored or participated in the resolution of such matters. 17 l 16 This has also been the case with isolated record falsifi-19 cations, such as the PTL incident discussed by Mr. McKay in 20 { 21 ! l his testimony, where Management has been involved to assure 22 23 ! that the responsible individual was immediately terminated 24 ! 25 ' and that the proper followup safety reviews were conducted. 26 27 B&R management will not hesitate to take prompt responsive 28 i 29 action, including termination of employment where appropriate, 3 against employees who management finds have acted unprofession-32 l ally or dishonestly in the performance of their job responsi-33 34 bilities. The termination of Mr. Swayze in 1978 is another 35 36 ' example of a sensitive issue which was closely monitored by 37 38 ' QA Management at the site and in Houston, and other Executive 39 40 B&R Management in Houston, to assure a fair and proper 41 42 resolution of the matter. l 43 l 44 In the case of the altercation between James Marshall 45 46 and Joe Bazea,that took place on June 30, 1977, which is 47 described in Messrs. Singleton and Wilson's testimony, site 48 49 50 51
~
I 1i 2 3j QA Management was fully aware of, and involved in, the 4 5 resolution of the matter, and Houston QA Management was kept 0 fully informed, from the time of the incident to final 7 1 8 resolution. This was considered to be a regrettable but ! 9 l 10 isolated incident that was properly handled by Site Management. 11 i 12 Similarly, in the case of the physical exchange between 13 14 ; Jerry Lacey and Gary May on March 7, 1979, swift action was , l~ gj ll taken by site QA and Construction Management, and senior Houston QA Management closely followed the matter to assure f7g 19 that appropriate steps were taken at the site to react to 20 ! 21 the physical exchange. 22 23 ! When an' allegation was made against Mr. Swayze in 1978 24}l 25 that he had solicited a bribe from a Construction Foreman, 26 1 27 j this allegation was treated with the utmost seriousness by 23 29 site and Houston Management. A comprehensive il7estigation 30 was undertaken, including interviews with employees who 32 I worked closely with the individuals involved. Senior officers, 23 34 including the B&R Power Group Vice President, the Power 35 36 Group Senior construction Manager, the Power Group QA Manager, 37 38 , and a representative from the B&R General Counsel's Office, 39 l 40 were directly involved in investigating the bribe allegation, 41 42 j in light of the seriousness and sensitivity of the charge. 43 ' 44 It was this Senior level management group that decided to l 5 terminate Mr. swayze after reviewing. employee statements and 1 47 in consideration of Mr. Swayze's refusal to fully cooperate 48 49 50 51 I
I 1{ , 2 in the investigation or to give a sworn statement in response 4 to the charge. 5 6 Q. 29 Was there concern within B&R management about 7 8 allegations from Mr. Dan Swayze, that QC inspectors were 9L 10 being subjected to intimidation and harassment by construction 11 personnel and were not performing their required inspections? 12 13 { 14 i What was done to investigate the situation? What were the f results and findings of these investigations? 17 A. 29 lE l (KMB): It was not until March 1979 that B&R 19 Management first became aware of allegations by Mr. Swayze 20 1 21 l that certain Civil QC Inspectors were involved in continuous 22 ' 23 : card games and failed to perform required inspections in 24 ! 1977. Statements to this effect were first made in a deposi-25 { 26 27 { tion of Mr. Swayze taken on March 2, 1979, in conjunction 28 29 with a lawsuit initiated by Mr. Swayze against B&R. The 30 lawsuit, which related to Mr. Swayze's terminaticn from B&R 31 1l 32 I on August 27, 1978, was dismissed with prejudice when Mr. 33 34 Swayze refused to sign his deposition. Allegations about 35 36 ( , the card games also were made in interviews with Mr. Swayze 37 1 38 which appeared on national television in October, 1979 and 39 40 then again in May, 1980. Finally, Mr. Swayze made statements 41 1 42 about the alleged card games in his deposition in this 43 44 proceeding taken on June 19, 1980. 45 46 There are numerous inconsistencies in those various 47 statements by Mr. Swayze with respect to the time frame in 48 49 50 51 l l
~
