ML20050E357

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Testimony of Jh Goldberg,Bl Lex & J Crnich Re Mgt of Project.Discusses Decisions to Replace Brown & Root as Ae, Const Manager & Constructor.Related Correspondence
ML20050E357
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 04/05/1982
From: Crnich J, Goldberg J, Lex B
BECHTEL GROUP, INC., EBASCO SERVICES, INC., HOUSTON LIGHTING & POWER CO.
To:
Shared Package
ML20050E354 List:
References
ISSUANCES-OL, NUDOCS 8204130236
Download: ML20050E357 (48)


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l9 UNITED STATES OF AMERICA 0! NUCLEAR REGULATORY COMMISSION 1!

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4 t' BEFORE THE ATOMIC SAFETY AND LICENSING BOARD l 5l l

6I 7l In the Matter of: $

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l  ! HOUSTON LIGHTING & POWER S Docket Nos. 50-4980L i COMPANY, ET AL. S 50-4990L

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-! (South Texas Project, S I Units 1 & 2) 9

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l TESTIMONY ON BEHALF OF HOUSTON LIGHTING & POWER COMPANY, ET AL.

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31 MR. JEROME H. GOLDBERG MR. BURTON L. LEX MR. JOHN CRNICH 34 I REGARDING 5l 6{ THE MANAGEMENT OF THE SOUTH TEXAS PROJECT 37 '

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'4 5 UNITED STATES OF AMERICA

[6 NUCLEAR REGULATORY COMMISSION "7

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 0!

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l2l In the Matter of: 5 3l 4 HOUSTON LIGHTING & POWER 5

$ Docket Nos. 50-4980L 5l COMPANY, ET AL. 9 50-4990L 6l (South Texas Project, 5

7i 5 gl Units 1 & 2) 6 9! I O!

1i 2! TESTIMONY OF MR. JEROME H. GOLDBERG, MR. BURTON L. LEX, 3j AND MR. JOHN CRNICH 4 REGARDING THE MANAGEMENT OF THE SOUTH TEXAS PROJECT 5

Q.l. Panel, please state your names and current posi-7 l8 -

9. tions.

l31 A.l. (JG): I am Jerome H. Goldberg, Vice President for 3 Nuclear Engineering and Construction at Houston Lighting &

34 Power Company (HL&P).

l (BL): I am Burton L. Lex, Project Manager for the l37 South Texas Project (STP) at Bechtel Power Corporation l40 l (Bechtel).

. (JC): I am John Crnich, Construction Manager for the 43 i STP at Ebasco Services Incorporated (Ebasco).

Q.2. Please describe your educational background and

'7 professional experience.

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4 5 A.2. (JG): My educational background and professional 76 L

7 experience are described in my previously filed testimony on 8

fg the current management of STP.

Of (BL): I received a Bachelor of Science degree in L2

  • Chemical Engineering from Oregon State University in 1952.

'3I 4! I have 29 years of professional experience, 26 of which have o5i 6l been in the nuclear field. I am a Registered Professional 7i

,g! Engineer in the State of California in the chemical, mechanical o9!

0l and nuclear disciplines and hold Professional Engineer

21 l registrations in the states of Arkansas and Massachusetts.

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-4 Since joining Bechtel in 1957, I have been assigned to .

5 several positions of increasing responsibility. From 1958 E7 to 1964 I held supervisory and senior engineering positions on Humboldt Bay Unit 3, Peach Bottom Unit 1, the Nuclear' '

'1 3 Fuel Services Reprocessing Plant at West Valley, New York, and several industrial projects. From 1964 to 1968 I served 34 l as Engineering Consultant to Union Electric Madrilena on the l

! Zorita Nuclear Power Plant. In 1968, I was named Project #

37 Engineer on the Arkansas Nuclear One Project Units 1 and 2 40 l and later, Pilgrim Station Unit 2.

In 1972 I was promoted to Engineering Manager and 43 assumed responsibility for a wide variety of fossil and p6 u clear power projects including Arkansas Nuclear One Project Units 1 and 2, Pilgrim Station Units 1 and 2, the Palisades 49 0l 1!

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retrofit, the Big Rock Point fuel pool liner and Humboldt I56 ,

7 Bay Unit 3 modifications. I became Manager of Engineering 189 for Bechtel Power Management in 1976. In this capacity, I Ol was responsible for the establishment of engineering policy, 11 2l 3i standards and procedures; effective use of human and technical 4! resources; maintenance of technical leadership; and representa-5l 6i tion of the engineering functions to clients, industry and 7!

gl regulatory agencies. In 1978, I assumed the Project Manager position on the Vogtle Nuclear Plant where I was responsible for engineeting, design, procurement, planning, staffing, l cost, schedule and startup support.

25 I was transferred to the STP as Project Manager in February 1982.

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i (JC): I graduated from the United States Merchant i

31 Marine Academy in 1946, completing the marine engineering curriculum. This included all the engineering credits later 34 ! required for a B.S. Degree in marine engineering. I am Ei!

37 a licensed Professional Engineer in Nuclear Engineering in the State of California.

40 i From 1946 to 1953, I held various positions in power plant operations with the Matson and Moore-McCormick Steamship 43 I companies, Army Chemical Center and in the United States Navy as a submarine officer. From 1953 to 1966, I was employed by the General Electric Company in the operations 3

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'4 5 Department of the Knolls Atomic Power Laboratory, which was F6 L7 engaged in the development, construction, and testing of Navy nuclear power plants. I was promoted to Operations f

0 Manager in 1956. In this capacity, I was responsible for 1l:

,2i construction completion, startup activities, and test opera-b3I 4! tions of fcur land based full scale nuclear propulsion p5; 6l plants for use by the U.S. Navy.

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i I joined the General Atomic Company, which was involved 9

in high temperature gas cooled reactor design and construc-1 tion, in 1966 as a Purchasing Staff Engineer. I later held 2

3i positions as Manager in the Cost Engineering, Project Develop-4i

'5! ment and Purchasing Departments. I became Project Manager 6I -

7i of the Ft. St. Vrain Project in 1973, where I had overall

$8 responsibility for construction management. I was promoted 190i to Director, Services and Construction in 1975, where I was l31 responsible for development of construction methods and

$4 ' practices, operator training, and startup testing for high IS6l l temperature gas reactor plants.

>]7 l I was employed again by the General Electric Company, l40 i Nuclear Power Division from 1976 to 1978 as Manager, Valve 1l Design.

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4 I came to Ebasco in March 1978 as Site Manager for the 5

Waterford Unit 3 Nuclear Project, where I was responsible for 7 the administration of all onsite activities, supervision of 8!

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1l, 12i l3 II I45 Ebasco site personnel, establishment of equipment and facil-l 6 1

7 ities requirements and overall responsibility for construction costs and schedule progress. I became an Assistant Construc-0 tion Manager assigned to the Ebasco New Orleans Regional 1l l23 Office in November 1980.

4l Q.3. Panel, what is the purpose of your testimony?

l5l 6i A.3. (JG, BL , JC): The purpose of our testimony is to 7i g! describe the transfer of STP architect / engineer and construc-9 tion management responsibilities from Brown & Root, Inc.

