ML20040E429
| ML20040E429 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/02/1982 |
| From: | Blau J, Frazar R, Overstreet H HOUSTON LIGHTING & POWER CO. |
| To: | |
| References | |
| 50-498-81-28, 50-499-81-28, ISSUANCES-OL, NUDOCS 8202040319 | |
| Download: ML20040E429 (14) | |
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UNITED STATES OF AMERICA S
Sf y;t 10 NUCLEAR REGULATORY COMMISSION Il 44 40
'11
's'h 11 12 13 A
14 BEFORE THE ATOMIC SAFETY AND LICENSING BO G
/p 15 m
16 In the Matter of:
19 HOUSTON LIGHTING & POWER Docket Nos. 50-4980L 20 COMPANY, ET AL.
9 50-4990L 22 (South Texas Project, 9
23 Units 1 & 2)
S 24 g
25 26 27 28 29 TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET AL.
30 31 OF MR. R. A.
FRAZAR MR. J.
L. BLAU 34 E. H. G. OW RSTREET 35 36 ON 37 38 CONTENTION 1.8 39 40 41 42 hgo3 43 44 S /
45 46
/
llY 47 48 49 50 51 8202040319 820202 PDR ADOCK 05000498 O
l 1
2 3
4 5
UNITED STATES OF AMERICA 6
NUCLEAR REGULATORY COMMISSION 7
8 9
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 10 11 12 13 In the Matter of:
6 14 g
15 HOUSTON LIGHTING & POWER Docket Nos. 50-4980L 16
- COMPANY, 17
--ET AL.
S 50-4990L t
S 18 (South Texas Project, 9
19 Units 1 & 2) 5 20 5
21 TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET AL.
23 4
OF 25 26 MR. R. A. FRAZAR 27 MR. J. L. BLAU 28 MR. H. G. OVERSTREET 29 30 ON 31 32 CONTENTION 1.8 33 l
34 Q.1 State your names.
i 35 A.1 Richard A. Frazar (RAF), Johnny L. Blau (JLB) and 36 Harry G. Overstreet (HGO).
37 I
38 Q.2 Mr. Frazar, Mr. Blau and Mr. Overstreet, by whom l
39 are you employed aTd what are your current responsibilites?
4 41 A.2 (RAF) I am employed by Houston Lighting & Power 42 Company (HL&P) as Manager, Engineering Assurance Department 43 with responsibility for development, managenemt and adminis-44 tration of the engineering assurance program.
45 46 (JLB) I am employed by HL&P as Supervising Project 47 Engineer with responsibility for supervising the HL&P Project 48 Engineering staff's overview of the South Texas Project 49 (STP) design and engineering activities.
50 51
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3 4
_HGO)
I am employed by HL&P as Supervisor, Quality
(
5 6
Assurance'(QA) Training & Administration.
My responsibili-7 ties include implementation of HL&P's QA training program 8
and supervising the Technical Reference Center.'
9 10 Q.3 Please briefly describe your educational and work experience background.
11 12 A.3 (RAF) This information is presented in my previous 13 testimony on HL&P's QA program for design and construction.
14 From June 1980 until I was replaced by Mr. J. E. Geiger on 15 June 22, 1981, I was the STP QA Manager.
After Mr. Geiger 16 joined HL&P, I resumed my previous duties as corporate 17 Manager, QA except that I no longer had responsibility for 18 the STP QA organization.
I remained in this position until 19 assuming my current position on January 22, 1982.
20 21 (JLB) I received a Bachelor of Science degree in 22 Mechanical Engineering from Texas Tech Univelsity in 1972.
I j ined HL&P in December 1972, with my initial assignment 23 eing a member of the Electrical Engineering Division (Instru-24 mentation and Controls) of the PoweroPlant Engineering 25 Department.
I worked on a variety of fossil-fueled projects 26 in this capacity until June 1977, when I was assigned as a 27 Project Engineer responsible for multi-discipline engineering 28 efforts.
In March 1979, I joined the South Texas Project as 29 Supervising Project Engineer (SPE) with responsibility for a 30 group known as Special Engineering Support, concentrating in 31 the areas of Piping, Pipe Supports, NSSS Interface,* and 32 HVAC.
In August 1980, I became SPE, Houston Engineering 33 with additional direct responsibilities for HL&P's total 34 home office engineering effort.