i 1 ll l 2 3 which these card games were alleged to have occurred, the 4l 5 identities of the alleged card players, the underlying 6 reasons for the card games, the percentage of time spent 7 8i each day playing cards, and the amount of inspection performed 9 10 by the alleged card players. 11 ; 12 } Nonetheless, B&R and the NRC investigated Mr. Swayze's 13 l 14 ' allegations regarding card games and non-inspections. After 15 i Mr. Swayze's first allegation in March 1979, B&R QA Management 16 { 17 i gg interviewed the QC Inspectors who had been named by Mr. 19 Swayze. Although the Inspectors did play cards during their 20 t 21 lunch hour and in other periods of low construction activity 22 , 23 ! during late 1976 and early 1977, none of the Inspectors had 24 ; 25 i any knowledge of the extensive card games alleged to have 26 l 27 ! occurred in 1977. Furthermore, none of the Inspectors were 28 ! 29 i aware of any case in which QC Inspectors failed to properly 30 'l 31 inspect safety-related civil activities or in which QC 22 33 Inspectors signed inspection records only when requested to 34 do so by Construction. Our findings were confirmed by the 35 36 NRC in Inspection Report 79-14, dated October 16, 1979. 37 38 After Mr. Swayze made sweeping allegations in October 39 40 1979 about widespread card playing and non-inspections by 41 42 Inspectors throughout 1977, B&R Senior Management directed 43 ' i 44 Mr. Warnick to review all civil inspection records for 1977 45 46 as a further means of investigating Mr. Swayze's allegations. 4'. 4f This review demonstrated that civil nonconformance reporting 49 50 51 l l l
~
1 1 1 l 2 3 in 1977 correlated well with the leve3 of civil construction activities during the year. Of the 55 civil safety-related 6 7 deficiency reports issued in 1977, 38 reports were issued by l 8 individuals alleged by Mr. Swayze to be card players, includ-9 10 ing 3 deficiency reports by Mr. Swayze himself. It is 11 k 12 noteworthy that during most of 1977, Mr. Swayze was a Lead 13 14 ' QC Inspector. Lead Inspectors would not normally be expected 15 f 16 ) to sign inspection records, f7g Part of Mr. Swayze's allegations suggested that QC 19 'l Inspectors were experiencing excessive pressure from Con-30 ' 21 l struction personnel which amounted to harassment or intimi-22 23 ' dation of the QC Inspectors. Prior to the NRC special 24 1 25 ; investigation beginning in November 1979, B&R Management was 26 : 27 i aware of occasional incidents involving confrontations 28 i 29 j between Construction and QC personnel. Each of these isolated 30 3g f incidents were fully investigated by B&R Site and/or Houston 32 Management, as indicated above. 33 { Although such occurrences 34 l! were taken seriously and were fully discussed with HL&P 35 l 36 i Project management, they did not reflect a generic problem 37 38 , of intimidation and harassment of QC Inspectors by construc-39 1 40 tion personnel. 41 42 i Q. 30 How and when did B&R become aware of the findings 43 44 of the NRC's special investigation performed in late 1979? l 5 What actions were taken by B&R Management to respond to this 47 information? How was this coordinated with HL&P? 48 49 50 51 i 1 2' 3 A. 30 (KMB): During the last week of December 1979 l 4 5 Mr. George Oprea, Executive Vice President of HL&P, met with 6i several representatives from B&R and other personnel from 7l 8l HL&P to discuss information that had been related to Mr. Oprea 9 10 by the NRC Region IV. It was during this meeting that I 11 12 first became aware of the types of findings which we could 13 14 l expect in the NRC's investigation report. Beginning with f6 this meeting, we were kept informed by HL&P of various I concerns or findings identified by the NRC to them in meetings 19 or discussions of their investigation. B&R and HL&P jointly 20 ! 21 l assembled a team of Project personnel to immediately begin 22 23 ' defining the responsive actions necessary and to develop 24 ! 25 i plans for implementing corrective actions for any and all 26 ! 27 l findings as we were informed of them. This Task Force 28 ;l eff rt continued through the issuance of the NRC's report 29 30 l ' 31 ! and the Show Cause Order and the preparation of HL&S's 32 33 l formal response in July 1980. Some of its activities continue 34 even today. 35 \ 36 ' That is, we, jointly with HL&P, assembled a team and 37 38 made assignments to responsible individuals to respond to 39 40 various items as they were identified. Throughout this i 4{9 4 entire process, management of both HL&P and B&R were kept 43 44 inf rmed on a frequent basis through formal meetings which 45 46 were held to discuss the status of the various items as well l 47 as informal. discussions, memoranda, etc. The response to i 48 l 49 l 50 51 ! l