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(B&R) to Bechtel and construction responsibilities to Ebasco; 3 the organization and staffing of Bechtel and Ebasco for 4

5, their respective responsibilities; and the relationship 6I 7{ among HL&P, Bechtel and Ebasco for the design and construc-8l tion of STP. -

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O'I Q.4. Mr. Goldberg, please summarize HL&P's decisions to 31 2

replace B&R as architect-engineer, construction manager and 34 constructor.

F6l A.4. (JG): By early summer of 1981, HL&P had concluded 37 '

that B&R lacked the necessary depth to perform the engineering 40 l and construction management tasks for STP in an orderly, timely and cost effective manner. We were concerned about 4 '

B&R's lack of engineering progress which was holding back construction, thereby affecting Project costs and scheduling.

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.5 Accordingly, we undertook to examine the feasibility of F6 L7 replacing B&R as AE and construction manager with an organiza-8 yg tion which had the, nuclear experience and resources necessary

_f to assume architect-engineering and construction management h2 l responsibilities for a job of this magnitude. We received 3:

4i and evaluated proposals during August and early September, 5!

6l and determined that Bechtel, which has, by far, engineered 7i 8l and built more nuclear power facilities in the U.S. than any

$9 I ther organization, was the best choice.

Ol An important factor l was the enormous technical resources that Bechtel was willing 3l and able to commit to the Project.

12 5 We were able to reach agreement in principle with 7 Bechtel by September 24, at which time we announced our l28 l intention to reallocate responsibilities from B&R to Bechtel.

19 Oii l31 At that time, B&R was progressing satisfactorily in 2

3 implementing needed improvements in its construction activi-l3 ties. Although we were concerned as to its ability to 6

complete the engineering and to manage the overall con-l37 t l

'3 struction effort in a cost effective manner, these concerns 9

l0l 1I did not extend to B&R's actual construction work. Thus, we did not plan to replace B&R as constructor and, in fact, 3l requested B&R to continue in that capacity at STP. ,

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'4 5 However, in November B&R notified HL&P that it would

[6 not serve as constructor and that it intended to withdraw t7 8

g from the Project. BL&P instituted a sear,ch for a new con-0{ ' structor and evaluated a number of firms. On February 15, 1l 2i 1982, we announced the selection of Ebasco. Ebasco also 3l 4! brings to the Project a wealth of nuclear experience, including 5i 6l participation as constructor or construction manager of 17 f7i nuclear power plants.

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0l Q.5. Mr. Lex, what are Bechtel's qualifications for 1f performing its responsibilities as architect-engineer and 3 construction manager for STP?

4 5 A.S. (BL): As summarized in the information submitted 6'

7! to the NRC on Decembe,r 11, 1981 (Applicants' Exh. 52),

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9 Bechtel's qualifications include more than 30 years of 0i y experience in the nuclear industry. We have participated in 2

3 the design, engineering and/or construction of 91 nuclear 4i 5l facilities in the United States and worldwide. The total 6! capacity of the power projects is in excess of 78,000 megawatts 7

8 and includes nearly all types of reactor design and power 9

0l concepts.

1l 2l Bechtel's major engineering experience within the past 3i 4 decade includes 50 nuclear power units with a total capacity 5

f 51,000 MW. Major power plant construction, construction 6

7 g supervision, and construction management experience within 9

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4 15 the past decade includes 41 nuclear power units with a total 6

7 capacity of 43,000 MW. This effort is carried out through 189 f ur divisions which are coordinated through Bechtel Power 0 Corporation Management Staff.

2f Bechtel's engineering experience has resulted in cor-3:

'4- porate development and NRC approval of twelve topical reports.

5l 6! These reports establish methods for the design of important 7i 8j features of nuclear power plants including pipe break effects, 9!

0; s@ compartment pressure analysis, Quality Assurance (QA),

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etc. Bechtel also maintains a corporate engineering staff (Bechtel Power Management) to coordinate solutions to and -

5 provide experience from within the corporation to focus on 6l 7! difficult or generic engineering problems, and to alert the 28 -

projects relative to actions necessary to resolve such 31 problems. Feedback from operating plants and plants under 3l construction is also disseminated through this organization.

34 ! Throughout Bechtel, senior staff personnel coordinate 156!l the flow of information between projects in all offices.

37 This results in a systematic review of engineering and 189i 40 l design information, evaluation and dissemination of licensing information to individual projects, development of company 43 4 positions on issues, and coordination with the regulatory agencies on generic matters.

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5 Q.6. Mr. Crnich, what are Ebasco's qualifications for 6

7 performing its responsibilities as constructor for STP?

A.6. (JC): As summarized in the information submitted 0 to the NRC on March 15, 1982 (Applicants' Exh. 53), Ebasco

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.2l has more than 20 years of experience in the nuclear industry.

,3 l 4i We have participated in the design, engineering, and/or

.5 l 6l construction of 30 nuclear facilities in the United States 7;

.8l and worldwide. The total capacity of these projects is in excess of 20,000 megawatts and includes every type of reactor

.1 design in commercial use in the U.S.

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Ebasco ,has been the constructor or construction manager

.4 l 5I at 17 nuclear units. We have served as constructor where I

( another company was architect / engineer (Ft. St. Vrain), and have taken over construction management where work was y started by others (Laguna Verde).

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Construction is carried out through an onsite organi-14l zation under the Ebasco Construction Manager, who reports to 5t 6l the Vice President, Construction at Ebasco's New York cor-17l porate headquarters. The duties of the New York Office IO l construction staff include the gathering and dissemination of construction experience from Ebasco and other plants.

This assures that the STP project will benefit from con-struction experience at other sites.

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'4 5 Q.7. Mr. Lex, please describe the Bechtel organization structure for performing its responsibilities for STP.

A.7. (BL): Bechtel began its activities relating to O! the assumption of architect-engineer and construction manage-1; 42 ment responsibilities for STP in October 1981. The objective 3

4 of these initial activities was to plan a comprehensive 5l 6l assessment of the status of the Project and the development 7li 8 of a program necessary to carry it to successful completion.

9 This transition program for Bechtel's assumption of its 22 1! responsibilities and Bechtel's organization for initiating 3! its implementation were generally described in the Transition 4l 5l Piogram Description (Applicants' Exh. 54). Our major current 6i 7l activities are associated with the transition tasks, and the 28 .

~9, task groups that began these activities continue to carry g' 0 2

out these assignments. Our organization has now evolved to the structure planned for continuation of the Project and 3

34 5i l most of the key positions have been filled.

6l Figure 1 attached to this testimony describes the 7l 8! current organization which is completing the transition and

!9l 40 l will carry the Project forward.

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! As can be seen from Figure 1, engineering and procure-ment functions are consolidated under the direction of an Assistant Project Manager. Within the engineering team, the W7 personnel under the overall direction of the Project Engineering 8

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I2 13 Manager are reorganized into three multi-disciplinary design 14 5 l67 teams, each headed by a Project Engineer and charged with the responsibility for defined portions of the engineering 0{ work. We are also adding a Project Resident Engineer at the 1!

l2{ 3 site, reporting to the Project Engineering Manager, to 4 provide coordination between the Design Office engineering isi I 6l team and the field organization. The procurement team, 7i 8l which is unchanged from the initial transition organization, 9'

is headed by the Project Procurement Manager.