In March 1981, I was 35 appointed Project Engineering Manager on an acting basis, assuming direct responsibility for HL&P's total project 36 engineering eff rt (home office and site engineering).
In 37 mid-October 1981, with HL&P's establishment of the new 38 position of Manager, Engineering, I was appointed to the 39 position of SPE, reporting to the Manager.
40 41 (HGO) I graduated from the National Electronics 42 Institute in 1968 and joined the United States Navy tha.t 43 same year.
I graduated from the Navy's Machinist Mate "A" 44 School in 1968 and completed Basic Nuclear Power School in 45 1969.
In 1970, I qualified as a Mechanical Operator at the 46 AlW Nuclear Power Training Unit, graduated from Submarine 47 School and was assigned to the U.S.S. Casimir Pulaski, a 48 nuclear submarine.
While stationed aboard the Casimir 49 50 51 l
1 2
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5 Pulaski, I attended several training classes administered by.
l i
6 the Engineering Advanced Training Division and held succes-l 7
sive assignments until 1974 when I was given the respon-l 8
sibility of Secondary Leading Petty Officer.
In this posi-9 tion, I was responsible for QA and Quality Control in the 10 Machinery Division.
11 l
Following my discharge from the Navy in 1975, I 12 joined HL&P as a QA Technician.
I have held successive i
13 assignments in HL&P's QA Department including Project QA l
14 Supervisor, Procurement for STP.
My current assignment is 15 Supervisor, QA Training and Administration.
I 16 I
17 Q.4 What is the purpose of your testimony?
18 19 A.4 (RAF, JLB, HGO) We will address the events dis-20 cussed in Allegation No. 1 of I&E Report No. 81-28 which is.
21 the basis for contentions 1.8 (a) and (b).
22 (RAF) In addition, I will address the events 23 4
discussed in Allegations Nos. 2 and 4 of the I&E Report 24 No. 81-28 which are the bases for contentions 1.8(c) and t
l 25 (d).
26 27 l Q.5 Mr. Blau and Mr. Overstreet, are you familiar with 28 the event's discussed in I&E Report No. 81-28 concerning NCR 29 ST-5A?
30 l
31 A.5 (JLB)
Yes.
This NCR contained three issues i
32 concerning access engineering, and HL&P's Project Engineer-33 ing group had responsibility for ensuring that Brown & Root, l
34 Inc. (B&R) resolved these issues.
The HL&P engineer who l
w6rked directly on the issues (Mr. H. R. Hesidence) reported 35 to me and I participated in the meeting which ultimately led 36 to the resolution of these issues.
37 38 (HGO)
Yes.
I worked on the drafting of NCR ST-5A 39 and was supervisor of the QA group which had responsibility 40 for these types of issues.
I participated in the principal 41 events discussed in Allegation No. 1 of I&E Report No. 81-28.
42 43 Q.6 Mr. Blau, what is " access engineering"?
I 44 1
45 A.6 (JLB)Section XI of the ASME Code requires and l
46 sets standards for the detailed inspection of Class 1, 2 and j
47 3 pressure retaining components, such as piping systems, l
48 both prior to operation of the plant (the Preservice Inspec-tion - PSI) and at periodic intervals during the life of the 49 50 l
51 m
1 2
3 4
5 plant (Inservice Inspection - ISI).
The Preservice Inspec-.
6 tion for a piping system, for example, would include the.
7 examination of the system's welds, pumps, valves and other 8
pressure retaining components.
Access engineering design 9
(or access design) is the process by which the designer 10 ensures that the PSI /ISI inspectors will have sufficient room, i.e. access, to perform the inspections required for lh the particular welds, pumps or valves in question.
Basically, l~
access design involves simply taking into consideration the 13 access requirements for inspection of each particular system 14 when establishing the physical design of each system.
15 16 Access engineering does not involve the selection 17 !
of the hardware - pipes, pumps, valves, vessels, etc. neces-18 I sary to perform any plant functions.
Further it is important 19 to recognize the distinction between access design and 20 access design review.
A misunderstanding within HL&P re-23 garding who within B&R performed access design was the most 2{ l important source of confusion during HL&P's attempts to i
On STP, access design involves 2J the work of the. system designer in considering access require-24 ments and potential access problems when he is actually 25 designing the system in question.
In contrast, access 26 I design review at STP is an independent review of the final 27 j system design conducted after design verification has been 28 l completed to ensure that access requirements are reflected l
29 !
in the designer's product.