1 l Li 2 h 3 the various items was a joint effort, as has been our practice 4 5l through the entire history of the Project, whereby if an l 6l item required actions by only B&R, we would develop the 7l 8 proposed corrective action and submit that to HL&P for its 9ll review and comment and possible modification to reflect 10 11 li 12 l their views. If the item only required HL&P's action, in 13 ! 14 i most cases, B&R would be asked to review and comment on 15 16 l their response; and, of course, any items requiring joint 17 g, efforts or joint actions would be approached and resolved in 19 l a joint fashion. 20 1 21 l Q. 31 What was the reaction of top management at B&R 22 ; 23 l to the NRC's enforcement action taken in April 1980? 24 ! 25 i A. 31 (KMB): To say the least, we were surprised. 26 ; 27 ! While we recognized that enforcement action is designed to 20 1 gg : spotlight deficiencies, we were dismayed because the Show 30 cause Order failed to place the STP program in a complete 32 perspective. For example, while the NRC's Order conceded 33 34 , that no items of major safety significance were found, the 35 l 36 ' Order did not mention (1) significant evidence of HL&P and 37 38 B&R management awareness of the key problem areas; (2) 39 40 significant corrective action which had already been initiated; 41 i 42 l (3; the extent to which Project problems had, in fact, been 43 44 identified by the Project QA program; and (4) the overall 45 quality of construction of the Project. 47 48 49 50 51
~
~
i 1 I 2 h 3 l Q.32 Dr. Broom, more specifically, what actions were 4 taken by B&R to investigate the NRC finding regarding alleged 5 6 7 intimidation and harassment of B&R QC Inspectors by Construc-8 tion personnel? 9 10 A.32 (KMB): 11 , This finding from the NRC special investiga-12 l tion was first identified to me by Mr. oprea in a meeting in 13 1 14 i late December 1979. I was extremely concerned about the NRC 15 16 finding of undue pressure on QC Inspection personnel as was 17 ' gg the entire B&R and HL&P management team. We took the matter 19 20 i very seriously. I immediately undertook an investigation to 21 ! 32 ! determine whether we had a " harassment and intimidation" 23 I 24 4 problem as suggested by the NRC's findings, and if we did 25 26 ! have such a problem - to determine the causes and to implement 27 l the proper corrective action. 28 i gg j Based on the information verbally obtained from 30 ' 31 i the NRC (written NRC findings were not available until April 3 1980), I personally directed members of my staff and an 34 i 35 i outside consultant to conduct extensive interviews with 36 ' 37 Construction and QC personnel to determine whether there was 38 39 a perception of harassment or intimidation of QC personnel 40 by construction. 41 In addition, Construction and QC personnel 42 responded on a confidential basis to a written survey ques-43 44 tionaire regarding employee attitudes and relationships. 45 46 The findings of this investigation, which was 47 48 concluded in January 1980, indicated to me that there was 49 50 l 51
I i Ll l not a perception on the part of QC Inspectors that they were 4 being inhibited from performing their work due to intimidation 5 6I or harassment by Construction. My investigation, however, l 7i SI confirmed that we had a morale problem among our QC personnel. 9! 10 l This problem involved the normal types of complaints from 11 ! 12 l employees about pay and benefits as well as a concern about 13 ! t4 e management support which indicated to me that our supervisory people within the QA/QC organization were not providing 17l feedback in the way of explanations of the resolution of 13 l 19 ! matters which inspectors had identified as nonconformances. 20 1 21 : Although a deficiency identified by an Inspector would be 22 ! 23 resolved by Engineering or by rework, in many cases, the 24 ' 35 Inspector who identified the item was not kept fully informed 26 27 j of how the matter was resolved. While, in theory, that may be an acceptable way of operating; in fact, it does not work 30 l well because the Inspector can lose confidence in his manage-31 l 32 ! ment, can lose sight of the consequences of his inspection, ) 33 34 and could become concerned that matters were not being 35 36 resolved satisfactorily. 37 38 ! These kinds of complaints by QC Inspectors were 39 ! 40 not new to me. We had heard similar concerns expressed by 41 42 l individual Inspectors from time to time, as Messrs. Warnick 43 44 and Singleton explain in their testimony. Furthermore, 45 46 Management had taken steps prior to January 1980 to address 47 these kinds of concerns. Ev.amples are given in Answer 22 d.3 45 90 51
-. . j l !