0 l12 The construction management team, under the direction 3 of the Manager of Construction, remains essentially unchanged 4

l5 from the initial program, except for the elimination of the l 6I .

7l Construction Management Survey Te.am and of the Manager of 28 l the Fabrication Shop, neither of which are needed any longer.

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31 Administrative and cost / schedule functions are con-solidated under the direction of an Assistant Project Manager, 34 I who oversees the Project Cost / Schedule Manager, the Project S

I6 Administrative Services Manager and the Project Information 37 l Services Manager. A Project Administrative Manager and the 40 i Records Management System Manager will report to the Project Administrative Services Manager. The Project Information

43 Services Manager will direct the on-project data processing

'$ 46 services support group.

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5 Two new Project Management positions have been added, a (67 Project Licensing Manager who is responsible for overall direc-8 9

tion of Bechtel's support of the STP licensing activities, 0l and a Strategic Planning Manager who will direct programs 1!

2 for incorporating constructability considerations into the 3

4i final design and for long-range planning of construction I5 !

6l methods and sequences.

7i g; Q.8. Mr. Crnich, please describe the Ebasco organizational 9'i 0

structure for performing its responsibilities for STP.

1f A.8. (JC): The Ebasco Construction Manager, who reports 3i to the Ebasco Vice President, Construction, is responsible 4

5 for all Ebasco activities at STP, with the exception of the 6!

7! technical direction of the Quality Program. He is respon-

.a j 9i sible fo,r providing the leadership necessary to develop, 0'

g integrate, and maintain a dynamic and cohesive construction 2

3 team of experienced and qual.ified personnel. He provides an 4' onsite Ebasco executive presence, as he is authorized by 5l 6l Ebasco to act on its behalf in directing affairs at STP.

7l 8! The Site Manager reports directly to the Ebasco Construc-9!

Oi tion Manager. He is accountable for all the day-to-day i

1 2 I construction activities, including quality, cost, and schedule 3

4 of work. He directs and coordinates all onsite activities, including staff management and mobilization of field payroll 7 non-manual starf. As shown on attached Figure 2, key individuals 8l P9 !

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15 reporting to the Site Manager are the two Project Superin-i 6 7 tendents (Units 1 and 2), the Senior Resident Engineer and 0

the Construction Control Superintendent. Also reporting to 19 0 the site Manager are the Labor Relations Representative, 1l:

l23 Safety / Fire Prevention Representative, and the Administration 4 Manager. As noted in the testimony of Mr. Hawn, the Quality j5l Program Site Manager coordinates with the Site Manager to 6j 7!

gj assure communication and administrative continuity.

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The Project Superintendents are responsible for the 1!

2i completion of construction activities at their assigned 3 units. They adminis.ter the detailed execution of schedules 4

5l for the activities of construction manpower and equipment 6i 7j and plant systems completion, and have the authority and 28 .

9 responsibility for'their implementation. They are responsible 31 f r safe work practice, fire prevention activities, coordina-3 tion with the Construction Control Superintendent in the 34 i development of plans and schedules, and the review of work 5l 16 l progress, techniques and procedures being implemented.

37 The Senior Resident Engineer is responsible for the 40 field engineering review of drawings and specifications, for l preparation of construction procedures and other field 43 1 documents, for establishing and maintaining a control system for controlled documents used by Construction and for resolving 7 field engineering problems and recommending solutions to 8

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12 l34 Bechtel. He is also required to provide technical support 15 l07 to the Area Superintendents and to provide the technical 8

interface to the Bechtel engineering group. In addition, he 19 .

O provides field survey crews to support Construction.

l23 The Construction Control Superintendent is responsible 4! for providing to Bechtel quantity tracking and schedule 5l 6l related information and any required quantity / manpower 7i gj reports related to construction activities. This is done by 9lI O

Producing quantity reports, schedules, material tracking 1l reports, production and productivity reports, forecasts and 3l trend analyses and other studies or. analyses as required to 41 5!. support Bechtel's overall construction plan.

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7; Q.9. Mr. Goldberg, since the last time that you testified, 28 l -

have there been any changes in HL&P's organization?

59O i3 31 A.9. (JG): Yes. There has been a realignment of organization responsibilities within HL&P in order to 34 l consolidate the nuclear program engineering and construction i

l activities under my direction. This "dematrixing" took place during the fall of 1981.

40 i The current STP organization is shown in attached Figure 3. The previous organization was essentially divided 43 into two major sections. Houston based activities reported to the Manager, Houston Operations, and site-related activities 7 reported to the Site Manager. In our revised organization, 8

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4 5 the Manager, Engineering reports directly to the Project f6 L7 Manager. Another important activity which needed more 8

9 visibility on this Project is records management and infor-

{ mation processing. We have assigned a Manager to supervise 1 2 the staff and to develop a comprehensive records management 3

4i plan. These two changes are the major differences between 5

6 HL&P's Project organization of May 1981 and the Project 7i

,8 ! organization today.

9' Ol As a result of this reorganization and the addition of 1f more experienced personnel, we have been able to reduce the 3l total number of professional personnel. Since all personnel 41 .

5l are dedicated to one project, they can work free from interrup-6! .

7{ tions due to secondary home office responsibilities. This

'8 increased efficiency has been enhanced by the addition of a l9 (0i number of seasoned personnel in Engineering.

2 We will continue to upgrade our experience in the f4i j5 l coming months.

6l We have also established an Engineering Assurance 37 Department under my direction whose function will be to 18 9i 40 i oversee a selective independent review of the design and 1I 2 engineering effort on HL&P's nuclear projects.

43 4 Q.10. Please identify the major activities involved in 5 transferring responsibilities at STP from B&R to Bechtel and 7 Ebasco.

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[4 5 A.10. (JG): The Transition Program Description filed I6 L

7 with the NRC on December 11, 1981, generally describes the 8

activities involved in transferring responsibilities from F9 '

90 ! B&R to Bechtel as architect-engineer and construction manager.

(fl2!! These include the detailed reviews of engineering, construc-

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4j tion and procurement which will be discussed below by Mr. Lex.

5 6 In addition, he will describe Bechtel's preparation for the l assumption of its responsibilities as architect / engineer and 9 construction manager.

Ol; 1 ,i Ebasco has begun to develop the procedures and assemble 2!

3i the staff required for the discharge of its responsibilities 4l 5l as constructor. These are discussed below by Mr. Crnich.

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7{ The activities involved in preparing and implementing 8I 9; the revised QA program applicable to the STP are described 31 in the separate testimony to be presented by Messrs. Geiger, 2 Krisha and Hawn.

3 34 i Finally, I will describe the steps taken by HL&P to 5l 6l assure itself that appropriate measures are included in the 37 '

a! transition program to achieve an effective transfer of 9!

40 i responsibilities, that they are implemented properly, and 1'!

2 that design and construction activities will resume satis-43 k factorily.