Access design review is an 30 additional layer of review which focuses specifically on 31 access requirements and is beyond the design verification 32 required by 10 C.F.R. Part 50, Appendix B.
l 33 Q.7 Mr. Overstreet, please describe the results of 34 HL&P audit BR-25 and its relevance to Allegation No. 1 of 35 I&E Report No. 81-28.
36 37 A.7 (BGO) HL&P audit BR-25 was an audit of B&R Engineer-38 ing conducted in July 1979 to evaluate the implementation 39 and effectiveness of the B&R Access Review Program.
The 40 audit found no basic problems, but three deficiencies were 41 noted.
One of the deficiencies, ADR BR-25-D-02, was a 42 failure to update the PSI /ISI Manual every six months as 43 required by the Manual's terms.
This ADR became one of the non-conformances cited in NCR ST-5 and SA.
44 45 Q.8 Mr. Blau, would you outline the efforts undertaken 46 to close out ADR BR-25-D-02?
47 48 49 50 51
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3 A.8 (JLB) The results of audit BR-25 were issued in 5
August 1979.
B&R first provided a response to ADR 6
BR-25-D-02 in September 1979 and amended their response in 7
October 1979.
B&R proposed to update the PSI /ISI Manual and 8
change it into a Technical Reference Document (TRD)'.
In 9
December 1979, HL&P identified three items in addition to 10 the issuance of the TRD necessary for resolution of 11 ADR BR-25-D-02.
In February 1980, B&R submitted another 12 revised response that included one of the items necessary 13 for close out - an evaluation of the impact of not updating 14 the PSI /ISI Manual periodically as required.
In April 1980, 15 B&R and HL&P discussed further actions necessary to close 16 out the ADR.
Work continued on the development of the TRD 17 and different drafts were reviewed by various parties in October and November 1980.
In December 1980, it was decided 18 that the TRD would be issued by May 1981.
In February 1981, 19 B&R submitted a the final draft TRD for review by HL&P and 20 its consultants.
Following incorporation and resolution of 21 comments, the access TRD was approved by HL&P in July 1981 22 and was issued for use in August 1981.
Upon approval of the 23 TRD, ADR BR-25-D-02 was closed out.
24 25 Q.9 Mr. Overstreet, what were the issues discussed in 26 NCR ST-5A?
27 28 A.9 (HGO)
There were three (3) issues in NCR ST-5A, 29 two of which were carried forward from NCR ST-5 issued in 30 November 1980.
The two issues that were in the original 31 NCR ST-5 were:
(1) B&R did not appear to have procedures in 32 place to implement access design, and (2) the PSI /ISI Manual 33 containing the criteria for access design had not been 34 updated every six months as required by its terms.
The third issue, which originated in NCR ST-5A, was a concern 35 1
that access design was being conducted using a draft 36 Technical Reference Document (TRD).
37 38 Q.10 Mr. Overstreet, did the drafting of a stop work 39 notice in conjunction with NCR ST-5A reflect an assessment 40 by QA that some activity was taking place which might cause 41 irreparable damage if not stopped?
42 43 A.10 (HGO) No.
The decision to draft a new NCR and a 44 stop work notice was made on June 5, 1981.
The two con-45 siderations discussed were that: (1) the new TRD necessary 46 47 48 49 50 51
.1 2
3 4
S to close out ADR BR-25-D-02 and NCR ST-5 had been promistd 6
for a long time but had not yet been issued; and (2) B&R did 7
not appear to have procedures implementing the access design g
program and had not written any implementing procedures for 9
access engineering since NCR ST-5 was issued.
HL&P-QA made 10,
no assessment of the technical significance of either con-sideration.
The purpose of the stop work notice was simply 1,!
to force a resolution of these outstanding issues.
12 l 13 Q.11 Mr. Overstreet, why was the draft stop work notice 14 not finalized and issued?
15 16 A.11 (HGO) The draft stop work notice was prepared on 17 June 8, 1981.
I took it and the revised NCR to Mr. Blau's lg I office to inform him of our intent to issue the revised NCR gg !
and stop work notice at the same time.
Mr. Blau suggested 20 that we discuss the matter with Mr. Barker, Manager, STP, and we did.