lj ! 2 3 above. Nonetheless, my investigation in January 1980 con-4 5 firmed that additional Management attention to QC morale 6 problems was necessary. 7 8 Q.33 What steps were taken by B&R Management beginning 9 10lj in January 1980 to address QC Inspectors morale problems and 11 i 12 j to improve communications between QC and Construction? 13 14
- A.33 (KMB): Even before my investigation was concluded, we held a meeting at the jobsite on January 4, 1980, with f7g all QA/QC personnel, together with Construction Supervision.
13 ! This was held as part of the "9 Point Action Plan" submitted 20 1 21 l by HL&P to the NRC in late December 1979, as described in 22 : 23 ! Mr. Frazar's testimony in this proceeding. 24 4 25 At this meeting, Project m'anagement and QA/QC 26 ! 27 l management addressed the subject of resolution of differences 28 29 of opinion between inspection personnel and construction 3 l personnel and other matters. The intent of this presentation 32 was to emphasize to everyone that we would not tolerate 33 34 unprofessional behavior by construction or QC personnel, 35 36 j . that they each had important roles to play and that there 37 i 38 i were management teams that were expected to resolve matters 39 ! 40 l that might be in dispute. Unfortunately, this presentation 41 i 42 ' became the subject of < cncern to NRC personnel who felt that 43 44 cost and schedule were overemphasized to our QA/QC inspection 45 personnel. I, reviewed that brochure before it was presented 47 : to the Project personnel, and I did not read that :oncern 48 l , 1 49 50 l 51 l 1
1 l f[ 4 into the presentation. My investigation sWasequently showed 5 that our Inspectors did not feel cost and schedule were 6 overemphasized. 7 However, our reaction was that if the NRC 8 9 perceived it in that way, then our personnel might have 10 , perceived it in the same fashion. In any event, pursuant to 11 ! 12 j the Show cause Order, we retracted that presentation and 13 ! 14 ; hild another presentation at which we made abundantly clear 10 7 that QA/QC personnel are expected to perform their function 17 ' 16 i free from concerns about cost and schedule. This subsequent 19 I 20 i presentation at the Site was made by W. M. Rice who heads 21 ! the Power Group. 22 ' 23 l 24 j A number of other steps were taken by B&R Management 25 beginning in January 1980 to address concerns in this area. 26 i 27 l Examples of the actions taken are: 28 -- I held a meeting in January 1980 at which the QA 30 } 31 Manager and I impressed upon our QC Supervisors 32 I 33 the need for attention to human relations and to 34 l ; 35 l personal discussion between supervisors and inspec-36 j , tion personnel to ensure that full feedback in 37 ' 38 this regard was occurring. 39 ! We instructed all QC 40 i Supervisors to hold meetings with their Inspectors 41 ! 42 j at least weekly. 43 -- A complete reevaluation of the B&R salary adminis-45 46 tration program for QA/QC personnel was conducted 47 48 under my direction during January-February 1980, 49 50 } 51 ____ J -- A =-
l i l 1l l 2 L 3 4 and a revised QC salary administration program was 5 i implemented on March 30, 1980. 6 Care was taken to 7 ensure fair and equitable compensation for QA/QC 8l 9j personnel. O y -- The B&R Project QA/QC organization was reevaluated 2 3, during January-February 1980, and in March 1980, 4 revisions to the organization were implemented 3l 6 7l including an upgraded reclassification of QC g supervisory personnel to provide equal stature 9 0i with their Construction counterparts. 1
}'! --
B&R Project management has issued a procedure, 3 4, STP-PGM-02, " Procedure for Resolving Disputes 5! Between Construction and QA/QC Personnel," rev. O, 6' 7i January 7, 1980, which clearly defines a step hy 8i 9j step process whereby any differences of opinion 0l 1! between Construction and QC personnel are resolved 2! 3l through the use of successive levels of super-4 5 vision in order to eliminate confrontations which 6' i7 could result in harassment or intimidation. The
;8 i9 i procedure has been discussed in indoctrination io il sessions for Construction supervision and QA/QC i ,2 personnel.