5 Q.11. Mr. Lex, please describe the program for Bechtel's 146 7 assumption of responsibility as architect / engineer.

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5 A.11. (BL): As described in the Transition Program l l6 Description, Bechtel is performing a review of the total 7

I plant design. As a first step in performing this review, 9

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1 the design has been segregated into discrete groupings i 1!

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called " work packages" which can be effectively reviewed as 4i individual tasks. A work package is an assemblage of docu-5l ments which describes the design, scope and the extent of 6!

7-8l completion of the engineering. Each work package is evaluated 9

l to assess the status and adequacy of the design, including 1!

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its interfaces with other elements of the plant design.

3 Bechtel reviewed the basic STP documentation to deter-4 5 mine the general status o.f design and to identify the break-6!

7{ down into work packages. From this review approximately- 150 8

9, work packages were initially identified, as listed in the 0'I y Transition Program Description. These include discrete work 2

packaces covering systems, structures, and major components.

34 Taken together the work packages address the entire plant 156l l i

scope. The list of work packages has changed as the review 37 has progressed, since some of the packages have been com-la9.

40 l bined and several have been divided.

Each work package consists of the documents necessary 43 '

to described the defined work and includes, as appropriate:

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46 system design criteria, system c'2scription, piping and instrumentation diagrams, loop .aagrams, logic diagrams, j 49 , i 1

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1 12 l3 5 fl w diagrams, equipment specifications, equipment sizing calculations, vendor drawings, special calculations, isometric 58 drawings, etc. B&R is providing the foregoing data utilizing l9 0! a further subdivision of the work into distinct subpackages.

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2! System work packages are concerned with a single process 3I 4l system, a single structure, or several related structures.

.5 l gl Examples of system work packages include:

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Fuel handling building a9 { -

Plant security system 0:

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Condensate storage tank

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Essential cooling pond

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480 V auxiliaries power distribution l system J .

8 Auxiliary feedwater system i

Station heating, ventilation and air

  • Conditioning system Fire protection system 34 l -

Containment spray system i In addition to the system work packages, there are also 37 l the following work packages which address interdisciplinary 40 { matters that are involved with many different systems or structures:

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Systems interaction and integration Licensing document review 46 Line break criteria and analysis l

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Pressure transient analysis f6 L

7 ALARA and shielding criteria 8

9 Environmental qualification 0l 1 i Safe shutdown criteria

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Implementation of post-TMI concerns E3 ;

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Classification of equipment and a5l structures

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Incorporation of NRC bulletins and

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NRC unresolved (generic) safety issues lj -

Quadrex issues 2-3l -

Protection against natural phenomena 4 and external hazards.

'S 6! The process of review and evaluation varies according 7i e8 l to the nature of the work under review. Engineering evaluates 9

0 the design assumptions and methods of analysis; determines al 2 whether the design satisfies the applicable criteria and 3

e41 addresses the necessary technical requirements; reviews 5l design interfaces with vendor supplied equipment and design 6l 57 work of other disciplines; checks for proper reference to 8

9, computer output; assesses the adequacy of design verifi-0I l cation; reviews the design, drawings, and determines if

'3j specifications and drawings are up to date.

4 The result of review of each work package will be

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documented in a report to HL&P and Bechtel Management. The 8 report will present:

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5 (1) a brief summary of the work covered by the f6 package; 7

8 (2) current status of engineering, design, documen-l9 ,

g0 ', ta' tion and licensing including any applicable 10 CFR 31!

12 Section 50.55(e), 10 CFR Part 21, or Quadrex concerns; 3

4l (3) any recommendations for remedial actions; 5!

'6l (4) any unresolved items; 7i 8l (5) a summary of work to go, plan for transfer of 9

0 remaining work, .ind statement of work which may require 21 i other organizations' participation; 2!

3 (6) a list of related work packages; and 4

5 (7) any additional references, assumptions or 6!

7l special conditions.

8l The report for each work package will be prepared in 9!

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1 draft form, and Bechtel will solicit verification of facts 2

B3 presented in the draft from B&R, to the extent possible, and l4I HL&P. Comments generated in the review process will be re-Sl 6l solved and incorporated, as appropriate, into the final

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report.

'0l 4 Once HL&P accepts a final report, a set of reproducible quality work package documents, including the final report, 43 '

will be assembled for retention as Project records. Activi-46 ties or items of work to be performed, including any correc-h7 tive actions, unresolved issues, and other activities not l8 l 49 5 0ll 1l n I g -zu-i _ __- - - - - - -

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5 n rmally included in Project schedules or work plans,.will be identified as action items in the final report. Assignment 8

of responsibility for each action item will be made by 9

0l Bechtel Engineering and a Master Actions Items List will be 1!

.2 maintained for the Project.

3 4l The extent to which the Bechtel engineering work may 5l repeat previous B&R design effort will depend on the com-6l 7;

8l Pleteness and clarity of the B&R documentation. Where there 9

0l; is sufficient evidence of the completeness and adequacy of 1 ,i calculations, design verifications and other design activities 2!

3! performed by B&R, the previous work will be accepted. If 4

5 there are instances where that is not the case, specific 6l 7l aspects of the work will be identifibd for further eng.ineering 8) 9; action as part of the post-transition activities. In short, Bechtel Engineering will perform the design reviews necessary 2 to satisfy Bechtel of the adequacy of the work so that it 3

f4l can be relied upon for use in future design.

j5 i 6l Q.12. Please describe the program for Bechtel's assumption

7. '

3 of responsibility as construction manager.

fg l A.12. (BL): Bechtel's responsibility as construction L

2 manager for STP includes the following principal jobsite functions:

6 Overall direction of construction.

7 -

Overall construction planning.

8 9

0l 1l E

-u-l

1 2

3 4

5 overall construction cost control 6 program (Ebasco will be responsible 7 for timekeeping and quantity reporting).

8 -

Summary and intermediate level 9 scheduling (Ebasco is responsible 0l for detail, daily, weekly, monthly 1i scheduling).

.2 !

3 -

Area management, which includes 4 providing direction and control to

.5 ; Ebasco's area and discipline super-i intendents (craft supervision is the 6l 7 responsibility of Ebasco).

'O -

Field engineering, which includes 9l 0

providing technical direction to Ebasco's field engineers, resolving l:!

'2 !

specific design problems through interface with Bechtel Project 3!

,4 I Engineering and approving the work plans and procedures of Ebasco and

'5{ other contractors.

6l

7 { -

Purchasing of all field procured permanent plant material and approval of Ebasco's purchase orders for j non-permanent materials and supplies.

Site document control (Ebasco will be responsible for control and distribution outside the Document Control Center).

Contract administration, which l7 ' includes formulating and administer-3 ing all jobsite contracts.

9l g) -

Safety / construction fire protection, t

I which includes monitoring the safety /

3 fire protection programs in order to

} ensure that contractual obligations are fulfilled.

3 5 -

Training, which includes the overall L6 direction of the jobsite training 7 and detailed training of Bechtel 8 personnel.

L9 01 1l ,

-as-

1 I

"l!

~

2 3

'4 5

Receiving and warehousing of permanent 76 plant material (Ebasco will provide L7 the labor for receiving and warehousing).

