ML19350A291

Identification of Witnesses & Substance of Testimony. Certificate of Svc Encl

ML19350A291
Person / Time
Site:	South Texas
Issue date:	03/02/1981
From:	HOUSTON LIGHTING & POWER CO.
To:
References
ISSUANCES-OL, NUDOCS 8103130416
Download: ML19350A291 (12)

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_. ,.4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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=0 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD N In the Matter of 5 5

HOUSTON LIGHTING & POWER 5 Docket Nos. 50-498 OL COMPANY, ET AL. 5 50-499 OL 5

(South Texas Project, 5 Units 1 and 2) 5 March 2, 1981 Applicants' Identification of Witnesses and Substance of Testimony Applicants hereby identify the following individuals as the witnesses they presently intend to call in this proceeding and the substance of their testimony.

Mr. Donald D. Jordan, President and Chief Executive Officer of Houston Lighting and Power Company (HL&P), will testify concerning the general management organization of g#

HL&P, HL&P's background and policy in dealing with the g 4[ h-public and regulatory agencies, and the reaction of the U//g [ .'1 highest management levels of HL&P to the NRC Show Cause k g Order. a gO' s'

A panel of witnesses including Mr. J. H. Goldberg, ,IW HL&P's Vice President, Nuclear Engineering and Construction, and Mr. Richard A. Frasar, EL&P's Manager, Quality Assurance, will testify concerning HL&P's current management of the siosiaa w 5 */I

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4 overall project activities of STP, including the quality assurance (QA) program relating thereto. Mr. Goldberg will describe HL&P's organization and staff' resources for such management and how HL&P is fulfilling its management respon-j' sibilities. Mr. Frazar will similarly describe HL&P's I organization and staff resources for management and implemen-tation'of its QA responsibilities relating to design and construction, and how.those responsibilities are bei '

properly discharged.

i A panel of witnesses including Mr. George W.

Oprea, Jr., HL&P's Executive Vice President, Mr. Joseph W.

l Briskin, HL&P's Project Manager-Houston Operations, Mr. Frazar, and Mr. John M. Amaral,' Manager of Quality Assurance of Bechtel Power Corporation (Bechtel), will testify concerning experience of HL&P in the design and construction of STP prior to the NRC investigation (79-19) and.Show Cause Order and the' actions taken by HL&P as a result thereof. Mr. Oprea l

l will provide an overview of STP' _empliance histor1, including the evolution of HL&P's QA program, and will discuss HL&P's l actions with respect to QA concerns before the Show Cause .

i Order, and how HL&P's management reacted promptly and fully i

to-the NRC investigation and Show Cause Order. Mr. Briskin L

will describe the organization and work of the task force I 4

-formed by HL&P'to respond to the Show Cause Order. Mr. Frazar

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b will discuss the changes which have been made in the adminis-trative controls in the STP QA program as a result of the Show Cause Order. Finally, Mr. Amaral will describe Sechtel's recommendations regarding the STP QA organization and explain the basis for such recommendations.

A panel of witnesses including Dr. Knox M. Broom, Jr., Senior Vice President of the Brown & Root, Inc. (E&R)

Power Group and Mr. Raymond J. Vurpillat, 3&R's Manager of Power Group Quality Assurance, will testify on B&R's imple-mentation of the STP QA program, B&R management's actions with respect to QA concerns before the NRC investigation and Show Cause Order and the B&R changes in personnel, organization and procedures in implementation of the STP QA program subsequent to the Show Caus- Order. This testimony will also include a discussion c: 5&R's attitude toward QA/QC from a management perspective.

Three panels of witnesses will testify concerning the concrete placement program at STP and related matters.

The first panel will include Mr. Joseph F. Artusc, President of Construction Engineering Consultants, Mr. Gerald R.

Murphy, B&R's STP Assistant Civil-Structural Project Engineer, and Mr. Ralph R. Hernandez, HL&P's Supervising Engineer, Civil-Structural Engineering. Mr. Artuso and Mr. Murphy will describe the organication and scope of activities of the task force established to review STP concrete placements in response to the Show Cause Order, the studies and analyses conducted by the consultants retained to review the concrete placements, and the conclusions reached as a result of the efforts of the task force and the consultants, including the conclusion that the STP concrete construction satisfies the design requirements and is comparable to or better than construction of similar facilities subject to similar require-ments. Mr. Hernandez will discuss HL&P's role in the concrete task force effort.

The second panel, including Mr. Albert D. Fral ey, Project General Superintendent of Brown & Root Construction, Mr. Gordon R. Purdy, B&R's Quality Engineering Manager, and Mr. Robert A. Carvel, HL&P's Project QA Supervisor, Civil-Structural, will describe recent improvements made in the STP concrete program and the status of the restart program for complex concrete placements.

The third panel will include Mr. Murphy, Mr. Gerald L.