r3
, ,g --
In January 1980, the position of B&R Assistant QA i5 i6 Department Manager was abolished, thereby shortening 47 L8 i , L9 l 10 il l 1 I
i L- l 2 l 3 l 4 t the communication chain between site QC personnel 1 5 i - S ! and top QA management to facilitate communication 7 ; and resolution of problems. o 8 i 9 3 On February 15-16 and February 22-23, 1980, a y formal training seminar on employee motivation, I 3 human relations, and supervisory skills was held 4 s for Construction and QA/QC supervision. This 6 j 7i program was conducted by professors in organiza-g{ 9! tional behavior management from the University of g; Houston. 1f 2 i During March 1980, a meeting was held for B&R 3{ 5 r QA/QC personnel in which B&R Power Group Management 5! 5! and QA Department Management discussed the B&R 7i 3i open-door policy for all employees to express 9} concerns as to any aspect of the STP operation or 0i gj 2 his personal treatment as an employee. Dedication 3 to achieving quality objectives was emphasized. 4 3
.I In March 1980, "QA Bulletins" were instituted oi 7 throughout the QA/QC department, including all 3
3 site B&R QA/QC personnel, to provide better under-3 Li standing of overall activities, capabilities and 3' support within the department. The objective was 3 4 5 to improve individual understanding of the inter-3 7 dependence of personnel in all Project quality
- 3 related activities.
'3 3 !1 l
. j LV I!
ll On March 27, 1980, the B&R Project General Manager Ii a issued a statement reitarating the mandate that f Project procedures, specifications and drawings be
!I ) rigorously followed.
Ii
;i --
A program of regular refresher training of B&R { Construction and QA/QC personnel in Project proce-I' 5' dures has been instituted to ensure better under-2 T1 standing of procedures governing their work. Il -- A complete review of B&R QA/QC personnel qualifi-Il
)
e i cations and recertification of those personnel, j, where necessary, was completed during January-April f 1980, to eliminate any doubt as to whether QA/QC I 2 personnel are properly qualified. Ii 3i Extra radios have been provided to B&R QA/QC
)! personnel and HL&P Site Surveillance personnel to 3\
Ll improve radio communication about field activities. Ii 3; These radios increase communication within B&R and 3 between HL&P and B&R Construction and QA/QC personnel. 3 On May 8-9, 1980, B&R QA management conducted 7 3 3
" meetings with site QC Supervisors to review NRC 3 Report Number 79-19. B&R QA management will Ll 1; continue to provide additional perspecti've on 3
g problems, the need for better communications and 5 g proper support of inspection personnel. 7 3 3 3 1 i Lj l 2 ' 3 - -- In May 1980, a supervisory skills course was 4, 5j Initiated for first line QA/QC supervision. A 6: 7l course was obtaines. from Practical Management 8l 9j Associates and encompasses necessary supervisory i 0 yj skills, and diagnosis of causes of personnel 2 problems. 4 In addition to these specific responsive actions, B&R 2
- 6. management has accomplished other basic QA program improve-7!
gi ments in 1980 and this year, which are discussed in Mr. 9 ;t. O Vurpillat's testimony. 1 i
}l Q.34 Are there indications that QC Inspector morale 3
4,i has improved as a result of management actions taken by B&R 5 since January 1980? 6' 7l A.34 (KMB): Yes. As Mr. Vurpillat indicates in his 8i 9j testimony, B&R and its consultant have found that our efforts 0i 1j have substantially reduced the previous QA/QC management
}l concerns expressed by some of the Inspectors. While ce are 4
5 of course encouraged by the apparent attitude improvements, 6' 7 we understand the importance of fully and effectively imple-8, menting our program and staying alert for any signs of 9j 0 morale problems, and we will do so. 1l 2 Q. 35 Mr. Vurpillat, describe the major changes in 3 4 B&R's QA program since the Show Cause Order. A. 35 ($JV): As reflected in HL&P's response to the 7
,8 Show Cause Order, improvements to the QA program for STP 29 iO il I
l t
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I i were identified in a number of major areas. Among the I significant changes made in the B&R QA program implementation T' are the following: I
) 1. Procedures have been clarified and simplified down 1 .r j to the job level. In this area, B&R has recognized L'
3 the need for improved STP procedures to facilitate fl 3 ease of compliance and to ensure consistency. Il i Significant rewriting of procedures was begun in i
),
1979 and has been accelerated since.