0 y9 Bechtel's principal construction management activity 90 ! during the transition has been to conduct a series of evalua-12f1ij tions to determine the status of construction. Emphasis has 3

4 been placed upon quality-related aspects of the work, with rL5 l 6l cost and schedule also being considered.

7i  !

g i The construction management transition activities ,

9 ' '

i consist of work in nine major areas: -

O; .- e

,s 1l. -

Management of the site maintenance s 2 and caretaking  !

3 3 ,2 4 -

Statusing of the exis' ting construction <

5 '

l -

Statusing of all material on the '

l jobsite I28 l 9

Evaluation of construction' facilities .

l31 Review of existing subc'entracts.

Development and implenentation of the site safety and tire protection (34 l programs SI _

I6 l -

Development of general construction (37 procedures ,

s l -

Development of training prog ars l40 l 4 -

Initiation of construction. planning j  ; _

43 { Reports of findings and recommendations are being ,

provided as individual tasks are completed. Results of l46 these activities will be used in planning future activities.

7 8 Q.13. Please describe the program for Bechtel's assump-  % ,

j9 ., .-

0l tion of responsibility for managing procurement activities.

1l , w >

, s l  !

f ' '

, l x__ .

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~

l - - - - - - - - - - - - - - - - - - - - - - - - - -

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1f' I2 i l3l 14 5 ' A.13. (BL): During the transition, Bechtel Procurement j6 is reviewing the status of purchased items to determine 7,3 8! their conformance to the procurement document requirements.

l91 0l (Engineering is concurrently reviewing the procurement 1i 2j requirements to determine their adequacy). Primary emphasis f is on the qualifications of the suppliers to meet the require-A5 l 6j ments of the Project, and on assuring that the documentation 7i jg ] provided meets the applicable Project requirements. In 9

0l ;

addition, Bechtel Procurement is statusing items delivered 6 1I to the jobsite, still in fabrication, and yet to be ordered.

'2 3l Particular attention is being given to the safety-related

. .4 l 5l Xcomponents to verify that the required inspections and tests 6

,1 y are being completed in accordance with approved procedures.

'8 9

. Procurement work packages are assembled from B&R docu-O

ments and reviewed by the appropriate sections of Bechtel Procurement. These reviews are coordinated with Bechtel 34l Engineering.

5i < ..

'6 l . A report covering all Procurement input on purchase 37' ,

3! orders associated with each work package will be included in 9!

40j the Engineering Report for the work package. The Procurement I

1' input tA~these Reports will contain the results of the 2

43 Procurement review and any recommended changes and/or correc-tive actions.

16 g7 38 49 VI l' l '

t s

-m-

\

I l l l2i1!

l3 5 All future Design Office procurement functions associated 6

with the Project will be managed by the Project Procurement 8

Manager, who reports to the Project Manager for operational 9

0i direction and to the Division Procurement Manager for func-11!

12 I tional direction. These functions include purchasing, 134 expediting and supplier surveillance. In addition to managing 15 6 all Design Office procurement activities, the Project Procure-gf ment Manager is responsible for the coordination of interrelated 9

0; activities of the Field Procure. ment group, which receives 1i operational direction from the Project Manager of Construction.

2:

3l The Contracts / Purchases staff on the Project will 4

5 develop and administer all Design Office initiated purchace 6l 7i contracts issued for permanent plant material and equipment.

8l The Project Expediting group will assure that goods con-9 0'

tracted for are delivered to the jobsite to support the construction schedule. Bechtel's Procurement Supplier 4 Quality (PSQ) Department will perform surveillance and 5

.6 audits of suppliers to provide an added degree of confidence that purchased items comply with the requirements contained 40 i in the contract documents. Further discussion of the PSQ Program is provided in Mr. Krisha's testimony.

43 Q.14. Please describe other major activities being i

conducted by Bechtel in assuming its responsibilities for 46 STP. I 178 I 49  !

E0 1lll E __

u-

1 L i .

1!

~2!

! 3I "4

~5 A.14. (BL): In addition to QA, engineering, construction management and procurement activities, other Bechtel activi-8 l 9 l, ties involve Project administration and cost / schedule. ,

0l Principal transition activities in Project adminis-1!

<2 tration include preparation for assumption of Bechtel's 3

4i responsibilities with respect to document control and records 5'

6i management. Project administration is also coordinating the 8 development of the Bechtel Project procedures. This involves organizing and integrating standard Bechtel practices into a l'41i specific Project program that incorporates the commitments 2.

l3 and relationships of Bechtel to HL&P, Ebasco, Westinghouse l41!

5l and other contractors.

6' In cost / scheduling, systems are being prepared to 7l 9 control Project cost and schedule. Material control ledgers l.01Il are being prepared for tracking current and future status.

Development of Project cost and schedule estimates is also i4l underway leading to an updated Project forecast in July 1982.

5i 6! Q.15. Please describe how controls, standards and procedures I37 l developed through Bechtel's previous nuclear experience are l40 { being utilized in planning and performing its work at STP.

A.15. (BL): Bechtel will carry out the work using our (43 proven practices developed as a result of the experience l46 gained by participation in 91 major nuclear projects.

7 a

149 !

0l t

1l !

1

-a-l - _ - - - - - - - - - -

l 1

2I 3I

[4 5 These practices include technical controls such as:

E6 L -

Complete control of the design by 7

g the Project Engineering team, including review and approval of proposed 9 *

  • changes by construction or suppliers.

O!

'l ! -

Design control and verification

[L2 l practices, which have been proven on

'3l4 a number of current nuclear projects.

l5 -

Independent Project QA reporting to

'6l Bechtel management above the Project 7; management. ,

8' I i -

Independent supplier source surveil-g!

0 lance inspection by the Bechtel Project Supplier Quality Department.

i 1 :l 2! -

Independent construction site QA and 3I QC functions reporting to Bechtel

- 4l Management above both site and Project l5l6l management.

7l -

Construction management practices

  • 8l Proven on a number of domestic and .

9! overseas projects.

lO'!

y Future engineering will utilize, as appropriate, the Bechtel Engineering Standards. These are a set of engineer-3 134! ing rules, principles, criteria, standards, drawings and 15 6li specifications developed for each engineering discipline.

l37 '

These standards help to bring Bechtel's extensive nuclear l40l and general engineering experience to bear in the engi-neering of each project.

143 i Bechtel will also utilize its Engineering Department Procedures as modified for Project unique requirements.

7 These procedures define the requirements to ensure uniform 8

l9 0

1l l

I y -a- 1

L 1

~2:

L3l 4!

5 methods of conducting work activities of the Engineering F

Department, explain the relationships and responsibilities necessary to accomplish work activities, etc.

{

g0 l Similarly, through its years of experience in the Eli 12 construction and construction management of nuclear projects, 3

4i Bechtel has developed procedures and instructions to control 5l 6l work in the field. These are being employed in the develop-7

8. ment of the specific procedures that will be used at STP.