Fisher, B&R's STP Civil-Structural Project Engineer, Mr. Charles M. Singleton, B&R's STP Civil Discipline Quality Control Superintendent, Mr. Hernandez, Mr. David G. Long, HL&P's Senior Engineer, Site Engineering, and Mr. Artuso.

Their testimony will describe several activities comprised

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within or related to the STP concrete work, including con-tainment shell placement, cadwelding, installation of water-proofing membranes and rebar erection. In the course of their testimony, the members of this panel will cover the contentions of the intervenors which relate to *he foregoing activities. With respect to Contention 1(2) (alleged voids

.in the concrete wall enclosing the containment building),

the testimony will describe the extensive investigation that has been performed of potential voids in the STP containment building walls, the repairs that have been performed, and the assurances that significant voids do not exist. With respect to Contentions 1(3) and 1(6) (alleged lost documer -

tation relating to cadweld inspections and alleged cadwele.s not capabla of being verified), the testimony will explain the cadwelding process, the applicable requirements, and the steps followed in making, inspecting, documenting and testing cadwelds; will provide the results of cadweld testing at STP;.will describe the basis for concluding that such cadwelds are adequate; and will respond to allegations concerning missing documentation. With respect to Contention 1(4)

(alleged damaged membrane' seals.in the containment structure),

the testimony will-explain the purpose and use of waterproofing membranes at STP,.the QA-QC'programurelating thereto and the assurances of the adequacy of-existing waterproofing. membranes.

With respect to Contention 1(5) (alleged missing reinfercing steel bars in the cor*:inment), the testimony will explain the process for designing, installing and inspecting rebar at STP, and will describe the review performed of alleged missing rebar and the basis for concluding that the as-built rebar configurations meet the structural design requirements.

Three panels of witnesses will testify concerning the placement and compaction of backfill at STP. The first panel will include Mr. Bernt Pettersson, S&R's Assistant Civil-Structural Project Engineer, Mr. Charles S. Hedges, Project Manager for Woodward-Clyde Consultants, Mr. W. S.

McKay, Corporate Quality Assurance Manager for Pittsburgh Testing Laboratory (PTL), and Mr. Timothy K. Logan, formerly HL&P's Lead Engineer, Civil QA. Mr. Pettersson, Mr. Hedges and Mr. McKay will describe the development of the backfill placement and inspection program at STP (including applicable requirements), the resolution of problems identified before the Show Cause Order, the backfill verification program undertaken as a result of the Shcw Cause Order, and the current backfill placement program. Mr. Logan will discuss HL&P's surveillance of backfill placement at STP and HL&P's participation in the backfill verification task force.

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4 The second panel will include Mr. Stanley D.

1 i- Wilson, a private geotechnical consulting engineer, and

Mr. Thomas Kirkland, Senior Principal Engineer of Shannon &

l' i Wilson, Inc., Consulting Geotechnical Engineers. They will describe the evaluation of the engineering adequacy of the Category I structural backfill at STP performed by a committee i

of independent geotechnical engineering experts, which was chaired by Mr. Wilson and supported by Mr. Kirkland and his staff. They will state and explain the conclusions reached by the committee, including its overall conclusion that the condition of the backfill is entirely adequate for the design requirements at STP.

The third panel will include Mr. Pettersson and j UMr. Jon G. White, HL&P's STP Licensing & Technical Coordinator, who will testify;on the alleged false statements in the ESAR concerning laboratory testing on backfill materials and

< 1 i inspection of backfill placement referred to in the'Show 1 l- 1 Cause' Order and will demonstrate that these statements were ,

not " false". Mr. Pettersson will explain how the FSAR sections were drafted and. reviewed, the programmatic require-ments described therein, certain~ deviations from those

! programmatic requirements, and the review and evaluation of

' the' significance of those. deviations'. Mr. White will explain '

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HL&P's procedure for preparation and review of the FSAR, 3

including the sections at issue.

Two panels of witnesses will testify concerning >

j. the welding program at STP. The first panel will include Mr. T. J. Natarajan, B&R's Materials Engineering Manager, i

j Mr. M. Sullivan, NUTECH's Project Manager for STP, Mr. Purdy and Mr. Logan D. Wilson, HL&P's Project Quality Assurance t

' Supervisor, Mechanical /NDE Discipline. Mr. Natarajan and Mr. Purdy will describe the development of the welding l

program and procedures at STP (including applicable require-ments), the welding experience early in the project and the background of the issuance of the B&R welding Stop Work

, Order of-April 11, 1980. Mr..Natarajan and Mr. Sullivan I

will describe the organization and activities of the welding i

task force, including work done in response to the NRC Show Cause Order,.as well as the overall results of the task i

l force activities. Mr. Wilson will describe HL&P's involvement j in the development and implementation of the welding program at STP.

'The second panel will include Mr. M. D. Muscente, r

B&R's' Project Welding Manager, Mr. Purdy,.Mr. . James L.

Hawks, B&R's Engineering Project Manager,-Mr. J. R. Molleda, HL&P's. Lead Project Engineer, Mechanical-Nuclear, and Mr. Wilson.