); Procedural revisions have been implemented to r
incorporate applicable criteria in the text of the l procedure rather than incorporating them by reference. I 3 In addition, construction procedures are being I Ii i revised to include more specifics. These revisions
): are intended to remove the need for subjective 1 ,, interpretations by field personnel, and will I simplify and make more consistent both field iI y constructions and QC inspections. Third, con-8 struction QA Procedures currently are being improved II so that the subject areas contained in each of the Il 1
10 CFR Part 50, Appendix B Criteria will be drawn I together in a single QAP or a series of QAP's. I g For ease of identification, the procedure numbers
- willicorrespond to appropriate criteria numbers. I i
1 ) )
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I Finally, B&R has developed a more efficient I! Ii process for making these procedural changes by I il T requiring responsible STP personnel to obtain
) input from all organizations whose activities will I
g be affected by the new or revised procedures. For i t 3 example, a QAP addressing the manner in which A 5i nonconformances are to be resolved must be reviewed
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2 ; by B&R Construction, Engineering, Materials Manage-7i I ment and Project Management personnel to ensure
) ); consistency within each organization's program.
L' In addition, all of these new or revised program 3I
&! procedures are submitted to HL&P for review and 1
3 l comments before final implementation. 2 ; 7! 2. An improved system for documenting and resolving 3i 9; non-conforming conditions has been developed. 3! (l Detailed trend analysis and data analysis proce-2l 3 dures have been developed and implemented in an f 3 attempt to better provide for early detection and
. i' 3
7 resolution of potential weaknesses and recurring 3 problems. 9 3 3. Training and indoctrination has been upgraded for li 2i personnel at all levels. This training and indoctri-3! 4 nation relates to quality related tasks with 3 3 special emphasis on the project goals of reliability 7 3 and safety, quality first, and "do it right the 9 first time." 0 1 i i 1 1: j 1 2 l 3 4 B&R has retained the Quality College consulting 5 6 firm headed by Philip Crosby, a noted QA consultant. 7 8 under Mr. Crosby's guidance, a formalized Quality i 9 j Improvement Program has been established and i 0 1 y seminars on elements of a good QA program have 2 been attended by over 100 B&R Project Management 4 ! a and QA/QC management personnel, as well as by 6l senior management personnel from both B&R and 7! E HL&P. 9 This Quality Improvement Program is a 0; 1 i long-term endeavor, and ultimately will cover all
}! aspects of the QA Program at STP, including Pur-3 chasing, Engineering, Construction, and QA/QC.
5j 4. 6; Stronger system controls have been initiated and 7! 8' are reflected in procedures which assure that 9 0 quality-related activities are initiated, controlled, 1l and properly documented. 2i B&R has developed an 3l 4 Inspection Planning Program to formalize the 5 existing inspection plans containedin the construc-6{ . tion procedures. 7! This program will ensure that 8! 9! the quality-related activities are adequately O 1, planned, performed as required, reviewed, evaluated, 21 3 documented and verified--all in the proper sequence. 4 5. 5 The system of audits on the Project has been 6l 7 improved to better verify adherence to procedures g and to identify deficiencies for resolution at the 9 0, appropriate level of management. 1
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L' i 2 l' 3 4 B&R and HL&P regularly perform audits which 5 i 5 i ensure that the QA Program commitments for STP 7 { 3 continue to be implemented in conformance with all 9 applicable requirements. First, B&R conducts 3 g audits of its QA Program activities at least annually, and more often if necessary. Similar 4 a ' auditr of B&R's QA Program are performed at least 5 i 7i annually by HL&P, and where appropriate, B&R and g l HL&P may perform joint audits. Audit Reports are 3! 3, distributed to B&R and HL&P management as well as Li 2l to the management of the audited organization, and f!
*I corrective action is taken where appropriate.