,9 :

0j Q.16. Please provide an estimate of the expected Bechtel l'l,i 2:

staffing levels for STP and describe the experience (including 3l nuclear) of assigned Bechtel personnel, 4l j 5[ A.16. (BL): Apart from the staffing of Bechtel's QA 6l 7l functions, which will be discussed by Mr. Krisha, our prelimi-l98 9, l nary estimate is that Bechtel staffing levels will be approxi-l0 mately 500 professionals in Engineering, 400 professionals 2

in Construction Management and 150 professionals on the 4j balance of the Project team.

5l 6! The senior Bechtel line management personnel assigned l37 l to the STP have extensive power plant engineering and con-l40l struction experience, much of which is in nuclear projects.

I report to Mr. D. W. Halligan who is a Vice President l43 i of Bechtel and Project Executive Director for the South 5 Texas Project. Mr. Halligan has 28 years of engineering l46 178 49 0l 1l l l

l -m-

{ . _ _ _ _ _ _ .

1f 2!

3!

4 c 5 experience, including 20 years on nuclear projects. His L6 assignments with Bechtel have included positions on a number 7 8l of nuclear power projects, such as Project Engineer for the i9!

Ol Palisades Nuclear Project and Project Manager for the Fast R1!

12 Plux Test Facility. Most recently he served as Deputy 3

4i Division Manager of the Bechtel San Francisco Power Division, 115 i 6l in which position he had a leadership role in planning 7l; 8 Bechtel's assumption of construction management responsibility 9l 0;

for the WPPSS Units 1, 2 & 4. Mr. Halligan received a 1 Bachelor of Science degree in Civil Engineering at Oregon 2l

,3 l State University and a Master's degree from Stanford University.

4l 9l He is a Registered Professional Engineer in the states of 6!

California, Washington, Maryland, Minnesota, Massachusetts

}7{

! and New York. .

lO7 The Assistant Project Manager-Engineering and Procure-2 ment is Mr. E. A. Rumbaugh. Of Mr. Rumbaugh's 25 years of I3 l4 engineering experience with Bechtel over 20 have been in the 6l nuclear area. This has included positions as Project Engineer on the Palisades Plant, the Pilgrim Nuclear Power Station, Oi and the Quanicassee Nuclear Plant. He has served as Chief I

1 2l Mechanical Engineer and Engineering Manager in Bechtel's Ann f 43 } Arbor office and comes to the STP from the position of 5 Manager of Division Engineering in Bechtel's Ann Arbor Power f46 .

7 Division. He holds a Bachelor of Science in Mechanical 8 z l49 e 5

101ll l i I i f , 1 -

I

)  !

2 l3 i Engineering degree from the University of California at f5 l6 Berkley and is a Registered Professional Engineer in the 8 states of Iowa, California, New York and Michigan.

l9 The Project Engineering Manager is R. L. Rogers who has 10 1i !

l12 j 17 years of nuclear engineering experience, including 6 years 3i 4! in the nuclear navy. Prior to assuming his responsibilities l5l6l at the STP, Mr. Rogers was Project Engineer for Bechtel on the San Onofre Nuclear Generating Station, Units 2 & 3. His 9 previous experience with Bechtel has included engineering 0l ;

1I assignments on the Rancho Seco Unit 1, the Vogtle Nuclear 72 l 3l Plant, and San Onofre Unit 1. He is a graduate of the 44 5 University of Kansas with a Bachelor of Science degree in 6

7l Mechanical Engineering and received training at the United - -

States Navy Advanced Nuclear Power School, Nuclear Power

Training Unit, and Submarine School. He is a Registered Professional Engineer in the state of California.

4j The Manager of Construction, B. R. McCullough, has Si l 25 years experience with Bechtel, 10 of which have been in 37 l the nuclear field. His experience included serving as Field 40 l Construction Manager on the San Onofre Nuclear Generating Station, Units 2 & 3, and most recently as Manager of Con-43 i struction of Nuclear Facilities for Bechtel's Los Angeles Power Div'ision, where he had responsibility for the construc-46 tion of San Onofre Units 1, 2&3, and the Palo Verde Nuclear 49 1I

? 5

1 2l 3!

4I 5 Generating Station, Units 1, 2&3. He has a Bachelor of 6.

Arts degree in Industrial Engineering.

7{

8

{g The Project Procurement Manager, Bryce F. Robertson, O

has approximately 12 years experience in Bechtel Procure-

,.2l ment. His assignments have included work as Architectural

.3 :

,4 i Supplier Quality Representative / Expeditor, Supervisor of

,.5 l

'6l

, Inspection and Expediting for Bechtel Pacific's Melbourne

,7 1.8 l Office, Procurement Supplier Quality Supervisor for all i

,9 0j Bechtel non-power divisions, and Procurement Supplier Quality l Representative for Field Services for Bechtel in San Francisco.

3! Most recently he served 2-1/2 years as Manager of the Procure-54 l 55 I ment Supplier Quality Department in Bechtel's Los Angeles Sl 7! Power Division.

8l 9!

As of the first week of February, approximately 422 ,

O'I y professional Bechtel personnel (outside of QA) had been assigned to STP. Their total professional experience is 3

4 5497 man-years (an average of 13 years per person), in-F6 cluding a total of 2306 man-years of nuclear experience (an 37 8 average of 5-1/2 years per person).

[9 5

'0l 8 It is expected that over 70 percent of the foregoing personnel will remain with the Project after transition 63 i 4 activities are completed, and that the experience of Bechtel personnel subsequently assigned to the Project will be l7 comparable.

l8 49 l 0l 1l ,

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}3I 5 Q.17. Mr. Crnich, please describe Ebasco's responsibilities l6 as constructor.

8i A.17. (JC): Ebasco will supply all labor and supervi-l9l g0! sion to complete the Project through to commercial operations, 31!

12 including the following activities:

3 4'! -

Secure ASME certificates.

l ct l6 I -

Establish an approved quality program 7- which will satisfy the Project QA commit-8 ments, including a QC inspection program i for safety related work and a construc-9 0;

i tion inspection program for non-safety related work.

1I 2' -

Develop and use work plan procedures and 3i quality inspection procedures which will

.4 I be approved by Bechtel and also develop l procedures for selected complex non-safety sl related work operations.

i -

7 Implement and support Bechtel's Project 8l control programs including cost, schedule t

, and material control.

1 -

Conduct jobsite training for Ebasco's scope of work.

4l I

- Purchase, receive and warehouse non-permanent plant material and supplies.

I 37 -

Implement and control a Project safety Rl;j and fire protection program and manage and operate the site emergency medical 40 i facility.

Provide a field engiheering program with 43 l sufficient engineers to support the field activities.

Perform housekeeping and preventive main-46 tenance activities, including operation of temporary construction facilities, 17 8l janitorial service, maintenance of installed 49 l 10 1lI

-u-

i l

I2 l3 equipment / vehicles and equipment maintenance, building maintenance, and also provide l6 craft personnel to perform warehouse functions under Bechtel's supervision.

178i 9{ Q.18. Please describe how procedures developed through -

0l '

1! Ebasco's previous nuclear experience are being utilized in 12 i 3! planning and performing its work at STP.

4!