During our meeting, which Mr. Eesidence also 21 attended, Mr. Barker recognized QA's authority to issue the 22 stop work notice, but expressed the view that it was not 23 necessary to stop work in order to get management's attention 24 focused on the issues.
Mr. Barker requested an opportunity 25 to discuss these issues with B&R upper management in order 26 I to obtain management action to resolve NCR ST-5A.
Since the 27 !
purpose of this.stop work notice was to get management's 28 attention, I agreed to give Mr. Barker an opportunity to 29 accomplish this goa; without the issuance of a stop work 30 notice.
31 Q.12 Mr. Overstreet, did you discuss your decision to 32 not issue the stop work notice at that time with anyone 33 else?
34 35 A.12 (HGO) No.
I made the decision at the meeting on 36 June 8, 1981, after discussing the matter with Mr. Barker,
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37 Mr. Blau and Mr. Hesidence.
38 39 Q.13 Mr. Overstreet, was your decision not to issue a 40 stop work notice proper under HL&P's procedures.
41 42 A.13 (HGO) Yes.
Our stop work procedure contains no 43 mechanically applied test to determine when a stop work notice should be issued.
An exercise of judgment is regrired 44 by our procedure and that is what I did.
45 46 Q.14 Mr. Frazar, did you concur in Mr. Overstreet's 47 judgment?
48 49 50 51 i
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5 A.14 (RAF)
Yes.
I was not involved in making this 6
decision, but Mr. Overstreet informed me later and I expressed 7
no opposition.
This was clearly a matter of judgment and I 8
had no reason then, or now, to question Mr. Overstreet's 9
decision.
10 Q.15 Mr. Blau, what occurred following the June 8th 13yj ;j meeting with Mr. Barker and Mr. Overstreet?
13 A.15 (JLB) Mr. Barker contacted Mr. E. A. Saltarelli, 14 B&R's Vice President and Chief Engineer for STP, on June 8, 15 1981.
Mr. H5sidence forwarded NCR ST-5A to B&R on June 16, 16 1981, and they responded on July 7, 1981.
As discussed in i
17 A.
17, after much discussion between HL&P and B&R personnel, i
18 the requirements for close out of NCR ST-5A were established 19 at the August 10, 1981, meeting.
20 21 Q.16 Mr. Overstreet, how were the three (3) issues in NCR ST-5A resolved?
22 l 23 A.16 (HGO) The third issue was resolved by the final 24 approval on July 8, 1981, of TRD No. 4UO10PQOO7-B entitled 25 "Preservice & Inservice Inspection".
Issuance of this TRD 26 I also was the basis for closing the second issue because the 27 '
TRD replaced the PSI /ISI Manual.
As noted above, the second 28 issue was derived from an audit deficiency report (ADR 29 BR-25-D-02) and this ADR was closed out on July 23, 1981, 30 based on.the final approval given to TRD 4UO10PQ007-B.
31 32 The first issue raised in the NCR had been deter-33 mined to be erroneous as a result of a meeting held on August 10, 1981, and subsequent investigation by HL&P.
We 34 held the NCR open, however, to ensure that B&R (1) amended
.5 certain other procedures'to reference the new TRD and re-36 quire its use and (2) conducted training on the new TRD.
37 These amendments would have been made in the normal course 38
- of business by B&R following the issuance of the TRD.
Our 39 holding the NCR open simply reinforced a review and amend-40 ment process that would have occurred anyway.
I also checked 41 to ensure that training on the use of the new TRD was being 42 conducted prior to closing out the NCR on September 30, 43 1981.
44 45 Q.17 Mr. Blau, how was the allegation that B&R had no Procedures in place to implement access design determined to 46 be erroneous?
47 48 49 50 51 i
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A.17 (JLB) In order to understand how this determina-S tion was made, one must first understand how the allegation 6
came to be made.
There are two alternative methods by which 7
architect-engineers can accomplish access design.
The first 8
method, which is used at STP, is to have each system designer 9
consider and incorporate the access requirements when per-10 forming the original design activity.
The second method 11 involves establishing a separate engineering organization to 12 take the output of the various system designers, apply the 13 access requirements and redesign if necessary to meet such 14 requirements.
15 16 When HL&P's NDE/ PSI /ISI QA personnel examined 77 B&R's access engineering program, the most obvious access yg engineering activity was that of a group headed by Mr.
Blakely.
This group was dedicated solely to access en-19 gineering and appeared to HL&P to be performing the access 20 design function in a manner similar to the second method 21 i described above.