5} a In addition to these B&R and HL&P audits, the 7 3! QAMRB directs an annual review of the B&R Power 3l Group Progr.m, including STP. This comprehensive 3\ L! review is performed with the assistance of outside 2! 3: consultants. Reports are reviewed and discussed b by all QAMRB members. 3 i 3 If unresolved items are 7 identified in the reports, the QAMRB, where it 3 9 deems appropriate, assigns particular organizations 3 L within B&R to close out these items. Written g 3 reports from these organizations which document 4 5 the corrective action taken for closecut are then ! a presented to and reviewed by the QAMRB. 7 3 9 3 L
*i Ll 2"
3 6. Visibility of and active participation by upper 4 5 management in QA/QC activities have been increased. 5 7 Since September 1980, B&R's long-established 8i g{ QAMRB, composed of B&R Power Group senior manage-0{' 3 ment executives, has held monthly meetings at the 2l STP site which HL&P management personnel have 3; 4, attended. The Board's activities have been dis-s. 6, cussed in prior testimony. In addition to these 7i gl QAMRB meetings, there have long been separate 9' O monthly Project review meetings held jointly by 1 i
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B&R and HL&P. At these meetings, attended by 3! officers of the B&R Power Group and senior .L&P 4 5{; Project management personnel, general Project QA 6; 7l issves are discussed. 8l On a weekly basis there are QA action item 9j 0l 1! meetings, attended by the B&R Project QA Manager, the HL&P Project QA Manager and others, if neca;sary. 4 Discussions at these meetings focus on unresolved 5 6' problems identified through HL&P site surveillance 7 8! activities. B&R personnel develop and implement 9I
- 0 corrective actions which must be reviewed and
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,2 j approved by HL&P before final closecut of the r3 ' , ,g problems. In addition, the HL&P Project QA Super-visor and the B&R Project QA Manager meet at least l'7 weekly to discuss QA related activities. Finally, 68 19 10 l l il
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L HL&P QA personnel in each discipline observe B&R i l QC Inspectors and Lead Inspectors on a daily i T basis. I y In addition, since September 1980, I have 3 ( reported each month to the B&R Operating Committee s 3 , regarding the status of the QA/QC Program for the I' STP. 5l 5 7l In addition to the above, changes in key personnel and yl reassignments have been made. B&R has accelerated earlier 3i
)l initiatives to strengthen and reorganize its QA management h team at STP. B&R has made these personnel and organiza-2 j ; tional changes by recruiting highly qualified, experienced
! Ii s personnel from the outside, reassigning home office personnel 7 3! from the B&R Power Group QA staff to the STP team, relocating 3i supervisory personnel from Houston to the STP site to facili-3! (t tate prompt decisions and problem resolutions, and reorganiz 2! 3} ing the QA management staff to increase direct involvement 3 3I by middle and upper level management in the STP QA process. 3 7 In my judgment the procedural changes and the increased s' management attention are both very important. But most 3I 3I important of all has been the significant qualitative improve-L ! gl ment in the personnel assigned to manage and carry out the 3i l QA function. We now have an outstanding team of qualified I 3 and dedicated supervisory QA personnel. 7 3 3 3 l1 1l 2 3 In about December 1979, the Project QA Manager moved 4 5i onto the STP site full-time to facilitate and speed responses 6\ to problems. 7l 8 i He also began reporting directly to the B&R 9j Power Group QA Manager, instead of repcrting through the Ot y{ Assistant Manager, to facilitate prompt action by higher 2 levels of QA management. Because of these changes, QA 4' Management for STP is now centered at the site where it can 3 , 6; exercise direct control over daily STP activities. In 7i g! addition, lines of communication have been shortened between oi 0l STP QA Management and B&R Power Group QA Management. 1l }! In mid-summer 1980, W. J. Friedrich, a QA consultant, 3 4 was temporarily assigned to STP as B&R Project QA Manager. 5l 6; Mr. Friedrich's prior experience includes eight years as a 7i site QA Manager at various nuclear plants and twelve years 81 9l of additional QA experience in the aerospace industry. O! 1l I was then hired in August 1980 as Power Group QA 2I 3: Manager to provide permanent Power Group QA management and 4I supervision. 5! I replaced Dr. Knox Broom, Senior Vice President 6! of the B&R Power Group, who had filled the position on an 7 8 i interim basis. . 91 0i In addition to changes in QA Management, changes were 1 2 also taking place in the Quality Engineering area. Until 3 4 about October 1979, the B&R Houston Power Group QE staff had 5. 6, ! been spending' about 50% of their time on STP and the rest of their time on various other Power Group QA projects. In 9 , Oi l 1, ,
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i 1:; 2 t-3 October 1979, i 4 l the B&R Power Group QE staff in Houston began 5 { devoting virtually full time to QE activities to STP. 6 k 7 ; 8
' In late December 1979, Mr. Gordon Purdy was transferred 9
0 by B&R from Houston to the STP site to assist the Project QA y 2 Manager, and in May 1980, the function began reporting 3 ,l directly to the Project QA Manager instead of to the Power 4 Group QA Manager. 3 l In January 1980, Mr. Purdy moved six 6 l 7 i Quality Engineers from the Houston Power Group QE team to g the site, l 9 ! to supplement the existing QE staff and to speed j O the QE decision-making process. 1 ! Since that time, the QE
}i staff at the STP site has been augmented in all disciplines 3! with additional qualified personnel.