A.18. (JC): Like Bechtel, Ebasco is using procedures l15 l which have been developed through many years of experience 8

in construction of nuclear power plants.

l9l 0; i

These construction and QC procedures have proven to be successful at these 1i 2! other nuclear plants. They include procedures for performing 3l 4 and for inspecting both safety-related and non-safety related 5

6t work, and they clearly define the respective responsibilities i

ly8f of both the construction and QC personnel. The types of , ,

nstruction procedures to be used include Administrative O

1 Site Procedures, which establish site organizational respon-2 3 sibilities, methods of operation at the site, and document 4!

5 control; Construction Site Procedures, which detail require-6 7 ments for specific construction processes; Construction l Maintenance Instructions, which detail requirements for 40 l maintenance and safeguarding equipment which is under the yj (2 control of Ebasco; and Inspection Procedures which establish responsibilities and methods of operation to assure that l46 g7 38

!49 Wl  !

E I

_;^_

E l

I l

E2llll l34 5l nsite non-safety-related activities have been satisfactorily 6

accomplished. The QA/QC procedures are discussed in Mr. Hawn's 8I testimony.

9l 0! Q.19. Please provide an estimate of the expected Ebasco l

11!

12 staffing levels for STP and describe the experience (including 3

4i nuclear) of Ebasco personnel that will be employed at STP.

5l 6

i A.19. (JC): From the current level of approximately 50, 7-8 !,

Ebasco expects to reach a peak level of over 250 professional, 9

supervisory and administrative personnel. The current staff 1l 2-will be steadily increased over the next eighteen (18) 3i months to reach this peak. The key personnel currently on 4

5 site are senior personnel with many years of construction 6!

7i experience, much of it being nuclear on multiple plants.

8l' '

durSiteManagerisMr.J.A. Thompson. Mr. Thompson 9i 0i 7 has 27 years of construction experience, including 14 years at nuclear projects, such as Millstone Unit 3, Nine Mile 4I Point, River Bend, and St. Lucie Units 1 and 2. He left St.

5l 6! Lucie in 1981 to join B&R as STP Deputy Project Manager.

37 '

The Project Superintendent for STP Unit 1 is Eugene K.

40 i Ferguson, who has over 30 years of construction experience, the majority of which is in the area of nuclear and fossil fueled power plants. He has been employed by Ebasco for the

,46 l past 5 years, including assignments as Deputy Site Manager 1

I 178 49 ,

l80 l

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1 2

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5 f r Allens Creek. His prior positions with other architect-engineers and constructors included construction positions at Seabrook and Three Mile Island. Mr. Ferguson is a graduate 0I of the U.S. Merchant Marine Academy, where he studied marine 1i 2l engineering.

3l The Project Superintendent for STP Unit 2 is Kenneth H.

4i 5i 6j Flanagan, who has over 35 years of construction experience, 7l; 8

the majority of which is also in the area of nuclear and 9

fossil fueled power plants. His assignments at Ebasco 1 ,I during the past 13 years have included senior construction 2

3 positions at Waterford Unit 3,and St. Lucie Units 1 and 2.

I 5 His experience at other architect-engineers and constructors 6l -

7; included duties on the Manhattan Project and at Turkey 8l 9! Point.

i lO7 The Senior Resident Engineer is Robert M. Bedford, who 2

3 has over 10 years of power plant construction experience.

4l 5i He has been employed for the past 4 years by Ebasco, where 6l his most recent assignment was Senior Resident Engineer for l37 j Allens Creek. His duties at other architect-engineers and l40 j constructors included construction positions at Seabrook and Three Mile Island. Mr. Bedford has a B.S.C.E. from Purdue l43 I University, is a registered Professional Engineer in Kentucky, E New Hampshire and Pennsylvania, and is a Surveyor in Pennsylvania.

b7 8t 49 !

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1ll 2'

L3 4

5 The buildup of personnel over the next 18 months will 6

utilize primarily experienced personnel coming off the 8! St. Lucie Unit 2 and Waterford Unit 3 nuclear projects which (9 !

0l are nearing construction completion.  !

1!

{

12 l Q.20. Mr. Goldberg, what steps were taken by HL&P to '

3; 4; assure itself that appropriate measures were included in the 5i 6l transition program and that the program was implemented gl satisfactorily?

9 0l A.20. (JG): HL&P reviewed and approved the transition 1 program (which is summarized in Applicants' Exh. 54) to 2

1341 j assure that it encompassed appropriately all of the major areas of the Project, including engineering, construction, 6'

157i l QA, procurement and Project control. This review process 28 l involved numerous meetings between senior HL&P personnel and 9;

0I Bechtel. Preliminary work plans and transition schedules 2 '

3 were reviewed in depth. The " work package" concept was 4l 5i evaluated and refined to incorporate HL&P's recommendations.

6l Methods for the transfer of engineering data were recommended 7l 3, by HL&P and incorporated into the transition program. HL&P I

9 80l personnel also reviewed the transition procedures utilized by Bechtel, and modifications were made as necessary to I3 reflect Project-specific technical and QA requirements, as 5 well as HL&P's preferences. '

66 7

18 49 0

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L 1

2l L3 I 4

5 HL&P's Project principals in the major areas and their staffs c'oordinate transition meetings on specific topics 8

between B&R and Bechtel to assure that Bechtel gains a c9 -

0; thorough understanding of activities conducted by B&R. In 1!

,2 addition, regular engineering discipline interface meetings 3

4l between HL&P, B&R and Bechtel are held to assure that informa-t5!

tion is appropriately transmitted, received and understood.

6l

,gf HL&P management also conducts weekly meetings to monitor the 9

status of the transition program and review progress.

Ol; P1 i With respect to Bechtel's review of the status of 2!

3l engineering, in addition to coordinating and expediting the v4 5 transfer of information from B&R, HL&P's engineering per-6!

,7{ sonnel review selected-work package information as it is 8

9 transmitted by B&R. HL&P also provides technical background

{0 information to Bechtel and helps answer questions that arise 2 during the review. When Bechtel completes its review of the 3

4i work packages covering the systems, structures and compo-5l 6l nents that comprise the Project, HL&P will review and evaluate b7 '

Bechtel's recommendations. Similarly, in other areas, such la9 ! I as construction and procurement, HL&P personnel are monitoring

!40 l the progress of Bechtel's transition efforts and assisting l43 i in their effective implementation.

14 5 46 7

8 69 0l 1l 1 l .

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as-

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l 1

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5 Q.21. Panel, what are the functional relationships among 6

7 HL&P, Bechtel and Ebasco in the management and performance 8i of the design and construction of STP?

9I O! A.21. (JG, BL, JC): The scopes of responsibilities of 1i 12 j Bechtel and Ebasco described in our testimony above are 3!

4l clearly defined, and formal lines of communication have been 15 ! l 6{ designated to assure appropriate control and coordination of l f the effort.

9l 0; Overall Project direction is provided by HL&P to Bechtel's 1i Project Manager. The HL&P Project organizations, including 2

3! Engineering and Site Management, provide a performance over-41 -

5l view of the corresponding Bechtel Project organizations, and 6! -

7{ have formal interfaces,at the Manager level. For example, 8{ the engineering interface is through the HL&P Manager, 9! ,

O Engineering and the Bechtel Project Engineering Manager.