Since Mr. Blakely's group did not have a 22 !
specific procedure which defined its role in the STP engi-23 neering organization, its interfaces with other organiza-24 tions or its method of operation, the HL&P QA personnel 25 concluded that B&R did not have a procedure governing the 26 access design activity.
Thus, NCR ST-5 was generated in 27 November 1980 citing this perceived lack of procedures as a 28 non-conformance.
29 i
30 In fact, however, Mr. Blakely's group was performing l
31 an access design review and not the access design work itself.
In writing NCR ST-5, HL&P had mistakenly confused 32 33 access design with access design review.
B&R was not using a separate engineering group to perform access design, but 34 rather, the general B&R procedures for both System Design 35 Descriptions and Design Verification required + hat the 36 1
designer and the design verifier utilize the PSI /ISI Manual.
l 37 in performing their work.
This Manual incorporated the 38 substantive access requirements of the ASITE Section XI Code 39 to which STP was committed.
i 40 41 In the spring of 1981, an HL&P engineer, Mr.
l 42 Hesidence, was assigned to work exclusively on STP access 43 engineering matters.
As he became more familiar with the l
44 B&R design procedures and access engineering program, he 45 sensed the mistake HL&P had made in confusing access design 46 with access design review.
Following the issuance of NCR 47 ST-5A and B&R's response, Mr. Hesidence called a meeting of 4g HL&P QA, HL&P engineering and B&R engineering personnel to 49 discuss the misunderstanding which had developed.
50 l
51.
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1 2
3 4
This meeting was held on August 10, 1981.
The 5
participants discussed the manner in which B&R accomplished 6
access design and design verification, the procedures which 7
governed these activities and their references to the PSI /ISI 3k Manual, the review function performed by Mr. Blakely's group 9
and the applicable ASIIE Code and 10 C.F.R. Part 50, Appendix B r
10 W requirements.
After a thorough discussion, the HL&P QA 11 personnel agreed that if.in fact the system designers'were 12 required by procedure to use the access requirements in 13 performing their work, then formal procedures were not re-14 quired for Mr. Blakely's group.
Following the meeting, Mr.
15 Hesidence performed an in-depth review of the B&R procedures 16 and confirmed the accuracy of B&R's description of the situation.
Given these facts, HL&P required in order to 17 18 close NCR ST-5A only (a) that the existing procedures be amended to reference the new TRD in lieu of the PSI /ISI f
Manual and (b) that training on the new TRD be conducted.
21 Q.18 Mr. Overstreet, was the resolution of NCR ST-5A 22 without a stop work notice satisfactory in content and 23 timeliness to HL&P QA?
24 25 A.18 (HGO) Yes.
The new TRD was finalized in early 27 )
26 July, approximately three weeks after the revised NCR was sent to B&R and, as noted above, the issuance of this TRD 28 resolved two of the three issues raised in NCR ST-5A.
Once 29 we understood the nature of B&R's system for ensuring access 30 design and verification, there was no need for the extensive 31 type of procedures we had contemplated and, thus, the remaining issue was resolved.
Given these facts, a stop work notice 32 33 was not required to achieve a satisfactory resolution of the NCR.
34 35 Q.19 Mr. Blau, what review has been made of the impact, 36 if any, on access design arising from (1) B&R's use of the 37 PSI /ISI Manual from 1976 to mid 1979 without the required 38 updating and (2) the subsequent delay in issuing the PSI /ISI i
39 TRD?
40 41 A.19 (JLB) As part of the close out for ADR BR-25-D-02, 42 B&R evaluated the impact of not updating the PSI /ISI Manual 43 every six months.
This evaluation found no significant 44 deficiencies in the work performed due to a failure to 45 revise the Manual every six months.
This result was reached 46 because the ASME Code edition and addenda governing access 47 engineering activities for STP had not changed since the 4g Manual was issued.
l 49 l
50 l
51 l
1 2
3 In addition, prior to the change in architect-engineer, 4
Mr. Blakely's group was reviewing the design work completed 5
prior to issuance of the TRD against the TRD requirements.
6 This review had not revealed any significant access problems.
7 Mr. Hesidence's independent review of some of the work 8
performed to date confirms Mr. Blakely's results.
9, 10 l A final factor indicating that the long development.