41 5' 6! In May 1980, Mr. Don Harris, a QA consultant, was 7! Si assigned to work with Mr. Purdy in supervising all QE activi-9i ties at STP. 0! Mr. Harris' prior experience includes nine 1l 2! years in the nuclear industry as a QE supervisor and QA 3l manager, and fourteen year' is a quality engineer in the 4 m aerospace industry. 6j 7l. Moreover, the interface between B&R and HL&P has been 8! strengthened. 9 Beginning with the HL&P's review and approval 0 1 of B&R's initial QA Program for STP, HL&P has maintained 2, control over the Program, 3 and in so doing has continually 4 5 interacted with B&R at all levels of management. HL&P 6 7 reviews and comments on all procedural changes before imple-8 mentation. HL&P also performs a continual surveillance of ! 9l 0l 1; f .. .
-l g.. .
I I all B&R QA Program activities, including activities at the ii STP site, in Houston, and vendor surveillance shop inspections. l s T B&R QA Project documents such as vendor surveillance reports, " l y nonconformance reports and audit reports routinely are 3 g presented to HL&P for review and appropriate action. In I addition, HL&P not only participates jointly with B&R in 3,
}'
s certain QA audits, but conducts its own independent audits 5, of B&R QA activities. Audits performed by B&R Audit Group 7l Il are discussed in exit critiques which HL&P personnel often 3l 3l attend. 1i 2l In sum, the interface between the two companies concern-3 4{ ing B&R's QA Program has always been and continues to be 5 extensive. 61 7l 8; Q. 36 Are there indications that these program changes 9i have in fact remedied problems identified in the Show Cause 0: 1i Order? 2 3l A. 36 (RJV): Yes. First of all, programmatic changes i 2 have been made in the areas of soils, concrete and welding, 6 and after a complete review by the NRC, restart of the 7 8I activities that had been stopped has occurred an? they are 91 0 being carried out well. Second, as a result of the salary, 1l 2 personnel and organizational changes made by B&R, there has 3! 4 been a marked improvement in the overall morale of personnel 5 6 at the STP site. The same conclusion has been communicated 7
,' 8 to us by the NRC at the August 19, 1980 public meeting.
'9 This conclusion has also been reaffirmed on two separate 10 ,i il l 1
. r 1 1 2 L 3
4 , follow-up evaluations by our consultant. Employees are 5 l 6 i asking questions of their supervisors more frequently, 7 supervisors and management personnel are taking more time to 8 9 l explain decisions to QC Inspectors, and disagreements between 0 y l Construction and QA/QC personnel are being resolved more 2 I 3 l expeditiously. 4 3 i Finally, under the newly revised and integrated quality 6l construction procedures, construction and inspection activi-7i g! ties conducted in the areas of welding and concrete have 9i 0i proved to be easier to understand and to perform. 1 .! 2! 3 4! 5! 6i 7l 8l 9j THUD:10:D 0; 1l 2! 3' 4 5, 6' 7 8 9! 0l 1j 2' 3 4 5 6 ' 7I i 8I j 9 l 0 l 1' l l
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