2 3,l There is, of course, regular and routine communication among 4 personnel at other engineering levels.

5l i 6! '

As construction manager, Bechtel directs the activities 7

of Ebasco and performs a QA overview of Ebasco's activities.

)3 9

40 l Except for QA, the construction interface is provided by 1 I 2l Bechtel's Manager of Construction and Ebasco's Construction 43 l Manager. This interface includes the transmittal of design 45 46 documents to Ebasco through Bechtel Construction Management.

7 There are also formal interfaces between key personnel in 8

49 ,

Ol 1l n I y -3b-I - _ - - - -

I 1

2

!3

?5 the Bechtel and Ebasco construction organizations below the Manager of Construction and Construction Manager level. For

"*"* ' ""9 "" "9 " " "9 f9 Ebasco Senior Resident Engineer and the Bechtel Project 101: l l12 Field Engineer. In addition, there is a regular and routine 3

4l communication among Bechtel and Ebasco personnel at various 5l levels.

l l The relationship among the QA organizations of HL&P,  ;

Bechtel.and Ebasco is addressed in the testimony of I'1 ! Messrs. Geiger, Krisha and Hawn.

'2 3! Q.22. In its May 23, 1980 response to a Notice of Vio- -

4l l lation issued by the NRC, HL&P pointed out that its studies

{ of the underlying causes of then-existing concerns had identified the need for improvement in the following six l basic areas:

W (1) translating specifications and job require-l34 i t

ments into clear, simple procedures;

! (2) documenting nonconforming conditions and l trending them to identify Project weaknesses;

$7 !

! (3) training and indoctrination of personnel

{ at all levels regarding the quality program with

$0 l special emphasis on the Project goals of reliability j and safety; 3' (4) system controls to assure that quality related activities are initiated, controlled and properly documented; p6 173

$9 i

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-n-i ---------- -

l 1,

2l 3l 4I 5 (5) verifying through an effective audit l 6 system adherence to procedures; and

.7 8

(6) visibility of, and participation by, upper management in QA activities.

9 0, Witnesses for Applicants have previously described in l 1i i 12 j this proceeding how these improvements have been implemented 3li 4 for STP. Please describe briefly how present and future 5l 6j activities at STP of HL&P, Bechtel and Ebasco address those I

six areas.

9 A.22. (JG, BL, JC):

0;l In planning for the resumption of l 1l construction of STP, Bechtel and Ebasco will be relying on 2! .

3l practices that have been employed successfully at other l4!

l 5l nuclear projects. These practices have effectively addressed 6!

7l the six requirements that are reflected above.

8 9 Translating specifications and job requirements into clear, simple procedures 0l l1 The construction procedures for STP will be drawn from 2

3 procedures that have been successfully used on other Bechtel l41 5I and Ebasco nuclear projects, modified to the extent necessary

, 6l 13 7 to accommodate specific STP requirements and organizational 13 9 interfaces.

l40 Documenting nonconforming conditions and gt 't g2 trending them to identify Project weaknesses 43 The documentation of nonconformances and trending are 5

QA functions and are addressed in the testimony of

%6 "7 Messrs. Geiger, Krisha and Hawn. As with construction 8l 99 !

Oi .

1l .

m I ._

w-g

\ _ - - - - _ - - - - - - - - - - -

i L

1 1l 2i 3

b4 5 Procedures, the procedures utilized by the QA organizations 6

have been successfully implemented on other Bechtel and Ebasco projects. The trending reports produced by the QA 9

organizations will be sent to each of us and to other members h;!

di of the senior management of HL&P, Bechtel and Ebasco.

! Training and indoctrination of personnel 5j regarding the quality program 0

HL&P, Bechtel and Ebasco each has a program for train-D8 j ing and indoctrination of personnel at all levels of the r 9, OI Project regarding the quality program. HL&P has recently 1i

! created a new training group in its corporate QA organiza-I 4 tion to give further emphasis to quality program training i

and indoctrination. Both Bechtel and Ebasco utilize company i

wide standard training programs which include emphasis on j the unique requirements applicable for nuclear work. As with the procedures, these training programs have been proven effective on other nuclear projects. Perhaps more important than these formal training programs is the selec-l7' 3 tion of qualified supervisory and management personnel. Key personnel on any project greatly affect the degree of personnel

'0i 4

awareness and respect for the quality program. As discussed

\

gj above, both Bechtel and Ebasco are filling these key posi-tions at STP with experienced personnel who have performed

$6 well on other nuclear projects.

I

$9 l l

a l l

l L

1 I' 2l 3I l (4

5 System controls to assure that quality related activities are initiated, controlled and properly documented

[67 The system controls incorporated in the procedures ,

9! utilized by Bechtel and Ebasco have been proven through l 0l li successful implementation on their other nuclear projects.

f2l 3l These procedures are reviewed and audited by the HL&P, 4i p5l Bechtel and Ebasco Project QA organizations to verify that 6!

7 the necessary controls are included.

l0l! i Verifying through an effective audit system adherence to procedures 0

21 i As described in detail in the testimony of Messrs. Geiger, l 2!

,4i 3l Krisha and Hawn, comprehensive audit programs will be imple-i j

i I 5l mented by all three companies. In addition to planned 6l 7; scheduled audits, when indicated by trend analyses or other 1 8l 9i conditions, supplemental audits will be performed. HL&P i

lOl7 also has adopted a policy of having an annual audit of the 2

Project QA program performed by an independent organization.

l34l 5i The findings of the audit programs will be reflected in 16 l periodic reports to us and the other members of Project 18 7 '

management, and we will each utilize that information to

!40 l identify aspects of the Project in need of management attention.

l43 14 5 36 7

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12 l3I I45 Visibility of, and participation by, upper management in QA Activities 6

Senior management of HL&P, Bechtel and Ebasco are kept l9 , informed of the status of the Project QA program through 0l 1 personal briefings and various written reports, including l 2 ;l 3; the trending reports and reports of audit findings. In 4i l 5j addition, there are periodic inter-company and internal 61 meetings to review Project status, including the status of 7l 8

l9 i the quality program. For example, there is a regularly ilI 0l scheduled monthly Project review meeting which is attended l 2l by senior management, including Mr. Oprea, Mr. Goldberg, Mr.

3 4 Halligan, Mr. Lex and key members of their staffs. Issues l5 6l related to the quality program are frequently discussed at l7l gj such meetings. Other meetings are held frequently. Within 91 0l Bechtel there is a monthly quality meeting chaired by the 3

Project QA Manager that is attended by Mr. Halligan and by 83 Mr. Lex and the key members of his Project team. Within 34 1 5I Ebasco there are periodic Project status review meetings 6l 37 held at the Ebasco headquarters in New York and attended by

! Ebasco executives, including Senior Vice Presidents and, at 40 !

1 I times, the President of Ebasco.

l4 Senior officials within our companies responsible for this Project are t,aking an active role in the Project.

l46 7

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2i l 3I I We are determined to have the Project succeed and management 6

is keenly aware that this hinges on the success of the ~

8i qua]ity program.

. That determination is manifested in manage-9I 0l ment's activities, and we believe, is receiving appropriate 81! visibility on the Project.

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