11 period of the TRD has not had any substantive impact is that 12 the substantive criteria in both the TRD and the Manual are 13 based on the same edition of the ASME Code,Section XI.
The 14 TRD uses different words and follows a different format than 15 the Manual, but the substantive requirements are virtually 16 the same.
Thus, the switch from the Manual to the TRD 17 ;
does not invalidate the work done pursuant to the Manual.
18 I 19 !
Q.20 Mr. Frazar, what was your involvement in the I
20 events described in Allegation No. 2 of I&E Report No. 81-28 21 which is the basis for contention 1.8(c)?
22 A.20 Allegation No. 2 of I&E Report No. 81-28 involves 23 an audit of the B&R site QA organization by HL&P QA personnel 24 in May-June 1981.
'During the course of the audit, B&R 25 personnel raised questions regarding the use of the Quality 26 j
Assurance Program Description (QAPD) and the B&R Project QA 27 Manual, Rev. 9 (QA Manual), in a field audit of this type.
28 A meeting involving HL&P and B&R QA personnel was held at 29 the site on June'll, 1981, to discuss this matter and I i
30 participated in that meeting.
31 32 Q.21 What was the problem that caused the meeting to be 33 called?
34 i 35 A.21 The audit was being conducted in the middle of 36 procedure and QA manual revision activities.
Because of 37 this unusual situation, the HL&P auditors were using the 38 upper-tier QA documents, the QA Manual and the QAPD, as 39 checklists for auditing the effectiveness of the B&R QA 40 Program.
B&R management felt this method of auditing was 41 causing confusion because the B&R staff level QA personnel 42 did not use these documents in their day-to-day construction 43 1 elated activities and, thus, were not always capable of 44 explaining how their activities implemented particular sections of those documents.
45 46 47 48 49 50 51 l s -
1 2
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5 Q.22 What happened at the June ll, 1981, meeting?
6 7
A.22 B&R's position, as expressed by Mr. R. J. Vurpillat 8
and Mr. A. W.
Smith, was that its personnel performed their 9
work in accordance with various specific procedures that 10 j were written to implement the QAPD and QA Manual, i.e. the 11 i upper-tier documents that establish and describe the QA 12 I program in a more general fashion.
B&R did not believe it 13 was appropriate to ask its field personnel to identify the 14 manner in which they implemented the upper-tier documents because the individuals in question did not use the upper 15,l tier documents in performing their daily work.
16 17 l I agreed that it was inappropriate in a field 18 audit to use licensing documents such as the FSAR and QAPD 19 20 l as checklists to measure the effectiveness of the B&R QA Program.
I explained that personnel who work to specific 21 procedures must be audited against those procedures.
The 22 comparison of upper-tier documents and the procedures to 23 ensure that the procedures fully implement the upper-tier 24 documents is an audit activity that should precede the 25 audit; it is not one that should be accomplished by pro-26 i pounding questions to the B&R working level personnel.
I 27 '
expressed. the view that the HL&P auditors should complete 28 the field audit using the implementing procedures as the 29 documents against which performance would be judged.
30 31 Q.23 Was there any confusion after the meeting regarding y ur comments?
32 33 A.23 Yes.
Later that day, HL&P's Lead QA Specialist 34 over auditing, HL&P's Quality System Supervisor, and I 35 continued our discussion.
During this second meeting, I l
36 became aware that my comments may have been interpreted to 37 mean that audit deficiency reports (ADRs) should never be 38 written against the QAPD or QA Manual.
While I had expressed
)
39 the opinien that the auditors should not write ADRs against 1
40 these documents in field audits, I had not intended to imply l
41 that HL&P would never audit the procedures against the 42 upper-tier documents.
I explained my position again and at 43 the conclusion of this second meeting, I thought the matter 44 was clear.
45 l
Q.24 How was the audit completed?
46 47 A.24 The auditors returned to Houston on June 11 and 48 met the next day with.their. supervisor, Mr. R. L. Ulrey.
- 9 50 51,
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1 2
3 4
5 After discussing the events of the previous day, Mr. Ulrey 6
instructed the auditors to complete the field audit using.
7 the implementing procedures as the basis for audits and not 8
to audit for conflicts between the procedures and the upper-9 tier QA documents.
Mr. Ulrey assigned another HL&P QA 10 i employee the specific job of reviewing the B&R procedures to 11 i ensure that they addressed the requirements of the QAPD and 12 '
QA Manual.
