ML20050C501
| ML20050C501 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 03/26/1982 |
| From: | Goldberg J HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML20050C500 | List: |
| References | |
| NUDOCS 8204080571 | |
| Download: ML20050C501 (6) | |
Text
.
3 giv7 ~
u
.g g.1jarch:'2'6, 1982 2
3 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 4
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of 9
5 6
HOUSTON LIGHTING & POWER COMPANY 9
Dock ~t No. 50-466 e
6 7
(Allens Creek Nuclear Generating 6
(Station, Unit 1) 8 SUPPLEMENTAL DIRECT TESTIMONY OF 9
JEROME H. GOLDBERG ON TECHNICAL QUALIFICATIONS 10 Q.
Mr. Goldberg, have you previously testified in this 11' proceeding?
12 A.
Yes. I testified on. October 7 and 8, 1981, in connection lf 13 with the issue of HL&P's technical qualifications to
-14 construct ACNGS,.which is TexPirg Additional Contention 15 31.
16 Q.
Have you read the Licensing Board's order of January 28, 17 1982, wherein additional testimony was requested on HL&P's technical qualifications in light of the " Design g
Review of Brown &' Root Engineering Work for the South Texas Project," prepared by the Quadrex Corporation in May, 1981 (hereinafter "Quadrex Report /B&R")?
l 21 l
A.
Yes, I am familiar with the Order.
22 Q.
Are you familia,r with the Quadrex Report /B&R?
23 A.
Yes,.I am familiar with the report.
It was prepared by 24 Quadrex at my request.
l F200080571 820326 PDR ADOCK 05000466 T.
PDR L_
o 1
2 Q.
Would you explain why you asked Quadrex to undertake 3
this review?
4 A.
As was indicated in my earlier testimony, I was hired 5
by HL&P to bring to the company a person with broad ex-perience in design and construction of nuclear power 6
plante.
After joining HL&P and examining the nature of some of the engineering problems at the South Texas 8
Project, I made some preliminary engineering observations 9
that suggested that a more thorough review of Brown &
10 Root's engineering work was appropriate.
After consid-11 ering which engineering firms were competent, willing 12 to do a third party review and previously uninvolved 13 with engineering of the South Texas Project, we selected 14 Quadrex.
No regulation, order or suggestion from the 15 NRC led to the commissioning of the Quadrex Report /B&R.
16 Instead, that report was prompted by my determination 17 to see that HL&P spared no effort in evaluating the Work of its architect / engineer.
g Q.
What significance did you attach to the result of the Quadrex review?
20 A.
The Quadrex review highlighted a number of concerns l
21 with nuclear engineering activities on the project, 22 although it did not place these concerns in a clear 23 perspectiveorsubstantiateallohthem.
As a matter l
24 e
l l.
o s
1
'2 of fact, a preliminary assessment by a Bechtel Task Force 3
has now been completed.
That Task Force found that over 4
two-thirds of the Quadrex/B&R findings relate to matters 0
5 that would have either been resolved by previusly
'{
n-g ing Brown & Root activities or would have required 6
no further action.
In general, Bechtel found that many I
of the Quadrex/B&R findings "were not as serious as had 8
been perceived by Quadrex".
Bechtel's final evaluation 9
of the Quadrex Report /B&R will not be ready until later 10 this year.
11 Q.
Did the Quadrex Report /B&R provide the single most 12 significant reason for terminating Brown & Root as 13 architect / engineer at the South Texas Project?
14 A.
No.
Brown and Root's lack of engineering productivity 15 was holding back construction, thereby affecting project 16 costs and scheduling.
As a result Brown & Root's work was terminated.
The Quadrex Report /B&R was simply 17 an ther indication that some of our concerns might be 18 well founded.
Q.
In response to the Board's order, can you explain why the Quadrex Report /B&R was not addressed in prior 21 testimony in this proceeding?
22 A.
We did not consider the report to be relevant to our 23 prior testimony unless, of course, one considers the 24 e
. e.
o 1
2 fact that HL&P took the initiative in commissioning the 3
engineering review to be a positive reflection on the 4-company's character and competence as well as its 5
commitment to assure a sound design of the south Texas Project.
In our view the primary thrust of the report 6
is not HL&P's technical competence or construction -
related problems of the type alleged in TexPirg's con-tention.
Moreover, the changes in HL&P's organization, 9
which Mr. Oprea and I described earlier and which were 10 begun before the issuance of the Quadrex Report /B&R, 11 were designed to cope with a broad range of problems at 12 STP, including a number of the problems that were later 13 reported by Quadrex.
14 Q.
Does the existence of the Quadrex Report /B&R change any 15 of your prior testimony?
16 A.
No.
17 Q.
Eave you made any organizational changes since you last testified because of the Quadrex Report /B&R?
18 A.
We have added an engineering assurance department since I last testified.
However, the decision to add that 20 group to our orga.nization was not made solely as a l
21 l
result of the Quadrex Report /B&R.
It was my determina-22 tion that we needed to enhance our engineering review 23 capability and the Quadrex Report /B&R confirmed that 24 l
1 2
determination.
This group will serve the needs of 3
Allens Creek as well as STP.
4 Q.
Do you foresee any other changes that would be required 5
in HL&P's organization because of the Quadrex Report /B&R?
A.
N, n t at this time.
I must emphasize that the Quadrex 6
Report /B&R deals with Brown & Root's engineering work.
t As I testified earlier in these hearings, it is not HL&P's job to do the engineering work of the architect /
9 engineer.
It is our job to see that they do the job 10 right.
When we concluded that Brown & Root could not 11 attract and retain the resources necessary to complete 12 the project in a timely and effective fashion, we 13 terminated them.
I think that is very dramatic proof 14 of HL&P's commitment to Effective management of its 15 nuclear projects.
16 Q.
Did you retain Quadrex to review the engineering work 17 being done by Ebasco on Allens Creek?
A.
es, we did.
A copy of their report, which was previously 18 provided to the Board and the parties, is attached g
hereto an Applicant Exhibit The Quadrex Report on Ebasco ("Quadrex Report /Ebasco") demonstrates that 21 Ebasco's work on Allens Creek meets or exceeds industry 22 standards.
23 24 1
-s-1
o 1
t 2
Q.
Is it your opinion that Ebasco has and will continue to 3
perform so as to prevent the types of problems noted in 4
the Quadrex Report /B&R from happening at Allens Creek?
A.
Yes.
Nothing in the Quadrex Report /Ebasco indicates 5
that the types of problems noted in the Quadrex Report /
6 B&R exist at Allens Creek.
In this regard, assuming
)
solely for purposes of this testimony that the generic findings in the Quadrex Report /B&R cited by Mr. Doherty 9
are valid, we have asked Mr. Louis J. Sas of Ebasco to 10
~ describe how the Ebasco engineering group functions to 11 prevent such problems.
12 Q.
Does that conclude your testimony?
l 13 A.
Yes.
1 j
~
14 1
15 l
l 16 17 18 19 20 21 22 23 24 e
e.
__