Mr. Muscente and Mr. Purdy will describe the welding. program 2 .

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improvements since the issuance of the Stop Work Order on safety-related welding and the re-examination, repair and restart program, including schedule, manpower and results to date. Mr. Hawks will describe the program for engineering

evaluation of inaccessible AWS structural welds being con-ducted by expert consultants, including the current status and schedule. Mr. Molleda and Mr. Wilson will discuss HL&P's role in the welding task force effort and in the revised STP welding program.

The following witnesses will testify on contentions of the intervenors, to the extent that these contentions have not been covered by the previous' testimony. With I

respect to Contention 1(1) (surveying error in the basemat j of the Unit 2 Mechanical Electrical Auxiliary Building), Mr.  ;

Richard W. Peverley, B&R's Assistant Engineering Project Manager-Special Services, will describe the error and its cause, the limited significance of the error, the remedial redesign and its compliance with all applicable requirements.

! With-respect to Contention 1(7)(a) (to the extent it alleges that QC ir,spectors.have a role in the verification of design i

changes) and Contentions 1(7)(b) and (c) (alleged improper approval of design changes), Mr. Peverley will describe the procedures for approval of design changes and how they were properly implemented at STP. With respect to Contentions i

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1(7)(d) and (e) (alleged falsification of pour cards; alleged harassment and intimidation of QC inspectors) and Contention 1(7)(a) (to the extent it alleges that QC inspectors were thwarted in their communications with design engineers),

testimony will be presented by a panel of witnesses including  ;

Mr. G. Thomas Warnick, B&R's former STP Quality Control Manager, Mr. Charles M. Singleton, and Mr. Logan D. Wilson.

Messrs. Warnick and Singleton will describe the QA program at STP as administered at the working level and will explain alleged incidents of harassment and intimidation. Mr. Wilson will' describe HL&P's actions in connection with alleged incidents of harassment and intimidation and falsification of pour cards. With respect to Contention 2 (alleged falsifica-

. tion of STP construction records), Mr. McKay and Mr. Logan will describe the incident of falsification by a FTL employee of concrete material test records as reported to the NRC by HL&P and the resulting investigations as identified in NRC Inspection Reports 77-03 and 77-05. In addition, Mr. Richard l Buckalew, a B&R Systems Technican and former cadwelding foreman, and Mr. John B. Duke, a B&R Vendor Surveillance Inspector and former QC Inspector, will address the allegation regarding falsification of as-built cadweld location records for'the Reactor Containment Building Unit 1 basemat as investigated by.the NRC in Inspection Report 78-09, and will explain why.the-falsification allegation is without basis.

l The last panel of witnesses to be presented by HL&P will include Mr. Oprea, Mr. Goldberg, Mr. Robert I.

Moles, HL&P's STP Plant Superintendent, and Mr. Frazar, who will testify concerning HL&P's planned organization for operation of the STP. Mr. Oprea vill describe HL&P's poli-cies for the conduct of operation and will present an overview of the organization and plans for operation, including a discussion of how the review of construction problems has affected such organization and plans. Mr. Moles will describe HL&P'a planned organizational structure and staffing, qu ali fi-cations and training of personnel, and development of procedures zor operation. Mr. Goldberg will discuss the planned organi-cational structure for technical support for STP operations, the transition from construction to operation, mechanisms for independent safety review, training programs for support personnel and procedures for approval of plant modifications.

Mr. Frasar will describe the planned QA organisational structure, the qualifications and training of personnel, the development of QA procedures, the transition from construction to operation, and current QA activities relating to operation.

TH:04:T CERTIFICATE OF SERVICE I hereby certify that the foregoing document has been served on the following individuals and entities by deposit in the U.S. Mail, first class, postage prepaid on this 2nd day of March, 1981.

Y, s&h T. B. Hudson, Jr. /

Charles Bechoefer, Esquire Docketing and Service Section . I Chairman Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission hashington, D.C. 20555 Washington, D.C. 20555 Mrs. Peggy Buchorn Dr. James C. Lamb Executive Director 313 Woodhaven Road Citizens for Equitable Utilities, Inc Chapel Hill, North Carolina 27514 Route 1, Box 1684 Brazoria, Texas 77422 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board Pat Coy U.S. Nuclear Regulatory Commission Citizens Concerned About Nuclear Washington, D.C. 20555 Power 5106 Casa Oro Bernard M. Bordenick, Esq. San Antonio, Texas 78233 Office of the Executive Legal Director Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board Panel Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Brian E. Berwick Assistant Attorney General Atomic Safety and Licensing for the State of Texas Board Panel P. O. Box 12548 U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C. 20555 Mr. Jack Newman Betty Wheeler, Esquire Lowenstein, Newman, Reis Hoffman, Steeg & Wheeler

& Axelrad 1008 S. Madison 1025 Connecticut Avenue, NW Amarillo, Texas 79101

' Washington, D.C. 20036 TH:4:D

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