13 14 Q.25 Did you become aware subsequently that some con-15 fusion regarding the writing of ADRs against the QAPD and QA Manual still existed?
16 17 !
A.25 Yes, but not for several weeks.
I left the office 18 l on July 10, 1981, for military duty to be followed by vaca-19 tion and did not return until August 10, 1981.
I had not 20 received a letter on this subject from Mr. Vurpillat dated 21 June 30, 1981 (ST-BR-HL-40268) at the time I left the office.
22 :
While dated June 30, 1981, Mr. Vurpillat's letter was apparently 23 not received by the B&R Document Control Center until July 13, 24 1981.
25 26 I Due to the foregoing circumstances, Mr. Vurpillat's 27 letter did not come to my attention until mid-August.
Upon i
3g reviewing the letter, I disagreed with it to the extent it
- 9 might be interpreted to mean that " disconnects" between the 30 l Upper-tier documents and implementing procedures should not be documented by NCRs or ADRs.
I corrected any possible 31 micunderstanding by writing a response to Mr. Vurpillat on 32 August 24, 1981 (ST-HL-BR-6443).
This letter was distributed 33 to HL&P audit personnel, and training of HL&P audit personnel 34 on the contents of the letter was held.
I&E Report No.
35 81-28 indicates that these actions eliminated any remaining 36 doubt in the minds of HL&P auditors concerning the writing 37 of ADRs against upper-tier QA documents.
38 39 Q.26 What was your involvement in the events described 40 in Allegation No. 4 of I&E Report No. 81-28 which is the 41 basis for contention 1.8(d)?
I 42 A.26 I am " individual X" in the report and was the 43 supervisor of individual C (Mr. H. G. Overstreet) until I 44 l
Was replaced as STP QA Manager by Mr. J. E. Geiger on June 22, 45 1981.
46 47 Q.27 What were the " minor problems" mentioned in Allega-48 l
tion 4 of I&E Report No. 81-28 that had developed in Mr.
49 overstreet's group during your tenure as his supervisor?
50 51 i I,
r 1l 2
3 4
5 A.27 I am aware of only two such problems.
First, Mr.
6 overstreet was utilized on several occasions by Mr. Barker 7
or his staff to follow up on QA problems assigned to Mr.
8' Barker's staff for resolution.
This practice reduced the 9!
amount of time Mr. Overstreet could devote to other activi-10 l ties and was improper from an organizational viewpoint.
11 i When I became aware of the situation, I spoke to Mr. Barker 12 i and he assured me that this practice would be stopped.
13
'4 The second problem was a tendency for Mr. Overstreet 15 to become too deeply involved in activities that the B&R QA 16 rganization was to perform.
Rather than having B&R correct some deficiency in their system, Mr. Overstreet would occa-7 7 ;l si nally do the activity himself or have it done by the HL&P 18 j
personnel.
19 20 Q.28 How did these problems develop?
21 22 l A.28 I was Mr. Overstreet's direct supervisor for the 23 '
period June 1980 to June 22, 1981.
During this period, I 24 was heavily involved in site-oriented activities resulting 25 from the Show Cause Order and subsequent B&R/HL&P task force 26 i investigations.
As a result of these commitments, I was not I
27 able to give Mr. Overstreet's group as much attention and 28 direction as I normally would have.
The fact that Mr.
29 overstreet's group officed in Houston, 90 miles from my office, exacerbated the problem, but was not the primary 30 cause.
31 32 Q.29 Has Mr. Overstreet's group received sufficient 33 direction since you were replaced by Mr. Geiger?
34 35 A.29 Yes.
I was aware of this problem and discussed it l
36 with Mr. Geiger when he took over as STP QA Manager.
Due to 37 the completion of many of the activities I was involved in 38 at the site, Mr. Geiger has been able to spend more time 39 with Mr. Overstreet's group than I was.
While we have t
l 40 [
referred to the QA group in question as "Mr. Overstreet's 41 '
9roup", it has been led by Mr. T. J. Jordan since January 4, 42 1982.
43 44 Q.30 Did either of the problems described in A.27 45 l result in a failure to implement the QA program?
46 A.30 No.
Both problems were relatively minor and dealt i
47 with the methods utilized by Mr. Overstreet to accomplish 46 his objectives rather than his substantive job performance.
,9 50 l
51 l TH:12:2:A I